PG&E Corporation
August 16, 2018
Ms. Meredith B. Cross, Esq.
1875 Pennsylvania Ave. NW
Washington, DC 20006
Re: United States of America v. Pacific Gas and Electric Company (N.D. Cal., Case No. R-14-
PG&E Corporation and Pacific Gas and Electric Company – Waiver Request of
Ineligible Issuer Status under Rule 405 of the Securities Act
Dear Ms. Cross:
This is in response to your letter dated August 14, 2018, written on behalf of PG&E
Corporation and Pacific Gas and Electric Company (“the Utility”) (together, “PG&E”) and
constituting an application for relief from PG&E being considered “ineligible issuer[s]” under Rule
405(1)(v) of the Securities Act of 1933 (“Securities Act”). PG&E requests relief from being
considered “ineligible issuers” under Rule 405 due to the August 9, 2016 guilty verdict against the
Utility (“Conviction”). The Conviction, in part, found the Utility guilty of obstructing a federal
agency proceeding, a felony violation of 18 U.S.C. § 1505. On January 26, 2017, the court entered a
judgment of conviction (“Judgment”) which requires, among other things, oversight by a third-party
monitor for five years and community service.
Based on the facts and representations in your letter, and assuming the Utility complies with
the Judgment, we have determined that PG&E has made a showing of good cause under clause (2) of
the definition of ineligible issuer in Rule 405 and that PG&E will not be considered ineligible issuers,
beginning August 16, 2018, as a result of the Conviction. Accordingly, the relief described above
from PG&E being ineligible issuers under Rule 405 of the Securities Act is hereby granted. Any
different facts from those represented or failure to comply with the terms of the Judgment would
require us to revisit our determination that good cause has been shown and could constitute grounds
to revoke or further condition the waivers. The Commission reserves the right, in its sole discretion,
to revoke or further condition the waivers under those circumstances.
For the Commission, by the Division of Corporation Finance, pursuant to delegated authority.
Tim Henseler
Chief, Office of Enforcement Liaison
Division of Corporation Finance
August 14, 2018
Tim Henseler
Chief, Office of Enforcement Liaison
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N .E.
Washington, DC 20549
Meredith B. Cross
+ 1 202 663 6644 (t)
+1 202 663 6363 (f)
Re: United States of America v. Pacific Gas and Electric Company (N.D. Cal., Case No. CR-
Dear Mr. Henseler:
We write on behalf of our clients, PG&E Corporation (the "Company") and its primary
operating subsidiary, Pacific Gas and Electric Company (the "Utility"), in connection with the
judgment of conviction entered against the Utility on January 26, 2017, which is described
below. Pursuant to Rule 405 promulgated under the Securities Act of 1933 (the "Securities
Act"), we hereby request that the Securities and Exchange Commission ("Commission") or the
Division of Corporation Finance, acting pursuant to delegated authority, determine that for good
cause shown it is not necessary under the circumstances that the Company or the Utility be
considered an "ineligible issuer" under Rule 405. Prior to this matter, neither the Company nor
the Utility has previously made a request for a waiver from the Commission.
The Company is a holding company whose primary operating subsidiary is the Utility.
The Utility is a public utility serving approximately 16 million people throughout 70,000 square
miles in northern and central California. As of December 31, 2017, the Company and the Utility
had approximately 23,000 regular employees, approximately 20 of whom were employees of the
Company. The Company and the Utility file periodic reports with the Commission under Section
13(a).ofthe Exchange Act on a combined basis.
On September 9, 2010, a tragic accident occurred in San Bruno, California, involving an
explosion of a portion of one of the Utility's gas transmission pipelines. Following
investigations by the Utility's primary regulator, the California Public Utilities Commission (the
"CPUC"), and the National Transportation Safety Board (the "NTSB"), on April 1, 2014, a
federal grand jury for the Northern District of California returned an indictment charging the
Wilmer Cutler Pickering Hale and Dorr u.r, 1875 Pennsylvania Avenue NW, Washington, DC 20006
Beijing Berlin Boston Brussels Denver Frankfurt London Los Angeles New York Palo Alto Washington
Mr. Tim Henseler
August 14, 2018
Utility with multiple pipeline violations, and the charge of obstructing an agency proceeding was
included in a superseding indictment filed July 29, 2014. A federal criminal trial against the
Utility began in June 2016 in the United States District Court for the Northern District of
