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the processes BPA uses to acquire new, electric generating 



resources, such as combustion turbines, and the process it seems 



to use to evaluate fuel 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. BPA has taken the 



position for at least the last dozen years that it cannot use 



fuel switching as a conservation resource. It maintains that it 



does not have the statutory authority to do so, since fuel 



switching does not meet either the definition of a "resource" or 



"conservation" in the Northwest Power Planning and Conservation 



Act. BPA cites legal opinions to back up this position. Because 



of this, BPA does not, in fact, evaluate fuel switching on equal 



terms with other resources and it does not seem to consider fuel 



switching in its processes to acquire and evaluate resources. I 



strongly believe that this position should be reviewed and 



reconsidered by BPA, particularly in light of the fact that these 



legal opinions were written before natural gas turbines were 



11 



