200 



resource priorities of the Act, and in general l:erp to the Ovjricil's Plan. 

 Thus, any tiered rate structure which BPA used which has the effect of 

 ificucing ccstorners to do acquisitions inust be designed tc cor.tinu*- RPA's 

 goals in resource developirent . Under this goal alternative, EFA couldn't 

 say, "Sorry, it's up to the custoirers now." Bonneville would have tf« 

 responsibility tc design rates which iradfc sure that acquisitions veie still 

 best for the region as stated in the Act. 



This issue is not rroct. Sorrie utilities have cirguec, fi;r exanpiie, that 

 existing laws, i^eri.iittinc and siting regulations siread>' adeqi.fitcly prevent 

 the acquisition of non-con.forrdng i to the Flcin) resources. Thus, they say, 

 there is no need for the FSC tc say anything ncro than "everyone ir-iist obey 

 all lav/s and regulations." They fec-i it would only add rcre red tape to 

 the already arduous process. NCAC begs to differ. 



Ke can state nuirerous instances where current regulations and laws 



would net prevent such acquisitions. Nevada, for instance, has alirost no 



siting requirements. Coal plants could easily be built there by or for NW 



utilities. Idaho and Washington havfr no needs standard. In wa.shington 



non-ccnfortT.inc generating resources under 250 aM» can be buiJt without 



nuch problem, including hydro projec ts in the Council " s protected areas . 



Large utilities are required by Federal law to have least -cost [)lans, 



but even those plans do not have to t-e openly arrived at, include any 



externalities or the lOVS conservation advantage. Thus it is iirperative, if 



BPA adopts the "Regional Goals" alternative, that protections be in the 



contract.'i. We list r:onie [Xjssiblities vjhich should be invest icoted. 



CC£TOI';ER ACtt'lSITlCh'S Require froir, utilities, :n addition to having an 



openly arrived at Least-cost Flan (IC1-), that: 



a) this LCP be in cot;pliance with the Council's; plan and be 

 approved by the Council, 