California involving 12 felony counts alleging that the Utility knowingly and willfully violated
minimum safety standards under the Natural Gas Pipeline Safety Act relating to record-keeping,
pipeline integrity management, and identification of pipeline threats, and one felony count
charging that the Utility obstructed the NTSB investigation into the cause of the San Bruno
accident. On August 9, 2016, the jury found the Utility guilty on one count of obstructing a
federal agency proceeding in violation of 18 U.S.C. § 1505 ("Section 1505") and five counts of
violations of pipeline integrity management regulations of the Natural Gas Pipeline Safety Act.
The jury acquitted the Utility on all six of the record-keeping allegations.
On January 26, 2017, the court issued a judgment of conviction, fining the Utility $3
million, and sentencing the Utility to a five-year corporate probation period, including, among
other conditions, oversight by a third-party monitor for a period of five years, with the ability to
apply for early termination after three years, certain advertising requirements, and community
The probation includes a requirement that the Utility not commit any local, state, or
federal crimes during the probation period. As part of the probation, the Utility was required to
retain a third-party monitor. The Utility engaged the monitor in February 2017. The goal of the
monitor is to help ensure that the Utility takes reasonable and appropriate steps to maintain the
safety of its gas and electric operations, and maintain effective ethics, compliance and safety
related incentive programs on a Utility-wide basis.
In 2005, the Commission revised the registration, communications, and offering
processes under the Securities Act. 1 As part of this offering reform, the Commission revised
Securities Act Rule 405, creating a new category of issuer, the "well-known seasoned issuer" (or
"WKSI"), and a new category of offering communication, the "free writing prospectus." A wellknown
seasoned issuer is eligible for important reforms that have changed the way corporate
finance transactions for large accelerated filers are offered and sold. These reforms include the
ability to "file-and-go" (i.e., eligibility for automatically effective shelf registration statements)
and "pay-as-you-go" (i.e., the ability to pay filing fees as the issuer sells securities off the shelf).
These reforms have removed the risk of regulatory delay in connection with capital formation.
In addition, well-known seasoned issuers are provided with the most flexibility in terms of
communications, including the ability to use free writing prospectuses in advance of filing a
1See Securities Offering Reform, Securities Act Release No. 8591, Exchange Act Release No. 52,056, Investment
Company Act Release No. 26,993, 70 Fed. Reg. 44,722, 44,790 (Aug. 3, 2005).
Mr. Tim Henseler
August 14, 2018
Page 3
registration statement and in connection with the offering of securities registered on the WKSI's
registration statement.
The Commission also created another category of issuer under Rule 405, the "ineligible
issuer." An ineligible issuer is excluded from the category of "well-known seasoned issuer" and
is ineligible to make communications by way of free writing prospectuses, except in limited
circumstances.2 As a result, an ineligible issuer that would otherwise be a well-known seasoned
issuer does not have access to file-and-go or pay-as-you-go, and cannot use most free writing
Securities Act Rule 405 authorizes the Commission to determine, "upon a showing of
good cause, that it is not necessary under the circumstances that the issuer be considered an
ineligible issuer. "3 The Commission has delegated the function of granting or denying such
applications to the Division of Corporation Finance.4
The Company and the Utility understand that the jury's verdict made the Company and
the Utility ineligible issuers under Rule 405. As such, neither the Company nor the Utility
currently is able to qualify as a "well-known seasoned issuer." The Company and the Utility
replaced their automatic shelf registration statements with non-automatic shelf registration
statements on Form S-3 in January 2017 in order to maintain their access to the capital markets
following the loss of WKSI status. However, the loss of the ability to access file-and-go and
other reforms available to well-known seasoned issuers continues to have an adverse impact on
the Company and the Utility.
Consistent with the framework outlined in the Division of Corporation Finance's Revised
Statement on Well-Known Seasoned Issuer Waivers issued on April 24, 2014, the Company and
the Utility respectfully request that the Commission determine that it is not necessary for either
the Company or the Utility to be considered an ineligible issuer as a result of the entry of the
