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7. Has BPA adequately accounted for the environmental externalities associated with 

 various energy sources in its resource acquisition process? If not, what specific 

 issues should BPA revisit? 



Bonneville began, over a decade ago, to carry out the research necessary to begin 

 assessing the environmental costs and benefits of energy resource development and 

 operations. Through its own efforts and via its sponsored research, Bonneville has made 

 significant progress in accounting for external environmental impacts in its resource p lanning 

 and acquisition processes, but there is still £u to go in truly crafting an integrated regional 

 resource program. 



BPA has taken a deliberate approach of explicitly including only those external costs 

 and benefits that are quantifiable. This focus on quantifiable Cu:tors is a result of the 

 requirements in the Northwest Power act as well as the fact that BPA uses the quantified 

 environmental costs in its computer models to develop the projected system costs for 

 proposed resource strategies. In addition, BPA has not explicitly included cost adders for 

 greenhouse gas emissions, for which ranges of costs have been proposed. 



While qualitative environmental impacts are 'considered" in BPA's planning activities, 

 EWEB believes Bonneville should recognize the need to expand its efforts at including the 

 less- or non-quantifiable inqtacts of resource decisions in a more comprehensive and 

 structured fashion. 



We believe BPA's woik in this area must continue to evolve and develop in concert 

 with the activities of other regional partners. Policy analysis efforts should expand to include 

 such issues as: 



environmental dispatch of existing and newly acquired resources; 

 the significant ncm-linearity of environmental inq>acts; 



