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appliances in Super Good Cents dwellings, refusing to pay the in- 

 centive if natural gas appliances are used in the home. 



Other utilities will allow only a sealed combustion direct vented 

 gas appHance, which pretty much limits the choice. 



The original intent of Super Good Cents and the MAP programs 

 were to encourage standardizing of higher levels of conservation 

 through increasingly stringent building codes. 



We think that goal has been largely achieved in the region. In 

 the states that we serve and Oregon and Washington now admin- 

 ister much tougher building codes. So instead of being a true con- 

 servation measure now, these programs are now a means of influ- 

 encing the consumer's choice of heating fuel. 



We believe very strongly that BPA should undertake several dif- 

 ferent efforts to encourage resource acquisition through fuel switch- 

 ing. First, we believe that they should become proactive in encour- 

 aging and providing incentives for fuel switching wherever it's eco- 

 nomic or feasible on systems that are served by Bonneville. 



They should be providing incentive dollars to their utility cus- 

 tomers to compensation them for reduced revenues when fiiel 

 switching does occur. 



Second, we beheve that the obsolete conservation programs, such 

 as Super Good Cents and MAP, would inhibit the use of natural 

 gas or inhibit the choice of natural gas. That should be eliminated. 



Third, the BPA and its customer electric utilities, along with the 

 natural gas utiHties, should be working together and planning not 

 only fiiel switching programs, but other uses, as weU, where natu- 

 ral gas is involved, such as the possibility of sharing pipeline ca- 

 pacity on projects where new combustion turbines are going to be 

 built, joint trenching operations where the consumer can save dol- 

 lars through the utilities working together in a single instead of 

 multiple installations of facilities , 



We believe that we owe it to the consumers of the Northwest to 

 conserve all forms of energy and to work together to reduce the 

 wasteful use of energy wherever possible. 



In response to your next question, should BPA prohibit the ex- 

 penditure of Super Good Cents incentives in areas where natural 

 gas service is currently available, you might say asked and an- 

 swered, a resounding yes. Those Super Good Cents programs in- 

 hibit the choice of natural gas and inhibit fuel switching which 

 benefits everyone. 



Question 2 asks in practice, are there significant differences in 

 the processes BPA uses to acquire and evaluate fossil conservation 

 and renewable resources in the processes it applies to the fuel 

 switching resource. Are procedures, requirements and administra- 

 tive demands essentially equivalent for equivalent resources? Are 

 resource acquisition costs and benefits appropriately shared? 



There are great differences in the processes that BPA uses to ac- 

 quire new electric generating resources, such as combustion tur- 

 bines, and the processes that it uses or seems to use to evaluate 

 fiiel switching. In practice, BPA has not made any significant 

 progress in promoting or acquiring the fuel switching resource, in 

 part, because fuel switching is not seen as a legitimate resource in 

 the planning process. 



