46 



falling far short. Indeed, examples continue to surface in which 

 BPA customers actually promote wasteful energy use through 

 promotional devices like declining block rates; a disgraceful 

 case in point is attached, involving a policy statement by 

 Idaho's Clearwater Power Company.' NRDC takes no position on 

 restructuring BPA's debt; our focus has been on ways to build a 

 sustainable energy future without having to rely on divisive and 

 politically dubious measures. If BPA's debt can be restructured 

 to the Treasury's satisfaction at little or no cost to the 

 region, of course, few are likely to object. 



2. If Bonneville is given legislative authority to refinance its 

 Treasury debt, should that authority be limited to Bonneville's 

 appropriated debt? Should Bonneville be given new borrowing 

 authority, either from the Treasury of the private financial 

 markets? 



RESPONSE: BPA's capacity to meet its statutory conservation and 

 fish/wildlife authority should not be constrained by arbitrary 

 limitations on borrowing; we would support raising those ceilings 

 well in advance of potential adverse impacts. In addition, third 

 party financing remains an extremely attractive option for 

 funding energy efficiency programs; we would like to see much 

 more emphasis on such financing at BPA. We take no position on 

 the refinancing of Treasury debt except to note skepticism about 

 claims that magical means can be found to send more money to D.C. 

 without any effect on BPA's rates. 



3. In general, discuss your views on the possibility of changing 

 Bonneville's status from that of a federal agency within the 

 Department of Energy to a government corporation. 



RESPONSE: In some ways BPA already is functionally a government 

 corporation; it is a self-sufficient, self-financed agency. Yet 



'Note that this letter to Clearwater's members, dated August 

 27, touts a "33% savings" for kilowatt-hours purchased in excess 

 of threshold amounts by residential, farm and commercial 

 customers. The letter cites these declining block rates as a way 

 to increase revenues and reward those who heat electrically. 



