From: Withey, Charlotte 

Sent: Saturday, December 21, 2013 8:55 AM

To: George Tsiolis

Cc: 'Giff, Jennifer'

Subject: RE: Arizona RHR FIP - Tribal Consultation Between EPA, SRPMIC and 

PCC

George, 

Thank you for your e-mail and for the quote for the ammonia solution, which I 

have passed along to Eugene. 

In response to SRPMIC’s question regarding the draft proposed compliance date 

of December 31, 2018, this date derives from the requirements of 40 CFR 

51.308(d)(1), under which the State (or EPA in a FIP) must set reasonable 

progress goals (RPGs) for “the period of the implementation plan” (i.e. for the first 

regional haze planning period, which started with the baseline period of 2000-

2004 and ends in the year 2018). We are required to consider four factors in 

setting RPGs: “the costs of compliance, the time necessary for compliance, the 

energy and non-air quality environmental impacts of compliance, and the 

remaining useful life of any potentially affected sources.” 40 CFR 

51.308(d)(1)(i)(A). EPA guidance also allows for the consideration of other 

relevant factors as part of this analysis. The draft regulatory text includes a date 

of December 18, 2018, based on our initial consideration of the statutory factors 

and the input provided thus far concerning potential economic impacts to 

SRPMIC.

In response to your request for the underlying visibility analysis, there are two 

central components to this analysis: (1) the CMAQ photochemical grid modeling 

performed by the Western Regional Air Partnership (WRAP) and (2) the 

individual source CALPUFF modeling performed by EPA’s contractor. The 

CMAQ modeling was incorporated into the Arizona Regional Haze SIP and is 

available in the docket for our action on the SIP. An initial draft of the CALPUFF 

modeling was part of the contractor report that Colleen sent to Verle Martz last 

November. PCC’s March 6, 2013 comment letter included comments on this 

modeling and we are taking these comments into account and revising our 

analysis accordingly. However, our modeling expert and other technical staff are 

out of the office for the remainder of the year, so I am unable to provide the 

current draft of this analysis. I would also note that any consideration of 

affordability or economic impacts to the tribe would not fall within the visibility 

analysis, but rather within the analysis of the four statutory reasonable progress 

factors and/or other relevant factors.
I should add that, while we will endeavor to consider any information that 

SRPMIC provides prior to proposal, at this point I cannot guarantee that we will 

have sufficient time to incorporate any additional information into our analysis 

before the proposal is issued. We would, however, include any non-CBI 

information in the docket, so that the public could review it and we could consider 

it in our final action. 

I hope that this provides the information SRPMIC needs in order to decide 

whether to submit financial information to EPA. Please let me know if you or your

clients have additional questions. 

Best,

Charlotte 

Charlotte Withey

Office of Regional Counsel

U.S. EPA Region 9

75 Hawthorne Street

San Francisco, CA 94105

Tel: (415) 972-3915

Fax: (415) 947-3570

withey.charlotte@epa.gov

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