163 



such a bet voluntarily. We are no more anxioas to provide this insurance to the 

 fossU fuel industry than the insurance companies are; the difference appears to 

 be that they have a choice in the matter. 



Far more compelling than the deficiencies of this particular project, though, are 

 BPA's wholly inadequate efforts to acquire higher priority resources. On page 

 22 of the issue paper, staff note that "it is unclear" how some higher priority 

 resource acquisition efforu will be affected by current Bonneville budget cuts. 



Unclear indeed. BPA's Assistant Administrator Steve Hickock contributed to 

 that lack of clarity when he announced, at a March 30 public meeting, that BPA 

 would like to be on the least-cost path, but may be unable to afford it for now. 

 In other words, "we can't afford to save money". 



One thing is clear, however. Right now, in Seattle, Eugene, and elsewhere, 

 people are lined up outside utilities' doors waiting to deliver cost-effective 

 conservation - most of it well below the cost of Tenaska. Those doors are 

 being slammed shut in their faces because BPA's Fiscal Year 93 conservation 

 budgets have been expended. This despite the fact that BPA promised the 

 Council that "cost-effective conservation will not be budget-constrained." Not 

 only is BPA violating that promise in 1993; they are flaunting it by planning in 

 advance to break it again in each of the next two budget years. How can the 

 Council credibly determine that BPA is "making reasonable efforts to acquire 

 higher priority resources" at the very moment that it is turning away 

 conservation and writing budgets that guarantee that it will continue to do so 

 for at least the next two years? 



The staff issue paper suggests that BPA's conservation acquisitions in the 

 past two years have met the Council's goals. We disagree. The Plan calls on 

 BPA to acquire all cost-effective conservation. NCAC and NRDC documented 

 potential conservation savings well in excess of those in the Council's plan, 

 especially in the industrial sector. We were assured that the cost-effective 

 savings not included in the Council's supply curves would be acquired. Yet 

 cost-effective savings are being foregone right now due to budget constraints. 

 This isn't hypothetical, supply curve stuff; these are real deals on the ground 

 that BPA won't make because of rate pressure. We believed them when they 

 promised you that this would not happen. 



The whole notion that BPA is preserving the resource by focusing on "lost 

 opportunities" is a relic of the surplus era. As conservation implementers will 

 tell you, any time someone is ready to let you harvest the conservation 

 resource in their home, office, or especially in an industrial facility, it's an 

 opportunity. If you fail to take it when you can get it, it's a lost opportunity. 

 Maybe you can come back for it later, maybe not 



When BPA asked its customers how much conservation they could deliver, 

 they arrived at a total substantially greater than BPA's 660 MWa target. The 

 Area Offices were told to pare that number down due to budget pressure. 

 Again, in direct contradiction of its promise that cost-effective conservation wiU 



