UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460 


APR 172012 


lFFICE. OF 

AIR AND RADIATION 

Mr. David Modeer 

General Manager 

Central Arizona Project 

23636 North Seventh Street 

Phoenix, Arizona 85024 

Dear Mr. Modeer: 

Thank you for your letter dated March 8, 2012 to Administrator Jackson, Secretary Chu, and Secretary 

Salazar regarding Navajo Generating Station. Administrator Jackson has asked me to draft a response to· 

your letter. 

In your letter, you described in detail the unique and important role of the Navajo Generating Station 

(NGS) in providing.Colorado River water to Arizona, including some of the results of the recent 

National Renewable Energy Laboratory's (NREL) study on NGS. Your letter also described the need for 

EPA to complete the Best Available Retrofit Technology (BART) rulemaking for Navajo Generating 

Station. You expressed concern that the February 16,2012 letter from Administrator Jackson to 

Secretaries Salazar and Chu suggest a potential change in EPA's focus on NGS. You also expressed 

concern that "the letter appears to be leading toward a near-tenn renewable energy option for NGS." 

I assure you that the U.S. Environmental Protection Agency (EPA) is aware of the interest ofmany 

stakeholders that we issue a proposed BART decision as soon as possible and is working towards 

proposing its BART detennination for NGS this summer. The EPA had delayed its BART detennination 

in order to allow the completion of the NREL study on Navajo Generating Station that you cited. The 

NREL study has been submitted to the EPA, and our Region 9 office, which has the lead responsibility 

for this rulemaking, is moving forward to complete its technical analysis. Due to the substantial interest 

in this action, we anticipate a longer than average public comment period on the proposed BART 

detennination. EPA will respond to all public comments received before finalizing this action. 

As discussed above, EPA's short-tenn goal is to complete the BART analysis and publish a proposed 

rule for public comment this summer. In addition, EPA, the Department of Energy, and the Department 

of Interior have begun to discuss the role ofrenewable energy development in meeting the needs of the 

various stakeholders that Navajo Generating Station now serves. From the beginning of our stakeholder 

discussions about the Navajo Generating Station, EPA has recognized that, like any power plant, Navajo 

Generating Station will not be operating in its current configuration forever, and that planning for a 

transition will be necessary. As a result, EPA agrees that further research by NREL on the technical, 

economic, environmental, social, regulatory and policy aspects of all feasible long-tenn power 

generation alternatives, including potential renewable sources of energy, would be useful. 

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EPA understands the significance of Navajo Generating Station to the Central Arizona Project and the 

variety ofTribal, municipal, and agricultural customers you serve, and we recognize the complex effects 

of the decisions we are facing. We are making every effort to work through these issues with our federal 

partners and the many stakeholders involved in a timely manner. 

I appreciated the opportunity to discuss your concerns in person during your recent visit to Washington, 

D.C. Please do not hesitate to contact me or my senior advisor on this issue, Janet McCabe, Principal 

Deputy Assistant Administrator for the Office of Air and Radiation, if you have additional questions or 

concerns. 

Sincerely, 

Gina McCarthy 

Assistant Administrator 

cc; Jared Blumenfeld, Region 9 Administrator, USEPA