RE: Fiscal Impact Statement revisions

From: Rod Skeen

Sent: Wed Aug 11 08:31:08 2010

To: FINNERAN Brian

Subject: RE: Fiscal Impact Statement revisions

Importance: Normal

Good Morning;

I was in a meeting all afternoon yesterday and so could not get back to you by COB. However, I was able to verify that the CTUIR does have a low income heating assistance program. Our funding for this program varies from year to year. As you have stated, increased rates will impact likely increase demand for this program.

My overall comment on the document is that I believe it understates the economic impacts that closing the coal plant will have on the local economy. The number of skilled jobs lost in Morrow County will be significant and will spread to throughout the support service sector (gas stations, grocery stores, furniture stores, car dealers, mechanics, etc). I believe a there is a multiplying factor that economists typically use to estimate the number of secondary job lost for every job supported by outside dollars. These loses should be directly accounted for in the economics of these options (Page 5 and 6 of document). I don’t think the document should speculate on the replacement of these jobs by the decision of PGE to build a different type of plant. It is my opinion that the decision to build, or not build, a gas fired power plant is outside the scope of the document which is evaluating the impacts of the BART rule on the existing plant.

On Page 8 the document should discuss the loss in tax revenue that will be observed by the state government by the closing of the coal fired plant. While the counties and cities will see the largest fractional decrease in revenue, the state will also be impacted by the job losses. These costs should at least be mentioned even if they can’t be quantified.

Finally, no mention on the economic impacts to natural resources was made in the document. Has the DEQ thought about how to calculate the change in value in natural resources and local farm products that might occur by the reduction in pollution? I am not sure these can be quantified, but it may be valuable to at least mention this as a positive impact to early closure.

Thank you for the opportunity to comment on this work.

Rod Skeen

============================================

Rodney S. Skeen, Ph.D., P.E.

Manager, Engineering and Modeling Program

Department of Science and Engineering

Confederated Tribes of the Umatilla Indian Reservation

Phone: (541) 429-7420

Fax: (541) 429-7420 (Yes, it is the same as phone)

Email: rodskeen@ctuir.org

Mailing/FedEx Address: 46411 Timine Way, Pendleton, OR 97801

=============================================

From: FINNERAN Brian [mailto:FINNERAN.Brian@deq.state.or.us]

Sent: Tuesday, August 10, 2010 12:50 PM

To: Rod Skeen

Subject: Fiscal Impact Statement revisions

Rod,

If you’d like to provide comments, attached is a new section of our fiscal statement document, which I sent you earlier. This part was created specifically to address impacts on tribal nations, and was discussed last week at our fiscal advisory committee meeting.

Would be curious to know your thoughts and whether you have any comments or additional suggestions on economic impacts. As noted below, I’m curious if there are any low-income heating assistance programs that you deal with.

I will be sending out the entire revised document to the committee later this week for comments.

This part needs to be completed by end of today if possible, or tomorrow at the latest. So if you have any comments let me know.

Thanks!

Brian Finneran

DEQ Air Quality

(503) 229-6278

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 Yakima Nation, and Confederated Tribes of the Umatilla Indian Reservation, through electricity rate increases, for tribal members, tribal businesses, or tribal government, who are customers of the four utility companies that own the Boardman plant. The rate classes listed in Table 4 on page 8 show these potential rate increases, contingent on the Oregon PUC approval.

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 want to recognize these potential negative impacts on tribal nations, should PGE choose to close the 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. DEQ does not know whether any of the tribal nations have such programs.