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Comanche Fact Sheet

Comanche is Young

 Comanche I & II are 44 and 42 years old, respectively. The typical useful life for coal-
fueled power plants in the U.S. is 60 to 70 years. Retiring a coal plant before the end of
its useful life, without any sizeable environmental compliance investments looming,
does not make sense.
Comanche is Clean

 Comanche I & II have recently added advanced environmental controls. Both units have
added:
o Baghouse fabric filters to remove 99% of fine particulates
o Dry scrubbers to remove over 90% of sulfur dioxide emissions
o Low-NOx burners with advanced over-fire air combustion to reduce nitrogen
oxide emissions
o Activated Carbon Injection to remove 80% of mercury in the flue gas stream

 According to EIA data, the investment in environmental controls by Comanche I & II is
over $190 million.1

 According to EPA CEMS data, over the last five years, Comanche I & II emission rates
have been significantly lower than the remaining Colorado coal fleet2:

o In 2017, Comanche I SO2 emission rate was 12 percent below the remaining
Colorado coal fleet
o In 2017, Comanche II SO2 emission rate was 15 percent below the remaining
Colorado coal fleet
o In 2017, Comanche I NOx emission rate was 33 percent below the remaining
Colorado coal fleet
o In 2017, Comanche II NOx emission rate was 7 percent below the remaining
Colorado coal fleet

1
https://www.eia.gov/electricity/data/eia860/
2
https://ampd.epa.gov/ampd/
Comanche is Low Cost

 According to FERC Form 1 data, Comanche consistently has been one of the lowest-cost
coal-fired power plants in Colorado.3

o In 2016, Comanche’s total cost of generation was $15.90/MWh, the lowest
one in Colorado (among FERC-reporting utilities) and one of the lowest in the
nation
o In comparison, the 2016 average cost of generation for the other five
investor-owned coal-fueled power plants in Colorado was $35.90
o Therefore, cost of generation at Comanche is more than 55 percent below
the average cost of generation for other coal-fired power plants in Colorado
Comanche is Useful

 Over the last five years, Comanche I & II average utilization rates were over 70 percent
 In contrast, the 5-year average utilization rate for Colorado coal plants was just 62
percent
 In 2017, the utilization rates for Comanche I & II were 69 and 82 percent, respectively
 In comparison, the 2017 average utilization rate for Colorado coal plants was 55 percent

Why should we be closing relatively young, low-cost, highly utilized, environmentally superior
coal-fueled plants? The answer is we shouldn’t.

3
https://www.ferc.gov/docs-filing/forms/form-1/data.asp