257 



Mr. DeFazio. Okay. To Randy Berggren, you talk about an ex- 

 emption for smaller projects, which is something I raised earlier, 

 the idea that there's an exempt level. Are you familiar with what 

 was brought up about the Gardner Mill? 



That was interesting to me that here on at least the industrial 

 side we had something that seemed where we set some rather 

 broad parameters and gave a couple of people the responsibility 

 and said, okay, you come back to us and we'll sign off on these 

 things quickly. That soiuids to me sort of along the line of what 

 you're talking about. 



Mr. Berggren. Right. I think we continue to have discussions 

 with Bonneville about that. Our view is that there is an order of 

 magnitude difference in risk relative to just the issue of acquisition 

 and that you can afford on smaller projects to basically kind of ver- 

 ify at a different level of administrative certainty than you need 

 perhaps on a very large project that has much more financial risk 

 associated with it. ... 



There is some pragmatic ability to balance the administrative 

 burden on smaller projects for the risk that you're assuming for de- 

 livery. . 



Mr. DeFazio. What are the problems that you see with their ap- 

 proach to third-party financing? 



Mr. Berggren. I think the issue that we have heard at this 

 point that is of most concern is the one that was raised earlier that 

 committing to additional third-party financing, would create a 

 higher percentage of their obligations as fixed, kind of ongoing, un- 

 controllable costs, and that that will mount and build over time to 

 the degree that they approach an unacceptable level. 



I think we're sensitive to that, but we think that there needs to 

 be a way to find new ways of doing that. I think in the short-term, 

 it makes sense to do third-party financing. It decreases Bonneville's 

 capital requirements, while it certainly increases perhaps their on- 

 going obligations to finance the debt service on those payments. 



The influx of that cash put in the local community where it can 

 really be applied to an end-use specific relationship with your cus- 

 tomers creates all kinds of flexibility that can truly, we think, cre- 

 ate orders of magnitude of increased acquisition of conservation. 



We don't deny the problem that Bonneville talks about, but we 

 have not felt hke that's been a particularly innovative discussion. 

 Looking for ways to fix the issue of budget management and cost 

 management, it's just been used as a barrier at this point in our 

 discussions with them, although they continue to, I think, entertain 

 discussion with us about that and we are still in dialogue and 

 hopeful that we can continue to use the last remaining portion of 

 our existing authorization to extend that pilot effort. 



Mr. DeFazio. I assume you're talking about billing credits going 

 to generation, not conservation. I know that EPUD can get billing 

 credits for the methane. Are you thinking of other generation? 



Mr. Berggren. I was commenting on our specific experience. 



Mr. DeFazio. I thought you were talking about it more generally. 



Mr. Berggren. No. I was being very specific to just our experi- 

 ence with Bonneville, which has basically only been successful in 

 the billing credits side with generation type projects, where they've 

 been much more flexible and, I think, have actually been very re- 