2 See Securities Act Rules 164(e), 405 & 433, 17 C.F.R. §§ 230.164(e), 230.405 & 230.433.
3 Securities Act Rule 405, 17 C.F.R. § 230.405.
4 17 C.F.R. § 200.30-l(a)(l0).
Mr. Tim Henseler
August 14, 2018
Nature ofViolation: Responsibility for and duration of the alleged violations
Neither the Company nor the Utility has been charged with any violation of the federal
securities laws, and the Utility's conviction relating to violations of pipeline integrity
management regulations of the Natural Gas Pipeline Safety Act do not implicate the ineligible
issuer definition. Rather, the sole basis of the determination that the Company and the Utility are
ineligible issuers under Rule 405 is the conviction of the Utility on one count of obstructing a
federal agency proceeding, based on the assumption that the Utility's violation of Section 1505
involves the making of a "false report" within the meaning of Section 15(b )( 4)(B)(i) of the
Exchange Act.
The conduct that gave rise to the Section 1505 violation involved the Utility's written
response to a data request sent to the Utility by the CPUC in its role as a party participant in the
NTSB investigation. The evidence presented at trial demonstrated that the Utility, in response to
the data request, initially provided a draft of a policy outlining the way in which it would address
potential manufacturing threats on segments of some of its oldest natural gas pipelines. Based on
the draft policy, the Utility collected certain information about these pipeline segments, but did
not prioritize them as high-risk and schedule required assessments. Approximately six weeks
after providing the draft policy, in April 2011 the Utility advised the NTSB and CPUC in a letter
that the version of the policy produced was an unapproved draft that had been produced in error,
and thereafter provided a prior, approved version of the policy as well as a newly revised
version. The Utility did not advise either agency that, in fact, it had been operating under the
draft policy. The Department of Justice argued that the Utility's failure to tell the NTSB that the
draft policy had been in effect was an effort to obstruct the NTSB' s investigation. The jury
found the Utility guilty of obstructing an agency proceeding in violation of Section 1505.
The Utility's conviction related to an isolated incident and was not part of a pattern of
conduct that would call into question the reliability of its or the Company's current and future
disclosures as issuers of securities. This conduct does not pertain to activities undertaken by the
Company or the Utility in connection with their roles as issuers of securities ( or any disclosure
related thereto) or to any of their filings with the Commission. None of the conduct is related in
any way to any of the Company or the Utility's current or future disclosures as an issuer of
securities or to any of their filings with the Commission, and does not call into question the
effectiveness of their disclosure controls and procedures.
In addition, Department of Justice did not allege misconduct by the board of directors,
executive management, or other senior officers of the Company or the Utility in connection with
the Section 1505 violation, nor was it alleged that any of the Company's or the Utility's directors
or senior management were aware of the violative conduct or ignored any warning signs or "red
Mr. Tim Henseler
August 14, 2018
Page 5
flags" regarding the obstruction violation. No individual Company or Utility employees were
charged withthe Section 1505 violation, and only a few Utility employees were alleged to be
involved in the events relating to that violation, none of whom had any responsibility for,
participated in, or had any influence over the preparation of the Company's or the Utility's
filings with the Commission. In discussions of the conduct underlying the obstruction charge,
the Department of Justice focused generally on two Utility employees, both of whom retired
prior to the indictment of the Utility.
Remedial Steps
In addition to significant gas pipeline safety improvements designed to address its
Natural Gas Pipeline Safety Act compliance, the Company and the Utility have taken the
following comprehensive measures, and will continue to take significant measures, to prevent
future occurrences such as the one giving rise to the Section 1505 violation.
During 2015, prior to the jury's verdict in this matter, the Company and the Utility
(together, "PG&E") as part of their commitment to strengthen their compliance and ethics
program and performance restructured the governance for managing compliance and ethics to
highlight and delineate more clearly the responsibilities for the implementation, coordination,
and monitoring of their compliance and ethics program.
