851 S.W. Sixth Avenue, Suite 1100 Telephone: 503-222-5161 Fax: 503-820-2370

 Portland, Oregon 97204-1348 Toll free: 800-452-5161 Web site: www.nwcouncil.org

JUDI DANIELSON 

CHAIR

Idaho

MELINDA S. EDEN

VICE-CHAIR

Oregon

Jim Kempton

Idaho

Frank L. Cassidy Jr.

“Larry”

Washington

Tom Karier

Washington

Gene Derfler

Oregon

Ed Bartlett

Montana

John Hines

Montana

Steve Crow

Executive Director

May 17, 2004

Mr. Steve Wright

Administrator and Chief Executive Officer

Bonneville Power Administration

PO Box 3621

Portland, OR 97208

Dear Mr. Wright:

The Northwest Power and Conservation Council is pleased to submit to you its Recommendations 

for the Future Role of the Bonneville Power Administration in Power Supply.

These recommendations were developed through a public process referred to as the regional 

dialogue, and represent a broad consensus about the fundamental model for how Bonneville should 

fulfill its role as power supplier to its regional customers. The recommendations are intended to 

provide guidance to Bonneville as it develops a policy proposal through its own public process 

scheduled to begin in June. The recommendations focus primarily on long-term, post 2011, 

questions rather than on issues Bonneville has raised regarding current contracts. The Council 

believes there is a high degree of overlap between these long-term issues and many of the questions 

pertaining to current contracts. The Council believes it is important that the current contract issues 

are resolved in a manner consistent with any new Bonneville policy for future contracts.

Bonneville and its customers will soon need to make decisions regarding power supplies for the 

post-2011 period. For that reason, the Council strongly recommends that Bonneville include in this 

summer’s policy process: 1) an identification of issues that must be resolved for the long-term; 2) 

the process by which they will be addressed; and 3) a schedule for their resolution that will support 

Bonneville offering new contracts by October of 2007. Now is the time to resolve these issues; 

they will not become easier to address with time.

The Council looks forward to working with Bonneville, its customers, and other parties to secure 

the region’s electricity future.~Sincerely,

Judi Danielson

Chair

Recommendations on the

Future Role of the 

Bonneville Power Administration

in Regional Power Supply

Council Document 2004-05

Council

Northwest

Power

Conservation

and

May 2004

The Northwest Power and Conservation Council’s Recommendations on 

the Future Role of the Bonneville Power Administration 

in Regional Power Supply

Table of Contents

Executive Summary i

The Council’s Goals 1

The Scope of the Recommendations 1

Recommendations 3

May 2004

Council Document 2004-05

Council Recommendations on the Future Role of Bonneville i

Over the past several years, the Bonneville Power 

Administration has faced periods of instability that have 

threatened its financial well being and that of its customers; hampered its ability to meet its obligations, including 

those to the U.S. Treasury; impeded the development 

of needed resources; and damaged the economy of the 

Northwest. The conclusion reached in several processes 

in recent years is that these problems have their roots 

in the ways in which Bonneville has carried out its role 

and the uncertainties that creates with respect to resource 

development and load-serving obligations.1 This led 

to proposals for changes in Bonneville’s role in power 

supply. The financial crisis precipitated by the Western 

Electricity Crisis of 2000-2001 focused renewed attention 

on Bonneville’s role. The region’s governors have asked 

the Council to work with Bonneville and interests in the 

region to resolve this issue. The Council has consulted 

with a number of interests in the region and has convened 

a broadly representative steering committee to help address the key questions.

Bonneville has announced its intent to carry out a 

policy process this summer that would define the agency’s future role as well as address a number of issues for 

the period remaining on its current power sales contracts. 

These recommendations are intended to provide input to 

Bonneville as it prepares its initial proposal for that policy process, as well as to the deliberations of Bonneville’s 

customers and other interests as they consider Bonneville’s long-term future role. The focus of these recommendations is primarily on the long-term as opposed to 

resolving questions Bonneville has raised for the last five 

years under the current contracts. However, there is a 

high degree of overlap between the long-term issues and 

Executive Summary

many of those raised under the existing contracts. There 

needs to be consistency between the resolution of these 

issues for the remainder of the current contracts and for 

future contracts. The Council believes the issues must 

be dealt with as a package rather than separately. The 

Council’s recommendations are summarized below. 

A fundamental change in how Bonneville carries 

out its role in power supply 

Resolving the problems that have afflicted Bonneville 

and the region requires a fundamental change in how 

Bonneville executes its role in power supply consistent 

with the Pacific Northwest Electric Power Planning and 

Conservation Act of 1980 (the Act). Under the Council’s 

recommendations, Bonneville would sell electricity from 

the existing Federal Columbia River Power System to 

eligible customers at its cost. Customers that request 

more power than Bonneville can provide from the existing federal system would pay the additional cost of 

providing that service.2 This change would clarify who 

would exercise responsibility for resource development; 

it would result in an equitable distribution of the costs 

of growth; and it would prevent the value of the existing 

federal system from being diluted by the higher costs of 

new resources. This change in role ultimately should 

be implemented through long-term (preferably 20-year) 

contracts and compatible rate structures. This change in 

Bonneville’s future role does not alter Bonneville’s fundamental responsibility to serve the loads of those qualifying customers who choose to place load on Bonneville; 

it does not alter Bonneville’s responsibility for ensuring 

the acquisition of Bonneville’s share of all cost effective conservation and renewable power identified in the 

1 See, for example, Comprehensive Review of the Northwest Energy System — Final Report: Toward a Competitive Electric Power Industry for 

the 21st Century, Comprehensive Review Document CR 96-26, December, 1996. http://www.nwcouncil.org/library/1996/cr96-26.htm; Cost Review of the Federal Columbia River Power System — Management Committee Recommendations, Document CR 98-2, March 10, 1998. http:

//www.nwcouncil.org/library/1998/cr98-2.htm; Investor-Owned Utility/Preference Utility Proposal For The Future Role Of The Bonneville Power 

Administration, October 29, 2002 Draft; What Led to the Current BPA Financial Crisis? A BPA Report to the Region, also known as “The Lessons Learned” report, Bonneville Power Administration, April 2003; Northwest Power Planning Council Recommendations on the Future Role of 

Bonneville in Power Supply, Council Document 2002-19, December 17, 2002. http://www.nwcouncil.org/library/2002/2002-19; The Future Role 

of Bonneville in Power Supply, Council Document 2003-18, October 2003, http://www.nwcouncil.org/library/2003/2003-18.htm. 

