Page 1 DEPARTMENT OF ENVIRONMENTAL QUALITY

Chapter 340 Proposed Rulemaking
STATEMENT OF NEED AND FISCAL AND ECONOMIC IMPACT

This form accompanies a Notice of Proposed Rulemaking

Title of Proposed Rulemaking Revisions to DEQ Regional Haze BART rules for the PG E Boardman Power Plant

Adopt: OAR 340

- 223

- 0060, 340

- 223

- 0070, 340

- 223

- 0080, 340

- 223

- 0090

Amend: 340

- 200

- 0040, OAR 340

- 223

- 0010, 340

- 223

- 0020, 340

- 223

- 0030, 340

- 223

- 0040,

340

- 223

- 0050 Statutory Authority or other Legal Authority

Statutes Implemented O RS 468.020 & 468A.310

ORS 468A.025

Purpose and Scope of Fiscal Analysis DEQ Rulemaking

The purpose of this fiscal and economic impact statement is to describe the estimated costs, or range of estimated costs, associated with the rule proposal of the De partment of Environmental Quality (DEQ)

. The discussion below reflects the best information available to DEQ at the time of this writing, including information obtained from DEQ’s fiscal advisory committee.

T here are two main types of costs discussed in this document. The fi r st type of costs are those

that result from proposed rule requirements to install pollution control technology known as Best Available R etrofit T echnology (BART )

. The costs of these pollution controls would be

borne by the owners of the Boardman coal plant. The owners of the Boardman coal plant are

Portland General Electric (PGE ), San Diego Gas and Electric (SDG&E)/General Electric Capital Corporation (GECC), Idacorp, Inc., and Power Resources Cooperative (PRC). (Note:

as used in th is document, PGE and the other owners of the plant will be referred to as simply

“PGE” . See T able 7 on page 1 1 for the respective share of ownership ). As noted below, it is likely these costs would be passed on to plant customers through increased electr ic rates.

PGE has stated a desire for an option to close the Boardman coal plant in December 2020. Pursuant to federal law, t he level of pollution control that is needed to satisfy BART can vary, depending on the remaining useful life of the Boardman p ower plant (which is a direct result of any closure date). DEQ does not have the regulatory authority to mandate a specific closure date for the Boardman power plant. That decision rests with the owners of the Boardman plant

. DEQ’s rulemaking proposes th ree pollution control technology options for meeting federal

BART requirements

. Each option reflects the type and stringency of pollution control required to meet BART given three possible closure scenarios: 2020, 2018, or 2015/2016

. DEQ has

used t he dir ect capital and operating costs associated with installing and maintaining pollution

controls at the Boardman plant

- in comb inat ion with the remaining useful life of the plant , the amount of air pollution reduced, the degree of visibility improvement and other factors

- to
determine BART for each of the three closure options

.

The owners of the Boardman plant will presumably attempt to pass on the costs of these controls to customers of the Boardman facility, and these costs will likely translate into

in creased electricity rates (although any proposed increase in electricity rates in Oregon is subject to approval by the Oregon Public Utility Commission). As a result, t he second type of

costs discussed in this document are the costs to those who may be ec onomically affected by early closure of the Boardman plant. These costs include, for example, increased electricity

rates , loss of employment and loss of tax revenue

. These costs are not required to comply with the proposed rules, but rather may result i f the owners of the Boardman plant decide to clos e the plant.Page 2 These costs and broader affects are acknowledged and discussed here to provide the public

with a comprehensive re view of the estimated fiscal and economic impacts that may arise from

the owne rs’ decision to close the Boardman plant

. It is important to note that the proposed rules would not require early closure of the Boardman plant, and in fact, the proposed rules would provide the option of running the plant indefinitely. The purpose of th e proposed rules is to establish the regional haze pollution control requirements that would be applicable if the owners of the Boardman plant independently decided to close the plant early. Only the owners of the Boardman plant have authority to close th e plant early.

Impact Groups Covered in this Document

This document describe s potential costs to seven key groups : the general public, small business, large business, local government, state agencies, including DEQ, and tribal nations.

For each of t he groups discussed below, DEQ describe s the capital and operating costs of DEQ’s BART options, as well as DEQ’s best estimate of likely rate increases that could be attributed to the BART control technology costs.

DEQ has included a section on page 1 5 that provides information provided by PGE o n the likely rate impacts that could result if PGE deci des to close the Boardman facility. These costs

include a wider range of activities including decommissioning the coal plant

, and the potential cost of replac ing the power generated by Boardman. DEQ also included information about the potential effects on employment and local government tax revenues that could result if PGE decides to close the Boardman facility early. In addition, DEQ recognizes the potentia l health benefits resulting from a Boardman plant closure.

Need for the Rule(s) Oregon Regional Haze Plan and PGE Boardman rules

To meet federal Clean Air Act requirements, DEQ must develop a series of regional haze plans to reduce haze pollution and improve visibility in Oregon wilderness areas and national parks

, as required under the federal regional haze rule . The Oregon Environmental Quality

Commission (EQC) adopted the state’s first regional haze plan in 2009. DEQ’s regional haze analysis sho ws that the PGE Boardman coal

- fired power plant is the largest individual source of haze pollution in Oregon

, causing significant visibility degradation and acid deposition in 14 national parks and wilderness areas in Oregon and Washington and the Columbia River Gorge National Scenic Area. Oregon’s 2009 Regional Haze Plan can be found at DEQ’s website at www.deq.state.or.us/aq/haze/index.htm

.

The 2009 Regional Haze Plan included emission control ru les for the PGE Boardman plant. These rules are currently in effect, and must be implemented unless revised by the EQC and approved by the Environmental Protection Agency. The 2009 Boardman rules require an initial phase of controls for sulfur dioxide ( SO 2 ) and oxides of nitrogen ( NO

x ) pollution that would reduce these emissions by about 66 percent by 2014, at a cost of about $306 million, and a second phase of more advanced NO

x controls that would provide a total reduction of 80 percent by 2018, at an addi tional cost of $192 million

. 1

On April 2nd, 2010

, PGE submitted a petition to the EQC to revise the existing air pollution control rules for the Boardman plant. In the petition, PGE proposed an alternative approach for meeting federal regional haze requir ements to install Best Available Retrofit Technology (BART), by using low sulfur coal to meet BART, and eliminating other pollution control requirements, in conjunction with early closure of the plant by December 31, 2020.

