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irrigation discount, than the mere provision of a pumping subsidy 

 at costs now approaching a biannual $30 million which saves no 

 jobs, some portion of which is exported from the region, and the 

 usage of which defers investment in conservation by irrigated 

 agriculture in the Basin. 



1.4 The discount accelerates retirement rather than 

 preserving irrigation in areas of groundwater depletion. 



Approximately 25,000 acres have been retired from irrigation 

 on the Basin in the last decade due to groundwater depletion. 

 Retirement of additional acres for this reason appears inevitable 

 in other areas within the next decade, most notably in the Odessa 

 and Stage Gulch critical groundwater areas, where pumping lifts are 

 in excess of 400 feet for low-return crops. Pumping rate discounts 

 of 10% - 20% will not preserve irrigation in these areas, but 

 merely offer incentives to continue depletion of the resource. If 

 these areas of agriculture are in structural decline, in part 

 through exhaustion of a natural resource, it makes little sense to 

 provide a discount with which to continue, for some undetermined 

 short term, depletion of the resource without some review and 

 planning to determine the effects upon the workforce and the 

 communities affected by the exhaustion of groundwater supplies. 



2.0 The Irrigation Discount Has Potentially Significant Adverse 

 Environaental and Socioeconoaic Consequences and Requires EIS 

 Review in the 1993 Rate Case. 



2.1 Increased water and power use and deferral of conservation 

 ■easures is a well-doctiaented irrigator response to discounted 

 pu^>inq rates. 



BPA has known since 1981 that reductions in pumping rates 

 motivate increased water and power use by irrigators. This was 

 BPA's conclusion in its Environmental Report on the issue of the 

 extension of pumping discounts through the residential exchange 

 program to investor owned utilties at that time. 10) Every study 

 commissioned by BPA since then has reached the same conclusion. 11) 

 Although not elastic in the economic sense, the effects of 

 discounted pumping rates — even in a context of general rate 

 increases — "may delay capital investments which would improve 

 irrigation efficiency," and motivate increased resource 

 consumption, as BPA found in 1981. The same findings have been 

 reiterated in 1986 and 1989 studies done for BPA by Northwest 

 Economic Associates. 12) 



2.2 To the extent that discounted pumping rates encourage 

 water usage in excess of crop requirements and motivate deferral of 

 conservation measures, they contribute to surface and ground trater 

 contamination caused by irrigation runoff. 



This was essentially BPA's conclusion in 1981: 



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