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agency is now poised to take on major fuel substitution 



initiatives; these should focus not simply on promoting gas use, 



but should incorporate the same life-cycle efficiency tests for gas 



equipment that are now routine on the electric side. Northwest gas 



utilities should be part of this process. 



Both electric and gas utilities' involvement in such programs 



would benefit greatly from regulatory reforms that sever the link 



between their profits and their energy sales. Such reforms are now 



underway in Washington and should soon emerge in Oregon, for 



investor-owned utilities.'" In light of this progress, and a lack 



of evidence about negative impacts, I would not suspend the Super 



Good Cents program in areas served by gas; instead, I would 



encourage gas utilities to introduce their own programs, or to 



integrate gas equipment choices into the Super Good Cents package. 



6. Has the Northwest Power Planning Council adeauatelv exercised 

 its responsibilities under the Act in the resource acquisition 

 field? Please describe the strengths and weaknesses of the 

 Council's activities related to resource acquisition. 



The Council's integrated resource acquisition plans are quite 

 simply the best that any agency or company has ever published. 

 However, the Council's capacity to influence actual acquisition has 

 been quite limited in practice, due in part to the cumbersome 

 quality of the enforcement tools provided explicitly in the 

 Regional Act. The Council's moral authority and political pressure 

 are often effective, but more is needed at least intermittently to 

 assert regional interests in least-cost resource acquisition. 



In my opinion, vindicating these interests will require 

 creative revisions of BPA's power sales contracts with its utility 

 and industrial customers, and in the attachment of conditions to 

 the valuable transmission and related services that EPA provides 

 regionwide. Obligations to support key elements of the Council's 



'""Revenues for Portland General Electric and Pacific Power & 

 Light would no longer be tied strictly to kilowatt-hour sales under 

 "decoupling" plans both utilities submitted this spring to the 

 Oregon Public Utilities Commission." Conservation Monitor , p. 10 

 (June 1993) . 