2 Implicit in this position is that the contracts through which Bonneville would serve load growth beyond the capability of the existing system not 

subject other Bonneville customers to increased rates or other financial risk associated with resource acquisition authorized under Section 6 of 

the 1980 Power Act.
ii Council Recommendations on the Future Role of Bonneville 

Council’s Regional Electric Power and Conservation Plan 

(Plan); and it does not alter Bonneville’s responsibility to 

fulfill its fish and wildlife obligations under the Act and 

the Council’s fish and wildlife program. It does represent 

a change in the way Bonneville has traditionally carried 

out those responsibilities.

Define a clear and durable policy framework for 

contracts and rate-making 

The Council believes that debate in the region over 

the future role of Bonneville is less about the end-state, 

a limited role for Bonneville in power supply, than about 

how to reach that end state. The Council acknowledges 

that both new long-term contracts and a revised pricing 

structure will be necessary to fully implement a new role 

for Bonneville. The Council believes, however, that a 

clearly articulated and durable policy regarding Bonneville’s future role must guide the necessary contract 

negotiations with customers and future rate cases. 

There is a spectrum of means by which such a policy 

might be established. Bonneville’s planned course of 

action is to propose a draft policy in June, undertake consultations and a formal public comment process, and then 

to adopt a final policy in the fall. The Council is concerned this process may not provide the necessary durability. The most durable alternative would be to establish 

the policy in legislation. However, the Council believes 

that would entail unacceptable risks for the region. In its 

draft recommendations, the Council proposed a middleground alternative. That recommendation encouraged 

Bonneville establish its new role through binding policy 

established by substantive rulemaking. This approach, in 

conjunction with new long-term contracts and compatible 

rate structures, has the potential to avoid the risk of new 

legislation while providing a more binding and durable 

solution than Bonneville policy implementation has 

demonstrated in the past. However, in response to the 

Council’s proposed recommendations, many commentors expressed concerns about a rulemaking. While the 

Council is not convinced those concerns are valid, it will 

not press for substantive rulemaking at this time. 

The Council remains concerned that the policy process Bonneville is planning to undertake will not provide 

the durability necessary to meet expectations for longterm contract negotiations and associated rate processes, 

and the region’s expectations for conservation and renewable resource development. To improve the durability 

of the policy, it must include clear identification of the 

priority issues that are to be resolved, the process by 

which they will be addressed, and an aggressive schedule 

for doing so. That schedule should result in offering new 

long-term contracts by October of 2007.

If this process proves incapable of resolving issues 

within the established schedule, alternative processes 

should considered. Bonneville and the Council should 

first determine if substantive rulemaking can be a vehicle 

for resolving the outstanding issues. If rulemaking is 

considered inappropriate, Bonneville and the Council 

should work together to identify specific legislation and 

seek comments from the public. Legislation should not 

be considered if there is not broad regional support including consensus among the region’s governors.

Offer long-term contracts as soon as possible 

Only long-term contracts will provide the certainty, 

continuity, and durability that customers need to make 

long-term resource commitments; the stability that Bonneville needs to be able to ensure Treasury repayment; 

and the protection the region needs for one of its most 

significant assets. Bonneville should offer such contracts 

no later than October of 2007.

The biggest impediment to long-term contracts is that 

Bonneville’s customers are concerned they would lose 

the major means by which they can exercise discipline on 

Bonneville’s costs and business practices – their ability 

to take load off Bonneville. Because long-term contracts 

have benefits for the parties and the entire region, all 

parties need to be open to examining ways to overcome 

concerns such as allocation of power, cost segregation, 

cost control, contract enforceability, dispute resolution, 

Bonneville business practices in general, and possible 

adverse impacts to Bonneville’s public service responsibilities under the Act. The Council commits to work with 

Bonneville, its customers, and others to identify a workable resolution of problems that may arise. 

Allocation of the existing system

Fundamental to implementing changes in Bonneville’s 

role in power supply is allocating the power from the 

existing federal system among eligible customers. Any 
Council Recommendations on the Future Role of Bonneville iii

allocation should be done in such a way as to minimize 

opportunities for gaming the process. For that reason, the 

Council believes that, lacking agreement on any alternative, allocation should be based on customers’ historic 

net requirements, normalized for economic and weather 

effects. In the case of new or annexed public utility 

loads, it is the Council’s understanding that Bonneville 

ultimately must serve all qualified public utilities on a 

comparable basis. Doing so would require a reallocation 

of the system. However, before any reallocation there 

should be a waiting period of sufficient duration to permit 

Bonneville and its customers to take the necessary longterm resource actions. The Council recognizes that some 

Bonneville customers may lose load over time. If this 

occurs, Bonneville should ensure that such customers’ 

long-term access to federal power at the embedded cost 

of the existing system is not unnecessarily diminished.

Tiered rates under existing contracts?

Tiered rates would be the clearest practical indication 

of how Bonneville will be carrying out its role in the future. If Bonneville defines its role as the Council recommends, and if critical issues are resolved in a timeframe 

consistent with the schedule established in Bonneville’s 

policy; and if new contracts are negotiated and offered 

by October of 2007; then the Council would not press 

for tiered rates under the current contracts for the next 

rate period. However, the Council reserves the right to 

reconsider this recommendation if those conditions are 

not met. 

Products 

Customers should have access to the full range of 

products that are currently available, such as requirements, block, and slice products. Importantly, the costs 

of each product should be confined to the purchasers of 

that product. Every effort should be made to eliminate 

cross-subsidies among products. In the process of negotiating new contracts, customers should have the opportunity to choose the products that best meet their needs. 

Direct Service Industries (DSIs) 

If a DSI has been a responsible customer of Bonneville, there may be an opportunity to provide a limited 

amount of power for a limited duration under specified 

terms and conditions. The existing federal system is 

roughly in load/resource balance. Consequently, some 

level of augmentation probably will be necessary to 

provide reasonably continuous service. If power is to 

be made available to DSIs, the amount and term should 

be limited; the cost impact on other customers should be 

minimized; and Bonneville should retain rights to interrupt service for purposes of maintaining system stability 

and addressing temporary power supply inadequacy. 

Benefits for the residential and small farm 

customers of investor-owned utilities

The Council strongly supports resolution of the issue 

of benefits for the residential and small-farm customers 

of investor-owned utilities (IOUs) for a significant period. 

