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March 23, 2012 ViaElectronic and OvernightMailDelivery EPA Region 10 1200 Sixth Avenue, Suite 900 Seattle, WA 98101 Attention: Keith Rose, Office ofAir, Waste and Taxies, AWT-107 

### Re: DocketIDNo. EPA-R10-0AR-2011-0367 DearMr. Rose: Golden ValleyElectric Association ("GVEA'') appreciates this opportunity to respond to the U.S. Environmental Protection Agency's ("EPA's") comments on the Alaska Regional Haze State Implementation Plan ("SIP"), published in the Federal Register on February 24, 2012. GVEA submits this letter documenting our comments and concerns as part ofthe record for Docket ID No

.EPA-R10-0AR-2011-0367

. GVEA offers comments on the State ofAlaska's ("State" or "Alaska") sources ofvisibility impairment in Denali NationalPark, Alaska's consideration ofemissions from Healy Power Plant Unit No. 2 in its reasonable progress evaluation, and the Best Available Retrofit Technology ("BART") determination for Healy Power PlantUnitNo. 1.
Sources ofVisibility Impairment Inits discussion ofsources ofvisibility impairment in Class I areas, EPA proposes to accept, among other things, Alaska's analysis ofthe impact ofidentified pollutants on visibility in Denali National Park. Alaska's analyses conclude that natural wildfires are the dominant source for all ofthe visibility impairing pollutants registered at both monitoring sites for Denali National Park. GVEA agrees with EPA and Alaska that natural wildfires inside Alaska are the primary contributors to regional haze at Denali National Park. GVEA also submits that the sources outside and upwind ofAlaska are significant contributors to visibility impairment, and ifEPA Region 10 March 23, 2012 Page 2
visibility is not improving as planned, the monitoring data should be evaluated to quantify not only the impacts from natural wildfires, but from the out-of-state, upwind air pollution as well.
Reasonable Progress Evaluation and Consideration ofHealy Power PlantUnit. No. 2 GVEA agrees with Alaska and EPA that the exact amount ofimpact from any operation ofHealy Unit No.2cannot be determined at this time. 77 Fed. Reg. 11036 (Feb. 24, 2012). We also agree with Alaska and EPA that it is not reasonable to require additional controls on the unit. However, GVEA does not agree with the State's assumption that it will necessarily have to "consider" Healy Unit No. 2 in its reasonable progress evaluation. First, the requirement for revising an implementation plan becomes applicable only after a state determines that there is a need for revision based upon the comparison ofthe visibility monitored versus the glide path projected. 40 CFR 51

.308(g)

- (h)

. Ifthe glide path projection is being met,there is no need and no requirement to revise a state's Long Term Strategy ("LTS"). At present, "the RPGs for Class I areas are projected to meet the URP in 2018." 77 Fed. Reg. 11036 (Feb 24, 2012). Therefore, assuming that Healy Unit No.2 will need to be considered at all in Alaska's reasonable progress evaluation is at best premature
. Nor will Alaska's estimate ofan increase ofNOx by a factor of4.0 and ofSOx by a factor of2.8 (should Healy Unit No

. 2 begin operating) support the assumption that the glide path will not be met. The increased emissions estimate is based on permitted, not actual emissions, and it assumes Healy Unit No.2 will operate at full capacity, that all other sources will continue to operate exactly as measured during the baseline period, and that no new sources will be brought on line. Such assumptions cannot be the basis for a current decision that Healy Unit No

. 2 will need to be considered in the future,particularly when actual emissions data would be available and other factors will likely change. Second, ifAlaska determines that the current regional haze SIP is inadequate to meet RPGs, the Regional Haze Rule does not support the State singling out Healy Unit No. 2 during a reasonable progress evaluation. Ifthe visibility goals are not being met, the Regional Haze Rule requires that the implementation plan be revised byreviewing all sources ofvisibility impairment and determining the best way to improve visibility given economic, energy and non-air quality environmental impacts ofcompliance, the remaining useful life ofany affected existing source, as well as the effect ofnew sources. 40 CFR 51.308(f). HealyUnit No. 2, along with other stationary sources, may be included in the evaluation for a revision ofthe implementation plan if the RPGs were not being met and Alaska determined that stationary sources within the United States were a significant cause ofthe visibility impairment. Third, as previously noted in these comments, EPA states that sources outside the country are significant contributors to regional haze at Denali National Park. When discussing transboundary emissions from outside the United States, "[T]he EPA does not expect States to restrict the emissions from domestic sources to offset the impacts ofinternational transport of pollution." 64 Fed. Reg. 35736 (July 1, 1999)(40 CFR 51.102 AND 51.103). Moreover, if "theEPA Region 10 March 23, 2012 Page 3
implementation plan is or may be inadequate to ensure reasonable progress due to emissions from sources in another country, the state shall provide notification, along with available information, to the Administrator." 40 CFR 51.308(h)(3). GVEA agrees with EPA that domestic sources should not be used to offset international impacts and, under the Regional Haze Rule ifAlaska's implementation plan were inadequate because ofupwind, out-ofcountry sources, the State ofAlaska would not be required to revise its plan. Therefore, GVEA requests that ifan evaluation is required during any 5 year progress report, that Alaskacarefully and quantitatively measure the impacts from international transport on visibility, clearly identify reductions from domestic stationary sources and demonstrate that any required reductions from domestic stationary sources are not offsets for international transport impacts. Healy Power PlantUnit No. 1 Regarding Healy Unit No. 1, GVEA agrees with Alaska and EPA that the BART determination for Healy Unit No. 1does not result in a state orfederally enforceable shut down ofHealy Unit No. 1in 2024. GVEA also agrees with Alaska and EPA that the BART process results in an emissions limit for NOx based on the limit that can be achieved with Selective Non-Catalytic Reduction ("SNCR") and that Selective Catalytic Reduction ("SCR") would not be cost effective. Although GVEA agrees with the agencies that SCR would not be cost effective, GVEA submits this comment to address EPA's characterization ofAlaska's determination. In particular, EPA indicates that Alaska's determination was inappropriately based on an 8-year period and that, in the absence ofa federally-enforceable shutdown date, Alaska should have considered a 15-year period. Alaska, through its contractorEnviroplan, considered both periods and found SCRcost prohibitive for both. In the Enviroplan Final BARTDetermination Reportfor GVEA (January 19, 2010), Enviroplan states "Itis nonetheless noted that the site-specific SCR [Selective Catalytic Reduction] cost evaluation performed by Fuel Tech

... has resulted in SCR being determined as cost ineffective, irrespective ofthe amortization period used in the cost analysis." Final Report at 16.
In conclusion, GVEA would like to thank the EPA for the opportunity to review the proposed approval ofthe Alaska Regional Haze SIP. We lookforward to revisions ofthe proposed approval.

Environmental Officer