Since 2015, PG&E has substantially increased senior-level oversight of its compliance
and ethics program, and has significantly expanded its compliance and ethics team. At the
management level, the companies' Chief Ethics and Compliance Officer (CECO), in partnership
with the lines of business, has day-to-day responsibility for overseeing and monitoring the
company-wide-compliance and ethics program, including compliance management, riskmitigation
and reporting; overseeing employee-investigatory processes; and reinforcing PG&E's
ethics and compliance culture. The lines of business are responsible for program implementation,
and regularly report to the CECO on compliance matters. Management also has established a
senior officer compliance and ethics committee that provides strategic guidance on, and
oversight of, the compliance and ethics program, including the programs and systems designed
to prevent, detect, and mitigate non-compliance. The CECO also leads the companies' ethics and
compliance training and culture-building efforts. In 2015, the Company's Board of Directors
also reconstituted its Public Policy Committee into the Compliance and Public Policy
Committee, which is accountable for overseeing the compliance and ethics program through
reports from the CECO, as well as outside compliance reports and external audits, and
monitoring that a consistent commitment to effective compliance programs is conveyed to
employees, contractors, and other relevant stakeholders.
The Utility currently has in place a rigorous internal risk and compliance program. Every
year, the Utility's senior executives from each line of business convene a discussion to review
Mr. Tim Henseler
August 14, 2018
Page 6
and assess its risks and compliance obligations, how it has performed in the past year, and its
plans to mitigate any open issues identified in this planning process. This annual meeting
represents the culmination of several months of work by each line of business to analyze and
assess its risk and compliance issues, identify gaps, and develop mitigation plans. The CECO
and Vice President of Enterprise and Operational Risk Management lead this meeting of the
Utility's senior executives, and the Company's Chairman and CEO. In addition, each line of
business within the Utility has its own risk and compliance committee, which regularly reviews
that business' most-significant risks and compliance requirements, including the status of
associated mitigations. The committees work to ensure full compliance with all laws and
regulatory requirements as well as maintain focus on operational risk management. The risk and
compliance committee meetings generally are led by officers from the specific line of business
for the express purpose of creating a forum to address its significant risks and compliance
In February 2018, PG&E Corporation and the Utility amended the employee Code of
Conduct to add a section directly addressing communications with regulatory personnel,
stressing that all such communications must be truthful and accurate. These new provisions
provide direct links to company procedures regulating ex parte communications with the CPUC
and the Federal Energy Regulatory Commission and note that employees who contact regulatory
agencies are expected to follow all company procedures and can consult with the Law
Department or Regulatory Affairs. Prior to these revisions, the Code of Conduct generally
emphasized the importance of accurate records, including in reports to government agencies, but
the new Code of Conduct highlights the applicability in regulatory proceedings, as well as
provides employees with easier access to guidance on how to conduct themselves.
Taken as a whole, PG&E believes its compliance and ethics program enhances
accountability for its employees, promotes the management and reporting of, and collaboration
on, compliance risks and mitigations across lines of business, fosters a culture of "speaking up,
listening up and following up," and promotes safety, integrity and compliance with regulatory
and legal requirements. These overall changes in processes and focus have strengthened
PG&E's compliance culture and are making PG&E's employees more mindful of their
responsibilities in dealing with all legal and regulatory requirements, thereby minimizing the risk
that PG&E employees would engage in conduct such as that underlying the obstruction charge in
the instantmatter.
Impact on Issuer
The ability to have flexible and seamless access to the capital markets in a timely fashion
is of critical importance to the Company and the Utility, and is in the public interest. The need
for the Company and the Utility to raise a significant amount of capital to fund their
infrastructure capital investment program and to pay potential liabilities in connection with the

