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 a ffected 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 statut ory 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

p erformed 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 th e 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 revisi ng 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 inf ormation 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

informatio n 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

wi they.charlotte@epa.gov

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