On June 17, 2010 the EQC denied PGE’s petition and directed DEQ to begin rulemaking to provide a broader range of control option s consistent with an early closure. DEQ developed

1 Cost estimates are in 2010 dollars.Page 3 three draft control option s for the Boardman power plant, which meet federal BART requirements. These optio ns are discussed in the “Overview” section below

. ( See also DEQ’s 2010 BART Report for the PGE Boardman Plant for more information.)

DEQ solicit ed initial public input on its th ree draft control option s during the month of July 2010. The public was encouraged to send comments to DEQ’s website, and these were considered by DEQ in developing this rule proposal. As noted above, DEQ also consulted with a fiscal advisory committee , w hich met on August 4, 2010 to provide additional input on

the likely costs associated with DEQ’s control option s

. A formal public comment period will be held during the month of September 2010

. DEQ intends to present its final rule

recommendation to the EQC in December 2010.

Documents Relied Upon for Rulemaking DEQ relied on the following documents in considering the need for and in preparing this rule, and for estimating the fiscal and economic effects related to this rulemaking:

1. EPA guidance for Best Available Control Technology www.deq.state.or.us/aq/haze/docs/bartcontrol.pdf

2. DEQ ’s 2010 report on BART recommendations for PGE Boardman www.deq.state.or.us/aq/haze/docs/pge/attachAreport.pdf

Copies of these documents and the complete list of documents DEQ used in its analysis can be reviewed at the DEQ office at 811 S.W. 6th Avenue, Portland, Oregon. Pleas e contact Brian Finneran at (503) 229

- 6278 for times when the documents and the complete list are available

for review.

Requests for Other Options Pursuant to ORS 183.335(2(b)(G), DEQ requests public comment on whether other options

should be considered for achieving the rule’s substantive goals while reducing negative economic impact of the rule on small business.

Fiscal and Economic Impact, Statement of Cost Compliance The following estimates of fiscal and economic impacts are based on DEQ’s best ava ilable information, experience with the 2009 PGE Boardman regional haze rules and information provided by PGE to estimate possible electricity rate increases. It should be noted that a ny future rate increases in Oregon are contingent on approval by the Or egon Public Utility Commission (PUC).

o DEQ also relied upon a fiscal advisory committee which met on August 4, 2010, to assist the agency in evaluating the financial consequences (scope and e ffect) of DEQ’s proposed options.

The fiscal advisory committee members represented a cross section of interests likely to be affected by DEQ’s propos ed rules , and who had expertise in assessing fiscal and economic impacts such as those associated with the controls proposed for PGE Boardman, and the likely

rate increas es that could affect the customers served by owners of the Boardman plant, including small businesses. The committee reviewed a draft of this Fiscal Impact Statement to determine if DEQ had reasonably characterized the costs and impacts of the proposed op tions, with special emphasis on potential impacts to small business. A summary of the fiscal advisory committee August 4 th meeting can be found at www.deq.state.or.us/aq/haze/shutdown.htm

.

Ret rofitting pollution controls on the PGE Boardman power plant is a major construction project, and will require a very complex engineering and construction effort. There are many variables that affect the cost of such a project, including future labor and material costs and the market pricing for pollution control equipment. Given the large and complex nature of this type of project, DEQ is providing an estimate of the capital and annual operating costs of the required emission controls. This assessment do es not estimate the benefit of reducing air pollutants associated with a Boardman early closure, such as greenhouse gas emissions, because DEQ lacks information needed to make an accurate estimate

.Page 4 The three options in DEQ’s proposed rule are based on the closure of the Boardman plant at various dates. DEQ’s proposed rule options would not require the owners to close the plant ; rather it would give the owners the choice to select one of the three option s or to implement the existing 2009 rule requirements

. DEQ is proposing to include all of these options because the owners have not yet made a final decision about whether and when to close the plant. In addition to the cost of BART controls, this decision will be affected by many factors outside

the contr ol of DEQ, including the potential costs of future federal legislation to reduce greenhouse gas emissions, the potential costs of future federal regulations to reduce hazardous air pollutants, the potential costs of litigation regarding previous modificati ons at the plant, the supply and cost of alternate sources of power, future demand for electricity, and the ability of the owners to recover costs from ratepayers. The proposed rules require the owners to select an option no later than June 30, 2014, by w hich time they will have more information about

these factors.

PGE’s decision to close the Boardman power plan t would result in a variety of costs, but also should involve significant cost savings. These would include the avoided costs of more stringent r egional haze pollution controls, the avoided costs of greenhouse gas regulation, and

t he avoided costs of future federal air quality regulation. DEQ lacks information to make accurate estimates of these cost savings.

Overview Summary of DEQ’s Proposed Th ree BART Options in this r ulemaking:

DEQ’s options below would meet federal requirements for BART, and are consistent with an early closure approach. If adopted, these options would be added to the existing regional haze rules adopted in 2009 for the Boardman plant. DEQ is proposing to adopt all three options

and allow PGE to select the option that matches the closure date the owners select for the plant

. If PGE selects none of these options, the existing 2009 rule s would apply. The existing

2009 ru le s would allow PGE to run the plant indefinitely and do not contain any closure

deadline

.

Each option below weighs factors such as the scope and magnitude of the air quality degradation caused by Boardman’s’ air pollution, the stringency necessary for re quired BART controls in light of different closure dates, the technical feasibility of retrofitting controls, and the cost effectiveness of those controls given different closure dates. Cost effectiveness is influenced by the remaining useful life of the facility (i.e. the closure date). In the following options, DEQ has identif

ied the emission control package that would be approvable as BART

for each closure date . Conceptually, the more expensive the emission control package, the longer the Boardman fac ility needs to operate to avoid exceeding the BART cost effective ness threshold . Less costly emission control packages would only meet BART with an earlier shutdown. For example, DEQ would consider an SO 2 scrubber necessary to meet the BART requirements i f the plant operates beyond the end of 2018, but DEQ would consider a dry sorbent injection system to be sufficient to meet BART if the plant closes earlier.

Option 1

- 2020 shutdown: This option would set the same NO

x limit (based on low

- NO

x burners) in 2011 and the same SO 2 limit (based on scrubbers) as the 2009 rules. Given an early shutdown in 2020, the additional NO

x limit in 2017 (based on SCR) would be replaced with a

NO

x limit in 2014 based on Selective Non

- catalytic Reduction (SNCR). SNCR is mu ch less expensive than SCR, and can reduce NO

x by 9 percent more than the limit based on the low

NO

x burners alone. 2 This option would achieve the same 46 percent reduction in NO

x in 2011

2 SNCR was not required as part of the 2009 rules. It was not considered cost

- effective when combined with the SCR controls required in 2017. Subsequently, DEQ has learned that SNCR can achieve a lower emission rate, and cost slightly less, than previously determined. Adding SNCR to the low NOx burners provides additional visibility benefit, and without SCR, is now considered cost

- effective under Options 1 and 2, but not Option

3.Page 5 and 80 percent reduction in SO 2 in 2014, an additional 9 percent red uction in NO

x in 2014,

none of the additional NO

x reductions in 2017, and eliminate all emissions from the coal plant after 2020. The estimated cost of this option is approximately $320 million, or $177 million

less than the 2009 controls.

Option 2

- 201 8 shutdown: This option includes the same NO

x limit (based on low

- NO

x burners) in 2011 as the 2009 rules. Given an early shutdown in 2018, the 2014 SO 2 limit based on scrubbers would be replaced with an SO 2 limit based on Dry Sorbent Injection (DSI), at

si gnificantly less cost. Like option 1, the more stringent NO

x limit in 2017 based on SCR would be replaced by a NO

x limit in 2014 based on SNCR. This option would achieve the same

reduction in NO

x in 2011, but only half of the reduction in SO 2 in 2014, an additional 9 percent

reduction in NO

x in 2014, none of the additional NO

x reduction in 2017, and eliminate all emissions from the coal plant after 2018. The estimated cost of this option is approximately $103 million, or $394 million less than 2009 control s.

Option 3

- 2015/2016 shutdown: This option would set a NO

x limit based on low NO

x burners in 2011, and no other emiss i on limits. The shutdown date in this option is based on the requirement to install BART controls within five years of federal approva l of a state regional haze plan. Since Oregon’s 2009 Regional Haze Plan is expected to be approved by the EPA in late 2010 or early 2011, this option establishes a shutdown date in five years, or by 2015 or 2016. This option would achieve the same reductio n in NO

x in 2011, and eliminate all emissions from the coal plant after 2015/2016. The estimated cost of this option is approximately $36 million, or $462 million less than 2009 controls.

Note: All three options would still require the Boardman plant to comply with DEQ’s existing mercury rules in 2012.

Table 1 summarizes the three control option s, compared to the 2009 rules

.

Table 1: Summary of 2009 Rules and DEQ proposed three options

Option Controls/Installation Date Capital

Cost (million $) Cost

savings

from 2009

rules (million $) Emission

reduction (tons/year
+ percent ) Additional

Em ission

reduction

after c los e date (tpy) 2011 (NO

x ) 2014

(SO 2 ) 2017

(NO

x )

2009

Rules LNB/MOFA Semi

- dry

Scrubber SCR $497.6

- 20, 8 00 (81%) n/a

Option 1 ( 2020 ) LNB/MOFA

/SNCR Semi

- dry

Scrubber - $320.6 $177 17,800 (69%) 7,700

Option 2 ( 2018 ) LNB/MOFA

/SNCR DSI

- $102.6 $395 10,600 (41%) 14,900

Option 3 ( 2015

- 16 ) LNB/MOFA

- - $35.7 $46 2 4,800 (19%) 20,900

Key to Table:

LNB/MOFA = Low NO

x burn ers with modified overfire air system.

SNCR = Selective Non

- Catalytic Reduction system.

Semi

- dry Scrubber, also known as semi

- dry flue gas desulfurization system. DSI = Dry Sorbent Injection SCR = Selective Catalytic Reduction.

Triggering of PSD from Opt ion 2 DSI System

As noted above in the description of DEQ’s Option 2, the SO 2 controls would consist of a dry sorbent injection system. P ermitting r ules for PM2.5 may result in the DSI system triggering DEQ’s P revention of S ignificant D eterioration (PSD) rules , under OAR 340

- 224

- 0070. A DSI
system installed at the PGE Boardman plant could cause an increase in PM2.5 emissions greater than the significant emission rate (10 tons/yr). If that occurred, PGE would be requiredPage 6 to install best available control technology and conduct an air quality impact analysis to ensure

the increase does not exceed the PSD increment or ambient air quality standards for PM2.5. DEQ cannot determine what will be required until accurate emission estimates are available.

Howeve r, it is possible that the existing electrostatic precipitator at the Boardman plant may satisfy the best available control technology requirement. In addition, the emission increase may not be great enough to cause a significant impact on the PSD increme nt or ambient air quality standard for PM2.5

.

However, if the emissions do cause an adverse impact, PGE may be required to install a fabric

filter to reduce the PM2.5 emissions , which would increase the cost of the DSI system considerably

. DEQ estimate s that DSI with a fabric filter could achieve 0.305 lb/MMBtu heat input (50% overall collection efficiency). Using this as the basis for the emission reduction

, the cost effectiveness of the system is estimated at $6,700/ton, which DEQ still consider s to be cost effective for Option 2 under federal BART rules . The details of this analysis are provided

in A ttachment A of DEQ’s 2010 report on BART recommendations for PGE Boardman

www .deq.state.or.us/aq/haze/docs/pge/attachAreport.pdf . Adding the fabric filter to the DSI system will also reduce the visibility impacts , and could also increase the estimated rate

increases in Table 4 and Table 12

.

Due to the uncertainty at this time re garding the PM2.5 emissions increase and the air quality impact, this fiscal analysis does not include the fabric filter costs as part of Option 2. As noted above, DEQ has included cost estimates for the fabric filter based on currently available

informat ion on the possible triggering of PSD under Option 2. Any further analysis of whether a fabric filter will be required is too speculative and not addressed in this document.

PGE’s Recommended Alternative to Option s 1 or 2

At the August 4, 2010 fiscal ad visory committee meeting, PGE requested that DEQ consider a change to DEQ’s options for meeting BART

, where PGE would commit to installing DSI, but based on a 2020 shutdown date, rather than 2018, and only after conducting a pilot study to

determine the te chnical feasibility of DSI controls, and i f the SO 2 emission limit identified by DEQ c an be met. This alternative would increase visibility impacts, but could reduce the

estimated rate increases in Table 4 and Table 12. For additional information on PGE’ s recommendation , see PGE’s July 30, 2010 letter “PGE Comments on DEQ’s Proposed Revisions to its Regional Haze Rules”

, at DEQ’s PGE Boardman website or go to www.deq.state.or.us/aq/haze/shutdown.htm#moreInfo

.