Mr. Tim Henseler
August 14, 2018

Page 7


Northern California wildfires that occurred in October 2017 (the "Northern California
wildfires"), all while complying with the Utility's capital structure conditions, has increased by
an order of magnitude and requires maximum flexibility to quickly access the capital markets on
a cost-effective basis. The Utility's need to invest in and enhance its infrastructure, including
new and innovative approaches to address the growing wildfire risk, requires the Company and
the Utility to continue to raise new capital to fund these investments.
As a regulated California entity, the Utility's capital structure is dictated by the CPUC.
The CPUC periodically conducts a cost of capital proceeding to authorize the Utility's capital
structure and rates of return for its electric generation, electric and natural gas distribution, and
natural gas transmission and storage rate base. As noted in the Company and the Utility's
Annual Report on Form 10-K for the year ended December 31, 2017, the CPU C has authorized
the Utility's capital structure through 2019, consisting of 52% common equity, 47% long-term
debt, and 1 % preferred stock. In order to fund its required capital expenditures while maintaining
its authorized capital structure, the Utility depends on access to the capital markets and equity
contributions from the Company. The primary source of the Company's equity contributions to
the Utility is the issuance of the Company's common stock.
Prior to the loss of WKSI status, the Company had two WKSI shelf registration
statements and the Utility had one, all of which were replaced with non-WKSI Form S-3 shelf
registration statements in early 2017. In 2017, the Company issued $416 million of common
stock and made equity contributions of $455 million to the Utility, and the Utility conducted one
registered offering using its shelf registration statement, issuing $600 million of senior notes in
March. In the three years prior to the loss of WKSI status, the Company and the Utility accessed
their WKSI shelf registration statements in 12 separate offerings registered under the Securities
Act: (i) the Company conducted five registered offerings using its automatic shelf registration
statement, of which four offerings were to provide proceeds to make equity contributions to the
Utility; and (ii) the Utility conducted seven shelf takedowns to raise funds for general corporate
purposes and to repay its outstanding commercial paper. In 2016, the Company issued
approximately $800 million of common stock and made equity contributions to the Utility of
$835 million, and the Utility issued $1 billion oflong-term debt. In 2015, the Company issued
approximately $800 million of common stock and made equity contributions to the Utility of
$705 million, and the Utility issued $1.15 billion of long-term debt.
The Utility's capital expenditures have increased significantly in recent years. From 2011
to 2017, the Utility's annual capital expenditures increased from $4 billion to approximately $5.7
billion. The Utility estimates it will incur $6.3 billion in 2018 and $6.0 billion in 2019.
Historically, the Utility's operating revenues have been insufficient to fund its capital
expenditure needs. The Utility has been, and will continue to be, reliant on the Company's access
Mr. Tim Henseler
August 14, 2018
Page 8
to the capital markets and the resulting equity contributions and the Utility's own debt issuance
to ensure sufficient funding for future expenses.
While to date it has been possible for the Company and the Utility to continue to access
the capital markets using their non-automatic shelf registration statements since the loss of
WKSI status, the reduced flexibility with respect to the amount of securities to be offered and the
inability to access the markets with very little notice are now posing significantly greater risks to
the Company and the Utility. Specifically, it is essential that the Company and the Utility have
flexibility to quickly access the capital markets to respond to unexpected capital needs that may
arise, such as increased capital expenditures or liquidity needs related to the Northern California
wildfires or other extreme weather conditions.
For instance, a Current Report on Form 8-K filed with the Commission on June 21, 2018
by the Company and the Utility (the "Form 8-K") addressed the potential impact of the Northern
California wildfires. In the Form 8-K, the Company and the Utility disclosed that they have
received approximately 200 complaints on behalf of at least 2,700 plaintiffs related to Northern
California wildfires. 5 The litigation pending against the Company and the Utility includes claims
under multiple theories of liability, including negligence and ·california' s strict liability regime
of inverse condemnation. Further, the Company and the Utility indicated that they intend to
record an estimated pre-tax charge in the amount of $2.5 billion for the quarter ending June 30,
2018 for losses in connection with 14 of the Northern California wildfires in connection with
which the California Department of Forestry and Fire Protection (CAL FIRE) issued its
determinations of cause. 6 The expected charge does not include any amounts in connection with
any of the other Northern California wildfires, including the wildfires as to which CAL FIRE has
not yet issued its determination of cause. 7
The timing and outcome of these and other potential proceedings are uncertain. Such
expenditures could necessitate capital raising in excess of the amounts already registered on the
existing shelf registration statements in a very short time period. Without WKSI status, the
Company and the Utility would likely be required to register a significantly greater amount of
securities than they would need in the short term to respond to these proceedings, and even with
that approach, it may not be possible to accomplish the required registration in time to satisfy
5 See Current Report on Form 8-K, PG&E Corporation and Pacific Gas and Electric Company, filed June 21, 2018
at Archives/edgar/data/7548_8/0001 l 9312518198514/d619252d8k.htm ("Form 8-K").
6 The Company and the Utility noted in the Form 8-K that on January 31, 2018, the California Department of
Insurance issued a news release announcing an update on property losses in connection with the October and
December 2017 wildfires in California, stating that, as of such date, "insurers have received nearly 45,000 insurance
claims totaling more than $11.79 billion in losses," of which approximately $10 billion relates to statewide claims
from the Northern California wildfires. That news release reflected insured property losses only and did not account
for uninsured losses, interest, attorneys' fees, fire suppression and clean-up costs, personal injury and wrongful
death damages or other costs.
7 See Form 8~K.
Mr. Tim Henseler
August 14, 2018
Page 9
capital expenditure and liquidity needs, and to stay in compliance with the CPUC's capital
structure condition. Alternatively, the delay imposed by registering smaller amounts of securities
may cause the Company and the Utility to fail to access capital when public markets present
conditions at reasonable cost, or at all. Both of these situations could create unnecessary costs to
shareholders and unnecessary delays in addressing and resolving proceedings. If the Company
and the Utility were to regain WKSI status, they would have the flexibility to use "file-and-go"
and "pay-as-you-go" to remove the risk ofregulatory delay and unnecessary costs in connection
with capital formation.
The capital raising flexibility available to a WKSI is critically important to the Company
and the Utility to resolve proceedings quickly and to stay within the authorized capital structure.
The Company's and the Utility's ability to raise capital to satisfy the Utility's capital expenditure
needs in a timely manner and without regulatory impediments is critical not only to investors but
to the California public. Capital provided by Utility debt issuances and equity contributions
from the Company is critical to protecting the power grid, investing in innovative approaches to
wildfire risk and ensuring that Utility pipelines and facilities are adequately protected from
In light of these and the other considerations described in this letter, continuing to subject
the Company and the Utility to ineligible issuer status is not necessary under the circumstances,
either in the public interest or for the protection of investors, and good cause exists to determine
that they should not be considered ineligible issuers under Rule 405 as a result of the judgment
of conviction. We respectfully request the Division of Corporation Finance to make that
Please contact me at 202-663-6644 if you should have any questions regarding this
Meredith B. Cross
Active US

