### Statement ofJohn F. Sullivan, Salt River Project EPA Public Hearing on

Introduction Arizona Regional Haze Federal Implementation Plan July 31, 2012 • Phoenix, Arizona

Thank you forthe opportunityto comment on EPA's proposed action to promulgate a Federal Implementation Plan ("FIP") forthree coal-fired electric generatingfacilities in Arizona. My name is John Sullivan and I
am the Associate General Managerfor Resource Management and Chief Resource Executive atthe Salt River Project Agricultural Improvement and Power District ("SRP"). SRP provides retail electric service to over 950,000 customers and operates Coronado Generating Station near St. Johns, Arizona, one ofthethree facilities affected by EPA's proposed action.

SRP is committed to clean air and improved visibility. Indeed, SRP is in thefinal stages of installing extensive new pollution control equipment at Coronado ata cost ofover $500 million. EPA's proposed FIP is particularlytroubling as it calls for additional controls
even beforethe current equipment installation process is complete. SRP believes thatthe proposed FIP is legallyflawed, and is based on inaccurate cost analysis and defective modeling. SRP respectfully requests that EPA withdraw its proposal and work collaboratively with the State ofArizona to approve the State's 

### entire regional haze implementation plan.Statement ofJohn F. Sullivan, Salt River Project Arizona Regional Haze FIP Public Hearing July 31, 2012 Page 2



### EPA's Actions are Legally Flawed The Arizona Department of Environmental Quality e'ADEQ'') developed and submitted a comprehensive State Implementation Plan {"SIP") that included a large number of measures to address avariety ofsources that contribute to regional haze, including mobile sources, wildfires and industrial facilities. EPA should consider, and act on, all ofthese
measures together ratherthan singling outthree power plantsfor imposition ofoverlystringent 

### NOx limits, especially consideringthat 

### NOx emissions from power plants are responsible for less than 5% of the haze inthis region.

Moreover, EPA's approach inappropriatelyoverrides the courtapproved agreement executed by EPA and SRP to upgrade Coronado's emission controls. In the agreement, SRP committed to the installation of new state-of-the-art emission-control technologyto reduce both S02 

### and 

### NOx emissions. When SRP agreed to install these controls, itwas with the understandingthattheywould address EPA's requirements for Best Available Control Technology {"BACT"). BACT emission limitations
are based on the maximum degree ofcontrol that can be achieved at a


### newsource and have been recognized as more stringent limitations than those authorized under regional haze retrofit regulations. Therefore, the controls SRP is installing provide "better-than-BART" compliance, and EPA is notjustified in imposing additional controls at Coronado through a regional haze FIP.Statement ofJohn F. Sullivan, Salt River Project Arizona Regional Haze FIP Public Hearing July 31, 2012 Page 3

EPA's Cost Analysis is Inaccurate Also troubling to SRP is EPA's disregard for previously submitted cost analyses for controls at Coronado. There is no basis for EPA to dismiss site-specific costs developed by professional engineeringfirms in favor ofcost estimates based on generic assumptions. SRP has retained the engineering consulting firm Sargent 

### & Lundyto review the initial cost estimates used forthe emission control projects approaching completion at Coronado. Although EPA believes SRP's estimates to be too high, the cost ofthe SCR on Coronado Unit 2 was estimated to be approximately $66 million and the actual costs are expected to be $98 million. Yet, EPA is projecting that a second SCR on Unit 1will cost only $57 million-about one-halfofSRP's current estimate of more than $110 million.

EPA's Modeling Shows No PerceptibleVisibility Benefits Finally, EPA's modelingfails to demonstratethatthere would be any perceptible visibility benefitfrom implementation ofthe FIP. EPA uses a metric known as a 11deciview" to measure the amount of haze present at each Class I area. EPA's guidance describes 1 deciview as the measured change in haze discernible tothe human eye. EPA's visibility modeling overestimates thevisibility benefits from the proposed BART limits. Although SRP has significant concerns with EPA's modeling, we notethat even this modeling approach found that noneofthe proposed control scenarios would improvevisibility by 1 deciview at anyofthe Class I areas near Coronado. This finding alone is enoughStatement ofJohn F. Sullivan, Salt River Project Arizona Regional Haze FIP Public Hearing July 31, 2012 Page4



### to conclude that SRP should not be required to spend morethan $110 million on additional control equipment atCoronado.

EPA's proposed rule tries to obscure this key conclusion-thatthe FIP's costly 

### NOx controls would produce no humanly perceptiblevisibility improvement-by applying a "cumulative" deciview metric. SRP and others have objected to use ofthis metric in comments on previous EPA actions, and SRP reiterates its objections here. As EPA is aware, the deciview metric is a measure ofan individual's abilityto perceive haze from a single viewpoint, and it is improperto implyotherwise by summing modeled, hypotheticalvisibility impactsfrom multiple sites to suggest that EPA control optionswill realize visibility benefits when, in fact, no such visibility benefits will occur. As we all know, it is impossible for asingle visitorto be at multipleviewpoints at multiple parks atthe same time.

Conclusion To conclude, EPA's proposed action is misguided and unsupported. SRP's installation of new state-of-the-art, better-than-BART controls at Coronado Generating Station, coupled with the legal and technical infirmities in EPA's proposed rule, warrant withdrawal ofthe FIP in favor ofthe state's comprehensive implementation plan.