April 7, 2011

Mr. Keith Rose EPA Region 10 Office of Air, Waste and Toxics, AWT

- 107 1200 Sixth Avenue, Suite 900 Seattle, WA 98101

Via email to R10

- Public_Comments@epa.gov

Dear Mr. Rose,

On behalf o f the National Parks Conservation Association (NPCA) , we respectfully submit the following comments on the proposed approval of the Oregon Regional Haze (RH) State Implementatio n Plan (SIP). Our organization represent s tens of thousands of Washingtonians and thousands of people throughout the nation that care deeply about protecting the air quality in our national parks and wilderness areas in the Northwest . We strongly encourage the Environmental Protection Agency (EPA) Region 10 to revise the Oregon RH SIP by requiring

further reductions in haze

- causing pollutants and otherwise advancing measures that will improve regional visibility as required by the Clean Air Act’s regional haze program.

We hereby adopt and resubmit the comments from the National Par k Service (NPS) dated October 1, 2010 (NPS Comments) , from NPCA dated October 1, 2010 (NPCA Comments), and from a coalition of environmental and conservation groups dated November 15, 2010 (Coalition Comments). As discussed in brief below, we believe that these comments have not been substantively or adequately addressed to date.

In particular, the Coalition Comments address the Oregon RH SIP pro posed on October 29,

2010 , which is vi rtually identical to the plan EPA proposes to approve . These comments id entify and describe a variety of concerns which still pertain to the proposed plan , specifically the determination of Best Available Retrofit Technology (BART) at the Boardman power plant, including:

1) The numerous loopholes incorporated into Oregon’s Admini strative Rules (OAR 340

- 223

- 0010 through 340

- 223

- 0080), including provisions that would inappropriately remove the requirement for Dry Sorbent Injection (DSI), the selected technology for the removal of sulfur dioxide (SO2). The conditions under which DSI would not be required, including a post

- BART determination of technical infeasibility or the triggering of additional Clean Air Act obligations, should not be allowed to preclude the installation of BART, which is by definition technically feasible. It is also not clear if there would be any public input into the triggering of these requirements.Page 2 of 2

2) The inappropriate double

- counting of “remaining useful life” to justify lesser pollution control requirements.

3) The dismissal of controls that are cost

- effective even with the state’s $7,300/ton and $10 million/dv thresholds, including semi

- dry flue gas desulfurization (SDFGD) , Selective

Non

- Catalytic Reduction (SNCR), and Selective Catalytic Reduction (SCR) , through inappropriately inflated costs, underestimates o f control effectiveness, arbitrarily shortened equipment life due to excessively long assumed installation times, and double

counting the impact of remaining useful life.

Finally, we note that on September 1, 2010, Oregon released a proposed rulemaking f or public comment that included BART requirements based on a variety of closure dates, including 2020 (see A ppendix D

- 6 of the Revised 2009 Oregon Regional Haze Plan ). In that proposal, which, though a fair approximation of BART, could itself have been improved, a shutdown of 2020 required installation of SDFGD and SNCR. These requirements for a 2020 closure date were

relaxed significantly (basically equivalent to the BART determination for a 2018 shutdown) in the proposal released on October 29, 2010, which is reflected in the plan EPA proposes to

approve (see Appendix D

- 7).

We do not believe there is sufficient justificati on for this relaxation of BART; in fact, the relaxation appears arbitrary. The most obvious example of this is the sudden determination that

SDFGD is not cost effective for a 2020 shutdown

– despite the asse ssment a few months earlier

that the same cost , which is below the state’s $7,300/ton threshold both in its own right and as a matter of incremental cost, was in fact cost effective. SNCR, cost effective just a short time prior, is treated similarly.

For the reasons noted above and in the attached documents , we believe that the proposed approval of the Oregon Regional Haze SIP is in appropriate

. We ask that EPA revise the Oregon RH plan to reflect more realistic, updated costs and benefits of air pollution controls, to require more stringent controls and emissions limits as a part of its BART determinations, and to recirculate its revised draft for public review.

Thank you for the opportunity to comment on the proposed approval of the Oregon Regional Haze plan.

Sincerely,

Nathan Miller Air Quality Specialist

National Parks Conservation Association 8 S. Michigan, Suite 2900 Chicago, IL 60603

312.263.0111 nmiller@npca.org