Pinal County Governmental Alliance, Inc. 

510 E. Florence Blvd.
 

Casa Grande Arizona 85122
 

Telephone: 520-421-8600 Fax: 520-421-8604
 

April 14, 2011 

Mr. Jared Blumenfeld 

Administrator for EPA, SW Region 

USEPA Region 9 

75 Hawthorne St./Mail Code ORA-1 

San Francisco, CA 94105

.-/' 

Re: Best Available Retrofit Technology Determination for Navajo Generating Station 

Dear Ms. Blumenfeld: 

The Pinal County Government Alliance (PCGA) understands that the United States 

Environmental Protection Agency (EPA) intends to propose a Best Available Retrofit 

Technology (BART) determination for the Navajo Generating Station (NGS) in the next several 

months. PCGA previously submitted a letter to EPA on April 7, 2010, expressing concerns 

regarding the potential implications of the Advanced Notice of Proposed Rulemaking (ANPR) 

that was issued by EPA in August 2009. With this letter, PCGA would like to reiterate and reemphasize the importance of those concerns in the context of the pending BART determination. 

It is the position of the PCGA that NGS provides a low cost source of power for Central Arizona 

Project (CAP) pumping that would be complicated and costly to replace, and that loss of NGS 

power would undermine existing water rights agreements and threaten water supplies to both 

Native American tribes and Pinal County communities. 

It is the position of the PCGA that the estimated $16.00 per acre-foot increase in energy 

charges that could result if EPA requires installation of Selective Catalytic Reduction (SCR) and 

Baghouses as BART for NGS would have a devastating economic impact on non-Indian and 

Indian water users in Pinal County. 1 

It is the position of the PCGA that the voluntarily installation of Low-NOx Burners and Separated 

Overfire Air (LNB/SOFA) by the NGS owners, which will be completed this spring, will improve 

air quality in the region and that this approach takes appropriate incremental steps toward 

achieving visibility goals while considering the associated costs to the water users. 

MEMBERS 

Apache Junction - Casa Grande - Central Arizona College District - Central Arizona Irrigation & Drainage District
 

Coolidge - Eloy - Florence - Kearny - Maricopa - Maricopa - Pinal County - Queen Creek
 

Santa Cruz Water & Power District Associations
 

I Letter from David V. Modeer, CAWCD, to Jared Blumenfeld. EPA Region9, November 22, 2010. 
It is the position of the PCGA that if the NGS owners decide to close the Plant, which could 

occur if SCR is required by EPA as BART, both energy and water costs for the non-Indian and 

Indian water users in Pinal County would increase much more significantly. 

Finally, it is the position of the PCGA that the water users have been granted rights to 

exclusively use discounted electrical power generated by NGS for pumping water to the 

municipalities and tribes in Pinal County, that a requirement by EPA to install SCR as BART 

would present a detrimental economic hardship to the non-Indian and Indian water users of the 

Central Arizona Water Conservation District. Accordingly, EPA should accept installation 

LNB/SOFA as BART for the control of nitrogen oxides (NOx). 

PCGA is a voluntary association consisting of, but not limited to, governmental agencies, Native 

American Indian Communities, Educational Institutions, and utility organizations in Pinal County 

with concerns in the areas of policy, planning, education, development and management. The 

underlying concept of the Alliance is that stakeholders, who are the units closest to the people, 

should exercise the basic initiative and leadership in the area of policy, planning, education, 

development and management. The Pinal County Governmental Alliance affords the 

participating entities an opportunity to collectively use their resources to address those issues 

which have a significant regional impact. 

PCGA is an association through which the individual members can work effectively and 

cooperatively to position governmental entities of Pinal County in the forefront of policy 

development and planning in the State of Arizona. 

PCGA would appreciate the EPA's consideration of these comments in developing a proposed 

BART determination for NGS. 

Sincerely, 

Mayor Vicki Kilvinger 

Chairwoman 

Pinal County Governmental Alliance 

cc: ~vernor Jan Brewer 

~olleen McKaughan, EPA, Region 9
 

PCGA Members