472 



Tiered rates would require an allocation of the Federal Based System (FBS). We feel that 

 an allocation should only be to BPA's public preference customers. Use the mechanism of 

 the re-negotiation of the power sales contract to achieve the allocation. DSIs would not 

 receive a firm FBS allocation. The costs included in the base tier would include all present 

 BPA obligations except resource acquisition. 



If BPA were not acquiring resources, tiered rates would offer an effective price signal for 

 utilities and IPPs to buy or develop competitive resources. The price signal hits the end- 

 user only if the tier is reflected in the retail rate. The retail rate is not in direct control of 

 BPA, and may ultimately be absorbed in budgets and rates which the end-user does not 

 see. 



Again, the BPA wholesale rate for 1994 - 1995 may already be the only price signal 

 necessary for the end-users to change their behaviors and energy choices. The proposed 

 wholesale rate places BPA rates on the brink of not remaining competitive. 



Columbia River PUD, St Helens, Oregon 

 Comments to the DeFazio Task Force 

 07/02/93, 03 ;36PM 

 page 7 



