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Bonneville should begin the process now of analyzing the fiscal 

 and environmental impacts of such a decision. These types of 

 studies take time; if the draft environmental impact statement 

 (EIS) on the contracts is to be finished by 1994, as Bonneville 

 plans, the studies ought to be begun promptly. 



The interruptibility analyses are important because we believe 

 that Bonneville has considerable legal discretion regarding the 

 terms and conditions of future DSI contracts. 



The DSIs are treated differently under the Northwest Power Act 

 than utilities. Section 5(b)(1) requires the Administrator to 

 offer long-term contracts to public entities and investor-owned 

 utilities "whenever requested" by those utilities. 



Section 5(d)(1)(A), in contrast, states that the Administrator 

 "is authorized" to offer contracts to the DSIs. 



Section 5(d)(1)(B) requires the Administrator to offer initial 

 long-term agreement, but the Act is silent about subsequent 

 contracts . 



Nor do the existing contracts with the DSIs require Bonneville to 

 offer subsequent long-term agreements for firm power. 



Section 12 (mid-term review) appears to contemplate some sort of 

 ongoing relationship between the two parties, but the section 

 clearly states that Bonneville "shall not be obligated" to grant 

 a request for a follow-on contract simply because a DSI gives 

 notice that it wants such an agreement. 



In sum, the interruptibility analysis which we request is based 

 on the Bonneville Administrator having significant legal 

 discretion to structure DSI contracts. 



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