The Act established a mechanism for sharing benefits 

of access to low-cost federal power. That 24-year-old 

mechanism has operated in such a way that it satisfies no 

one. However, “fixing” that feature of the Act through 

legislation could have broad ramifications. The Council 

favors a long-term settlement that provides benefits in 

the form of dollars. The Council cannot judge what is an 

equitable settlement. However, the necessary characteristics of a settlement can be defined. A settlement must 

provide certainty, it must be transparent, and it must not 

be subject to manipulation. The proposed settlement that 

collapsed in early 2004 contained these elements and was 

supported by nearly all of Bonneville’s Northwest customers. The Council believes this could be the template 

for a long-term settlement.

Fulfilling responsibilities for conservation 

and renewables

The Council expects Bonneville and the region’s utilities to continue to acquire the cost-effective conservation 

and renewable resources identified in the Council’s power 

plans. Bonneville should employ mechanisms similar 

to the current Conservation and Renewables Discount 

(C&RD) program and provide essential support activities 

to encourage and facilitate utility action. Bonneville’s 

role will be substantially reduced to the extent that 

customers can meet these objectives. But if necessary, 

Bonneville must be prepared to provide a backstop mechanism to ensure that these objectives are met. Bonneville 

must retain the ability to secure its regional share of costeffective conservation and renewables identified in the 

Council’s power plan that are not otherwise secured by 
iv Council Recommendations on the Future Role of Bonneville 

its customers. The costs of the backstop actions would 

be paid by utilities that fail to meet their responsibilities. 

The C&RD program has been instrumental in motivating 

many utilities to pursue conservation and renewables activities. But the rate discount needs to be refined as outlined in the Council’s December 2002 recommendations 

on the future role of Bonneville. The focus needs to be 

on determining how to reliably acquire all the cost-effective conservation at the lowest cost to the utility system. 

Bonneville and the Council should facilitate a collaborative process to refine the details of a rate discount and 

produce recommendations by early 2005. 

However, a rate discount should not necessarily be 

the only mechanism available to encourage utilities to 

acquire conservation and renewable resources. There 

are a number of activities that can be carried out more 

effectively if they are approached on a coordinated 

regional basis with local implementation. These include 

activities like market transformation, limited development and demonstration activities, and program design 

and administration where there are significant economies of scale to be gained. Bonneville should continue 

these activities and, in addition, its support of low-income weatherization.

The Council continues to believe that levels of renewable resource development should be guided by the 

Council’s Plan. The C&RD could be used to support 

customer acquisition of renewable resources so long as 

cost-effective conservation is also acquired. 

Bonneville is uniquely suited to pursue some renewable resources development that would not happen 

without its participation. These activities benefit all of 

Bonneville’s customers, and their costs should be recovered from the existing system. These include activities 

such as: 1) removing barriers to cost-effective renewable 

resource development; 2) developing storage and shaping services, developing transmission re-dispatch products and making transmission acquisition for renewable 

resources easier; and 3) limited, region-specific research 

and demonstration. The costs of providing services like 

storage and shaping should be paid by the purchaser. 

With regard to acquiring the output of new renewable resources, the Council believes Bonneville’s 

activities should be consistent with the Plan. Bonneville should acquire new renewable output to meet new 

or replacement resource needs placed on the agency, 

provided resources are cost-effective after accounting 

for any risk reduction or other benefits the resources 

provide. The Council encourages those utilities that 

choose to take responsibility to meet their own load 

growth to use their best efforts to acquire renewables 

consistent with the Council’s Plan and for Bonneville to 

use its capabilities to facilitate such acquisitions.

Resource adequacy

Even without changes in the way Bonneville carries out its role in power supply, the issue of resource 

adequacy, and the possible need for an adequacy standard or target to ensure that adequate power supplies are 

maintained, has been a major concern of the Council and 

others in the region. A change that results in more of 

the risk and responsibility of meeting future load obligations being borne by individual utilities instead of by 

Bonneville does not reduce overall risk. The Council is 

aware that new policies may be necessary to ensure that 

adequate information and safeguards exist to determine 

the power system’s adequacy. In particular, the Council 

is concerned about the possibility that a severe deficit by 

any one utility could have detrimental effects on other 

utilities in the region. This risk can only be removed if 

all utilities ensure an adequate level of resources for their 

own load-serving responsibilities. 

The Council is committed to working with Bonneville, utilities, the states, regulatory commissions, and 

other regional and West-wide organizations to ensure that 

appropriate adequacy policies are in place and that the 

data and other tools to implement the policies are available. The Council believes these policies need to be in 

place prior to the implementation of long-term contracts. 

 Fulfilling responsibilities for fish and wildlife

The Council believes these recommendations will not 

affect Bonneville’s fish and wildlife obligations. Those 

obligations will be determined in a manner consistent 

with the requirements of the Act and the Council’s Columbia River Basin Fish and Wildlife Program. Bonneville’s mitigation costs should be allocated to the existing 

federal power system. 
Council Recommendations on the Future Role of Bonneville 1

The Council recommends that efforts to change the way 

in which Bonneville carries out its role in power supply 

should be directed toward achieving the following goals:

• Preserve and enhance the benefits of the 

Federal Columbia River Power System for the 

Northwest;

• Not increase and, preferably, reduce the risk to 

the U.S. Treasury and taxpayers; 

• Achieve an equitable sharing of the benefits of 

the federal power system;

• Develop and maintain widespread support for 

the federal system and reduce conflicts within 

the region;

• Align the costs and benefits of access to federal 

power; 

• Maintain and improve the adequacy and 

reliability of the Northwest power system;

• Make clear who will be responsible for meeting 

load growth and on what terms;

• Provide clear signals regarding the value of new 

energy resources;

• Lessen Bonneville’s exposure to market risk;

• Lessen Bonneville’s impact on the market; 

• Satisfy Bonneville’s responsibilities for 

conservation and renewable resource 

development; 

• Satisfy Bonneville’s responsibilities with respect 

to fish and wildlife; and

• Accomplish all these goals efficiently and at as 

low as possible a cost to the region’s consumers. 

The Council’s Goals

The Scope of the Recommendations

The Council’s recommendations are focused primarily on achieving long-term resolution of the question of 

how Bonneville carries out its role in power supply in 

the future. The recommendations are intended to guide 

Bonneville as it develops its “future role” proposal in 

June, 2004, and to serve as a reference during “future 

role” deliberations among Bonneville, its customers, and 

interested parties over the coming months and years. 

