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Unfortunately, BPA does not have the cost accounting of a 

 market-driven organization and lacks concrete information 

 concerning the costs of its services. Revision of the system and 

 the establishment of true costs must precede institution of 

 unbundled services - BPA can't very well sell something if it does 

 not know the cost. 



SUB believes that the costs of fish and wildlife mitigation 

 must be associated with the benefits produced. The first tier FBS 

 would include those fish and wildlife costs associated with the 

 current system under SUB's proposal. 



The decentralization envisioned by Springfield in an 

 unbundled, tiered rate BPA is not the equivalent of chaos. 

 Regional coordination of existing resources and planning for new 

 resources will still take place, and there will be more minds on 

 the job. The Coordination Agreement ( or some successor ) will 

 still be in place. Resources (including both conservation and 

 generation) that are cost effective will be acquired more flexibly 

 with decentralized decision making without any loss of coordination 

 while BPA provides open access transmission. 



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