Statement of John F. Sullivan, Salt River Project 

EPA Public Hearing on 

Introduction 

Arizona Regional Haze Federal Implementation Plan 

July 31, 2012 • Phoenix, Arizona 

Thank you for the opportunity to comment on EPA's proposed action to 

promulgate a Federal Implementation Plan ("FIP") for three coal-fired 

electric generating facilities in Arizona. My name is John Sullivan and I 

am the Associate General Manager for Resource Management and 

Chief Resource Executive at the 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 of the three facilities affected by 

EPA's proposed action. 

SRP is committed to clean air and improved visibility. Indeed, SRP is in 

the final stages of installing extensive new pollution control 

equipment at Coronado at a cost of over $500 million. EPA's 

proposed FIP is particularly troubling as it calls for additional controls 

even before the current equipment installation process is complete. 

SRP believes that the proposed FIP is legally flawed, and is based on 

inaccurate cost analysis and defective modeling. SRP respectfully 

requests that EPA withdraw its proposal and work collaboratively with 

the State of Arizona to approve the State's entire regional haze 

implementation plan. 
Statement of John 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 a variety of sources 

that contribute to regional haze, including mobile sources, wildfires and 

industrial facilities. EPA should consider, and act on, all of these 

measures together rather than singling out three power plants for 

imposition of overly stringent NOx limits, especially considering that 

NOx emissions from power plants are responsible for less than 5% of 

the haze in this region. 

Moreover, EPA's approach inappropriately overrides 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 technology to reduce both S02 

and NOx emissions. When SRP agreed to install these controls, it was 

with the understanding that they would address EPA's requirements for 

Best Available Control Technology {"BACT"). BACT emission limitations 

are based on the maximum degree of control that can be achieved at a 

new source 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 not justified in imposing additional controls at 

Coronado through a regional haze FIP. 
Statement of John 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 engineering firms 

in favor of cost estimates based on generic assumptions. SRP has 

retained the engineering consulting firm Sargent & Lundy to review the 

initial cost estimates used for the emission control projects 

approaching completion at Coronado. Although EPA believes SRP's 

estimates to be too high, the cost of the 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 1 will cost only $57 million-about one-half of SRP's current 

estimate of more than $110 million. 

EPA's Modeling Shows No Perceptible Visibility Benefits 

Finally, EPA's modeling fails to demonstrate that there would be any 

perceptible visibility benefit from implementation of the 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 to the human eye. EPA's visibility 

modeling overestimates the visibility benefits from the proposed BART 

limits. Although SRP has significant concerns with EPA's modeling, we 

note that even this modeling approach found that none of the 

proposed control scenarios would improve visibility by 1 deciview at 

any of the Class I areas near Coronado. This finding alone is enough 
Statement of John 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 more than $110 

million on additional control equipment at Coronado. 

EPA's proposed rule tries to obscure this key conclusion-that the FIP's 

costly NOx controls would produce no humanly perceptible visibility 

improvement-by applying a "cumulative" deciview metric. SRP and 

others have objected to use of this metric in comments on previous 

EPA actions, and SRP reiterates its objections here. As EPA is aware, 

the deciview metric is a measure of an individual's ability to perceive 

haze from a single viewpoint, and it is improper to imply otherwise by 

summing modeled, hypothetical visibility impacts from multiple sites 

to suggest that EPA control options will realize visibility benefits 

when, in fact, no such visibility benefits will occur. As we all know, it is 

impossible for a single visitor to be at multiple viewpoints at multiple 

parks at the 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 of the FIP in 

favor of the state's comprehensive implementation plan.