# .\..,'

October 

### 22. 2010
Mr. Dick Pedersen Executive Director Oregon DepartmentofEnvironmental**Quality~** 

### 811 SW 6th 

### Avenue Portland, OR 97204
Dear Mr. Pedersen:
The Citizens' Utility Board, Renewable Northwest Project, Angus Duncan, Oregon Environmental Council, and NW Energy Coalition (the "Group") herebyrequestthatyou, inyourrole as Director ofthe Department ofEnvironmental Quality ("DEQ") and representative ofthe Oregon Environmental Quality Commission ("EQC"), re-open the Regional Haze BestAvailable Retrofit Technology ("BART") rulemaking record to considerthe agreementbetween the Group and Portland General Electric Company ePGE") reflected in the enclosed letters dated October 

### 22,2010.
Over the pastmonth, the Group and PGE have engaged in significant stakeholder discussions around the cessation ofcoal-fired operations at the Boardmanplant and, the process for developinglow-carbon portfolio scenarios thatwould satisfyPGE's reSDurce requirements. As reflected in the enclosed letters, the Group has agreed to supporta plan thatceases Boardman coal-fired operatiDns no laterthan December 

### 31,2020 (butdoes nDt exclude otherclosure dates), as a part ofa comprehensive plan that 

### (1) makes significant emissions reductiDns under the Clean Air Act; (2) allDws flexible emissionlimitssimilar to. the mercury rule-to. accDmmDdate the prDposed cDntrol technolDgy propDsed byDEQi (3) n1eets the least-cost/least-riskstandard; and (4) is accompanied by meaningful commitments by PGE to develop IRP candidate resource pDrtfoliD options thatachieve specific 

### COz reduction targetsto. be defined by the Group, in consultatiDn with PGE.
Ifsuch a plan can be finally approved byDEQ, the EQC and the Environmental PrDtection Agency, PGE 

### will
cease coal-fired operations atBDardman atleast 20 years early and achieve significant emissions reductions in the interim. In 

### all. Oregon will have achieved a significant environmental victory.

We appreciateyou consideringourrequestto. enterthis letter, and the two. enclDsed letters, into. the record, and we thankyou for yourwork on this matter over the past several years. Sincerely,

# ~P)~**~t.f1L** Bob Jenks, Citizens' Utility Board Andrea Durbin, OregonEnvirDnmental Council

# ~~,**~'r~~~-'** L 

### Rachel Shimshak, Renewable Northwest PrDject Angus Duncan

Sara PartDn, NW Energy CoalitionOctober 22, 2010

Mr. Jim Lobdell Vice President, Power Operations and Resource Strategy Portland General Electric Company 121 SW Salmon Street Portland, OR 97204

DearMr. Lobdell:
Certain members ofthe public interest community, including to date, the Citizens' Utility Board ("CUB"), the Renewable Northwest Project, Angus Duncan, Oregon Environmental Council, and the NW Energy Coalition (the "Group"), have been in discussions with Portland General Electric Company ("POE") about POE's method ofconstructing Boardman candidate replacement resource portfolio options to be considered in the Oregon Public Utility Commission's ("OPUCn ) Integrated Resource Planning process related to the cessation ofBoardman coal-fired operations. The Group and POEhave also been discussing the Group's support for cessation ofBoardman coal-fired operations at the Oregon Department ofEnvironmental Quality ("DEQ"), the Environmental Quality Commission 

### C'EQC") and the OPUC. This letter represents the Group's understanding ofits role withrespect to these discussions, and should be read in the contextofthe corresponding letterofthe same date from Jim Lobdell, POE, to Bob Jenks, CUB dated October 22, 2010 (the "PGELetter").
The Group supports a plan that is similarto POE's BART

# m proposal that would cease coal-fired operations at Boardman no laterthan December 31,2020 as a part ofa comprehensive plan (the "Plan") that satisfies the Clean Air Act 

### ("CAN') and makes significant emissions reductions, meets the leastcost/least-risk standard, and is accompanied by commitments to a good faith process, within POE's next IRP process and sanctionedby the OPUC, to develop a limitednumber ofcarbon reduction candidate
resource portfolio options for replacing Boardman upon cessation ofits coal-fired operations, and meeting the anticipated resource requirements ofthe utility's customers. The portfolios 

### will be designed to achieve the best combination ofexpected costs and associated risks and uncertainties for POE and its customers, and also reduce the carbon footprint ofthe company's resource portfolio over time. The Group agrees that 

### it will, in consultation with POE, define specific CO2 reduction targets on which these portfolios can be based. Such portfolios will be evaluated against other constructed resource portfolios developed during the lRP process.
The Group strongly believes that greenhouse gas and criteria pollutant reductions consistent with Oregon's climate goals and CleanAir Act standards are compatible with safe, reliable and affordable utility electricity service, and that POE, in its disposition ofBoardrnan and in its next lRP, can serve as a leader in achieving these outcomes, andproviding a clean energy future for Oregon. We invite POE to embrace this leadership position and would assist the company in realizing this vision.
The DEQ 2018 and POE BART III proposals now under consideration have many similarities, but differ in their treatment ofoperating flexibility. We encourage DEQ to develop appropriately flexible emission limits-similar to the mercury rule-to accommodate the proposed control technology recommendations, while achieving significant emissions reductions under the CAA.

### Mr. Jim Lobdell October22,2010 Page 2 of2

All members ofthe Group, including individuals speaking on behalfofthe Group, will immediately:

• Workin good faith with PGE for adoption and implementation ofthe Plan. Members ofthe**Group~rei:ijiifnffee** ·to aavocateariiriYfimeand iil-anYpiocess(iifulifdfifgaftheOPUC) ·fo1'·· elimination ofa 2040 date, or any date later. than 2020, for terminating coal-fired operations at Boardman.
• Advocate strongly for the Plan in comparison to other Boardman emission control options being considered in public and private forums and communications, including the following:
o Department ofEnvironmental Quality: Speak strongly in favor and/or file written comments at any additional hearings or comment periods prior to an EQC decision;
o Environmental Quality Commission: Speak strongly in favor athearings and public meetings where public comments on the Plan are taken and/or file written comments supportive ofthe Plan at the appropriate times;
o Environmental Protection Agency: Speak strongly in favor at hearings and public meetings where public comments on the Plan (i.e., Boardman BART State Implementation Plan approval) are taken and/or file written comments supportive ofthe Plan at the appropriate times;
o Oregon Public Utility Commission: Speak strongly in favor and/or file written comments supportive ofthe Plan, including the Boardman replacement power process described in the PGE Letter at appropriate scheduled times. The Group's advocacy will include seeldng OPUC acknowledgment ofthe Boardman replacement powerprocess.
Members ofthe Group will comment in otherpublic venues, includingprint and broadcast media, strongly in favor ofthe Plan and consistentwith the content ofthis letter and the PGELetter, including co-authorship with PGE ofajoint opinion editorial bythe Group that will generally reflect the content of these letters, including spealdng to the importance ofthe Plan to cease coal-fired operations atBoardman and the replacement resource process that will enable PGE's transition to a cleaner, low-carbon resource portfolio, tobe filed with the Oregonian and other relevant news outlets prior to the EQC decision on this matter.
The Group commits to using its best efforts and to work in good faith and adhere to the OPUC's prevailing IRP guidelines and process.
Thank you for taking the time to engage inthese discussions. Sincerely.

# ~I)~ Bob Jenks. Citizens' Utility Board Andrea Durbin, Oregon Environmental Council

# ~~- .



## .. Rachel Shimshak, Renewable Northwest Project Angus Duncan

# ~ Sara Patton, NW Energy Coalition