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From: Carl Edlund

To: Barbara Nann


Cc: Al Armendariz; Brad Toups; Chrissy Mann; J effrey Robinson; Lynda Carroll; Suzanne Murray; Suzanne Smith;
Thomas Diggs; William Luthans; Wk; mansuri layla
Subject: Re: San J uan Generating Title V Petition Decision Briefing
Date: 01/22/2012 10:19 PM
Great info!

Sent by EPA Wireless E-Mail Services
From: Barbara Nann
Sent: 01/22/2012 06:54 PM CST
To: Carl Edlund
Cc: Al Armendariz; Brad Toups; Chrissy Mann; J effrey Robinson; Lynda Carroll; Suzanne Murray;
Suzanne Smith; Thomas Diggs; William Luthans; edlund.carl@epa.gov; mansuri.layla@epa.gov
Subject: Re: San J uan Generating Title V Petition Decision Briefing
From the Statement of Basis of the Title V Permit for San Juan and a letter from PNM to
NMED commenting on the draft Title V permit (dated 12/23/96), the construction dates of
the four boilers were identified. Unit 1 began construction on June 1974. Unit 2 began
construction on December 1970. Unit 4 began construction on April 1976. Unit 4 began
construction on August 1977.
Barbara A. Nann
Assistant Regional Counsel
EPA Region 6 (6RC-S)
1445 Ross Avenue
Dallas, TX 75202
phone: (214) 665-2157
fax: (214) 665-6460
nann.barbara@epa.gov
-----Carl Edlund/R6/USEPA/US wrote: -----
To: Jeffrey Robinson/R6/USEPA/US@EPA
From: Carl Edlund/R6/USEPA/US
Date: 01/22/2012 06:06PM
Cc: Al Armendariz/R6/USEPA/US@EPA, Barbara Nann/R6/USEPA/US@EPA, Brad
Toups/R6/USEPA/US@EPA, Chrissy Mann/R6/USEPA/US@EPA, "Wk"
<edlund.carl@epa.gov>, Lynda Carroll/R6/USEPA/US@EPA, "Layla Mansuri"
<mansuri.layla@epa.gov>, Suzanne Murray/R6/USEPA/US@EPA, Suzanne
Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, William
Luthans/R6/USEPA/US@EPA
Subject: Re: San Juan Generating Title V Petition Decision Briefing
(b) (5)
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege, FOIA Exemption (b)(5) - Attorney Work Product Privilege
Sent by EPA Wireless E-Mail Services
Jeffrey Robinson
----- Original Message -----
From: Jeffrey Robinson
Sent: 01/22/2012 04:48 PM CST
To: Carl Edlund
Cc: Al Armendariz; Barbara Nann; Brad Toups; Chrissy Mann; "Carl Edlund"
<edlund.carl@epa.gov>; Lynda Carroll; "Layla Mansuri" <mansuri.layla@epa.gov>; Suzanne Murray;
Suzanne Smith; Thomas Diggs; William Luthans
Subject: Re: San Juan Generating Title V Petition Decision Briefing
We also worked
with NMED to get copies of their historical records for the facility. I do not recall us
having any records in our archives that alludes to any permitting decisions when EPA
potentially would have been the permitting authority or prior to PSD.
NMED has
typically included the chronological permitting history in their Statement of Basis for
Title V permits which included the units in question here.....the permitting history for
these units even included an approximate issuance date of permits or date of filing for
certificates of registration for the units. We'll request a copy of any records from
archives again to see what we have.

Carl Edlund---01/22/2012 03:40:10 PM---
From: Carl Edlund/R6/USEPA/US
To: Jeffrey Robinson/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, Barbara Nann/R6/USEPA/US@EPA, Brad
Toups/R6/USEPA/US@EPA, Chrissy Mann/R6/USEPA/US@EPA, "Carl Edlund"
<edlund.carl@epa.gov>, Lynda Carroll/R6/USEPA/US@EPA, "Layla Mansuri"
<mansuri.layla@epa.gov>, Suzanne Murray/R6/USEPA/US@EPA, Suzanne
Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, William
Luthans/R6/USEPA/US@EPA
Date: 01/22/2012 03:40 PM
Subject: Re: San Juan Generating Title V Petition Decision Briefing
(b) (5)
(b) (5)
(b) (5)
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege


Jeffrey Robinson---01/20/2012 10:20:32 AM---Attached are background materials for
this afternoon's discussion. We'll attempt to be brief in o
From: Jeffrey Robinson/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, "Carl Edlund" <edlund.carl@epa.gov>, Thomas
Diggs/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Suzanne
Murray/R6/USEPA/US@EPA, Barbara Nann/R6/USEPA/US@EPA, Brad
Toups/R6/USEPA/US@EPA
Cc: "Layla Mansuri" <mansuri.layla@epa.gov>, Chrissy Mann/R6/USEPA/US@EPA,
William Luthans/R6/USEPA/US@EPA, Lynda Carroll/R6/USEPA/US@EPA
Date: 01/20/2012 10:20 AM
Subject: San Juan Generating Title V Petition Decision Briefing
Attached are background materials for this afternoon's discussion. We'll attempt to be
brief in our discussion today.....


[attachment "San Juan Generating Station Petition Response Jan 20 2012
we_care_briefing edited.docx" deleted by Carl Edlund/R6/USEPA/US] [attachment "San
Juan Generating petition Jan 20 12 Armendariz Briefing.pptx" deleted by Carl
Edlund/R6/USEPA/US]
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Carl Edlund
To: J effrey Robinson; Al Armendariz; Layla Mansuri; Wk
Cc: Thomas Diggs; Ms. Barbara Nann
Subject: Re: San J uan Generating Title V Petition Decision Briefing
Date: 01/22/2012 10:16 PM
Thanks..
Sent by EPA Wireless E-Mail Services
From: J effrey Robinson
Sent: 01/22/2012 02:59 PM CST
To: Al Armendariz; "Layla Mansuri" <mansuri.layla@epa.gov>; "Carl Edlund" <edlund.carl@epa.gov>
Cc: Thomas Diggs
Subject: Fw: San J uan Generating Title V Petition Decision Briefing
I wanted to give you a chance to read the Agency's current draft response for Claim 1A.


Section 505(b)(2) of the Act, 42 U.S.C. 7661d(b)(2), and 40 C.F.R. 70.8(d)
state that objections to a title V permit will only be based on comments raised with
reasonable specificity during the public comment period unless Petitioners
demonstrate that (1) it was impracticable to raise such objections during the public
comment period; or (2) the grounds for such objection arose after the public comment
period.

(b) (5)
FOIA Exemption (b)(5) - Deliberat
FOIA Exemption (b)(5) - Deliberative Process Privilege



Jeff
----- Forwarded by J effrey Robinson/R6/USEPA/US on 01/22/2012 02:37 PM -----
From: J effrey Robinson/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, "Carl Edlund" <edlund.carl@epa.gov>, Thomas Diggs/R6/USEPA/US@EPA, Suzanne
Smith/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Barbara Nann/R6/USEPA/US@EPA, Brad
Toups/R6/USEPA/US@EPA
Cc: "Layla Mansuri" <mansuri.layla@epa.gov>, Chrissy Mann/R6/USEPA/US@EPA, William Luthans/R6/USEPA/US@EPA, Lynda
Carroll/R6/USEPA/US@EPA
Date: 01/20/2012 10:20 AM
Subject: San J uan Generating Title V Petition Decision Briefing
Attached are background materials for this afternoon's discussion.

[attachment "San J uan Generating Station Petition Response J an 20 2012 we_care_briefing
edited.docx" deleted by J effrey Robinson/R6/USEPA/US] [attachment "San J uan Generating petition
J an 20 12 Armendariz Briefing.pptx" deleted by J effrey Robinson/R6/USEPA/US]
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: J effrey Robinson
To: Al Armendariz; Carl Edlund; Thomas Diggs; Suzanne Smith; Suzanne Murray; Barbara Nann; Brad Toups
Cc: Layla Mansuri; Chrissy Mann; William Luthans; Lynda Carroll
Subject: San J uan Generating Title V Petition Decision Briefing
Date: 01/20/2012 10:20 AM
Attachments: San J uan Generating Station Petition Response J an 20 2012 we care briefing edited.docx
San J uan Generating petition J an 20 12 Armendariz Briefing.pptx
Attached are background materials for this afternoon's discussion.

(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Al Armendariz
To: Carl Edlund; Murray, Suzanne; Suzanne Smith; Self; J ohn Blevins
Cc: Layla Mansuri; Chrissy Mann; Thomas Diggs; J oe Kordzi; Guy Donaldson
Subject: Re: Update on Regional Haze developments and upcoming actions as of 1/6/2012
Date: 01/08/2012 12:13 PM
Thanks Carl.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
Carl Edlund
----- Original Message -----
From: Carl Edlund
Sent: 01/08/2012 01:00 PM EST
To: "Suzanne Murray" <murray.suzanne@epa.gov>; Suzanne Smith; "Al
Armendariz" <armendariz.al@epa.gov>; John Blevins
Cc: Layla Mansuri; Chrissy Mann; Thomas Diggs; Joe Kordzi; Guy Donaldson
Subject: FW: Update on Regional Haze developments and upcoming actions
Do you have some insight J oe/Guy?
Sent with Good (www.good.com)
----- Forwarded by Carl Edlund/R6/USEPA/US on 01/08/2012 01:00:00 PM-----
-------- Original Message --------
From : Phil Lorang/RTP/USEPA/US
To : J anet McCabe/DC/USEPA/US@EPA, Anna Wood/RTP/USEPA/US@EPA,
"Rhea J ones" <J ones.Rhea@epamail.epa.gov>, "Kirsten King"
<King.Kirsten@epamail.epa.gov>, "Steve Page" <page.steve@epa.gov>, Scott
Mathias/RTP/USEPA/US@EPA, Rhea J ones/RTP/USEPA/US@EPA, Martha
Keating/RTP/USEPA/US@EPA, Lea Anderson/DC/USEPA/US@EPA, Todd
Hawes/RTP/USEPA/US@EPA, Peter South/RTP/USEPA/US@EPA, Megan
Brachtl/RTP/USEPA/US@EPA, Sara Terry/RTP/USEPA/US@EPA, Mary
Henigin/DC/USEPA/US@EPA, Alan Rush/DC/USEPA/US@EPA, Paula
VanLare/DC/USEPA/US@EPA, Kristina Friedman/DC/USEPA/US@EPA, Air Division
Directors and Deputies, Lucy Edmondson/R1/USEPA/US@EPA, Michael
Ling/RTP/USEPA/US@EPA
Cc :
Sent on : 01/06/2012 07:23:32 PM
Subject : Update on Regional Haze developments and upcoming actions as of
FOIA Exemption (b)(5) - Deliberative Process Privilege
1/6/2012
Hi, all
A lot is happening very quickly regarding Regional Haze, so this may
not cover everything of interest and may be out of date quickly. Please
call or send questions or corrections, and more recent information if
you have it.
Recent developments
CSAPR Stay - The Court of Appeals has stayed CSAPR and
extended CAIR indefinitely while litigation in in process.

CSAPR Better-than-BART Rule - The proposed rule was
published in the Federal Register on December 30, 2011. The
public hearing will be held on J anuary 17, 2012 at the EPA
campus in Research Triangle Park, NC.
FLM Discussions on RAVI - As part of the interagency
discussion of the CSAPR Better-than-BART rule,

North Dakota - A federal district court in North Dakota has
(b) (5)
(b) (5)
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process P
ruled in favor of the state in a disagreement regarding the
BACT determination under an enforcement case against the
Milton R. Young electric generating station, putting a cloud
over EPA's proposal to require SCR as BART at several EGUs.

NPCA et al. Consent Decree - The comment period was
originally announced as closing on J anuary 3, 2012. However,
due to an error in the Federal Register notice in listing the
states that are affected by the CD, as a procedural precaution
the comment period has been extended to February 3.
Because some time is needed anyway to assess comments
that came in before J anuary 3, the extension is not expected
to delay the finalization of the CD by much.
NPCA et al. priorities for commenting on proposed SIP/FIP
actions - NPCA representatives met with J anet McCabe on
J anuary 5, and provided a list of their priorities.
South Carolina - Congratulations to Region 4 on signing a
proposed action well before the February 15, 2012, CD
deadline but has not yet been published. This notice
addresses (by proposing to approve?) elements other than
EGU BART. A limited disapproval for EGU BART was included
in the proposed Better-than-BART action. South Carolina did
not receive a finding of failure to submit a Regional Haze SIP,
and so partial disapproval will not create an immediate FIP
obligation.
New York - New York has not submitted certain SIP elements
that must be in hand for EPA to propose action on the SIP,
even considering the possibility of parallel processing.
(b) (5)
(b)
(5)
(b)
(5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
Montana - The last update said that the deadline for the
proposed action is J anuary 20, 2012. It actually is now March
20, 2012. (This may not be official yet.)
Pennsylvania - A proposed action on this SIP must be signed
by J anuary 17.
Approaching Action Dates
J anuary 17, 2012 - proposed actions for Illinois, Indiana,
Minnesota, New York (may be extended), Ohio, Pennsylvania,
and Virginia. These will be proposed approvals for requirements
other than EGU BART. Note, however, the above issue for
Pennsylvania.
February 9, 2012 - final FIP action in North Dakota. (This date is
in flux, as there is a negotiated extension to March 2 which has
not been formalized by DOJ .)
February 14, 2102 - final action on Arkansas' RH SIP. The very
recent proposal was a partial approval and a partial disapproval
because of (1) inadequate analysis of reasonable progress and
(2) inadequate analysis of BART for 9 sources. If the final
action includes a partial disapproval, we would have two years
to fully approve a new SIP submission or promulgate a FIP.
February 15, 2012 - proposed actions for Alabama, Alaska (all
BART elements), Albuquerque/Bernalillio County, Georgia, Iowa,
Louisiana, Maryland, Mississippi, Missouri, Nebraska, New
Hampshire, New Mexico
(b) (5)
(b) (5)
(b) (5)
(b) (5)
(b) (5)
, North Carolina, Rhode Island,
Vermont, Wisconsin.
For Nebraska, there will be a proposed FIP to use the
CSAPR Better-than-BART rule to fill what would otherwise be a
BART gap at one EGU.
Schedule of Required Actions for Reference
Attached is a fully updated edition of our master list of dates from all
the settlements combined, sorted in order of final action date. As
noted above, the action date for North Dakota is in flux.
[attachment "Regional Haze CD Action Dates_J anuary 4_2012.docx" deleted by Al
Armendariz/R6/USEPA/US]
Phil Lorang, Senior Policy Advisor
Air Quality Policy Division, OAQPS, EPA
919-541-5463
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Carl Edlund
To: Suzanne Murray; Suzanne Smith; Al Armendariz; J ohn Blevins
Cc: Layla Mansuri; Chrissy Mann; Thomas Diggs; J oe Kordzi; Guy Donaldson
Subject: FW: Update on Regional Haze developments and upcoming actions as of 1/6/2012
Date: 01/08/2012 12:00 PM
Attachments: Regional Haze CD Action Dates J anuary 4 2012.docx
Do you have some insight J oe/Guy?
Sent with Good (www.good.com)
----- Forwarded by Carl Edlund/R6/USEPA/US on 01/08/2012 01:00:00 PM-----
-------- Original Message --------
From : Phil Lorang/RTP/USEPA/US
To : J anet McCabe/DC/USEPA/US@EPA, Anna Wood/RTP/USEPA/US@EPA,
"Rhea J ones" <J ones.Rhea@epamail.epa.gov>, "Kirsten King"
<King.Kirsten@epamail.epa.gov>, "Steve Page" <page.steve@epa.gov>, Scott
Mathias/RTP/USEPA/US@EPA, Rhea J ones/RTP/USEPA/US@EPA, Martha
Keating/RTP/USEPA/US@EPA, Lea Anderson/DC/USEPA/US@EPA, Todd
Hawes/RTP/USEPA/US@EPA, Peter South/RTP/USEPA/US@EPA, Megan
Brachtl/RTP/USEPA/US@EPA, Sara Terry/RTP/USEPA/US@EPA, Mary
Henigin/DC/USEPA/US@EPA, Alan Rush/DC/USEPA/US@EPA, Paula
VanLare/DC/USEPA/US@EPA, Kristina Friedman/DC/USEPA/US@EPA, Air Division
Directors and Deputies, Lucy Edmondson/R1/USEPA/US@EPA, Michael
Ling/RTP/USEPA/US@EPA
Cc :
Sent on : 01/06/2012 07:23:32 PM
Subject : Update on Regional Haze developments and upcoming actions as of
1/6/2012
Hi, all
A lot is happening very quickly regarding Regional Haze, so this may not cover
everything of interest and may be out of date quickly. Please call or send questions
or corrections, and more recent information if you have it.
Recent developments
CSAPR Stay - The Court of Appeals has stayed CSAPR and extended CAIR
indefinitely while litigation in in process.

(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
CSAPR Better-than-BART Rule - The proposed rule was published in the
Federal Register on December 30, 2011. The public hearing will be held on
J anuary 17, 2012 at the EPA campus in Research Triangle Park, NC.

FLM Discussions on RAVI - As part of the interagency discussion of the
CSAPR Better-than-BART rule,
North Dakota - A federal district court in North Dakota has ruled in favor of
the state in a disagreement regarding the BACT determination under an
enforcement case against the Milton R. Young electric generating station,
putting a cloud over EPA's proposal to require SCR as BART at several
EGUs.
NPCA et al. Consent Decree - The comment period was originally
announced as closing on J anuary 3, 2012. However, due to an error in the
Federal Register notice in listing the states that are affected by the CD, as a
procedural precaution the comment period has been extended to February
3. Because some time is needed anyway to assess comments that came in
before J anuary 3, the extension is not expected to delay the finalization of
the CD by much.
NPCA et al. priorities for commenting on proposed SIP/FIP actions - NPCA
representatives met with J anet McCabe on J anuary 5, and provided a list of
their priorities.
(b) (5)
(b) (5)
(b) (5)
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
South Carolina - Congratulations to Region 4 on signing a proposed action
well before the February 15, 2012, CD deadline but has not yet been
published. This notice addresses (by proposing to approve?) elements other
than EGU BART. A limited disapproval for EGU BART was included in the
proposed Better-than-BART action. South Carolina did not receive a finding
of failure to submit a Regional Haze SIP, and so partial disapproval will not
create an immediate FIP obligation.
New York - New York has not submitted certain SIP elements that must be
in hand for EPA to propose action on the SIP, even considering the
possibility of parallel processing.
Montana - The last update said that the deadline for the proposed action is
J anuary 20, 2012. It actually is now March 20, 2012. (This may not be
official yet.)
Pennsylvania - A proposed action on this SIP must be signed by J anuary
17.
Approaching Action Dates
J anuary 17, 2012 - proposed actions for Illinois, Indiana, Minnesota, New York
(may be extended), Ohio, Pennsylvania, and Virginia. These will be proposed
approvals for requirements other than EGU BART. Note, however, the above
issue for Pennsylvania.
February 9, 2012 - final FIP action in North Dakota. (This date is in flux, as
there is a negotiated extension to March 2 which has not been formalized by
DOJ .)
February 14, 2102 - final action on Arkansas' RH SIP. The very recent
proposal was a partial approval and a partial disapproval because of (1)
(b) (5)
(b) (5)
(b) (5)
(b) (5)
inadequate analysis of reasonable progress and (2) inadequate analysis of
BART for 9 sources. If the final action includes a partial disapproval, we
would have two years to fully approve a new SIP submission or promulgate a
FIP. .
February 15, 2012 - proposed actions for Alabama, Alaska (all BART
elements), Albuquerque/Bernalillio County, Georgia, Iowa, Louisiana,
Maryland, Mississippi, Missouri, Nebraska, New Hampshire, New Mexico
, North Carolina, Rhode Island, Vermont, Wisconsin.
For Nebraska, there will be a proposed FIP to use the
CSAPR Better-than-BART rule to fill what would otherwise be a BART gap at
one EGU.
Schedule of Required Actions for Reference
Attached is a fully updated edition of our master list of dates from all the settlements
combined, sorted in order of final action date. As noted above, the action date for
North Dakota is in flux.
Phil Lorang, Senior Policy Advisor
Air Quality Policy Division, OAQPS, EPA
919-541-5463
(b) (5)
(b)
(5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Carl Edlund
To: Al Armendariz; Ruben Casso; Thomas Diggs
Cc: David Gray
Subject: Fw: Saturday MATS Clips
Date: 12/17/2011 09:58 PM
Sent by EPA Wireless E-Mail Services
From: Nate McMichael
Sent: 12/17/2011 12:31 PM EST
To: Nate McMichael; Allison Dennis; Andrea Drinkard; Beverly Banister; Bruce Sypniewski; Carl Daly;
Carl Edlund; Carl Soderberg; Carol Kemker; Cheryl Newton; Christine Guitar; Colleen McKaughan; Dave
Bray; Dave Conroy; David Arnold; Deborah J ordan; Deborah Lebow-Aal; Deirdre Rothery; Diana Esher;
Edward Messina; Elizabeth Adams; Ellen Kurlansky; Erika Wilson; J ackie Ashley; J anet McCabe; J anis
Hastings; J eaneanne Gettle; J eff Whitlow; J effrey Clark; J ohn Filippelli; J ohn Millett; J ohn Smith; J oshua
Tapp; Kellie Ortega; Ken Mitchell; Ken Moraff; Kerry Drake; Kevin Culligan; Lorie Schmidt; Lucy
Edmondson; Marcia Spink; Marka Smith; Michael Harris; Monica Morales; Niloufar Glosson; Peter
Tsirigotis; Phillip Brooks; Rebecca Weber; Richard Haeuber; Rick Albright; Robertj Wayland; Stephen
Perkins; Steve Page; Tamara Saltman; Thomas Diggs; Toni Gargas; William Baker
Subject: Saturday MATS Clips
Hi Everyone,

Here are a few clips from stories that were posted today. The Boston Globe article is a
nice piece that discusses MATS and some of our other actions. Have a nice weekend.

EPA finalizes tough new rules on emissions by power plants Washington Post
http://www.washingtonpost.com/national/health-science/epa-finalizes-tough-new-rules-on-emissions-by-
power-plants/2011/12/16/gIQAc2WTzO story.html?tid=pm national pop
The Obama administration finished crafting tough new rules Friday curbing mercury and other poisons
emitted by coal-fired utilities, according to several people briefed on the decision, culminating more
than two decades of work to clean up the nations dirtiest power plants. As part of last-minute
negotiations between the White House and the Environmental Protection Agency, the regulations give
some flexibility to power plant operators who argued they could not meet the three-year deadline for
compliance outlined by the EPA. Several individuals familiar with the details declined to be identified
because the agency will not announce the rules until next week.

Illinois coal plants ahead of EPA mercury rule Bloomberg BusinessWeek (AP)
http://www.businessweek.com/ap/financialnews/D9RLQ6PO0.htm
Most Illinois utilities won't miss a beat when the U.S. Environmental Protection Agency requires coal-
fired power plants to control mercury emissions for the first time -- a decision environmental and health
advocates say will reduce developmental problems in children but some industry groups complain is
too restrictive. In fact, the state already is way ahead.

San Juan Plant Meets Latest Limit; EPA Rule Targets Mercury, Arsenic Power Industry News
http://www.utilityproducts.com/news/2011/12/1564917025/san-juan-plant -meets-latest-limit-epa-
rule-targets-mercury-arsenic.html
A tough new federal rule to limit mercury, arsenic and other emissions at the nation's power plants
poses no compliance challenge at the San Juan Generating Station near Farmington, the plant's major
owner says. The Environmental Protection Agency rule, to be announced Monday, isn't expected to
veer far from a March draft setting the standard at 1.2 pounds of mercury per million BTUs of energy
produced and giving industry three years to comply. Public Service Company of New Mexico, which
operates San Juan and owns nearly half of it, says the plant already meets the mercury standard due
to a $320 million upgrade finished in 2009 and is below the levels for non-mercury metals and acid
gases. The upgrade was required in a 2005 federal consent decree to settle air quality violations
between 2001-04. "We are proud that each of the plant's four units already is removing more than the
EPAproposed removal rate of 91 percent," PNM president and CEO Pat Vincent-Collawn said. "In fact,
those units are among the top five nationally for coal-fired units using activated carbon injection to
remove mercury."

Cleaning the air: New air quality rules would build on the states pollution limits Boston Globe
(Opinion)
http://www.bostonglobe.com/opinion/2011/12/17/cleaning-air/WRK914yQr4HGd93kKzbsuN/story.html
FOR YEARS, the Northeast has been called the tailpipe of the United States - a place where air
pollutants from across the country foul our skies and lungs. That negative moniker is due to no fault of
our own, but is a casualty of our location downwind of pollution sources in other regions.
Under Governor Deval Patrick, Massachusetts has led the nation in reducing pollution from power
plants, cars and trucks, industrial sources and consumer products. For example, strict mercury limits for
coal plants went into effect in 2008, and the plants have reported dramatic reductions in mercury
emissions.
-------------------------------------------------
Nate McMichael
U.S. Environmental Protection Agency
Office of Air and Radiation
Office: (202) 564-0382
Cell: (
Cell: (
From: Chrissy Mann
To: Al Armendariz
Cc: Abi Vijayan; Erik Snyder; Guy Donaldson; Suzanne Smith; Thomas Diggs
Subject: Re: Fw: Front office's edits to consultation RTC
Date: 12/16/2011 01:00 PM
Attachments: TX i-SIP Consultation RTC 12.16 streamlined.B.docx
TX i-SIP Consultation RTC 12.16 streamlined.A.docx
Ok. Here are edits.
There are two documents.

Its all in track changes. Both documents. It will need formatting and proofing, etc.
Chrissy Mann
Special Assistant to the Regional Administrator
EPA Region 6
214-665-7295
mann.chrissy@epa.gov
Al Armendariz---12/16/2011 11:37:56 AM---Tom and Team, I have made edits to
the document and no later than 12:30 you should have 2 versions s
From: Al Armendariz/R6/USEPA/US
To: Thomas Diggs/R6/USEPA/US@EPA
Cc: Abi Vijayan/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA,
Suzanne Smith/R6/USEPA/US@EPA, Chrissy Mann/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA
Date: 12/16/2011 11:37 AM
Subject: Re: Fw: Front office's edits to consultation RTC
(b) (5)
(b) (5)
Tom and Team,
I have made edits to the document and no later than 12:30 you
should have 2 versions sent to you by Chrissy who is now
proofing my work.
When you get these from Chrissy, please examine both and discuss
with HQ to see what is preferred that everyone can sign off on.
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
-----Thomas Diggs/R6/USEPA/US wrote: -----
To: Al Armendariz/R6/USEPA/US@EPA
From: Thomas Diggs/R6/USEPA/US
Date: 12/16/2011 10:48AM
Cc: Suzanne Smith/R6/USEPA/US@EPA, Abi Vijayan/R6/USEPA/US@EPA,
Erik Snyder/R6/USEPA/US@EPA
Subject: Fw: Front office's edits to consultation RTC
Here is the latest message. Brian Dosters shorter version is
his 12/16 -- 10:36am email below.
Tom
Thomas Diggs
Associate Director - Air
US EPA Region 6
214-665-3102
fax 214-665-7263
diggs.thomas@epa.gov
----- Forwarded by Thomas Diggs/R6/USEPA/US on 12/16/2011 10:45
AM -----
From: Anna Wood/RTP/USEPA/US
To: Brian Doster/DC/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA,
Tyler Fox/RTP/USEPA/US@EPA
Cc: Lucinda Watson/R6/USEPA/US@EPA, Abi Vijayan/R6/USEPA/US@EPA,
Carrie Paige/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA,
Geoffrey Wilcox/DC/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA,
Kevin McLean/DC/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA,
Michael Ling/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA, Raj
Rao/RTP/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA, Suzanne
Murray/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA, Dan
Deroeck/RTP/USEPA/US@EPA, Richard Wayland/RTP/USEPA/US@EPA
Date: 12/16/2011 10:32 AM
Subject: Re: Fw: Front office's edits to consultation RTC
Brian and others, we've taken a closer look at Brian's version
(b) (5)
below and would like for those addi
? If need be we can get on a call to discuss further, please
let us know. Thanks.
_______________________________
Anna Marie Wood
Director, Air Quality Policy Division
Office of Air Quality Planning & Standards
U.S. Environmental Protection Agency
AQPD (C504-01)
109 T.W. Alexander Drive
Research Triangle Park, NC 27711
Phone: (919) 541- 3604
Fax: (919) 541- 4028
From: Brian Doster/DC/USEPA/US
To: Lucinda Watson/R6/USEPA/US@EPA
Cc: Anna Wood/RTP/USEPA/US@EPA, Abi Vijayan/R6/USEPA/US@EPA,
Carrie Paige/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA,
Geoffrey Wilcox/DC/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA,
Kevin McLean/DC/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA,
Michael Ling/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA, Raj
Rao/RTP/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA, Suzanne
Murray/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA, Dan
Deroeck/RTP/USEPA/US@EPA
Date: 12/16/2011 10:36 AM
Subject: Re: Fw: Front office's edits to consultation RTC



Please review and let me know what you think.
(See attached file: TX i-SIP Consultation RTC 12.15 minimum +
bld alternative to address OAR concerns.docx)
Lucinda Watson---12/15/2011 07:25:04 PM---Abi will schedule the
call for all and include Al. As I indicated in my previous
message, it is th
From: Lucinda Watson/R6/USEPA/US
To: Anna Wood/RTP/USEPA/US@EPA
Cc: Abi Vijayan/R6/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA,
Carrie Paige/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA,
Geoffrey Wilcox/DC/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA,
Kevin McLean/DC/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA,
Michael Ling/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA, Raj
Rao/RTP/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA, Suzanne
Murray/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA, Al
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
Armendariz/R6/USEPA/US@EPA
Date: 12/15/2011 07:25 PM
Subject: Re: Fw: Front office's edits to consultation RTC
Abi will schedule the call for all and include Al.
As I indicated in my previous message, it is the version that
Brian edited and indicated where it addresses HQ's concerns that
was provided to Al. It is titled RTC 12.15 minimum bld
comments.
I attach it again for convenience.
(See attached file: TX i-SIP Consultation RTC 12.15 minimum +
bld comments.docx)
Anna Wood---12/15/2011 10:22:22 PM---Hi Erik, I did share this
information below with Janet McCabe and we continue to have some
concerns
From: Anna Wood/RTP/USEPA/US
To: Erik Snyder/R6/USEPA/US@EPA
Cc: Abi Vijayan/R6/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA,
Carrie Paige/R6/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA,
Guy Donaldson/R6/USEPA/US@EPA, Kevin McLean/DC/USEPA/US@EPA,
Lucinda Watson/R6/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA,
Michael Ling/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA, Raj
Rao/RTP/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA, Suzanne
Murray/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA
Date: 12/15/2011 10:22 PM
Subject: Re: Fw: Front office's edits to consultation RTC
Hi Erik, I did share this information below with Janet McCabe
and we continue to have some concerns
_______________________________
Anna Marie Wood
Director, Air Quality Policy Division
Office of Air Quality Planning & Standards
U.S. Environmental Protection Agency
AQPD (C504-01)
109 T.W. Alexander Drive
Research Triangle Park, NC 27711
Phone: (919) 541- 3604
Fax: (919) 541- 4028
-----Erik Snyder/R6/USEPA/US wrote: -----
To: Abi Vijayan/R6/USEPA/US@EPA
From: Erik Snyder/R6/USEPA/US
Date: 12/15/2011 09:49PM
Cc: Brian Doster/DC/USEPA/US@EPA, Melina
Williams/DC/USEPA/US@EPA, Lucinda Watson/R6/USEPA/US@EPA, Kevin
McLean/DC/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA,
Tyler Fox/RTP/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA, Raj
Rao/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA, Anna
Wood/RTP/USEPA/US@EPA
FOIA Exemption (b)(5) - Deliberative Process Privilege
Subject: Re: Fw: Front office's edits to consultation RTC
Hi,
As Abi indicated we greatly appreciate everyone's attention to
this as we finalize our action. We appreciate the input on
preference for this 'RTC 12.15 full' version or the 'RTC 12.15
Minimum' version.
Thanks,
Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
email: snyder.erik@epa.gov
(See attached file: TX i-SIP Consultation RTC 12.15 full -
clean.docx)
(See attached file: TX i-SIP Consultation RTC 12.15 full -
marked up.docx)
Abi Vijayan---12/15/2011 07:22:37 PM---Thank you all for the
continuing fire drill discussion and assistance on this! If
anyone has souveni
(b) (5)
From: Abi Vijayan/R6/USEPA/US
To: Brian Doster/DC/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA
Cc: Lucinda Watson/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA,
Kevin McLean/DC/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA,
Tyler Fox/RTP/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA, Raj
Rao/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA, Anna
Wood/RTP/USEPA/US@EPA
Date: 12/15/2011 07:22 PM
Subject: Re: Fw: Front office's edits to consultation RTC
Thank you all for the continuing fire drill discussion and
assistance on this! If anyone has souvenirs or borderline tacky
gifts of gratitude they'd enjoy from Dallas, Texas, just let us
know.
Thanks to all again, please do not hesitate to ping us.
[attachment "TX i-SIP Consultation RTC 12.15 minimum.docx"
deleted by Erik Snyder/R6/USEPA/US]
Abi Vijayan
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6RC-M)
Dallas, TX 75202
Tel: (214) 665-7303
Fax: (214) 665-2182
NOTICE: This communication may contain privileged or otherwise
confidential information. If you are not the intended
recipient, or believe you have received this communication in
error, please delete the copy you received, and do not print,
copy, re-transmit, disseminate or otherwise use the
information. Thank you.
Brian Doster---12/15/2011 11:36:35 AM---Having now had a chance
to review the email chain more carefully, I see that Erik has
put forward a
From: Brian Doster/DC/USEPA/US
To: Lucinda Watson/R6/USEPA/US@EPA
Cc: Erik Snyder/R6/USEPA/US@EPA, Kevin McLean/DC/USEPA/US@EPA,
Abi Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
FOIA Exemption (b)(5) - Deliberative Process Privilege
Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA,
Tyler Fox/RTP/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA, Raj
Rao/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA, Anna
Wood/RTP/USEPA/US@EPA
Date: 12/15/2011 11:36 AM
Subject: Re: Fw: Front office's edits to consultation RTC
Having now had a chance to review the email chain more
carefully, I see that Erik has put forward a proposal






Lucinda Watson---1 h
From: Lucinda Watson/R6/USEPA/US
To: Brian Doster/DC/USEPA/US@EPA
Cc: Erik Snyder/R6/USEPA/US@EPA, Kevin McLean/DC/USEPA/US@EPA,
(b) (5)
FOIA Exemption (b)(5) - Deliberativ
FOIA Exemption (b)(5) - Deliberative Process Privilege
Abi Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA,
Tyler Fox/RTP/USEPA/US@EPA
Date: 12/15/2011 12:02 PM
Subject: Re: Fw: Front office's edits to consultation RTC
Brian,
Brian Doster---12/15/2011 08:38:37 AM---I don't believe I'm
privy to Kevin's email and I didn't copy him on mine, so I'll
need too check in
From: Brian Doster/DC/USEPA/US
To: Erik Snyder/R6/USEPA/US@EPA
Cc: Kevin McLean/DC/USEPA/US@EPA, Abi Vijayan/R6/USEPA/US@EPA,
Carrie Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA,
watson.lucinda@epa.gov, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA,
Tyler Fox/RTP/USEPA/US@EPA
Date: 12/15/2011 08:38 AM
Subject: Re: Fw: Front office's edits to consultation RTC
I don't believe I'm privy to Kevin's email and I didn't copy him
on mine, so I'll need too check in with him.


