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3. In practice there is a significant difference in the way BPA acquires conservation com- 

 pared to other resources. In reality and from personal experience the criteria and proce- 

 dures are quite different as implemented by BPA. In our efforts to market the 53 MW 

 of the Boardman Coal Fired Plant to BPA they were extremely detailed in including all 

 costs, however when it comes to their evaluation of conservation costs they clearly 

 have refused to include the total and real costs by both BPA and the utilities. Quite 

 honestly, the program people within the BPA don't want to know the real cost, for fear 

 that many of these programs would be exposed for the liberal, not cost effective 

 programs they have evolved into. When comparing other resource acquisitions to con- 

 servation the real truth is many of the conservation programs should be eliminated or 

 terminated just as some of the renewables or fossil resources have been rejected. 



Let me be very blunt many of the conservation programs and fundings have become 

 viewed as entitlements and not considerate of their cost effectiveness. These programs 

 within BPA as well as many of the utilities are actually being used to milk the system 

 as marketing schemes and provide employment under the guise of conservation. 



Lets be fair, the regional act gave conservation a 10% edge, but absent this, all acquisi- 

 tion are not but should be evaluated consistently both as to costs and benefits. 



4. We recognize the competitive elements that prompt developers to want to keep the 

 details of acquisition contracts confidential. However, there is a competing interest on 

 the part of customers to want to know the type of financial commitments BPA is 

 making on their behalf. The guiding principle should be to disclose as much informa- 

 tion as possible without harming the competitive interests of the developer. One way to 

 accomplish this would be to disclose the total purchase price and levelized cost of the 

 project. This would give the customers an idea of the size of the financial commitment 

 without compromising details of fuel price escalation forecasts or other embedded as- 

 sumptions that would be detrimental to the developers interests. 



BPA has demonstrated through third party financing that there can be benefits both to 

 BPA and its customers, the continuation of this vehicle certainly is a benefit to the 

 region and it's ratepayers, we would strongly encourage its increased usage with the 

 sharing of the benefits being the stimulus for future participation. Due to the lack of 

 performance to date relative to BPA's billing credits I am unable to comment on how 

 effective this means will be. 



