# Pinal County Governmental Alliance, Inc. 510 E

. Florence Blvd. Casa Grande Arizona 85222 Telephone: 520-421-8600 Fax: 520-421-8604

April 7, 2010

Ms. Colleen McKaughan Associate Director, Air Division Region IX United States Environmental Protection Agenc y 75 Hawthorne Street San Francisco , CA 94105
RE: Assessment of Anticipated Visibility Improvements at Surrounding Class I Areas and Cost Effectiveness of Best Available Retrofit Technology for Four Comers Power Plant and Navajo Generation Station: Advance Notice of Proposed Rulemaking , Docket No. EPA-R09-0AR 2009 0598
Dear Ms. McKaughan: Regarding the August 28 , 2009 , Advanced Notice ofProposed Rulemaking (ANPR) on Assessment ofAnticipated Visibility Improvements at Surrounding Class I Areas and Cost Effectiveness of Best Available Retrofit Technology (BART) for Four Comers Power Plant and Navajo Generating Station (NGS). The members ofthe Pinal County Government Alliance (PCGA) respectfully submit the following position:
It is the position ofthe PCGA that the Navajo Generating Station , provides a low cost source ofpower for CAP pumping that would be complicated and costly to replace and that loss ofNGS power would undermine existing water rights agreements and threaten water supplies to both Native American tribes and Arizona communities.
It is the position ofthe PCGA that the non-Indian and the Indian water users are the water users who would be most adversely affected by the estimated $9 .85 per acre-foot increase in energy charges that would result from installment ofthe selective catalytic reduction equipment required by the EPA

. It is the position ofthe PCGA that the owners of the Navajo Generating Station have agreed to voluntarily install improvements (low NOx burners and separated over fire air) that would improve air quality in the region ofthe generating plant and that this approach takes appropriate incremental steps toward achieving visibility goals while considering the associated costs to the water users.

MEMBERS Apac he Junction - Casa Grande - Centra l Ar izona Co llege D istrict - Cent ral A rizona Irrigation & D rainage D istrict Coo lidge - E loy - Florence - Kearny - Maricopa - Mar icopa - P inal County - Queen Creek Santa Cruz Water & Power D istrict AssociationsIt is the position ofthe PCGA that for the partners ofNavajo Generating Station an alternative to the cost of installing the selective catalytic reduction equipment may be to close the Plant by 2016 (the date for completion of the SCR installation); closing the Plant would severely increase both energy and water costs for the non-Indian and Indian water users.
And , it is the position ofthe PCGA that the water users have been granted rights to exclusively use discounted electrical power generated by the Navajo Generating Station for pumping water to the municipalities and the tribes in Pinal County , that installation of selective catalytic burners would present a detrimental economic hardship to the nonIndian and Indian water users ofthe Central Arizona Water Conservation District , and that the EPA should accept installation of low NOx burners and separated over fire air at the Navajo Generating Station as Best Available Retrofit Technology (BART) for the control ofoxides ofnitrogen (NOx)

. The Pinal County Governmental Alliance is a voluntary association consisting ofbut not limited to governmental agencies , Native American Indian Communities , Educational Institutions , and utility organizations in Pinal County with concerns in the areas ofpolicy , planning , education, development and management. The underlying concept ofthe Alliance is that stakeholders , who are the units closest to the people , should exercise the basic initiative and leadership in the area ofpolicy , planning , education, development and management. The Pinal County Governmental Alliance affords the participating entities an opportunity to collectively use their resources to address those issues which have a significant regional impact.
The Alliance is an association through which the individual members can work effectively and cooperatively to position governmental entities ofPinal County in the forefront ofpolicy development and planning in the State of Arizona

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# »:**~..,,-~~-** Mayor

## Byr~**Ja~kson** Chairman Pinal County Governmental Alliance
Cc: Governor Jan Brewer PCGA Members

MEMBERS Apache Junct ion - Casa Grande

- Central Arizona College D istrict - Cent ral Arizona Irrigation & Dra inage Distr ict Coo lidge

- E loy - Florence - Kearny - Mar icopa - Mar icopa - P inal Cou nty - Q ueen Creek Santa Cruz Water & Power D istrict Associations