Erik Snyder---12/15/2011 09:22:52 AM---Hi, Lots of email traffic
floating around throughout the night and early this morning.
After talkin
From: Erik Snyder/R6/USEPA/US
To: Kevin McLean/DC/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA
Cc: Abi Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA,
Guy Donaldson/R6/USEPA/US@EPA, watson.lucinda@epa.gov, Suzanne
Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Suzanne
Murray/R6/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA, Geoffrey
Wilcox/DC/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA
Date: 12/15/2011 09:22 AM
Subject: Fw: Front office's edits to consultation RTC
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
Hi,
Lots of email traffic floating around throughout the night and
early this morning. After talking with Guy and Tom this
morning,



.
Appreciate feedback on this concept from the group.
Thanks,
Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
email: snyder.erik@epa.gov
Pun of the Day - My new theory on inertia doesn't seem to be
gaining momentum.
----- Forwarded by Erik Snyder/R6/USEPA/US on 12/15/2011 08:06
AM -----
From: Guy Donaldson/R6/USEPA/US
To: Erik Snyder/R6/USEPA/US@EPA
Cc: Abi Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA,
Lucinda Watson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA,
Jeffrey Robinson/R6/USEPA/US@EPA
Date: 12/14/2011 10:49 PM
Subject: Re: Front office's edits to consultation RTC

[attachment "TX i-SIP Consultation RTC 12.12 clean. CMguy.
docx.docx" deleted by Brian Doster/DC/USEPA/US]
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Erik Snyder/R6/USEPA/US
To: Abi Vijayan/R6/USEPA/US@EPA
Cc: Carrie Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA,
Lucinda Watson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA,
Jeffrey Robinson/R6/USEPA/US@EPA
Date: 12/14/2011 10:34 PM
Subject: Re: Front office's edits to consultation RTC
Hi,
Here is some thoughts on how we might try to frame things...








Will need to flush out details further and work on a rewrite,
but it is the best option that I see currently
I will loo the
-Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
FOIA Exemption (b)(5) - Deliberative Process Privilege
email: snyder.erik@epa.gov
Pun of the Day - My new theory on inertia doesn't seem to be
gaining momentum.
Abi Vijayan---12/14/2011 09:57:54 PM---From: Abi
Vijayan/R6/USEPA/US To: Erik Snyder/R6/USEPA/US@EPA
From: Abi Vijayan/R6/USEPA/US
To: Erik Snyder/R6/USEPA/US@EPA
Cc: Lucinda Watson/R6/USEPA/US@EPA, Suzanne
Smith/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA
Date: 12/14/2011 09:57 PM
Subject: Re: Front office's edits to consultation RTC
Abi Vijayan
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6RC-M)
Dallas, TX 75202
Tel: (214) 665-7303
Fax: (214) 665-2182
NOTICE: This communication may contain privileged or otherwise
confidential information. If you are not the intended recipient,
or believe you have received this communication in error, please
delete the copy you received, and do not print, copy, re-
transmit, disseminate or otherwise use the information. Thank
you.
-----Erik Snyder/R6/USEPA/US wrote: -----
To: Abi Vijayan/R6/USEPA/US@EPA
From: Erik Snyder/R6/USEPA/US
Date: 12/14/2011 09:42PM
Subject: Re: Front office's edits to consultation RTC
The documents did not come through. Looks like they were
removed when you forwarded. Can you send them? Thanks.
I have not been in all the discussions with OGC and OAQPS, but
wonder if we can work a solution.
FOIA Exemption (b)(5) - Deliberative Process Privilege
Thanks,
Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
email: snyder.erik@epa.gov
Pun of the Day - My new theory on inertia doesn't seem to be
gaining momentum.
From: Abi Vijayan/R6/USEPA/US
To: Suzanne Smith/R6/USEPA/US@EPA, Suzanne
Murray/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Carrie
Paige/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Erik
Snyder/R6/USEPA/US@EPA, Jeffrey Robinson/R6/USEPA/US@EPA
Date: 12/14/2011 08:49 PM
Subject: Front office's edits to consultation RTC




Abi Vijayan
Office of Regional Counsel
(b) (5)
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6RC-M)
Dallas, TX 75202
Tel: (214) 665-7303
Fax: (214) 665-2182
NOTICE: This communication may contain privileged or otherwise
confidential information. If you are not the intended recipient,
or believe you have received this communication in error, please
delete the copy you received, and do not print, copy, re-
transmit, disseminate or otherwise use the information. Thank
you.
-----Chrissy Mann/R6/USEPA/US wrote: -----
To: Suzanne Smith/R6/USEPA/US@EPA
From: Chrissy Mann/R6/USEPA/US
Date: 12/14/2011 07:59PM
Cc: Al Armendariz/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA,
Carrie Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA,
Layla Mansuri/R6/USEPA/US@EPA, Murray.Suzanne@epamail.epa.gov,
Thomas Diggs/R6/USEPA/US@EPA, Vijayan.Abi@epamail.epa.gov
Subject: Re: TX I-SIP



Let me know what you think.
Chrissy Mann
Special Assistant to the Regional Administrator
EPA Region 6
214-665-7295
mann.chrissy@epa.gov
From: Suzanne Smith/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Chrissy
Mann/R6/USEPA/US@EPA, Layla Mansuri/R6/USEPA/US@EPA
Cc: Murray.Suzanne@epamail.epa.gov, Carl
Edlund/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA,
Vijayan.Abi@epamail.epa.gov
Date: 12/13/2011 03:46 PM
Subject: TX I-SIP
DELIBERATIVE
Al-
Attached please find the draft TX Infrastructure SIP (named TX
draft 12-13 sans BACT sans SSO hilite) as of today. This draft
does not include comments/responses to single source ozone
modeling, BACT, or PM 2.5 at this time.
[attachment "TX draft 12-13 sans BACT sans SSO hilite.docx"
deleted by Chrissy Mann/R6/USEPA/US]
(b) (5)
1. As a preliminary matter, we would like to hear your thoughts
on some of our potential responses. The first is if you are
comfortable with the direction we are taking with respect to the
manner in which we are handling implementation as it relates to
the I-SIP.








[attachment "TX i-SIP Consultation RTC 12.12 clean.docx" deleted
by Chrissy Mann/R6/USEPA/US] [attachment "TX 1-SIP alt consult
12.13.docx" deleted by Chrissy Mann/R6/USEPA/US]
3. I'm also attaching draft language on PM2.5 comments/
responses. It is near completion of the vetting process with
OGC and OAQPS so this can give you an idea of the direction of
the response.
[attachment "DRAFT insert for TX RTC NSRPSD issue GW 12 1 11
+slhcmts.ss+bld 12 11 11.docx" deleted by Chrissy
Mann/R6/USEPA/US]
Thank you!!!
Suzanne J. Smith
Chief, Multimedia Counseling Branch
Office of Regional Counsel
214-665-8027
[attachment "TX 1-SIP alt consult 12.13.CM.docx" removed by Abi
Vijayan/R6/USEPA/US]
[attachment "TX i-SIP Consultation RTC 12.12 clean. CM.
docx.docx" removed by Abi Vijayan/R6/USEPA/US][attachment "TX i-
SIP Consultation RTC 12.12 clean. CM. docx.docx" deleted by Erik
Snyder/R6/USEPA/US] [attachment "TX 1-SIP alt consult
12.13.CM.docx" deleted by Erik Snyder/R6/USEPA/US]
[attachment "TX i-SIP Consultation RTC 12.15 full - clean.docx"
removed by Anna Wood/RTP/USEPA/US]
[attachment "TX i-SIP Consultation RTC 12.15 full - marked
up.docx" removed by Anna Wood/RTP/USEPA/US]
[attachment "TX i-SIP Consultation RTC 12.15 minimum + bld
alternative to address OAR concerns.docx" removed by Al
Armendariz/R6/USEPA/US]
FOIA Exemption (b)(5) - Deliberative Process Privilege
[attachment "TX i-SIP Consultation RTC 12.15 minimum + bld
comments.docx" removed by Al Armendariz/R6/USEPA/US]
From: Thomas Diggs
To: Al Armendariz; Chrissy Mann
Cc: Carl Edlund; Suzanne Smith
Subject: Fw: Front office's edits to consultation RTC
Date: 12/16/2011 10:59 AM
Attachments: TX i-SIP Consultation RTC 12.15 minimum + bld alternative to address OAR concerns docx
TX i-SIP Consultation RTC 12.15 minimum + bld comments docx
Al:
This summary by Brian Doster may be useful.
Tom
Thomas Diggs
Associate Director - Air
US EPA Region 6
214-665-3102
fax 214-665-7263
diggs.thomas@epa.gov
----- Forwarded by Thomas Diggs/R6/USEPA/US on 12/16/2011 10:59 AM -----
From: Brian Doster/DC/USEPA/US
To: Anna Wood/RTP/USEPA/US@EPA
Cc: Thomas Diggs/R6/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA, Lucinda Watson/R6/USEPA/US@EPA, Abi
Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA, Geoffrey
Wilcox/DC/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Kevin McLean/DC/USEPA/US@EPA, Melina
Williams/DC/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA, Raj
Rao/RTP/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Suzanne
Smith/R6/USEPA/US@EPA, Dan Deroeck/RTP/USEPA/US@EPA, Richard Wayland/RTP/USEPA/US@EPA
Date: 12/16/2011 10:55 AM
Subject: Re: Fw: Front office's edits to consultation RTC




Anna Wood---12/16/2011 11:32:25 AM--- Brian and others, we've taken a closer look at Brian's version
below and would like for those addit
From: Anna Wood/RTP/USEPA/US
To: Brian Doster/DC/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA
Cc: Lucinda Watson/R6/USEPA/US@EPA, Abi Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA,
(b) (5)
Erik Snyder/R6/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA,
Kevin McLean/DC/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA,
Phil Lorang/RTP/USEPA/US@EPA, Raj Rao/RTP/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA,
Suzanne Murray/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA,
Tyler Fox/RTP/USEPA/US@EPA, Dan Deroeck/RTP/USEPA/US@EPA, Richard Wayland/RTP/USEPA/US@EPA
Date: 12/16/2011 11:32 AM
Subject: Re: Fw: Front office's edits to consultation RTC
Brian and others, we've taken a closer look at Brian's version below and would like for those additional
changes to be made if everyone is comfortable with them.
If need be we can get on a call to discuss further, please let us know. Thanks.
_______________________________
Anna Marie Wood
Director, Air Quality Policy Division
Office of Air Quality Planning & Standards
U.S. Environmental Protection Agency
AQPD (C504-01)
109 T.W. Alexander Drive
Research Triangle Park, NC 27711
Phone: (919) 541- 3604
Fax: (919) 541- 4028
Brian Doster---12/16/2011 10:36:29 AM---
From: Brian Doster/DC/USEPA/US
To: Lucinda Watson/R6/USEPA/US@EPA
Cc: Anna Wood/RTP/USEPA/US@EPA, Abi Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA,
Erik Snyder/R6/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA,
Kevin McLean/DC/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA,
Phil Lorang/RTP/USEPA/US@EPA, Raj Rao/RTP/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA,
Suzanne Murray/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA,
Tyler Fox/RTP/USEPA/US@EPA, Dan Deroeck/RTP/USEPA/US@EPA
Date: 12/16/2011 10:36 AM
Subject: Re: Fw: Front office's edits to consultation RTC



I'm not sending to Al and J anet and this time so that staff can get an opportunity to think about this first and
determine whether you think it would be productive to put this in front of them at the 11:00 call.
Please review and let me know what you think.
Lucinda Watson---12/15/2011 07:25:04 PM---Abi will schedule the call for all and include Al. As I
indicated in my previous message, it is th
From: Lucinda Watson/R6/USEPA/US
To: Anna Wood/RTP/USEPA/US@EPA
Cc: Abi Vijayan/R6/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA,
Erik Snyder/R6/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA,
Kevin McLean/DC/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA,
Phil Lorang/RTP/USEPA/US@EPA, Raj Rao/RTP/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA,
Suzanne Murray/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA,
Tyler Fox/RTP/USEPA/US@EPA, Al Armendariz/R6/USEPA/US@EPA
Date: 12/15/2011 07:25 PM
Subject: Re: Fw: Front office's edits to consultation RTC
Abi will schedule the call for all and include Al.
(b) (5)
(b) (5)
(b) (5)
As I indicated in my previous message, it is the version that Brian edited and indicated where it addresses
HQ's concerns that was provided to Al. It is titled RTC 12.15 minimum bld comments.
I attach it again for convenience.
Anna Wood---12/15/2011 10:22:22 PM---Hi Erik, I did share this information below with J anet McCabe and
we continue to have some concerns
From: Anna Wood/RTP/USEPA/US
To: Erik Snyder/R6/USEPA/US@EPA
Cc: Abi Vijayan/R6/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA,
Geoffrey Wilcox/DC/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Kevin McLean/DC/USEPA/US@EPA,
Lucinda Watson/R6/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA,
Phil Lorang/RTP/USEPA/US@EPA, Raj Rao/RTP/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA,
Suzanne Murray/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA,
Tyler Fox/RTP/USEPA/US@EPA
Date: 12/15/2011 10:22 PM
Subject: Re: Fw: Front office's edits to consultation RTC
Hi Erik, I did share this information below with J anet McCabe and we continue to have some
concerns
Thank you.
_______________________________
Anna Marie Wood
Director, Air Quality Policy Division
Office of Air Quality Planning & Standards
U.S. Environmental Protection Agency
AQPD (C504-01)
109 T.W. Alexander Drive
Research Triangle Park, NC 27711
Phone: (919) 541- 3604
Fax: (919) 541- 4028
-----Erik Snyder/R6/USEPA/US wrote: -----
To: Abi Vijayan/R6/USEPA/US@EPA
From: Erik Snyder/R6/USEPA/US
Date: 12/15/2011 09:49PM
Cc: Brian Doster/DC/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA, Lucinda
Watson/R6/USEPA/US@EPA, Kevin McLean/DC/USEPA/US@EPA, Carrie
Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Suzanne
Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Suzanne
Murray/R6/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA, Geoffrey
Wilcox/DC/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA,
Raj Rao/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA, Anna
Wood/RTP/USEPA/US@EPA
Subject: Re: Fw: Front office's edits to consultation RTC
Hi,


(b) (5)
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
agreed with ROs on the approach, but Texas hasn't); As long as a state and RO were in




As Abi indicated we greatly appreciate everyone's attention to this as we finalize our action.
We appreciate the input on preference for this 'RTC 12.15 full' version or the 'RTC 12.15
Minimum' version.
Thanks,
Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
email: snyder.erik@epa.gov
(See attached file: TX i-SIP Consultation RTC 12.15 full - clean.docx)
(See attached file: TX i-SIP Consultation RTC 12.15 full - marked up.docx)
yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBBYmkgVmlqYXlhbi0tLTEyLzE1
LzIwMTEgMDc6MjI6MzcgUE0tLS1UaGFuayB5b3UgYWxsIGZvciB0aGUgY29udGludWluZyBmaXJ l
IGRyaWxsIGRpc2N1c3Npb24gYW5kIGFzcw== Abi Vijayan---12/15/2011 07:22:37 PM---Thank
you all for the continuing fire drill discussion and assistance on this! If anyone has souveni
From: Abi Vijayan/R6/USEPA/US
To: Brian Doster/DC/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA
Cc: Lucinda Watson/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA, Kevin
McLean/DC/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Tyler
Fox/RTP/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA, Raj Rao/RTP/USEPA/US@EPA, Phil
Lorang/RTP/USEPA/US@EPA, Anna Wood/RTP/USEPA/US@EPA
Date: 12/15/2011 07:22 PM
Subject: Re: Fw: Front office's edits to consultation RTC
Thank you all for the continuing fire drill discussion and assistance on this! If anyone has
souvenirs or borderline tacky gifts of gratitude they'd enjoy from Dallas, Texas, just let us know.
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege

Thanks to all again, please do not hesitate to ping us.
[attachment "TX i-SIP Consultation RTC 12.15 minimum.docx" deleted by Erik
Snyder/R6/USEPA/US]
Abi Vijayan
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6RC-M)
Dallas, TX 75202
Tel: (214) 665-7303
Fax: (214) 665-2182
NOTICE: This communication may contain privileged or otherwise confidential information. If
you are not the intended recipient, or believe you have received this communication in error,
please delete the copy you received, and do not print, copy, re-transmit, disseminate or
otherwise use the information. Thank you.
yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBCcmlhbiBEb3N0ZXItLS0xMi8x
NS8yMDExIDExOjM2OjM1IEFNLS0tSGF2aW5nIG5vdyBoYWQgYSBjaGFuY2UgdG8gcmV2aWV3IHRo
ZSBlbWFpbCBjaGFpbiBtb3J lIGNhcmVmdQ== Brian Doster---12/15/2011 11:36:35 AM---Having
now had a chance to review the email chain more carefully, I see that Erik has put forward a
From: Brian Doster/DC/USEPA/US
To: Lucinda Watson/R6/USEPA/US@EPA
Cc: Erik Snyder/R6/USEPA/US@EPA, Kevin McLean/DC/USEPA/US@EPA, Abi
Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Tyler
Fox/RTP/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA, Raj Rao/RTP/USEPA/US@EPA, Phil
Lorang/RTP/USEPA/US@EPA, Anna Wood/RTP/USEPA/US@EPA
Date: 12/15/2011 11:36 AM
Subject: Re: Fw: Front office's edits to consultation RTC
Having now had a chance to review the email chain more carefully, I see that Erik has put
forward a proposal



(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege



yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBMdWNpbmRhIFdhdHNvbi0tLTEy
LzE1LzIwMTEgMTI6MDI6MDUgUE0tLS1CcmlhbiwgSSBhZ3J lZSB3aXRoIHlvdSAxMDAgcGVyY2Vu
dC4gIEkgYW0gZWxhdGVkIHRoYXQgSHFzIA== Lucinda Watson---12/15/2011 12:02:05 PM---
Brian, I agree with you 100 percent.
From: Lucinda Watson/R6/USEPA/US
To: Brian Doster/DC/USEPA/US@EPA
Cc: Erik Snyder/R6/USEPA/US@EPA, Kevin McLean/DC/USEPA/US@EPA, Abi
Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Tyler
Fox/RTP/USEPA/US@EPA
Date: 12/15/2011 12:02 PM
Subject: Re: Fw: Front office's edits to consultation RTC
Brian,
I agree with you 100 percent.
yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBCcmlhbiBEb3N0ZXItLS0xMi8x
NS8yMDExIDA4OjM4OjM3IEFNLS0tSSBkb24ndCBiZWxpZXZlIEknbSBwcml2eSB0byBLZXZpbidz
IGVtYWlsIGFuZCBJ IGRpZG4ndCBjb3B5IA== Brian Doster---12/15/2011 08:38:37 AM---I don't
believe I'm privy to Kevin's email and I didn't copy him on mine, so I'll need too check in
From: Brian Doster/DC/USEPA/US
To: Erik Snyder/R6/USEPA/US@EPA
Cc: Kevin McLean/DC/USEPA/US@EPA, Abi Vijayan/R6/USEPA/US@EPA, Carrie
Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, watson.lucinda@epa.gov,
Suzanne Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Suzanne
Murray/R6/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA, Geoffrey
Wilcox/DC/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA
(b) (5)
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
Date: 12/15/2011 08:38 AM
Subject: Re: Fw: Front office's edits to consultation RTC
I don't believe I'm privy to Kevin's email and I didn't copy him on mine, so I'll need too check in
with him.



yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBFcmlrIFNueWRlci0tLTEyLzE1
LzIwMTEgMDk6MjI6NTIgQU0tLS1IaSwgTG90cyBvZiBlbWFpbCB0cmFmZmljIGZsb2F0aW5nIGFy
b3VuZCB0aHJ vdWdob3V0IHRoZSBuaWdodA== Erik Snyder---12/15/2011 09:22:52 AM---Hi,
Lots of email traffic floating around throughout the night and early this morning. After talkin
From: Erik Snyder/R6/USEPA/US
To: Kevin McLean/DC/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA
Cc: Abi Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, watson.lucinda@epa.gov, Suzanne Smith/R6/USEPA/US@EPA,
Thomas Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Tyler
Fox/RTP/USEPA/US@EPA
Date: 12/15/2011 09:22 AM
Subject: Fw: Front office's edits to consultation RTC
Hi,
Lots of email traffic floating around throughout the night and early this morning. After talking
with Guy and Tom this morning,

For
more details on this concept see my attached email below. Appreciate feedback on this concept
from the group.
Thanks,
Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
email: snyder.erik@epa.gov
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
Pun of the Day - My new theory on inertia doesn't seem to be gaining momentum.
----- Forwarded by Erik Snyder/R6/USEPA/US on 12/15/2011 08:06 AM -----
From: Guy Donaldson/R6/USEPA/US
To: Erik Snyder/R6/USEPA/US@EPA
Cc: Abi Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Lucinda
Watson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, J effrey
Robinson/R6/USEPA/US@EPA
Date: 12/14/2011 10:49 PM
Subject: Re: Front office's edits to consultation RTC


[attachment "TX i-SIP Consultation RTC 12.12 clean. CMguy. docx.docx" deleted by Brian
Doster/DC/USEPA/US]
yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBFcmlrIFNueWRlci0tLTEyLzE0
LzIwMTEgMTA6MzQ6NDIgUE0tLS1IaSwgSSBrbm93IHdlIGFyZSBkYW5jaW5nIG9uIGEgcGluaGVh
ZCBvbiB0aGlzIGlzc3VlLiAgSSBzZWUgdA== Erik Snyder---12/14/2011 10:34:42 PM---Hi,
From: Erik Snyder/R6/USEPA/US
To: Abi Vijayan/R6/USEPA/US@EPA
Cc: Carrie Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Lucinda
Watson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, J effrey
Robinson/R6/USEPA/US@EPA
Date: 12/14/2011 10:34 PM
Subject: Re: Front office's edits to consultation RTC
Hi,
Here is some thoughts on how we might try to frame things...

(b) (5)
(b) (5)
(b) (5)
Will need to flush out details further and work on a rewrite, but it is the best option that I see
currently
I will look over the edits further and be ready to go in the morning.

-Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
email: snyder.erik@epa.gov
Pun of the Day - My new theory on inertia doesn't seem to be gaining momentum.
yv+KAH4AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBBYmkgVmlqYXlhbi0tLTEyLzE0
LzIwMTEgMDk6NTc6NTQgUE0tLS1Gcm9tOiBBYmkgVmlqYXlhbi9SNi9VU0VQQS9VUyBUbzogRXJ p
ayBTbnlkZXIvUjYvVVNFUEEvVVNARVBB Abi Vijayan---12/14/2011 09:57:54 PM---From: Abi
Vijayan/R6/USEPA/US To: Erik Snyder/R6/USEPA/US@EPA
From: Abi Vijayan/R6/USEPA/US
To: Erik Snyder/R6/USEPA/US@EPA
Cc: Lucinda Watson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Carrie
Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA
Date: 12/14/2011 09:57 PM
Subject: Re: Front office's edits to consultation RTC
Thanks, Erik.
Abi Vijayan
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6RC-M)
Dallas, TX 75202
Tel: (214) 665-7303
Fax: (214) 665-2182
NOTICE: This communication may contain privileged or otherwise confidential information. If
you are not the intended recipient, or believe you have received this communication in error,
(b) (5)
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
please delete the copy you received, and do not print, copy, re-transmit, disseminate or
otherwise use the information. Thank you.
-----Erik Snyder/R6/USEPA/US wrote: -----
To: Abi Vijayan/R6/USEPA/US@EPA
From: Erik Snyder/R6/USEPA/US
Date: 12/14/2011 09:42PM
Subject: Re: Front office's edits to consultation RTC
The documents did not come through. Looks like they were removed when you
forwarded. Can you send them? Thanks.
I have not been in all the discussions with OGC and OAQPS, but wonder if we can work a
solution.
I think


Thanks,
Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
email: snyder.erik@epa.gov
Pun of the Day - My new theory on inertia doesn't seem to be gaining momentum.
Abi Vijayan---12/14/2011 08:49:40 PM---
From: Abi Vijayan/R6/USEPA/US
To: Suzanne Smith/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA, J effrey
Robinson/R6/USEPA/US@EPA
Date: 12/14/2011 08:49 PM
Subject: Front office's edits to consultation RTC


(b) (5)
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege

Abi Vijayan
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6RC-M)
Dallas, TX 75202
Tel: (214) 665-7303
Fax: (214) 665-2182
NOTICE: This communication may contain privileged or otherwise confidential
information. If you are not the intended recipient, or believe you have received this
communication in error, please delete the copy you received, and do not print, copy, re-
transmit, disseminate or otherwise use the information. Thank you.
-----Chrissy Mann/R6/USEPA/US wrote: -----
To: Suzanne Smith/R6/USEPA/US@EPA
From: Chrissy Mann/R6/USEPA/US
Date: 12/14/2011 07:59PM
Cc: Al Armendariz/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Carrie
Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Layla
Mansuri/R6/USEPA/US@EPA, Murray.Suzanne@epamail.epa.gov, Thomas
Diggs/R6/USEPA/US@EPA, Vijayan.Abi@epamail.epa.gov
Subject: Re: TX I-SIP
I spoke with Al and . The documents are attached,
However, what is important
per our conversation is:

Let me know what you think.
Chrissy Mann
Special Assistant to the Regional Administrator
EPA Region 6
214-665-7295
mann.chrissy@epa.gov
From: Suzanne Smith/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Chrissy Mann/R6/USEPA/US@EPA, Layla Mansuri/R6/USEPA/US@EPA
Cc: Murray.Suzanne@epamail.epa.gov, Carl Edlund/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Vijayan.Abi@epamail.epa gov
Date: 12/13/2011 03:46 PM
Subject: TX I -SIP
DELIBERATIVE
(b) (5)
(b)
(5)
(b) (5)
(b) (5)
Al-
Attached please find the draft TX Infrastructure SIP (named TX draft 12-13 sans
BACT sans SSO hilite) as of today. This draft does not include
comments/responses to single source ozone modeling, BACT, or PM 2.5 at this
time.
[attachment "TX draft 12-13 sans BACT sans SSO hilite.docx" deleted by Chrissy
Mann/R6/USEPA/US]
1. As a preliminary matter, we would like to hear your thoughts on some of our
potential responses. The first is if you are comfortable with the direction we are
taking with respect to the manner in which we are handling implementation as it
relates to the I-SIP



[attachment "TX i-SIP Consultation RTC 12.12 clean.docx" deleted by Chrissy
Mann/R6/USEPA/US] [attachment "TX 1-SIP alt consult 12.13.docx" deleted by
Chrissy Mann/R6/USEPA/US]
3. I'm also attaching draft language on PM2.5 comments/ responses. It is near
completion of the vetting process with OGC and OAQPS so this can give you an
idea of the direction of the response.
[attachment "DRAFT insert for TX RTC NSRPSD issue GW 12 1 11 +slhcmts.ss+bld
12 11 11.docx" deleted by Chrissy Mann/R6/USEPA/US]
Thank you!!!
Suzanne J . Smith
Chief, Multimedia Counseling Branch
Office of Regional Counsel
214-665-8027
[attachment "TX 1-SIP alt consult 12.13.CM.docx" removed by Abi Vijayan/R6/USEPA/US]
[attachment "TX i-SIP Consultation RTC 12.12 clean. CM. docx.docx" removed by Abi
Vijayan/R6/USEPA/US][attachment "TX i-SIP Consultation RTC 12.12 clean. CM.
docx.docx" deleted by Erik Snyder/R6/USEPA/US] [attachment "TX 1-SIP alt consult
12.13.CM.docx" deleted by Erik Snyder/R6/USEPA/US]
[attachment "TX i-SIP Consultation RTC 12.15 full - clean.docx" removed by Anna
Wood/RTP/USEPA/US]
[attachment "TX i-SIP Consultation RTC 12.15 full - marked up.docx" removed by Anna
Wood/RTP/USEPA/US]
(b) (5)
(b) (5)
From: Al Armendariz
To: Mann Chrissy; Mansuri Layla
Subject: Fw: Fw: Front office's edits to consultation RTC
Date: 12/15/2011 10:58 PM
Attachments: TX i-SIP Consultation RTC 12.15 minimum + bld comments docx
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
Lucinda Watson
----- Original Message -----
From: Lucinda Watson
Sent: 12/15/2011 10:30 PM CST
To: Anna Wood
Cc: Abi Vijayan; Brian Doster; Carrie Paige; Erik Snyder; Geoffrey Wilcox; Guy Donaldson; Kevin
Mclean; Melina Williams; Michael Ling; Phil Lorang; Raj Rao; Sara Schneeberg; Suzanne Murray;
Suzanne Smith; Thomas Diggs; Tyler Fox; Al Armendariz
Subject: Re: Fw: Front office's edits to consultation RTC
Abi will schedule the call for all and include Al.
As I indicated in my previous message, it is the version that Brian edited and indicated where it addresses
HQ's concerns that was provided to Al. It is titled RTC 12.15 minimum bld comments.
I attach it again for convenience.
Anna Wood---12/15/2011 10:22:22 PM---Hi Erik, I did share this information below with J anet McCabe and
we continue to have some concerns
From: Anna Wood/RTP/USEPA/US
To: Erik Snyder/R6/USEPA/US@EPA
Cc: Abi Vijayan/R6/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA,
Geoffrey Wilcox/DC/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Kevin McLean/DC/USEPA/US@EPA,
Lucinda Watson/R6/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA,
Phil Lorang/RTP/USEPA/US@EPA, Raj Rao/RTP/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA,
Suzanne Murray/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA,
Tyler Fox/RTP/USEPA/US@EPA
Date: 12/15/2011 10:22 PM
Subject: Re: Fw: Front office's edits to consultation RTC
Hi Erik, I did share this information below with J anet McCabe and we continue to have some
concerns
Thank you.
_______________________________
Anna Marie Wood
Director, Air Quality Policy Division
Office of Air Quality Planning & Standards
U.S. Environmental Protection Agency
AQPD (C504-01)
109 T.W. Alexander Drive
Research Triangle Park, NC 27711
Phone: (919) 541- 3604
(b) (5)
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
Fax: (919) 541- 4028
-----Erik Snyder/R6/USEPA/US wrote: -----
To: Abi Vijayan/R6/USEPA/US@EPA
From: Erik Snyder/R6/USEPA/US
Date: 12/15/2011 09:49PM
Cc: Brian Doster/DC/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA, Lucinda
Watson/R6/USEPA/US@EPA, Kevin McLean/DC/USEPA/US@EPA, Carrie
Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Suzanne
Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Suzanne
Murray/R6/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA, Geoffrey
Wilcox/DC/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA,
Raj Rao/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA, Anna
Wood/RTP/USEPA/US@EPA
Subject: Re: Fw: Front office's edits to consultation RTC
Hi,






As Abi indicated we greatly appreciate everyone's attention to this as we finalize our action.
We appreciate the input on preference for this 'RTC 12.15 full' version or the 'RTC 12.15
Minimum' version.
Thanks,
Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
email: snyder.erik@epa.gov
(See attached file: TX i-SIP Consultation RTC 12.15 full - clean.docx)
(b) (5)
(See attached file: TX i-SIP Consultation RTC 12.15 full - marked up.docx)
yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBBYmkgVmlqYXlhbi0tLTEyLzE1
LzIwMTEgMDc6MjI6MzcgUE0tLS1UaGFuayB5b3UgYWxsIGZvciB0aGUgY29udGludWluZyBmaXJ l
IGRyaWxsIGRpc2N1c3Npb24gYW5kIGFzcw== Abi Vijayan---12/15/2011 07:22:37 PM---Thank
you all for the continuing fire drill discussion and assistance on this! If anyone has souveni
From: Abi Vijayan/R6/USEPA/US
To: Brian Doster/DC/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA
Cc: Lucinda Watson/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA, Kevin
McLean/DC/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Tyler
Fox/RTP/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA, Raj Rao/RTP/USEPA/US@EPA, Phil
Lorang/RTP/USEPA/US@EPA, Anna Wood/RTP/USEPA/US@EPA
Date: 12/15/2011 07:22 PM
Subject: Re: Fw: Front office's edits to consultation RTC
Thank you all for the continuing fire drill discussion and assistance on this! If anyone has
souvenirs or borderline tacky gifts of gratitude they'd enjoy from Dallas, Texas, just let us know.

Thanks to all again, please do not hesitate to ping us.
[attachment "TX i-SIP Consultation RTC 12.15 minimum.docx" deleted by Erik
Snyder/R6/USEPA/US]
Abi Vijayan
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6RC-M)
Dallas, TX 75202
Tel: (214) 665-7303
Fax: (214) 665-2182
NOTICE: This communication may contain privileged or otherwise confidential information. If
you are not the intended recipient, or believe you have received this communication in error,
please delete the copy you received, and do not print, copy, re-transmit, disseminate or
otherwise use the information. Thank you.
yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBCcmlhbiBEb3N0ZXItLS0xMi8x
NS8yMDExIDExOjM2OjM1IEFNLS0tSGF2aW5nIG5vdyBoYWQgYSBjaGFuY2UgdG8gcmV2aWV3IHRo
ZSBlbWFpbCBjaGFpbiBtb3J lIGNhcmVmdQ== Brian Doster---12/15/2011 11:36:35 AM---Having
now had a chance to review the email chain more carefully, I see that Erik has put forward a
(b) (5)
From: Brian Doster/DC/USEPA/US
To: Lucinda Watson/R6/USEPA/US@EPA
Cc: Erik Snyder/R6/USEPA/US@EPA, Kevin McLean/DC/USEPA/US@EPA, Abi
Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Tyler
Fox/RTP/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA, Raj Rao/RTP/USEPA/US@EPA, Phil
Lorang/RTP/USEPA/US@EPA, Anna Wood/RTP/USEPA/US@EPA
Date: 12/15/2011 11:36 AM
Subject: Re: Fw: Front office's edits to consultation RTC
Having now had a chance to review the email chain more carefully, I see that Erik has put
forward a proposal










yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBMdWNpbmRhIFdhdHNvbi0tLTEy
LzE1LzIwMTEgMTI6MDI6MDUgUE0tLS1CcmlhbiwgSSBhZ3J lZSB3aXRoIHlvdSAxMDAgcGVyY2Vu
dC4gIEkgYW0gZWxhdGVkIHRoYXQgSHFzIA== Lucinda Watson---12/15/2011 12:02:05 PM---
Brian, I agree with you 100 percent.
From: Lucinda Watson/R6/USEPA/US
To: Brian Doster/DC/USEPA/US@EPA
Cc: Erik Snyder/R6/USEPA/US@EPA, Kevin McLean/DC/USEPA/US@EPA, Abi
Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Tyler
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
Fox/RTP/USEPA/US@EPA
Date: 12/15/2011 12:02 PM
Subject: Re: Fw: Front office's edits to consultation RTC
Brian,
I agree with you 100 percent.
yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBCcmlhbiBEb3N0ZXItLS0xMi8x
NS8yMDExIDA4OjM4OjM3IEFNLS0tSSBkb24ndCBiZWxpZXZlIEknbSBwcml2eSB0byBLZXZpbidz
IGVtYWlsIGFuZCBJ IGRpZG4ndCBjb3B5IA== Brian Doster---12/15/2011 08:38:37 AM---I don't
believe I'm privy to Kevin's email and I didn't copy him on mine, so I'll need too check in
From: Brian Doster/DC/USEPA/US
To: Erik Snyder/R6/USEPA/US@EPA
Cc: Kevin McLean/DC/USEPA/US@EPA, Abi Vijayan/R6/USEPA/US@EPA, Carrie
Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, watson.lucinda@epa.gov,
Suzanne Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Suzanne
Murray/R6/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA, Geoffrey
Wilcox/DC/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA
Date: 12/15/2011 08:38 AM
Subject: Re: Fw: Front office's edits to consultation RTC
I don't believe I'm privy to Kevin's email and I didn't copy him on mine, so I'll need too check in
with him.



yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBFcmlrIFNueWRlci0tLTEyLzE1
LzIwMTEgMDk6MjI6NTIgQU0tLS1IaSwgTG90cyBvZiBlbWFpbCB0cmFmZmljIGZsb2F0aW5nIGFy
b3VuZCB0aHJ vdWdob3V0IHRoZSBuaWdodA== Erik Snyder---12/15/2011 09:22:52 AM---Hi,
Lots of email traffic floating around throughout the night and early this morning. After talkin
From: Erik Snyder/R6/USEPA/US
To: Kevin McLean/DC/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA
Cc: Abi Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, watson.lucinda@epa.gov, Suzanne Smith/R6/USEPA/US@EPA,
Thomas Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Tyler
Fox/RTP/USEPA/US@EPA
Date: 12/15/2011 09:22 AM
Subject: Fw: Front office's edits to consultation RTC
Hi,
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
Lots of email traffic floating around throughout the night and early this morning. After talking
with Guy and Tom this morning,

For
more details on this concept see my attached email below. Appreciate feedback on this concept
from the group.
Thanks,
Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
email: snyder.erik@epa.gov
Pun of the Day - My new theory on inertia doesn't seem to be gaining momentum.
----- Forwarded by Erik Snyder/R6/USEPA/US on 12/15/2011 08:06 AM -----
From: Guy Donaldson/R6/USEPA/US
To: Erik Snyder/R6/USEPA/US@EPA
Cc: Abi Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Lucinda
Watson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, J effrey
Robinson/R6/USEPA/US@EPA
Date: 12/14/2011 10:49 PM
Subject: Re: Front office's edits to consultation RTC


[attachment "TX i-SIP Consultation RTC 12.12 clean. CMguy. docx.docx" deleted by Brian
Doster/DC/USEPA/US]
yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBFcmlrIFNueWRlci0tLTEyLzE0
LzIwMTEgMTA6MzQ6NDIgUE0tLS1IaSwgSSBrbm93IHdlIGFyZSBkYW5jaW5nIG9uIGEgcGluaGVh
ZCBvbiB0aGlzIGlzc3VlLiAgSSBzZWUgdA== Erik Snyder---12/14/2011 10:34:42 PM---Hi,
From: Erik Snyder/R6/USEPA/US
To: Abi Vijayan/R6/USEPA/US@EPA
Cc: Carrie Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Lucinda
Watson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, J effrey
Robinson/R6/USEPA/US@EPA
Date: 12/14/2011 10:34 PM
Subject: Re: Front office's edits to consultation RTC
(b) (5)
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
Hi,
Here is some thoughts on how we might try to frame things...