Upcoming Federal Hazardous Air Pollutant Emission Standard

In March 2011 the Environmental Protection Agency is expected to propose new rules to

address hazardo us air pollutant s from power plants like the PGE Boardman plant. Final adoption of these rules is expected in November 2011. It is anticipated that the rules will address acid gases (HCl and HF), as well as mercury. The same types of controls considered for the BART rules, or perhaps even more stringent controls, could be required by EPA under

t hese new rules

. If EPA requires the same or more stringent controls, then the fiscal and economic impact of DEQ’s proposed rules would be less, because the costs of the controls proposed by DEQ would already be required by federal law. Since the se rules have not been proposed, however, it would be too speculative at this time to assess their potential effect on the fiscal and economic impact of DEQ’s proposed rul es

.

Public Health and Environmental Benefits

C losure of the Boardman coal

- fired boiler would permanently eliminate approximately 25,500

ton s of air pollution per year , including visibility impairing pollutants of sulfur dioxide and nitrogen oxide, and w ell as fine particulate, and mercury (an air toxic). DEQ expect s this reduction would have a significant heath benefit for the public; however, DEQ cannot at thisPage 7 time estimate these benefits in term of health costs or dollars saved because it lacks the

n ecessary and complicated data to estimate those types of benefits

. However, DEQ does recognize that these health benefits do exist.

T he three BART options would reduce emissions from the Boardman plant in the range of 4,800 to 17,800 tons/year prior to the proposed clos ure date, and an additional 7,700 to 20,900 tons/year

after closure . This would significantly improve visibility in 14 federal wilderness areas in Oregon and Washington, as well as the Columbia River Gorge National Scenic Area. See DEQ’s 2010 BART Report for the PGE Boardman Plant for more information on the visibility benefits from the emission reductions under the three options. In addition to visibility benef its, the emission

reductions would reduce the plant’s contribution to acid deposition in areas such as the Columbia Gorge, which poses risk to sensitive ecosystems and valued cultural resources, such as Native American rock images. In addition, closure of the Boardman plant would eliminate approximately 4,000,000 tons of greenhouse gas emissions in Oregon. DEQ cannot estimate the benefits from this reduction in dollar terms, because it lacks information that would help it accurately

estimate those benefits

, but these benefits should be recognized.

Types of Costs

The fiscal and economic impacts of these three options can be summarized as follows. F irst, there will be costs to the owners of the Boardman power plant for installing and operating new polluti on control technology. Second, costs to the owners of the Boardman power plant will likely be passed on to customers served by the plant through increased electric rates. DEQ’s estimated rate increases associated with each option are summarized in the se ctions below. Any potential rate increase will be contingent on future actions taken by the PUC. Third, closing Boardman could result higher rate increases and eliminat ion of jobs associated with running the power plant , and have impacts on the local tax base and economy . Fourth, closing the Boardman power plant would also result in decreased revenue to DEQ fr o m permit and emission fees paid by Boardman under the Title V permit pr o gram , which is a significant portion of the total fees DEQ receives under this program

.

Table 2 below summarizes the estimated total capital costs and annual costs for the control option s , compared to the 2009 rules . The total annual cost would increase for Option 1 (2020 closure) and decrease significantly for Option 2 (201 8 closure) and Option 3 (2015

- 2016 closure).

Table 2: Cost comparison

- 2009 rules vs. DEQ three options

Option Capital

Costs (Million $) Indirect

Annual Cost *
(Million $) Direct Annual

Cost **
(Million $) Total Estimated

Annual Cost ** *
(Million $)

Current 2009 rules 497.6 47 20 67 Option 1 (2020 closure) 320.6 60.6 16.1 76.7 Option 2 (2018 closure) 102.6 24 4.9 28.9 Option 3 (2015

- 16 closure) 35.7 9.7 0.7 10.4

* The indirect annual cost i s determined by amortizing the capital costs over the rem aining useful life of the plant.

** The direct annual costs are the costs associated with operation and maintenance of the controls.

* * * The t otal estimated annual cost is the sum of the indirect and direct annual cost s

.

Table 3 shows the annualized emiss ion reductions and cost for the control option s compared to

the current 2009 BART rules, based on the capital costs annualized out to 2040 and additional emission reductions from closure of the plant

. This information is included as a means of comparing t he cost of the three options to the total emission reductions from the BART

controls and the closure of the plant

. This was not part of DEQ’s BART determination, as the federal BART criteria requires the remaining life of the equipment be considered ( or i n this case, the early shutdown dates

. ) However, Table 3 does give a sense of cost/benefit of thePage 8 three options when compar ed to the current BART rules for PGE Boardman.

For example, under the current 2009 rules, it is assumed the plant will operate un til at least

2040

. Even after the required controls are installed, the plant would continue to have emissions, whereas under the three options, all emissions would be eliminated. Table 3 below

show s that for the current 2009 rules

, over the 30 year perio d the average annual cost per ton is $2,520. If compared to Option 3, the table shows that the BART controls would reduce Boardman emissions until 2016, after which the emissions would be zero. Over a 30

- year period the average annual cost per ton would $74. This low cost reflects the cost of the

controls in Option 3, divided by the average emissions from 2010 to 2016

, and no emissions

from 2017 to 2040. Again, this table is included here to provide additional information on the

cost/benefit of the three options, but is not one of the criteria for evaluating BART controls.

Table 3: Annualized emission reduction and c ost

- 2009 rules vs. DEQ three options *

Option Average Annual emission

reduction through 2040 (tons/year) Average Annual cost

per ton through 2040

Current 2009 rules 18,410 $2,520 Option 1 (2020 closure) 21,453 $837 Option 2 (2018 closure) 20,888 $249 Option 3 (2015

- 16 closure) 22,103 $74

* This table does not include the emissions or cost of replacement power that may be required under early closure options

.

Estimated Rate Increases by Class

Table 4 summarizes the estimated rate increases for different rate classes, comparing the 2009

rules for the PGE Boardman plant to the three proposed control option s , based on the cost of

BA RT controls



### . To estimate potential rate increases, DEQ used the methodology used by PGE

in their 20 10 rate increase request to the PUC. See the section on “Assumptions” on page 1 6

for additional information on rate increas e estimation. See also Attachme nt A for a detailed breakdown of possible rate increases

.

Table 4 : Estimated rate increases

- 2009 rules vs. DEQ proposed three options *

Estimated Rate Increases from DEQ Proposed Rule Options

Rate Class Current 2009

PGE BART

Rule Option

- 1

Estimated Ra te

Increase Option

- 2

Estimated

Rate Increase Option

- 3

Estimated

Rate Increase

Residential/

Commercial 2.56% 2.93% 1.11% 0.37%

Irrigation & Drainage 1.58% 1.80% 0.68% 0.23%

Small non

residential 2.57% 2.93% 1.11% 0.37%

Large non

residential 3.31% 3.78% 1 .43% 0.48%

Traffic Signs 3.06% 3.50% 1.32% 0.44%

Lighting 1.39% 1.59% 0.60% 0.20% Average 2.84% 3.24% 1.22% 0.41%

* This table only includes potential rate increases caused by the cost of pollution controls under DEQ’s proposed rules. See Table 12 fo r PGE’s estimate s of potential rate increases due to costs of early closure, includ ing plant decommissioning and potential replacement power costs.Page 9 Rate increases are subject to approval by the PUC. DEQ anticipates that PGE would request a

rate increase to recover the cost of complying with DEQ’s rule. DEQ anticipates that the other owners of the Boardman plant would make similar requests to the boards that govern electricity rates in their jurisdictions.

Impacts on the
General Public BART Costs asso ciated with DEQ Rule

DEQ estimates that its proposed rule options could impact the general public by increasing electricity rate s for customers of the four utility companies that own the Boardman plant , listed

in Table 7 on page 1 1

. Some of these custome rs may reside outside of Oregon. For Oregon residents, t hese impacts are contingent on the Oregon PUC approving any rate increase request

from PGE. DEQ has estimated the potential range of rate increase to the general public due to

the BART emission cont rol technology as follows.

Table 5 : Estimated rate increases

– General Public *

Estimated Rate Increases from DEQ Proposed Rule Options

Rate Class Current 2009

PGE BART

Rule Option

- 1

Estimated Rate

Increase Option

- 2

Estimated

Rate Increase Option

- 3

Esti mated

Rate Increase

Residential/

Commercial 2.56% 2.93% 1.11% 0.37%

* This table only includes potential rate increases caused by the cost of pollution controls under DEQ’s proposed rules. See Table 12 for PGE’s estimate s of potential rate increases due to costs of early closure, includ ing plant decommissioning and potential replacement power costs.

In addition to rate increase s
, a decision to close the Boardman plant would affect the current employees of the plant. The plant currently employs 110 full

- time workers, 30 contractors, and 225 seasonal workers. Another economic impact would be to secondary jobs, estimated to be 3

- 4 times the primary jobs. This means a potential impact of up to 1000 primary and secondary jobs in the region, if the plant we re closed.

PGE has indicated it would seek to replace the power generated by the Boardman plant if the plant closes, and some of the employment impact s could be offset if PGE builds a natural gas plant at or near the current Boardman plant, or other for m of electrical generation plant that provides new employment opportunities. Based on PGE estimates, and assuming PGE received regulatory approval to build a 600 megawatt natural gas plant, such as plant would employ about 25 full

- time staff. PGE is curr ently i n the permitting process for a new but

smaller facility at the Boardman plant location, and it’s possible the coal

- fire d boiler could be replaced in the future with a new boiler burning another type of fuel. Whether current employees at the coal pl ant wo uld work at any new facilities is a decision for PGE

. This assessment does not estimate the benefit of replacement power on employment because DEQ does not know if replacement power generating capacity will be added at the Boardman location, exactly how many individuals might be employed at a replacement plant, and other information needed to make an accurate estimate. See also the section s below on impacts to small businesses and local governments.

Impacts to Small

Business (50 or fewer employee s

– ORS183.310(10)) BART Costs associated with DEQ Rule

Based on discussion s with its f iscal advisory c ommittee, DEQ finds that DEQ’s proposed rule options c ould have a significant adverse impact on small businesses by increasing electricity

rate s . This i mpact would be limited to those businesses that are customers of the four utility companies that own the Boardman plant , and are also contingent on the Oregon PUC approving any rate increase request from PGE. A summary of the fiscal advisory committee Aug ust 4 thPage 10 meeting can be found at www.deq.state.or.us/aq/haze/shutdown.htm

.

Table 6 below summarizes the potential range of rate increase s to small businesses due to

the BART emission control tec hnology

.

Table 6 : Estimated rate increases

– Small B usinesses *

Rate Class Current 2009

PGE BART

Rule DEQ Option

- 1

Estimated Rate

Increase DEQ Option

- 2

Estimated

Rate Increase DEQ Option

- 3

Estimated

Rate Increase

Residential/

Commercial 2.56 % 2.93% 1.11% 0.37%

Large non

residential 3.31% 3.78% 1.43% 0.48%

Average 2.93% 3.24% 1.22% 0.41%

* This table only includes potential rate increases caused by the cost of pollution controls under DEQ’s proposed rules. See Table 12 for PGE’s estimate s of potential rate increases due to costs of early closure, includ ing plant decommissioning and potential replacement power costs.

Small business customers within other rate classes would likely experience lower rate

increases. See also Table 4 for other applicable rate classes.

DEQ and its fiscal advisory committee discussed whether there were any options for mitigating the cost to small businesses without undermining the environmental goal of the

rule . One committee member pointed out that any impacts on small bu sinesses would be even more significant due to the current poor economic conditions in Oregon and the

nation . Another comment was made that PGE’s new proposal recommending an alternative to Options 1 or 2 also represents a lower cost, and could mitigate t he cost to

small businesses , providing the alternative is determined to meet BART

.

DEQ also recognize s that if PGE decide s to close the Boardman coal plant , any resulting job losses may have a ripple effect to some small businesses within the comm unity through

loss of sales

. This could include impacts on secondary jobs, estimated to be 3

- 4 times the primary jobs at the plant, as noted in the prior section on impacts to the general public

. DEQ does not have any information with which to estimate t he possible dollar impacts

involved.

In addition, reducing air pollution at the Boardman facility will affect DEQ revenue generated through emission fees, and potentially require a change in the fee structure of the Title V air quality permitting program. This could affect small and large businesses and government agencies holding Title V permits. See the section below (Impacts to DEQ), and the subsection

ti t led: Associated potential impacts to businesses and agencies holding Title V air quality permits.

The next section illustrates that DEQ’s rule proposal does not impose any regulatory or reporting requirements on small businesses.