The Council believes that decisions resulting from this 

deliberative process should be implemented as quickly as 

possible, and in a way that will provide the certainty, continuity, and durability required for the resource decisions 

that Bonneville and its customers will need to make over 

the next few years. 

It is important for Bonneville and its customers to 

resolve near-term issues affecting current contracts, 

most of which do not expire until 2011. The Council 

also recognizes the right of customers to stay with their 

current contracts. However, the pressure of near-term 

issues should not be allowed to detract from the efforts to 

resolve Bonneville’s future role for the long-term. Moreover, there is a great deal of overlap between many of 

these near-term issues and the long-term issues addressed 

here. Using the Council’s recommendations as a guide, 

Bonneville and its customers should resolve near-term 

contract issues in a manner consistent with a transition to 

Bonneville’s long-term future role. The Council intends 

to be an active participant in Bonneville’s “future role” 

process as it evolves.
2 Council Recommendations on the Future Role of Bonneville 
Council Recommendations on the Future Role of Bonneville 3

A fundamental change in how Bonneville 

carries out its role in power supply 

The region’s governors, the Council, most customers, 

and interested parties who have been engaged in recommending a new role for Bonneville believe a fundamental 

change is required in traditional power supply business practices. Those with a stake in the benefits of the 

Federal Columbia River Power System (FCRPS) believe 

Bonneville should transition toward a new role in marketing the FCRPS, providing power to eligible customers 

from the existing federal system at its embedded cost, 

and serving load growth that exceeds the capability of the 

existing federal system in such a way that customers requesting such service bear its costs and risks. This would 

result in an equitable distribution of the costs of growth. 

Customers that choose to take responsibility for their own 

load growth would not be exposed to the costs of new resources undertaken to serve the needs of other customers. 

Those that choose to have Bonneville serve their load 

growth would pay only the costs of serving their growth. 

Such a change would prevent the value of the existing 

federal system from being diluted by the higher costs of 

new resources. 

The change in Bonneville’s future role that the Council recommends does not alter Bonneville’s fundamental responsibility to serve the loads of those qualifying 

customers that choose to place load on Bonneville; it 

does not alter Bonneville’s responsibility for ensuring the 

acquisition of Bonneville’s share of all cost effective conservation and renewable power identified in the Council’s 

Plan; and it does not alter Bonneville’s responsibility to 

fulfill its fish and wildlife obligations under the Act and 

the Council’s fish and wildlife program. It does represent 

a change in the way Bonneville has traditionally carried 

out those responsibilities.

Conceptually, this revised role for Bonneville developed as an outgrowth of the 1996 Comprehensive 

Review and was carried forward in the 2002 Joint Customer “future role of Bonneville” proposal. Subsequent 

Council recommendations to Bonneville, and comment 

received during the latest round of regional dialogue 

discussions largely support the concept. Bonneville’s 

planned course of action in concluding the regional 

dialogue process is to submit a draft regional dialogue 

policy proposal to the region in June, to undertake consultations and a formal public comment process, and to 

adopt a final policy in the fall. 

Define a clear and durable policy framework for 

contracts and rate-making

The Council believes that debate in the region over 

the future role of Bonneville is less about the end-state, 

a limited role for Bonneville, than about how to reach 

that end-state. The Council acknowledges that both new 

long-term contracts and compatible rate structures will 

be necessary to fully implement the vision. However, 

the Council also believes that significant policy changes 

involving allocation of the existing federal system and 

re-structuring of Bonneville’s role in serving load growth 

and acquiring resources should not be accomplished 

through contract negotiations and associated rate processes; processes in which participation is practically 

and legally limited. The issues involved are matters of 

fundamental public policy that cut across the entire range 

of agency missions and can potentially affect the region 

in profound ways. A clear and durable policy framework 

established with broad regional participation is necessary. 

Beginning with the 1996 Comprehensive Review, the 

Council, many Bonneville customers and other interested 

parties have engaged in processes that ultimately recommended that Bonneville limit and condition its role in the 

region’s power supply in ways compatible with what is 

recommended here. Bonneville has attempted to satisfy 

regional resource objectives under the Act using tools 

such as policy statements, strategies, and records of decision leading to contract negotiations and rate processes. 

However, the Council, many Bonneville customers, and 

others do not believe these tools have been sufficient to 

provide the necessary level of policy durability. Customers are concerned that future power supply decisions will 

be made, only to discover that the intended changes in 

Bonneville’s role have not been implemented. 

There is a spectrum of means by which regional 

objectives might be definitively established. The most 

Recommendations
4 Council Recommendations on the Future Role of Bonneville 

durable alternative would be to establish policy through 

new legislation focused on specific issues. However, 

the Council believes the process of seeking legislation 

could entail unacceptable risks for the region. It is the 

Council’s position that desired objectives should first be 

attempted without legislation. 

In its draft recommendations, the Council proposed 

a middle ground alternative— encouraging Bonneville 

to take a decisive step and establish its new role through 

a substantive rulemaking that would create a binding 

policy before beginning contract negotiations and associated rate cases. Such a rule could have the force of 

law, similar to a statute, and bind the agency and those 

affected by the agency in all future implementing actions unless the formally established rule is amended or 

rescinded through the same administrative procedures 

process that establishes it. This approach, in conjunction 

with new long-term contracts and compatible rate structures, has the potential to avoid the risk of new legislation 

while providing a more binding and durable solution than 

Bonneville policy implementation has demonstrated in 

the past. 

During comment on its draft recommendations, many 

in the region, including Bonneville, had misgivings about 

the rulemaking process. These misgivings included 

whether Bonneville actually had the authority to undertake such rulemaking, whether such rulemaking would 

conflict with statutory directives regarding the establishment of rates, and whether such rulemaking might expose 

the region to risks of external federal reviews not typically associated with Bonneville decision processes. The 

Council is not convinced these concerns have had sufficient study. They may be valid, or they may not. However, the Council is sensitive to the concerns expressed in 

the region and will not press for substantive rulemaking 

at the present time. 

Policy should include the process and schedule for 

resolving issues

Given the foregoing, the Council accepts Bonneville’s present course of action to submit a draft policy 

proposal to the region in June; to undertake consultations and a formal public comment process; and to 

adopt a final policy in the fall. Nonetheless, the Council remains concerned that this policy process is not 

uniquely different from previous Bonneville policy processes. Bonneville needs to take steps to ensure that the 

final policy provides the durability necessary to meet 

Bonneville customer expectations for long-term contract 

negotiations and associated rate processes; and that the 

region’s expectations for conservation and renewable 

resource development are fulfilled. 