Will need to flush out details further and work on a rewrite, but it is the best option that I see
currently
I will look over the edits further and be ready to go in the morning.

-Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
email: snyder.erik@epa.gov
Pun of the Day - My new theory on inertia doesn't seem to be gaining momentum.
yv+KAH4AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBBYmkgVmlqYXlhbi0tLTEyLzE0
LzIwMTEgMDk6NTc6NTQgUE0tLS1Gcm9tOiBBYmkgVmlqYXlhbi9SNi9VU0VQQS9VUyBUbzogRXJ p
ayBTbnlkZXIvUjYvVVNFUEEvVVNARVBB Abi Vijayan---12/14/2011 09:57:54 PM---From: Abi
Vijayan/R6/USEPA/US To: Erik Snyder/R6/USEPA/US@EPA
From: Abi Vijayan/R6/USEPA/US
To: Erik Snyder/R6/USEPA/US@EPA
Cc: Lucinda Watson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Carrie
Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA
Date: 12/14/2011 09:57 PM
Subject: Re: Front office's edits to consultation RTC
(b) (5)
(b) (5)
(b) (5)
Thanks, Erik.
Abi Vijayan
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6RC-M)
Dallas, TX 75202
Tel: (214) 665-7303
Fax: (214) 665-2182
NOTICE: This communication may contain privileged or otherwise confidential information. If
you are not the intended recipient, or believe you have received this communication in error,
please delete the copy you received, and do not print, copy, re-transmit, disseminate or
otherwise use the information. Thank you.
-----Erik Snyder/R6/USEPA/US wrote: -----
To: Abi Vijayan/R6/USEPA/US@EPA
From: Erik Snyder/R6/USEPA/US
Date: 12/14/2011 09:42PM
Subject: Re: Front office's edits to consultation RTC
The documents did not come through. Looks like they were removed when you
forwarded. Can you send them? Thanks.
I have not been in all the discussions with OGC and OAQPS, but wonder if we can work a
solution.
I think


Thanks,
Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
email: snyder.erik@epa.gov
Pun of the Day - My new theory on inertia doesn't seem to be gaining momentum.
Abi Vijayan---12/14/2011 08:49:40 PM---
From: Abi Vijayan/R6/USEPA/US
To: Suzanne Smith/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Guy
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
Donaldson/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA, J effrey
Robinson/R6/USEPA/US@EPA
Date: 12/14/2011 08:49 PM
Subject: Front office's edits to consultation RTC




Abi Vijayan
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6RC-M)
Dallas, TX 75202
Tel: (214) 665-7303
Fax: (214) 665-2182
NOTICE: This communication may contain privileged or otherwise confidential
information. If you are not the intended recipient, or believe you have received this
communication in error, please delete the copy you received, and do not print, copy, re-
transmit, disseminate or otherwise use the information. Thank you.
-----Chrissy Mann/R6/USEPA/US wrote: -----
To: Suzanne Smith/R6/USEPA/US@EPA
From: Chrissy Mann/R6/USEPA/US
Date: 12/14/2011 07:59PM
Cc: Al Armendariz/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Carrie
Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Layla
Mansuri/R6/USEPA/US@EPA, Murray.Suzanne@epamail.epa.gov, Thomas
Diggs/R6/USEPA/US@EPA, Vijayan.Abi@epamail.epa.gov
Subject: Re: TX I-SIP


(b) (5)
(b) (5)

Let me know what you think.
Chrissy Mann
Special Assistant to the Regional Administrator
EPA Region 6
214-665-7295
mann.chrissy@epa.gov
From: Suzanne Smith/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Chrissy Mann/R6/USEPA/US@EPA, Layla Mansuri/R6/USEPA/US@EPA
Cc: Murray.Suzanne@epamail.epa.gov, Carl Edlund/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Vijayan.Abi@epamail.epa gov
Date: 12/13/2011 03:46 PM
Subject: TX I -SIP
DELIBERATIVE
Al-
Attached please find the draft TX Infrastructure SIP (named TX draft 12-13 sans
BACT sans SSO hilite) as of today. This draft does not include
comments/responses to single source ozone modeling, BACT, or PM 2.5 at this
time.
[attachment "TX draft 12-13 sans BACT sans SSO hilite.docx" deleted by Chrissy
Mann/R6/USEPA/US]
1. As a preliminary matter, we would like to hear your thoughts on some of our
potential responses. The first is if you are comfortable with the direction we are
taking with respect to the manner in which we are handling implementation as it
relates to the I-SIP.



[attachment "TX i-SIP Consultation RTC 12.12 clean.docx" deleted by Chrissy
Mann/R6/USEPA/US] [attachment "TX 1-SIP alt consult 12.13.docx" deleted by
Chrissy Mann/R6/USEPA/US]
(b) (5)
3. I'm also attaching draft language on PM2.5 comments/ responses. It is near
completion of the vetting process with OGC and OAQPS so this can give you an
idea of the direction of the response.
[attachment "DRAFT insert for TX RTC NSRPSD issue GW 12 1 11 +slhcmts.ss+bld
12 11 11.docx" deleted by Chrissy Mann/R6/USEPA/US]
Thank you!!!
Suzanne J . Smith
Chief, Multimedia Counseling Branch
Office of Regional Counsel
214-665-8027
[attachment "TX 1-SIP alt consult 12.13.CM.docx" removed by Abi Vijayan/R6/USEPA/US]
[attachment "TX i-SIP Consultation RTC 12.12 clean. CM. docx.docx" removed by Abi
Vijayan/R6/USEPA/US][attachment "TX i-SIP Consultation RTC 12.12 clean. CM.
docx.docx" deleted by Erik Snyder/R6/USEPA/US] [attachment "TX 1-SIP alt consult
12.13.CM.docx" deleted by Erik Snyder/R6/USEPA/US]
[attachment "TX i-SIP Consultation RTC 12.15 full - clean.docx" removed by Anna
Wood/RTP/USEPA/US]
[attachment "TX i-SIP Consultation RTC 12.15 full - marked up.docx" removed by Anna
Wood/RTP/USEPA/US]
From: Lucinda Watson
To: Anna Wood
Cc: Abi Vijayan; Brian Doster; Carrie Paige; Erik Snyder; Geoffrey Wilcox; Guy Donaldson; Kevin McLean; Melina Williams; Michael Ling; Phil Lorang; Raj
Rao; Sara Schneeberg; Suzanne Murray; Suzanne Smith; Thomas Diggs; Tyler Fox; Al Armendariz
Subject: Re: Fw: Front office's edits to consultation RTC
Date: 12/15/2011 10:19 PM
Attachments: TX i-SIP Consultation RTC 12.15 minimum + bld comments docx
This version (w/o Brian's minimal edits) is before Al for his review. We are waiting to hear from him if this
approach is acceptable. I have copied Al so that he knows about J anet's concerns and her offer to have a
call tomorrow.
Lucinda S Watson
R6 Air Counseling Practice Group Leader
214-333-2237
Anna Wood---12/15/2011 09:21:53 PM---Thanks for the update, in communicating with J anet, she is
concerned about ramifications of defining
From: Anna Wood/RTP/USEPA/US
To: Abi Vijayan/R6/USEPA/US@EPA
Cc: Brian Doster/DC/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA,
Geoffrey Wilcox/DC/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Kevin McLean/DC/USEPA/US@EPA,
Lucinda Watson/R6/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA,
Phil Lorang/RTP/USEPA/US@EPA, Raj Rao/RTP/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA,
Suzanne Murray/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA,
Tyler Fox/RTP/USEPA/US@EPA
Date: 12/15/2011 09:21 PM
Subject: Re: Fw: Front office's edits to consultation RTC
Thanks for the update,


Thanks, Anna
_______________________________
Anna Marie Wood
Director, Air Quality Policy Division
Office of Air Quality Planning & Standards
U.S. Environmental Protection Agency
AQPD (C504-01)
109 T.W. Alexander Drive
Research Triangle Park, NC 27711
Phone: (919) 541- 3604
Fax: (919) 541- 4028
-----Abi Vijayan/R6/USEPA/US wrote: -----
To: Brian Doster/DC/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA
From: Abi Vijayan/R6/USEPA/US
Date: 12/15/2011 08:22PM
Cc: Lucinda Watson/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA, Kevin
(b) (5)
(b) (5)
McLean/DC/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Tyler
Fox/RTP/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA, Raj Rao/RTP/USEPA/US@EPA, Phil
Lorang/RTP/USEPA/US@EPA, Anna Wood/RTP/USEPA/US@EPA
Subject: Re: Fw: Front office's edits to consultation RTC
Thank you all for the continuing fire drill discussion and assistance on this! If anyone has
souvenirs or borderline tacky gifts of gratitude they'd enjoy from Dallas, Texas, just let us know.

Thanks to all again, please do not hesitate to ping us.
(See attached file: TX i-SIP Consultation RTC 12.15 minimum.docx)
Abi Vijayan
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6RC-M)
Dallas, TX 75202
Tel: (214) 665-7303
Fax: (214) 665-2182
NOTICE: This communication may contain privileged or otherwise confidential information. If
you are not the intended recipient, or believe you have received this communication in error,
please delete the copy you received, and do not print, copy, re-transmit, disseminate or
otherwise use the information. Thank you.
yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBCcmlhbiBEb3N0ZXItLS0xMi8x
NS8yMDExIDExOjM2OjM1IEFNLS0tSGF2aW5nIG5vdyBoYWQgYSBjaGFuY2UgdG8gcmV2aWV3IHRo
ZSBlbWFpbCBjaGFpbiBtb3J lIGNhcmVmdQ== Brian Doster---12/15/2011 11:36:35 AM---Having
now had a chance to review the email chain more carefully, I see that Erik has put forward a
From: Brian Doster/DC/USEPA/US
To: Lucinda Watson/R6/USEPA/US@EPA
Cc: Erik Snyder/R6/USEPA/US@EPA, Kevin McLean/DC/USEPA/US@EPA, Abi
Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Tyler
Fox/RTP/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA, Raj Rao/RTP/USEPA/US@EPA, Phil
Lorang/RTP/USEPA/US@EPA, Anna Wood/RTP/USEPA/US@EPA
Date: 12/15/2011 11:36 AM
Subject: Re: Fw: Front office's edits to consultation RTC
Having now had a chance to review the email chain more carefully, I see that Erik has put
forward a proposal
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege






yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBMdWNpbmRhIFdhdHNvbi0tLTEy
LzE1LzIwMTEgMTI6MDI6MDUgUE0tLS1CcmlhbiwgSSBhZ3J lZSB3aXRoIHlvdSAxMDAgcGVyY2Vu
dC4gIEkgYW0gZWxhdGVkIHRoYXQgSHFzIA== Lucinda Watson---12/15/2011 12:02:05 PM---
Brian, I agree with you 100 percent.
From: Lucinda Watson/R6/USEPA/US
To: Brian Doster/DC/USEPA/US@EPA
Cc: Erik Snyder/R6/USEPA/US@EPA, Kevin McLean/DC/USEPA/US@EPA, Abi
Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Tyler
Fox/RTP/USEPA/US@EPA
Date: 12/15/2011 12:02 PM
Subject: Re: Fw: Front office's edits to consultation RTC
Brian,
I agree with you 100 percent.
(b) (5)
(b) (5)
(b) (5)
yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBCcmlhbiBEb3N0ZXItLS0xMi8x
NS8yMDExIDA4OjM4OjM3IEFNLS0tSSBkb24ndCBiZWxpZXZlIEknbSBwcml2eSB0byBLZXZpbidz
IGVtYWlsIGFuZCBJ IGRpZG4ndCBjb3B5IA== Brian Doster---12/15/2011 08:38:37 AM---I don't
believe I'm privy to Kevin's email and I didn't copy him on mine, so I'll need too check in
From: Brian Doster/DC/USEPA/US
To: Erik Snyder/R6/USEPA/US@EPA
Cc: Kevin McLean/DC/USEPA/US@EPA, Abi Vijayan/R6/USEPA/US@EPA, Carrie
Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, watson.lucinda@epa.gov,
Suzanne Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Suzanne
Murray/R6/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA, Geoffrey
Wilcox/DC/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA
Date: 12/15/2011 08:38 AM
Subject: Re: Fw: Front office's edits to consultation RTC
I don't believe I'm privy to Kevin's email and I didn't copy him on mine, so I'll need too check in
with him.



yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBFcmlrIFNueWRlci0tLTEyLzE1
LzIwMTEgMDk6MjI6NTIgQU0tLS1IaSwgTG90cyBvZiBlbWFpbCB0cmFmZmljIGZsb2F0aW5nIGFy
b3VuZCB0aHJ vdWdob3V0IHRoZSBuaWdodA== Erik Snyder---12/15/2011 09:22:52 AM---Hi,
Lots of email traffic floating around throughout the night and early this morning. After talkin
From: Erik Snyder/R6/USEPA/US
To: Kevin McLean/DC/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA
Cc: Abi Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, watson.lucinda@epa.gov, Suzanne Smith/R6/USEPA/US@EPA,
Thomas Diggs/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Tyler
Fox/RTP/USEPA/US@EPA
Date: 12/15/2011 09:22 AM
Subject: Fw: Front office's edits to consultation RTC
Hi,
Lots of email traffic floating around throughout the night and early this morning. After talking
with Guy and Tom this morning,

FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
For
more details on this concept see my attached email below. Appreciate feedback on this concept
from the group.
Thanks,
Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
email: snyder.erik@epa.gov
Pun of the Day - My new theory on inertia doesn't seem to be gaining momentum.
----- Forwarded by Erik Snyder/R6/USEPA/US on 12/15/2011 08:06 AM -----
From: Guy Donaldson/R6/USEPA/US
To: Erik Snyder/R6/USEPA/US@EPA
Cc: Abi Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Lucinda
Watson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, J effrey
Robinson/R6/USEPA/US@EPA
Date: 12/14/2011 10:49 PM
Subject: Re: Front office's edits to consultation RTC


[attachment "TX i-SIP Consultation RTC 12.12 clean. CMguy. docx.docx" deleted by Brian
Doster/DC/USEPA/US]
yv+LAH8AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBFcmlrIFNueWRlci0tLTEyLzE0
LzIwMTEgMTA6MzQ6NDIgUE0tLS1IaSwgSSBrbm93IHdlIGFyZSBkYW5jaW5nIG9uIGEgcGluaGVh
ZCBvbiB0aGlzIGlzc3VlLiAgSSBzZWUgdA== Erik Snyder---12/14/2011 10:34:42 PM---Hi,
From: Erik Snyder/R6/USEPA/US
To: Abi Vijayan/R6/USEPA/US@EPA
Cc: Carrie Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Lucinda
Watson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, J effrey
Robinson/R6/USEPA/US@EPA
Date: 12/14/2011 10:34 PM
Subject: Re: Front office's edits to consultation RTC
Hi,
Here is some thoughts on how we might try to frame things...
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege

Will need to flush out details further and work on a rewrite, but it is the best option that I see
currently
I will look over the edits further and be ready to go in the morning.

-Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
email: snyder.erik@epa.gov
Pun of the Day - My new theory on inertia doesn't seem to be gaining momentum.
yv+KAH4AAAAAAAAASW5hY3RpdmUgaGlkZSBkZXRhaWxzIGZvciBBYmkgVmlqYXlhbi0tLTEyLzE0
LzIwMTEgMDk6NTc6NTQgUE0tLS1Gcm9tOiBBYmkgVmlqYXlhbi9SNi9VU0VQQS9VUyBUbzogRXJ p
ayBTbnlkZXIvUjYvVVNFUEEvVVNARVBB Abi Vijayan---12/14/2011 09:57:54 PM---From: Abi
Vijayan/R6/USEPA/US To: Erik Snyder/R6/USEPA/US@EPA
From: Abi Vijayan/R6/USEPA/US
To: Erik Snyder/R6/USEPA/US@EPA
Cc: Lucinda Watson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Carrie
Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA
Date: 12/14/2011 09:57 PM
Subject: Re: Front office's edits to consultation RTC
Thanks, Erik.
(b) (5)
(b) (5)
Abi Vijayan
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6RC-M)
Dallas, TX 75202
Tel: (214) 665-7303
Fax: (214) 665-2182
NOTICE: This communication may contain privileged or otherwise confidential information. If
you are not the intended recipient, or believe you have received this communication in error,
please delete the copy you received, and do not print, copy, re-transmit, disseminate or
otherwise use the information. Thank you.
-----Erik Snyder/R6/USEPA/US wrote: -----
To: Abi Vijayan/R6/USEPA/US@EPA
From: Erik Snyder/R6/USEPA/US
Date: 12/14/2011 09:42PM
Subject: Re: Front office's edits to consultation RTC
The documents did not come through. Looks like they were removed when you
forwarded. Can you send them? Thanks.
I have not been in all the discussions with OGC and OAQPS, but wonder if we can work a
solution.
I think


Thanks,
Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
email: snyder.erik@epa.gov
Pun of the Day - My new theory on inertia doesn't seem to be gaining momentum.
Abi Vijayan---12/14/2011 08:49:40 PM---
From: Abi Vijayan/R6/USEPA/US
To: Suzanne Smith/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA, J effrey
Robinson/R6/USEPA/US@EPA
Date: 12/14/2011 08:49 PM
Subject: Front office's edits to consultation RTC

(b) (5)
(b) (5)
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege



Abi Vijayan
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6RC-M)
Dallas, TX 75202
Tel: (214) 665-7303
Fax: (214) 665-2182
NOTICE: This communication may contain privileged or otherwise confidential
information. If you are not the intended recipient, or believe you have received this
communication in error, please delete the copy you received, and do not print, copy, re-
transmit, disseminate or otherwise use the information. Thank you.
-----Chrissy Mann/R6/USEPA/US wrote: -----
To: Suzanne Smith/R6/USEPA/US@EPA
From: Chrissy Mann/R6/USEPA/US
Date: 12/14/2011 07:59PM
Cc: Al Armendariz/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Carrie
Paige/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Layla
Mansuri/R6/USEPA/US@EPA, Murray.Suzanne@epamail.epa.gov, Thomas
Diggs/R6/USEPA/US@EPA, Vijayan.Abi@epamail.epa.gov
Subject: Re: TX I-SIP
I spoke with Al


Let me know what you think.
Chrissy Mann
Special Assistant to the Regional Administrator
EPA Region 6
214-665-7295
mann.chrissy@epa.gov
(b) (5)
(b) (5)
From: Suzanne Smith/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Chrissy Mann/R6/USEPA/US@EPA, Layla Mansuri/R6/USEPA/US@EPA
Cc: Murray.Suzanne@epamail.epa.gov, Carl Edlund/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Vijayan.Abi@epamail.epa gov
Date: 12/13/2011 03:46 PM
Subject: TX I -SIP
DELIBERATIVE
Al-
Attached please find the draft TX Infrastructure SIP (named TX draft 12-13 sans
BACT sans SSO hilite) as of today. This draft does not include
comments/responses to single source ozone modeling, BACT, or PM 2.5 at this
time.
[attachment "TX draft 12-13 sans BACT sans SSO hilite.docx" deleted by Chrissy
Mann/R6/USEPA/US]
1. As a preliminary matter, we would like to hear your thoughts on some of our
potential responses. The first is if you are comfortable with the direction we are
taking with respect to the manner in which we are handling implementation as it
relates to the I-SIP.



[attachment "TX i-SIP Consultation RTC 12.12 clean.docx" deleted by Chrissy
Mann/R6/USEPA/US] [attachment "TX 1-SIP alt consult 12.13.docx" deleted by
Chrissy Mann/R6/USEPA/US]
3. I'm also attaching draft language on PM2.5 comments/ responses. It is near
completion of the vetting process with OGC and OAQPS so this can give you an
idea of the direction of the response.
[attachment "DRAFT insert for TX RTC NSRPSD issue GW 12 1 11 +slhcmts.ss+bld
12 11 11.docx" deleted by Chrissy Mann/R6/USEPA/US]
Thank you!!!
Suzanne J . Smith
Chief, Multimedia Counseling Branch
Office of Regional Counsel
214-665-8027
[attachment "TX 1-SIP alt consult 12.13.CM.docx" removed by Abi Vijayan/R6/USEPA/US]
[attachment "TX i-SIP Consultation RTC 12.12 clean. CM. docx.docx" removed by Abi
Vijayan/R6/USEPA/US][attachment "TX i-SIP Consultation RTC 12.12 clean. CM.
docx.docx" deleted by Erik Snyder/R6/USEPA/US] [attachment "TX 1-SIP alt consult
12.13.CM.docx" deleted by Erik Snyder/R6/USEPA/US]
[attachment "TX i-SIP Consultation RTC 12.15 minimum.docx" removed by Anna
Wood/RTP/USEPA/US]
From: J effrey Robinson
To: Carl Edlund
Cc: David Gray; Al Armendariz; Carl Edlund; Suzanne Murray; Thomas Diggs
Subject: Re: Fw: Louisiana Emission Fee Petition
Date: 12/14/2011 10:30 AM
As time allows, we'll move forward to get our audit questions out in J anuary to
LDEQ. However, I've had to move Brad Toups to the San J uan Generating Title V
petition with Chad's departure......the Title V petition has to be signed by the
Administrator by Feb. 16, so we'll not be able to begin the audit until later half of
Feb and into March 2012. Do we want to wait until this is controlled to send a
letter to EIP on the Louisiana Fees?
Carl Edlund---12/14/2011 10:23:00 AM---Thanks David. In September we sent
Peggy Hatch a letter stating that we would do a Title V fee aud
From: Carl Edlund/R6/USEPA/US
To: David Gray/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, "Carl Edlund"
<edlund.carl@epa.gov>, Suzanne Murray/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, robinson.jeffrey@epa.gov
Date: 12/14/2011 10:23 AM
Subject: Re: Fw: Louisiana Emission Fee Petition
Thanks David. In September we sent Peggy Hatch a letter stating that
we would do a Title V fee audit in the spring of 2012.

From: David Gray/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US, Suzanne Murray/R6/USEPA/US, "Carl Edlund"
<edlund.carl@epa.gov>
Date: 12/14/2011 09:37 AM
Subject: Fw: Louisiana Emission Fee Petition
FYI
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
(b) (5)
Sent from Blackberry
From: Sparsh Khandeshi [skhandeshi@environmentalintegrity.org]
Sent: 12/14/2011 10:34 AM EST
To: LisaP Jackson
Cc: David Gray; "DEQ-WWWOfficeoftheSecretaryContact@la.gov" <DEQ-
WWWOfficeoftheSecretaryContact@la.gov>; OIG WEBCOMMENTS
Subject: Louisiana Emission Fee Petition
Administrator Jackson and Regional Administrator Armendariz,

The Louisiana Bucket Brigade and the Environmental Integrity Project
respectfully submit this petition requesting EPA to review Louisianas Clean
Air Act title V program. As described in our petition Louisiana does not
collect sufficient emission fees to properly implement the title V program.
Specifically, the lack of funding is hampering the States ability to issue
permits, monitor the compliance status of major sources, and perform its
enforcement responsibilities effectively. For these reasons, our petition is
requesting EPA to issue Louisiana a Notice of Deficiency and take any other
steps necessary.

If you have any questions about the attached petition please contact me.


Respectfully,
Sparsh Khandeshi
Attorney
Environmental Integrity Project
1 Thomas Circle, NW
Suite 900
Washington, DC 20005
Phone: 202.263.4446
Fax: 202.296.8822

[attachment "Louisiana Emission Fee Petition Final Signed.pdf" deleted
by J effrey Robinson/R6/USEPA/US]
From: Carl Edlund
To: Al Armendariz
Cc: David Gray; Edlund, CN=Thomas Diggs/OU=R6/O=USEPA/C=US@EPA, murray.suzanne@epa.gov, ,
Subject: Re: OK Haze
Date: 12/13/2011 07:44 PM
FYI In addition to Steve Thompson, I left voice mail messages with both J ohn
Horning and J eremy Nichols of Wild Earth Guardians
Al Armendariz---12/13/2011 06:54:46 PM---Please get started. I was not terribly
successful.
From: Al Armendariz/R6/USEPA/US
To: David Gray/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA
Cc: "Edlund, Carl" <edlund.carl@epa.gov>
Date: 12/13/2011 06:54 PM
Subject: Re: OK Haze
Please get started.
I was not terribly successful.
Left voice messages with 2 people from Inhofe's office, 2 from Coburn,
and no answer for env second gary sherrer.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
David Gray
----- Original Message -----
From: David Gray
Sent: 12/13/2011 07:43 PM EST
To: Carl Edlund
Cc: Al Armendariz; "Carl Edlund" <edlund.carl@epa.gov>
Subject: Re: OK Haze
Good. Let's wait on Al.
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
Carl Edlund
----- Original Message -----
From: Carl Edlund
Sent: 12/13/2011 06:42 PM CST
To: David Gray
Cc: Al Armendariz; "Carl Edlund" <edlund.carl@epa.gov>
Subject: Re: OK Haze
I'm ready to do my list whenever the high sign is given
David Gray---12/13/2011 06:31:41 PM---No problem. I haven't heard from Carl
yet. If not, I will pick up his list. David Gray
From: David Gray/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, "Carl Edlund"
<edlund.carl@epa.gov>
Date: 12/13/2011 06:31 PM
Subject: Re: OK Haze
No problem. I haven't heard from Carl yet. If not, I will pick up his list.
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 12/13/2011 07:27 PM EST
To: David Gray; "Edlund, Carl" <edlund.carl@epa.gov>
Subject: Re: OK Haze
Will do. I'm going to need about about 15 minutes.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
David Gray
----- Original Message -----
From: David Gray
Sent: 12/13/2011 07:20 PM EST
To: Al Armendariz; "Carl Edlund" <edlund.carl@epa.gov>
Subject: Re: OK Haze
Please confirm when you are done so we know status.
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 12/13/2011 07:15 PM EST
To: David Gray; "Edlund, Carl" <edlund.carl@epa.gov>
Subject: Re: OK Haze
Yes. Starting when exactly?
Now?

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
David Gray
----- Original Message -----
From: David Gray
Sent: 12/13/2011 07:03 PM EST
To: Al Armendariz; "Carl Edlund" <edlund.carl@epa.gov>
Subject: Re: OK Haze
Great. The FIP is signed.
Let's plan for Al to contact Senators offices and Secr Sherrer.
Carl - if you could handle Director Thompson and WildEarth Guardians
rep.
I can handle the Congressmans offices.
The comm plan has contacts. Phone calls with a follow up email if
needed. We will share documents tomorrow early.
Okay?
David
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 12/13/2011 05:30 PM EST
To: David Gray; "Edlund, Carl" <edlund.carl@epa.gov>
Subject: Re: OK Haze
Yes. Available, but away from office on a BB.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
David Gray
----- Original Message -----
From: David Gray
Sent: 12/13/2011 05:28 PM EST
To: Al Armendariz; "Carl Edlund" <edlund.carl@epa.gov>
Subject: OK Haze
We should have signature later tonight. We will plan pre-notifications
around 6:30 to 7 pm our time.
Will either of you be available?
David
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: David Gray
To: Al Armendariz; Carl Edlund
Subject: Re: OK Haze
Date: 12/13/2011 06:17 PM
Yes. Everyone is good to go. I will wait a few on Cong to give you all a
head start.
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 12/13/2011 07:15 PM EST
To: David Gray; "Edlund, Carl" <edlund.carl@epa.gov>
Subject: Re: OK Haze
Yes. Starting when exactly?
Now?

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
David Gray
----- Original Message -----
From: David Gray
Sent: 12/13/2011 07:03 PM EST
To: Al Armendariz; "Carl Edlund" <edlund.carl@epa.gov>
Subject: Re: OK Haze
Great. The FIP is signed.
Let's plan for Al to contact Senators offices and Secr Sherrer.
Carl - if you could handle Director Thompson and WildEarth Guardians
rep.
I can handle the Congressmans offices.
The comm plan has contacts. Phone calls with a follow up email if
needed. We will share documents tomorrow early.
Okay?
David
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 12/13/2011 05:30 PM EST
To: David Gray; "Edlund, Carl" <edlund.carl@epa.gov>
Subject: Re: OK Haze
Yes. Available, but away from office on a BB.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
David Gray
----- Original Message -----
From: David Gray
Sent: 12/13/2011 05:28 PM EST
To: Al Armendariz; "Carl Edlund" <edlund.carl@epa.gov>
Subject: OK Haze
We should have signature later tonight. We will plan pre-notifications
around 6:30 to 7 pm our time.
Will either of you be available?
David
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: David Gray
To: Al Armendariz
Subject: Re: OK Haze
Date: 12/13/2011 06:16 PM
Yes. You are good to go.
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 12/13/2011 07:15 PM EST
To: David Gray; "Edlund, Carl" <edlund.carl@epa.gov>
Subject: Re: OK Haze
Yes. Starting when exactly?
Now?

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
David Gray
----- Original Message -----
From: David Gray
Sent: 12/13/2011 07:03 PM EST
To: Al Armendariz; "Carl Edlund" <edlund.carl@epa.gov>
Subject: Re: OK Haze
Great. The FIP is signed.
Let's plan for Al to contact Senators offices and Secr Sherrer.
Carl - if you could handle Director Thompson and WildEarth Guardians
rep.
I can handle the Congressmans offices.
The comm plan has contacts. Phone calls with a follow up email if
needed. We will share documents tomorrow early.
Okay?
David
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 12/13/2011 05:30 PM EST
To: David Gray; "Edlund, Carl" <edlund.carl@epa.gov>
Subject: Re: OK Haze
Yes. Available, but away from office on a BB.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
David Gray
----- Original Message -----
From: David Gray
Sent: 12/13/2011 05:28 PM EST
To: Al Armendariz; "Carl Edlund" <edlund.carl@epa.gov>
Subject: OK Haze
We should have signature later tonight. We will plan pre-notifications
around 6:30 to 7 pm our time.
Will either of you be available?
David
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: David Gray
To:
Bcc: Al Armendariz
Subject: Region 6 Weekly Report December 12, 2011 (contains predecision information)
Date: 12/13/2011 08:12 AM
PREDECISION INFORMATION
Region 6 Weekly Report December 12, 2011
[December 12 to December 26]
Contact: David Gray, 214-665-2200
POTENTIAL OR EXPECTED PRESS STORIES, SIGNIFICANT POLICY,
REGULATORY, OR LEGAL ACTIONS:
Oklahoma Regional Haze FIP
On Tuesday, December 13, under a Consent Decree from WildEarth Guardians, EPA is
scheduled final action on a Federal Implementation Plan (FIP) to limit air emissions that
cause Regional Haze from three coal-burning power plants in Oklahoma. The power plants
facilities are: the Oklahoma Gas and Electric (OG&E) plant near Muskogee, the OG&E
Sooner plant in north central Oklahoma, and the American Electric Power/Public Service
Company of Oklahoma plant northeast of Tulsa. Operators of these oldest coal-fired power
plants will be required to install technology or switch to cleaner burning natural gas to
control sulfur dioxide (SO2) pollution within the next five years.
Texas Infrastructure SIP
On Friday, December 16, EPA, under Consent Decree, is scheduled to complete final action
for the Texas' Clean Air Act 110(a)(2) Infrastructure submission for the 1997 ozone and PM
2.5 National Ambient Air Quality Standards (NAAQS). EPA is scheduled to partially
approve and partially disapprove submittals from the state of Texas pursuant to the Clean Air
Act (CAA or Act) that address the infrastructure elements specified in the CAA section
110(a)(2), necessary to implement, maintain, and enforce the 1997 8-hour ozone and 1997
and 2006 fine particulate matter (PM2.5) national ambient air quality standards (NAAQS or
standards).
Oklahoma Transport Infrastructure SIP
On Friday, December 16, EPA, under Consent Decree, is scheduled to propose approval of a
finding for the 1997 and 2006 PM standard that the state of Oklahoma will not contribute to
attainment and maintenance of the PM standard in downwind states. EPA will also offer two
alternative proposals. One is a proposed disapproval for the Ozone standard due to the
proposed finding of contribution under the CSAPR and the alternative a proposed approval if
the CSAPR supplemental rule for Oklahoma is not finalized.
GRANT ANNOUNCEMENTS:
None
LEGISLATIVE ENGAGEMENT:
None
TRAVEL/PUBLIC MEETINGS/SPEAKING ENGAGEMENTS FOR THE ASSISTANT
ADMINISTRATORS, OR REGIONAL ADMINISTRATORS:
GSA Sustainability Roundtable
On Wednesday, December 14, RA Al Armendariz will participate in a roundtable discussing
sustainability with officials from GSA at the Fort Worth Museum of Science and History.
Stephen Leeds, Senior Counselor to the Administrator of GSA and Senior Sustainability
Officer, and JD Salinas, Greater Southwest Regional Administrator of GSA, will be
participating. The focus of the roundtable is for government, local community leaders and
organizations to share ideas in an open forum.
OTHER INFORMATION:
Public Hearing on EPA Objection to Oklahoma NPDES Permit
On Monday, December 19, EPA will hold a public hearing in Pryor, Oklahoma, regarding its
objection to the Oklahoma Ordnance Works Authority (OOWA) and Solae, LLC combined
wastewater discharge permit, which was drafted by the Oklahoma Department of
Environmental Quality (ODEQ). EPA objected to ODEQ's draft permit on July 25, 2011, for
failing to implement the standard for Carbonaceous Biological Oxygen Demand (CBOD5)
within an appropriate timeframe. Attendance from local residents concerned about potential
impact on jobs is expected. If the issue is not resolved, the permit could fall to EPA for
issuance.
From: Al Armendariz
To: Thomas Diggs; Carl Edlund; Chrissy Mann
Cc: Donaldson, Guy; J oe Kordzi
Subject: Re: Briefing re San J uan Generating Station - in Carl Edlund's conference room on 6th floor
Date: 12/09/2011 08:13 AM
Thanks. I'll be calling in from car

