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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 PGE 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

ORS 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 Department 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. 

There are two main types of costs discussed in this document. The first type of costs are those 

that result from proposed rule requirements to install pollution control technology known as 

Best Available Retrofit Technology (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 this document, PGE and the other owners of the plant will be referred to as simply 

“PGE”. See Table 7 on page 11 for the respective share of ownership). As noted below, it is 

likely these costs would be passed on to plant customers through increased electric rates. 

PGE has stated a desire for an option to close the Boardman coal plant in December 2020. 

Pursuant to federal law, the level of pollution control that is needed to satisfy BART can vary, 

depending on the remaining useful life of the Boardman power 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 three 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 the direct capital and operating costs associated with installing and maintaining pollution 

controls at the Boardman plant - in combination 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 

increased electricity rates (although any proposed increase in electricity rates in Oregon is 

subject to approval by the Oregon Public Utility Commission). As a result, the second type of 

costs discussed in this document are the costs to those who may be economically 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 if the owners of the Boardman plant decide to close

the plant. 
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These costs and broader affects are acknowledged and discussed here to provide the public 

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

the owners’ 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 the 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 the plant early. 

Impact Groups Covered in this Document

This document describes 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 the groups discussed below, DEQ describes 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 15 that provides information provided by PGE on the 

likely rate impacts that could result if PGE decides to close the Boardman facility. These costs 

include a wider range of activities including decommissioning the coal plant, and the potential

cost of replacing 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 potential 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 shows 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 rules 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 (SO2) and oxides of nitrogen (NOx) 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 NOx controls that would provide a total reduction of 80 percent 

by 2018, at an additional 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 requirements 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 options consistent with an early closure. DEQ developed 

 

1 Cost estimates are in 2010 dollars.
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three draft control options for the Boardman power plant, which meet federal BART 

requirements. These options are discussed in the “Overview” section below. (See also DEQ’s 

2010 BART Report for the PGE Boardman Plant for more information.)

DEQ solicited initial public input on its three draft control options 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, which met on August 4, 2010 to provide additional input on 

the likely costs associated with DEQ’s control options. 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. Please 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 available 

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 any 

future rate increases in Oregon are contingent on approval by the Oregon 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 effect) of DEQ’s proposed options. 

The fiscal advisory committee members represented a cross section of interests likely to be 

affected by DEQ’s proposed 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 increases 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 options, 

with special emphasis on potential impacts to small business. A summary of the fiscal 

advisory committee August 4th meeting can be found at 

www.deq.state.or.us/aq/haze/shutdown.htm.

Retrofitting 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 does 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.
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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 options 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 control 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 modifications 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 which time they will have more information about 

these factors.

PGE’s decision to close the Boardman power plant would result in a variety of costs, but also 

should involve significant cost savings. These would include the avoided costs of more 

stringent regional haze pollution controls, the avoided costs of greenhouse gas regulation, and 

the 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 Three BART Options in this rulemaking:

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 rules would apply. The existing

2009 rules 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 required 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 identified 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 facility needs to operate to avoid exceeding the BART cost effectiveness 

threshold. Less costly emission control packages would only meet BART with an earlier 

shutdown. For example, DEQ would consider an SO2 scrubber necessary to meet the BART 

requirements if 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 NOx limit (based on low-NOx

burners) in 2011 and the same SO2 limit (based on scrubbers) as the 2009 rules. Given an early 

shutdown in 2020, the additional NOx limit in 2017 (based on SCR) would be replaced with a 

NOx limit in 2014 based on Selective Non-catalytic Reduction (SNCR). SNCR is much less 

expensive than SCR, and can reduce NOx by 9 percent more than the limit based on the lowNOx burners alone.2 This option would achieve the same 46 percent reduction in NOx 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. 
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and 80 percent reduction in SO2 in 2014, an additional 9 percent reduction in NOx in 2014, 

none of the additional NOx 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 - 2018 shutdown: This option includes the same NOx limit (based on low-NOx

burners) in 2011 as the 2009 rules. Given an early shutdown in 2018, the 2014 SO2 limit based 

on scrubbers would be replaced with an SO2 limit based on Dry Sorbent Injection (DSI), at 

significantly less cost. Like option 1, the more stringent NOx limit in 2017 based on SCR 

would be replaced by a NOx limit in 2014 based on SNCR. This option would achieve the same 

reduction in NOx in 2011, but only half of the reduction in SO2 in 2014, an additional 9 percent 

reduction in NOx in 2014, none of the additional NOx 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 controls. 

