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not be budget-constrained, BPA succumbed to rate pressure and lowered the 

 targets. 



No fossil fuel-fired generating resource can be regarded as consistent with the 

 Plan unless and until Bonneville makes firm, long-term commitments to acquire 

 the conservation that end-users are literally waiting to deliver. This is not to 

 imply that the resource priorities of the Act arc necessarily sequential, with 

 each tier's acquisitions completed before the next tier's begin. It simply means 

 that if one can choose between generation and conservation resources of 

 comparable cost at any one point in time, one must choose the conservation. 

 Either BPA is in the resource acquisition business or it is not. If it is, then it 

 cannot simultaneously acquire combustion turbines and claim that it can't afford 

 conservation. The Congressional Record on the Act is replete with references 

 that clearly establish Congress' intent to acquire conservation first and 

 foremost As Representative Dicks said in House debate on HR 8157: 



Thermal plants would be constructed "only if we have used all of the 

 conservation alternatives available in the Pacific Northwest, even 

 though they are 10 percent more expensive and, secondly, if we have 

 used all of the alternative energy sources available in the Pacific 

 Northwest. Those things have to be done first." (Congressional 

 Record, 9/29/80, p. H-9861) 



BPA contends that it can achieve the Council's targets while dramatically 

 cutting budgets simply by "spending smarter." To be sure, there are 

 efficiencies to be gained, and the Council has taken the lead in identifying them. 

 (The primary reason that BPA's cost per kilowatt hour saved is too high is that 

 the denominator is too small; it simply isn't saving enough.) 



But let's call a spade a spade. This 20% cut isn't a sudden conversion to a 

 more streamlined approach. It is simply caving in to myopic pressure to 

 minimize rates in the short-term at the expense of incurring substantially 

 higher long-term costs. It is, in Vice-Chaiiman Bottiger's words, "having future 

 generations pay for the lack of their parents willingness to do so." 



And what do we gain by cuts of this magnitude? A 20% cut in conservation 

 would save less than 2 hundredths of a cent per kilowatt hour from BPA's 

 rates. One has to wonder whether those who would substantially increase 

 long-term costs in exchange for such negligible rate relief are really planning to 

 stay in the region for long. One thing is certain; the low-income folks that we 

 represent will still be here to pick up the tab. They may be close to the margin, 

 but they are not so short-sighted as to urge BPA to defer modest investments 

 that minimize costs over time. 



In closing, we'd like to make a couple of observations about the 6(c) process. 

 The Plan clearly does not call for immediate acquisition of this project Your 

 own staff paper acknowledges that BPA's program cuts render its capacity to 

 acquire higher priority resources "uncertain." The Plan itself is being second- 

 guessed and arguably rewritten in forums ranging from the rate case to the 

 Power Sales Contract negotiations. We would guess that no one on the 



