20130625Organizations Joint Comments.pdf

Powder River Basin Resource Council *Sierra Club *HEAL Utah
Snake River Alliance *Idaho Conservation League
June 21,2013
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Idaho Public Utilities Commission
Utah Public Service Commission
Oregon Public Utility Commission
Wyoming Public Service Commission
Washington Utilities and Transportation Commission
California Public Utilities Commission
RE PacifiCorp’s 2013 Integrated Resource Plan
Dear Commissioners:
Our organizations are writing to express concerns about the scope of analysis in PacifiCorp’s 2013
Integrated Resource Plan (IRP)that the company submitted to you at the end of April.Specifically,
we have significant concerns about the scope of PacifiCorp’s analysis related to reasonably
foreseeable coal plant costs and how those costs relate to electric generation options of the company
in both the short and long term.
On May 23,2013 the U.S.Environmental Protection Agency (EPA),through its regional office in
Denver,issued a draft proposal related to implementation of the regional haze rule in Wyoming.
The regional haze rule requires Best Available Retrofit Technology (BART)pollution controls at
ten PacifiCorp coal units in Wyoming and additional pollution controls at two older coal units as
part of the long-term strategy to reduce haze-causing pollution.
We understand the difficulties inherent in assessing yet-to-be-finalized government regulations.
However,forecasting liability,such as the liability created by the regional haze rule,is a paramount
part of properly being able to select resource choices that will be the least-cost,least-risk for
customers.
In the case of the PacifiCorp IRP and its related coal study,the company completely missed the
mark.Despite knowing about the range of potential pollution controls that EPA was evaluating as
part of its regional haze rulemaking process,PacifiCorp did not consider selective catalytic
reduction (SCR)controls for nitrogen oxide emissions at three of its units and selective non-
catalytic reduction (SNCR)controls at one other unit in the near term.To help explain the situation,
here is what was analyzed versus what will be required:
Coal Unit NOx Control Technology NOx Control Technology
Analyzed in the IRP Required by the EPA
Naughton Unit 1 No additional controls SCR in 201$
Naughton Unit 2 No additional controls SCR in 2018
Dave Johnston Unit 3 SNCR in 2017 SCR in 2018
Dave Johnston Unit 4 No additional controls SNCR in 2018
Regrettably,PacifiCorp’s failure to consider the possibility that these costs would be foreseeable
came as a result of willfully ignoring the advice and comments of our organizations.On at least
three occasions throughout the stakeholder engagement process,Powder River Basin Resource
Council and others asked PaciflCorp to consider a more stringent regional haze scenario where SCR
would be required on additional coal units.Organizations told the company that they believed this
would be a reasonably foreseeable outcome of EPA’s action and should therefore be analyzed.The
company refused.Now that EPA has in fact recommended these pollution controls,PacifiCorp’s
IRP in regards to a significant portion ofthe coal fleet is fundamentally flawed.
The costs of these pollution controls are important to analyze both in the context of the individual
coal units but also in the context of the company’s entire coal fleet.Neither the unit specific nor the
cumulative economic analysis for these possible expenditures was conducted as part of the
company’s IRP.As a result,PacifiCorp’s IRP does not include an accurate accounting of the likely
additional capital investments required to operate these plants.
Our organizations will be participating in the IRP public comment and hearing processes in each of
our respective states.However,we wanted to send this joint letter to all of the Commissions to let
you know about this serious flaw in the IRP in the hope that you will be able to address it as soon as
possible.
To the extent that the timing does not allow for a request for additional analysis from the company,
we ask that you take action to not acknowledge any portions of the IRP related to coal plant
expenditures and future resource allocation choices until such time as PacifiCorp remedies its
analysis.
Thank you for your time and attention.
Sincerely,
Shannon Anderson Christopher Thomas
StaffAttorney,Powder River Basin Resource Executive Director,HEAL Utah
Council Salt Lake City,UT
Sheridan,WY
Ken Miller
Travis Ritchie Energy Program Director,Snake River
Associate Attorney,Sierra Club Alliance
San Francisco,CA Boise,ID
Ben Otto
Energy Associate,Idaho Conservation League
Boise,ID