With elections behind us, Page and Navajo Nation residents can now look forward to the announcement of the Environmental Protection Agency's (EPA) proposed BART rule for the Navajo Generating Station (NGS) and the series of events that will follow.
BART stands for Best Available Retrofit Technology. EPA must decide what technologies it will require, if any, as BART for NGS as part of its Regional Haze Rule. The goal of that rule is to reduce regional emissions from man-made sources in order to achieve natural background visibility conditions in certain national parks and wilderness areas by the year 2064.
Exactly when the EPA will announce its proposed decision for NGS remains uncertain. There is no set deadline but we know that EPA is working on a rule and we hope to hear in the next 60 days.
The BART process requires EPA to decide whether NGS's existing pollution controls are sufficient to comply with the Regional Haze Rule. NGS has a long and strong history of emissions control, and its owners have invested millions of dollars through the years.
Since it went online in 1974, NGS has removed 99.5 percent of its particulate matter with its electrostatic precipitators. Since 1999, it has removed 95 percent of sulfur dioxide with its wet limestone scrubbers. And since April 2011, it has reduced nitrogen oxide emissions by 40 percent with low-NOx burners and separated overfire air technology.
Existing pollution controls are among the five factors EPA considers in its BART determination. EPA will also consider the cost of additional technology, energy and non-air quality impacts such as employment and economic consequences, visibility impacts and the projected life of the power plant.
The most important letter in BART is R - for retrofit. The additional emission control retrofits that EPA is considering are very expensive. Should the EPA determine NGS needs the most expensive additional controls - called Selective Catalytic Reduction and baghouses that filter particulates - engineering professionals have estimated the cost will be $1.1 billion.
More importantly, if this option is selected, the NGS owners will need enough time to resolve a number of uncertainties facing the plant before they can make such a significant investment. The owners are currently renegotiating the site lease agreement with the Navajo Nation. A new lease agreement that authorizes operation beyond 2019 will not be issued until it is approved by the Secretary of Interior, which cannot occur until an environmental study is completed.
The owners are concerned that EPA could require costly additional controls on a schedule that does not allow the owners sufficient time to get through the federal environmental review process and anticipated litigation, secure the necessary air permits, and complete the design and construction of the additional controls.
Of course, NGS has been doing all it can to educate and inform EPA staff of its unique situation. Earlier this year, EPA Deputy Administrator Gina McCarthy toured the plant with Navajo Nation President Ben Shelly and his staff. Deputy Assistant Administrator Janet McCabe, Region 9 Administrator Jared Blumenfeld and Division 9 Associate Director, Air Division Colleen McKaughan also visited NGS.
During these tours, EPA officials met some of our Operator Specialists in the control room to learn about their lives, where on the Navajo Nation they grew up, how long they've worked at NGS, the training they've received, and what their jobs mean to them.
Often people are surprised to find our workers stay for 30 or 40 years, and that they may be second- or third-generation NGS employees. That conveys the close ties between NGS and our area communities - a factor that is critical to the BART decision.
Another important factor in EPA's final decision will be the comments it receives. When the proposed BART rule is announced, a public comment period of 60 to 90 days or more will begin and local public hearings will be scheduled. This is your opportunity to be part of the process.
There are three ways to submit comments: by letter, e-mail or in person at public hearings.
Your comments will help the EPA understand the immense economic ripple effect that radiates from NGS to our neighborhoods, our school district, our medical providers, our local Navajo chapters, across the Navajo Nation and across the state. Without NGS, Page would be a much different community and the western Navajo Nation would be a much emptier place.
Many outside our region have little understanding of the importance of these jobs, and the importance of NGS as a cultural anchor that allows our Navajo employees to remain and work on their own homeland. The EPA needs to hear from the people who work at NGS and who live in our communities. It needs to know about the hundreds of Navajo workers who travel the country all year for jobs but look forward to coming home for annual overhauls to at least be with their families for four to eight weeks.
Most of all, EPA needs to know what would happen if NGS wasn't here. As one of our workers told me, "I don't want my kids to move away from their grandmother." Just like that, this is a call for people to tell their own stories.
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