DCC Board of Directors

Nancy Bale Nan Eagleson Hannah Ragland

Barbara Brease Charlie Loeb Erica Watson

JJ Neville Jared Zimmerman

March 26, 2012

Re: Docket ID No. EPA-R10-OAR-2011-0367

To whom it may concern: 

I am writing on behalf of Denali Citizens Council to express concerns and questions related to 

the Alaska Regional Haze State Implementation Plan (SIP). DCC is a grassroots 501(c)(3) 

conservation organization with over 300 members who live primarily in the Denali Borough and 

who are concerned with public policy related to both the local community and Denali National 

Park and Preserve. Denali provides outstanding wilderness opportunities, including premiere 

views of North America’s tallest peak and visibility unparalleled in other areas in Alaska and the 

United States. The opportunities in Denali are world-renowned, and DCC supports the Regional 

Haze rule and its efforts to preserve the superlative viewsheds that can be found in Denali 

National Park and Preserve. Thank you for considering our comments.

The SIP fails to adequately address the shutdown dates required as part of the Best Available 

Retrofit Technology (BART) determination for Golden Valley Electric Association’s (GVEA) 

Unit #1. When GVEA suggested in comments that a shutdown date was not required for Unit 

#1, the state responded that, “If circumstances change and it makes sense to operate Healy Unit I 

beyond 2024, the Department will evaluate the situation at that time.” This SIP should make 

clear that a shutdown date of 2024 is a requirement for Unit #1 (without further review and 

determinations as part of the Regional Haze Rule), as the state has asserted that it cannot require 

such a shutdown date in current air quality permits. BART guidelines require that if a shutdown 

date “affects the BART determination, this date should be assured by a federally- or Stateenforceable restriction preventing further operation.” This requirement is not addressed in this 

SIP, and Unit #1 shutdown requirements should be formally addressed here.

While Healy Coal Plant’s Unit #2 (i.e. “Healy Clean Coal Plant”) is not currently operating, it is 

inadequate to delay discussion of controls and mitigations related to the plant’s opening and its 

impacts to regional haze. This SIP acknowledges great impacts to regional haze from Unit #2 

operations but fails to consider what mitigations and controls are necessary to preserve visibility 

in Denali’s Class I Airshed if Unit #2 were to begin operations. While the state is adamant that 

Unit #2 operations would be not be a major modification of the plant (requiring further review 

under the Regional Haze Rule), they refuse to consider the permitted emissions from this plant as 

part of this SIP, as if it does not exist. The SIP states that “If brought on line, the point source 

NOx emitted within the Denali Borough would increase by a factor of 4.0 and the Sox would 

increase by a factor of 2.8 (based on permitted not actual emissions). This increase would make 

the Denali Borough the largest sources of anthropogenic emissions and the second largest 

source of all emissions impacting the Denali monitors.” Contradicting the clear impact to 

visibility acknowledged in this statement, the SIP further states that “Since many of the coal fired 
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boiler control options considered in the four-factor analysis have already been implemented at 

this facility, the modeling results provide conflicting views of the potential impacts and the 

facility has an active permit, as a result ADEC is not mandating additional controls prior to 

startup through this SIP.” Considering the proximity to Denali’s Class I airshed, it is crucial that 

the state consider the impacts of Unit #2’s “restart” (and appropriate mitigations and controls

associated with long-term strategies and reasonable progress goals) in its Regional Haze SIP, or 

in air quality permits, prior to the plant’s operation. 

While it appears that this SIP equally considers data from both the Denali Headquarters and 

Trapper Creek monitoring sites, it does not explicitly state that this is the case. The SIP 

describes the Denali Headquarters IMPROVE site as now a “protocol site” (and “originally the 

IMPROVE site”) but does not define the difference between a protocol and primary site, or 

whether data from a primary site would be given preference over a protocol site. Monitoring 

pollutants affecting visibility in Denali should not only (or primarily) consider pollutant 

information south of the Alaska Range, displaced from major sources of pollutants such as the 

adjacent Healy Coal Plant and nearby Fairbanks-area sources. The SIP should clearly state that 

data from both monitoring sites will be given equal consideration in the future and should clarify 

how (or whether) data from primary versus protocol sites would be considered. The Denali 

Headquarters site is the only monitoring site in the entire state that included data for all of 2000-

2004, and data from this site extends over a longer period of time (beginning in 1988) than other 

sites, making it a valuable source for continued data collection and monitoring. Also, the Denali 

Headquarters site is located on the northern side of the Alaska Range, and along the Denali Park 

Road. Using data from Trapper Creek (on the south side of the Alaska Range, over 100 miles 

from the Park Entrance area, and far from Interior Alaskan pollutants that affect the north side of 

the Range) alone or primarily is inadequate. 

It is unclear whether this SIP fully reviews and addresses all options for control of anthropogenic 

pollutants that impair visibility in Denali’s Class I Airshed. For example, while the SIP 

references coal combustion as a source of Organic Matter Carbon (OMC) and Elemental Carbon 

(EC), it attributes all OMC and EC in the Denali region to wildfires. Considering that OMC and 

EC are present year-round, it’s unclear why the state has avoided mention of OMC and EC’s 

relationship to the Healy Coal Plant (including ash byproduct) and combustion related to power 

generation and home heating in and near the Denali Borough. Instead the SIP suggests that the 

OMC and EC found in Denali during winter months originate overseas. This SIP should 

acknowledge the presence of OMC and EC from anthropogenic sources in and near the Denali 

Borough (and within the state), and should consider methods to control OMC and EC pollutants 

related to anthropogenic sources.

In general the SIP does little to address additional emissions that are reasonably foreseeable. A 

number of industrial developments are currently moving forward in the Denali region, and are 

not even mentioned in this SIP. Some foreseeable projects include the Eva Creek Wind Project 

(construction currently underway), the Alaska Stand Alone Pipeline (Environmental Impact 

Statement currently under consideration, work projected to begin in 2016 and continue through 

2019), the Nenana Basin gas exploration (currently licensed for exploration with anticipated 

developments in the near future), and the Healy Basin gas exploration (permitted in 2011, but 

currently under appeal in the Alaska Supreme Court). In particular, gas development activities in 
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other areas of the country have created significant air pollution problems for both local 

communities and national parks. The construction activities should also be considered by this 

SIP, especially regarding cumulative impacts and appropriate mitigations and controls associated 

with long-term strategies and reasonable progress goals. At a minimum, the SIP should address 

how it will deal with future emissions and construction activities occurring prior to the SIP’s 

next review phase that would affect Denali’s Class I Airshed. It is not prudent to delay this 

planning to the future.

Thanks again for the opportunity to comment on Alaska’s Regional Haze State Implementation 

Plan.

Sincerely, 

/s/ Hannah Ragland, on behalf of the Denali Citizens Council Board of Directors