CAP's Comments to EPA's Spplemental Proposal - 1/14
CAP, along with the Gila River Indian Community, the Navajo Nation, Salt River Project, the Environmental Defense Fund, the U.S. Department of the Interior and Western Resource Advocates, developed an alternative "Better than BART" plan for NGS. The plan includes two alternatives that both achieve even greater NOx emission reductions than the EPA's proposed rule.
- Alternative A
- Cease coal generation on one unit or substantially reduce generation by January 1, 2020, depending on ownership changes.
- Install SCR or an equivalent technology on the other two units at NGS by December 31, 2030.
- Alternative B
- If the conditions for Alternative A are not met, reduce NOx emissions equivalent to the shutdown of one Unit from 2020 to 2030.
- Submit annual Implementation Plans describing the operating scenarios to be used to achieve greater NOx emission reductions than EPA’s Proposed BART Rule.
- Under either Alternative A or B, the NGS Participants agree to maintain emissions below the total 2009-2044 NOx emissions cap delineated under EPA’s BART proposal.
Benefits of TWG BART Proposal to CAP and its customers/stakeholders
- The long term viability of NGS provides certainty that stable and reliable power supplies are available to CAP for decades.
- The costs associated with the EPA rule is significantly delayed, potentially until 2030, ensuring CAP can continue to deliver affordable, renewable supplies while preparing for future cost increases in a deliberate fashion.
- It preserves CAP’s ability to fund Arizona’s repayment obligation to the federal government for construction of the CAP system through the sale of surplus NGS power.
- Power cost increases that threatened to disrupt the Native American water rights settlements are mitigated.
Additional Elements of TWG BART Proposal
- The current owners of NGS will cease their operation of conventional coal-fired generation at NGS no later than December 22, 2044 (the Navajo Nation can continue after 2044 at its election).
- SRP will assist the Navajo Nation to advocate to EPA for “Treatment as a State” status under the Clean Air Act.
- A $5 million Local Benefit Fund for community improvement projects within 100 miles of NGS or the Kayenta Mine (which supplies coal to NGS).