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
Thomas Diggs
----- Original Message -----
From: Thomas Diggs
Sent: 12/09/2011 08:11 AM CST
To: Al Armendariz; Carl Edlund; Chrissy Mann
Cc: Donaldson.Guy@epa.gov; Joe Kordzi
Subject: Briefing re San Juan Generating Station - in Carl Edlund's
conference room on 6th floor
We will take the call in Carl's conference room at 8:15am. The audio call in number
is 866-299-3188 code 202-564-4711.
Tom
Thomas Diggs
Associate Director - Air
US EPA Region 6
214-665-3102
fax 214-665-7263
diggs.thomas@epa.gov
----- Forwarded by Thomas Diggs/R6/USEPA/US on 12/09/2011 08:08 AM -----
From: Phil Lorang/RTP/USEPA/US
To: Anna Wood/RTP/USEPA/US@EPA, Todd Hawes/RTP/USEPA/US@EPA,
Al Armendariz/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Peter
Tsirigotis/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, J oe
Kordzi/R6/USEPA/US@EPA, Lea Anderson/DC/USEPA/US@EPA, J ohnetta
Heilig/RTP/USEPA/US@EPA, Rhea J ones/RTP/USEPA/US@EPA, Martha
Keating/RTP/USEPA/US@EPA
Cc: Colleen McKaughan/R9/USEPA/US@EPA
Date: 12/08/2011 02:47 PM
Subject: Briefing re San J uan Generating Station in prep for tomorrow's
meeting with Bob P
Attached are briefing materials developed by Region 6 (with minor
edits by OAQPS) in prep for tomorrow's meeting with Bob P. Note
that we are anticipating that Region 6 will present these materials at
tomorrow's meeting.
The meeting is at 9:00 - 9:45 am in 5400 ARN, Conf Line: 866 299 3188 Access: 202
564 4711 (Video). San Juan is one of two topics, and in the "call" for the meeting it was listed second,
but I don't know if that is the order that Bob P will want to follow. The formal invitation list was very
short, and I don't know if others are welcome to also be present or call in.
[attachment "Briefing Sheet for Bob P on NM FIP 12-9-11bteditspl.docx" deleted by
Al Armendariz/R6/USEPA/US]
Phil Lorang, Senior Policy Advisor
Air Quality Policy Division, OAQPS, EPA
919-541-5463
From: Phil Lorang
To: Anna Wood; Todd Hawes; Al Armendariz; Carl Edlund; Peter Tsirigotis; Phil Lorang; Guy Donaldson; Thomas
Diggs; J oe Kordzi; Lea Anderson; J ohnetta Heilig; Rhea J ones; Martha Keating
Cc: Colleen McKaughan
Subject: Briefing re San J uan Generating Station in prep for tomorrow's meeting with Bob P
Date: 12/08/2011 02:47 PM
Attachments: Briefing Sheet for Bob P on NM FIP 12-9-11bteditspl.docx
Attached are briefing materials developed by Region 6 (with minor edits by OAQPS)
in prep for tomorrow's meeting with Bob P. Note that we are anticipating that
Region 6 will present these materials at tomorrow's meeting.
The meeting is at 9:00 - 9:45 am in 5400 ARN, Conf Line: 866 299 3188 Access: 202 564 4711 (Video).
San Juan is one of two topics, and in the "call" for the meeting it was listed second, but I don't know if that is the order that
Bob P will want to follow. The formal invitation list was very short, and I don't know if others are welcome to also be
present or call in.
Phil Lorang, Senior Policy Advisor
Air Quality Policy Division, OAQPS, EPA
919-541-5463
(b) (5)
From: Gina Weber
To: David Gray
Cc: Al Armendariz; Chrissy Mann; Layla Mansuri; LaWanda Thomas
Subject: Re: EPA Environmental Play at Dallas Environmental and Science Academy (DESA)
Date: 12/07/2011 11:02 AM
HELLO! We may be able to move the play until J anuary to coincide with Martin
Luther King Day celebration. I will let you know the new date.
Gina Weber
U.S.-Mexico Border and International Coordinator
(214) 665-6787 (office)
(214) 665-7263 (fax)
www.epa.gov/Border2012
Please don't print this e-mail unless you really have to....
David Gray---12/06/2011 04:34:04 PM---Gina, Unfortunately, Al has a briefing
with Deputy Adm Bob Perciasepe on San J uan Generating Station
From: David Gray/R6/USEPA/US
To: Gina Weber/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, "Layla Mansuri"
<Mansuri.Layla@epamail.epa.gov>, Chrissy Mann/R6/USEPA/US@EPA
Date: 12/06/2011 04:34 PM
Subject: Re: EPA Environmental Play at Dallas Environmental and Science
Academy (DESA)
Gina,
Unfortunately, Al has a briefing with Deputy Adm Bob Perciasepe on
San J uan Generating Station at 8:15 am. I don't think he will be able to
make it now that the date has moved to Dec 9. Thanks for thinking of
him.
David
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
Gina Weber
----- Original Message -----
From: Gina Weber
Sent: 11/15/2011 11:11 AM CST
To: David Gray
Cc: Al Armendariz
Subject: EPA Environmental Play at Dallas Environmental and
Science Academy (DESA)
Good morning David! I saw Al at the LDP session a couple of weeks ago, and I
mentioned to him that EPA staff will be performing a short play for students of the
middle school Dallas Environmental Science Academy (DESA). The EPA team will
perform "A Team of Allies" which was previously shown at the Black History Month
Celebration. I asked Al if he would be interested in giving the introduction to the
play, and talk to the middle schoolers about EPA. Al said he would be interested,
and to ask you if he would be available. The play will be held on Tuesday,
December 6, 2011, at 9 am. DESA is in West Dallas about 10 minutes from the
office. School address is 3635 Greenleaf Street, Dallas TX 75212. Let me know if Al
can join us. THANKS!
Gina Weber
U.S.-Mexico Border and International Coordinator
(214) 665-6787 (office)
(214) 665-7263 (fax)
www.epa.gov/Border2012
Please don't print this e-mail unless you really have to....
From: Twitter
Reply To: noreply@postmaster.twitter.com
To: Al Armendariz/R6/USEPA/US@EPA
Subject: J eremy J Nichols (@ClimateWest) is now following you on Twitter!
Date: 12/02/2011 01:21 PM
Twitter
Jeremy J Nichols @ClimateWest is now following you
(@al_armendariz).
ClimateWest Jeremy J Nichols
News, Views, and the Latest on
Tackling Climate Change in the
American West from the Climate
and Energy Program Director for
WildEarth Guardians.
American West
121
Tweets
230
Following
66
Followers
You follow a user who follows @ClimateWest:
@Interior
View @ClimateWests profile
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From: Carl Edlund
To: Al Armendariz
Subject: Fw: Backgrounder in prep for J anet's meeting with PMN Resources tomorrow
Date: 11/30/2011 02:11 PM
Attachments: PMN meeting background 11 30 11.docx
Directions.doc
Al...is this one of your meetings tomorrow??????
Sent by EPA Wireless E-Mail Services
Guy Donaldson
----- Original Message -----
From: Guy Donaldson
Sent: 11/30/2011 07:49 AM CST
To: Phil Lorang
Cc: Thomas Diggs; Carl Edlund
Subject: Fw: Backgrounder in prep for Janet's meeting with PMN Resources tomorrow
I guess I shouldn't complain about Region 6 being left out given how crazy busy everyone is down here right now but it is
trouble some. Please let us know how it goes.

----- Forwarded by Guy Donaldson/R6/USEPA/US on 11/30/2011 07:44 AM -----
From: Phil Lorang/RTP/USEPA/US
To: Rhea J ones/RTP/USEPA/US@EPA, J ohnetta Heilig/RTP/USEPA/US@EPA, Lea Anderson/DC/USEPA/US@EPA, Martha
Keating/RTP/USEPA/US@EPA, Todd Hawes/RTP/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA
Date: 11/29/2011 04:06 PM
Subject: Backgrounder in prep for J anet's meeting with PMN Resources tomorrow
Tom and Guy - we were not asked to provide any Region 6 names to be included in this meeting, but you should be
aware of it. One of us will tell you if anything interesting happens.
Phil Lorang, Senior Policy Advisor
Air Quality Policy Division, OAQPS, EPA
919-541-5463
----- Forwarded by Phil Lorang/RTP/USEPA/US on 11/29/2011 05:02 PM -----
From: Peter South/RTP/USEPA/US
To: Carlos Alfaro/DC/USEPA/US@EPA, Don Zinger/DC/USEPA/US@EPA, J ean Walker/RTP/USEPA/US@EPA, J oseph-J
Dougherty/DC/USEPA/US@EPA, Mary Henigin/DC/USEPA/US@EPA, Crystal Edwards/DC/USEPA/US@EPA, Peter
South/RTP/USEPA/US@EPA, Maria Sanders/RTP/USEPA/US@EPA, Alan Rush/DC/USEPA/US@EPA, Cindy
Huang/DC/USEPA/US@EPA, Addie J ohnson/DC/USEPA/US@EPA, Kirsten King/DC/USEPA/US@EPA, Kristina
Friedman/DC/USEPA/US@EPA, Gregory Green/RTP/USEPA/US@EPA, Lala Alston/RTP/USEPA/US@EPA, J effrey
Clark/RTP/USEPA/US@EPA
Cc: Phil Lorang/RTP/USEPA/US@EPA, J ohnetta Heilig/RTP/USEPA/US@EPA
Date: 11/29/2011 04:55 PM
Subject: Fw: Meet w/Pat Collawn & J eanette Pablo - PNM Resources
I have attached a two-page backgrounder in prep for J anet's meeting with PMN Resources tomorrow. Please
note that these materials have been developed as background for J anet--they should not be distributed in
the meeting room.
Thanks and call me with any questions.
Pete South
Office of Air Quality Planning and Standards/IO
Office of Air and Radiation
U.S. EPA
Phone: 919 541-5359
Cell:
----- Forwarded by Peter South/RTP/USEPA/US on 11/29/2011 04:40 PM -----
Meet w/Pat Collawn & Jeanette Pablo - PNM Resources
(b) (5)
(b) (5)
Wed
11/30/2011 12:30
PM - 1:00 PM
/P86AAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAUAAAAAAAAAAQAAAAAAAAAAAAAAAAAA
AA==
Janet McCabe
Chair: Bob
Perciasepe/DC/USEPA/US
Sent By: Teri
Porterfield/DC/USEPA/US
Location: 1200 Pennsylvania Avenue, NW Room - 3412 ARN
/P86AAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAEAAAACAAAAAQAAAAAAAAAAAAAAAAAA AA==
Gina McCarthy/DC/USEPA/US@EPA, Janet McCabe/DC/USEPA/US@EPA, Laura Vaught/DC/USEPA/US@EPA, Steve Page/RTP/USEPA/US@EPA
Hi Teri
Great talking to you this morning! I am confirming by this email that Pat Collawn, CEO of PNM Resources, and I will be meeting
with Deputy Administrator Bob Perciasepe on Wednesday, November 30 at 12:30 - 1 pm.
If anyone else will be joining us at the meeting, I will let you know in advance. I'll also provide a bio for Ms. Collawn.
Let me know if you need anything else.
Regards,
Jeanette
Jeanette Pablo
Federal Affairs Consultant for PNM Resources
Navitas Strategies
5505 Connecticut Avenue, NW
#216
Washington, DC 20015
Jeanette.Pablo@PNMResources.com
202.468.9688 (cell)
202.318.1284 (fax)
Re: Request for Meeting with EPA Deputy Administrator Perciasepe by Pat Collawn, PNM Resources CEO
Elizabeth
Ashwell
to: Pablo, J eanette, Teri Porterfield
10/31/2011
03:49 PM
Cc: "Edwards, Cindy", Laura Vaught
Hi J eanette-
I've copied Teri Porterfield from Deputy Administrator Perciasepe's office. She's your best point of contact to try to
arrange a meeting with him.
Best-
EA
Elizabeth Ashwell
Director of Scheduling & Advance
Office of the Administrator | US EPA
Phone: 202-564-1008
"Pablo, J eanette" ---10/31/2011 03:12:01 PM---Hi Elizabeth Would it be possible to schedule a meeting with Deputy
Administrator
From: "Pablo, J eanette" <jeanette.pablo@pnmresources.com>
To: Elizabeth Ashwell/DC/USEPA/US@EPA
Cc: Laura Vaught/DC/USEPA/US@EPA, "Edwards, Cindy" <Cindy.Edwards@pnmresources.com>, "Pablo, J eanette" <jeanette.pablo@pnmresources.com>
Date: 10/31/2011 03:12 PM
Subject: Request for Meeting with EPA Deputy Administrator Perciasepe by Pat Collawn, PNM Resources CEO
Hi Elizabeth
Would it be possible to schedule a meeting with Deputy Administrator
Perciasepe on the afternoon of November 29 or the morning of November 30
with Pat Collawn, CEO, PNM Resources?
Thanks for all your help.
Sincerely,
Jeanette
Jeanette Pablo
Federal Affairs Consultant for PNM Resources
Navitas Strategies
5505 Connectticut Avenue NW
Number 216
Washington, DC 20015
202.468.9688 T
202.318.1284 F
jeanette.pablo@pnmresources.com
-----Original Message-----
From: Ashwell.Elizabeth@epamail.epa.gov
[mailto:Ashwell.Elizabeth@epamail.epa.gov]
Sent: Thursday, September 22, 2011 12:33 PM
To: Pablo, Jeanette
Cc: Vaught.Laura@epamail.epa.gov
Subject: Re: Request for Meeting with EPA Administrator Lisa Jackson by
Pat Collawn, PNM Resources CEO
Hi Jeanette-
I apologize in the delay in following up on your request for a meeting
with EPA and Ms. Collawn. Our recommendation is that the Ms. Collawn
meet with Deputy Administrator Perciasepe, please advise her
availability to meet, or if a call is a better option if she's not
scheduled to be in DC.
Thank you-
EA
Elizabeth Ashwell
Director of Scheduling & Advance
Office of the Administrator | US EPA
Phone: 202-564-1008
From: "Pablo, Jeanette" <jeanette.pablo@pnmresources.com>
To: Elizabeth Ashwell/DC/USEPA/US@EPA
Cc: "Wolff, Brian" <BWolff@eei.org>, Laura
Vaught/DC/USEPA/US@EPA, "C'Debaca, Ernest"
<Ernest.CDebaca@pnmresources.com>
Date: 09/12/2011 09:15 PM
Subject: Request for Meeting with EPA Administrator Lisa Jackson
by
Pat Collawn, PNM Resources CEO
Hi Elizabeth
On behalf of Pat Collawn, CEO of PNM Resources, I wish to request a
meeting with EPA Administrator Lisa Jackson to discuss the Regional Haze
State Implementation Plan for New Mexico which impacts the San Juan
Generating Station, which we operate.
I will call you tomorrow to see what additional information you may
need.
Sincerely,
Jeanette
Jeanette Pablo
Federal Affairs Consultant
PNM Resources
5505 Connecticut Avenue, NW
#216
Washington, DC 20015
Jeanette.Pablo@PNMResources.com
202.468.9688 (cell)
202.318.1284 (fax)
From: Carl Edlund
To: murray.suzanne@epa.gov; armendariz.al@epa.gov; Suzanne Smith
Cc: Layla Mansuri; gray.david@epa.gov; Chrissy Mann; Thomas Diggs; Guy Donaldson
Subject: Fw: Weekly update on Regional Haze developments and upcoming actions (as of 11/18 with some update on
11/28)
Date: 11/28/2011 12:37 PM
Attachments: OK Briefing Sheet-Administrator.docx
Regional Haze Action Dates with internal-only comments 11 18 2011.docx
Regional Haze CD Action Dates November 18 2011.docx
FYI ..I didn't see you in the address line and thought that you'd be interested in a
summary of Haze SIP/FIP rules in play.
----- Forwarded by Carl Edlund/R6/USEPA/US on 11/28/2011 12:30 PM -----
From: Jeff Whitlow/RTP/USEPA/US
To: Air Division Directors and Deputies
Date: 11/28/2011 08:20 AM
Subject: Weekly update on Regional Haze developments and upcoming actions (as of 11/18 with some update on 11/28)
Regional Haze developments and upcoming actions
Disclaimer: This summary should not be relied upon as the sole source of information on any items
that may be controversial, still under deliberation, or especially complex. Please contact Rhea Jones or
Phil Lorang in OAQPS or the responsible ADD or APM in the involved Region to get the latest and
most complete information. Please report significant errors in information to Phil Lorang. Please do not
circulate this widely and do not circulate at all outside EPA.
Recent general developments
NPCA et al . Consent Decree - The draft CD was announced publicly on November 9 and
posted on the OAQPS Regional Haze webpage. It has not been announced in the FR yet. The
end of the comment period and final filing will be Dec. 20 or even later. This means that the final
version will not list the Dec. 13 and Dec. 15 deadlines for several actions.
CSAPR Better-than-BART Rule - The TSD including the analysis that shows that the proposed
increases in emissions budgets for Texas and several other states will not impact the outcome
of the "better than BART" test has been provided to OMB and distributed to the other agencies
reviewing the rule. These agencies have been asked to forward any clarifying questions
immediately and to provide comments to OMB by Nov. 29. We are hoping to have the proposed
rule signed in December.
Recent state-specific developments (in alphabetical order)
Arkansas - The date for final action was extended 60 days to Feb. 14, 2012. Arkansas was
proposed for partial disapproval; final disapproval will start a 2-year FIP clock.
Colorado - Region 8 is investigating the possibility of using a one-state "better-than-BART"
approach for approving the Colorado SIP. The issue is that the SIP did not adopt BART-level
control at one unit of one power plant.
DC- The proposed approval, due on November 15, has been signed.
Maine- The proposed approval, due on November 15, has been signed.
Minnesota - Region 5 has contacted OAQPS to begin the decision process regarding how to
handle the Sherco power plant. DOI has certified that this plant makes a Reasonably
Attributable Visibility Impact (RAVI) on a Class I area, the first such certification ever. An old
provision in the Visibility Protection Rule means that this finding triggers an obligation on the
state to apply BART to the plant. The state has not applied BART and does not want to. The
state will be relying on CSAPR to satisfy its regular BART obligation
Nebraska -
Nevada - Region 9 proposed to fully approve the SIP on June 9,
OGC has made an initial contact with NPCA about the possibility that we will request an
extension for this part of the action now scheduled for Dec. 13.
New Mexico -- Public Service of New Mexico has asked about EPA's interest in a possible
settlement of its lawsuit. We expect a motion to stay the FIP. Janet McCabe met on November
15 with officials from M-S-R Public Power Agency in California, partial owners of the San Juan
Generating Station.
North Dakota - No news.
Oklahoma - Signature on the final action is needed by December 13. Region 6 has provided the
attached 3-pager that includes information on how Region 6 is responding to specific comments
about costs.
South Dakota -- Under the draft consent decree with NPCA, the proposal for action on the SIP
is to be signed by November 29. Work on the notice to propose full approval continued over
the holiday weekend.
Texas - OAQPS will be setting up a briefing with Janet McCabe soon to get guidance on the
approach for Texas, so Region 6 can plan its technical work accordingly.
Washington State - Region 10 is going to give an update for OAQPS staff on November 29 on
the sources it plans to address in its new technical analysis to fill gaps in the SIP's analysis and
the possible outcomes of that analysis.
Action Dates

November 29, 2011 - proposed approval of RH SIP for South Dakota (negotiated NPCA deadline)
TBD (no specific deadline) - proposed action on RH SIP for Kentucky (final due March 15, 2012 under
(b) (5)
(b) (5)
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
KEF CD)
December 13, 2011 - final action on all parts of Nevada's RH SIP. See the status report above. (
negotiated NPCA deadline, recently extended)
December 13, 2011 - (WEG deadline for
transport SIP, extended)
December 15, 2011 - final approval of the RH SIP for New Jersey (negotiated NPCA deadline)
December 15, 2011 - final action on the RH SIP for Kansas. Approval has been proposed, but there
were adverse public comments disputing the adequacy of some of the analyses.

January 17, 2012 - proposed actions for Illinois, Indiana, Minnesota, New York, Ohio, Pennsylvania,
and Virginia. The
proposed findings and FIP actions for EGU BART for these states are contained in the CSAPR Better-
than-BART proposal. (negotiated NPCA deadline)
January 20, 2012 - proposed action on Montana.
. (WEG deadline)
February 9, 2012 - final FIP action in North Dakota. (WEG deadline)
February 14, 2102 - final action on Arkansas' RH SIP. The very recent proposal was a partial approval
and a partial disapproval because of (1) inadequate analysis of reasonable progress and (2) inadequate
analysis of BART for 9 sources.
Region 6 hopes to get an approvable new SIP submission.
(negotiated NPCA deadline)
February 15, 2012 - proposed actions for Alabama, Alaska (all BART elements),
Albuquerque/Bernalillio County, Georgia, Iowa, Louisiana, Maryland, Mississippi, Missouri, Nebraska,
New Hampshire, New Mexico (all remaining RH SIP elements), North Carolina, Rhode Island, South
Carolina, Vermont, Wisconsin.
The proposed findings and FIP actions for EGU BART for these
states are contained in the CSAPR Better-than-BART proposal. (negotiated NPCA deadline)
Files for Reference
Attached is a fully updated edition of our master list of dates from all the settlements combined, sorted
in order of final action date. One version has internal-only comments included, and the other lists only
the dates. The file names have been changed to better indicate the contents to avoid mix-ups.
Changes have been made since the last version to correct some errors and to incorporate the
developments listed above when relevant for this type of summary.
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
Jeff Whitlow
Office of Air Quality Planning and Standards
Office of Air and Radiation
US Environmental Protection Agency
p: 919.541.5523
From: Gina McCarthy
To: Al Armendariz
Cc: Bob Perciasepe; Brendan Gilfillan; David Bloomgren; Ganesan, Arvin; J oseph Goffman; Oster, Seth; Sussman,
Bob; Windsor, Richard; Woodka, J anet
Subject: Re: Fluor to Provide Construction Services for Luminants Environmental Retrofit Program Nov 1 2011 |
Nachricht | finanzen.net
Date: 11/01/2011 03:31 PM
Al Armendariz---11/01/2011 01:28:29
From: Al Armendariz/R6/USEPA/US
To: "McCarthy, Gina" <McCarthy.Gina@epamail.epa.gov>
Cc: "Windsor, Richard" <windsor.richard@epa.gov>, Bob
Perciasepe/DC/USEPA/US, "Oster, Seth" <Oster.Seth@epamail.epa.gov>,
Brendan Gilfillan/DC/USEPA/US@EPA, "Ganesan, Arvin"
<Ganesan.Arvin@epamail.epa.gov>, "Woodka, J anet"
<woodka.janet@epa.gov>, "Sussman, Bob" <sussman.bob@epa.gov>,
David Bloomgren/DC/USEPA/US, J oseph Goffman/DC/USEPA/US
Date: 11/01/2011 01:28 PM
Subject: Fluor to Provide Construction Services for Luminants
Environmental Retrofit Program Nov 1 2011 | Nachricht | finanzen.net
:)
Al
Fluor to Provide Construction Services for Luminants Environmental
Retrofit Program
Fluor Corporation (NYSE: FLR) announced today that it was awarded a
multi-year special projects supplement to their existing contract to
provide construction and other support services for Luminants
environmental retrofit program. Luminant is a subsidiary of Energy
Future Holdings Corp. The undisclosed contract value was booked in
the companys third quarter.
Fluor will supply management, supervision and craft personnel to
support construction services and environmental retrofits to Luminants
current coal-fired power plant units. Fluor began providing ongoing
maintenance and modification services at four of Luminants power
units in 1984 and has since grown the relationship to cover all of the
companys fossil power generating units and equipment repair center.
During this time, Fluor has successfully executed multiple major capital
projects including the recently completed Oak Grove Units 1 & 2 clean
coal project and the balance-of-plant construction for Luminants
Sandow 5 Selective Catalytic Reduction project.
"Fluor is extremely well positioned to support our customers and
partners who must retrofit their generating fleets to comply with the
(b) (5)
(b) (6)
(b) (5)
requirements of the cross-state air pollution rule (CSAPR) and the
electric generating unit maximum achievable control technology (EGU
MACT) standards, said Dave Dunning, president of Fluors Power
Group. "Fluors scope extension of its ongoing maintenance and
services contract with Luminant fits our strategy to assist a valued
partner with their environmental compliance needs.
"This new work is a natural outgrowth of Fluors more than 25 years of
providing Luminant with high value maintenance and construction
services throughout its power generation fleet in Texas, said Rick
Graves, senior vice president of Fluors Power Group. "Assisting power
clients in providing clean energy to their customers is within our sweet
spot, and we are pleased that Luminant has placed its confidence in us
to deliver value-added solutions for this important environmental
retrofit program.
Luminant is a competitive power generation business including mining,
wholesale marketing and trading, and development operations. With a
total of 15,400 megawatts of generation in Texas, 2,300 megawatts
are fueled by nuclear power and 8,000 megawatts fueled by coal. The
company is also the largest purchaser of wind-generated electricity in
Texas and fifth largest in the United States.
About Fluor Corporation
Fluor Corporation (NYSE: FLR) designs, builds and maintains many of
the world's most challenging and complex projects. Through its global
network of offices on six continents, the company provides
comprehensive capabilities and world-class expertise in the fields of
engineering, procurement, construction, commissioning, operations,
maintenance and project management. Headquartered in Irving, Texas,
Fluor is a FORTUNE 200 company and had revenue of $20.8 billion in
2010. For more information, visit www.fluor.com.
http://www.finanzen.net/nachricht/Fluor-to-Provide-Construction-
Services-for-Luminant-s-Environmental-Retrofit-Program-1448796

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: Richard Windsor
To: Al Armendariz
Cc: Gina McCarthy
Subject: Re: Fluor to Provide Construction Services for Luminants Environmental Retrofit Program Nov 1 2011 |
Nachricht | finanzen.net
Date: 11/01/2011 01:16 PM
Importance: High
tx for the article Al. good thing you sent it .
Al Armendariz---11/01/2011 01:28:29 PM---Gina:
From: Al Armendariz/R6/USEPA/US
To: "McCarthy, Gina" <McCarthy.Gina@epamail.epa.gov>
Cc: "Windsor, Richard" <windsor.richard@epa.gov>, Bob
Perciasepe/DC/USEPA/US, "Oster, Seth" <Oster.Seth@epamail.epa.gov>,
Brendan Gilfillan/DC/USEPA/US@EPA, "Ganesan, Arvin"
<Ganesan.Arvin@epamail.epa.gov>, "Woodka, J anet"
<woodka.janet@epa.gov>, "Sussman, Bob" <sussman.bob@epa.gov>,
David Bloomgren/DC/USEPA/US, J oseph Goffman/DC/USEPA/US
Date: 11/01/2011 01:28 PM
Subject: Fluor to Provide Construction Services for Luminants
Environmental Retrofit Program Nov 1 2011 | Nachricht | finanzen.net
:)
Al
Fluor to Provide Construction Services for Luminants Environmental
Retrofit Program
Fluor Corporation (NYSE: FLR) announced today that it was awarded a
multi-year special projects supplement to their existing contract to
provide construction and other support services for Luminants
environmental retrofit program. Luminant is a subsidiary of Energy
Future Holdings Corp. The undisclosed contract value was booked in
the companys third quarter.
Fluor will supply management, supervision and craft personnel to
support construction services and environmental retrofits to Luminants
current coal-fired power plant units. Fluor began providing ongoing
maintenance and modification services at four of Luminants power
units in 1984 and has since grown the relationship to cover all of the
companys fossil power generating units and equipment repair center.
During this time, Fluor has successfully executed multiple major capital
projects including the recently completed Oak Grove Units 1 & 2 clean
coal project and the balance-of-plant construction for Luminants
Sandow 5 Selective Catalytic Reduction project.
"Fluor is extremely well positioned to support our customers and
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
partners who must retrofit their generating fleets to comply with the
requirements of the cross-state air pollution rule (CSAPR) and the
electric generating unit maximum achievable control technology (EGU
MACT) standards, said Dave Dunning, president of Fluors Power
Group. "Fluors scope extension of its ongoing maintenance and
services contract with Luminant fits our strategy to assist a valued
partner with their environmental compliance needs.
"This new work is a natural outgrowth of Fluors more than 25 years of
providing Luminant with high value maintenance and construction
services throughout its power generation fleet in Texas, said Rick
Graves, senior vice president of Fluors Power Group. "Assisting power
clients in providing clean energy to their customers is within our sweet
spot, and we are pleased that Luminant has placed its confidence in us
to deliver value-added solutions for this important environmental
retrofit program.
Luminant is a competitive power generation business including mining,
wholesale marketing and trading, and development operations. With a
total of 15,400 megawatts of generation in Texas, 2,300 megawatts
are fueled by nuclear power and 8,000 megawatts fueled by coal. The
company is also the largest purchaser of wind-generated electricity in
Texas and fifth largest in the United States.
About Fluor Corporation
Fluor Corporation (NYSE: FLR) designs, builds and maintains many of
the world's most challenging and complex projects. Through its global
network of offices on six continents, the company provides
comprehensive capabilities and world-class expertise in the fields of
engineering, procurement, construction, commissioning, operations,
maintenance and project management. Headquartered in Irving, Texas,
Fluor is a FORTUNE 200 company and had revenue of $20.8 billion in
2010. For more information, visit www.fluor.com.
http://www.finanzen.net/nachricht/Fluor-to-Provide-Construction-
Services-for-Luminant-s-Environmental-Retrofit-Program-1448796

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: Al Armendariz
To: edlund.carl@epa.gov; gray.david@epa.gov; murray.suzanne@epa.gov; J ohn Blevins
Cc: taheri.diane@epa.gov; mann.chrissy@epa.gov
Subject: the clean air act in action
Date: 11/01/2011 12:49 PM
nice.
Fluor to Provide Construction Services for Luminants Environmental Retrofit Program
Fluor Corporation (NYSE: FLR) announced today that it was awarded a multi-year
special projects supplement to their existing contract to provide construction and
other support services for Luminants environmental retrofit program. Luminant is a
subsidiary of Energy Future Holdings Corp. The undisclosed contract value was
booked in the companys third quarter.
Fluor will supply management, supervision and craft personnel to support
construction services and environmental retrofits to Luminants current coal-fired
power plant units. Fluor began providing ongoing maintenance and modification
services at four of Luminants power units in 1984 and has since grown the
relationship to cover all of the companys fossil power generating units and
equipment repair center.
During this time, Fluor has successfully executed multiple major capital projects
including the recently completed Oak Grove Units 1 & 2 clean coal project and the
balance-of-plant construction for Luminants Sandow 5 Selective Catalytic Reduction
project.
"Fluor is extremely well positioned to support our customers and partners who must
retrofit their generating fleets to comply with the requirements of the cross-state air
pollution rule (CSAPR) and the electric generating unit maximum achievable control
technology (EGU MACT) standards, said Dave Dunning, president of Fluors Power
Group. "Fluors scope extension of its ongoing maintenance and services contract
with Luminant fits our strategy to assist a valued partner with their environmental
compliance needs.
"This new work is a natural outgrowth of Fluors more than 25 years of providing
Luminant with high value maintenance and construction services throughout its
power generation fleet in Texas, said Rick Graves, senior vice president of Fluors
Power Group. "Assisting power clients in providing clean energy to their customers is
within our sweet spot, and we are pleased that Luminant has placed its confidence
in us to deliver value-added solutions for this important environmental retrofit
program.
Luminant is a competitive power generation business including mining, wholesale
marketing and trading, and development operations. With a total of 15,400
megawatts of generation in Texas, 2,300 megawatts are fueled by nuclear power
and 8,000 megawatts fueled by coal. The company is also the largest purchaser of
wind-generated electricity in Texas and fifth largest in the United States.
About Fluor Corporation
Fluor Corporation (NYSE: FLR) designs, builds and maintains many of the world's
most challenging and complex projects. Through its global network of offices on six
continents, the company provides comprehensive capabilities and world-class
expertise in the fields of engineering, procurement, construction, commissioning,
operations, maintenance and project management. Headquartered in Irving, Texas,
Fluor is a FORTUNE 200 company and had revenue of $20.8 billion in 2010. For
more information, visit www.fluor.com.
http://www.finanzen.net/nachricht/Fluor-to-Provide-Construction-Services-for-
Luminant-s-Environmental-Retrofit-Program-1448796
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
From: Brian Fontenot
To: Al Armendariz
Cc: J ane Watson/R6/USEPA/US@EPA; Philip Crocker
Subject: Fw: Agenda for 10/26 event on Santa Fe River
Date: 10/24/2011 02:00 PM
Here is some additional information about the agenda for 10/26 as well.
Brian Fontenot, Ph.D.
EPA Region 6 (6WQ-EW)
1445 Ross Ave., Suite 1200
Dallas, TX 75202
214-665-7286
----- Forwarded by Brian Fontenot/R6/USEPA/US on 10/24/2011 02:00 PM -----
From: "Franklin, Abraham, NMENV" <abraham.franklin@state.nm.us>
To: Travis Loop/DC/USEPA/US@EPA, J ohn Senn/DC/USEPA/US@EPA
Cc: Brian Fontenot/R6/USEPA/US@EPA, "Bearzi, J ames, NMENV"
<james.bearzi@state.nm.us>, "Davis, J im, NMENV" <J im.Davis@state.nm.us>
Date: 10/21/2011 12:09 PM
Subject: Agenda for 10/26 event on Santa Fe River
Travis,

We have been discussing some specifics about the agenda for 10/26,
and are thinking of doing the first few items a little differently. Here is
the latest concept:

Meet at the selected site (10/26/11, 10:30 am)
Opening remarks and introductions (NMED, 5 min)
Summary of Success Story (Abe Franklin, confirmed, 5 min)
Watershed overview (Mayor Coss, confirmed, 5 min)
Description of WildEarth Guardians projects (John Horning, WEG
ED, confirmed, 5 min)
Description of SWCD role and work (Jose Varela-Lopez, invited, 5
min)
Santa Fe County Perspective (Colleen Baker, SF County Open
Space Coordinator, confirmed, 5 min)
Walk closer to river (2.5 min)
Q+A, or possibly informal discussion and exploration (15 min)
EPA comments and feedback (Nancy Stoner, confirmed, 10 min)
Walk back to cars (2.5 min).

Only the second and third items are slightly different. There is no need
to change the press advisory, unless you want to add me to the who
section. Jim Davis will be there, and may provide the opening remarks.

