367 



supplement the FBS for continued bad water years (worse flows 

 than critical) for example. 



18. Pooling of allocations. Utilities should be allowed to pool 

 their allocations of power. Sales from the pooled 

 allocations could then be made to those utilities forming the 

 pool . 



SUB believes that pooling resources among preference 

 customers in both tiers should be encouraged and sales from 

 the pooled allocations can be made to other Northwest 

 preference customers outside the pool. However, there should 

 be no marketing of Federal power for profit or re-sale. 



Allocations of FBS power go with mergers of publics. 

 Allocations of FBS power are redistributed among public 

 preference customers when publics are acquired by privates. 



19. Revenues from sales of secondary energy (and other services) 

 must stay in the relevant resource pool. If there is a 

 surplus of first tier energy or capacity, BPA will ma)ce it 

 available to preference customers first. Any remaining 

 surpluses can be marketed. All revenue to flow back to the 

 first tier. 



20. SUB believes there should be no FBS replacements. Freeze the 

 current size in aMW, based on (average water year) actual 

 operations. Tier 1 may diminish/fluctuate in size due to 

 weather, fish, age of facilities, repayment reform, private 

 acquisition of publics, dissolution of DSI 

 Reductions/Increases would be allocated equally among 

 preference customers. 



All new resources or replacements to the FBS (and their 

 associated services) will make up Tiers 2, 3, 4, etc. 



21. SUB supports take or pay contracts, subject to notice 

 provisions, for all tiers and all parties. However, adequate 

 price control mechanisms must be established so that BPA can 

 not raise rates beyond what is reasonable. This take or pay 

 provision would only be instituted in conjunction with the 

 ability to pool allocations among customers and the 

 customers' right to audit BPA costs. 



22. SUB supports classification of conservation as an unbundled 

 service, not associated with an allocation of Tiered capacity 

 and energy. Fundamental to this premise is that Conservation 

 should be viewed as a resource similar to generation. In 

 addition. Conservation should be given a priority status (as 

 defined in the Act) when BPA acquires resources for the 

 various Tiers. 



SPRINGFIELD UTILITY BOARD PAGE 6 SEPT. 25, 1993 



