Statement

of Michael Hummel Salt River Project EPA Public Hearing

on 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 proposed rule 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.StatementofMikeHummel,SaltRiverProjectArizonaRegionalHazeFIPPublicHearingAugust14,2012Page2SRPiscommittedtocleanairandimprovedvisibility.Indeed,SRPisinthefinalstagesofinstallingextensivenewpollutioncontrolequipmentatCoronadoatacostofover$500million.EPA’sproposedFIPisparticularlytroublingasitcallsforadditionalcontrolsevenbeforethecurrentequipmentinstallationprocessiscomplete.SRPbelievesthattheproposedFIPislegallyflawed,andisbasedoninaccuratecostanalysisanddefectivemodeling.SRPrespectfullyrequeststhatEPAwithdrawitsproposalandworkcollaborativelywiththeStateofArizonatoapprovetheState’sentireregionalhazeimplementationplan.EPA’sActionsareLegallyFlawedTheArizonaDepartmentofEnvironmentalQuality(“ADEQ”)developedandsubmittedacomprehensiveStateImplementationPlan(“SIP”)thatincludedalargenumberofmeasurestoaddressavarietyofsourcesthatcontributetoregionalhaze,includingmobilesources,wildfiresandindustrialfacilities.EPAshouldconsider,andacton,allofthesemeasurestogetherratherthansinglingoutthreepowerplantsforimpositionofoverlystringentNOlimits,especiallyconsideringthatNOemissionsfrompowerplantsareresponsibleforlessthan5%ofthehazeinthisregion.EPA’sCostAnalysisisInaccurateSRPhasretainedtheengineeringconsultingfirmSargent&LundytohelpreviewEPA’scostestimates.EPAisprojectingthatasecondSCRStatement

of Mike Hummel, Salt River Project Arizona Regional Haze FIP Public Hearing August
14, 2012 Page

3 on Unit

1 will cost only $57 million. However,
the actual costs for the SCR on Unit

2, which

is approaching completion,

are expected

to be 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 the measured 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.Statement

of Mike Hummel, Salt River Project Arizona Regional Haze FIP Public Hearing August
14, 2012 Page

4 EPA’s proposed rule tries to obscure this key conclusion

by applying

a “cumulative” deciview metric. SRP strongly objects

to use of this 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.