DATE
U.S. Environmental Protection Agency
EPA Docket Center (EPA/DC)
Mail Code 28221T
Attn: Docket ID No. EPA-HQ-OAR-2013-0602
1200 Pennsylvania Avenue, NW
Washington, DC 20460
RE: EPA-HQ-OAR-2013-0602
As part of its Clean Power Plan, on October 28, 2014, the U.S. Environmental Protection Agency
(EPA) released a Supplemental Proposal to address greenhouse gas emissions at existing power
plants on Indian lands. This letter is written in support of the Supplemental Proposal on behalf of
the [INSERT YOUR ORGANIZATION HERE. In a following sentence, you may wish to also
include demographic information and other specifics about your organization. For example:
Founded in _____, the City of _________ is one of Arizona's largest cities and serves a
population of more than 200,000 people.]
Our interest in EPA's recent action stems from its applicability to the Navajo Generating Station
(NGS) located in northern Arizona. NGS is critical to the operation of the Central Arizona
Project (CAP), providing more than 90-percent of the power CAP needs to deliver Colorado
River water to central and southern Arizona populations. In turn, the [your organization] relies
on CAP to reliably and affordably deliver this water. [Here you may wish to include information
about how much CAP water you take, percentage of water portfolio, and other reliances.]
[Your organization] supports the Supplemental Proposal because it specifies critical goals to
improve air quality, rather than mandating specific requirements on tribal governments.
Importantly, it recognizes that these goals are attainable through compliance with NGS' Best
Available Retrofit Technology (BART) rule finalized by the EPA in September. In
acknowledging this, the EPA states that it does not expect additional emission reductions from
areas of Indian Country with affected power plants, including the Navajo Nation's lands, because
of expected compliance with the BART rule.
We strongly encourage the EPA to continue to maintain this determination in the final rule
because the possible imposition of additional requirements to control carbon emissions and
resulting costs will otherwise have a devastating impact on water use in the state. The cost of
CAP water already is on the rise in part due to compliance with BART. [Include here how your
organization is affected by rising CAP water costs: impact on your budget, customers, rates,
etc.]
The BART rule drew an extraordinary balance between NGS constituents and the EPA to find a
mutually acceptable solution for the continued operation of NGS. Likewise, the Supplemental
Proposal strikes a similar balance and is further evidence of the EPA's commitment to achieve air
quality standards while ensuring the continued economic vitality of CAP and, consequently, its
water customers and stakeholders like the [your organization].
We appreciate the opportunity to provide comment, and urge the EPA to adopt the Supplemental
Proposal as part of the Clean Power Plan final rulemaking.
Sincerely,