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 Agency

75 Hawthorne Street

San Francisco, CA 94105

RE: Assessment of Anticipated Visibility Improvements at Surrounding Class I Areas

and Cost Effectiveness ofBest 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 of Proposed Rulemaking (ANPR) on

Assessment of Anticipated 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 of power 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 ofthe 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 Arizona College District - Central Arizona Irrigation & Drainage District

Coolidge - Eloy - Florence - Kearny - Maricopa - Maricopa - Pinal County - Queen Creek

Santa Cruz Water &Power District Associations
It 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 ofthe 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 of oxides of nitrogen (NOx).

The Pinal County Governmental Alliance is a voluntary association consisting of but not

limited to governmental agencies, Native American Indian Communities, Educational

Institutions, and utility organizations in Pinal County with concerns in the areas of policy,

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 of policy, 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 of Pinal County in the

forefront of policy development and planning in the State of Arizona.

~~e~rQ~I~~I,:::::::=:::: ,,----~ ~-~ »: ~..,,-~~- Mayor Byr~ Ja~kson Chairman

Pinal County Governmental Alliance

Cc: Governor Jan Brewer

PCGA Members

MEMBERS

Apache Junction - Casa Grande - Central Arizona College District - Central Arizona Irrigation & Drainage District

Coolidge - Eloy - Florence - Kearny - Maricopa - Maricopa - Pinal County - Queen Creek

Santa Cruz Water & Power District Associations