U.S. Environmental Protection Agency 

EPA Docket Center 

Docket: EPA-HQ-OAR-2014-0464 

Mail Code 28221 T 

1200 Pennsylvania Avenue, NW 

Washington, D.C. 20460 

March 31,2016 

RE: Docket ID No. EPA-HQ-OAR-2014-0464 

FILED VIA U.S. MAIL AND EMAIL 

Comments to EPA Recommendation for S02 NAAQS Designation 

LDEQ Agency Interest No. 328 

Dear Sir or Madam: 

These comments are submitted by the Louisiana Pulp & Paper Association ("LPP A") 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 specifically relate to the S02 NAAQS 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 Analysis for the DeSoto Parish, 

Louisiana Area ("Technical Analysis for 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 not include S02 emissions from the paper mill. Thus, EPA has 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, LPP A 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 of this public comment period. 

1 The LPP A is a nonprofit Louisiana corporation that includes seven member companies located at eight 

pulp and paper mills in Louisiana. 
Docket ID No. EPA-HQ-OAR-2014-0464 

March 31,2016 

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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 by the Sierra Club. LPP A 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 of the 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 simply because 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 LPP A urges EPA to accept LD EQ' s initial recommendation 

for this area by July 2, 2016. 

Finally, LPP A urges EPA to make the final designation based solely on what is in the 

administrative record on or before 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." Technical Analysis for DeSoto, p. 10. EPA's analysis 

further states that the "[i]nclusion of IP emissions may likely increase modeled values just below 

the standard to exceedance levels." Id., p. 12. EPA's decision to include or not 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 by the state and federal agencies. 

For these reasons, LPPA requests that EPA exclude International Paper's Mansfield Mill 

from any nonattainment area in DeSoto Parish. LPP A further encourages EPA to consider data 

that supports an attainment designation for this area. Finally, EPA should base its final decision 

strictly on information that is known to it and has been included in the administrative record. 

If you have any questions concerning these comments, I can be reached at (225)336-845. 

Very truly yours, 

J(~5e~ Kyle B. Beall 

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