Option 3 - 2015/2016 shutdown: This option would set a NOx limit based on low NOx burners 

in 2011, and no other emission limits. The shutdown date in this option is based on the 

requirement to install BART controls within five years of federal approval 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 reduction in NOx 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 options, 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 

Emission 

reduction

after close 

date (tpy) 

2011

(NOx)

2014 

(SO2)

2017 

(NOx)

2009 

Rules

LNB/MOFA Semi-dry 

Scrubber

SCR $497.6 - 20,800

(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 $462 4,800

(19%)

20,900

Key to Table:

LNB/MOFA = Low NOx burners 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 Option 2 DSI System

As noted above in the description of DEQ’s Option 2, the SO2 controls would consist of a dry 

sorbent injection system. Permitting rules for PM2.5 may result in the DSI system triggering 

DEQ’s Prevention of Significant Deterioration (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 required 
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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. 

However, 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 increment 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 estimates 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 considers to be

cost effective for Option 2 under federal BART rules. The details of this analysis are provided 

in Attachment 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 regarding 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 

information 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 Options 1 or 2

At the August 4, 2010 fiscal advisory 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 technical feasibility of DSI controls, and if the SO2 emission limit identified by 

DEQ can 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 hazardous air pollutants 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 

these 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 these 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 rules.

Public Health and Environmental Benefits

Closure of the Boardman coal-fired boiler would permanently eliminate approximately 25,500 

tons of air pollution per year, including visibility impairing pollutants of sulfur dioxide and 

nitrogen oxide, and well as fine particulate, and mercury (an air toxic). DEQ expects this 

reduction would have a significant heath benefit for the public; however, DEQ cannot at this 
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time estimate these benefits in term of health costs or dollars saved because it lacks the 

necessary and complicated data to estimate those types of benefits. However, DEQ does 

recognize that these health benefits do exist. 

The 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 closure 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 benefits, 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. First, 

there will be costs to the owners of the Boardman power plant for installing and operating new 

pollution 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 sections below. 

Any potential rate increase will be contingent on future actions taken by the PUC. Third, 

closing Boardman could result higher rate increases and elimination 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 from permit and 

emission fees paid by Boardman under the Title V permit program, 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 

options, compared to the 2009 rules. The total annual cost would increase for Option 1 (2020 

closure) and decrease significantly for Option 2 (2018 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 is determined by amortizing the capital costs over the remaining useful life of the plant.

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

*** The total estimated annual cost is the sum of the indirect and direct annual costs.

Table 3 shows the annualized emission reductions and cost for the control options 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 the 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 in this 

case, the early shutdown dates.) However, Table 3 does give a sense of cost/benefit of the 
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three options when compared to the current BART rules for PGE Boardman.

For example, under the current 2009 rules, it is assumed the plant will operate until 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 

shows that for the current 2009 rules, over the 30 year period 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 cost - 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 options, based on the cost of 

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

in their 2010 rate increase request to the PUC. See the section on “Assumptions” on page 16

for additional information on rate increase estimation. See also Attachment 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 Rate 

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 nonresidential

2.57% 2.93% 1.11% 0.37%

Large nonresidential

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 for PGE’s estimates of potential rate increases due to 

costs of early closure, including plant decommissioning and potential replacement power costs.
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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 associated with DEQ Rule

DEQ estimates that its proposed rule options could impact the general public by increasing 

electricity rates for customers of the four utility companies that own the Boardman plant, listed 

in Table 7 on page 11. Some of these customers may reside outside of Oregon. For Oregon 

residents, 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 the general public due to 

the BART emission control 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

Estimated

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 estimates of potential rate increases due to 

costs of early closure, including plant decommissioning and potential replacement power costs.

In addition to rate increases, 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 were 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 impacts could be offset if PGE builds a natural gas 

plant at or near the current Boardman plant, or other form 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 currently in the permitting process for a new but 

smaller facility at the Boardman plant location, and it’s possible the coal-fired boiler could 

be replaced in the future with a new boiler burning another type of fuel. Whether current 

employees at the coal plant would 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 sections

below on impacts to small businesses and local governments.

Impacts to Small 

Business

(50 or fewer 

employees –

ORS183.310(10))

BART Costs associated with DEQ Rule

Based on discussions with its fiscal advisory committee, DEQ finds that DEQ’s proposed rule 

options could have a significant adverse impact on small businesses by increasing electricity 

rates. This impact 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 August 4th
Page 10

meeting can be found at www.deq.state.or.us/aq/haze/shutdown.htm.

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

the BART emission control technology.

Table 6: Estimated rate increases – Small Businesses*

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 nonresidential

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 estimates of potential rate increases due to 

costs of early closure, including 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 businesses 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 the cost to 

small businesses, providing the alternative is determined to meet BART. 

