PacifiCorp ready to take comments to hearing

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Utah’s Regional Haze State Implementation Plan Revision
PacifiCorp currently operates five coal-fired generating units in Utah, four of which are best available retrofit technology (“BART”) eligible under the Regional Haze Rules. These units include:
Hunter Unit 1 (BART-eligible; 2042 approved depreciable life; 1978 in-service)
Hunter Unit 2 (BART-eligible; 2042 approved depreciable life; 1980 in-service)
Hunter Unit 3 (not BART-eligible; 2042 approved depreciable life; 1983 in-service)
Huntington Unit 1 (BART-eligible; 2036 approved depreciable life; 1977 in-service)
Huntington Unit 2 (BART-eligible; 2036 approved depreciable life: 1974 in-service)
PacifiCorp retired two coal-fired generating units in Utah in 2015. These units are: Carbon Unit 1 (retired in April 2015 because of MATS and state’s Regional Haze SIP) Carbon Unit 2 (retired in April 2015 because of MATS and state’s Regional Haze SIP)
The Utah Department of Environmental Quality’s (“UDEQ”) Regional Haze state implementation plan (“SIP”) provides greater reasonable progress towards visibility goals at a significantly lower cost than does the EPA co-proposal that would require the installation of selective catalytic reduction (“SCR”).
From 2007 ” 2015, the requirements imposed by Utah’s Regional Haze SIP and Utah’s Regional Haze SIP Revision have been fully implemented and should be approved by EPA as submitted (EPA’s first proposed Option in its December 16, 2015 proposed action).
The Alternative Measure included in the Utah Regional Haze SIP Revision not only produces greater reasonable progress under the Regional Haze Rule, including lower total emissions and improved visibility, but it does so at a capital cost savings to PacifiCorp’s customers of over $700 million as compared to the installation of SCR (the most stringent NOX control technology) and NOX emissions limits being proposed by EPA (EPA’s second proposed Option in its December 16, 2015 proposed action).
EPA’s co-proposal does not represent a choice between two distinct options. PacifiCorp has already implemented the requirements of Utah’s Regional Haze SIP (EPA’s first proposed Option) and has already achieved significant and sufficient NOx reductions. If EPA requires its second Option to be implemented, it is in essence requiring PacifiCorp to implement BOTH Options in order to satisfy the Regional Haze BART requirements in Utah, which have already been satisfied under Utah’s Regional Haze SIP.
Avoiding the unnecessary major incremental compliance expenditures under EPA’s second proposed Option for NOX emissions, which will not produce meaningful visibility improvements above those already achieved, is in the best interests of Utah and its stakeholders.