To improve the durability of the policy, the policy 

must include: clear identification of the priority issues 

that are to be resolved before the region can move to 

developing new contracts and rates; the process by which 

the issues will be addressed; and a detailed and aggressive schedule for doing so. Among the issues, the policy 

must be responsive to concern among customer utilities 

that the scope of the policy include sufficient “process” 

detail to guide utility decisions in long-term resource 

planning; the inclusion of provisions by which Bonneville intends to extend assurances of contract durability 

and enforcement in areas such as Bonneville cost control, 

dispute resolution, continuation of Bonneville’s role in 

conservation and renewables, fish and wildlife mitigation, 

and allocation of the existing federal power system. The 

schedule should include offering new contracts no later 

than October of 2007.

Consider alternative processes, if necessary

Should activities undertaken in response to the 

Bonneville policy prove inadequate to meet the schedule 

established for resolution of regional issues leading to 

development and offering of new contracts by October 

of 2007, then alternative means of resolving these issues 

should be considered. 

Some Bonneville customers may advocate legislative changes to the Act as a means of resolving difficult 

issues. The Council remains convinced that diverse 

proposals to amend the Act can introduce instability in a 

region already precariously balanced between opposing 

agendas for power, conservation, renewable resources, 

and fish and wildlife mitigation within the Columbia 

River Basin. Before considering legislation, the Council recommends that Bonneville and the Council work 

jointly to determine if substantive rulemaking under 

the Administrative Procedure Act can be a vehicle for 

resolving the outstanding issues. If so, such a rulemaking should be promptly undertaken. In preparation for 

this possibility, the Council will continue to work with 
Council Recommendations on the Future Role of Bonneville 5

Bonneville and regional interests on the relative merits of 

substantive rulemaking. 

Lacking agreement that substantive rulemaking is an 

appropriate substitute for a proposed amendment of the 

Act, the Council recommends that Bonneville and the 

Council work jointly to seek specific language for the 

proposed amendment. Public comment gathered through 

the public process could then be forwarded to the Northwest Congressional Delegation with separate recommendations or comments from Bonneville and the Council, 

as appropriate. Legislation should not be recommended 

without broad regional support, including consensus 

among the four Northwest governors. 

Offer long-term contracts as soon as possible

Long-term contracts (preferably 20-years) based on 

the Bonneville policy should be offered no later than 

October of 2007. New long-term contracts should be 

offered as soon as possible to provide as much certainty 

as possible for the development of new resources that 

will be needed. Resource decisions will almost certainly 

need to be made well before 2011. Although it would not 

be necessary for the new contracts to take effect before 

2011, offering new contracts by 2007 would provide the 

business certainty that the customers need regarding load 

serving responsibility after 2011. 

To be implement the new role for Bonneville, new 

contracts should be consistent with Bonneville’s policy 

in describing how power from the existing federal system 

will be allocated to customers, and the terms under which 

Bonneville will serve additional load beyond the capability of the existing federal system. The contracts must 

also incorporate necessary checks and balances to protect 

customers from unwarranted costs while ensuring that 

Bonneville is able to fulfill its responsibilities, including 

conservation and renewables, fish and wildlife mitigation, 

and timely repayment of debt. 

Cost Control and Business Practices

The biggest impediment to long-term contracts is 

the customers’ concern that by entering into long-term 

contract they will give up a major point of leverage to 

exercise discipline on Bonneville’s costs and business 

practices — their ability to take load off Bonneville. Issues of contract enforceability are prominent among the 

customers’ concerns. Bonneville and the customers have 

taken steps to provide greater transparency to Bonneville’s costs and decision processes through the Customer 

Collaborative and Sounding Board processes. These 

efforts should be continued. However, that is only part of 

the customers’ concerns. In particular, many customers 

are concerned by what they see as Bonneville’s practice 

of defining issues in such a way that disputes are adjudicated in the Ninth Circuit Court of Appeals, where the 

scope of judicial review is limited to the record established by Bonneville. The agency should use the upcoming regional dialogue policy to make clear the scope and 

limits to Bonneville’s authority in dispute resolution.

The Council believes that if the basic business construct proposed in these recommendations is implemented, a major pressure on Bonneville’s costs — the cost 

of augmentation for load growth beyond the capability 

of existing federal power system — will be limited. 

At the same time, the Council recognizes a different 

category of costs derived from Bonneville’s broader 

public purpose responsibilities under the Act. The successful fulfillment of these responsibilities will continue 

to require an active role by Bonneville, guided by the 

Council’s power plan and fish and wildlife program, and 

informed by broad public involvement, including input 

from Bonneville customers.

The benefits of long-term contracts are sufficient that 

all parties need to be open to examining ways in which 

concerns can be overcome. These concerns include 

system allocation, cost segregation, cost control, contract 

enforceability, dispute resolution, Bonneville business 

practices in general, and possible adverse impacts to 

Bonneville’s public service responsibilities under the 

Act. The Council commits to work with Bonneville, its 

customers, and others to identify a workable resolution of 

problems that may arise. 

Allocation of the existing system

Fundamental to implementing the changes in Bonneville’s role in power supply is allocating the power from 

the existing federal system among eligible customers. 

In the long-term model, it is a utility’s allocation of this 

power that would be purchased at the lowest embedded 

cost rate. A utility’s requirements above this level would 

either be met by the utility itself or by Bonneville, with 

the customer bearing the cost and risk of the additional 

resources required. Any implementation of tiered rates 
6 Council Recommendations on the Future Role of Bonneville 

under existing contracts should be consistent with the 

long-term model. 

Any allocation should be done in such a way as to 

minimize opportunities for gaming the process. For that 

reason the Council believes that, lacking agreement on 

any alternative basis, allocation should be based on customers’ historic net requirements placed on Bonneville, 

normalized for economic and weather effects. 

New or Annexed Public Loads

It is the Council’s understanding that Bonneville 

must ultimately serve all qualified public loads on a 

comparable basis. This includes the loads of newly 

formed public utilities or the loads of areas annexed by 

public utilities. The Council understands the dilemma 

that potential new public loads present. The possible 

dilution of the benefits of the existing system resources 

reduces certainty for customers. 

 Serving new or annexed public loads from the existing system would require either a reallocation of the 

existing federal system, which would result in all customers getting a reduced share, or augmentation of the 

existing federal system with the costs of that augmentation included in the cost of the existing federal system. 

