The Navajo Nation submitted comments on the ANPRM for BART FIP for FCPP and NGS. The Nation is concerned with achieving emissions reductions while minimizing negative economic impacts such as job losses and revenue reduction. The Nation takes the position that a phased approach to emissions controls beginning with combustion controls is preferable to more stringent controls. The Nation looks forward to commenting on forthcoming proposed rules for both facilities and maintaining consultation, with the goal of protecting Navajo economic interests and concerns while making reasonable progress on emissions reductions.

1. Navajo Nation Comments To ANPRM for BART FIP for FCPP and NGS

2. Topics Navajo Nation interests in ANPRM Emissions reductions Economics Reasons for comments to ANPRM Navajo Nation position Future comments to USEPA proposed rules

3. Navajo Nation Resources -Natural resourcesinclude oil, gas, timber, coal, uranium, hunting, fishing, agriculture -Land base approximate size of West Virginia; Population > 250,000

4. Navajo Nation Emission Inventory Area sources 48% CO emissions from prescribed burns 35% NOx emissions from oil and gas compressor engines 54% SO2 from prescribed burns 77 VOC emissions from residential/wood combustion 39% PM2.5 from unpaved road dust 77% PM10 from unpaved road dust Point sources NOx most significant contributor with 80,918.4 tpy

5. Navajo Nation Interests in ANPRM Continued reasonable progress for emissions reductions Negative economic impacts – job losses, revenue reduction Future regulations impacting power plants (other than nitrogen oxides and PM)

6. Reasons for Comments to ANPRM Achieve emissions reductions with least economic impacts Protect NN’s economic interests/concerns Interpretation of data presented in ANPRM

7. Navajo Nation Position Phased approach to emissions controls Begin with combustion controls – LNB and SOFA Review recorded, not simply modeled, results

8. Future Comments to Proposed Rules for NGS and FCPP NN position/comments remain the same Plants are different Proposed rules may be different NN position/comments may change NN awaits forthcoming proposals for both facilities Consultation NN will comment

9. Contacts Stephen B. Etsitty, Executive Director Navajo Nation Environmental Protection Agency stephenbetsitty@navajo.org Telephone: 928/871-7692 Eugenia Quintana, Environmental Department Manager Air & Toxics Department/NNEPA eugeniaquintana@navajo.org Telephone: 928/871-7800 Charlene Nelson, Environmental Program Supervisor Navajo Air Quality Control Program/NNEPA charlenenelson@navajo.org Telephone: 928/729-4247