DEQ also recognizes that if PGE decides to close the Boardman coal plant, any resulting 

job losses may have a ripple effect to some small businesses within the community 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 the 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 

titled: 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 businesses 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 businesses 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 small 

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 

business, 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 apply only to that plant. DEQ 

understands the owners to be Portland General Electric (PGE), San Diego Gas and Electric 

(SDG&E)/General Electric Capital Corporation (GECC), Idacorp, Inc., and Power 

Resources Cooperative (PRC). Table 7 below summarizes the proportional annualized

costs of the BART emission control technology requirements for each of the four plant 

owners under each DEQ option.

Table 7: Proportional 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 

Cost

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 $10,412,838

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 could have a negative impact on other large 

businesses by increasing electricity rates. 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 increases 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 Increase

Option-3

Estimated

Rate Increase

Large nonresidential

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 estimates of potential rate increases due to 

costs of early closure, including 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 rate 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 fees 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 titled “Associated 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 impacts 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, and 225 

seasonal workers. Based on information from the Port of Morrow, these 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, 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 were closed. The net impact could potentially exceed $50 million to the 

local economy. 

The property taxes from the PGE 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. DEQ 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 construct other similar power 

plants, or convert the existing Boardman plant to a different fuel type. These actions could 

help offset any economic impact to local governments of closing the coal plant but DEQ 

lacks information to accurately estimate these potential 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 approving 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 governments 
Page 13

are charged according to the “large nonresidential” rate class. Local government customers 

within other rate classes would likely experience lower rate increases. See also Table 4 for 

other applicable rate classes.

Table 9: Estimated rate increases – Local Governments*

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 nonresidential

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 estimates of potential rate increases due to 

costs of early closure, including 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, requiring 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 impacts to DEQ, and the subsection 

“Associated potential 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 

electricity rates 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 would likely experience lower rate increases.

See also 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 nonresidential

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 estimates of potential rate increases due to 

costs of early closure, including plant decommissioning and potential replacement power costs.

Impacts on DEQ BART Costs associated with DEQ Rule

DEQ estimates that its proposed rule options could impact its operations in two ways. Any 

increase in electricity rates for units of state government would also affect DEQ operations that 
Page 14

are customers of the four utility companies that own the Boardman plant listed earlier. These 

impacts 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 customers 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 also Table 4 for other applicable rate classes.

Table 11: 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 nonresidential

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 estimates of potential rate increases due to 

costs of early closure, including plant decommissioning and potential replacement power costs.

In addition, under each BART option DEQ would experience a loss in revenue from the 

installation of pollution control technology. DEQ charges all Title V sources fees based on 

emissions. If emissions 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 that operation). 

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

to approximately $225,000 after installing the Phase-2 NOx controls in 2017. Under the various 

closure options, DEQ’s Title V revenue from the Boardman 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 fired boiler. 

DEQ could regain some revenue (permit and emission fees) if PGE constructs a replacement 

power facility, however DEQ cannot accurately estimate this revenue because it depends on 

future actions by PGE.

Since Option 1 and 2 do not include Phase-2 NOx 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 years, after which DEQ would 

lose this funding. This is not the case under 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 holders of Title V air quality permits in an amount

sufficient to support DEQ’s operation of the Title 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 Title V program in order to ensure adequate DEQ permitting resources and 

customer service to Title V permittees. This could result in a DEQ request to the Oregon 

legislature for a fee increase that would affect all businesses and agencies holding Title V air 

quality operating permits. DEQ cannot calculate the likely fee increase at this time, as it 

depends 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 options 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 rates. 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 

rule 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, and 

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 impacts. 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 increase 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 the 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 

BART cost effectiveness. 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 acknowledged and 

discussed here to provide the public with a more comprehensive review of costs and affects.

Table 12 shows PGE’s estimated rate increase for each BART option including 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 just 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 alternatives 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 resulted 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 accuracy 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 12: PGE Estimated rate increases*

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/%

increase 

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.

The 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 estimate 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.

Assumptions 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 2010

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 generation 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 proposal, 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 credits 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 impacts 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 2.56 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 minimal 

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 Oregon Administrative 

Procedures Act, ORS 183.310 et seq. (APA) and to meet the requirements in ORS 183.333. 

