203 



5) All customers should have the opportunity to bid to provide BPA's 

 reserve requireinents. 



6) Service to the DSIs from the hydro system must be much more 

 interruptible to allow operation of the dams for the benefit of fish. 



RATE DESIGN ISSUES 



Certain rate design options should be analyzed for their iit^jacts on 



salmon. While tiered rates should encourage conservation in general, sore 



other specific measures could benefit the fish with or vdthout the 



inplementation of tiered rates. 



1) Eliminate, or restructure the irrigation discount so that irrigators 

 see the full price ramifications of taking water from the river at certain 

 times of the year. [See NCAC's rate case testiiiony.] 



2) Restructure the Low Density Discount on a per-customer basis to 

 encourage coiservation. [See NCAC's rate case testimony.] 



3) All rates should include water availability adjustments tc reflect the 

 value to the fish of water used for power generation. ITiis adjustmait (for 

 wet or dry years, high or low snowpack) could be superinposed on fixed 

 seasonal adjustments. 



4) BPA should examine the alternative of offering contracts at a favorable 

 rate to any taker who is willing to be fully interruptible in the fail and 

 winter. 



5) Eecause of BPA's equitable treatment obligation [Sec. 4(h)(ll) (A)(i)l, 

 EPA should exanine apportioning the FBS to the anadromous fishery, apart 

 from and prior to any contracts or sales are entered into; or, issue a 

 "fish contract" to the fisheries agencies and tribes. KCAC fully supports 

 the option put forward by American Rivers in their scoping comments, so we 

 will not repeat those here. 



6) The costs and benefits to the region for FELCC shifting should be 

 reevaluated. 



7) BFA should have the right to run its our. conservation programs for lOU 

 customers served by the Exchange. It is in BPA's financial interest to 

 conserve cost-effective Exchcinge energy, but because the benefit."; of the 

 Exchange are sinply passed through to the retail lOU customers, much 

 conservation is not being done for this customer class. 



Respectfully submitted. 



Steven Weiss, for the 



Northv)est Conservation Act Coalition 



cccDon Wolfe 



