U.S. Environmental Protection Agency EPADocket Center Docket: EPA-HQ-OAR-2014-0464 Mail Code 28221T 1200 PennsylvaniaAvenue, NW Washington, D.C. 20460 March 31,2016

RE: Docket ID No. EPA-HQ-OAR-2014-0464 FILED VIA U.S. MAIL AND EMAIL

Commentsto EPARecommendation for S02NAAQS Designation LDEQAgencyInterestNo. 328
Dear Sir orMadam:
These comments are submittedbythe Louisiana Pulp & PaperAssociation ("LPPA") and concern designations by the U.S. Environmental Protection Agency ("EPA") for the 1-hour sulfur dioxide ("S02") national ambient air quality standard ("NAAQS") in Louisiana. 1 These comments specificallyrelate to the S02NAAQS final designation for the DeSoto Parish area. LPPA has become aware of EPA's proposal to designate a portion of DeSoto Parish, Louisiana as nonattainment with the 1-hour S02 NAAQS. See, Letter from Ron Curry to Gov. John Bel Edwards, dated Feb. 11, 2016, attaching Technical Analysisfor the DeSoto Parish, Louisiana Area ("Technical Analysisfor DeSoto"), pp. 6-19. As discussed in this letter, EPA intends to modify a recommendation of "attainment" by the Louisiana Department of Environmental Quality ("LDEQ") for this geographic area. EPA also intends to include a paper mill located in Mansfield, Louisiana in the nonattainment area within DeSoto Parish in addition to a coal-fired utility.
EPA seeks to include International Paper's Mansfield Mill in the proposed nonattainment area within DeSoto Parish despite the fact that modeling analyses submitted by the Sierra Club and the LDEQ did notinclude S02 emissions from thepapermill. Thus, EPAhas no scientific or technical basis to conclude that the paper mill contributes to concentration gradients near those caused by the coal-fired utility. For this reason, LPPA encourages EPA to make a final designation based solely on the information that has been presented to it, including any supplemental information submitted as a part ofthis public commentperiod.

1The LPPA is a nonprofit Louisiana corporation that includes seven member companies located at eight pulp andpapermills in Louisiana.Docket ID No. EPA-HQ-OAR-2014-0464 March 31,2016 Page2

It is our understanding that International Paper and the LDEQ have submitted (or will submit) comments to EPA related to the S02 NAAQS designation for DeSoto Parish and that these comments may include a higher quality air modeling analysis than what was previously submitted bythe Sierra Club. LPPA urges EPA to closely review the supplemental modeling. If the modeling demonstrates that S02 emissions from the paper mill have a de minimis impact to any modeled exceedances ofthe S02 NAAQS for this area, EPA should unquestionably exclude the paper mill from the final nonattainment area. There is no legal basis to include a stationary source in a nonattainment area simplybecause it emits above a certain threshold. In fact, this is the very reason air modeling is used by EPA and states to determine which geographic areas should be included within a particular boundary. If other modeling supports a designation of attainment for the entire parish, then LPPA urges EPA to accept LDEQ's initial recommendation for this areabyJuly2, 2016. Finally, LPPA urges EPA to make the final designation based solely on what is in the administrative record on orbefore its court-ordered deadline. Based on current information, it is arbitrary and capricious for EPA to include International Paper's Mansfield Mill in the proposed nonattainment area for DeSoto Parish. EPA made several conclusory statements within the technical analysis concerning the paper mill. For example, despite Sierra Club's failure to include the paper mill in its modeling, EPA concluded that "it is likely that the source causes concentration gradients that extend to area impacted by Dolet Hills with some of the higher modeled values that are near the standard." TechnicalAnalysis forDeSoto, p. 10. EPA's analysis further states that the "[i]nclusion ofIP emissions maylikelyincrease modeled valuesjustbelow the standard to exceedance levels." Id., p. 12. EPA's decision to include ornot include the paper mill in a nonattainment area should not be based on conjecture or speculation. Rather, such a weighty and impactful decision should be based on data that is known and that has been closely evaluated and critiqued bythe state and federal agencies. For these reasons, LPPA requests that EPA exclude International Paper's Mansfield Mill from any nonattainment area in DeSoto Parish. LPPA further encourages EPA to consider data that supports an attainment designation for this area. Finally, EPA should base its final decision strictlyon information that is knownto it and hasbeenincluded inthe administrative record. Ifyou have any questions concerningthese comments, I canbereached at (225)336-845. Verytrulyyours,



# J(~5e~ Kyle B. Beall

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