However, before reallocation or augmentation would take 

effect, a waiting period of reasonable duration is needed 

to allow existing customers and Bonneville to make and 

implement necessary resource decisions. 

To make this process as equitable as possible, the 

amount of the new or annexed load that would qualify for 

service from the existing system should be determined on 

the same basis as the system allocation for existing public 

utilities described earlier. Utilities requiring additional 

power above that level would pay for the resources 

required to serve those loads—or the utilities could serve 

those loads themselves. 

Until reallocation took place, new publics or annexed areas could be served by Bonneville at the cost of 

the resources required to serve them—or by the new or 

annexing public itself. In cases where a new public was 

formed from IOU territory or IOU territory was annexed, 

a proportional part of the residential and small farm benefit would transfer to the new or annexing public utility 

until a reallocation of the federal system is carried out. 

Existing customers whose allocation is reduced as 

a result of new or annexed public loads would have the 

option of having Bonneville serve the amount of load that 

can no longer be served by the existing federal system at 

the cost of the resources required—or they could serve 

the loads themselves. 

Reduced Public Utility Loads 

There is the potential for a utility’s net requirements 

to fall below its allocation of existing system resources. 

This could well be a temporary phenomenon. The 

Council encourages Bonneville to use what flexibility 

it has to ensure that a utility’s long-term ability to access existing federal system power at its embedded cost 

rate not be unnecessarily diminished. In particular, the 

Council believes the risk of diminished access to existing 

system power would be a disincentive to development of 

cost-effective conservation. Should this become an issue, 

the Council encourages Bonneville to implement mechanisms to mitigate the problem. 

 Loss of Existing Federal System Resources

There is always the potential for the loss of resources 

from the existing federal system. If such loss were to occur, customers should have the option of having Bonneville replace their share and charge them the cost of 

replacement or of replacing the resource themselves. 

Tiered rates under current contracts?

Tiered rates would be the clearest practical indication of how Bonneville will be carrying out its role in 

the future. Nonetheless, if Bonneville’s role is defined 

as recommended and: 1) critical issues are resolved in 

a timeframe consistent with the schedule established in 

Bonneville’s policy; and 2) new contracts are negotiated and offered by October of 2007; the Council will not 

press for tiered rates under the current contracts for the 

next rate period. However, the Council reserves the right 

to reconsider this recommendation if the region is not 

meeting these conditions. 

Products 

Customers should have access to the full range of 

products that are currently available, e.g., requirements 

products, block products, and slice. What is important is 

that the costs of each product be confined to the purchas-
Council Recommendations on the Future Role of Bonneville 7

ers of that product. The costs of serving load growth 

should be confined to those purchasing that service, and 

every effort should be made to eliminate cross-subsidies 

among products. In the process of negotiating new contracts, customers should have the opportunity to choose 

the products that best meet their needs. 

Service to:

Direct Service Industries 

While Bonneville may contract to supply power to Direct Service Industries (DSIs), it is not required to do so. 

However, the decision not to serve some DSI load cannot 

be taken lightly. Some DSIs are still important sources of 

employment in their respective local economies. If a DSI 

has been a responsible customer of Bonneville—that is, if 

the DSI has not imposed stranded costs on Bonneville by 

substituting market purchase for federal power; has not 

rejected its Bonneville power contract in a bankruptcy 

proceeding; and has not defaulted on its payment obligation under an existing contract, there may be an opportunity to provide a limited amount of power for a limited 

duration under specified terms and conditions. 

The existing federal system is roughly in load/

resource balance. Consequently, some level of augmentation will probably be necessary to provide reasonably 

continuous service. If power is to be made available to 

DSIs, the amount and term should be limited; the cost 

impact on other customers should be minimized; and 

Bonneville should retain rights to interrupt service for 

purposes of maintaining system stability and addressing 

temporary power supply inadequacy. 

New Large Single Loads

Moving to a system whereby power from the existing 

federal system is allocated, and where additional power 

requirements are met at the cost of the power to serve 

them, essentially makes the question of new large single 

loads moot. Power for service to new large single loads 

would be served at the cost of the resource acquired to 

serve them. The choice of whether to meld those costs at 

the retail level would be the decision of the retail utility. 

Until such time as an allocation is made, the existing 

new large single load policy should be adhered to and such 

loads should not be included in subsequent calculations of 

a customer’s allocation of the existing federal system. DSI 

loads should not be allowed to migrate to local utilities and 

be included in the utilities allocation calculation.

Benefits for the residential and small farm 

customers of the region’s investor-owned utilities

The Council supports a resolution of the issue of 

benefits for the residential and small farm customers of 

investor-owned utilities (IOUs) for a significant period. 

Accomplishing this would be an indication of having achieved an equitable sharing of the benefits of the 

federal system between the customers of publicly owned 

utilities and the residential and small farm customers of 

the investor-owned utilities; it would resolve significant 

public/private disputes and would result in a broad crosssection of the region seeing a direct, long-term interest in 

preserving the Federal Columbia River Power System for 

the region.

This was the objective of the exchange settlement under the existing contracts. Given the litigation surrounding that settlement, the question of benefits for residential 

and small farm customers of the IOUs under the existing contracts may be decided by the courts. Otherwise, 

Bonneville should fulfill its obligations under the existing 

contracts within its existing authorities.

For the longer term, there is general agreement that 

the mechanism for sharing the benefits established in 

the Act has operated in such a way that it satisfies no 

one. However, “fixing” these features of the Act through 

legislative action could have broad regional ramifications. 

The Council is opposed to such legislation. 

This would appear to leave settlement as the only option. The objective of the exchange provisions of the Act 

was an equitable sharing of the benefits of low-cost federal power to the residential and small farm consumers of 

the region, no matter who served them: publicly-owned 

utilities or investor-owned. Under a settlement, benefits 

could be provided in the form of power or dollars. The 

Council believes that providing the benefits in the form 

of power is more risky for Bonneville and could make the 

question of allocation more difficult. 

The Council cannot judge what is equitable in the 

eyes of the parties. It is clear, however, that there are 

some desirable characteristics of a settlement that can be 

defined. It must provide certainty, it must be transparent, 
8 Council Recommendations on the Future Role of Bonneville 

and it must not be subject to manipulation. Certainty requires that the cost impact on publicly owned customers 

be capped on the upside and that there be a floor under 

the benefits for the residential and small farm customer 

of the IOUs. Transparency requires that the benefit be 

calculated in such a way that it is easily understood. And 

if it is not to be manipulated, the key parameters must be 

subject to independent verification. 

