1

Shoshone Bannock Tribes Air Quality Department- 6/21/12

Comments on EPA’s Proposed Approval of Idaho’s Regional Haze SIP

Docket ID No. EPA-R10-OAR-2010-0930

Submitted by email to: R10-Public_Comments@epa.gov

Identification of four factor analysis- Idaho needs to demonstrate that it is making reasonable progress 

in reducing anthropogenic emissions within the State, especially with respect to non-BART sources in 

Eastern Idaho. Within the I-SIP, neither the Simplot Don Plant, a wet-phosphoric acid plant and sulfuric 

acid plant, the Agrium plant nor the Monsanto (or ”P4) plant, were detailed enough to report BART and 

Non-BART emissions of Haze pollutants within their plants. 

a. In the case of the Simplot Don Plant, though facts presented are sketchy, the I-SIP reported that 

the most significant sources of Haze pollutants were non-BART sources within the plant. WRAP 

reported 31 separate emission sources within the plant. Hence, the I-SIP should have carried 

out the 4 factor – Reasonable Progress Analyses of this plant, as required by 40 CFR 

51.308(d)(1)(i) and Section 169A of the Clean Air Act. This plant is large and has operated with 

few process changes over the years and has been well characterized and permitted by IDEQ. 

The 2007 toxic release inventory is as follows:

State Facility 

Identifier

Pollutant 

Code 2007 TPY 

07700006 CO

 

45.40 

07700006 NH3

 

116.30 

07700006 NOX

 

112.33 

07700006 PM10-PRI

 

211.39 

07700006 PM25-PRI

 

211.29 

07700006 SO2

 

1,610.72 

07700006 VOC

 

3.30 

From the above inventory this source emits 4 tons per day of sulfur dioxide. This release 

inventory is typical of Simplot’s annual emissions. In view of the potential significance of this 

source, particularly on impacts to visibility within Craters-of –the Moon National Monument, 

Teton and Yellowstone National Parks, the I-SIP should have detailed emission sources and 

emission values within the plant, potential control technologies, and regulatory plans to limit 

these non-Bart emissions. 
2

Unfortunately the I-SIP stated that IDEQ needs more time to do so. But the State of Idaho was

late in their SIP to begin with and failed to submit any of the required regional haze SIP 

elements at 40 CFR § 51.308. These elements were required to be submitted no later than 

December 17, 2007. (The EPA Federal Register of May 22, 2012, is remiss in not discussing this, 

in considering approving the Idaho Haze SIP.) 

Had the State of Idaho submitted their Haze SIP on time, they likely would have had time to 

complete the 4 factor analyses of large point sources. The State of Idaho’s Haze SIP should not 

be approved by EPA when there are these point sources, such as phosphate plants in eastern 

Idaho that emit large amounts of haze producing pollutants, and when the State is not 

following Federal haze regulatory deadlines, and when the SIP is not adhering to the four part 

Reasonable Progress Analysis requirements of Section 40 CFR308(d)(1)(i), of Simplot Don Plant, 

as well as other point sources. In view of the above factors, the EPA should not approve the 

State of Idaho’s Haze SIP.

Reason for Reasonable Progress Analyses Delay - Additional information has been made 

available that indicates Idaho’s reason for delay, in the case of the Simplot Don Plant’s, 4 factor 

analysis, is inaccurate. That is, the I-SIP requests 5 years more time for Sulfuric Acid plant 

analysis (two years for modeling, and 3 years to install emission controls). However, the 

Simplot Don Plant recently applied for a permit to construct an improved sulfuric acid plant 

wherein, they have indicated a one year time-table for installing an improved (BACT) scrubber 

at the Sulfuric acid plant- underscoring the unreasonableness of the I-SIP with respect to 

implementing control technology. (Reference: Simplot, Permit-To-Construct, for 400 Sulfuric 

Acid Plant, Prepared by RTP Environmental Associates, Inc., December 2011. ) So, the projected 

3 years for installing emission controls at Simplot is erroneous, just as the 2 year modeling 

schedule for these large sources is unreasonable. (Idaho requires sources to carry out modeling 

as part of their permit application.) EPA should require Idaho to complete the Reasonable 

Progress Analyses on a realistic schedule and not approve the existing Haze SIP which has an 

unreasonable delay in implementation of four factor analysis for Non-BART sources.

Moreover, it appears that the State of Idaho, in their Haze SIP is not only requesting an 

unreasonable time-table for compliance as reviewed by EPA in this initial review, but by 

unreasonably projecting another 5 year delay is attempting to also establish the possibility that 

Simplot and other point sources may not be ready for emission reductions in time for the next 5 

year review period! ( 40 CFR 51.308(i)(1)(4) requires five-year progress reports.) This is 

unacceptable and EPA should review this issue and require IDEQ to revise the Haze SIP 

accordingly. 