Cost of Compliance on
Small Business (50 or fewer employees

– ORS183.310(10)) a) The estimated number of

small business es subject to DEQ’s proposed rule. None.

b) The types of businesses and

industries with small businesses subject to DEQ’s proposed rule. None.Page 11 c) The projected reporting, recordkeeping and other administrative activities required by small busines ses for compliance with DEQ’s proposed rule. None.

d) The equipment, supplies, labor, and increased administration required by small businesses for compliance with DEQ’s proposed rule. None.

e) A description of the manner in which DEQ involved s mall businesses in the development of this rulemaking. DEQ’s Fiscal Advisory Committee included representatives from

Associated Oregon Industries, Port of Morrow, and DEQ’s small business Compliance Assistance Program (CAP). The public, including small

bus iness, was also invited to provide initial comments to DEQ prior to DEQ initiating formal rulemaking in September 2010.

Impacts on Large
Business (all businesses that
are not “small
businesses” under ORS183.310(10)) BART Costs associated with DEQ Rule

DEQ ’s proposed rule options will directly impact the owners of the Boardman plant which are large businesses, because DEQ’s proposed rule options appl y only to that plant. DEQ understands the owners to be Portland General Electric (PGE), San Diego Gas an d Electric (SDG&E)/General Electric Capital Corporation (GECC), Idacorp, Inc., and P ower Resources Cooperative (PRC). Table 7 below summarizes the proportional annual ized

costs of the BART emission control technology requirements for each of the four plan t

owners under each DEQ option

.

Table 7 : P roportional costs by owner

- 2009 rules vs. DEQ proposed three options

Plant

Owner Share of

Ownership 2009 Rule

Proportional

Cost Option

- 1

Proportional

Cost Option

- 2

Proportional

Cost Option

- 3

Proportional

Cos t

PGE 65% $43,529,200 $49,890,866 $18,769,661 $6,768,344

SDG&E/

GECC 15% $10,045,200 $11,513,277 $4,331,460 $1,561,926

PRC 10% $6,696,800 $7,675,518 $2,887,640 $1,041,284
Idacorp 10% $6,696,800 $7,675,518 $2,887,640 $1,041,284

Total 100% $66,968,000 $ 76,755,179 $28,876,401 $10,412,83 8

Note : the relative percent ownership in the Boardman facility may change over time as

lease agreements between PGE and other companies expire or are renegotiated.

DEQ estimates that its proposed rule options c ould have a negative impact on other large

businesses by increasing electricity rate s . This impact would be limited to those businesses

that are customers of the four utility companies that own the Boardman plant , and are contingent on the Oregon PUC approving any rate increase request from PGE. DEQ has estimated the potential range of rate increase s to large businesses due to the BART emission control technology as follows:

Table 8 below summarizes the potential range of rate increases to large businesses due to the BART emission control technology.Page 12 Table 8 : Estimated rate increases

– Large Business *

Estimated Rate Increases from DEQ Proposed Rule Options

Rate Class Current 2009

PGE BART

Rule Option

- 1

Estimated Rate

Increase Option

- 2

Estimated

Rate Incr ease Option

- 3

Estimated

Rate Increase Large non

residential 3.31% 3.78% 1.43% 0.48%

* This table only includes potential rate increases caused by the cost of pollution controls under DEQ’s proposed rules. See Table 12 for PGE’s estimate s of potential r ate increases due to costs of early closure, includ ing plant decommissioning and potential replacement power costs.

Large business customers within other rate classes would likely experience lower rate

increases. See also Table 4 for other applicable rat e classes.

In addition, reducing air pollution at the Boardman facility will affect DEQ revenue generated through emission fees, and potentially require a change in the fee structure of the Title V air quality permitting program. This could increases fee s for businesses and agencies holding

Title V permits. Since most Title V sources are large businesses, this potential increase in fees could more directly affect large businesses. See the section below on Impacts to DEQ and the

subsection ti t led “ Associ ated potential impacts to businesses and agencies holding Title V air quality permits ”

.

Impacts on Local

Government BART Costs associated with DEQ Rule

DEQ estimates that its proposed rule options could impact local government in two ways. One

is the potentially significant economic impact s on the local economy , such as the City of

Boardman

, Morrow County , and local service districts if PGE chooses to close the Boardman

coal plant. The plant currently employs 110 full

- time workers, 30 contractors, an d 225

seasonal workers. Based on information from the Port of Morrow, t hese jobs provide an

estimated payroll of $20

- 25 million annually to citizens that reside in Morrow and Umatilla Counties. Another economic impact would be to secondary jobs, estimate d to be 3

- 4 times the primary jobs. This means a potential impact of up to 1000 primary and secondary jobs in the region, if the plant were closed. The net impact could potentially exceed $50 million to the local economy.

The property taxes from the P GE Boardman plant generate approximately $2.8 million per year in revenue to local government, which represents 15 to 18 percent of the revenue to each government entity in Morrow county. These taxes pay for health services and public safety,

which could be significantly impacted if the plant were to close

. These adverse impacts could extend beyond the city and county level, and potentially to the region as a whole. There is also potential lost revenue from state income taxes, should the plant close. DE Q lacks adequate

information to estimate the extent of these economic impacts to the region and the state

.

PGE is planning construction of a new natural gas power plant at approximately the same location as the Boardman coal plant, and may choose to con struct other similar power plants, or convert the existing Boardman plant to a different fuel type. Th ese action s could help offset any economic impact to local governments of closing the coal plant but DEQ lacks information to accurately estimate these p otential offsets

.

The second impact to local government could be an increase in electricity rates for units of local government who are customers of the four utility companies that own the Boardman plant. These impacts are contingent on the Oregon PUC ap proving any rate increase request from

PGE. DEQ has estimated the potential range of rate increase to local government due to the BART emission control technology as follows. These rate impacts assume local governmentsPage 13 are charged according to the “large nonresidential” rate class. Local government customers within other rate classes would likely experience lower rate increases. See a lso Table 4 for other applicable rate classes.

Table 9 : Estimated rate increases

– Local Governments *

Estimated Rate Inc reases from DEQ Proposed Rule Options

Rate Class Current 2009

PGE BART

Rule Option

- 1

Estimated Rate

Increase Option

- 2

Estimated

Rate Increase Option

- 3

Estimated

Rate Increase Large non

residential 3.31% 3.78% 1.43% 0.48%

* This table only includes pot ential rate increases caused by the cost of pollution controls under DEQ’s proposed rules. See Table 12 for PGE’s estimate s of potential rate increases due to costs of early closure, includ ing plant decommissioning and potential replacement power costs.

