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To increase accountability, both at BPA and at the utility 

 level, SUB supports the concept of tiered rates. Our 

 implementation plan is contained in my written testimony but the 

 principle is simple; create accountability for the region's 

 utilities. Under tiered rates, the responsibility, accountability 

 and risk for developing resources (including conservation) , belongs 

 to the utilities and its customers. BPA will only acquire 

 resources for tier two or subsequent tiers upon receiving 

 definitive notice from its customers that they wish to place load 

 on BPA. 



There are those who will resist changes of this type and urge 

 special consideration for their particular situation. In almost 

 every case, these are to the region's detriment. 



Tiered wholesale rates, as outlined in our written testimony, 

 provide the utility with tools and clear price signals. Under 

 tiered wholesale rates, the retail rates paid by industrial 

 customers of those utilities reflect that utility's decisions, not 

 mandates from BPA. 



As BPA implements tiered rates, it becomes possible to 

 unbundle products and services as independent and discrete 

 marketable commodities, not associated with any particular tier. 

 Unbundled services should be priced, as should all BPA services and 

 products, at cost. 



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