Thank You,

Abe

--
Abraham J. Franklin
Program Manager
Watershed Protection Section
Surface Water Quality Bureau
New Mexico Environment Department
PO Box 5469
Santa Fe, NM 87502-5469
Physical Address:
1190 St. Francis Drive, Rm. 2050
Santa Fe, NM 87505
phone: 505-827-2793
fax: 505-827-0160



From: David Gray
To: Al Armendariz/R6/USEPA/US@EPA; Chrissy Mann; Mansuri.Layla@epamail.epa.gov
Subject: NGO - Western Resources Advocates
Date: 10/14/2011 02:09 PM
Steven Michel
smichel@westernresources.org
http://www.westernresourceadvocates.org/
505.690.8733
He would like to talk about possible solutions at PNM and San J uan Generating
Station. He has some ideas and approaches that he would like to discuss with EPA.
He has been in touch with PNM and reports that they are 'interested' if EPA would
be willing to accept the approach.
Al - you may have received a call or email from Region 8 about him.
Let me know how you would like to proceed.
David
Steven Michel: Chief Counsel, Energy Program
Mr. Michel joined WRA in 2007, bringing with him 25 years of experience in the
energy industry. For 17 years, he served as general counsel for the New Mexico
Industrial Energy Consumers, and before that, worked five years as Assistant Attorney
General in the New Mexico Attorney Generals Consumer Division Energy Unit. Mr.
Michel has donated countless hours of pro bono work and, as counsel for a coalition
of Indian tribes and environmental groups in the 1990s, was instrumental in stopping
the construction of a major utility transmission line through New Mexicos Jemez
Mountains. In 1995, Mr. Michel was awarded the New Mexico State Bars Robert H.
LaFollette Pro Bono Award. He has served on many governmental task forces dealing
with energy issues, and has helped develop and draft energy-related legislation in
New Mexico. Mr. Michel received a B.A. degree in History and Economics from
Northwestern University and received M.B.A. and J.D. degrees from Vanderbilt
University.
From: Chrissy Mann
To: Layla Mansuri; Al Armendariz
Subject: Re: Wildearth Guardian Challenge of Ozone Decision
Date: 09/17/2011 07:34 AM
Note that the suit and press release complain about the decision, then
ask EPA to implement 75.
Sent by EPA Wireless Email Services
Layla Mansuri
----- Original Message -----
From: Layla Mansuri
Sent: 09/16/2011 08:03 PM EDT
To: Al Armendariz
Cc: Chrissy Mann
Subject: Fw: Wildearth Guardian Challenge of Ozone Decision
Suzanne Murray
----- Original Message -----
From: Suzanne Murray
Sent: 09/16/2011 07:22 PM EDT
To: "Lawrence Starfield" <starfield.lawrence@epa.gov>; "Layla
Mansuri" <mansuri.layla@epa.gov>
Subject: Fw: Wildearth Guardian Challenge of Ozone Decision
Sent by EPA Wireless E-Mail Services
Suzanne Smith
----- Original Message -----
From: Suzanne Smith
Sent: 09/16/2011 07:19 PM EDT
To: Suzanne Murray; Lucinda Watson
Subject: Fw: Wildearth Guardian Challenge of Ozone Decision
Thomas Diggs
----- Original Message -----
From: Thomas Diggs
Sent: 09/16/2011 05:37 PM CDT
To: Donaldson.Guy@epa.gov; Carrie Paige
Cc: Suzanne Smith
Subject: Wildearth Guardian Challenge of Ozone Decision
This announcement by Wild Earth Guardian contains their report and
the litigation filed in the Arizona Federal Court.
You may have already seen this. My assumption is this may be one of
the things that OAR/ OGC/ OAQPS is pouring over before coming to an
announcement on next steps with the Ozone standard.
FYI.
http://www.wildearthguardians.org/site/News2?
page=NewsArticle&id=7171&news_iv_ctrl=1194
Thomas Diggs
Associate Director - Air
US EPA Region 6
214-665-3102
fax 214-665-7263
diggs.thomas@epa.gov
From: Lawrence Starfield
To: Al Armendariz
Subject: Fw: Wildearth Guardian Challenge of Ozone Decision
Date: 09/16/2011 10:07 PM
Al,
Interesting article, if you haven't already seen it.
Larry
----- Forwarded by Lawrence Starfield/R6/USEPA/US on 09/16/2011 10:06 PM -----
Fw: Wildearth Guardian Challenge of Ozone Decision
Suzanne
Murray
to: Lawrence Starfield, Layla Mansuri
09/16/2011
06:22 PM
From: Suzanne Murray/R6/USEPA/US
To: "Lawrence Starfield" <starfield.lawrence@epa.gov>, "Layla Mansuri"
<mansuri.layla@epa.gov>
Sent by EPA Wireless E-Mail Services
Suzanne Smith
----- Original Message -----
From: Suzanne Smith
Sent: 09/16/2011 07:19 PM EDT
To: Suzanne Murray; Lucinda Watson
Subject: Fw: Wildearth Guardian Challenge of Ozone Decision
Thomas Diggs
----- Original Message -----
From: Thomas Diggs
Sent: 09/16/2011 05:37 PM CDT
To: Donaldson.Guy@epa.gov; Carrie Paige
Cc: Suzanne Smith
Subject: Wildearth Guardian Challenge of Ozone Decision
This announcement by Wild Earth Guardian contains their report and
the litigation filed in the Arizona Federal Court.
You may have already seen this. My assumption is this may be one of
the things that OAR/ OGC/ OAQPS is pouring over before coming to an
announcement on next steps with the Ozone standard.
FYI.
http://www.wildearthguardians.org/site/News2?
page=NewsArticle&id=7171&news_iv_ctrl=1194
Thomas Diggs
Associate Director - Air
US EPA Region 6
214-665-3102
fax 214-665-7263
diggs.thomas@epa.gov
From: David Gray
To: Al Armendariz; Suzanne Murray; Layla Mansuri; Lawrence Starfield; Carl Edlund; Thomas Diggs; J effrey
Robinson
Subject: Fw: Request for Administrative Stay of EPA's San J uan Generating Station BART Rule
Date: 09/16/2011 04:44 PM
Attachments: Request for Stay of the San J uan BART Rule with Attachments.pdf
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: "Nickel, Henry" [hnickel@hunton.com]
Sent: 09/16/2011 05:32 PM AST
To: LisaP J ackson
Cc: Gina McCarthy; David Gray
Subject: Request for Administrative Stay of EPA's San J uan Generating Station BART Rule
Dear Administrator Jackson:

Attached please find a copy of Public Service Company of New Mexico's Request for Administrative
Stay of EPA's Final Rule: "Approval and Promulgation of Implementation Plans; New Mexico; Federal
Implementation Plan for Interstate Transport of Pollution Affecting Visibility and Best Available Retrofit
Technology Determination" (Docket No. EPA-R06-OAR-2010-0846).

If you have any questions about this request, please contact me at any time.

