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JOtllltlOn Attachment 1 to NCAC testimony: NCAC letter to Norttiwest Power Planning Council 



regarding review ot Tenaska project under Section 6(c) ot the Regional Act; June 10, 1993 



June 10, 1993 



Stan Grace, Chainnan 

 Northwest Power Planning Council 

 851 S.W. Sixth Avenue, Suite 1100 

 Portland, Oregon 97204-1337 



Re: Council review of Tenaska Washington n project under Section 6(c); 

 Council issue paper 93*12 



Dear Stan: 



The Council is justly famous for its pathbreaking work in least-cost energy planning. 

 But, in your review of the Tenaska projea for consistency with the Plan, you face a 

 crucial test: Are you willing to use the relatively nxxlest formal authority you have 

 under the Aa to insist upon least-cost action? 



Your authority under Section 6(c) gives you the power to reject proposals that 

 are inconsistent with the Plan. Clearly, however, the Plan cannot be 

 implemented by process of elimination. You have wisely chosen to interpret 

 your authority in a way that gives you some leverage to efTea positive 

 commitments to the Plan by asking, on p. 21 of the issue paper "Is BPA 

 making reasonable efforts to acquire higher priority resources?" We applaud 

 you for asking the question. But we feel very strongly that staff have arrived at 

 the wrong answer. Before making that case, we want to raise a few questions 

 about the project itself. 



First, the competitive bidding process from which this project emerged was 

 shrouded in far more secrecy than legitimate proprietary concerns can justify. 

 Other utilities have successfully used open, self-scoring resource auctions that 

 allow for full public review of the resource selection process. Especially in a 

 region that prides itself on open planning and the consensus it has achieved on 

 energy priorities, we find this secrecy highly inappropriate. To give your 

 blessing to the low bid in a closed competitive bidding process leads folks to 

 question why we bother with the Regional Plan at all. 



Second, as nearly as we can tell, the environmental analysis does not seem to 

 account for the fact that the extreme cold weather conditions under which the 

 plant would be most likely to bum oil generally coincide with the worst air 

 quality emergencies in the Puget Sound area. We suspea that air quality 

 authorities might take a dim view of this prospect and encourage utilities to 



6532 Phinney Ave N, Suite 15 • Seattle, WA 198103 • (206) 784-4585 • Fax (206) 784-4577 



^Pnnied on rccvcled paper wiih vegcublc-bascd inks 



