Arizona Regional Haze Federal Implementation Plan

August 14, 2012 • Holbrook, Arizona

Introduction

Thank you for the opportunity to comment on EPA’s proposed action to

promulgate a Federal Implementation Plan (“FIP”) for three coal-fired

electric generating facilities in Arizona. My name is Mike Hummel and I

am the Associate General Manager and Chief Power System Executive

at the Salt River Project Agricultural Improvement and Power District(“SRP”). SRP provides retail electric service to over 950,000 customers

and operates Coronado Generating Station near St. Johns, Arizona, one

of the three facilities affected by EPA’s proposed action.

Coronado, and the other two power plants impacted by this proposedrule are vital economic engines for the rural communities in which they

are located. They provide local tax revenue that supports colleges,

schools, roads, health care and other vital community services. EPA’s

actions have reached the point where they affect the economic viability

of coal plants, and threaten to remove these valuable assets from areas

severely impacted by this country’s recession, It seems nonsensical

under these conditions to move forward with a costly haze regulation

that will not improve visibility.
equipment at Coronado at a cost of over $500 million. EPA’s

proposed FIP is particularly troubling as it calls for additional controls

even before the current equipment installation process is complete.

SRP believes that the proposed FIP is legally flawed, and is based on

inaccurate cost analysis and defective modeling. SRP respectfullyrequests that EPA withdraw its proposal and work collaboratively with

the State of Arizona to approve the State’s entire regional haze

implementation plan.

EPA’s Actions are Legally Flawed

The Arizona Department of Environmental Quality (“ADEQ”) developed

and submitted a comprehensive State Implementation Plan (“SIP”) that

included a large number of measures to address a variety of sources

that contribute to regional haze, including mobile sources, wildfires and

industrial facilities. EPA should consider, and act on, all of these

measures together rather than singling out three power plants for

imposition of overly stringent NO limits, especially considering that

NO emissions from power plants are responsible for less than 5% of

the haze in this region.

EPA’s Cost Analysis is Inaccurate

SRP has retained the engineering consulting firm Sargent & Lundy to

help review EPA’s cost estimates. EPA is projecting that a second SCR
about $90 million. Clearly EPA’s estimation techniques do not account

for site-specific conditions, which should be considered in a sourcespecific BART analysis. Sargent & Lundy’s site-specific estimates for

Coronado show a second SCR on Unit 1 will cost SRP customers about$110 million. (Note: the increased cost is attributed to increased

retrofit difficulty) There is no basis for EPA to dismiss these sitespecific costs developed by a professional engineering firm in favor of

a cost estimate based on generic assumptions.

EPA’s Modeling Shows No Perceptible Visibility Benefits

Finally, EPA’s modeling fails to demonstrate that there would be any

perceptible visibility benefit from implementation of the FIP. EPA uses

a metric known as a “deciview” to measure the amount of haze present

at each Class I area. EPA’s guidance describes 1 deciview as themeasured change in haze discernible to the human eye. EPA made

many changes from Arizona’s modeling to try to identify a perceptible

visibility benefit from the controls EPA wants to install at Coronado.

EPA’s effort did not work. SRP notes that EPA’s modeling approach

found that none of the proposed control scenarios would improve

visibility by 1 deciview at any of the Class I areas near Coronado. This

finding alone is enough to conclude that SRP customers should not be

required to spend more than $110 million on additional control

equipment at Coronado.
metric. As EPA is aware, the deciview metric is a measure of an

individual’s ability to perceive haze from a single viewpoint, and it is

improper to imply otherwise by summing modeled, hypothetical

visibility impacts from multiple sites to suggest that EPA control

options will realize visibility benefits when, in fact, no such visibility

benefits will occur.

Conclusion

To conclude, EPA’s proposed action is misguided and unsupported. It is

clearly not cost-effective to mandate additional controls at Coronado

Generating Station that would produce no visibility benefit. EPA should

withdraw the FIP and support the State’s comprehensive regional haze

plan.