Oregon's Boardman Coal Plant is set to close next year

We got a look inside Boardman Coal Plant. It's the biggest single-point pollution source in the state. But it also provides low-cost power and high-income jobs.

Author: Pat Dooris
Published: 7:21 PM PDT October 1, 2019
Updated: 6:03 PM PDT October 2, 2019

Shutting it down

Inside the Boardman Coal Plant

How it works

Oregon's largest single-point source of pollution

What will replace the Boardman Coal Plant?

BOARDMAN, Ore. — The Boardman Coal Plant was built in the late 1970s for Portland General Electric. It was a time when Oregon’s population was growing and the OPEC oil embargo of the early 1970s was still fresh. The country wanted more energy choices, and a coal plant seemed like a good choice at the time.

Times have changed. A combination of lawsuits, political pressure and cheaper alternative power have doomed the plant long before its mechanical life is over.

Portland General Electric has agreed to shut the plant down in 2020. Because it's the biggest single-point source of pollution in Oregon, environmental advocates like the Sierra Club's Cesia Kearns say it a big win that sets an example for the nationwide fight against climate change.

But it’s heartbreaking for the workers who've spent years at the plant, making a good wage and lifelong friendships.

Oregon's Boardman Coal Plant is set to close next year

Shutting it down
Chapter 1
Inside the Boardman Coal Plant
Chapter 2
How it works
Chapter 3
Oregon's largest single-point source of pollution
Chapter 4
What will replace the Boardman Coal Plant?
Chapter 5

Chapter 1
Shutting it down

The Boardman Coal Plant could run another 30 or 40 years, according to the people who work there; instead, PGE has agreed to shut it down next year.

“We’re gonna put the thing to bed early,” said Dave Rodgers. He's an electrical engineer who spent years working at the plant, many of them as the top executive. He now manages all of the PGE thermal plants in Eastern Oregon.

He is proud of his years at the coal plant and what it accomplished.

“The question is, 'Did you do something worthwhile with your life?' And I can honestly say, 'Yeah.' I can say I provided a useful product to people that they used, that they benefited from,” Rodgers said.

Boardman stands in stark contrast to the surrounding farm fields.

The smoke stack stands 656 feet tall, roughly the height of a 60-story building.

The stack at Boardman
The stack at Boardman puts out carbon dioxide. But it's invisible, not the plumes of smoke people might associate with a coal plant.

