# Pinal County Governmental Alliance, Inc. 510 E. Florence Blvd. Casa GrandeArizona 85122 Telephone: 520-421-8600 Fax: 520-421-8604 April 14, 2011

Mr. Jared Blumenfeld Administratorfor EPA, SW Region USEPA Region 9 75 HawthorneSt./Mail Code ORA-1 San Francisco, CA 94105 .-/' Re: BestAvailable Retrofit TechnologyDetermination forNavajo Generating Station Dear Ms. Blumenfeld: The Pinal County GovernmentAlliance (PCGA) understandsthat the United States Environmental Protection Agency (EPA) intends to propose a BestAvailable Retrofit Technology (BART) determination for the Navajo Generating Station (NGS) in the next several months. PCGA previously submitted a letterto EPA on April 7, 2010, expressing concerns regarding the potential implications ofthe Advanced Notice of Proposed Rulemaking (ANPR) thatwas issued by EPA in August 2009. With this letter, PCGA would like to reiterate and reemphasize the importance ofthose concerns in the context ofthe pending BART determination. It is the position ofthe PCGAthat NGS provides a low cost source ofpowerfor Central Arizona Project (CAP) pumping thatwould be complicated and costly to replace, and that loss of NGS powerwould undermine existing water rights agreements and threaten water supplies to both Native American tribes and Pinal County communities. It is the position ofthe PCGA thatthe 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 BARTfor NGS would have a devastating economic impact on non-Indian and Indian water users in Pinal County. 1 It is the position ofthe PCGA that the voluntarily installation of Low-NOx Burners and Separated OverfireAir (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
- CentralArizona College District
- Central Arizona Irrigation & Drainage District Coolidge
- Eloy
- Florence
- Kearny
- Maricopa
- Maricopa
- Pinal County
- Queen Creek Santa CruzWater & Power DistrictAssociations
Letterfrom David V. Modeer, CAWCD,to Jared Blumenfeld. EPA Region9, November22, 2010. IIt is the position ofthe PCGAthat ifthe NGS owners decideto close the Plant, which could occur if SCR is required by EPA as BART, both energy and water costs forthe non-Indian and Indian water users in Pinal County would increase much more significantly. Finally, it is the position ofthe PCGA that thewater users have been granted rights to exclusively use discounted electrical powergenerated by NGS for pumping waterto 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 ofthe Central Arizona Water Conservation District. Accordingly, EPA should accept installation LNB/SOFA as BARTforthe control of nitrogen oxides (NOx). PCGA is avoluntary 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 ofthe Alliance is that stakeholders, who are the units closest to the people, should exercisethe basic initiative and leadership in the area of policy, planning, education, development and management. The Pinal County GovernmentalAlliance affords the participating entities an opportunity to collectively use their resources to addressthose 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 theforefront of policy development and planning in the State ofArizona. PCGA would appreciate the EPA's consideration ofthese comments in developing a proposed BART determination for NGS. Sincerely,

MayorVicki Kilvinger Chairwoman Pinal County Governmental Alliance
cc:**~vernor** Jan Brewer**~olleen** McKaughan, EPA, Region 9 PCGA Members