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We need to ask, is fuel swittAmg a resource or is it only an interim solution that will 

 come back to haunt utilities in 20-25 yeais wbtn nanual gas supplies are exhausted and the 

 cost of the fuel is no longer competitive with electricity. And, are we addressing die grave 

 picture of a gas system that is subscribed to the point that some intemiptible contracts have 

 scheduled periods of backup oil? WiJbout tbe inqxKition of regulations that prevent switching 

 back to electricity as a heating fiiel at some time in the fiinire, we believe fuel switching is of 

 questionable vahie as a long-teim resomce. Fuel substitution in the short term, however, 

 could be considered a resource, bat the priority regardless of fuel type is always efficiency of 



end use. 



What Bonneville, the Council, utilities and die natural gas industry need to be doing is 

 more truly integrated resource plamung that takes into consideration all fuel options, supply 

 limitations, and demand growth. By encouraging fiiel switching now to reduce electric load 

 without smdying the long-term natural gas supply and demand pictures, we may simply be 

 dodging one bullet in dK electric sapi^y curve now for tbe next generation to stop when gas 

 supplies are depleted. 



If Bonneville would also move toward a marginal costing approach in its wholesale 

 rate structure, more correa price signals could be communicated dirough dieir retail 

 customers. This would help to clarify tbe tnie market environment in which retail customers 

 make their energy decisions. 



Bonneville should not prohibit te expenditure of Super Good Cents incentives in 

 areas where naniral gas sernce is currently available. In utilities where gas is available, 

 Super Good Cents participation as a percentage of all new electric homes was only 11% in 

 1992. By Bonneville's own estimate. 13% of the 11% (or 1.3% of total electric homes) 