It should be noted that the above estimated rate increases could affect county community action programs that administer state and federal low

- income heating assistance programs. Increases in utility rates often increase the demand for these programs, req uiring counties to handle more information requests, applications, one

- on

- one client support and advocacy, and referrals.

In addition, reducing air pollution at the Boardman facility will affect DEQ revenue generated through emission fees, and potentially require a change in the fee structure of the Title V air quality permitting program. This could affect small and large businesses and government agencies holding Title V permits. See the section below on i mpacts to DEQ, and the subsection

“ Associated pot ential impacts to businesses and agencies holding Title V air quality permits. ”

Impacts on State Agencies other
than DEQ BART Costs associated with DEQ Rule

DEQ estimates that its proposed rule options could impact other state agencies by increasing

e lectricity rate s for units of state government who are customers of the four utility companies that own the Boardman plant. These impacts are contingent on the Oregon PUC approving any rate increase request from PGE. DEQ has estimated the potential range of rate increase to state government due to the BART emission control technology as follows. These rate impacts assume state governments are charged according to the “large nonresidential” rate class. State government customers within other rate classes w ould likely experience lower rate increases.

See al so Table 4 for other applicable rate classes.

Table 10 : Estimated rate increases

– State Agencies *

Estimated Rate Increases from DEQ Proposed Rule Options

Rate Class Current 2009

PGE BART

Rule Option

- 1

Estimated Rate

Increase Option

- 2

Estimated

Rate Increase Option

- 3

Estimated

Rate Increase Large non

residential 3.31% 3.78% 1.43% 0.48%

* This table only includes potential rate increases caused by the cost of pollution controls under DEQ’s proposed r ules. See Table 12 for PGE’s estimate s of potential rate increases due to costs of early closure, includ ing plant decommissioning and potential replacement power costs.

Impacts on DEQ BART Costs associated with DEQ Rule

DEQ estimates that its propos ed rule options could impact its operations in two ways. Any increase in electricity rates for units of state government would also affect DEQ operations thatPage 14 are customers of the four utility companies that own the Boardman plant listed earlier

. These

i mpacts are contingent on the Oregon PUC approving any rate increase request from PGE. DEQ has estimated the potential range of rate increase due to the BART emission control technology as follows. These rate impacts assume that DEQ operations which are cus tomers of Boardman are charged according to the “large nonresidential” rate class. DEQ operations (that are customers of Boardman) within other rate classes would likely experience lower rate increases.

See a lso Table 4 for other applicable rate classes.

Table 1 1 : Estimated rate increases

– DEQ *

Estimated Rate Increases from DEQ Proposed Rule Options

Rate Class Current 2009

PGE BART

Rule Option

- 1

Estimated Rate

Increase Option

- 2

Estimated

Rate Increase Option

- 3

Estimated

Rate Increase Large non

reside ntial 3.31% 3.78% 1.43% 0.48%

* This table only includes potential rate increases caused by the cost of pollution controls under DEQ’s proposed rules. See Table 12 for PGE’s estimate s of potential rate increases due to costs of early closure, includ ing plant decommissioning and potential replacement power costs.

In addition, under each BART option DEQ would experience a lo s s in revenue from the installation of pollution control technology. DEQ charges all Title V sources fees based on

emissions. If emis sion s are reduced , DEQ’s fees and revenue necessary to fund the Tile V permitting program are reduced. DEQ would experience an additional loss of revenue if

PGE elects to close the Boardman coal plant (i.e. eliminating all permit and emissions fees

from th at operation).

Under the 2009 Boardman rules, annual emission fee revenue from the Boardman plant drop s

to approximately $225,000 after installing the Phase

- 2 NO

x controls in 2017. Under the various closure options, DEQ’s Title V revenue from the Boardma n facility (permit and emission fees)

will be significantly reduced to various degrees in the 2015

- 2020 timeframe depending on

which option is selected by PGE. Revenue losses for DEQ could be as high as approximately $380,000 a year. DEQ would completely lose this revenue if PGE closes the coal fire d boiler

. DEQ could regain some revenue (permit and emission fee s ) if PGE constructs a replacement power facility, however DEQ cannot accurately estimate this revenue because it depends on

future action s by PG E.

S ince Option 1 and 2 do not include Phase

- 2 NO

x controls

, the emissions are higher after 2017

and the fees would be $360,000 and $380,000 respectively

, until the 2020 and 2018 closure

dates

. Therefore, some fee revenue would continue for 1 to 3 year s
, afte r which DEQ would lose this funding

. This is not the case u nder Option 3 due to the earlier closure in 2015

- 16

.

Associated potential impacts to businesses and agencies holding Title V air quality permits.

By statute, DEQ must charge fees to holder s of Title V air quality permits in an amount
sufficient to support DEQ’s operation of the Ti t le V permitting program . A significant loss in

revenue from any of the BART options for PGE Boardman would require DEQ to adjust the

fee structure of the Ti t le V program in order to ensure adequate DEQ permitting resources and

customer service to Title V permi t tees

. This could result in a DEQ request to the Oregon legislature for a fee increase that would affect all businesses and agencies holding T itle V air

qua lity operating permits. DEQ cannot calculate the likely fee increase at this time, as it depend s on which BART option PGE selects in the future.Page 15

Impact on Tribal

Nations BART Costs associated with DEQ Rule

DEQ estimates that its proposed rule option s could impact tribal nations

, including the

Confederated Tribes and Bands of the Yakama Nation, and Confederated Tribes of the

Umatilla Indian Reservation

, by increasing electricity rate s . This could affect tribal members, businesses, and government, who are customers of the four utility companies that own the Boardman plant

. The rate classes listed in Table 4 on page 9 show these potential rate

increases

.

In addition to rate increases, there are other potential economic impacts under the proposed

rul e options that could affect tribal nations. As noted above in the sections on the general public and local government, a decision to close the Boardman plant would result in job loss

, and would be expected to have an economic impact in Morrow and Umatilla counties, an d potentially the region as a whole. DEQ lacks adequate information to estimate if these job losses will occur; and if so, the extent of these economic impact s

. DEQ does

, however

, recognize these potential negative economic impacts on tribal nations, should PGE choose to close the

Boardman coal plant. Also

, as noted above in the local government section, where there are currently state and federal low

- income heating assistance programs , increases in utility rates would be expected to increas e the demand for these programs

.

