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 of the National Parks Conservation Association (NPCA), we respectfully submit the 

following comments on the proposed approval of the Oregon Regional Haze (RH) State 

Implementation Plan (SIP). Our organization represents 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 Park 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 proposed on October 29, 

2010, which is virtually identical to the plan EPA proposes to approve. These comments identify 

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 Administrative 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. 
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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 of control effectiveness, arbitrarily 

shortened equipment life due to excessively long assumed installation times, and doublecounting the impact of remaining useful life. 

Finally, we note that on September 1, 2010, Oregon released a proposed rulemaking for public 

comment that included BART requirements based on a variety of closure dates, including 2020 

(see Appendix 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 justification 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 assessment 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 inappropriate. 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