Regional Haze Permit Comments.pdf

The Powder River Basin Resource Council, National Parks Conservation Association, and Sierra Club submitted comments on proposed revisions to Wyoming's regional haze SIP and Jim Bridger Power Plant air permits, urging Wyoming not to finalize the proposed amendments and instead require PacifiCorp to comply with current emission limits. The proposed amendments would replace unit-specific NOx emissions rates with monthly mass-based limits for SO2 and NOx emissions on a plant-wide basis. The organizations argue that the proposed reassessment has serious flaws, undermining the claimed visibility benefits, and that DEQ's conclusions based on CALPUFF modeling are flawed and invalid. They also argue that PacifiCorp's permit application should be denied as it is an illegal about-face of long-standing agency determinations requiring SCRs at units 1 and 2 of the Jim Bridger Power Plant. DEQ's review of the current proposal was inadequate, with a rushed permit application process and insufficient comment period, and the agency failed to provide a justification for its change in position.