.\..,' 


October 22. 2010 

Mr. Dick Pedersen 

Executive Director 

Oregon Departmentof Environmental 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") hereby request that you, in your role as Director of the 

Department of Environmental Quality ("DEQ") and representative of the Oregon Environmental Quality 

Commission ("EQC"), re-open the Regional Haze Best Available Retrofit Technology ("BART") rulemaking 

record to consider the agreement between the Group and Portland General Electric Company ePGE") 

reflected in the enclosed letters dated October 22,2010. 

Over the past month, the Group and PGE have engaged in significant stakeholder discussions around the 

cessation of coal-fired operations at the Boardman plant and, the process for developing low-carbon 

portfolio scenarios that would satisfy PGE's reSDurce requirements. As reflected in the enclosed letters, 

the Group has agreed to support a plan that ceases Boardman coal-fired operatiDns no later than 

December 31,2020 (but does nDt exclude other closure dates), as a part of a comprehensive plan that (1) 

makes significant emissions reductiDns under the Clean Air Act; (2) allDws flexible emission limitssimilar to. the mercury rule-to. accDmmDdate the prDposed cDntrol technolDgy propDsed by DEQi (3) 

n1eets the least-cost/least-risk standard; and (4) is accompanied by meaningful commitments by PGE to 

develop IRP candidate resource pDrtfoliD options that achieve specific COz reduction targets to. be defined 

by the Group, in consultatiDn with PGE. 

If such a plan can be finally approved by DEQ, the EQC and the Environmental PrDtection Agency, PGE will 

cease coal-fired operations at BDardman at least 20 years early and achieve significant emissions 

reductions in the interim. In all. Oregon will have achieved a significant environmental victory. 

We appreciate you considering our request to. enter this letter, and the two. enclDsed letters, into. the 

record, and we thank you for your work on this matter over the past several years. 

Sincerely, 

~P)~ ~t.f1L 

Bob Jenks, Citizens' Utility Board Andrea Durbin, Oregon EnvirDnmental Council 

~~, ~'r~~~-' L 

Rachel Shimshak, Renewable Northwest PrDject Angus Duncan 

Sara PartDn, NW Energy Coalition 

October 22, 2010 

Mr. Jim Lobdell 

Vice President, Power Operations and Resource Strategy 

Portland General Electric Company 

121 SW Salmon Street 

Portland, OR 97204 

Dear Mr. Lobdell: 

Certain members of the 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 of Boardman coal-fired operations. The Group and POE have also been 

discussing the Group's support for cessation of Boardman 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 of its role with respect to these discussions, and should 

be read in the context of the corresponding letter of the same date from Jim Lobdell, POE, to Bob Jenks, 

CUB dated October 22, 2010 (the "PGE Letter"). 

The Group supports a plan that is similar to POE's BART mproposal that would cease coal-fired 

operations at Boardman no later than December 31,2020 as a part of a 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 sanctioned by the OPUC, to develop a limited number of carbon reduction candidate 

resource portfolio options for replacing Boardman upon cessation ofits coal-fired operations, and meeting 

the anticipated resource requirements of the utility's customers. The portfolios will be designed to achieve 

the best combination of expected 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 Clean Air 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, and providing 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 of operating 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 

October 22,2010 

Page 2 of2 

All members of the Group, including individuals speaking on behalf of the Group, will immediately: 

• Work in good faith with PGE for adoption and implementation ofthe Plan. Members of the 

Group~rei:ijiifnffee ·to aavocateariiriYfimeand iil-anYpiocess(iifulifdfifgaftheOPUC) ·fo1'·· 

elimination of a 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 at hearings 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 of the 

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 of the Boardman replacement power process. 

Members ofthe Group will comment in other public venues, including print and broadcast media, 

strongly in favor of the Plan and consistent with the content ofthis letter and the PGE Letter, including 

co-authorship with PGE of a joint opinion editorial by the Group that will generally reflect the content of 

these letters, including spealdng to the importance of the Plan to cease coal-fired operations at Boardman 

and the replacement resource process that will enable PGE's transition to a cleaner, low-carbon resource 

portfolio, to be 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 in these 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