The recent proposed settlement contained these 

elements for the period of the current contract and was 

supported by most of the customers in the region. The 

Council believes this could be the template for a longterm settlement. One of the objections raised about the 

settlement was that it did not provide long-term certainty 

beyond the current contract period. Using this settlement 

as the starting point for the long-term solution would address that concern. 

The Council encourages all parties to carefully 

consider the benefits to be derived from substantially 

reducing the uncertainty surrounding the benefits to be 

provided for the residential and small farm customers of 

the IOUs. The Council believes this value is the basis for 

a successful compromise.

Fulfilling responsibilities for conservation 

and renewables

The Act requires Bonneville to prioritize cost-effective conservation and renewables in its role of providing 

new resources for the region. It is critical that these priority resources continue to be developed in the new role 

envisioned for Bonneville. The Council expects Bonneville and the region’s utilities to continue to acquire 

the cost-effective conservation and renewable resources 

identified in the Council’s power plans. Bonneville 

should employ mechanisms similar to the current C&RD 

program and provide essential support activities to 

encourage and facilitate utility action. Bonneville’s role 

will be substantially reduced to the extent that customers 

can meet these objectives. But if necessary, Bonneville 

must be prepared to provide a backstop mechanism to ensure that these objectives are met. Bonneville must retain 

the ability to secure its regional share of cost-effective 

conservation and renewables identified in the Council’s 

Plan that is not otherwise secured by its customers. The 

costs of the backstop actions would be the responsibility 

of the individual utilities that fail to meet their responsibilities. Contracts have to be consistent with preserving 

Bonneville’s ability to fulfill this obligation. 

Conservation

Many of the comments received raised serious questions with the Council about whether the Act’s directive 

to secure all cost-effective conservation would be met. 

These comments imply that if utilities face a marginal 

price signal, as is proposed in these recommendations, 

decisions regarding the implementation of conservation 

will be at the discretion of utilities, and utilities will have 

sufficient incentive to pursue these resources. The Council 

believes this ignores what the Northwest and other parts of 

the country have experienced. Conservation faces significantly greater obstacles than conventional generating 

resources, even though conservation may be more cost-effective.3

 This region has compiled an admirable record of 

conservation achievements over the last 20 years. However, it has not been easy. It has required constant attention 

from the Council and state regulatory agencies, and it has 

required significant institutional support from Bonneville. 

In particular, the role Bonneville has played in providing 

necessary regional infrastructure has been essential. While 

providing utilities with a marginal price signal should 

improve the situation, it is not sufficient. If it were, the 

record of conservation achievement in other parts of the 

country where utilities have uniformly faced marginal 

price signals would be much better than it is. 

The Act places a special emphasis on conservation. 

One of the fundamental premises of the Act is that by 

increasing the efficiency of all electricity consumption, 

from generation through transmission and distribution 

to its final end use, the region could extend the economic benefits of the region’s low cost hydroelectric 

system. The Act created an ongoing responsibility for 

Bonneville to acquire conservation to “reduce load,” not 

just meet load growth. And while the Council’s recommendations may reduce Bonneville’s responsibility for 

meeting load growth in the region, they would do so 

only for the duration of the contracts. Nothing prevents 

customers from bringing additional net requirements to 

3 These impediments include the fact that, due in part to the way in which many utilities currently structure their retail rates, conservation reduces 

utility revenues in the short term even while reducing long-term costs.
Council Recommendations on the Future Role of Bonneville 9

Bonneville at the end of the contract period. For these 

reasons, the Council continues to support its conservation recommendations. They are fundamentally the 

same as its December 2002 recommendations.4 In summary, those recommendations were:

• The system for conservation development 

should: 1) rely on the Council’s Plan to define 

the cost-effective resource; 2) rely on proven 

delivery mechanisms; 3) provide stabilized 

and adequate funding for conservation over the 

duration of the new contracts; 4) reinforce the 

role and capabilities of the Regional Technical 

Forum; 5) provide a mechanism for ensuring 

that cost-effective conservation is implemented; 

and 6) capture conservation at as low a cost to 

the power system as possible.

• Bonneville should establish conservation 

budgets based on Bonneville’s share of regional 

conservation potential identified in the Council’s 

Plan and estimated program costs to capture that 

conservation. However, conservation savings 

targets and mechanisms should be designed 

to encourage conservation on all loads of 

preference- customer utilities, not just the part 

served by Bonneville.

• Bonneville’s obligations and authority with 

respect to IOU conservation is limited to the 

residential and small farm loads of those utilities 

that are subject to the residential exchange. The 

Council, however, will continue to encourage and 

support the work of the states’ utility regulatory 

commissions to use their authorities and leastcost planning regulations to ensure that the 

cost-effective conservation on all IOU load is 

accomplished. 

• Conceptually, the Council supports the use of a 

mechanism like the C&RD program to support 

local implementation. However, the existing 

mechanism must be redesigned to ensure costeffective acquisitions, encourage best practices, 

and minimize the cost of acquisition consistent 

with achieving the savings. The mechanism 

also must limit expenditures on activities that do 

not clearly support the development of tangible 

savings and ensure accountability. 

• Further, the Council believes the mechanism 

should be designed to reduce the need for any 

Bonneville backstop mechanism. A better 

alternative would be to work with utilities 

at the outset to identify good opportunities 

and approaches. The discount could then be 

provided incrementally, addressing the local 

utilities’ immediate cash flow requirements. 

Subsequent payments would be made on 

demonstration of progress. Bonneville would 

step in only as a last resort.

Customers prefer a mechanism in which they are 

granted the full discount at the outset and only 

charged if a customer fails to take the actions 

necessary to achieve its target. The Council is 

willing to give consideration to such a model, 

but only if there are frequent (annual) progress 

checks and the ability for Bonneville to take 

action, if necessary, in response to the results of 

those progress checks. 

• The Council believes a broader range of 

conservation activities should be carried out at 

the regional level than what is described in the 

original customer proposal. This is necessary 

because there are a number of activities that 

can be carried out more effectively if they are 

approached on a coordinated regional basis 

with local implementation. These include 

activities like market transformation, limited 

development and demonstration activities, and 

program design and administration where there 

are significant economies of scale to be gained. 

In addition, Bonneville’s support of low-income 

weatherization should be continued.