Sincerely,

Henry V. Nickel

From: Al Armendariz
To: J oseph Goffman@EPA; Brendan Gilfillan; sussman.bob@epa.gov; gray.david@epa.gov; David Bloomgren; David
Cohen
Cc: Oster.Seth@epamail.epa.gov
Subject: Luminant - CRS Congressional Research Service report on CSAPR Clean air rules, August 2011
Date: 09/12/2011 11:26 AM
Attachments: CRS-EPA.pdf
Quote from summary page of attached report by independent CRS (August 2011):
"The primary impacts of many of the rules will largely be on coal-fired plants more than 40 years
old that have not, until now, installed state-of-the-art pollution controls. Many of these plants are
inefficient and are being replaced by more efficient combined cycle natural gas plants, a
development likely to be encouraged if the price of competing fuelnatural gascontinues to be
low, almost regardless of EPA rules."
Page 11
"Both EEI and NERC included the Cross-State Rule in their analyses, and their estimates of the
rules cost and the impact on coal-fired power do not appear to differ greatly from those of EPA,
particularly in the train wreck years, from now until 2017. NERC, for example, concluded that
the Cross-State Rule as proposed (then referred to as the Transport Rule) would lead to 2.9 GW
of deratings13 or retirements by 2015.14 This would represent less than 1% of coal-fired capacity,
and less than 0.3% of all EGU capacity. EPA, by comparison, projects that 4.8 GW of coal-fired
capacity would be uneconomic to maintain as a result of the rule.15"
Page 12
"To summarize, CAIR and its replacement, the Cross-State Air Pollution Rule, would impose
annual costs in the $2 billion to $3 billion range on previously uncontrolled coal-fired electric
generating units. Although these are significant costs, the industry has already complied with
Phase 1, which was the most ambitious of the rules requirements. Prompted by the ability to
generate tradable allowances, the industry complied well ahead of schedule. The final version of
the Cross-State Rule allows additional allowance trading as compared to the proposed rule, giving
EGUs additional flexibility in determining how to comply and lowering compliance costs."
Page 33 -
"The Institute of Clean Air Companies, which represents the pollution control industry, states that
utilities installed 60 GW of scrubbers and 20 GW of selective catalytic reduction (SCR) between
2008 and 2010. (See Figure 7.) In the early 2000s, in response to the NOx SIP Call, the industry
installed 96 GW of SCR in a five-year period while successfully maintaining system reliability.
This was a much more capital and manpower intensive effort than the Utility MACT will be,
according to David Foerter, the groups Executive Director."
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
----- Forwarded by Al Armendariz/R6/USEPA/US on 09/12/2011 11:12 AM -----
From: J oseph Goffman/DC/USEPA/US
To: Seth Oster/DC/USEPA/US@EPA, "Brendan Gilfillan" <gilfillan.brendan@epa.gov>, "Bob
Sussman" <Sussman.Bob@epamail.epa.gov>, "Al Armendariz"
<Armendariz.Al@epamail.epa.gov>
Date: 09/12/2011 10:53 AM
Subject: Fw: TXU's/Luminant's Aug 24 SEC filing
J ohn Millett
----- Original Message -----
From: John Millett
Sent: 08/30/2011 02:46 PM EDT
To: Gina McCarthy; Joseph Goffman; Sam Napolitano; Jeb Stenhouse
Subject: TXU's/Luminant's Aug 24 SEC filing
I pulled the below from Luminant's parent company's Aug 24, 2011
SEC filing (Energy Future Holdings Corp /TX/ (TXU) --
http://phx.corporate-ir.net/staging/phoenix.zhtml?c=102498&p=irol-
secFutureInterm). This is a discussion of their risk factors. While
CSAPR is mentioned below, they don't provide cost estimates. To the
average person, their financial risk and projected natural gas market
looks more alarming than CSAPR, which doesn't demand substantially
more than CAIR would have in 2012.
RISK FACTORS
You should carefully consider the risk factors set forth below and the risk factors
incorporated into this prospectus by reference to our 2010 Form 10-K
and 2011 Forms 10-Q, as well as the other information contained in and incorporated by
reference into this prospectus before deciding to invest in the notes.
The selected risks described below and the risks that are incorporated into this prospectus
by reference to our 2010 Form 10-K and 2011 Forms 10-Q are not
our only risks. Additional risks and uncertainties not currently known to us or those we
currently view to be immaterial also may materially and adversely
affect our business, financial condition or results of operations. Any of the following risks or
any of the risks described in our 2010 Form 10-K and 2011
Forms 10-Q could materially and adversely affect our business, financial condition,
operating results or cash flow. In such a case, the trading price of the
notes could decline, or we may not be able to make payments of interest and principal on
the notes, and you may lose all or part of your original investment.
Risks Related to the Notes and Our Substantial Indebtedness
Our substantial leverage could adversely affect our ability to raise additional capital
to fund our operations, limit our ability to react to changes in
the economy or our industry, expose us to interest rate risk to the extent of our
variable rate debt and prevent us from meeting obligations under the
various debt agreements governing our debt.
We are highly leveraged. As of June 30, 2011, our consolidated principal amount of debt
(short-term borrowings and long-term debt, including amounts
due currently) totaled $37.1 billion, which does not include $6.016 billion principal amount
of debt of Oncor. Our substantial leverage could have important
consequences, including:
making it more difficult for us to make payments on our debt;
requiring a substantial portion of cash flow to be dedicated to the payment of principal
and interest on our debt, thereby reducing our ability to
use our cash flow to fund operations, capital expenditures and future business
opportunities and execute our strategy;
increasing our vulnerability to adverse economic, industry or competitive developments;
exposing us to the risk of increased interest rates because, as of June 30, 2011, taking
into consideration interest swap transactions, 3% of our
long-term borrowings were at variable rates of interest through September 2014 and 18%
for October 2014 through October 2017;
limiting our ability to make strategic acquisitions or causing us to make non-strategic
divestitures;
limiting our ability to obtain additional financing for working capital, capital expenditures,
product development, debt service requirements,
acquisitions and general corporate or other purposes, or to refinance existing debt, and
limiting our ability to adjust to changing market conditions and placing us at a competitive
disadvantage compared to competitors who are less
highly leveraged and who therefore, may be able to take advantage of opportunities that
we cannot due to our substantial leverage.
We may not be able to repay or refinance our debt as or before it becomes due, or
obtain additional financing, particularly if forward natural gas
prices do not significantly increase.
We may not be able to repay or refinance our debt obligations as or before they become
due, or may be able to refinance such amounts only on terms
that will increase our cost of borrowing or on terms that may be more onerous. Our ability
to successfully implement any future refinancing of our debt will
depend, among other things, on our financial condition and operating performance, which
is subject to prevailing economic and competitive conditions and to
certain financial, business and other factors beyond our control, including, without
limitation, wholesale electricity prices in the Electric Reliability Council of
Texas ("ERCOT") market (which are primarily driven by the price of natural gas and
ERCOT market heat rates) and general conditions in the credit markets.
Refinancing may be difficult because of the slow economic recovery, the possibility of
rising interest rates and the impending surge of large debt maturities of
other borrowers. Due to the weakness of our credit, we may be more heavily exposed to
these refinancing risks than other borrowers.
A substantial amount of our debt is comprised of debt incurred under the TCEH senior
secured credit facilities. As a result of the extension of the
commitments and loans under the TCEH senior secured credit facilities (the "Extension")
becoming effective in April 2011, the non-extended commitments
under the TCEH revolving credit facility (approximately $645 million) will mature in October
2013, approximately $3.9 billion aggregate principal amount of
non-extended term and deposit letter of credit loans under the TCEH senior secured credit
facilities will mature in October 2014, the extended revolving
commitments under the TCEH revolving credit facility (approximately $1.4 billion) will
mature in October 2016 and approximately $16.4 billion aggregate
principal amount of extended term loans and extended letter of credit loans under the
TCEH senior secured credit facilities will mature in October 2017.
As a result of the Extension becoming effective, the extended loans include a "springing
maturity" provision pursuant to which (a) in the event that
$500 million aggregate principal amount of the TCEH Senior Notes due in 2015 (other
than notes held by EFH Corp. or its controlled affiliates as of
March 31, 2011 to the extent held as of the date of determination) or more than $150
million aggregate principal amount of the TCEH Senior Notes due in
2016 (other than notes held by EFH Corp. or its controlled affiliates as of March 31, 2011
to the extent held as of the date of determination), as applicable,
remain outstanding as of 91 days prior to the maturity date of the applicable notes and (b)
TCEH's Consolidated Total Debt to Consolidated EBITDA Ratio
(as such term is defined in the TCEH senior secured credit facilities) is greater than 6.00 to
1.00 at such applicable determination date, then the maturity date
of the extended loans will automatically change to 90 days prior to the maturity date of the
applicable notes. As a result of this "springing maturity" provision,
we may lose the benefit of the Extension if we are unable to refinance the requisite portion
of the TCEH Senior Notes by the applicable deadline. If holders of
the TCEH Senior Notes are unwilling to extend the maturities of their notes, then, to avoid
the "springing maturity" of the extended loans, we may be required
to repay a substantial portion of the TCEH Senior Notes at prices above market or at par.
There is no assurance that we will be able to make such payments
whether through cash on hand or additional financings.
Wholesale electricity prices in the ERCOT market largely correlate with the price of natural
gas. Accordingly, the contribution to earnings and the value
of our nuclear and lignite/coal-fueled generation assets are dependent in significant part
upon the price of natural gas. Forward natural gas prices have
generally trended downward since mid-2008. In recent years natural gas supply has
outpaced demand as a result of increased drilling of shale gas deposits
combined with lingering demand weakness associated with the economic recession, and
many industry experts expect this supply/demand imbalance to
continue for a number of years, thereby depressing natural gas prices for a long-term
period. These market conditions are challenging to the long-term
profitability of our generation assets. Specifically, low natural gas prices and their
correlated effect in ERCOT on wholesale electricity prices could have a
material adverse impact on the overall profitability of our generation assets for periods in
which we do not have significant hedge positions. As of June 30,
2011, we have hedged only approximately 51% and 26% of our wholesale natural gas
price exposure related to expected generation output for 2013 and 2014,
respectively, and do not have any significant amounts of hedges in place for periods after
2014. A continuation of current forward natural gas prices or a
further decline of forward natural gas prices could limit our ability to hedge our wholesale
electricity revenues at sufficient price levels to support our interest
payments and debt maturities, result in further declines in the values of our nuclear and
lignite/coal-fueled generation assets and adversely impact our ability
to refinance our debt or obtain additional financing.
In July 2011, the EPA issued the Cross-State Air Pollution Rule (the "CSAPR"). The
CSAPR requires states (including the State of Texas) to reduce
emissions of sulfur dioxide and nitrogen oxide that significantly contribute to or interfere
with the maintenance of the EPA's National Ambient Air Quality
Standards for fine particulate matter and/or ozone in downwind states. These programs
require significant additional reductions of sulfur dioxide and nitrogen
oxide emissions from TCEH's fossil-fueled generation units beginning on January 1, 2012.
In order to ensure near-term compliance with the CSAPR, TCEH
has identified several potential actions that likely will require TCEH to incur material capital
expenditures and operating costs and experience material
revenue decreases due to reduced generation and wholesale electricity sales volumes.
This increase in expenditures and reduction in revenue could adversely
impact TCEH's ability to make interest payments on its debt and to loan funds to EFH
Corp., which may affect EFH Corp.'s ability to make interest payments
on EFH Corp.'s debt, including the notes.
In addition, our liabilities and those of EFCH exceed our and EFCH's assets as shown on
our and EFCH's respective balance sheet prepared in
accordance with U.S. generally accepted accounting principles ("GAAP") as of June 30,
2011. Our assets include $6.2 billion of goodwill as of June 30, 2011.
In the third quarter 2010, we recorded a $4.1 billion noncash goodwill impairment charge
reflecting the estimated effect of lower wholesale electricity prices
on the enterprise value of TCEH, driven by the sustained decline in forward natural gas
prices, as indicated by our cash flow projections and declines in
market values of securities of comparable companies. The value of our goodwill will
continue to depend on, among other things, wholesale electricity prices
in the ERCOT market. Valuation analyses of TCEH's business indicate that the principal
amount of its outstanding debt exceeds its enterprise value. We may
have difficulty successfully implementing any refinancing of our debt or obtaining additional
financing due to the valuation of our assets.
~~~~~~~~~~~~~~~~~~~
J ohn Millett
Office of Air and Radiation Communications
U.S. Environmental Protection Agency
5411 Ariel Rios Building North
Washington, DC 20460
Phone: 202/564-2903
Cell:
From: Suzanne Murray
To: Al Armendariz; Chrissy Mann; Lawrence Starfield; Layla Mansuri
Subject: Confidential
Date: 09/12/2011 06:57 AM
Sent by EPA Wireless E-Mail Services
Suzanne Smith
----- Original Message -----
From: Suzanne Smith
Sent: 09/12/2011 07:48 AM EDT
To: Suzanne Murray
Subject: Fw: For final review: language for TX infr SIP PSD
single source ozone - all comments incorporated
Guy is trying to push some more
Guy Donaldson
----- Original Message -----
From: Guy Donaldson
Sent: 09/11/2011 11:10 PM CDT
To: Sara Schneeberg
Cc: Suzanne Smith; Abi Vijayan; Carrie Paige; Dan Deroeck;
Erik Snyder; Geoffrey Wilcox; Jeffrey Robinson; Lucinda Watson;
Melina Williams; Tyler Fox/RTP/USEPA/US@EPA page.steve
Subject: Re: For final review: language for TX infr SIP PSD
single source ozone - all comments incorporated
I am disappointed that people are just now figuring out the implementation versus
structure of the SIP issue.





(b) (5)
Sara Schneeberg---09/09/2011 04:05:57 PM---
From: Sara Schneeberg/DC/USEPA/US
To: Suzanne Smith/R6/USEPA/US@EPA
Cc: Guy Donaldson/R6/USEPA/US@EPA, Abi Vijayan/R6/USEPA/US@EPA,
Carrie Paige/R6/USEPA/US@EPA, Dan Deroeck/RTP/USEPA/US@EPA, Erik
Snyder/R6/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, J effrey
Robinson/R6/USEPA/US@EPA, Lucinda Watson/R6/USEPA/US@EPA, Melina
Williams/DC/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA page.steve
Date: 09/09/2011 04:05 PM
Subject: Re: For final review: language for TX infr SIP PSD single source
ozone - all comments incorporated

Sara Schneeberg
USEPA Office of General Counsel
Phone: 202/564-5592
Fax: 202/564-5603
Suzanne Smith---09/09/2011 05:00:31 PM---I've done some tweaking with
everyone's tweaks. Below is a clean version of what I tweaked, the red
From: Suzanne Smith/R6/USEPA/US
To: Guy Donaldson/R6/USEPA/US@EPA
Cc: Abi Vijayan/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Dan
Deroeck/RTP/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA, Geoffrey
Wilcox/DC/USEPA/US@EPA, J effrey Robinson/R6/USEPA/US@EPA, Lucinda
Watson/R6/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA
Date: 09/09/2011 05:00 PM
Subject: Re: For final review: language for TX infr SIP PSD single source
ozone - all comments incorporated
I've done some tweaking with everyone's tweaks. Below is a clean version of
what I tweaked, the redline/ strikeout is attached.
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege


[attachment "TX infr PSD single source 9-9.docx" deleted by Sara
Schneeberg/DC/USEPA/US]
Suzanne J . Smith
Chief, Multimedia Counseling Branch
Office of Regional Counsel
214-665-8027
Guy Donaldson---09/09/2011 01:35:34 PM---I thinks this is largely OK. I am
FOIA Exemption (b)(5) - Deliberative Process Privilege
concerned that
From: Guy Donaldson/R6/USEPA/US
To: Abi Vijayan/R6/USEPA/US@EPA
Cc: Carrie Paige/R6/USEPA/US@EPA, Dan Deroeck/RTP/USEPA/US@EPA,
Erik Snyder/R6/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA,
J effrey Robinson/R6/USEPA/US@EPA, Lucinda Watson/R6/USEPA/US@EPA,
Melina Williams/DC/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA,
Suzanne Smith/R6/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA
Date: 09/09/2011 01:35 PM
Subject: Re: For final review: language for TX infr SIP PSD single source
ozone - all comments incorporated
I thinks this is largely OK. I am concerned that
[attachment "TX infr PSD single source 9-9.docx" deleted by Suzanne
Smith/R6/USEPA/US]
Abi Vijayan---09/09/2011 01:02:48 PM---Hi all, The attached draft incorporates
all comments/edits from Suzanne, Lucinda, Geoff, Sara, Melin
From: Abi Vijayan/R6/USEPA/US
To: Suzanne Smith/R6/USEPA/US@EPA, Lucinda
Watson/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, J effrey
Robinson/R6/USEPA/US@EPA, Carrie Paige/R6/USEPA/US@EPA, Erik
Snyder/R6/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA, Sara
Schneeberg/DC/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA, Dan
Deroeck/RTP/USEPA/US@EPA, Tyler Fox/RTP/USEPA/US@EPA
Date: 09/09/2011 01:02 PM
Subject: For final review: language for TX infr SIP PSD single source
ozone - all comments incorporated
Hi all,
The attached draft incorporates all comments/edits from Suzanne, Lucinda, Geoff,
Sara, Melina, Erik, and various OAQPS folks to date. I'd appreciate if you could
review the new language as a whole to ensure that we have covered all our bases
accurately from both the legal and technical perspectives we have discussed. This
should hopefully be the final round of review before we put it into the proposal for
the RA's signature!!
Please let me know if you have any comments/concerns/questions ASAP, much
appreciated. Everyone has been extremely helpful in their prompt response and
communication, and I am grateful.
J eff R. - Guy asked I send this to you for your review as well.
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
[attachment "TX infr PSD single source 9-9.docx" deleted by Suzanne
Smith/R6/USEPA/US]
Abi Vijayan
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6RC-M)
Dallas, TX 75202
Tel: (214) 665-7303
Fax: (214) 665-2182
NOTICE: This communication may contain privileged or otherwise confidential
information. If you are not the intended recipient, or believe you have received this
communication in error, please delete the copy you received, and do not print, copy,
re-transmit, disseminate or otherwise use the information. Thank you.
(b) (5)
From: Lawrence Starfield
To: Steve Mouck
Cc: Al Armendariz; Lynda Carroll; I -J ung Chiang
Subject: Fw: Fw: Region 6 Input for Agency Annual Performance Report
Date: 09/08/2011 10:53 PM
Sent by EPA Wireless E-Mail Services
----- Original Message -----
From: [astarfield@tx.rr.com]
Sent: 09/08/2011 10:15 PM AST
To: Lawrence Starfield
Subject: Re: Fw: Region 6 Input for Agency Annual Performance Report
Steve,
Thanks for sending this along, and for strengthening the write-ups. They're in better shape than
earlier in the week.

































Please see if Al has any additional comments, and then submit the revised papers tomorrow.
Thanks.
Larry
> ----- Original Message -----
> From: Steve Mouck
> Sent: 09/08/2011 11:50 AM CDT
> To: Al Armendariz; Lawrence Starfield
> Cc: I-Jung Chiang
> Subject: Region 6 Rep


(b) (2), FOIA Exemption (b)(5) - Deliberative Process Privilege
(b) (2), FOIA Exemption (b)(5) - Deliberative Process Privilege
> highlighting our most significant regional, state, tribal, or local
>



































































































(b) (2), FOIA
Exemption (b)
(5) -
Deliberative
Process
Privilege
> area. Presented at a September 2011 public meeting, the
>




























































> (See attached file: FY 2011 Region 6 Cross Cutting Fundamental
> Strategy Accomplishments.docx)
>
>
> OCFO has asked that our input be recorded in their data base by COB
> Friday, September 9, 2011. Please let me know if you have any questions
> or need additional action/information.
>
>
> Steve Mouck
> EPA, Region 6
> Resources Branch, Mgt Division
> 1445 Ross Avenue
> Dallas, Texas 75202-3175
> Phone: 214-665-6524
> Fax: 214-665-8505
>
>
>
> From: Lawrence Starfield/R6/USEPA/US
> To: "I-Jung Chiang" <Chiang.I-Jung@epamail.epa.gov>, Steve
> Mouck/R6/USEPA/US@EPA
> Cc: Al Armendariz/R6/USEPA/US
> Date: 09/07/2011 03:57 PM
> Subject: Fw: Fw: EPA's Annual Performance Report - please review in
> advance of Senior Staff
>
>
> I-Jung and Steve,
>
> Thanks.
(b) (2), FOIA Exemption (b)(5) - Deliberative Process Privilege
Not responsive to this request.
>
> Larry
> Sent by EPA Wireless E-Mail Services
>
>
> ----- Original Message -----
> From: Myron Knudson
> Sent: 09/07/2011 01:52 PM CDT
> To: Lawrence Starfield
> Cc: Steve Mouck; morton.michael@epa.gov
> Subject: Re: Fw: EPA's Annual Performance Report - please review in
> advance of Senior Staff

CREM
>
>
>
>
> From: Lawrence Starfield/R6/USEPA/US
> To: Myron Knudson/R6/USEPA/US@EPA
> Date: 09/06/2011 03:42 PM
> Subject: Fw: EPA's Annual Performance Report - please review in
> advance of Senior Staff
> Sent by: Connie Sanchez
>
>
> is this it?
>
>
> ----- Forwarded by Connie Sanchez/R6/USEPA/US on 09/06/2011 03:42 PM
> -----
>
> From: Lawrence Starfield/R6/USEPA/US
> To: John Blevins/R6/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA,
> Miguel Flores/R6/USEPA/US@EPA, Sam Coleman/R6/USEPA/US@EPA,
> Lynda Carroll/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA,
> Suzanne Murray/R6/USEPA/US@EPA, Jeannine
> Hale/R6/USEPA/US@EPA, William Luthans/R6/USEPA/US@EPA, Pam
> Phillips/R6/USEPA/US@EPA, William Honker/R6/USEPA/US@EPA,
> Sam Becker/R4/USEPA/US@EPA, Ben Harrison/R6/USEPA/US@EPA,
> Stephen Gilrein/R6/USEPA/US@EPA, Diane
> Taheri/R6/USEPA/US@EPA, Deborah Ponder/R6/USEPA/US@EPA,
> Layla Mansuri/R6/USEPA/US@EPA
> Cc: Al Armendariz/R6/USEPA/US, I-Jung Chiang/R6/USEPA/US@EPA,
> Chrissy Mann/R6/USEPA/US@EPA, Steve Mouck/R6/USEPA/US@EPA
> Date: 09/05/2011 06:09 PM
> Subject: EPA's Annual Performance Report - please review in advance
> of Senior Staff
>
>
>

.
> Thanks for your help.
>
> Larry
>
> ----- Forwarded by Lawrence Starfield/R6/USEPA/US on 09/05/2011 05:31 PM
> -----
>
(
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)
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2
)
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x
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(b) (2)
>
>
> Proposed R6 Input for EPA's Annual Performance Report
>
>
> Steve Mouck
> to:
> Lawrence Starfield
> 09/02/2011 01:10 PM
>
>
>
>
> Cc:
> Rhea.William, Olivia-R Balandran, Connie Overbay, Mary Kemp, Tressa
> Tillman, Lynda Carroll, Marya Stanton, Terrie Mikus, I-Jung Chiang
>
>
>
>
>
>
>
> (
> E
> m
> b
> e
> d
> d
> e
> d
> i
> m
> a
> g
> e
> m
> o
> v
> e
> d
> t
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> :
> p
> i
> c
> 1
> 7
> 8
> 0
> 3
> .
> g
> i
> f
> )
>
> F Steve Mouck/R6/USEPA/US
> r
> o
> m
> :
>
>
>
> T Lawrence Starfield/R6/USEPA/US@EPA
> o
> :
>
>
>
> C Rhea.William@epamail.epa.gov, Olivia-R Balandran/R6/USEPA/US@EPA,
> c Connie Overbay/R6/USEPA/US@EPA, Mary Kemp/R6/USEPA/US@EPA, Tressa
> : Tillman/R6/USEPA/US@EPA, Lynda Carroll/R6/USEPA/US@EPA, Marya
> Stanton/R6/USEPA/US@EPA, Terrie Mikus/R6/USEPA/US@EPA, I-Jung
> Chiang/R6/USEPA/US@EPA
>
>
>
>
>
>
>





(b) (2)
>














































[attachment "FY 2011 Regional Highlight Proposals for the Annual
Performance Report.docx" deleted by Myron Knudson/R6/USEPA/US]
> [attachment "FY 2011 Region 6 Cross Cutting Fundamental Strategy
> Accomplishments.docx" deleted by Myron Knudson/R6/USEPA/US]
>
>
> Steve Mouck
> EPA, Region 6
> Resources Branch, Mgt Division
> 1445 Ross Avenue
> Dallas, Texas 75202-3175
> Phone: 214-665-6524
> Fax: 214-665-8505
>
>
>
>
(b) (2)
From: I -J ung Chiang
To: Al Armendariz; Lawrence Starfield
Cc: Steve Mouck
Subject: Re: Region 6 Input for Agency Annual Performance Report
Date: 09/08/2011 12:46 PM


I-J ung Chiang
Special Assistant to the Deputy Regional Administrator
U.S. Environmental Protection Agency
1445 Ross Avenue
Dallas, Texas 75202
214.665.2160
214.665.6648 (fax)
chiang.i-jung@epa.gov
Steve Mouck---09/08/2011 11:50:30 AM--- Hi Al and Larry - As noted in my
earlier correspondence, OCFO is in the process of developing the
From: Steve Mouck/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Lawrence
Starfield/R6/USEPA/US@EPA
Cc: I -J ung Chiang/R6/USEPA/US@EPA
Date: 09/08/2011 11:50 AM
Subject: Region 6 Input for Agency Annual Performance Report
Hi Al and Larry - As noted in my earlier correspondence, OCFO is in the process of
developing the Agency's FY 2011 Annual Performance Report. Regions are required
to provide input for two sections of the report, (1) the "Regional Map" and (2)
accomplishments related to the Agency's Cross Cutting Fundamental Strategies.
1.

(b) (2)
Not responsive to this request.
Not responsive to this request.





(b) (2)
The attached document contains these write-ups and all the other
Division submittals and/or revisions received to date.
[attachment "Regional Map Accomplishments.docx" deleted by I-
J ung Chiang/R6/USEPA/US]
2.


(b) (2)
(b) (5)
(b) (2)




(b) (2)
(b) (2)
[attachment "FY 2011 Region 6 Cross Cutting Fundamental
Strategy Accomplishments.docx" deleted by I-J ung
Chiang/R6/USEPA/US]

OCFO has asked that our input be recorded in their data base by COB
Friday, September 9, 2011. Please let me know if you have any
questions or need additional action/information.
Steve Mouck
EPA, Region 6
Resources Branch, Mgt Division
1445 Ross Avenue
Dallas, Texas 75202-3175
Phone: 214-665-6524
Fax: 214-665-8505
Lawrence Starfield---09/07/2011 03:57:17 PM---I-J ung and Steve, Pls work
together to compile the suggestions that come in by COB, and give us your
From: Lawrence Starfield/R6/USEPA/US
To: "I -J ung Chiang" <Chiang.I -J ung@epamail.epa.gov>, Steve
Mouck/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US
Date: 09/07/2011 03:57 PM
Subject: Fw: Fw: EPA's Annual Performance Report - please review in
advance of Senior Staff
I-J ung and Steve,
Thanks.
Larry
Sent by EPA Wireless E-Mail Services
Myron Knudson
----- Original Message -----
From: Myron Knudson
Sent: 09/07/2011 01:52 PM CDT
To: Lawrence Starfield
Cc: Steve Mouck; morton.michael@epa.gov
Subject: Re: Fw: EPA's Annual Performance Report - please
Not responsive to this request.
review in advance of Senior Staff
FY 2011 Region 6 Cross Cutting Fundamental
Strategy Accomplishments



Lawrence Starfield---09/06/2011 03:42:49 PM---is this it?
From: Lawrence Starfield/R6/USEPA/US
To: Myron Knudson/R6/USEPA/US@EPA
Date: 09/06/2011 03:42 PM
Subject: Fw: EPA's Annual Performance Report - please review in advance
of Senior Staff
Sent by: Connie Sanchez
is this it?
----- Forwarded by Connie Sanchez/R6/USEPA/US on 09/06/2011 03:42 PM -----
From: Lawrence Starfield/R6/USEPA/US
To: J ohn Blevins/R6/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA,
Miguel Flores/R6/USEPA/US@EPA, Sam Coleman/R6/USEPA/US@EPA, Lynda
Carroll/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Suzanne
(b) (2)
Murray/R6/USEPA/US@EPA, J eannine Hale/R6/USEPA/US@EPA, William
Luthans/R6/USEPA/US@EPA, Pam Phillips/R6/USEPA/US@EPA, William
Honker/R6/USEPA/US@EPA, Sam Becker/R4/USEPA/US@EPA, Ben
Harrison/R6/USEPA/US@EPA, Stephen Gilrein/R6/USEPA/US@EPA, Diane
Taheri/R6/USEPA/US@EPA, Deborah Ponder/R6/USEPA/US@EPA, Layla
Mansuri/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US, I -J ung Chiang/R6/USEPA/US@EPA,
Chrissy Mann/R6/USEPA/US@EPA, Steve Mouck/R6/USEPA/US@EPA
Date: 09/05/2011 06:09 PM
Subject: EPA's Annual Performance Report - please review in advance of
Senior Staff
Senior Staff:
Thanks for your help.
Larry
----- Forwarded by Lawrence Starfield/R6/USEPA/US on 09/05/2011 05:31 PM -----
Proposed R6 Input for EPA's Annual Performance Report
Steve
Mouck
to: Lawrence Starfield
09/02/2011
01:10 PM
Cc: Rhea.William, Olivia-R Balandran, Connie Overbay, Mary Kemp, Tressa Tillman, Lynda Carroll, Marya
Stanton, Terrie Mikus, I -J ung Chiang
From: Steve Mouck/R6/USEPA/US
To: Lawrence Starfield/R6/USEPA/US@EPA
Cc: Rhea.William@epamail.epa.gov, Olivia-R Balandran/R6/USEPA/US@EPA, Connie
Overbay/R6/USEPA/US@EPA, Mary Kemp/R6/USEPA/US@EPA, Tressa
Tillman/R6/USEPA/US@EPA, Lynda Carroll/R6/USEPA/US@EPA, Marya
Stanton/R6/USEPA/US@EPA, Terrie Mikus/R6/USEPA/US@EPA, I -J ung
Chiang/R6/USEPA/US@EPA
Not responsive to this request.
Hi Larry -








is
(b) (2)
attached.



[attachment "FY 2011 Regional Highlight Proposals for the Annual Performance
Report.docx" deleted by Myron Knudson/R6/USEPA/US] [attachment "FY 2011
Region 6 Cross Cutting Fundamental Strategy Accomplishments.docx" deleted by
Myron Knudson/R6/USEPA/US]
Steve Mouck
EPA, Region 6
Resources Branch, Mgt Division
1445 Ross Avenue
Dallas, Texas 75202-3175
Phone: 214-665-6524
Fax: 214-665-8505
(b) (5)
From: Steve Mouck
To: Al Armendariz; Lawrence Starfield
Cc: I -J ung Chiang
Subject: Region 6 Input for Agency Annual Performance Report
Date: 09/08/2011 11:50 AM
Attachments: Regional Map Accomplishments.docx
FY 2011 Region 6 Cross Cutting Fundamental Strategy Accomplishments.docx
Hi Al and Larry -







(b) (2)





(b) (2)
(b) (2)
(b) (2)








(b) (2)
(b) (2)
(b) (2)
OCFO has asked that our input be recorded in their data base by COB Friday,
September 9, 2011. Please let me know if you have any questions or need
additional action/information.
Steve Mouck
EPA, Region 6
Resources Branch, Mgt Division
1445 Ross Avenue
Dallas, Texas 75202-3175
Phone: 214-665-6524
Fax: 214-665-8505
Lawrence Starfield---09/07/2011 03:57:17 PM---I-J ung and Steve, Pls work
together to compile the suggestions that come in by COB, and give us your
From: Lawrence Starfield/R6/USEPA/US
To: "I -J ung Chiang" <Chiang.I -J ung@epamail.epa.gov>, Steve
Mouck/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US
Date: 09/07/2011 03:57 PM
Subject: Fw: Fw: EPA's Annual Performance Report - please review in
advance of Senior Staff
I-J ung and Steve,
Thanks.
Larry
Sent by EPA Wireless E-Mail Services
Myron Knudson
----- Original Message -----
From: Myron Knudson
Sent: 09/07/2011 01:52 PM CDT
To: Lawrence Starfield
Cc: Steve Mouck; morton.michael@epa.gov
Subject: Re: Fw: EPA's Annual Performance Report - please
review in advance of Senior Staff
FY 2011 Region 6 Cross Cutting Fundamental
Strategy Accomplishments
Not responsive to this request.
Not responsive to this request.



Lawrence Starfield---09/06/2011 03:42:49 PM---is this it?
From: Lawrence Starfield/R6/USEPA/US
To: Myron Knudson/R6/USEPA/US@EPA
Date: 09/06/2011 03:42 PM
Subject: Fw: EPA's Annual Performance Report - please review in advance
of Senior Staff
Sent by: Connie Sanchez
is this it?
----- Forwarded by Connie Sanchez/R6/USEPA/US on 09/06/2011 03:42 PM -----
From: Lawrence Starfield/R6/USEPA/US
To: J ohn Blevins/R6/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA,
Miguel Flores/R6/USEPA/US@EPA, Sam Coleman/R6/USEPA/US@EPA, Lynda
Carroll/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Suzanne
Murray/R6/USEPA/US@EPA, J eannine Hale/R6/USEPA/US@EPA, William
Luthans/R6/USEPA/US@EPA, Pam Phillips/R6/USEPA/US@EPA, William
Honker/R6/USEPA/US@EPA, Sam Becker/R4/USEPA/US@EPA, Ben
Harrison/R6/USEPA/US@EPA, Stephen Gilrein/R6/USEPA/US@EPA, Diane
Taheri/R6/USEPA/US@EPA, Deborah Ponder/R6/USEPA/US@EPA, Layla
Mansuri/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US, I -J ung Chiang/R6/USEPA/US@EPA,
Chrissy Mann/R6/USEPA/US@EPA, Steve Mouck/R6/USEPA/US@EPA
Date: 09/05/2011 06:09 PM
Subject: EPA's Annual Performance Report - please review in advance of
(b) (2)
Senior Staff
Senior Staff:
Thanks for your help.
Larry
----- Forwarded by Lawrence Starfield/R6/USEPA/US on 09/05/2011 05:31 PM -----
Proposed R6 Input for EPA's Annual Performance Report
Steve
Mouck
to: Lawrence Starfield
09/02/2011
01:10 PM
Cc: Rhea.William, Olivia-R Balandran, Connie Overbay, Mary Kemp, Tressa Tillman, Lynda Carroll, Marya
Stanton, Terrie Mikus, I -J ung Chiang
From: Steve Mouck/R6/USEPA/US
To: Lawrence Starfield/R6/USEPA/US@EPA
Cc: Rhea.William@epamail.epa.gov, Olivia-R Balandran/R6/USEPA/US@EPA, Connie
Overbay/R6/USEPA/US@EPA, Mary Kemp/R6/USEPA/US@EPA, Tressa
Tillman/R6/USEPA/US@EPA, Lynda Carroll/R6/USEPA/US@EPA, Marya
Stanton/R6/USEPA/US@EPA, Terrie Mikus/R6/USEPA/US@EPA, I -J ung
Chiang/R6/USEPA/US@EPA
Hi Larry -
(b) (2)
Not responsive to this request.















[attachment "FY 2011 Regional Highlight Proposals for the Annual Performance
Report.docx" deleted by Myron Knudson/R6/USEPA/US] [attachment "FY 2011
Region 6 Cross Cutting Fundamental Strategy Accomplishments.docx" deleted by
Myron Knudson/R6/USEPA/US]
(b) (2)
Steve Mouck
EPA, Region 6
Resources Branch, Mgt Division
1445 Ross Avenue
Dallas, Texas 75202-3175
Phone: 214-665-6524
Fax: 214-665-8505
From: Lawrence Starfield
To: I -J ung Chiang; Steve Mouck
Cc: Al Armendariz
Subject: Fw: Fw: EPA's Annual Performance Report - please review in advance of Senior Staff
Date: 09/07/2011 03:57 PM
I-J ung and Steve,
Please send something to both Al and me by mid-day tomorrow.
Thanks.
Larry
Sent by EPA Wireless E-Mail Services
Myron Knudson
----- Original Message -----
From: Myron Knudson
Sent: 09/07/2011 01:52 PM CDT
To: Lawrence Starfield
Cc: Steve Mouck; morton.michael@epa.gov
Subject: Re: Fw: EPA's Annual Performance Report - please review in
advance of Senior Staff
FY 2011 Region 6 Cross Cutting Fundamental
Strategy Accomplishments



Not responsive to this request.
(b) (2)
Lawrence Starfield---09/06/2011 03:42:49 PM---is this it?
From: Lawrence Starfield/R6/USEPA/US
To: Myron Knudson/R6/USEPA/US@EPA
Date: 09/06/2011 03:42 PM
Subject: Fw: EPA's Annual Performance Report - please review in advance
of Senior Staff
Sent by: Connie Sanchez
is this it?
----- Forwarded by Connie Sanchez/R6/USEPA/US on 09/06/2011 03:42 PM -----
From: Lawrence Starfield/R6/USEPA/US
To: J ohn Blevins/R6/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA,
Miguel Flores/R6/USEPA/US@EPA, Sam Coleman/R6/USEPA/US@EPA, Lynda
Carroll/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Suzanne
Murray/R6/USEPA/US@EPA, J eannine Hale/R6/USEPA/US@EPA, William
Luthans/R6/USEPA/US@EPA, Pam Phillips/R6/USEPA/US@EPA, William
Honker/R6/USEPA/US@EPA, Sam Becker/R4/USEPA/US@EPA, Ben
Harrison/R6/USEPA/US@EPA, Stephen Gilrein/R6/USEPA/US@EPA, Diane
Taheri/R6/USEPA/US@EPA, Deborah Ponder/R6/USEPA/US@EPA, Layla
Mansuri/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US, I -J ung Chiang/R6/USEPA/US@EPA,
Chrissy Mann/R6/USEPA/US@EPA, Steve Mouck/R6/USEPA/US@EPA
Date: 09/05/2011 06:09 PM
Subject: EPA's Annual Performance Report - please review in advance of
Senior Staff
Senior Staff:
Thanks for your help.
Larry
(b) (2)
Not responsive to this request.
----- Forwarded by Lawrence Starfield/R6/USEPA/US on 09/05/2011 05:31 PM -----
Proposed R6 Input for EPA's Annual Performance Report
Steve
Mouck
to: Lawrence Starfield
09/02/2011
01:10 PM
Cc: Rhea.William, Olivia-R Balandran, Connie Overbay, Mary Kemp, Tressa Tillman, Lynda Carroll, Marya
Stanton, Terrie Mikus, I -J ung Chiang
From: Steve Mouck/R6/USEPA/US
To: Lawrence Starfield/R6/USEPA/US@EPA
Cc: Rhea.William@epamail.epa.gov, Olivia-R Balandran/R6/USEPA/US@EPA, Connie
Overbay/R6/USEPA/US@EPA, Mary Kemp/R6/USEPA/US@EPA, Tressa
Tillman/R6/USEPA/US@EPA, Lynda Carroll/R6/USEPA/US@EPA, Marya
Stanton/R6/USEPA/US@EPA, Terrie Mikus/R6/USEPA/US@EPA, I -J ung
Chiang/R6/USEPA/US@EPA
Hi Larry -





(b) (2)






[attachment "FY 2011 Regional Highlight Proposals for the Annual Performance
Report.docx" deleted by Myron Knudson/R6/USEPA/US] [attachment "FY 2011
Region 6 Cross Cutting Fundamental Strategy Accomplishments.docx" deleted by
Myron Knudson/R6/USEPA/US]
Steve Mouck
EPA, Region 6
Resources Branch, Mgt Division
1445 Ross Avenue
Dallas, Texas 75202-3175
Phone: 214-665-6524
Fax: 214-665-8505
(b) (2)
From: Al Armendariz
To: Claudia Hosch
Cc: Brent Larsen; Isaac Chen; J oyce Runyan; Lawrence Starfield; Miguel Flores; Rob Lawrence; Stacey Dwyer;
William Honker
Subject: Re: Briefing paper - ERCOT visit tomorrow
Date: 09/01/2011 09:47 PM
Thank you Claudia. Very helpful.
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
-----Claudia Hosch/R6/USEPA/US wrote: -----
To: Al Armendariz/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA
From: Claudia Hosch/R6/USEPA/US
Date: 09/01/2011 04:29PM
Cc: Joyce Runyan/R6/USEPA/US@EPA, Miguel Flores/R6/USEPA/US@EPA, Stacey Dwyer/R6/USEPA/US@EPA,
William Honker/R6/USEPA/US@EPA, Brent Larsen/R6/USEPA/US@EPA, Isaac Chen/R6/USEPA/US@EPA, Rob
Lawrence/R6/USEPA/US@EPA
Subject: Briefing paper - ERCOT visit tomorrow
Al and Larry-
Below are a couple of briefing papers for ERCOT's visit tomorrow afternoon.
Claudia
----- Forwarded by Claudia Hosch/R6/USEPA/US on 09/01/2011 03:25 PM -----
From: Isaac Chen/R6/USEPA/US
To: Claudia Hosch/R6/USEPA/US@EPA
Cc: Brent Larsen/R6/USEPA/US@EPA
Date: 09/01/2011 03:11 PM
Subject: Fw: ERCOT REVIEWS IMPACT OF FEDERAL ENVIRONMENTAL REGULATIONS - June 2011 Newsletter
article
Claudia,
Here is the revised briefing paper to be sent to Al, Larry and Rob- please see Miguel's email
below. Thanks!
(See attached file: we_care_briefing_090111.doc) (See attached file: factsheet_proposed.pdf)
----- Forwarded by Isaac Chen/R6/USEPA/US on 09/01/2011 02:08 PM -----
From: Brent Larsen/R6/USEPA/US
To: Isaac Chen/R6/USEPA/US@EPA
Date: 08/29/2011 03:31 PM
Subject: Fw: ERCOT REVIEWS IMPACT OF FEDERAL ENVIRONMENTAL REGULATIONS - June 2011 Newsletter
article
Isaac:
Need a Briefing Sheet in Official Format addressing the 316(b) issues we talked about last week.
Can you have it ready by COB Wednesday?
Takk,
Brent Larsen
Chief
Permits and Technical Assistance Section (6WQ-PP)
NPDES Permits & TMDLs Branch
EPA Region 6
1445 Ross Ave., Suite 1200
Dallas, TX 75202
214-665-7523
FAX 214-665-2191
larsen.brent@epa.gov
(See attached file: we_care_briefing_template.doc)
----- Forwarded by Brent Larsen/R6/USEPA/US on 08/29/2011 03:23 PM -----
From: Miguel Flores/R6/USEPA/US
To: Troy Hill/R6/USEPA/US@EPA, Claudia Hosch/R6/USEPA/US@EPA, Larsen.Brent@epamail.epa.gov
Cc: Rob Lawrence/R6/USEPA/US@EPA
Date: 08/29/2011 03:00 PM
Subject: Fw: ERCOT REVIEWS IMPACT OF FEDERAL ENVIRONMENTAL REGULATIONS - June 2011 Newsletter
article
Al will be meeting with ERCOT folks this Friday, and one of the major issues they've raised
(attached) is the costs of complying with 316(b) regs due to requirement for closed-loop systems.
Please prepare something for him that responds to the claims in this report and forward to him,
Larry and Rob Lawrence. Thanks,
Miguel
MIGUEL I. FLORES
Director, Water Quality Protection Division
U.S EPA, Region 6 (6WQ)
1445 Ross Avenue
Dallas, TX 75202-2733
214-665-7101 -- 214-665-7373 (FAX) -- 214-789-1818 (Cell)
----- Forwarded by Miguel Flores/R6/USEPA/US on 08/29/2011 02:58 PM -----
From: Rob Lawrence/R6/USEPA/US
To: Brent Larsen/R6/USEPA/US@EPA, Isaac Chen/R6/USEPA/US@EPA, Miguel Flores/R6/USEPA/US@EPA
Date: 08/25/2011 10:20 AM
Subject: Fw: ERCOT REVIEWS IMPACT OF FEDERAL ENVIRONMENTAL REGULATIONS - June 2011
Newsletter article
Brent - here is the ERCOT press release and their analysis. The RA is to have a meeting with the
Chair of ERCOT and the executive director sometime next week - last I heard it was on Wednesday or
Thursday. One of the critical points made in the analysis is the perceived belief that CWA 316b
applies to all facilities and would require substantial investments. Appendix A has a plant-by-
plant analysis. The worse case scenario is captured in the footnote at the bottom of the
Appendix.
Based on a regulatory scenario that would require all lignite-fired coal plants to have a wet
limestone scrubber, selective non-catalytic reduction, a baghouse with activated carbon injection,
and a closed-loop cooling tower system; all sub-bituminous coal plants required to have dry
sorbent injection, a baghouse with activated carbon injection, and a closed-loop cooling tower
system.
Rob Lawrence
Senior Policy Advisor - Energy Issues
lawrence.rob@epa.gov
214.665.6580 (Desk)
214.665.7263 (FAX)
----- Forwarded by Rob Lawrence/R6/USEPA/US on 08/25/2011 10:15 AM -----
From: Rob Lawrence/R6/USEPA/US
To: Carl Edlund/R6/USEPA/US@EPA
Cc: James Yarbrough/R6/USEPA/US@EPA
Date: 06/27/2011 01:09 PM
Subject: Fw: ERCOT REVIEWS IMPACT OF FEDERAL ENVIRONMENTAL REGULATIONS - June 2011
Newsletter article
I suspect that this article captures the information raised at the PUC meeting for which Platts
Energy is seeking an EPA response.
Rob Lawrence
Senior Policy Advisor - Energy Issues
lawrence.rob@epa.gov
214.665.6580 (Desk)
214.665.7263 (FAX)
----- Forwarded by Rob Lawrence/R6/USEPA/US on 06/27/2011 01:07 PM ----- From: David
Gray/R6/USEPA/US
To: Lawrence.Rob@epamail.epa.gov
Date: 06/07/2011 07:53 AM
Subject: ERCOT REVIEWS IMPACT OF FEDERAL ENVIRONMENTAL REGULATIONS - June 2011 Newsletter article
ERCOT REVIEWS IMPACT OF FEDERAL
ENVIRONMENTAL REGULATIONS
ERCOT has released an evaluation of the potential
impacts of proposed environmental regulations on
generation facilities in ERCOT, as requested by the
chairman of the Public Utility Commission in
December 2010.
The study looked at four potential rule changes:
Clean Water Act Section 316(b), regarding
new requirements for cooling-water intake
structures;
Clean Air Act new emission limits for
hazardous air pollutants;
Clean Air Transport Rule;
Coal Combustion Residuals Disposal regulations.
The 21-page report, Review of the Potential
Impacts of Proposed Environmental Regulations on
the ERCOT System, is available at www.ercot.com
in the News/Reports and Presentations section
under Operations and System Planning. (ATTACHED)
Some conclusions from the analysis include:
A significant amount of coal-fired generation is
unlikely to be retired, based on currently
available information regarding compliance
requirements, unless several factors such as low
natural gas prices and carbon emission fees
combine to reduce the economic viability of
these units.
Older gas steam units that are subject to retrofit
requirements are more likely to be retired.
Closed-loop cooling tower requirements
proposed as changes to the Clean Water Act are
likely to result in the retirement of more than
8,000 megawatts (MW) of gas-fired generation,
with a majority of these units being located in or
near Dallas/Fort Worth and Houston. Without
addi t ional replacement generat ion, the
retirement of this gas-fired generation would
reduce generation reserve margins to below 2
percent in 2015.
Development of new gas-fired peaking capacity
may require sufficient hours of scarcity pricing
to justify new investment and sufficient lead
time for favorable market conditions to become
apparent.
Preliminary analysis indicates that the loss of
gas-fired generation would impact transmission
reliability in the Houston and Dallas/Fort Worth
areas. Redevelopment of existing generation
sites in these urban areas with new generating
units could reduce or delay the need for
additional transmission infrastructure and would
likely lead to substantial savings to the overall
ERCOT system.
[attachment "ERCOT_Review_EPA_Planning_Final.pdf" deleted by Miguel Flores/R6/USEPA/US]
[attachment "we_care_briefing_090111.doc" removed by Al Armendariz/R6/USEPA/US]
[attachment "factsheet_proposed.pdf" removed by Al Armendariz/R6/USEPA/US]
[attachment "we_care_briefing_template.doc" removed by Al Armendariz/R6/USEPA/US]
From: Claudia Hosch
To: Al Armendariz; Lawrence Starfield
Cc: J oyce Runyan; Miguel Flores; Stacey Dwyer; William Honker; Brent Larsen; Isaac Chen; Rob Lawrence
Subject: Briefing paper - ERCOT visit tomorrow
Date: 09/01/2011 04:29 PM
Attachments: we care briefing 090111.doc
factsheet proposed.pdf
we care briefing template.doc
Al and Larry-
Below are a couple of briefing papers for ERCOT's visit tomorrow afternoon.
Claudia
----- Forwarded by Claudia Hosch/R6/USEPA/US on 09/01/2011 03:25 PM -----
From: Isaac Chen/R6/USEPA/US
To: Claudia Hosch/R6/USEPA/US@EPA
Cc: Brent Larsen/R6/USEPA/US@EPA
Date: 09/01/2011 03:11 PM
Subject: Fw: ERCOT REVIEWS IMPACT OF FEDERAL ENVIRONMENTAL REGULATIONS -
J une 2011 Newsletter article
Claudia,
Here is the revised briefing paper to be sent to Al, Larry and Rob- please see
Miguel's email below. Thanks!
----- Forwarded by Isaac Chen/R6/USEPA/US on 09/01/2011 02:08 PM -----
From: Brent Larsen/R6/USEPA/US
To: Isaac Chen/R6/USEPA/US@EPA
Date: 08/29/2011 03:31 PM
Subject: Fw: ERCOT REVIEWS IMPACT OF FEDERAL ENVIRONMENTAL REGULATIONS -
J une 2011 Newsletter article
Isaac:
Need a Briefing Sheet in Official Format addressing the 316(b) issues we talked
about last week. Can you have it ready by COB Wednesday?
Takk,
Brent Larsen
Chief
Permits and Technical Assistance Section (6WQ-PP)
NPDES Permits & TMDLs Branch
EPA Region 6
1445 Ross Ave., Suite 1200
Dallas, TX 75202
214-665-7523
FAX 214-665-2191
larsen.brent@epa.gov
----- Forwarded by Brent Larsen/R6/USEPA/US on 08/29/2011 03:23 PM -----
From: Miguel Flores/R6/USEPA/US
To: Troy Hill/R6/USEPA/US@EPA, Claudia Hosch/R6/USEPA/US@EPA,
Larsen.Brent@epamail.epa.gov
Cc: Rob Lawrence/R6/USEPA/US@EPA
Date: 08/29/2011 03:00 PM
Subject: Fw: ERCOT REVIEWS IMPACT OF FEDERAL ENVIRONMENTAL REGULATIONS -
J une 2011 Newsletter article
Al will be meeting with ERCOT folks this Friday, and one of the major issues they've
raised (attached) is the costs of complying with 316(b) regs due to requirement for
closed-loop systems. Please prepare something for him that responds to the claims
in this report and forward to him, Larry and Rob Lawrence. Thanks,
Miguel
MIGUEL I. FLORES