PGE Closure Cost

Estimates

– Rate Impacts PGE Closure Costs

– Rate Impacts

If PGE chooses to close the Boardman coal plant, PGE will need to address a variety of costs, including decommissioning the coal plant

, capital recovery on investments, replacement power, revenue requirements, salvage costs, property taxes, and others

. These costs and potential rate impacts would be described in PGE’s Integrated Resource Plan and reviewed by

the PUC.

Again, DEQ does not have t he regulatory authority to mandate a specific closure date for the Boardman power plant. That decision rests with the owners of the Boardman facility. The

costs of closure are not attributable to DEQ’s rule and will not be included in the calculation of

B ART cost effective ness

. However, PGE’s decision to close the Boardman facility (whenever that occurs) will likely have an effect on electricity rates for customers of the Boardman facility, as well as other affects. These costs and broader affects are ac knowledged and

discussed here to provide the public with a more comprehensive re view of costs and affects

.

Table 1 2 shows PGE’s estimated rate increase for each BART option includ ing the cost of

BART

, as well as estimates on the cost of replacement power , decommissioning the plant, the future cost of carbon controls, and other costs associated with a PGE decision to close the facility. This information was provided by PGE during the August 4, 2010 fiscal advisory committee meeting. The table shows PGE’s estimate of the average rate increase and the selected highest one year rate spike that could occur in connection with the three closure dates in DEQ’s options. The rate analysis provided by PGE did not include expected rate impacts by

rate class , but ju st an average rate increase

.

PGE’s estimated rate increases assume that the Boardman plant will be replaced by the construction of a new natural gas power plant. PGE has not provided DEQ an analysis of the technical and economic feasibility of other alt ernatives for replacement power, and one member of the fiscal advisory committee questioned whether other alternatives might be cheaper, and whether the natural gas price forecasts and load growth forecasts underlying PGE’s estimates were too high and resu lted in inflated estimates of rate increases.

PGE’s estimated rate increases also include changes to the estimated costs for emission control equipment needed to comply with some of the options. DEQ does not have adequate

information to evaluate the ac curacy of these revised costs at the time of this writing.Page 16 For these reasons, DEQ welcomes additional information on replacement power costs and other aspects of PGE’s cost estimates during the public comment period. 3

Table 1 2 : PGE Estimated rate incre ases *

PGE Rate Increase Comparison DEQ Option 1

2020 Closure DEQ Option 2

2018 Closure DEQ Option 3

2015/16 Closure Average Increase

2011

- 2021 4.6% 3.2% 3.9%

Single Highest Year /%

i ncrease 2017/6.7% 2019/6.8% 2016/7.4%

Cumulative Nominal Impact by 2021 ($/Millions) $958 $677 $824

* This table includes PGE’s estimate of potential rate increases caused by compliance with the proposed rules, as well other costs of closing , including decommissioning the plant

, and potential replacement power costs.

T he rate analysis provided by PGE, and included in this document, is based on higher estimated costs for SO2 controls (i.e. semi

- dry flue gas desulfurization control technology) than were used by DEQ in its analysis. DEQ’s assumed costs are based on an est imate of $270

million that was provided by PGE on April 2, 2010. On August 10, 2010, PGE submitted to DEQ a draft revised SO2 control cost estimate of $352 million. DEQ will evaluate this new cost information during the public comment period.

Assumptio ns DEQ has accurately estimated the range of costs associated with its proposed rule options for

the Boardman plant, given all the complexities of estimating costs for projects of this scale and the information available to DEQ at the time of this writing

.

“Cost of Compliance” refers to costs to comply with the proposed rules borne by the entities directly regulated under the proposed rules (i.e. the owners of the Boardman facility). There are other associated costs that could include impacts to Boardman ’s customers, employees, and the local governments involved.

“Fiscal impact” and “economic impact” are used interchangeably throughout the document.

To estimate potential rate increases, DEQ used the methodology used by PGE in their 20 10

rate increase request to the PUC. In the rate increase request, PGE listed costs associated with several activities, including power generation, transmission, distribution, etc. It is assumed that costs associated with BART compliance will be included in the power ge neration cost

category.

DEQ’s estimates of rate increases are based on best available information. DEQ has used its past experience with its recent PGE Boardman rules to estimate the range of possible electricity rate increases associated with this prop osal, and relied upon information provided by PGE as well as input from the Fiscal Advisory Committee. Actual future rate increases will also be subject to the rate setting process governed by the PUC.

The affect of any potential pollution control tax c redits are not included in these cost estimates.

3 It is important to note that, based upon available information, this fiscal impact statement estimates fiscal and economic im pacts with sufficient accuracy to notify the public, businesses and government that their interests may be affected by the proposed rules.Page 17

Housing Costs 

### DEQ estimates that the proposed rule options may have a small negative impact due to the

possible increased cost of the electricity used to construct a house . The possible impact

appears to be minimal because DEQ has estimated the maximum possible increased cost of electricity at 2.5 6 percent for residential customers



### . However, DEQ cannot fully quantify this impact for the development of a 6,000 square foot parcel and the construction of a 1,200 square foot detached single family dwelling on that parcel because the information available to DEQ for the amount of electricity used for the development is not adequate to form a reasonable estimate, and any such estimate would be speculation. A m inimal amount of electricity is needed to construct a house and DEQ did not find information on the cost of electricity to develop a parcel.

Administrative Rule Advisory Committee DEQ formed a fiscal impact advisory committee in accordance with the Orego n Administrative Procedures Act, ORS 183.310 et seq. (APA ) and to meet the requirements in ORS 183.333.

T he committee helped evaluate the fiscal and economic impacts of this rulemaking and provided recommendations to DEQ. A summary of the f iscal a dvisor y co mmittee meeting on August 4, 2010 can be found at www.deq.state.or.us/aq/haze/shutdown.htm

.

_________________________________ ____ _____________ ________________ __________
_______ Prepared by Printed name Date

_________________________________ _________________ ________________ __________________ Approved by DEQ Budget Office Printed name DatePage 18 

### Attachment A

Supplemental cost information

1. Co sts related to 2009 PGE Boardman rules:

2. Costs related to 2020 Control option :Page 19 

### 3. Costs related to 2018 Control option :

4 . Costs related to 2015

- 16 Control option :