Memorandum for File:

Summary of Arizona Regional Haze SIP/FIP Meeting, December 21, 2011

This meeting was a teleconference between EPA staff, ADEQ staff, and utility company 

representatives.

Present at R9 in San Francisco: Tom Webb, Steve Frey, Scott Bohning, Eugene Chen

Present at Phoenix: Colleen McKaughan (EPA), Francisco Dóñez (EPA), Eric Bakken (TEP), Eric 

Massey (ADEQ), Kara Montalvo, Chas Spell (APS), Jim Andrew (AEPCO), Michelle Freeark 

(AEPCO), Sue Kidd (APS) , C.V. Mathai (APS)

General Topics of Discussion:

1) EPA’s general concerns and constraints

2) Specific issues w/ Arizona RH SIP

3) Visibility modeling

4) Nevada RH SIP, other EPA RH actions

Discussion of EPA’s General Concerns and Consent Decree Constraints

Colleen: EPA is under a consent decree (w/ NPCA) to take action on RH SIPs. We must either 

approve these RH SIPs or propose a FIP for those that we disapprove.

May 15, 2012 – proposed action date

November 15, 2012 – final action date

We have several issues with the Arizona RH SIP, include how sources were determined subject 

to BART, the BART determinations, and the ability to meet reasonable progress goals (RPGs). 

By May, we will be approving certain portions of the SIP, disapproving other portions, and FIPing those portions we don’t approve. 

RPGs do not show reasonable progress at 4 AZ class I areas. In fact, degradation is actually 

shown at several, which is not allowed by the regional haze rule (RHR). In addition, the 

timeframe for reasonable progress was too long.

A letter was sent out to ensure that everyone is aware and informed of our process.

If we make a BART determination that is different from AZ DEQ, we want you to be informed. 

If we do make a different BART determination, we want to discuss with the stakeholders. 

We would prefer/like to pursue a SIP revision, but timing would be an issue. We are also 

interested in developing a better idea of what is happening at these four Class I areas. 

We have no idea and no preconceived notion of what the outcome of these BART 

determinations will indicate. 

As long as we are in the rulemaking process, we are able to share information and discuss. 

After we propose, administrative procedures limit our freedom of communication with outside 

parties. 
Since we’re talking about coal-fired units, the outcome of our BART determinations will be 

closely scrutinized and challenged by enviro groups and National Park Service (NPS), regardless 

of the final answer. As a result, we want to ensure that our determination is well documented 

and supported. 

Question: Once EPA approves/disapproves, is there a mechanism to allow us time to 

reconsider or update what we originally proposed? 

Colleen: Yes, there will be an opportunity to submit public comments.

Subsequent discussion was on the following topics:

Discussion of specific issues/deficiencies of RH SIP

Discussion of Visibility Modeling

Discussion of Nevada RH SIP, other EPA RH action

Colleen: As a follow-up to this meeting, we will provide the following information to you:

We’ll let you know about what costs are disallowed,

Drop dead date in a letter,

List of modeling input data, and

Link to the Nevada RH SIP docket.