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

Dear Mr. Dietrich:

The Forest Service (FS) has been made aware ofproposed revisions to the Wyoming Regiona aze State

Implementation Plan (SIP). In the past, communication between the FS and the Wyoming DEQ about

regional haze SIPs has been adequate, however the FS has no records ofthe State ofWyoming contacting

us about this SIP revision. We ask to be provided with a full 60-day comment period, as is required in

federal regulation for all SIP revisions (see below).

This plan's intent is to demonstrate how the State ofWyoming will make reasonable progress toward

meeting the national goal ofpreventing any future, and remedying any existing, impairment of visibility

in mandatory Class I areas.

The regulations describing what these 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, Flat Tops, and Eagles Nest Class I Wildernesses, the FS is very interested in

the Wyoming Regional Haze Plan.

The regional haze regulations at 40 CFR 51.308(i) require consultation between the FLMs and the State.

These provisions apply to 309(g) SIPs and SIP revisions. Specifically:

The State must provide the Federal LandManager with an opportunityfor consultation, in

perSon and at least 60 days prior to holding any public hearing on an implementation plan

(or plan revision)for regional haze required by this subpart. This consultation must include

the opportunityfor the affected Federal Land Managers to discuss their:

(i) Assessment ofimpairment ofvisibility in any mandatory Class I Federal area; and

(ii) Recommendations on the development ofthe reasonable progress goal and on the

development and implementation ofstrategies 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 at this time regarding the 309(g) material:

I. In section 8.3.5, Wyoming indicates that the DEQ can't complete evaluation of oil and gas

contributions without the WRAP Phase III report. The FS understands that the Phase III work is

in progress for the Wind River, Upper Green River, and Powder River Basins. Completions of

these inventories are expected beginning July 20II. We look forward to Wyoming addressing

this important emission category when the Phase III report 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 significantly impact visibility in Class I areas in Wyoming and in other

states. Therefore, the FS requests that the 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 of natural 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