Since these recommendations were developed, a few 

things have become clear. Customers have expressed 

an interest in continuing the status quo through the next 

rate period. The status quo is a half mill rate discount 

4 Council Document 2002-19, op. cit. pages 20-27
10 Council Recommendations on the Future Role of Bonneville 

with considerable built-in flexibility for “local conservation,” some funding of regional conservation approaches, 

as well as qualifying renewable resource activities from 

system revenues paid by all. That solution alone is not 

likely to capture all cost-effective conservation that has 

been identified during the development of the Council’s 

Fifth Power Plan. 

The region has benefited tremendously from the last 

20 years of conservation development. It has reduced 

loads about 2,800 average megawatts at a cost less than 

half of that of adding similar amounts of generation. The 

Council expects its future Plans will continue to identify 

significant cost-effective conservation potential that the 

region should pursue. This conservation is valuable to 

the region regardless of whether the region is developing 

new generation or not. However, given recent large retail 

rate increases, the Council believes Bonneville and the 

utilities may find it difficult to raise rates to adequately 

fund conservation activities as they have been implemented in the past.5

Therefore, the Council believes it is increasingly 

important that the region continue to enhance its conservation efforts to ensure that it is achieving conservation at the lowest cost to the utility system. Bonneville 

should use the full extent of its authority to ensure that 

all cost-effective conservation is captured in an efficient, 

low-cost, and timely way; and Bonneville should retain 

a strong and active role in the coordinated planning and 

implementation of conservation efforts across the region.

Bonneville should continue to support a rate discount 

mechanism for some conservation. However, a rate 

discount should not necessarily be the only mechanism. 

The C&RD program has been instrumental in motivating some utilities to pursue conservation and renewables 

activities, and it clearly expanded the portfolio of activities and measures deployed across the region. Those 

attributes should not be lost. But the rate discount needs 

to be refined along the lines recommended in 2002.6 

Bonneville and the Council should facilitate a collaborative process to refine the details of a rate discount and 

produce recommendations by early 2005. 

Furthermore, in addition to a rate discount, Bonneville 

should establish budgets and other mechanisms, including bilateral contracts with its customers, to ensure the 

development and local implementation of conservation 

and the full portfolio of activities and approaches. 

The Council believes there is a need for increased 

budgets for regional implementation activities including 

market transformation, cross service territory program 

design and marketing activities, and evaluation activities. 

Guided by the Council’s Plan, the region should come to 

agreement on the level of funding for regional implementation of conservation through a process facilitated by the 

Council. The goal should be to capture conservation at as 

low a cost to the power system as possible. 

Renewables

The C&RD mechanism has been used to support 

development of renewable resources, and the Council 

supports continuing this policy, so long as the cost-effective conservation is also acquired. 

Some advocate a pattern of “sustained orderly development” for renewable resources such as wind. This 

would translate into a megawatts-per-year target for renewables development. The Council continues to believe 

that levels of renewables development should be guided 

by the Council’s Plan that evaluates resources on the basis of cost and risk mitigation values. Where Bonneville 

is serving load growth, the Council expects Bonneville’s 

resource acquisitions to be consistent with the Council’s 

Plan, including renewable resources. The Council 

encourages those utilities that choose to take responsibility for meeting their own load growth to use their best 

efforts to acquire renewable resources consistent with the 

Council’s Plan, and for Bonneville to use its capabilities 

to facilitate such acquisition. 

There are some renewable resource development 

activities that Bonneville is uniquely suited to pursue, and 

that would not happen without its participation. These 

activities benefit all of Bonneville’s customers, and their 

costs should be recovered from the existing system. 

These include activities such as: 1) removing barriers 

to cost-effective renewable; 2) development of services 

5

 Conservation and renewables work group discussions.

6

 Council Document 2002-19, op cit.
Council Recommendations on the Future Role of Bonneville 11

and products such as storage and shaping, transmission 

re-dispatch products, and making transmission acquisition for renewables easier; and 3) limited, region-specific 

research and demonstration. The costs of actually providing services like storage and shaping should be paid 

by the purchaser. 

The Council expects this portfolio of activities will 

change over time as new cost-effective resources emerge 

and new implementation barriers are discovered. The 

Council’s Plan will identify some of these barriers. 

Bonneville and the Council should facilitate a process 

to periodically review and identify renewable resource 

activities and budgets suitable for funding by all Bonneville customers. 

Resource adequacy

Even without changes in the way Bonneville carries out its role in power supply, the issue of resource 

adequacy, and the possible need for adequacy measures 

to ensure that adequate power supplies are maintained, 

has been a major concern of the Council and others in 

the region. A change that places more risk and responsibility for meeting future load obligations on individual 

utilities rather than on Bonneville does not reduce 

overall risk. The Council is aware that new policies 

may be necessary to ensure that adequate information 

and safeguards exist to determine the power system’s 

adequacy. In particular, the Council is concerned about 

the possibility that a severe deficit by any one utility 

could have detrimental effects on other utilities in the 

region. This risk can only be removed if all utilities 

ensure an adequate level of resources.

The Council accepts the responsibility of working 

with all regional players including Bonneville, utilities, 

the states and their regulators, and other regional and 

West-wide organizations to ensure that appropriate adequacy policies are in place, and the data and other tools 

to implement them are available. The Council believes 

that these policies need to be in place prior to the implementation of long-term contracts.

Some of the commentors objected to the idea of a regulatory adequacy standard. The Council did not intend 

for a resource adequacy standard to be the only means for 

achieving resource adequacy. At this time, there is also 

no obvious mechanism to create or enforce an adequacy 

standard for all load-serving entities in the Northwest. 

There are, however, other options. For example, the 

Council could facilitate the development of adequacy 

benchmarks for the region and for individual utilities. 

These benchmarks would permit a systematic review of 

regional adequacy and allow utilities the opportunity to 

assess their own individual performance against their 

appropriate adequacy benchmark. There are, no doubt, 

other approaches to adequacy that the Council can help 

the region evaluate and ultimately implement.

Fish and Wildlife

The Council believes these policies will not affect 

Bonneville’s fish and wildlife obligations. Those obligations will be determined in a manner consistent with 

the requirements of the Act and the Council’s Columbia 

River Basin Fish and Wildlife Program. Costs should be 

allocated to the existing system. 
Council

Northwest

Power

Conservation

and

851 S.W. Sixth Avenue, Suite 1100

Portland, Oregon 97204

Telephone: 503-222-5161

Toll Free: 800-452-5161

Web site: www.nwcouncil.org