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DeFazio Hearing 

 Emerald PUD, page 7 

 September 25, 1993 



the implementation of a formula that would fix the initial amount of the 

 residential exchange that could vary based on the differential of average lOU 

 and public retail rates. 



VI. Utilities should have the option of relying on Bonneville or themselves for load 

 growth services. 



VII. Priority firm customers should have the right to assign their first tier allocations. 

 This creates a market for conservation transfers. We should consider a queue 

 for offering first tier allocations exclusively in the Northwest to publics, then 

 lOUs or DSIs; and whether they should be offered to out-of-region publics and 

 out-of-region lOUs. This right should include the potential for power pooling, 

 where the pool would retain all of the efficiency gains that it would create from 

 pooling. 



IIX. Conservation prograuns should be offered to those utilities relying on Bonneville 

 for load growth services. Emerald is intrigued by the notion of Bonneville 

 regioncUly acquiring all cost-effective conservation, paying the participating 

 utility's costs plus a premium, where all cost and revenues for the conservation 

 would stay in the first tier, and Bonneville could resell the developed 

 conservation savings in the second tier. 



IX. Utilities that wish to develop resources other than conservation (and maybe 

 renewables) should be required to do a leasl-cost plan. It is hard for public 

 utilities to argue that they should not be required to do a least-cost plan, given 

 nearly all of the region's lOUs are required to do a least-cost plan by state utility 

 commissions, and that by law all Western Area Power Administration customers 

 are required to do a least-cost plan. Without a least-cost plan we would 

 question the basis by which resource acquisition decisions are made. 



Least-cost pleinning "guidelines" should be developed by Bonneville and the 

 Council, in a collaborative public process. The guidelines would be the 

 evaluation criteria for an "acceptable" least-cost plan. Specific guidelines 

 should ensure at a minimum that plans are consistent with the Council's 

 planning process, meaningful public involvement, i.e., a Citizen's Advisory 

 Committee, integrated resource planning, i.e., all resources included and on a 

 "level playing field," full cost accounting of all costs including all environmental 

 externalities. Environmental externalities should include at least a 1 percent 

 conservation adder as provided in the Northwest Power Act, compliance with 

 Council's Fish & Wildlife Plan, and appropriate environmental adders such as 

 the Oregon Public Utility Commission's methodology or Bonneville's adders, 

 explicitly including COg. 



