# USDA United States Department of Agriculture Forest Service Rocky Mountain Region 740 Simms Street Golden, CO 80401 Voice: 303-275-5350 TOO: 303-275-5367 File Code: 2580 Date: 

### DEC 3 2010 Steven 

### A. Dietrich Air Quality Administrator Wyoming Dept. ofEnvironmental Quality

- Air Division' 122 W. 25th St. Herschler Building Cheyenne, WY 82002 DearMr. Dietrich: The Forest Service (FS) has been made aware ofproposedrevisions to the Wyoming Regiona aze State Implementation Plan (SIP). In the past, communicationbetween the FS and the Wyoming DEQ about regional haze SIPs has been adequate, howeverthe FS has no records ofthe State ofWyoming contacting us aboutthis SIP revision. We askto be provided with a full 60-day commentperiod, as is required in federal regulation for all SIP revisions (see below). This plan's intentis to demonstrate how the State ofWyoming will make reasonable progress toward meeting the national goal ofpreventing any future, and remedying any existing, impairment ofvisibility in mandatory Class I areas. The regulations describing whatthese plans should contain are found at 40 CFR 51.300 through 309. As the Federal Land Manager (FLM) for the North Absaroka, Washakie, Teton, Fitzpatrick, Bridger, Savage Run, Mount Zirkel, Rawah, FlatTops, and Eagles NestClass I Wildernesses, the FS is very interested in the Wyoming Regional Haze Plan. The regional haze regulations at40 CFR 51.308(i) require consultationbetweenthe FLMs and the State. These provisions apply to 309(g) SIPs and SIP revisions. Specifically: The State mustprovide the FederalLandManager with an opportunity for consultation, in perSon andat least 60 daysprior to holding anypublic hearing on an implementationplan (orplan revision)for regional haze requiredby this subpart. This consultation must include the opportunity for the affectedFederalLandManagers to discuss their: (i) Assessment of impairmentof visibility in any mandatory Class I Federal area; and 

### (ii) Recommendations on the development of the reasonableprogress goal andon the developmentandimplementation of strategies to address visibility impairment. The FS has conducted a cursory review ofthe 309 and 309(g) material dated October 21, 2010. We request the full 60 days, through December 20ti', to complete a more thorough review. In the interim, we can offer the following comments atthis time regarding the 309(g) material: I. In section 8.3.5, Wyoming indicates that the DEQ can't complete evaluation ofoil and gas contributions withoutthe WRAP Phase III report. The FS understands thatthe Phase III workis in progress for the Wind River, Upper Green River, and PowderRiverBasins. Completions of these inventories are expectedbeginning July 20II. We lookforward to Wyoming addressing this importantemission category when the Phase IIIreport is completed; however, these reports

It's Cool to Be Safe Printed on Recycled Paper (')Steven A. Dietrich, WY-DEQ 2

apparently will not address oil and gas development in the entire State. Oil and gas activities throughout Wyoming may significantlyimpact visibility in Class I areas in Wyoming and in other states. Therefore, the FS requests thatthe efforts be expanded to include all potential visibilityimpairing oil and gas related emissions.
2. Figure 8.3 .6-7 does not appear to reflect the changes in BART compliance dates. The FS compliments you on your hard work and dedication to significant improvement in our nation's air quality values and visibility. Cooperative efforts such as these ensure that, together, we will continue to make progress toward the Clean Air Act's goal ofnatural visibility conditions at our Class I wilderness areas and parks. We appreciate the opportunity to continue to work closely with your agency as you develop this SIP. If you have questions or comments, please contact Randy Karstaedt, Director, Physical Resources at (303) 275·5374, or by email atrkarstaedt@fs.fed.us. Sincerely,

cc: 

### Patricia F Brewer, Tim 

### Allen