Portland General Electric Company 

121 SW Salmon Street. Port/and, Oregon 97204 

PortlandGeneral,com 

October 22, 2010 

Mr. Dick Pedersen 

Executive Director 

Oregon Department of Environmental Quality 

811 SW 6th Avenue 

Portland, OR 97204 

Dear Mr. Pedersen: 

Please accept the attached letter from Mr. Jim Lobdell, Vice President of Power Operations 

and Resource Strategy at Portland General Electric to Mr. Bob Jenks, the Executive Director 

ofthe Citizens' Utility Board of Oregon regarding the Boardman Best Available Retrofit 

Technology ("BART") rule making. PGE hereby requests that you, in your role as Director of 

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

Environmental Quality Commission (ttEQC"), re-open the Regional Haze Best Available 

Retrofit Technology ("BART") rulemaking record to include this letter. This letter is to be 

read in conjunction with a Jetter from a number of environmental groups to Mr. Jim Lobdell 

ofPGE dated October 22, 2010. 

Thank you fot considering this request. 

Sincerely, 

Dave Robertson 

Vice President, Public Policy 

'

/pc;" ~ Portland General Electric Company 	 James F. Lobdell 

121 SW Salmon St,'eet • Port/and, Oregon 97204 Viet President 

~ ~ ~ ~~ _ _ _ __ _ _ _~503) 464:-2723 • Facsimile (503) 464-2222 PQWer Operations and ReslJUrce Strategy 

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October 22, 2010 . 

Mr. Bob Jenks 


Executive Director 


Citizens' Utility Board ofOregon 


610 SW Broadway, Suite 308 


Portland, OR 97205 


RE: PGE Boardman replacement resource planning process. 

Dear Mr. Jenks: 

Portland General Electric Company ("PGE") has been working with certain members of the 

public interest community (including to date, the Citizens' Utility Board ("CUB"), the Renewable 

Northwest Project, Angus Duncan, Oregon Environmental Council, and the NW Energy Coalition 

(the "Group")) to discuss PGE's public commitment to construct Boardman candidate 

replacement resource portfolio options to be considered in the Oregon Public Utility 

Commission's ("OPUC") Integrated Resource Planning process related to the cessation of 

Boardman coal-fired operations. The Group and PGE have also been discussing the Group's 

support for ceasing coal-frred operations at Boardman no later than December. 31,2020 as part of 

a comprehensive plan, as further described in the Group's letter from Bob Jenks of CUB to Jim 

Lobdell ofPGE dated October 22,2010 (the "Group Letter"). This letter represents PGE's 

understanding ofits role with respect to these discussions. 

Within the context ofthe Integrated Resource Planning Process ("IRP") and the guidelines 

adopted for that process by the OPUC, and in consideration of the Group's support as described 

in the Group Letter, and contingent upon EQC approval of BART ill or a plan that is 

substantially similar to BART TIl and acceptable to PGE, PGE will: 

,. 	 Lead an effort in its next lRP to develop a limited number of carbon reduction candidate 

resource portfolio options to meet anticipated utility resource requirements including the 

replacement ofBoardman coal generation and designed to achieve the best combination 

of expected costs and associated risks and uncertainties for PGE and its customers and 

also reduce the carbon footprint ofthe company's resource portfolio over time ("C02 

reduction portfolios"). Such portfolios will be evaluated against other constructed 

resource portfolios developed during the IRP process. 

.. 	 Define CO2 reduction portfolios as prospective supply and demand side resource options 

that are teclmically feasible and commercially available during the lRP planning period 

that could potentially be candidates for reducing portfolio carbon emissions and meet 

forecasted energy and capacity defici'ts related to the cessation ofBoardman coal-fired 

operations and other resource requirements. _ 

.. 	 Design in consultation with the Group the CO2 reduction portfolios to meet specific CO2 

reduction targets to be defined by the Group. 
.. 


Portland General Electric 

• 	 Allocate sufficient funding, not to exceed $50,000 without PGE's prior approval, to be 

made available on a one-time basis for the sole purpose of securing technical consulting 

assistance services (to be selected jointly by PGE and the Group) to assist with 

development and evaluation of the potential candidate resource portfolios for Boardman . 

. • ~~·Iiilliatea.linmeaniiiiiber~oI wOiksliOpiCdesfgn-euJo-deveIOpl:lie7:l)2feOilCtloo-portfiillos'--- ... 

during the next IRP process. 

o 	 Invite all m..p stakeholders, including OPUC and ODOE staff to the workshops. 

• 	 Affirm publicly that the process described above represents a commitment by PGE to use 

its best efforts to develop and evaluate carbon emission reduction portfolios that support 

Oregon's efforts to reduce greenhouse gas emissions while operating within the OPUC's 

least-costlleast-risk paradigm. 

• 	 Support the elimination of the DEQ BART Rule that now allows for continued coal-flred 

operations at Boardman through 2040, or the end of its economic life, upon occurrence of 

all of the following: (1) a revised Boardman BART/Reasonable Progress rule acceptable 

to PGE has been adopted by EQC; (2) such Boardman BART/Reasonable Progress rule 

has been included in Oregon's State Implementation Plan (SIP); and (3) the Boardman 

BART/Reasonable Progress portion of the Oregon SIP has been finally approved by the 

Environmental Protection Agency and becomes binding on Boardman. Until such flnal 

approval by EPA of the Boardman BARTlReaS0118.ble Progress portion of the Oregon 

SIP, PGE is free to advocate for a 2040 backstop option should EQC and EPA not 

approve a BART rule that is acceptable to the company. 

PGE will comment, consistent with the content of this letter and the Group Letter, in other public 

venues, including print and broadcast media strongly In favor of this process, including coauthorship with the Group of a joint opinion editorial speaking to the importance of these efforts 

to cease coal-fired operations at Boardman, and the repll,l.cement resource process that all parties 

hope will enable PGE's transition to a lower carbon least-cost resource portfolio, to be filed with 

the Oregonian and other relevant news outlets prior to the EQC decision on this matter. 

PGE understands that nothing in this document will require the company to t!J.ke any action that is 

in conflict with the OPUC's IRP Guidelines and process. 

Thank you for taking the time to engage in these discussions. 

Sincerely, 

~