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We propose that BPA and its customers form the question before they decide that a tiered 

 wholesale rate is the answer. We propose the question is: 



How does the region develop efTicient, cost-effective and 

 environmentally sound resources? 



The options we have limit competitive acquisition of energy resources because of BPA's 

 inability to effectively implement the Regional Act's billing credits process and sustain 

 conservation acquisition funding, barriers in our power sales contract, and the State of 

 Oregon's siting requirements. 



One method of decreasing BPA's resource acquisition costs is to shift the billing credits 

 process to utilities. The utilities wanting to develop resources would then issue their own 

 Request for Proposal (RFP), evaluate the projects, select the one(s) best suited for their 

 needs, and submit the final projecU to BPA BPA would evaluate and award the 

 contract(s) to the cost-effective and environmentally sound projects. 



In the BPA billing credits example, a small utility may have an independent power 

 producer propose a generating plant in their service territory. How does the utility work 

 with the IPP, BPA, state and regional bodies to get the resource on-line and remain 

 competitive? We suggest a few questions to stimulate solution finding: 



1. How does Oregon detetmine a "need" for the resource under Energy Facilities 

 Siting Council (EFSC)? 



2. Will EFSC hamper Oregon utilities in developing resources because we have to 

 "demonstrate need"? 



3. How can we bring state, regional and federal rules and regulation together in 

 acquiring competitive and environmentally sound resources? 



4. Which entity will oversee the development of state and regional resources? 



Columbia River PUD, St Helens, Oregon 

 Comments to the DeFazio Task Force 

 07/02/93, 03:36 PM 

 pages 