Pat Dooris

Mountains of black coal rise from the ground. There are roughly 500,000 tons tons of it here at any given time, enough to run the coal plant and power 500,000 Portland-area homes for a month-and-a-half. When its running at full output the plant burns five-and-a-half tons of coal a minute.

Hold the coal in your hand and you'll notice it is surprisingly lightweight, like the pumice rock you might find around Mt. St. Helens.

The coal looks like firewood that burned to black but did not disintegrate, and it comes apart easily.

Three trains a week re-supply the coal pile. Each train pulls 100 cars and each car carries 120 tons of coal from the Powder River Basin of Montana and Wyoming.

2016: New PGE Boardman plant $100M over budget

The plant only orders, and will only burn, low-sulfur coal to help reduce emissions.

Ten years ago, PGE installed $60 million worth of pollution controls to further lower pollution from Boardman.

A spokesman said the decision to mothball the plant came back in 2009 after it was clear PGE would need to spend $600 million to fully comply with emissions requirements.

Cesia Kearns fights coal plants like this on a regional basis for the Sierra Club. The Sierra Club filed the lawsuit that led to the decision to close Boardman.

She said the end of the state’s only coal plant is good for everyone.

“This plant was the largest source of climate pollution—the largest single source of climate pollution and air pollution—in Oregon. And the fact that we’re going to be moving past that, and hopefully accounting for the change that’s coming for the community, is a pretty big deal,” she said.

Chapter 2

Inside the Boardman Coal Plant

Drive east of Portland for 170 miles along the Columbia River and you will approach the town of Boardman. Turn right and travel south, down a quiet farm road another 10 miles and you will arrive at Oregon’s only coal-fired electric plant.

The first thing you notice in the empty visitor parking lot (yes, its that much off the beaten path) is the crackle of electricity. It comes from the coal plant and runs on thick wires to the nearby substation next to the parking lot. It sounds like the static noise you hear under high-voltage lines out in rural areas, but much louder.

Photos: A tour of the Boardman Coal Plant

01 / 11
Nearly 200 miles from Portland, down a quiet farm road, is the Boardman Coal Plant

02 / 11
Approaching the Boardman Coal Plant

03 / 11
The stack at Boardman puts out carbon dioxide. But it's invisible, not the plumes of smoke people might associate with a coal plant.

04 / 11
Just a handful of the huge pipes that run throughout the Boardman Coal Plant

05 / 11
The crushing machines turn chunks of coal into powder

06 / 11
A diagram along one of the walls at the Boardman Coal Plant shows how coal is used to create electricity

07 / 11
One of the huge generators that produces electricity at Boardman

08 / 11
A look inside the Boardman Coal Plant control room

09 / 11
Dave Rodgers gives us a peek inside the coal burner

10 / 11
The view from the roof of the Boardman Coal Plant

11 / 11
Another view from the roof of the Boardman Coal Plant

The Boardman Coal Plant is a good employer for the people who work there. The average wage is around $90,000 a year, very good money with the lower cost of living in Eastern Oregon.

Becky Gardner started working at the plant 15 years ago. She and everyone else have known for nearly a decade that the end is coming. But as it gets closer, that reality gets harder.

“To me, its sad,” she said. “There are a lot of great, knowledgeable workers here."

Gardner will retire when the plant closes. Others will join her or take jobs with PGE in other plants, and still others will end up unemployed.

Josh Hagel is the current plant manager at Boardman. He grew up in Estacada then moved to the Boardman area to start working at the plant. He was 22 years old back then. Over the years he’s worked his way to the top.

On a recent visit he showed off the plant, which gives off a deafening sound when you step inside. Massive machines were running to operate the plant in a tower of engineering mastery.

Pipes seem to run everywhere. They carry cold and hot water and chemicals that help keep the pipes and other metals from corroding.

The cement floor is surprisingly clean, not a scrap of paper or debris is left anywhere.

Chapter 3

How it works

The coal is moved from the yard to a pulverizer machine, where it's crushed into fine powder, similar to talcum powder. The powder is sprayed through nozzles into a massive burner where a roaring fire is underway. The powder ignites and keeps the furnace super hot.

The burner is part of a boiler 20 stories high, hanging from the ceiling.

The fire heats water in pipes above the boiler, turning it to incredibly hot steam, 1,000 degrees Fahrenheit.

