390 



find it hard to regard a simple transfer of costs from 

 Bonneville's budget to ours or our customers' as an 

 "efficiency" . 



I must tell you also that we cannot promise that we can take a 

 reduction in our program support from Bonneville and still 

 deliver the same number of megawatts we had planned on. 

 Obviously we'll do our best to do the most with whatever 

 resources we have available. But I am not at all prepared to 

 concede that we have been running our programs in such an 

 inefficient or profligate manner that a significant hit on our 

 budget will have no effect on program production. 



I understand that these calls for "efficiency" are being 

 justified in some quarters by a perception that Bonneville 

 conservation programs are costlier than those of other 

 utilities and therefore have economies available which won't 

 compromise the megawatt savings. We don't buy it. Consider 

 our commercial sector conservation program, the Energy Smart 

 Design program. Since incentives were added to our ESD 

 program, the levelized costs for incentives have consistently 

 been in the 15-20 mills/kwh range. With the addition of 

 utility delivery costs at current levels, the total delivered 

 cost runs in the low- to mid-20's. These numbers do not 

 support the premise of an excessively costly resource. Either 

 the costs are elsewhere (in which case the efficiencies are, 

 too) or the premise is wrong. 



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