( 

444 East 800 North 

Logan, UT 84321 

t: 435,752.2111 

1. 435753.7447 

Mr. Steve Body 

Docket ID No. EPA-RlO-OAR-201O-1072 

U.S. EPA Region 10, Suite 900 

Office ofAir, Waste and Toxins 

1200 Sixth Avenue 

Seattle, W A 98101 

January 18, 2011 

Dear Mr. Body, 

The Wyoming Outdoor Council would like to offer the following comments on the 

proposed rule to approve promulgation ofthe regional haze rule state implementation 

plan (SIP) for the State ofIdaho. 76 Fed. Reg. 1579 (Jan. 11,2011). 

We urge the EPA to require the adoption of Best Available Retrofit Technology (BART) 

for additional emissions sources in Idaho. As proposed, BART would only be required 

for the Monsanto/P4 Production LLC facility in Soda Springs and the TASCO facility in 

Nampa. However, we believe that at a minimum BART should be required for the J.R. 

Simplot Don Plant in Pocatello and the NU WestiAgrium plant in Soda Springs because 

these plants could and very likely do negatively impact visibility ill Wyoming Class I 

areas. 

At a minimum, the Bridger and Fitzapatrick Wilderness Class I areas could be negatively 

impacted by these plants because they are directly downwind from them, and these Class 

1 areas are little more than 60 miles from Soda Springs as the crow flies. The EPA 

recognizes in the Federal Register notice that Idaho is the second ranked contributor to 

visibility impairing pollutants at the North Absoraka and Bridger Wilderness Areas in 

Wyoming on the twenty percent worst impaired days. 76 Fed. Reg. at 1586. It also 

states, "The greatest improvement from BART controls at Mansanto/P4 is seen in the 

Teton Wilderness Area in Wyoming." Id. at 1589. Thus, it is clear that Idaho sources of 

pollution should be a principle area ofconcern relative to protecting visibility in 

Wyoming Class J areas. And given that the lR. Simplot and NU West plants are directly 

upwind and in close proximity to Wyoming Class I areas, it seems clear they should merit 

special attention through a requirement for the installation of HART. Data the State of 

Wyoming has developed for its draft regional haze rule SIP also make it clear that Idaho 

sources of air pollution are one of the most significant contributors to visibility impairing 

haze in Wyoming Class I areas. See http://deq.sta!9.,,yy.us{!!q4'~ionalhaze.asp 

(presenting the draft Wyoming section 309 and 309(g) SIPs). 

In considering Idaho's proposed SIP, the EPA concluded that the explanation for the 0.5 

dv threshold provided by the State to determine sources of emissions "subject to BART" 

"is not adequate to justify the selection ofsuch a threshold." 76 Fed. Reg. at 1586. The 

EPA nevertheless proposed to aIlow the 0.5 dv threshold because, the EPA claimed, the 

five sources ofemissions that would not be required to install BART (including the J.R. 

1 


Working to protect public lands and wildlife since 1967 

.. 


Simplot and NU West plants) have "relatively limited impact on visibility" and thus 

"Idaho could have reasonably concluded that a 0.5 dv threshold was appropriate for 

capturing those BART eligible sources with significant impacts on visibility in Class I 

areas." Id. 

We believe, however, that even ifthis rationale might be valid relative to impacts to 

Class I areas in Idaho, it fails when Wyoming Class I areas are considered. TIle impacts 

apparently under consideration in this analysis seem to relate primarily and perhaps 

entirely to the three Class I areas entirely within Idaho's jurisdiction: Craters ofthe Moon 

National Monument, Sawtooth Wilderness Area, and Selway-Bitteroot Wilderness Area. 

But these Class I areas are distinctly upwind ofthe J.R. Simplot and NU West plants, so 

it is not surprising they would experience little impact from these emissions sources. But 

as pointed out, all seven Wyoming Class I areas, and especially the Bridger and 

Fitzpatrick Wilderness Areas, are directly downwind ofthese plants, and in quite close 

proximity to them. Thus, absent empirical data to the contrary, there should be no 

finding that the J.R. Simplot and NU West plants are not significantly impacting 

Wyoming Class I areas. 

Accordingly, we believe that Region 10 should make good on its finding that the 0.5 dv 

threshold is not adequate to avoid the requirement for BART to be installed because there 

is likely no objective basis to claim that the J .R. Simplot and NU West plants have 

"relatively lim ited impact on visibility" when it comes to Wyoming Class (areas. If the 

greatest improvements due to BART being required on the Monsanto/P4 Plant are seen at 

the Teton Wilderness area, it seems very likely that even greater benefits would be seen 

at the Bridger and Fitzpatrick Wilderness areas if BART were required for the J .R. 

Simplot and NU West plants. Consequently BART should be required for these sources 

of emissions. 

Thank you for considering these comments. 

Sincerely, '\) 

~).~. 

Bruce Pendery 

cc: 	Jim Martin, EPA Region 8 

Callie Videtich, EPA Region 8 

Steven Dietrich, Wyoming Air Quality Division 

2