The committee helped evaluate the fiscal and economic impacts of this rulemaking and 

provided recommendations to DEQ. A summary of the fiscal advisory committee 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 Date
Page 18

Attachment A

Supplemental cost information

1. Costs related to 2009 PGE Boardman rules:

$ 66,968,750

$ 12,054,375

$ 79,023,125

$ 51,365,031

Revenue Revenue

Requirement Revenue + Revenue Rate

Rate Class by Rate Class by Rate Class Requirement Impact

Residential/Commercial $ 526,330,000 44% $ 22,731,536 $ 887,004,000 $ 909,735,536 2.56%

Irrigation & Drainage $ 6,643,000 1% $ 286,903 $ 18,181,000 $ 18,467,903 1.58%

Small Nonresidential $ 95,131,000 8% $ 4,108,589 $ 160,044,000 $ 164,152,589 2.57%

Large Nonresidential $ 553,538,000 47% $ 23,906,616 $ 722,095,000 $ 746,001,616 3.31%

Traffic Signs $ 268,000 0% $ 11,575 $ 378,000 $ 389,575 3.06%

Lighting $ 7,405,000 1% $ 319,813 $ 22,991,000 $ 23,310,813 1.39%

$ 1,189,315,000 $ 51,365,031 $ 1,810,693,000 $ 1,862,058,031 2.84%

Cost Allocation

Production

by Rate Class

Annualized Cost of Controls

Return on Investment/Taxes (1.18)

Total Revenue Requirement

PGE Share (65%)

2. Costs related to 2020 Control option:

$ 76,555,179

$ 13,779,932

$ 90,335,111

$ 58,717,822

Revenue Revenue

Requirement Revenue + Revenue Rate

Rate Class by Rate Class by Rate Class Requirement Impact

Residential/Commercial $ 526,330,000 44% $ 25,985,505 $ 887,004,000 $ 912,989,505 2.93%

Irrigation & Drainage $ 6,643,000 1% $ 327,972 $ 18,181,000 $ 18,508,972 1.80%

Small Nonresidential $ 95,131,000 8% $ 4,696,725 $ 160,044,000 $ 164,740,725 2.93%

Large Nonresidential $ 553,538,000 47% $ 27,328,795 $ 722,095,000 $ 749,423,795 3.78%

Traffic Signs $ 268,000 0% $ 13,231 $ 378,000 $ 391,231 3.50%

Lighting $ 7,405,000 1% $ 365,593 $ 22,991,000 $ 23,356,593 1.59%

$ 1,189,315,000 $ 58,717,822 $ 1,810,693,000 $ 1,869,410,822 3.24%

by Rate Class

Annualized Cost of Controls

Return on Investment/Taxes (1.18)

Total Revenue Requirement

PGE Share (65%)

Production

Cost Allocation
Page 19

3. Costs related to 2018 Control option:

$ 28,876,401

$ 5,197,752

$ 34,074,153

$ 22,148,200

Revenue Revenue

Requirement Revenue + Revenue Rate

Rate Class by Rate Class by Rate Class Requirement Impact

Residential/Commercial $ 526,330,000 44% $ 9,801,661 $ 887,004,000 $ 896,805,661 1.11%

Irrigation & Drainage $ 6,643,000 1% $ 123,710 $ 18,181,000 $ 18,304,710 0.68%

Small Nonresidential $ 95,131,000 8% $ 1,771,592 $ 160,044,000 $ 161,815,592 1.11%

Large Nonresidential $ 553,538,000 47% $ 10,308,346 $ 722,095,000 $ 732,403,346 1.43%

Traffic Signs $ 268,000 0% $ 4,991 $ 378,000 $ 382,991 1.32%

Lighting $ 7,405,000 1% $ 137,901 $ 22,991,000 $ 23,128,901 0.60%

$ 1,189,315,000 $ 22,148,200 $ 1,810,693,000 $ 1,832,841,200 1.22%

by Rate Class

Annualized Cost of Controls

Return on Investment/Taxes (1.18)

Total Revenue Requirement

PGE Share (65%)

Production

Cost Allocation

4. Costs related to 2015-16 Control option:

$ 9,717,837

$ 1,749,211

$ 11,467,048

$ 7,453,581

Revenue Revenue

Requirement Revenue + Revenue Rate

Rate Class by Rate Class by Rate Class Requirement Impact

Residential/Commercial $ 526,330,000 44% $ 3,298,574 $ 887,004,000 $ 890,302,574 0.37%

Irrigation & Drainage $ 6,643,000 1% $ 41,632 $ 18,181,000 $ 18,222,632 0.23%

Small Nonresidential $ 95,131,000 8% $ 596,197 $ 160,044,000 $ 160,640,197 0.37%

Large Nonresidential $ 553,538,000 47% $ 3,469,090 $ 722,095,000 $ 725,564,090 0.48%

Traffic Signs $ 268,000 0% $ 1,680 $ 378,000 $ 379,680 0.44%

Lighting $ 7,405,000 1% $ 46,408 $ 22,991,000 $ 23,037,408 0.20%

$ 1,189,315,000 $ 7,453,581 $ 1,810,693,000 $ 1,818,146,581 0.41%

by Rate Class

Annualized Cost of Controls

Return on Investment/Taxes (1.18)

Total Revenue Requirement

PGE Share (65%)

Production

Cost Allocation