Director, Water Quality Protection Division
U.S EPA, Region 6 (6WQ)
1445 Ross Avenue
Dallas, TX 75202-2733
214-665-7101 -- 214-665-7373 (FAX) -- 214-789-1818 (Cell)
----- Forwarded by Miguel Flores/R6/USEPA/US on 08/29/2011 02:58 PM -----
From: Rob Lawrence/R6/USEPA/US
To: Brent Larsen/R6/USEPA/US@EPA, Isaac Chen/R6/USEPA/US@EPA, Miguel Flores/R6/USEPA/US@EPA
Date: 08/25/2011 10:20 AM
Subject: Fw: ERCOT REVIEWS IMPACT OF FEDERAL ENVIRONMENTAL REGULATIONS - J une 2011 Newsletter article
Brent - here is the ERCOT press release and their analysis. The RA is to have a
meeting with the Chair of ERCOT and the executive director sometime next week -
last I heard it was on Wednesday or Thursday. One of the critical points made in
the analysis is the perceived belief that CWA 316b applies to all facilities and would
require substantial investments. Appendix A has a plant-by-plant analysis. The
worse case scenario is captured in the footnote at the bottom of the Appendix.
Based on a regulatory scenario that would require all lignite-fired coal plants to
have a wet limestone scrubber, selective non-catalytic reduction, a baghouse with
activated carbon injection, and a closed-loop cooling tower system; all sub-
bituminous coal plants required to have dry sorbent injection, a baghouse with
activated carbon injection, and a closed-loop cooling tower system.
Rob Lawrence
Senior Policy Advisor - Energy Issues
lawrence.rob@epa.gov
214.665.6580 (Desk)
214.665.7263 (FAX)
----- Forwarded by Rob Lawrence/R6/USEPA/US on 08/25/2011 10:15 AM -----
From: Rob Lawrence/R6/USEPA/US
To: Carl Edlund/R6/USEPA/US@EPA
Cc: J ames Yarbrough/R6/USEPA/US@EPA
Date: 06/27/2011 01:09 PM
Subject: Fw: ERCOT REVIEWS IMPACT OF FEDERAL ENVIRONMENTAL REGULATIONS - J une 2011 Newsletter article
I suspect that this article captures the information raised at the PUC meeting for
which Platts Energy is seeking an EPA response.
Rob Lawrence
Senior Policy Advisor - Energy Issues
lawrence.rob@epa.gov
214.665.6580 (Desk)
214.665.7263 (FAX)
----- Forwarded by Rob Lawrence/R6/USEPA/US on 06/27/2011 01:07 PM -----
From: David Gray/R6/USEPA/US
To: Lawrence.Rob@epamail.epa.gov
Date: 06/07/2011 07:53 AM
Subject:
ERCOT REVIEWS IMPACT OF FEDERAL ENVIRONMENTAL REGULATIONS - J une 2011 Newsletter article
ERCOT REVIEWS IMPACT OF FEDERAL
ENVIRONMENTAL REGULATIONS
ERCOT has released an evaluation of the potential
impacts of proposed environmental regulations on
generation facilities in ERCOT, as requested by the
chairman of the Public Utility Commission in
December 2010.
The study looked at four potential rule changes:
Clean Water Act Section 316(b), regarding
new requirements for cooling-water intake
structures;
Clean Air Act new emission limits for
hazardous air pollutants;
Clean Air Transport Rule;
Coal Combustion Residuals Disposal regulations.
The 21-page report, Review of the Potential
Impacts of Proposed Environmental Regulations on
the ERCOT System, is available at www.ercot.com
in the News/Reports and Presentations section
under Operations and System Planning. (ATTACHED)
Some conclusions from the analysis include:
A significant amount of coal -fired generation is
unlikely to be retired, based on currently
available information regarding compliance
requirements, unless several factors such as low
natural gas prices and carbon emission fees
combine to reduce the economic viability of
these units.
Older gas steam units that are subject to retrofit
requirements are more likely to be retired.
Closed-loop cooling tower requirements
proposed as changes to the Clean Water Act are
likely to result in the retirement of more than
8,000 megawatts (MW) of gas-fired generation,
with a majority of these units being located in or
near Dallas/Fort Worth and Houston. Without
addi t ional replacement generat ion, the
retirement of this gas-fired generation would
reduce generation reserve margins to below 2
percent in 2015.
Development of new gas-fired peaking capacity
may require sufficient hours of scarcity pricing
to justify new investment and sufficient lead
time for favorable market conditions to become
apparent.
Preliminary analysis indicates that the loss of
gas-fired generation would impact transmission
reliability in the Houston and Dallas/Fort Worth
areas. Redevelopment of existing generation
sites in these urban areas with new generating
units could reduce or delay the need for
additional transmission infrastructure and would
likely lead to substantial savings to the overall
ERCOT system.
[attachment "ERCOT_Review_EPA_Planning_Final.pdf" deleted by Miguel
Flores/R6/USEPA/US]
From: Al Armendariz
To: Mann, Chrissy; Mansuri, Layla
Subject: EPA Urged to Apply New Mexico Coal-Plant Pollution Limits in Nevada
Date: 08/27/2011 08:27 PM
ripple effects --
Al
------------------------
EPA Urged to Apply New Mexico Coal-Plant Pollution Limits in Nevada
August 25, 2011
LAS VEGAS - It's now up to the Environmental Protection Agency to decide what
kind of pollution limits the Reid Gardner coal-burning power plant must meet to
protect air quality for southern Nevada and neighboring states.
The Moapa Paiute tribe is located a couple hundred yards from the plant. In
comments to the EPA this week, tribal chairman William Anderson said people in
Nevada would be a lot safer if the power plant had to meet the same kind of
pollution limits that are the law of the land for a similar plant in New Mexico.
"The EPA in that region was able to go ahead and have them cut down their
emissions 90 percent. For the Region Nine area, like here in the state of Nevada,
they are trying to only reduce it to like 40 percent."
When pollution-related health costs for his tribe and neighbors in the region are
tallied, Anderson says, the price tag totals $28 million a year.
"Too many of our children here have asthma. Too many have respiratory illnesses.
For some people that are close by, it is dangerous to be outside. Some of our elders
say they can feel their skin burn on certain days."
The plant was built in the 1960s and the state is requesting pollution controls that
would drop emissions by 40 percent. Anderson says the EPA made the right move
with the San J uan Generating Station in New Mexico, and that if those controls were
put in place in Nevada they would cut nitrogen oxide pollution by 90 percent.
Plant owner NV Energy says pollution limits at the 40 percent level meet current
Clean Air Act requirements and are more affordable. Anderson says Reid Gardner
emits more than 4,000 tons of nitrogen oxide pollution each year, which he says
creates a hazardous haze that impacts not only his tribe but also residents of
southern Nevada, Utah and Arizona.
Mike Clifford/Dallas Heltzell, Public News Service - NV

Copyright 2011 Public News Service

http://www.publicnewsservice.org/index.php?/content/article/21873-
1&utm_source=twitterfeed&utm_medium=twitter

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: Al Armendariz
To: Blumenfeld, J ared; McCarthy, Gina; Depass, Michelle
Subject: EPA Urged to Apply New Mexico Coal-Plant Pollution Limits in Nevada
Date: 08/25/2011 10:38 PM
In case you haven't seen.
Al
http://www.publicnewsservice.org/index.php?/content/article/21873-
1&utm_source=twitterfeed&utm_medium=twitter
August 25, 2011
LAS VEGAS - It's now up to the Environmental Protection Agency to decide what
kind of pollution limits the Reid Gardner coal-burning power plant must meet to
protect air quality for southern Nevada and neighboring states.
The Moapa Paiute tribe is located a couple hundred yards from the plant. In
comments to the EPA this week, tribal chairman William Anderson said people in
Nevada would be a lot safer if the power plant had to meet the same kind of
pollution limits that are the law of the land for a similar plant in New Mexico.
"The EPA in that region was able to go ahead and have them cut down their
emissions 90 percent. For the Region Nine area, like here in the state of Nevada,
they are trying to only reduce it to like 40 percent."
When pollution-related health costs for his tribe and neighbors in the region are
tallied, Anderson says, the price tag totals $28 million a year.
"Too many of our children here have asthma. Too many have respiratory illnesses.
For some people that are close by, it is dangerous to be outside. Some of our elders
say they can feel their skin burn on certain days."
The plant was built in the 1960s and the state is requesting pollution controls that
would drop emissions by 40 percent. Anderson says the EPA made the right move
with the San J uan Generating Station in New Mexico, and that if those controls were
put in place in Nevada they would cut nitrogen oxide pollution by 90 percent.
Plant owner NV Energy says pollution limits at the 40 percent level meet current
Clean Air Act requirements and are more affordable. Anderson says Reid Gardner
emits more than 4,000 tons of nitrogen oxide pollution each year, which he says
creates a hazardous haze that impacts not only his tribe but also residents of
southern Nevada, Utah and Arizona.
Mike Clifford/Dallas Heltzell, Public News Service - NV

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: Al Armendariz
To: Mann, Chrissy; Mansuri, Layla
Subject: Fw: Fw: AEP Plans
Date: 08/25/2011 06:54 PM
Things moving fast in Oklahoma. Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 08/25/2011 07:53 PM EDT
To: Carl Edlund; Lawrence Starfield
Cc: "Armendariz, Al" <Armendariz.Al@epa.gov>; "Murray,
Suzanne" <murray.suzanne@epa.gov>
Subject: Re: Fw: AEP Plans
Thanks Carl.
Yes, let's talk to ODEQ about these plans.
Certainly will put OG&E in a bit of a box, if AEP decides to comply
instead of fight.
Thanks
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
Carl Edlund
----- Original Message -----
From: Carl Edlund
Sent: 08/25/2011 07:48 PM EDT
To: Lawrence Starfield
Cc: "Al Armendariz" <armendariz.al@epa.gov>; "Suzanne Murray"
<murray.suzanne@epa.gov>
Subject: FW: Fw: AEP Plans
FYI ....things we may wish to discuss with ODEQ
Sent with Good (www.good.com)
----- Forwarded by Carl Edlund/R6/USEPA/US on 08/25/2011 07:48:12 PM-----
-------- Original Message --------
From : J oe Kordzi/R6/USEPA/US
To : Guy Donaldson/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA,
Carl Edlund/R6/USEPA/US@EPA
Cc : Lea Anderson/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA,
Todd Hawes/RTP/USEPA/US@EPA
Sent on : 08/25/2011 09:08:14 AM
Subject : Fw: AEP Plans
fyi - this is definitely a good sign that AEP has already conceded that they will install
scrubbers. This covers 2 of the 6 units of our OK FIP - the remaining 4 being the
OG&E units at Sooner and Muskogee. Maybe this takes some steam out of the OK
AG's suit.
"The two coal-fueled generating units at the Northeastern Plant (935 MW) in Oolagah, OK,
would be idled for a year or more while FGD equipment is installed. Both units would be
idled beginning Jan. 1, 2016. One unit would return to service by Dec. 31, 2016. The other
unit would return to service by Dec. 31, 2017."
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
----- Forwarded by J oe Kordzi/R6/USEPA/US on 08/25/2011 08:01 AM -----
From: Phyllis Fox <phyllisfox@gmail.com>
To: J oe Kordzi/R6/USEPA/US@EPA
Date: 08/24/2011 05:07 PM
Subject: AEP Plans
Scrubbers planned for Northeastern.
[attachment "AEP Retirement Plans FGD and DeNOx 7-11.doc" deleted
by Al Armendariz/R6/USEPA/US]
From: Carl Edlund
To: Lawrence Starfield
Cc: Al Armendariz; Suzanne Murray
Subject: FW: Fw: AEP Plans
Date: 08/25/2011 06:48 PM
Attachments: AEP Retirement Plans FGD and DeNOx 7-11.doc
FYI ....things we may wish to discuss with ODEQ
Sent with Good (www.good.com)
----- Forwarded by Carl Edlund/R6/USEPA/US on 08/25/2011 07:48:12 PM-----
-------- Original Message --------
From : J oe Kordzi/R6/USEPA/US
To : Guy Donaldson/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA,
Carl Edlund/R6/USEPA/US@EPA
Cc : Lea Anderson/DC/USEPA/US@EPA, Geoffrey Wilcox/DC/USEPA/US@EPA,
Todd Hawes/RTP/USEPA/US@EPA
Sent on : 08/25/2011 09:08:14 AM
Subject : Fw: AEP Plans
fyi - this is definitely a good sign that AEP has already conceded that they will install
scrubbers. This covers 2 of the 6 units of our OK FIP - the remaining 4 being the
OG&E units at Sooner and Muskogee. Maybe this takes some steam out of the OK
AG's suit.
"The two coal-fueled generating units at the Northeastern Plant (935 MW) in Oolagah, OK,
would be idled for a year or more while FGD equipment is installed. Both units would be
idled beginning Jan. 1, 2016. One unit would return to service by Dec. 31, 2016. The other
unit would return to service by Dec. 31, 2017."
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
----- Forwarded by J oe Kordzi/R6/USEPA/US on 08/25/2011 08:01 AM -----
From: Phyllis Fox <phyllisfox@gmail.com>
To: J oe Kordzi/R6/USEPA/US@EPA
Date: 08/24/2011 05:07 PM
Subject: AEP Plans
Scrubbers planned for Northeastern.
From: Al Armendariz
To: mansuri.layla@epa.gov; mann.chrissy@epa.gov
Subject: regional haze
Date: 08/24/2011 02:01 PM
Daily News
Industry Pushes Transport Rule As Utility Compliance For
State Haze Plans
Posted: August 23, 2011
Industry is pushing EPA to find that states can rely on the agency's final cap-and-trade rule to cut power plant
emissions as an adequate emissions control measure for meeting the requirements of EPA's regional haze
program, but the agency is yet to decide on whether the transport rule can be seen as compliance with the haze
program.
EPA's haze program aims to cut pollution from power plants and other sources to improve visibility in national
parks and wilderness areas. States subject to the program must craft state implementation plans (SIPs) outlining
the best available retrofit technology (BART) emissions controls they will impose on industry to comply with the
rule. States have wide discretion in choosing BART, but EPA must give its final approval to whatever states
choose.
The haze program has been in place for several years and during the Bush administration, EPA said that its
Clean Air Interstate Rule (CAIR) trading rule to cut power plant emissions could qualify as BART. Any of the 31
states subject to CAIR could simply cite their obligations under CAIR as BART for power plants in the haze
program.
It is unclear how many states relied on CAIR in their haze SIPs, and several states are overdue in submitting
their plans to EPA. Environmentalists have filed lawsuits seeking final action on haze SIPs (see related story).
The U.S. Court of Appeals for the District of Columbia Circuit in a 2008 ruling remanded CAIR back to EPA,
finding fault with its trading program for nitrogen oxide (NOx) and sulfur dioxide (SO2) emissions. The Obama
EPA subsequently issued in July its Cross-State Air Pollution Rule (CSAPR) replacement trading program for
utilities.
EPA is performing a technical analysis that will determine whether the 27 states subject to CSAPR can rely on
that rule to qualify as BART for power plants and other sources in their haze SIPs. "We are anticipating [in] any
decision on this matter EPA will provide a period for public review and comment," says a Pennsylvania air
regulator.
But the American Coalition for Clean Coal Electricity (ACCCE), representing coal -burning utilities, coal producing
companies, railroads and associated industries, is pushing EPA to find that CSAPR is BART for haze.
If EPA finds that CSAPR is BART that could ease pressure on state regulators to identify BART for utilities, and
help utilities avoid additional emissions controls beyond those necessary to comply with CSAPR.
Some environmentalists however have previously questioned the use of a trading program to meet emissions
control requirements in state air quality plans, because cap-and-trade allows facilities to decide between
investing in pollution controls or buying credits to comply with the trading program's overall pollution cap.
BART Requirements
ACCCE in July 18 comments on a proposed EPA partial disapproval of Tennessee's haze SIP published in the
June 9 Federal Register urges EPA to "move expeditiously to assess" whether the emissions cuts CSAPR will
achieve will be sufficient to satisfy BART control requirements for electric generating units (EGUs) under the
regional haze program.
"Since, as EPA states, the Cross-State Air Pollution Rule will achieve emission reductions equal to or greater
than under the [CAIR], the results of such assessment should enable EPA to find that compliance with the Cross-
State Air Pollution Rule satisfies EGU BART requirements," ACCCE adds. The group notes that EPA
disapproves part of the Tennessee SIP on the grounds that the state would rely on CAIR for BART after the CAIR
trading program sunsets at the end of 2011, a common failing among states that relied on CAIR to satisfy BART
requirements.
In its proposed SIP disapproval, EPA said it may be necessary to wait until regular five-year reviews are
completed to assess the impact of the final CSAPR, then known as the "Transport Rule," in order to assess the
impact on individual Class I areas, which includes national parks and wilderness areas with pristine air quality
levels.
ACCCE urges EPA not to wait this long. "Waiting five years to perform this assessment creates a great deal of
uncertainty as to whether EGUs will be subject to control requirements for regional haze that are additional not
only to the Cross-State Air Pollution Rule but to other EPA power sector regulations as well," the group says.
In the final CSAPR, EPA says it may not wait five years to determine BART eligibility. "In this final action, EPA
has not conducted any technical analysis to determine whether compliance with the Transport Rule would satisfy"
either haze BART requirements or could qualify as reasonably available control technology (RACT) -- the level of
pollution control required in areas out of attainment with the agency's national ambient air quality standards.
"For that reason, EPA is neither making determinations nor establishing any presumptions that compliance with
the Transport Rule satisfies any RACT or BART-related requirements for EGUs," the agency says.
EPA in CSAPR adds that it "intends to undertake a separate analysis to determine if compliance with the
Transport Rule would provide sufficient reductions to satisfy BART requirements for EGUs."
New Jersey Plan
In a related development, EPA Aug. 11 proposed to approve New Jersey's regional haze SIP. The state was
included in CAIR and is also subject to CSAPR for both NOx and SO2 emissions trading.
New Jersey's SIP includes specific emissions limits under BART and emissions control requirements including
selective catalytic reduction (SCR). "Although New Jersey was subject to CAIR, its regional haze SIP did not rely
on CAIR to meet the requirements for BART or for attaining the in-state emissions reductions necessary to
ensure reasonable progress, instead, New Jersey evaluated controls for its potential BART sources," EPA says
in its proposal.
New Jersey facilities eligible for BART are already subject to other emissions control programs and/or consent
decrees with EPA that impose a range of emissions limits and various control technologies in addition to SCR,
specific to each facility, which also include low NOx burners, flue gas desulfurization and new bag house air
pollution control systems for particulate matter reduction, according to EPA's proposed approval. -- Stuart
Parker (sparker@iwpnews.com)
http://insideepa.com/201108232373598/EPA-Daily-News/Daily-News/industry-pushes-
transport-rule-as-utility-compliance-for-state-haze-plans/menu-id-95.html
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
From: Layla Mansuri
To: Al Armendariz
Cc: gray.david@epa.gov; Lawrence Starfield; Chrissy Mann
Subject: Inside EPA article on Haze
Date: 08/24/2011 11:45 AM
Activists Claim Success In Fights With
States, EPA For Strict Haze Plans
Posted: August 23, 2011
Environmentalists are claiming early success in their ongoing fights with states and EPA to try and
force stringent emissions control plans for meeting the agency's regional haze program
requirements, noting administrative and legal wins in their attempts to strengthen the haze planning
process that they say is proceeding too slowly.
In two new legal agreements EPA is committing to binding schedules for taking action on either
approving or rejecting pending haze plans from Colorado, Montana, Wyoming, North Dakota and
Arkansas.
The agency has also unveiled its first final federal implementation plan (FIP) to directly take over
haze emissions controls planning in a state, which will force pollution cuts from a large coal-fired
power plant in New Mexico. Activists say the FIP will impose strict controls that should serve as
an example for other haze air quality plans, either through state implementation plans (SIPs) for
haze or FIPs, which EPA can impose if it finds a SIP inadequate.
EPA's regional haze program aims to eliminate by 2064 view-obscuring haze in "Class I" areas --
national parks and wilderness areas -- caused by air pollution. States were due to submit haze SIPs
that EPA could approve or reject by Dec. 17, 2007, but many states failed to submit plans on time,
or the agency failed to take action on SIPs. That prompted environmentalists to file lawsuits trying
to force legally binding deadlines for action on haze plans.
In response to one of those lawsuits, EPA and WildEarth Guardians submitted a settlement
agreement to the U.S. District Court for the District of Colorado Aug. 12 to resolve the
environmental group's claims that the agency has failed to act on a Clean Air Act requirement to
decide on several states' regional haze plans.
In the settlement EPA agrees to activist demands to take final action to approve or disapprove
Colorado's regional haze program by Sept. 10, 2012, and sets deadlines for final action on air
quality plans from Montana, Wyoming and North Dakota, all states where activists say regional
haze SIPs or FIPs are long overdue.
"Today's action is a positive step towards clearing the air in Colorado's front range," said Pamela
Campos, an attorney for the Environmental Defense Fund, one of the litigants in the case,
WildEarth Guardians v. EPA, in an Aug. 15 statement.
For Wyoming, EPA would issue a proposed rule to approve or disapprove the SIP by April 15,
2012, with a final rule to follow by Oct. 15 of that year. For Montana, the dates would be Jan 20,
2012 for a proposed SIP rule and June 29, 2012 for the final rule. For Colorado, EPA would
propose a haze SIP rule by March 8, 2012, and a final rule by Sept. 10, 2012.
EPA in its Aug. 12 motion to submit the decree notes opposition from industry, North Dakota and
Montana because of their belief that the deadlines for EPA actions addressing regional haze
implementation deadlines are unreasonable. However, the agency says that that since the deadlines
imposed are years later than they should have been under the air law, they are consistent with the
air act. "EPA believes the agreed dates are practical and can be met."
EPA also rejects claims by North Dakota and others that the court lacks jurisdiction over
environmentalists' claims in the haze suit, that EPA must first act on SIPs before issuing FIPs, and
that the agency does not have a non-discretionary duty to promulgate FIPs to meet regional haze
implementation requirements.
Non-Discretionary Duty
Under citizen suit provisions of the air act, EPA argues, there is no obligation for parties to file a
notice of intent to sue and give 180 days' notice before suing, as they would in a case alleging
"unreasonable delay" by EPA, because this case alleges EPA's failure to perform a non-
discretionary duty, requiring only 60 day's notice to the agency.
The agency also says it does have a non-discretionary duty to act under the haze program, and the
court has the proper jurisdiction to hear such a case. EPA also says the agency does not under the
air act have to disapprove recently-submitted SIPs before imposing a FIP if states are far behind
schedule in providing their SIP.
Meanwhile, Sierra Club and EPA Aug. 3 reached a settlement in a separate suit seeking a final
decision on Arkansas' haze SIP. Under the deal, EPA will issue a final decision by Dec. 15. A
Sierra Club source says the agreement, filed with the U.S. District Court for the District of
Columbia, is crucial to roll back industrial pollution in the state. The proposed consent decree is
slated for publication in the Federal Register Aug. 17.
EPA missed a mandatory deadline of March 22 to approve or disapprove Arkansas' SIP, the Sierra
Club source says. The source says that this meant the plan was not federally enforceable and was
too weak, because industry lobbied successfully to have the plan's implementation date of October
15, 2013 pushed back, in effect, indefinitely. Under a "variance" granted by state authorities, the
SIP should now be implemented "as expeditiously as practicable, but in no event later than five
years after EPA approval of the Arkansas regional haze SIP." Therefore, if the EPA never takes
action on the SIP, there would never be an effective state deadline, the source says.
The plan would set emissions limits on one power plant -- the White Bluff coal plant owned by
American Electric Power subsidiary Southwestern Electric Power Company. The Sierra Club
source says "we think it is extremely historic and significant," but says the group will reserve
judgment pending EPA's final decision.
Environmentalists are also welcoming EPA's announcement Aug. 5 of its first final FIP for
regional haze that will impose best available retrofit technology (BART) emissions control
requirements on the San Juan Generating Station in New Mexico, a coal-fired power plant blamed
by activists and the agency for much of the state's pollution contributing to haze in Mesa Verde
National Park and other federally protected areas.
EPA acted to impose controls on the plant after state efforts to impose BART on the facility fell
through following a switch to a Republican administration in the state last year. The EPA plan
calls for installation of selective catalytic reduction (SCR), an expensive technology for reducing
emissions of nitrogen oxides.
A source with WildEarth Guardians, which sued EPA to take action over the state's missing haze
SIP and subsequently reached a settlement agreement on the issue with the agency earlier this year,
says the FIP is reassuringly tough, setting an emissions rate control "that is pretty strong."
Although the FIP will not set the bar for every BART determination in the future, "it will strongly
influence what other states do," the activist says.
The imposition of SCR is significant, the activist says, noting that it goes beyond a proposal by the
San Juan plant's owner, PNM, to impose non-catalytic reduction technology, a less expensive but
less effective option, instead. "We are expecting other haze FIPs, both for Montana and North
Dakota," the source notes.
Oklahoma FIP
EPA also proposed in March to impose a haze FIP on Oklahoma, prompting legal action by the
state to head this off. The agency says the state's SIP is deficient because although it would
drastically cut emissions by switching coal plants to natural gas fuels, it would do so too slowly to
meet mandatory air act deadlines, EPA has said. But that plan is still at the proposed stage,
whereas the New Mexico FIP is the first final agency action on a haze FIP, sources say.
Oklahoma is suing EPA in the U.S. District Court for the Western District of Oklahoma to try and
block EPA from pursuing and implementing the FIP, claiming that EPA has missed its own
statutory deadlines for imposing a FIP and urging the court to block the agency from taking further
steps to implement the FIP. The state argues that when EPA in a Jan. 15, 2009, rule found that
Oklahoma and 36 other states failed to submit a haze SIP for review, that triggered a two-year
window for the agency to impose FIPs on those states, a deadline Oklahoma says EPA missed.
"EPA should be enjoined from taking any further action with respect to the proposed regional haze
FIP unless and until its proposed disapproval of portions of the Oklahoma regional haze SIP
becomes final," Oklahoma Attorney General E. Scott Pruitt (R) said at the time.
However, in a motion to dismiss the case July 22, EPA counters that "Jurisdiction to review any
challenge to the substance of EPA action under the [Clean Air] Act lies in the exclusive
jurisdiction of the courts of appeals. And, of course, it is a basic principle of administrative law
that such review must await final agency action. Thus, this court lacks jurisdiction over Plaintiff's
claims." -- Stuart Parker (sparker@iwpnews.com)
From: David Gray
To: Miguel Flores; Sam Coleman; David Gray; Carl Edlund; Carroll.Lynda@epamail.epa.gov; J ohn Blevins;
Knudson.Myron@epamail.epa.gov; Suzanne Murray/R6/USEPA/US@EPA; J eannine Hale/R6/USEPA/US@EPA; Al
Armendariz/R6/USEPA/US@EPA; Layla Mansuri
Subject: Region 6 Weekly Report August 15, 2011 [CONTAINS PREDECISION INFORMATION]
Date: 08/22/2011 08:51 AM
Region 6 Weekly Report August 15, 2011
[August 15 to August 29]
Contact: David Gray, 214-665-2200
SIGNIFICANT ACTIONS
NAACP - Dallas
On Tuesday, August 16, the Dallas Chapter of the NAACP and Hilton Kelly, an
environmental justice advocate, will hold a news conference to announce its opposition of the
City of Dallas proposal to divert all trash collected within the city limits to the city owned
McCommas Landfill in Southern Dallas. The association has sent a letter to Regional
Administrator of the U.S. Environmental Protection Agency requesting immediate assistance
in reviewing the citys Flow Control proposal. EPA is convening a meeting with Mr. Kelly
and City of Dallas officials later in the week.
Title V Petition New Mexico [PREDECISION INFORMATION]
On Wednesday, August 17, EPA will issue for publication in the Federal Register of the
Administrator decision to grant the petition, submitted by WildEarth Guardians and the San
Juan Citizens Alliance, to object to the March 19, 2010, operating permit issued to Williams
Four Corners, LLC, for the Sims Mesa Delivery Point compressor station in Rio Arriba
County, New Mexico. EPA received the petition dated April 14, 2010, requesting that EPA
object to the renewal of the Title V air permit. The notice will be published in the Federal
Register in about 10 days.
Baton Rouge Redesignation [PREDECISION INFORMATION]
On Thursday, August 18, EPA will proposal to redesignate the five-parish Baton Rouge non-
attainment area to attainment of the 1997 8-hour ozone standard. The area has been in non-
attainment of the ozone standard since it was first established in the 1970s. After publication
in the Federal Register, public comment will be accepted for 30 days. Interest has been high.
Gulf of Mexico Outer-continental Shelf Oil and Gas Lease Sales [PREDECISION
INFORMATION]
On Thursday, August 18, EPA will submit comments on the second draft Supplemental
Environmental Impact Statement (EIS) for the Central Planning Area lease sales, 216 and
222. This supplemental EIS documents changes to the baseline conditions for the offshore
marine environment and coastal parishes and counties of Mississippi, Louisiana, and
Alabama based on current information. EPA does not expect to raise significant issues in its
review of the EIS.
GRANT ANNOUNCEMENTS
None
LEGISLATIVE ENGAGEMENT
On Friday, August 19, Regional Administrator Armendariz and Superfund Director Sam
Coleman will meet with El Paso Mayor Cook, ASARCO trustee, and other local officials to
discuss the ASARCO clean-up activities and next steps. A group of former employees are
asking for more sampling to ensure what goes offsite will not contaminate other communities
and to potentially identify some of the components of materials that were potentially burned
illegally there.
TBD, Regional Administrator Armendariz and Frisco Mayor Maso will host a community
meeting to discuss the new NAAQS for lead, the states proposed lead non-attainment area
around the Exide plant, and the new secondary lead MACT and its impacts on the plant.
PUBLIC EVENTS
Dallas Council of Engineering Companies
On Monday, August 22, RA Armendariz will be speaking to the Dallas Council of
Engineering Companies in Dallas, TX. The Dallas Council of Engineering Companies
comprises leaders from more than 100 of the most prominent engineering firms in the Dallas
area. The group is part of the American Council of Engineering Companies, the largest
national organization of engineers engaged in the practice of consulting engineering.
Midland West County Road Superfund Site
On August 23, EPA will hold a community meeting to discuss recent sampling results at the
West County Road 112 Superfund site in Midland. The site is a ground water plume of
chromium/hexavalent chromium located in a rural area of Midland County, Texas. To date,
the Texas Commission on Environmental Quality (TCEQ) has sampled approximately 234
private water wells and 46 water wells have concentrations of total chromium above the
Maximum Contaminant Levels (MCLs) of 100 ppb. TCEQ has installed water filtration
systems at homes where total chromium has been detected above the MCLs. The site was
added to the NPL in March 2011.
OTHER ACTIVITIES
Haynesville Shale Hydraulic Fracturing
EPA has filed an administrative complaint against Camterra Resources, Inc. of Marshall,
Texas for violations of the Clean Water Act. Camterra constructs well pads for hydraulic
fracturing operations in the Haynesville Shale in Louisiana. Camterra Resources began filling
in 33 acres of wetlands in Caddo and DeSoto parishes, Louisiana in the fall months of 2008
without receiving authorization from the U.S. Army Corps of Engineers (COE). EPA has
notified the public of the filing of this complaint and has afforded the public 30 days to
comment on the complaint and on the proposed $67,200 fine. At the expiration of the public
notice period, EPA will consider any comments filed by the public and issue a final order.
From: Al Armendariz
To: Erik Snyder; Guy Donaldson
Subject: Fw: Review of Modeling in TX Regional Haze SIP
Date: 08/11/2011 12:07 PM
Attachments: Texas Regional Haze SIP Report - FINAL.pdf
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
-----Forwarded by Al Armendariz/R6/USEPA/US on 08/11/2011 11:07AM -----
To: Al Armendariz/R6/USEPA/US@EPA
From: Nathan Miller <nmiller@npca.org>
Date: 08/11/2011 10:59AM
Cc: Lawrence Starfield/R6/USEPA/US@EPA, Layla Mansuri/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA,
McCrystie Adams <madams@earthjustice.org>, Michael Hiatt <mhiatt@earthjustice.org>, Stephanie Kodish
<skodish@npca.org>, "digs.thomas@epa.gov" <digs.thomas@epa.gov>, Brian Tomasovic/R6/USEPA/US@EPA,
Chrissy Mann/R6/USEPA/US@EPA, Joe Kordzi/R6/USEPA/US@EPA, Agustin Carbo-Lugo/R6/USEPA/US@EPA,
Barbara Nann/R6/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA, Michael Feldman/R6/USEPA/US@EPA
Subject: Review of Modeling in TX Regional Haze SIP
(See attached file: Texas Regional Haze SIP Report - FINAL.pdf)
Al, Thank you again for meeting with us in June. As you know, the regional haze program is of
utmost importance to our organizations missions. We appreciate the great gains to be accomplished
from the recent San Juan decision, as well as forthcoming decisions. We value not only the
visibility improvement accomplished through these plans, but also the co-benefits of improved
health and economy, which provide even greater impetus for implementing the regional haze rule.
As promised at our June meeting, attached is the expert report which we commissioned from Air
Resource Specialists. During our discussion, based on this report and additional analysis, we
identified several overarching issues with the Texas Regional Haze plan submittal, including: -
Over-reliance on CSAPR (then CAIR/Transport) to prematurely exempt EGUs from BART-
Piecemeal analysis (pollutant-by-pollutant or park-by-park analysis that minimizes impacts)-
Inconsistent documentation and justification (sources that are unaccounted for; key parameters,
choices, or exemptions that are not explained or justified)- Use of artificially high
natural background visibility impairment Please feel free to contact us with any questions. We
look forward to being in touch with you more in the coming months. Sincerely, Nathan Miller
Nathan MillerAir Quality Analyst National Parks Conservation AssociationMidwest Regional Office8 S.
Michigan, Suite 2900Chicago, IL 60603P: 312.263.0111F: 312.263.0140C: 773.230.5823nmiller@npca.org
Protecting Our National Parks for Future Generations
From: Al Armendariz
To: J anet McCabe
Subject: Re: Greenwire: EPA orders N.M. coal plant to clear haze at parks
Date: 08/09/2011 09:27 AM
Thanks.

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
J anet McCabe
----- Original Message -----
From: Janet McCabe
Sent: 08/09/2011 10:20 AM EDT
To: Al Armendariz; Jim Martin
Subject: Fw: Greenwire: EPA orders N.M. coal plant to clear haze at
parks
fyi
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
----- Forwarded by J anet McCabe/DC/USEPA/US on 08/09/2011 10:19 AM -----
From: Andrea Drinkard/DC/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA, Lorie Schmidt/DC/USEPA/US@EPA
Cc: Sara Terry/RTP/USEPA/US@EPA, Don Zinger/DC/USEPA/US@EPA
Date: 08/09/2011 10:17 AM
Subject: Greenwire: EPA orders N.M. coal plant to clear haze at parks
Greenwire pretty much sums the state of play up in this article. Note the
forward looking paragraph towards the end of the article (in bold).
Apologies for the duplication if you've already seen this one.
Thanks!
-AD-
News Headline: AIR POLLUTION: EPA orders N.M. coal plant to clear
haze at parks |
Outlet Full Name: Greenwire
News Text: Taking an early step under a Clean Air Act program meant
to clean up the air at prized wilderness areas, U.S. EPA has come out
with a final plan for cutting air pollution at New Mexico's San Juan
Generating Station, an 1,800-megawatt coal plant that has been blamed
for haze in the Four Corners region.
EPA says the 1,800-megawatt plant, owned by Public Service Co. of New
Mexico, or PNM, causes an estimated 80 percent of the visibility problems
at Colorado's Mesa Verde National Park and some of the haze at other
nearby parks, including the Grand Canyon.
Overriding a plan that was approved by New Mexico officials, the final
rule released Friday afternoon sets emissions limits that would require
PNM to add selective catalytic reduction (SCR) systems to the boilers at
the plant. Those pollution controls, projected by EPA to cost about $345
million, could make an 80 percent cut in emissions of nitrogen oxides,
which cause haze, soot and smog.
The final rule hews closely to a proposal released in December (E&ENews
PM, Dec. 21, 2010).
The only major difference is that the final rule would give PNM five years
rather than three to add the pollution controls. Environmental groups,
which have filed a series of lawsuits to makeEPA come out with haze
plans, praised Friday's final rule despite that change.
"Because of the EPA and this plan, the people of and visitors drawn to
this region will be able to breathe easier and to see clearer the incredible
splendor of places like Mesa Verde and the Grand Canyon," said
Stephanie Kodish, clean air counsel at the National Parks Conservation
Association. "We look forward to the EPA's work in future months to
require similar pollution limits, which truly take the intent of the Clean Air
Act to heart, to additional power plants nationwide."
The power company vowed to challenge EPA's plan, saying it would pass
along unneeded costs to electricity customers. A plan that cleared the
New Mexico Environmental Improvement Board in June would have
allowed PNM to use selective non-catalytic reduction (SNCR), which is
usually about four to five times less expensive but is not as effective at
cutting emissions.
According to PNM, the SCR systems preferred by EPA would cost $750
million compared with $77 million for SNCR, raising electricity rates by 10
percent for the average residential customer.
"The EPA plan adds unnecessary costs to one of our lowest-cost sources
of reliable power," said Pat Themig, a vice president at the company, in a
statement. "If it stands, it will lead to significantly higher future electric
rates for the 2 million customers who rely on the plant for reasonably
priced power."
Friday's rule is an early sign of things to come as EPA moves
toward finalizing haze plans for every state, as the Clean Air Act
requires. The agency has proposed its own plan in Oklahoma after
deciding the state's plan would not do enough to cut emissions and
has signaled it will do the same in North Dakota.
It has gotten the attention of lawmakers on Capitol Hill, who say
that EPA shouldn't be rejecting state plans. If the House continues work
on EPA's budget after the August recess, Reps. Rick Berg (R-N.D.) and
James Lankford (R-Okla.) will be ready with amendments that would stop
the agency from imposing "one size fits all" haze rules, as Berg's office
put it.
Proposed decisions on plans for several hotly contested Western states,
such as Wyoming, are scheduled to follow this year and next under a
settlement with environmental groups. More settlements are likely to
follow, setting deadlines for other states (E&ENews PM, June 14).
Environmentalists, who have kept busy filing lawsuits to make EPA move
forward, want the agency to reject state plans that do not require the
technology that would do the best job of cutting haze. They say haze
isn't the only reason to add those controls.
According to an analysis by Abt Associates Inc. using EPA data, the soot
and smog from the San Juan Generation Station is responsible for 33
premature deaths, 50 nonfatal heart attacks, 600 asthma attacks and
more than 30 hospital admissions each year, passing along to the public
about $255 million in annual health costs.
Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 202.564.1601
Cell:
From: Al Armendariz
To: Laura Vaught
Subject: Re: Expect Coverage: PNM to Appeal Today's EPA Decision on San J uan
Date: 08/05/2011 04:11 PM
Thanks.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
Laura Vaught
----- Original Message -----
From: Laura Vaught
Sent: 08/05/2011 04:51 PM EDT
To: Janet McCabe; Al Armendariz; David Gray; Andrea Drinkard; Brendan
Gilfillan; Gina McCarthy
Subject: Fw: Expect Coverage: PNM to Appeal Today's EPA Decision on San
Juan
FYI - in case you haven't seen.
----- Forwarded by Laura Vaught/DC/USEPA/US on 08/05/2011 04:40 PM -----
From: "Pablo, J eanette" <jeanette.pablo@pnmresources.com>
To: Laura Vaught/DC/USEPA/US@EPA
Date: 08/05/2011 04:31 PM
Subject: Fwd: Expect Coverage: PNM to Appeal Today's EPA Decision on
San J uan
Hi Laura
FYI.
Jeanette
Jeanette Pablo
Federal Affairs
PNM Resources
5505 Connecticut Avenue, NW
#216
Washington, DC 20015
202-468-9688
Jeanette.Pablo@PNMResources.com
The release below has been sent to NM and trade media. Please let me
know if you have questions. Thanks!
PNM to Appeal EPA Decision
on San Juan Generating Station
State Plan Would Achieve Similar Results at One-Tenth the Cost;
Company Opposes Adding Unneeded Cost to Low-Cost Power
Resources
(ALBUQUERQUE, N.M.) Concerned about adding unnecessary
cost to one of its lowest cost sources of power for customers, PNM
officials said they will appeal a decision by the U.S. Environmental
Protection Agency today to require expensive, new environmental
controls on the companys San Juan Generating Station.
EPA today finalized its plan to require the coal-fired power plant near
Farmington, N.M., to install selective catalytic reduction technology on
all four units within five years. In finalizing its plan, EPA has bypassed
an alternative technology approved by the state that would meet the
same federal visibility rules for a tenth of the cost, according to
company officials.
The EPA plan adds unnecessary costs to one of our lowest-cost
sources of reliable power, said Pat Themig, vice president of
generation. If it stands, it will lead to significantly higher future
electric rates for the 2 million customers who rely on the plant for
reasonably priced power.
EPAs decision would require an investment of $750 million or more,
Themig said, while the same federal rules can be met with a different
technology for $77 million.
The N.M. Environmental Improvement Board in June approved a state
proposal to require the installation of the lower cost option at San Juan.
That technology, selective non-catalytic reduction, would meet the
federal visibility requirements of the federal Clean Air Act.
Themig said EPAs analysis is flawed, substantially underestimating
the cost of installing EPAs recommended technology while
overestimating the resulting visibility improvements. Additionally,
PNM believes EPA finalized its plan for San Juan without properly
reviewing the states plan as required by the Clean Air Act. The New
Mexico plan was approved by the state on June 1.
The Clean Air Act gives each state the authority to implement a
regional haze program appropriate for the state, and New Mexico
exercised this authority when it approved its own plan in June,
Themig said. EPAs decision does not relieve it of legal responsibility
to fully consider New Mexicos plan.
Appeal of EPAs decision must be filed within 60 days from when the
new EPA rule is published in the Federal Register. Publication is
expected within the next months.
From: Al Armendariz
To: J anet McCabe
Cc: Andrea Drinkard; Brendan Gilfillan; David Gray; Gina McCarthy; J osh Lewis; Laura Vaught
Subject: Re: NM Statement REVISED
Date: 08/05/2011 10:56 AM
NMED Deputy Secretary (the secretary is giving a key note) expressed similar sentiments about the
additional 2 years. He also indicated that the while the state AG might choose the path of
litigation, he hopes NMED and R6 can continue to talk about the substantive issues in the SIP and
FIP. I told him that was exactly my intention and that continued dialogue was the path forward.
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
-----Janet McCabe/DC/USEPA/US wrote: -----
To: Andrea Drinkard/DC/USEPA/US@EPA, Gina McCarthy/DC/USEPA/US@EPA, Al Armendariz/R6/USEPA/US@EPA
From: Janet McCabe/DC/USEPA/US
Date: 08/05/2011 10:53AM
Cc: Brendan Gilfillan/DC/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA, Josh Lewis/DC/USEPA/US@EPA, Laura
Vaught/DC/USEPA/US@EPA
Subject: Re: NM Statement REVISED
I just spoke to Bill Bumpers, who has been working for the utility. he said a couple things I
wanted to pass on....he assumes the state will still challenge our decision, but the 2 year
extension will help, as will our indication in the decision that we would work with the company on
an averaging plan, as they both will help the company avoid having to spend $$$ especially on the
smaller units.
Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
Andrea Drinkard---08/05/2011 11:39:49 AM---Thanks and point taken on the dialogue. Andrea
Drinkard
From: Andrea Drinkard/DC/USEPA/US
To: Janet McCabe/DC/USEPA/US@EPA
Cc: Brendan Gilfillan/DC/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA, Josh Lewis/DC/USEPA/US@EPA, Laura
Vaught/DC/USEPA/US@EPA
Date: 08/05/2011 11:39 AM
Subject: Re: NM Statement REVISED
Thanks and point taken on the dialogue.
Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 1
