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did not warrant stringent adherence to conservation or efficiency 

 standards . 



Also, BPA has historically been most responsive to well-organized 

 and influential interests among its customer groups in the region, 

 often at the cost of rationality in its programs and rate designs, 

 as evidenced by the disarray in its current policies and practices 

 in irrigated agriculture. BPA's responsiveness to special interest 

 pressures partially accounts for the fact that large irrigators, 

 whose economic self-interest is sufficient to induce investments in 

 energy and water application efficiences, are subsidized with 

 conservation cost sharing agreements and discounted power rates, 

 while smaller farmers who may require specific forms of assistance 

 receive but a relatively small share of BPA's expenditures. 



BPA's failure to design and implement an effective water 

 conservation program is also a consequence of the agency's 

 historical relations with utilities. By virtue of its role as a 

 power marketing agency, BPA's natural relations with agriculture 

 are with the public utilities with large irrigation loads; 

 irrigator utilities, in turn, are often dominated by the organized 

 interests of large users of pumping power such as Northwest 

 Irrigator Utilities. Thus while BPA is aware that the most 

 inefficient irrigation practices are found on Reclamation-served 

 irrigation districts — where water is cheap, pumping lifts low, 

 farmers small, capital and management scarce — the agency 

 continues to subsidize the larger, more organized corporate farming 

 operations . 



It seems clear that an effective program of investment by BPA in 

 water conservation for purposes of instream recapture is desirable. 

 But it would require strategic concentration among the least 

 efficient class of irrigators where instream recapture at the point 

 of diversion makes such investments cost-effective. To accomplish 

 such a strategy BPA would be required to develop a program in 

 concert with the Bureau of Reclamation, and through Reclamation 

 with the irrigation districts. USDA's Conservation Districts and 

 the Soil Conservation Service would also require involvement. 

 Notably, both USDA and the Bureau of Reclamation have specific 

 mandates to accomplish water conservation and water quality 

 improvement in agriculture, while BPA's conservation 

 responsibilities are expressed in terms of energy savings, not 

 water . 



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