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Major weaknesses of the Council are the Council has lost sight, 

 as I mentioned earUer, of the Act's stated purpose, adequate supply 

 and low rates; lack of expertise of staff and members, practically 

 no people, that I know of, with past experience with actually plan- 

 ning to meet utility loads. 



The Council has lost much credibility with the utilities, partly 

 because of cynical comments by some Council members about utili- 

 ties' concerns over rate increase impacts on their consumers. 



There are significant differences between the processes for con- 

 servation and generation acquisition. One is not including the cost 

 of creating the electricity which is delivered to new load after con- 

 servation expenditures have released it from its existing consum- 

 ers. Another is the excessive discounting of conservation costs and 

 the excessive inflating of generation costs before applying the cost 

 of comparisons. 



Resource acquisition costs Eind benefits for conservation are not 

 appropriately shared. The benefitted consumer fi-om conservation 

 measures should pay much more of his or her costs of becoming ef- 

 ficient, because they receive the benefit. 



We favor BPA acquiring the output of the Tenaska project. It is 

 a dependable peaking resource. It can firm up non-firm hydro. Con- 

 servation and renewables cannot do these two things. Although the 

 costs are relatively high, the Tenaska rate impact on consumers 

 will be much less than the same amount of conservation acquired 

 at the same cost. 



It is common and necessary practice that certain information 

 submitted by resource proposers be privileged and confidential. 

 BPA will make the best arrangement possible. They share the ob- 

 jective of low cost dependable resources. The Council, however, 

 should develop the capability to keep certain information confiden- 

 tial in the fiiture. 



With reggtrd to fuel switching, the Act does not require it. Fuel 

 switching is not conservation and BPA and the Council should 

 allow the market to work. Switching to gas can actually increase 

 the energy use and can increase pollution, as was mentioned by an 

 earUer speaker. 



Conservation incentives should not discriminate against those 

 consumers where gas is available. The Act requires that quantifi- 

 able environmental costs be included in the system cost of a re- 

 source. We believe BPA has gone far beyond quantification as in- 

 tended by the Act in assessing environmental externalities. 



And appl3dng such penalties to existing conventional resources 

 which are going to operate anjrway and produce the environmental 

 effects, whether BPA acquires the output or not, is wrong. 

 Boardm£in is a good example of that. 



Our limited experience deeding with BPA on acquiring billing 

 credit resources in a gas generating plant has not been good. It 

 does not appear at this time that BPA is an effective acquirer also 

 of indirect resources. Thus far, the Council has been concerned 

 about electric energy. The time is coming fast when the region 

 must give much attention to peaking resources. And if you think 

 planning an energy supply is confusing, wait till you deal with the 

 peaking resources. 



