238 



Despite this diversity, public power has spoken with a united 

 voice regarding the regional fuel choice policy. We continue to be- 

 lieve that fuel choice issues are best addressed on the local level. 



With regard to the role of the Coimcil, the question evokes two 

 responses. First, the Council's ultimate value to the region in 

 power planning is that it calculates the cost planning and operat- 

 ing of the region versus on an individual, utility-by-utility basis. 

 The world envisioned by the Act, with Bonneville acquiring re- 

 sources for everyone, including the investor-owned utilities, is very 

 different from the world we know today. 



Although it is unlikely that we will experience single utility plan- 

 ning and operation anytime soon, it is still valuable to estimate the 

 cost of pursuing that course. Second, the Council's role is that of 

 planning, not implementation. Congress never intended the Council 

 actually to implement a power plan. The job was left to Bonneville 

 and the utilities. 



The Council's mission is to develop a power plan and determine 

 that the Administrator's actions are consistent with the plan, but 

 not to perform an oversight role or to act as regional public utihties 

 commission. In fact, as a Federal agency, Bonnevfile reports to 

 Congress and the Executive Branch of the Federal Government. 

 The Council is not to perform an oversight role, and in fact, the 

 word does not appear in the Act itself with respect to the Council's 

 role. 



The Council's role is power planning. The responsibility of imple- 

 mentation falls to Bonneville and the utilities. 



Those that would suggest the region must exhaust all available 

 conservation before considering other resources do not sufficiently 

 understand the Act's intent, the concept of least-cost planning or 

 utihty resource planning. First, it must be understood that the 

 prioritization of the Act is intended to provide a system to screen 

 resources in the development of a least-cost plan. 



The Act's prioritization is designed to improve the comparative 

 economics of conservation and renewables. Ultimately, however, 

 BPA is to select the resources of the least-cost. If, after tweaking 

 the economics under the Act's prioritization standards, certain con- 

 servation resources are not least-cost, then the Act directs BPA to 

 acquire alternative resources. 



Second, prudent utility planning argues against acquiring con- 

 servation to the exclusion of all other resources. The WPPSS expe- 

 rience demonstrates all too well the potential risk of placing too 

 much emphasis on one resource t5rpe. New York State Commis- 

 sioner Peter Bradford, a strong conservation proponent, has 

 warned against tinning conservation into the nuclear resource of 

 the 1990s. 



In addition, it must be understood that factors other than price 

 enter into the utility resource acquisition decision. For inst£uice, a 

 utility may be willing to pay more for resources that are 

 dispatchable, a characteristic not attributable to conservation. 



In considering whether BPA has accounted for the environmental 

 externalities associated with resource acquisition, I would raise one 

 concern. Clearly, the impact on retail rates, primarily in the rural 

 non-growing areas of the region, can have a very substantial effect, 

 since not only is BPA's cost passed on, but the loss of revenue to 