The steam spins a turbine that turns a generator and makes electricity.

Boardman diagram
A diagram along one of the walls at the Boardman Coal Plant shows how coal is used to create electricity

Pat Dooris

A 17-acre man-made lake sits next to the plant. It was created to rotate cold and hot water through the plant’s system. The nearby smokestack looms over everything.

“It just helps with the burning, the flue gas. After we air-combust with the plant, it has to go through the rest of the boiler, through the plant and that helps with the draft, taking it out of the plant,” said Hagel.

The coal plant was running full out but nothing visible was coming out of the smokestack.

“We have precipitators and they’re electrically charged panels in there, and it takes all the ash and the flash out of there,” said Hagel.

PGE spokesman Steve Corson said additional steps have helped cut pollution at the site.

“When we settled on the Boardman 2020 plan for regional haze, and separately agreed on a plan to meet new state/federal rules for mercury control, we agreed to install new emissions controls that included the injection systems to remove mercury and SO2, plus new low-NOx burners to reduce emissions of oxides of nitrogen," Corson said. "Those added up to an investment of about $60 million, and reduced nitrogen oxide emissions by about 50 percent, mercury emissions by 90 percent, and sulfur dioxide emissions by 75 percent.

Still, the plant has a significant environmental impact. It puts out about a million and half metric tons of carbon dioxide each year.

Chapter 4

Oregon's largest single-point source of pollution

That carbon dioxide output makes the coal plant the largest single-point source of pollution in Oregon. Automobiles are the largest non-single-point source of pollution in the state.

But it’s also tiny when you consider worldwide carbon emissions from coal plants in 2018 totaled 10 gigatons—that’s 10 billion metric tons—according to the International Energy Agency. Most of that came from Asia, according to the agency’s report.

“Well you might think about a drop in the ocean. The ocean is comprised of drops right?” Kearns said when asked about the relatively small global impact of closing Boardman.

She said the Boardman plant’s pollution contributes to acid rain that harms sensitive Native American sites in the Columbia Gorge and it increases health problems in the area. She added that closing Boardman will set a good example nationally.

She believes the era of using coal a power source is coming to an end in the Northwest.

“I think it is and I think it has to,” she said.

Not surprisingly, not everyone in the plant agrees.

“I do think coal has its place in power generation for the reliability,” said plant electrical engineer Marc Andreason.

He has a personal warning about the future.

“Hydro’s great. The wind and solar are great as well. But in peak load times, heavy summer, heavy winter, you have to have a reliable backup, and this is what this plant provides," he said. "Not only a backup, but we’ve got storage on site that even other plants, even other thermals don’t have. Unique. We have a month and a half of coal to burn, full load, on the ground. Natural gas doesn’t really have that.

"It’s the whole picture. And the frustrating thing to me is: I don’t think the general public understands the full picture. And with them not understanding it, they want coal to go away. But yet, they still want the power when they want it, at all times of the year.”

Chapter 5

What will replace the Boardman Coal Plant?

PGE said it has plans for replacing most of the lost coal power, though there are still some unknowns. But the plant will close; there’s no going back on that one.

Not everyone is happy about that, including Morrow County Commissioner Don Russell.

“Those jobs are at the very top end of the pay scale for this area,” he said.

He is one of many who are unhappy with the closing of Boardman and the expansion of alternative energy across Eastern Oregon.

“There’s only so much room here, and although we in Eastern Oregon have agreed to allow windmills to dot our landscape, and we’ve got the resource for sun, it’s not unlimited," he said. "And we don’t want all of our ground covered by windmills and solar."

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I asked if he resents the changing landscape, including wind turbines, which keep the lights on in Portland.

“The viewscape is important to us, just like it is to the people who live in the west hills of Portland,” he said.

He added that the county recently signed a new contract with a wind farm that will keep the blinking red lights at the top of the machines off at night, unless something approaches it.

Regardless of resentments about alternative energy or concerns about dependable supplies, the Boardman Coal Plant is closing.

Dave Rodgers, the former plant manager, will always have fond memories of the Boardman Coal Plant.

“I’m an electrical engineer by education and profession," he said. "I couldn’t think of a better place than a power plant to work."

“I just, you know, I really like working here," said Rodgers. "It’s a good place.”