Nu West/ Agrium -

This source of emissions is inadequately covered in the I-SIP. The individual plant emission 

sources and emission estimates for each source should be provided in the Haze SIP, as well as 

more discussion of BART eligibility. For those sources that are non-BART, the I-SIP should 
3

provide a four point Reasonable Progress Analyses of the sources and control technology as 

required under 40 CFR 51.308 (d)(1)(i)(A).

The I-SIP is totally inadequate with respect to analyzing this large source of haze-generating 

pollutants and EPA should require a revision of the HAZE SIP to complete the 4 point analyses of 

this plant, and including a review of emissions and emission controls.

Crop Residue Burning - The I-SIP does not adequately analyze crop residue burning impacts to 

Class I air-sheds, rather the I-SIP merely states that the program was approved by EPA. But the 

controversial crop residue burning in Idaho may impact Class 1 areas, and has not adequately 

been reviewed in the I-SIP. The I-SIP is estimating a 54% reduction in anthropogenic fires. Yet, 

from the period between 2002 to present, there has been a significant increase in agricultural 

burning: 44,280 acres were burned on state lands in 2002 (Source: 2002 Idaho Agricultural 

Smoke Management Program Statewide Summary, February 26, 2003) and for the 2011 year –

a significant source of haze producing pollutants unrecognized in the Haze SIP. The primary 

strategy of permitting crop residue burns (and prescribed burns) is to disperse the smoke by 

prevailing winds. While it is true that smoke is reduced in down-wind concentration by this 

strategy, given the large acreages being burned, it increases haze on a regional scale and 

increases haze impacts in down-wind Class 1 areas, especially in the fall when field burning is 

scheduled. The resulting haze should be reviewed, and modeled by I-SIP, included in the longterm strategy. 

5.8 Long-Term strategy- In this section of the I-SIP it lists “Smoke management techniques for 

agricultural and forestry burning, including plans to reduce smoke impacts.” The IDEQ allows 

prescribed and agricultural burns to take place without regard for regional haze, in fact the 

entire strategy of “Smoke Management” in IDEQ rules is to avoid smoke accumulating close to 

the burn, and allowing it to be dispersed farther down-wind. That is, promote burning when 

conditions disperse the smoke to a regional-based impact, while avoiding impacts close by. 

With over 44,000 acres being burned annually, the I-SIP should address the Long Term strategy 

of Agricultural Burning, because it increases haze at Class I areas. The I-SIP should make plans 

to model these recently allowed “Crop Residue Burns” and Prescribed burns; and begin 

planning for better emission controls to protect Class 1 areas. Crop residue burning is 

increasing with the advent of the relatively new “Crop Residue Burning” section of IDEQ’s Rules. 

Consultation with Federal Land Managers and Wyoming

Federal Haze rules require consultation with Federal Land Managers and neighboring States. 

The I-SIP did not provide enough detail of Wyoming’s comments and consultation. Neither did 

the I-SIP discuss resolving comments submitted by the National Park Service and U.S. Forest 

Service. This should be reported in more detail.

Summary

The EPA should reconsider their approval of Idaho’s Haze State Implementation Plan (SIP). This 

I-SIP, was years late to begin with, and yet with this submission the IDEQ, failed to fulfill the 
4

requirements at 40 CFR section 51.308...again stating that they did not have time. As a 

consequence a critical section of the Haze SIP plan is incomplete, with Reasonable Progress 

Analyses and controls left undone at large point sources in Idaho that impact Class 1 areas. As 

an example of this deficit, the Simplot Don Plant, has few BART sources, but most of their 

emission inventory is non-BART sources that adversely impact visibility, but for which Idaho 

failed to complete the needed four point factor analysis. Other point sources have similar 

deficits in carrying out Reasonable Progress analysis. 

Field burning within Idaho may adversely impact Class 1 areas and Idaho’s Haze SIP did not 

adequately review impacts (short-term or long-term) to Class 1 areas, nor did it accurately 

describe the permit program which seldom, if ever denies burns that might impact National 

Parks or Monuments: That is, the permit program is largely a registration program rather than a 

program with realistic tools to monitor Class 1 impacts, let alone limit Agricultural-based burns 

to safeguard Class 1 airsheds. 

In consideration of this issue the EPA should disapprove the draft Regional Haze SIP of Idaho

and request a fast track by the IDEQ to revise the Haze SIP. To do otherwise is counter to the 

Clean Air Act (Section 169A) and results poorly controlled emissions of haze producing 

pollutants reaching Class 1 areas of Idaho and Wyoming.

Thank you for this opportunity to comment on this important step by EPA to reduce regional 

haze in the west.

Regards,

Roger Turner

Interim Air Quality Manager

Shoshone-Bannock Tribes

P.O. Box 306

Fort Hall, ID 83203

airquality@sbtribes.com