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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 OutdoorCouncil would like to offerthe 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 EPAto require the adoption ofBest 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 theTASCO facility in Nampa. However, we believe that at a minimum BART should berequired 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 impactvisibility ill Wyoming Class I
areas.

At a minimum, the Bridger and Fitzapatrick Wilderness Class I areas could be negatively impacted by these plants becausethey are directly downwind from them, and these Class 1areas 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 atthe North Absoraka and BridgerWilderness Areas in Wyoming on the twenty percent worst impaired days. 76 Fed. Reg. at 1586. 

### It also states, "The greatest improvement from BARTcontrols at Mansanto/P4 is seen in the Teton Wilderness Area in Wyoming."Id. at 1589. Thus, it is clearthatIdaho sourcesof pollution should be a principle area ofconcern relativeto protecting visibility in Wyoming Class 

### Jareas. And given thatthe 

### lR. Simplot and NU West plants are directly upwind and in close proximity to Wyoming Class I areas, it seems clearthey should merit special attention through a requirementfor the installation ofHART. Data the State of Wyoming has developed for its draft regional haze rule SIP also make it clearthat Idaho

sources ofair pollution are one ofthe most significant contributors to visibility impairing haze in Wyoming Class I areas. See**http://deq.sta!9.,,yy.us{!!q4'~ionalhaze.asp** (presentingthe draft Wyoming section 309 and 309(g) SIPs).



### In considering Idaho's proposed SIP, the EPA concludedthatthe explanation for the 0.5 dv threshold provided by the State to determine sources ofemissions "subjectto BART" "is not adequatetojustifythe 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 capturingthose 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 underconsideration in this analysis seem to relate primarily and perhaps entirely to the three Class I areas entirely within Idaho'sjurisdiction: Craters ofthe Moon National Monument, Sawtooth Wilderness Area, and Selway-BitterootWilderness Area. Butthese Class I areas are distinctly upwind ofthe J.R. Simplot and NUWest plants, so it is not surprising they would experience little impactfrom these emissions sources. But
as pointed out, all seven Wyoming Class I areas, and especially the Bridgerand Fitzpatrick Wilderness Areas, are directly downwind ofthese plants, and in quite close proximitytothem. Thus, absent empirical data to the contrary, there should be no finding that theJ.R. Simplot and NU West plants are not significantly impacting Wyoming Class I areas. Accordingly, we believe that Region 10 shouldmake good on its finding thatthe 0.5 dv threshold is not adequateto avoid the requirement for BARTto be installed because there is likely no objective basisto claim thatthe J.R. Simplot and NU Westplants have "relatively limited impact on visibility" when it comes to 

### Wyoming Class (areas. Ifthe greatest improvements due to BART being required on theMonsanto/P4 Plant are seen at the Teton Wilderness area, it seems very likelythateven greater benefits would be seen atthe Bridger and Fitzpatrick Wilderness areas ifBART were required for the J.R. Simplot and NU West plants. Consequently BART should be required for these sources ofemissions.

Thankyou for consideringthese comments.
Sincerely, '\)

# ~).~. Bruce Pendery

cc: Jim Martin, EPA Region 8 Callie Videtich, EPA Region 8 Steven Dietrich, Wyoming Air Quality Division

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