7-16-12 - Jeff Clay, HEAL Utah Comment

July 16, 2012 By email: r8airrulemakings@epa.gov Carl Daly, Director Air Program Environmental Protection Agency, Region 8 Mail code 8P-AR 1595 Wynkoop St. Denver, Colorado 80202-1129 Comments on EPA Proposed Rule on State Implementation Plans; Utah; Regional Haze Rule Requirements for Mandatory Class I Areas. Docket ID No. EPA–R08– OAR–2011–0114, Dear Mr. Daly: As a member of the HEAL Utah Board of Directors, I appreciate the opportunity to comment on the agency’s evaluation of Utah’s proposal for complying with federal Regional Haze requirements. HEAL as an organization has already signed on to much more detailed and thorough comments from a group of regional Conservation Organizations, which you will also receive, but I wanted to add a few additional comments as a board member to clarify several key issues from a broader policy perspective. These are important to our grassroots membership of more than 5,000 interested in protecting Utah from toxics and nuclear risks and promoting a transition to clean renewable energy. First, let us plainly state: We believe the EPA rightly disapproved portions of Utah’s deficient state plan, specifically the Utah RH SIP “Best Available Retrofit Technology” (“BART”) determinations for nitrogen oxides (“NOx”) and particulate matter (“PM”.) We applaud the agency for finding the DAQ had failed to adequately demonstrate that it had chosen sufficient pollution controls. We thank the EPA for rejecting Utah’s inadequate plan to address coal power plant air pollution – and now, as the Regional Haze plans reach their final, critical steps, the EPA must keep the pressure on, as we argue below. Specifically, we join our fellow Conservation Organizations in calling for the EPA to “either require revisions to the Utah RH SIP to ensure greater reasonable progress toward natural visibility conditions at Class I areas impacted by Utah air pollution sources or require the installation of the BART for SO2 under Section 308.” Here’s why: