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Maurin, Lawrence

From: Maurin, Lawrence

Sent: Thursday, December 17, 2015 11:05 AM

To: 'john_nystedt@fws.gov'

Cc: 'Marr, Carrie'; 'brenda_smith@fws.gov'; Ann Lyons; Gerardo Rios 

(Rios.Gerardo@epa.gov)

Subject: Request for US FWS Concurrence - No Effect on NGS Project

Hi John,

Based on discussion over the phone with you on Tuesday, December 15th, US Fish and Wildlife Service has agreed, based

on information provided to USFWS on November 20, 2015, that the Refined Coal Treatment System Project at Salt River

Project’s Navajo Generating Station will have no effect on any federally‐listed endangered or threatened species or

critical habitat for such species. The Refined Coal Treatment System Project is not expected to emit any pollutants which

would exceed the Significant Impact Limits (SILs) outside the existing boundaries of the facility. EPA has reviewed the

application and modeling report from SRP for the Refined Coal Treatment System Project and has concluded that the

increase in PM, PM10, and PM2.5 emissions which are expected from the Project will not affect the California Condor or

any other federally‐listed threatened or endangered species because emissions from the Project extending beyond the

existing facility boundary are insignificant and do not result in any ambient air concentrations which would result in

exceedance of any applicable National Ambient Air Quality Standards (NAAQS).

EPA would like to request concurrence from USFWS with our determination that the Refined Coal Treatment System

Project will have no effect on any federally‐listed endangered or threatened species or critical habitat for such species.

We request specifically that the following items are addressed by USFWS:

1. PM, PM10, and PM2.5 emitted from proposed Refined Coal Treatment System Project are not expected to affect

any federally‐listed endangered or threatened species or critical habitat for such species at the maximum

concentrations modeled at the existing facility boundary.

2. The California Condor (Gymnogyps californianus) is not expected to be affected by the proposed Refined Coal

Treatment System Project. Based on prior discussions with USFWS, this species generally avoids human contact,

and is unlikely to be observed near the developed plant site.

3. The Narrow‐headed Garter Snake (Thamnophis rufipunctatus) and the Northern Mexican Garter Snake

(Thamnophis eques megalops), both of which were added to the Federal Coconino County threatened and

endangered species list since 2008, are not expected to be affected by the proposed Refined Coal Treatment

System Project. Based on prior discussions with USFWS, these species do not occur near the Navajo Generating

Station.

We would like to request that, if possible, this concurrence come in the form of a letter, addressed to:

Larry Maurin

Air Permits Office (AIR‐3)

U.S. Environmental Protection Agency, Region 9

75 Hawthorne Street

San Francisco, CA 94105

and sent electronically to: Maurin.lawrence@epa.gov.

If concurrence with this determination is not possible by letter, we would accept concurrence via email. Please let me

know if you have any questions. Thank you for you help.
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Sincerely,

Larry

Larry Maurin

Air Permits Office (AIR‐3)

U.S. Environmental Protection Agency, Region 9

75 Hawthorne Street

San Francisco, CA 94105

(415) 972-3943 (phone) / (415) 947-3579 (fax) 

Maurin.Lawrence@epa.gov