Cell:
couple tick points in bold from me.
From: Janet McCabe/DC/USEPA/US
To: Andrea Drinkard/DC/USEPA/US@EPA
Cc: Brendan Gilfillan/DC/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA, Josh Lewis/DC/USEPA/US@EPA, Laura
Vaught/DC/USEPA/US@EPA
Date: 08/05/2011 11:34 AM
Subject: Re: NM Statement REVISED
a couple tick points in bold from me.


Has anyone starting making calls yet?
Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
FOIA Exemption (b)(5) - Deliberative Process Privilege
Andrea Drinkard---08/05/2011 11:15:39 AM---Here are updates to the key messages as well. I re
copy and pasted Janet's edited desk statement for
From: Andrea Drinkard/DC/USEPA/US
To: Janet McCabe/DC/USEPA/US@EPA
Cc: Janet McCabe/DC/USEPA/US@EPA, Brendan Gilfillan/DC/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA,
Josh Lewis/DC/USEPA/US@EPA, Laura Vaught/DC/USEPA/US@EPA, A "room" must be a valid entry in the
Domino Directory
Date: 08/05/2011 11:15 AM
Subject: Re: NM Statement REVISED
Here are updates to the key messages as well. I re copy and pasted Janet's edited desk statement
for easy reading :).
Statement










Talking points/key messages
- EPA has been working with New Mexico, as it has with states across the country, to ensure that
these long overdue plans that reduce pollution, improve visibility and public health, and are put
in place as required by the Clean Air Act
--the pollution from this plant is significant, impacting visibility and public health in New
Mexico and neighboring states and will be significantly reduced by widely used and cost effective
technology
--this decision is based on a thorough analysis of available technologies, costs and improvements
to air quality. while each decision is based on its own facts and circumstances, this decision is
consistent with others that EPA and the states are making
-EPA is improving scenic visibility under the Clean Air Acts Regional Haze Program that was
-This action will protect public health, significantly improve air quality and protect scenic
views at 16 of our nations most treasured areas including the Grand Canyon, Mesa Verde and Arches
National Parks and Bandelier National Monument.
-Facilities found to impact visibility at national parks or wilderness areas will rely on proven,
cost-effective and widely available pollution control methods.
-The reduction in NOx emissions will decrease visibility impacts from the facility in each park or
wilderness area by more than 50% and significantly decrease the number of days the plant impairs
scenic views.
-San Juan Generating Station power plant is one of the largest sources of nitrogen oxides (NOx)
pollution in the nation. This action requires the San Juan Generating Station to install controls
for for the oxides of nitrogen (NOx), and limits emissions of sulfur dioxide (SO2), and sulfuric
acid (H2SO4)).
-San Juan Generating Station power plant was constructed more than 30 years ago and does not have
pollution control technology that meets all current air quality goals and achieves emission
reductions that are readily available with cost-effective updated controls.
-This action relies on proven, cost-effective and widely used technologies to protect public
health in New Mexico and neighboring states by cutting dangerous NOx emissions by over 80 percent.
-Regional haze requirements were established in 1999 and state plans were due in 2007.
- As it has with states across the country, EPA has been working with the state for years to put
in place long over-due plans that reduce dangerous emissions that impact public health and impair
visibility in our most treasured natural areas and parks.
-While states are best suited to address regional haze, New Mexico Environment Department failed
to submit a State Implementation Plan by the deadline and EPA does not believe the plan meets the
requirements. EPA proposed its plan in December 2010.
-EPA has done extensive costs and technical analysis and believes the approach outlined in the
final federal plan is both cost-effective and protective.
-In response to comments, EPA is extending the compliance deadline from three to five years
-Although the state plan New Mexico recently submitted to the agency did not provide a basis to
delay todays decision, EPA will review the plan promptly and remains committed to working with
New Mexico on this important issue.
Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 1
Cell:
FOIA Exemption (b)(5) - Deliberative Process Privilege
Janet McCabe---08/05/2011 11:10:43 AM---sorry, Laura.... Janet McCabe
From: Janet McCabe/DC/USEPA/US
To: Janet McCabe/DC/USEPA/US@EPA
Cc: Andrea Drinkard/DC/USEPA/US@EPA, Brendan Gilfillan/DC/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA,
Josh Lewis/DC/USEPA/US@EPA, Laura Vaught/DC/USEPA/US@EPA, A "room" must be a valid entry in the
Domino Directory
Date: 08/05/2011 11:10 AM
Subject: Re: NM Statement REVISED
sorry, Laura....
Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
Janet McCabe---08/05/2011 11:09:59 AM---What about these tweaks? Today, EPA is issuing a final
source-specific federal plan that will help p
From: Janet McCabe/DC/USEPA/US
To: Andrea Drinkard/DC/USEPA/US@EPA
Cc: Brendan Gilfillan/DC/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA, Josh Lewis/DC/USEPA/US@EPA
Date: 08/05/2011 11:09 AM
Subject: Re: NM Statement REVISED
What about these tweaks?
Today EPA is issuing a final source-specific federal plan that will help protect public health










Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
Andrea Drinkard---08/05/2011 10:56:40 AM---In the interest of time, here's a revised statement.
Working on additions to the key messages now. P
From: Andrea Drinkard/DC/USEPA/US
To: Brendan Gilfillan/DC/USEPA/US@EPA, Josh Lewis/DC/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA, Janet
McCabe/DC/USEPA/US@EPA
Date: 08/05/2011 10:56 AM
Subject: NM Statement REVISED
In the interest of time, here's a revised statement. Working on additions to the key messages now.
Please send thoughts and comments my way ASAP.









U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 1
Cell:
(b) (5)
(b) (5)
From: Al Armendariz
To: McCabe, J anet
Subject: Re: NM Statement REVISED
Date: 08/05/2011 10:43 AM
J anet: yes, david and I are calling the NM congressional offices,
governor, and nmed. So far, very matter of fact.
I really like the new edits.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
David Gray
----- Original Message -----
From: David Gray
Sent: 08/05/2011 11:41 AM EDT
To: Al Armendariz
Subject: Fw: NM Statement REVISED
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
J anet McCabe
----- Original Message -----
From: Janet McCabe
Sent: 08/05/2011 11:34 AM EDT
To: Andrea Drinkard
Cc: Brendan Gilfillan; David Gray; Josh Lewis; Laura Vaught
Subject: Re: NM Statement REVIS
a couple tick points in bold from me.
Has anyone starting making calls yet?
J anet McCabe
(b) (5)
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
Andrea Drinkard---08/05/2011 11:15:39 AM---Here are updates to the key
messages as well. I re copy and pasted J anet's edited desk statement for
From: Andrea Drinkard/DC/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA
Cc: J anet McCabe/DC/USEPA/US@EPA, Brendan
Gilfillan/DC/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA, J osh
Lewis/DC/USEPA/US@EPA, Laura Vaught/DC/USEPA/US@EPA, A "room"
must be a valid entry in the Domino Directory
Date: 08/05/2011 11:15 AM
Subject: Re: NM Statement REVISED
Here are updates to the key messages as well. I re copy and pasted Janet's
edited desk statement for easy reading :).
Statement

Talking points/key messages
- EPA has been working with New Mexico, as it has with states across the
country, to ensure that these long overdue plans that reduce pollution,
improve visibility and public health, and are put in place as required by
the Clean Air Act
--the pollution from this plant is significant, impacting visibility and
public health in New Mexico and neighboring states and will be
FOIA Exemption (b)(5) - Deliberative Process Privilege
significantly reduced by widely used and cost effective technology
--this decision is based on a thorough analysis of available technologies,
costs and improvements to air quality. while each decision is based on its
own facts and circumstances, this decision is consistent with others that
EPA and the states are making
-EPA is improving scenic visibility under the Clean Air Acts Regional Haze
Program that was
-This action will protect public health, significantly improve air quality and
protect scenic views at 16 of our nations most treasured areas including the
Grand Canyon, Mesa Verde and Arches National Parks and Bandelier National
Monument.
-Facilities found to impact visibility at national parks or wilderness areas will rely
on proven, cost-effective and widely available pollution control methods.
-The reduction in NOx emissions will decrease visibility impacts from the facility
in each park or wilderness area by more than 50% and significantly decrease the
number of days the plant impairs scenic views.
-San Juan Generating Station power plant is one of the largest sources of
nitrogen oxides (NOx) pollution in the nation. This action requires the San Juan
Generating Station to install controls for for the oxides of nitrogen (NOx), and
limits emissions of sulfur dioxide (SO
2
), and sulfuric acid (H
2
SO
4
)).
-San Juan Generating Station power plant was constructed more than 30 years
ago and does not have pollution control technology that meets all current air
quality goals and achieves emission reductions that are readily available with cost-
effective updated controls.
-This action relies on proven, cost-effective and widely used technologies to
protect public health in New Mexico and neighboring states by cutting dangerous
NOx emissions by over 80 percent.
-Regional haze requirements were established in 1999 and state plans were due in
2007.
- As it has with states across the country, EPA has been working with the state
for years to put in place long over-due plans that reduce dangerous emissions that
impact public health and impair visibility in our most treasured natural areas and
parks.
-While states are best suited to address regional haze, New Mexico Environment
Department failed to submit a State Implementation Plan by the deadline and
EPA does not believe the plan meets the requirements. EPA proposed its plan in
December 2010.
-EPA has done extensive costs and technical analysis and believes the approach
outlined in the final federal plan is both cost-effective and protective.
-In response to comments, EPA is extending the compliance deadline from three
to five years
-Although the state plan New Mexico recently submitted to the agency did not
provide a basis to delay todays decision, EPA will review the plan promptly and
remains committed to working with New Mexico on this important issue.
Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 202.564.1601
Cell:
J anet McCabe---08/05/2011 11:10:43 AM---sorry, Laura.... J anet McCabe
From: J anet McCabe/DC/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA
Cc: Andrea Drinkard/DC/USEPA/US@EPA, Brendan
Gilfillan/DC/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA, J osh
Lewis/DC/USEPA/US@EPA, Laura Vaught/DC/USEPA/US@EPA, A "room"
must be a valid entry in the Domino Directory
Date: 08/05/2011 11:10 AM
Subject: Re: NM Statement REVISED
sorry, Laura....
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
J anet McCabe---08/05/2011 11:09:59 AM---What about these tweaks? Today,
EPA is issuing a final source-specific federal plan that will help p
From: J anet McCabe/DC/USEPA/US
To: Andrea Drinkard/DC/USEPA/US@EPA
Cc: Brendan Gilfillan/DC/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA,
J osh Lewis/DC/USEPA/US@EPA
Date: 08/05/2011 11:09 AM
Subject: Re: NM Statement REVISED
What about these tweaks?

J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
Andrea Drinkard---08/05/2011 10:56:40 AM---In the interest of time, here's a
revised statement. Working on additions to the key messages now. P
From: Andrea Drinkard/DC/USEPA/US
To: Brendan Gilfillan/DC/USEPA/US@EPA, J osh Lewis/DC/USEPA/US@EPA,
David Gray/R6/USEPA/US@EPA, J anet McCabe/DC/USEPA/US@EPA
Date: 08/05/2011 10:56 AM
Subject: NM Statement REVISED

(b) (5)
(b) (5)

Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 202.564.1601
Cell:
(b) (5)
From: Al Armendariz
To: Andrea Drinkard; Laura Vaught
Cc: David Gray; Gray, David; J anet McCabe; Brendan Gilfillan
Subject: Re: New Mexico - UPDATED INFO #2
Date: 08/05/2011 08:27 AM
The phrase is accurate. Of the thousands of major sources in R6 and in the country,
the plant is in the top 20 highest NOx emitters.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
Andrea Drinkard
----- Original Message -----
From: Andrea Drinkard
Sent: 08/05/2011 09:23 AM EDT
To: Laura Vaught
Cc: Al Armendariz; David Gray; "Gray, David" <gray.david@epa.gov>; Janet
McCabe; Brendan Gilfillan
Subject: Re: New Mexico - UPDATED INFO #2
Hi Laura,
I simplified the response to that q and added a few other edits. Here's
that q for review, and the whole document is attached. Also, I slight
edit to the desk statement.

-Andrea-
Statement

(b) (5)
(b) (5)


[attachment "NM FIP Q&A 8.5.11 v3.docx" deleted by Al Armendariz/R6/USEPA/US]
[attachment "NM FIP COMMUNICATIONS STRATEGY 8.5_930.docx" deleted by Al
Armendariz/R6/USEPA/US]
Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 202.564.1601
Cell:
Laura Vaught---08/05/2011 08:30:28 AM---Thank you! ----- Original Message -
----
From: Laura Vaught/DC/USEPA/US
To: Andrea Drinkard/DC/USEPA/US@EPA, Al
Armendariz/R6/USEPA/US@EPA
Cc: David Gray/R6/USEPA/US@EPA, "Gray, David" <gray.david@epa.gov>,
J anet McCabe/DC/USEPA/US@EPA
Date: 08/05/2011 08:30 AM
Subject: Re: New Mexico - UPDATED INFO #2
Thank you!
Andrea Drinkard
----- Original Message -----
From: Andrea Drinkard
Sent: 08/05/2011 08:27 AM EDT
To: Laura Vaught; Al Armendariz
Cc: David Gray; "Gray, David" <gray.david@epa.gov>; Janet
McCabe
Subject: Re: New Mexico - UPDATED INFO #2
The q&as are an internal document that we can pull from as needed.
Will edit that q and resend so we're all on the same page.
Thanks for flagging.
AD
Laura Vaught
(b) (5)
----- Original Message -----
From: Laura Vaught
Sent: 08/05/2011 08:17 AM EDT
To: Andrea Drinkard; Al Armendariz
Cc: David Gray; "Gray, David" <gray.david@epa.gov>; Janet
McCabe

Andrea Drinkard
----- Original Message -----
From: Andrea Drinkard
Sent: 08/04/2011 02:30 PM EDT
To: Al Armendariz
Cc: David Gray; "Gray, David" <gray.david@epa.gov>; Janet
McCabe; Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
We also referenced that point in the statement, so I've revised that
based on the simpler version and copy and pasted both below. I've
updated in the attached, if that would help as well.
Let me know if there are any additional edits.
Thanks!
Desk Statement

Topline messages
(b) (5)
(b) (5)

[attachment "NM FIP COMMUNICATIONS STRATEGY
8.4.11v4_230PM.docx" deleted by Laura Vaught/DC/USEPA/US]
Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 202.564.1601
Cell:
Al Armendariz---08/04/2011 02:03:37 PM---I like it.
From: Al Armendariz/R6/USEPA/US
To: Andrea Drinkard/DC/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA
Cc: "Gray, David" <gray.david@epa.gov>, J anet
McCabe/DC/USEPA/US@EPA, Laura Vaught/DC/USEPA/US@EPA
Date: 08/04/2011 02:03 PM
Subject: Re: New Mexico - UPDATED INFO #2
I like it.

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
Andrea Drinkard
----- Original Message -----
From: Andrea Drinkard
Sent: 08/04/2011 01:59 PM EDT
To: David Gray
Cc: Al Armendariz; "David Gray" <gray.david@epa.gov>; Janet
McCabe; Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
After talking to J anet, maybe simpler is better:

Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 202.564.1601
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
Cell:
David Gray---08/04/2011 01:54:41 PM---Can we say? I can run it by the tech
team. In addition, EPA will continue to work with New Mexico to
From: David Gray/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, Andrea
Drinkard/DC/USEPA/US@EPA, "David Gray" <gray.david@epa.gov>, Laura
Vaught/DC/USEPA/US@EPA
Date: 08/04/2011 01:54 PM
Subject: Re: New Mexico - UPDATED INFO #2
Can we say? I can run it by the tech team.
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: Janet McCabe
Sent: 08/04/2011 01:41 PM EDT
To: David Gray
Cc: Al Armendariz; Andrea Drinkard; "David Gray" <gray.david@epa.gov>;
Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
Great.

J anet McCabe
(b) (5)
(b) (5)
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: David Gray/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, Andrea Drinkard/DC/USEPA/US@EPA, "David Gray"
<gray.david@epa.gov>, Laura Vaught/DC/USEPA/US@EPA
Date: 08/04/2011 01:25 PM
Subject: Re: New Mexico - UPDATED INFO #2
Janet,

David
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: Janet McCabe
Sent: 08/04/2011 01:17 PM EDT
To: David Gray
Cc: Al Armendariz; Andrea Drinkard; "David Gray" <gray.david@epa.gov>;
(b) (5)
Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
I know we keep going around and around on this, but I have one more
thing to note.

J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: David Gray/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Andrea Drinkard/DC/USEPA/US@EPA, J anet
McCabe/DC/USEPA/US@EPA
Cc: "David Gray" <gray.david@epa.gov>
Date: 08/04/2011 09:21 AM
Subject: New Mexico - UPDATED INFO #2
Last version dropped Andrea's corrections. Other inconsistencies are
also corrected in this version.
New Mexico Interstate Transport and Regional Haze Federal Implementation
Plan
Communication Strategy
Action Summary
(b) (5)
EPA is under a consent decree deadline to sign a final action by August 5 to issue
a visibility transport decision for New Mexico. EPA is issuing a Federal
Implementation Plan (FIP) under the Clean Air Act for the San Juan Generating
Station power plant, which will significantly reduce harmful emissions and
improve visibility and respiratory health for the surrounding multi-state area.
EPAs FIP addresses both the Visibility Transport and Regional Haze
requirements that are applicable at the San Juan Generating Station power plant.
Under the FIP, the four unit coal plant will be required to utilize the best
pollution-control technology available for this type of facility. EPA found SCR
technology to be a cost effective control to achieve required emission reductions.
Desk Statement

Topline messages





FOIA Exemption (b)(5) - Deliberative Process Privilege




FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Al Armendariz
To: Andrea Drinkard
Cc: Brendan Gilfillan; David Gray; J anet McCabe; Laura Vaught; David Gray
Subject: Re: New Mexico - UPDATED INFO #2
Date: 08/05/2011 08:25 AM
I think the phrase is accurate. Of the thousands of major sources in R6 and the country, NOx
emissions from the plant place it in the top 20 highest emitting sources.
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
-----Andrea Drinkard/DC/USEPA/US wrote: -----
To: Laura Vaught/DC/USEPA/US@EPA
From: Andrea Drinkard/DC/USEPA/US
Date: 08/05/2011 08:23AM
Cc: Al Armendariz/R6/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA, "Gray, David" <gray.david@epa.gov>,
Janet McCabe/DC/USEPA/US@EPA, Brendan Gilfillan/DC/USEPA/US@EPA
Subject: Re: New Mexico - UPDATED INFO #2
Hi Laura,
I simplified the response to that q and added a few other edits. Here's that q for review, and the
whole document is attached. Also, I slight edit to the desk statement. Let me know if "one of the
country's largest polluting power plants" is not accurate. We can tweak when we talk later this
morning.
-Andrea-













(See attached file: NM FIP Q&A 8.5.11 v3.docx) (See attached file: NM FIP COMMUNICATIONS STRATEGY
8.5_930.docx)
Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 1
Cell:
Laura Vaught---08/05/2011 08:30:28 AM---Thank you! ----- Original Message -----
From: Laura Vaught/DC/USEPA/US
To: Andrea Drinkard/DC/USEPA/US@EPA, Al Armendariz/R6/USEPA/US@EPA
Cc: David Gray/R6/USEPA/US@EPA, "Gray, David" <gray.david@epa.gov>, Janet McCabe/DC/USEPA/US@EPA
Date: 08/05/2011 08:30 AM
Subject: Re: New Mexico - UPDATED INFO #2
Thank you!
Andrea Drinkard
----- Original Message -----
From: Andrea Drinkard
Sent: 08/05/2011 08:27 AM EDT
To: Laura Vaught; Al Armendariz
Cc: David Gray; "Gray, David" <gray.david@epa.gov>; Janet McCabe
Subject: Re: New Mexico - UPDATED INFO #2
The q&as are an internal document that we can pull from as needed. Will edit that q and resend so
we're all on the same page.
Thanks for flagging.
AD Laura Vaught
----- Original Message -----
(b) (5)
From: Laura Vaught
Sent: 08/05/2011 08:17 AM EDT
To: Andrea Drinkard; Al Armendariz
Cc: David Gray; "Gray, David" <gray.david@epa.gov>; Janet McCabe
Subject: Re: New Mexico - UPDATED INFO #2






Message -----
rinkard
Sent: 08/04/2011 02:30 PM EDT
To: Al Armendariz
Cc: David Gray; "Gray, David" <gray.david@epa.gov>; Janet McCabe; Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
We also referenced that point in the statement, so I've revised that based on the simpler version
and copy and pasted both below. I've updated in the attached, if that would help as well.
Let me know if there are any additional edits.
Thanks!
Desk Statement







Topline messages
8.4.11v4_230PM.docx" deleted by Laura Vaught/DC/USEPA/US]
Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 1
Cell:
Al Armendariz---08/04/2011 02:03:37 PM---I like it.
From: Al Armendariz/R6/USEPA/US
To: Andrea Drinkard/DC/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA
Cc: "Gray, David" <gray.david@epa.gov>, Janet McCabe/DC/USEPA/US@EPA, Laura Vaught/DC/USEPA/US@EPA
Date: 08/04/2011 02:03 PM
Subject: Re: New Mexico - UPDATED INFO #2
I like it.

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
Andrea Drinkard
----- Original Message -----
From: Andrea Drinkard
Sent: 08/04/2011 01:59 PM EDT
To: David Gray
Cc: Al Armendariz; "David Gray" <gray.david@epa.gov>; Janet McCabe; Laura Vaught

Protection Agency
Radiation
Email: drinkard.andrea@epa.gov
Phone 1
Cell:
David Gray---08/04/2011 01:54:41 PM---Can we say? I can run it by the tech team. In addition, EPA
will continue to work with New Mexico to
From: David Gray/R6/USEPA/US
To: Janet McCabe/DC/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, Andrea Drinkard/DC/USEPA/US@EPA, "David Gray"
<gray.david@epa.gov>, Laura Vaught/DC/USEPA/US@EPA
Date: 08/04/2011 01:54 PM
Subject: Re: New Mexico - UPDATED INFO #2
(b) (5)
(b) (5)
FOIA Exemption (b)(5) - Deliberative Process Privilege
Can we say? I can run it by the tech team.
Affairs
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: Janet McCabe
Sent: 08/04/2011 01:41 PM EDT
To: David Gray
Cc: Al Armendariz; Andrea Drinkard; "David Gray" <gray.david@epa.gov>; Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
Great. Can we somehow get the notion in there that we will continue to work with the state--they
might come up with some other approach that they would like to explore--not exactly the same as
"significant new information that changes our analysis"....
Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: David Gray/R6/USEPA/US
To: Janet McCabe/DC/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, Andrea Drinkard/DC/USEPA/US@EPA, "David Gray"
<gray.david@epa.gov>, Laura Vaught/DC/USEPA/US@EPA
Date: 08/04/2011 01:25 PM
Subject: Re: New Mexico - UPDATED INFO #2
Janet,



David
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: Janet McCabe
Sent: 08/04/2011 01:17 PM EDT
To: David Gray
Cc: Al Armendariz; Andrea Drinkard; "David Gray" <gray.david@epa.gov>; Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
I know we keep going around and around on this, but I have one more thing to note.


ik
Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: David Gray/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Andrea Drinkard/DC/USEPA/US@EPA, Janet
(b) (5)
(b) (5)
(b) (5)
McCabe/DC/USEPA/US@EPA
Cc: "David Gray" <gray.david@epa.gov>
Date: 08/04/2011 09:21 AM
Subject: New Mexico - UPDATED INFO #2
Last version dropped Andrea's corrections. Other inconsistencies are also corrected in this
version.
New Mexico Interstate Transport and Regional Haze Federal Implementation Plan
Communication Strategy
Action Summary
EPA is under a consent decree deadline to sign a final action by August 5 to issue a visibility
transport decision for New Mexico. EPA is issuing a Federal Implementation Plan (FIP) under the
Clean Air Act for the San Juan Generating Station power plant, which will significantly reduce
harmful emissions and improve visibility and respiratory health for the surrounding multi-state
area. EPAs FIP addresses both the Visibility Transport and Regional Haze requirements that are
applicable at the San Juan Generating Station power plant. Under the FIP, the four unit coal plant
will be required to utilize the best pollution-control technology available for this type of
facility. EPA found SCR technology to be a cost effective control to achieve required emission
reductions.
Desk Statement







Topline messages


















[attachment "NM FIP Q&A 8.5.11 v3.docx" removed by Al Armendariz/R6/USEPA/US]
[attachment "NM FIP COMMUNICATIONS STRATEGY 8.5_930.docx" removed by Al Armendariz/R6/USEPA/US]
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Andrea Drinkard
To: Laura Vaught
Cc: Al Armendariz; David Gray; Gray, David; J anet McCabe; Brendan Gilfillan
Subject: Re: New Mexico - UPDATED INFO #2
Date: 08/05/2011 08:23 AM
Attachments: NM FIP Q&A 8.5.11 v3.docx
NM FIP COMMUNICATIONS STRATEGY 8.5 930.docx
Hi Laura,
I simplified the response to that q and added a few other edits. Here's that q for
review, and the whole document is attached. Also, I slight edit to the desk
statement

-Andrea-


Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 202.564.1601
Cell:
(b) (5)
(b) (5)
(b) (5)
Laura Vaught---08/05/2011 08:30:28 AM---Thank you! ----- Original Message -
----
From: Laura Vaught/DC/USEPA/US
To: Andrea Drinkard/DC/USEPA/US@EPA, Al
Armendariz/R6/USEPA/US@EPA
Cc: David Gray/R6/USEPA/US@EPA, "Gray, David" <gray.david@epa.gov>,
J anet McCabe/DC/USEPA/US@EPA
Date: 08/05/2011 08:30 AM
Subject: Re: New Mexico - UPDATED INFO #2
Thank you!
Andrea Drinkard
----- Original Message -----
From: Andrea Drinkard
Sent: 08/05/2011 08:27 AM EDT
To: Laura Vaught; Al Armendariz
Cc: David Gray; "Gray, David" <gray.david@epa.gov>; Janet
McCabe
Subject: Re: New Mexico - UPDATED INFO #2
The q&as are an internal document that we can pull from as needed.
Will edit that q and resend so we're all on the same page.
Thanks for flagging.
AD
Laura Vaught
----- Original Message -----
From: Laura Vaught
Sent: 08/05/2011 08:17 AM EDT
To: Andrea Drinkard; Al Armendariz
Cc: David Gray; "Gray, David" <gray.david@epa.gov>; Janet
McCabe

Andrea Drinkard
----- Original Message -----
From: Andrea Drinkard
Sent: 08/04/2011 02:30 PM EDT
To: Al Armendariz
Cc: David Gray; "Gray, David" <gray.david@epa.gov>; Janet
McCabe; Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
(b) (5)
We also referenced that point in the statement, so I've revised that based on the
simpler version and copy and pasted both below. I've updated in the attached, if
that would help as well.
Let me know if there are any additional edits.
Thanks!
Desk Statement

Topline messages

[attachment "NM FIP COMMUNICATIONS STRATEGY
8.4.11v4_230PM.docx" deleted by Laura Vaught/DC/USEPA/US]
Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 202.564.1601
Cell:
Al Armendariz---08/04/2011 02:03:37 PM---I like it.
From: Al Armendariz/R6/USEPA/US
To: Andrea Drinkard/DC/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA
Cc: "Gray, David" <gray.david@epa.gov>, J anet
McCabe/DC/USEPA/US@EPA, Laura Vaught/DC/USEPA/US@EPA
Date: 08/04/2011 02:03 PM
Subject: Re: New Mexico - UPDATED INFO #2
I like it.

____________________
FOIA Exemption (b)(5) - Deliberative Process Privilege
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
Andrea Drinkard
----- Original Message -----
From: Andrea Drinkard
Sent: 08/04/2011 01:59 PM EDT
To: David Gray
Cc: Al Armendariz; "David Gray" <gray.david@epa.gov>; Janet
McCabe; Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
After talking to J anet, maybe simpler is better:
EPA will review the regional haze plan that New Mexico submitted in July
2011 and will continue to work with the state on this important issue.
Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 202.564.1601
Cell:
David Gray---08/04/2011 01:54:41 PM---Can we say? I can run it by the tech
team. In addition, EPA will continue to work with New Mexico to
From: David Gray/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, Andrea
Drinkard/DC/USEPA/US@EPA, "David Gray" <gray.david@epa.gov>, Laura
Vaught/DC/USEPA/US@EPA
Date: 08/04/2011 01:54 PM
Subject: Re: New Mexico - UPDATED INFO #2
Can we say? I can run it by the tech team.
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
(b) (5)
Sent from Blackberry
From: Janet McCabe
Sent: 08/04/2011 01:41 PM EDT
To: David Gray
Cc: Al Armendariz; Andrea Drinkard; "David Gray" <gray.david@epa.gov>;
Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
Great.

J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: David Gray/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, Andrea Drinkard/DC/USEPA/US@EPA, "David Gray"
<gray.david@epa.gov>, Laura Vaught/DC/USEPA/US@EPA
Date: 08/04/2011 01:25 PM
Subject: Re: New Mexico - UPDATED INFO #2
Janet,

(b) (5)
(b) (5)

David
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: Janet McCabe
Sent: 08/04/2011 01:17 PM EDT
To: David Gray
Cc: Al Armendariz; Andrea Drinkard; "David Gray" <gray.david@epa.gov>;
Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
I know we keep going around and around on this, but I have one more
thing to note.

J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
(b) (5)
(b) (5)
From: David Gray/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Andrea Drinkard/DC/USEPA/US@EPA, J anet
McCabe/DC/USEPA/US@EPA
Cc: "David Gray" <gray.david@epa.gov>
Date: 08/04/2011 09:21 AM
Subject: New Mexico - UPDATED INFO #2
Last version dropped Andrea's corrections. Other inconsistencies are
also corrected in this version.
New Mexico Interstate Transport and Regional Haze Federal Implementation
Plan
Communication Strategy
Action Summary
EPA is under a consent decree deadline to sign a final action by August 5 to issue
a visibility transport decision for New Mexico. EPA is issuing a Federal
Implementation Plan (FIP) under the Clean Air Act for the San Juan Generating
Station power plant, which will significantly reduce harmful emissions and
improve visibility and respiratory health for the surrounding multi-state area.
EPAs FIP addresses both the Visibility Transport and Regional Haze
requirements that are applicable at the San Juan Generating Station power plant.
Under the FIP, the four unit coal plant will be required to utilize the best
pollution-control technology available for this type of facility. EPA found SCR
technology to be a cost effective control to achieve required emission reductions.
Desk Statement

FOIA Exemption (b)(5) - Deliberative Process Privilege
Topline messages









FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Andrea Drinkard
To: Al Armendariz
Cc: David Gray; Gray, David; J anet McCabe; Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
Date: 08/04/2011 01:30 PM
Attachments: NM FIP COMMUNICATIONS STRATEGY 8.4.11v4 230PM.docx
We also referenced that point in the statement, so I've revised that based on the
simpler version and copy and pasted both below. I've updated in the attached, if
that would help as well.
Let me know if there are any additional edits.
Thanks!
Desk Statement

Topline messages

Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 202.564.1601
Cell:
Al Armendariz---08/04/2011 02:03:37 PM---I like it.
From: Al Armendariz/R6/USEPA/US
To: Andrea Drinkard/DC/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA
Cc: "Gray, David" <gray.david@epa.gov>, J anet
McCabe/DC/USEPA/US@EPA, Laura Vaught/DC/USEPA/US@EPA
Date: 08/04/2011 02:03 PM
Subject: Re: New Mexico - UPDATED INFO #2
FOIA Exemption (b)(5) - Deliberative Process Privilege
I like it.

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
Andrea Drinkard
----- Original Message -----
From: Andrea Drinkard
Sent: 08/04/2011 01:59 PM EDT
To: David Gray
Cc: Al Armendariz; "David Gray" <gray.david@epa.gov>; Janet
McCabe; Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
After talking to J anet, maybe simpler is better:
EPA will review the regional haze plan that New Mexico submitted in July
2011 and will continue to work with the state on this important issue.
Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 202.564.1601
Cell:
David Gray---08/04/2011 01:54:41 PM---Can we say? I can run it by the tech
team. In addition, EPA will continue to work with New Mexico to
From: David Gray/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, Andrea
Drinkard/DC/USEPA/US@EPA, "David Gray" <gray.david@epa.gov>, Laura
Vaught/DC/USEPA/US@EPA
Date: 08/04/2011 01:54 PM
Subject: Re: New Mexico - UPDATED INFO #2
Can we say? I can run it by the tech team.
David Gray
Director
(b) (5)
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: Janet McCabe
Sent: 08/04/2011 01:41 PM EDT
To: David Gray
Cc: Al Armendariz; Andrea Drinkard; "David Gray" <gray.david@epa.gov>;
Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
Great.

J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: David Gray/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, Andrea Drinkard/DC/USEPA/US@EPA, "David Gray"
<gray.david@epa.gov>, Laura Vaught/DC/USEPA/US@EPA
Date: 08/04/2011 01:25 PM
Subject: Re: New Mexico - UPDATED INFO #2
Janet,
(b) (5)
(b) (5)


David
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: Janet McCabe
Sent: 08/04/2011 01:17 PM EDT
To: David Gray
Cc: Al Armendariz; Andrea Drinkard; "David Gray" <gray.david@epa.gov>;
Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
I know we keep going around and around on this, but I have one more
thing to note.

J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
(b) (5)
(b) (5)
202-564-3206
mccabe.janet@epa.gov
From: David Gray/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Andrea Drinkard/DC/USEPA/US@EPA, J anet
McCabe/DC/USEPA/US@EPA
Cc: "David Gray" <gray.david@epa.gov>
Date: 08/04/2011 09:21 AM
Subject: New Mexico - UPDATED INFO #2
Last version dropped Andrea's corrections. Other inconsistencies are
also corrected in this version.
New Mexico Interstate Transport and Regional Haze Federal Implementation
Plan
Communication Strategy
Action Summary
EPA is under a consent decree deadline to sign a final action by August 5 to issue
a visibility transport decision for New Mexico. EPA is issuing a Federal
Implementation Plan (FIP) under the Clean Air Act for the San Juan Generating
Station power plant, which will significantly reduce harmful emissions and
improve visibility and respiratory health for the surrounding multi-state area.
EPAs FIP addresses both the Visibility Transport and Regional Haze
requirements that are applicable at the San Juan Generating Station power plant.
Under the FIP, the four unit coal plant will be required to utilize the best
pollution-control technology available for this type of facility. EPA found SCR
technology to be a cost effective control to achieve required emission reductions.
Desk Statement
FOIA Exemption (b)(5) - Deliberative Process Privilege

Topline messages









FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Laura Vaught
To: J anet McCabe
Cc: David Gray; Al Armendariz; Andrea Drinkard; David Gray
Subject: Re: New Mexico - UPDATED INFO #2
Date: 08/04/2011 12:51 PM
J anet McCabe---08/04/2011 01:41:33 PM---Great. Can we somehow get the
notion in there that we will continue to work with the state--they mi
From: J anet McCabe/DC/USEPA/US
To: David Gray/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, Andrea
Drinkard/DC/USEPA/US@EPA, "David Gray" <gray.david@epa.gov>, Laura
Vaught/DC/USEPA/US@EPA
Date: 08/04/2011 01:41 PM
Subject: Re: New Mexico - UPDATED INFO #2
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
David Gray---08/04/2011 01:25:33 PM---J anet, I suggest we update to reflect the
language we used in the FR overview. It will give us a cha
From: David Gray/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, Andrea
Drinkard/DC/USEPA/US@EPA, "David Gray" <gray.david@epa.gov>, Laura
Vaught/DC/USEPA/US@EPA
Date: 08/04/2011 01:25 PM
Subject: Re: New Mexico - UPDATED INFO #2
Janet,
(b) (5)
(b) (5)
(b) (5)


David
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: Janet McCabe
Sent: 08/04/2011 01:17 PM EDT
To: David Gray
Cc: Al Armendariz; Andrea Drinkard; "David Gray" <gray.david@epa.gov>;
Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
I know we keep going around and around on this, but I have one more
thing to note.

J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
(b) (5)
(b) (5)
202-564-3206
mccabe.janet@epa.gov
From: David Gray/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Andrea Drinkard/DC/USEPA/US@EPA, J anet
McCabe/DC/USEPA/US@EPA
Cc: "David Gray" <gray.david@epa.gov>
Date: 08/04/2011 09:21 AM
Subject: New Mexico - UPDATED INFO #2
Last version dropped Andrea's corrections. Other inconsistencies are
also corrected in this version.
New Mexico Interstate Transport and Regional Haze Federal Implementation
Plan
Communication Strategy
Action Summary
EPA is under a consent decree deadline to sign a final action by August 5 to issue
a visibility transport decision for New Mexico. EPA is issuing a Federal
Implementation Plan (FIP) under the Clean Air Act for the San Juan Generating
Station power plant, which will significantly reduce harmful emissions and
improve visibility and respiratory health for the surrounding multi-state area.
EPAs FIP addresses both the Visibility Transport and Regional Haze
requirements that are applicable at the San Juan Generating Station power plant.
Under the FIP, the four unit coal plant will be required to utilize the best
pollution-control technology available for this type of facility. EPA found SCR
technology to be a cost effective control to achieve required emission reductions.
Desk Statement
FOIA Exemption (b)(5) - Deliberative Process Privilege

Topline messages









FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Laura Vaught
To: David Gray; J anet McCabe
Cc: Al Armendariz; Andrea Drinkard; David Gray
Subject: Re: New Mexico - UPDATED INFO #2
Date: 08/04/2011 12:31 PM
Also - based on conversations within Administration - we need to update the talking point on bifurcation
to read along the lines J anet pointed out. Thanks.
From: David Gray
Sent: 08/04/2011 01:25 PM EDT
To: J anet McCabe
Cc: Al Armendariz; Andrea Drinkard; "David Gray" <gray.david@epa.gov>; Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
J anet,


David
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: J anet McCabe
Sent: 08/04/2011 01:17 PM EDT
To: David Gray
Cc: Al Armendariz; Andrea Drinkard; "David Gray" <gray.david@epa.gov>; Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
I know we keep going around and around on this, but I have one more thing to note.
Janet McCabe
(b) (5)
(b) (5)
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: David Gray/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Andrea Drinkard/DC/USEPA/US@EPA, Janet McCabe/DC/USEPA/US@EPA
Cc: "David Gray" <gray.david@epa.gov>
Date: 08/04/2011 09:21 AM
Subject: New Mexico - UPDATED INFO #2
Last version dropped Andrea's corrections. Other inconsistencies are also corrected in this version.
New Mexico Interstate Transport and Regional Haze Federal Implementation Plan
Communication Strategy
Action Summary
EPA is under a consent decree deadline to sign a final action by August 5 to issue a visibility
transport decision for New Mexico. EPA is issuing a Federal Implementation Plan (FIP) under
the Clean Air Act for the San Juan Generating Station power plant, which will significantly
reduce harmful emissions and improve visibility and respiratory health for the surrounding multi-
state area. EPAs FIP addresses both the Visibility Transport and Regional Haze requirements
that are applicable at the San Juan Generating Station power plant. Under the FIP, the four unit
coal plant will be required to utilize the best pollution-control technology available for this type
of facility. EPA found SCR technology to be a cost effective control to achieve required
emission reductions.
Desk Statement
FOIA Exemption (b)(5) - Deliberative Process Privilege
Topline messages










From: Andrea Drinkard
To: J anet McCabe
Cc: David Gray; Al Armendariz; David Gray; Laura Vaught
Subject: Re: New Mexico - UPDATED INFO #2
Date: 08/04/2011 12:24 PM
Good point. Would it work to end it after as quickly as possible?
EPA is working with the New Mexico Environment Department to review its recently submitted
regional haze plan as quickly as possible.
Andrea Drinkard
U.S. Environmental Protection Agency
Office of Air and Radiation
Email: drinkard.andrea@epa.gov
Phone: 202.564.1601
Cell:
J anet McCabe---08/04/2011 01:17:24 PM---I know we keep going around and
around on this, but I have one more thing to note. the very last bul
From: J anet McCabe/DC/USEPA/US
To: David Gray/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, Andrea
Drinkard/DC/USEPA/US@EPA, "David Gray" <gray.david@epa.gov>, Laura
Vaught/DC/USEPA/US@EPA
Date: 08/04/2011 01:17 PM
Subject: Re: New Mexico - UPDATED INFO #2
I know we keep going around and around on this, but I have one more
thing to note.
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
(b) (5)
David Gray---08/04/2011 09:21:39 AM---Last version dropped Andrea's
corrections. Other inconsistencies are also corrected in this version
From: David Gray/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Andrea
Drinkard/DC/USEPA/US@EPA, J anet McCabe/DC/USEPA/US@EPA
Cc: "David Gray" <gray.david@epa.gov>
Date: 08/04/2011 09:21 AM
Subject: New Mexico - UPDATED INFO #2
Last version dropped Andrea's corrections. Other inconsistencies are also corrected
in this version.
New Mexico Interstate Transport and Regional Haze Federal Implementation
Plan
Communication Strategy
Action Summary
EPA is under a consent decree deadline to sign a final action by August 5 to issue a visibility
transport decision for New Mexico. EPA is issuing a Federal Implementation Plan (FIP) under
the Clean Air Act for the San Juan Generating Station power plant, which will significantly
reduce harmful emissions and improve visibility and respiratory health for the surrounding multi-
state area. EPAs FIP addresses both the Visibility Transport and Regional Haze requirements
that are applicable at the San Juan Generating Station power plant. Under the FIP, the four unit
coal plant will be required to utilize the best pollution-control technology available for this type
of facility. EPA found SCR technology to be a cost effective control to achieve required
emission reductions.
Desk Statement
Topline messages
FOIA Exemption (b)(5) - Deliberative Process Privilege







FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Neal Fann
To: J anet McCabe
Cc: Al Armendariz; Bryan Hubbell; David Gray; Lawrence Starfield; Lydia Wegman; Rob Brenner; Rosalina
Rodriguez
Subject: Re: Fw: Response to your request for San J uan EGU PM2.5 benefits
Date: 08/04/2011 10:05 AM
J anet,
That's correct--these are estimates of the PM2.5 deaths avoided and monetized
benefits per year.
Thanks,
Neal
_______________________________
Neal Fann
USEPA
Office of Air Quality Planning & Standards
Risk and Benefits Group
C539-07
RTP, NC 27711
voice: (919) 541-0209
fax: (919) 541-5315
J anet McCabe---08/04/2011 10:52:13 AM---Thanks, Rob and Neal, for running
this analysis. these are annual numbers, right? looping in the Re
From: J anet McCabe/DC/USEPA/US
To: Rob Brenner/DC/USEPA/US@EPA
Cc: Bryan Hubbell/RTP/USEPA/US@EPA, Lydia Wegman/RTP/USEPA/US@EPA, Neal
Fann/RTP/USEPA/US@EPA, Rosalina Rodriguez/RTP/USEPA/US@EPA, Al
Armendariz/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, David
Gray/R6/USEPA/US@EPA
Date: 08/04/2011 10:52 AM
Subject: Re: Fw: Response to your request for San J uan EGU PM2.5 benefits
Thanks, Rob and Neal, for running this analysis. these are annual
numbers, right?
looping in the Region 6 folks....
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
Rob Brenner---08/04/2011 10:22:27 AM---Hi J anet, Neal Fann, who works in
Bryan Hubbel's group developed a quick assessment of the SCR vs.
From: Rob Brenner/DC/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA
Cc: Lydia Wegman/RTP/USEPA/US@EPA, Rosalina
Rodriguez/RTP/USEPA/US@EPA, Bryan Hubbell/RTP/USEPA/US@EPA, Neal
Fann/RTP/USEPA/US@EPA
Date: 08/04/2011 10:22 AM
Subject: Fw: Response to your request for San J uan EGU PM2.5 benefits
Hi J anet,
Neal Fann, who works in Bryan Hubbel's group developed a quick
assessment of the SCR vs. SNCR health benefits for the San J uan
decision. It shows that, in addition to the visibility benefits, there are
some significant public health benefits as a result of less downwind
PM2.5 formation. (The Pope and Laden references refer to 2 different
methodologies for relating fine particle exposures to mortality--we
typically show both approaches in our benefits analyses.)
Rob
Neal Fann
----- Original Message -----
From: Neal Fann
Sent: 08/02/2011 04:56 PM EDT
To: Rob Brenner
Cc: Lydia Wegman; Rosalina Rodriguez; Bryan Hubbell
Subject: Response to your request for San Juan EGU PM2.5
benefits
Rob,
Summarized below are the PM2.5-related monetized benefits and
deaths avoided that are attributable to the installation of SCR controls
in place of NSCR at the San J uan EGU. As I indicated in my e-mail to
you, there are some important uncertainties associated with estimating
the benefits of a single EGU using benefit per ton estimates--
particularly one located in a relatively rural area. For this reason, I
have provided two sets of estimates--one using a national average
benefit per ton, and one using a benefit per ton developed for Phoenix
(which, for the cities in which we have generated benefit per ton
estimates, is the urban area most similar to San J uan, which is located
in relatively close proximity to Santa Fe and Albuquerque). The size of
the benefits are relatively insensitive to the benefit per ton used--giving
us greater confidence in the overall estimate of benefits.
It's worth noting that this analysis omits other important benefits we
would expect from these NOx reductions--including ozone-related
deaths and illnesses avoided and improvements in recreational
visibility. These omissions suggest that the benefits reported below are
underestimated.
Please let me know if you have any further questions, or if you need
me to document these results in a formal memo.
Best,
Neal
_______________________________
Neal Fann
USEPA
Office of Air Quality Planning & Standards
Risk and Benefits Group
C539-07
RTP, NC 27711
voice: (919) 541-0209
fax: (919) 541-5315
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Al Armendariz
To: Donaldson, Guy; Diggs, Thomas; Edlund, Carl; Erik Snyder; Starfield, Larry
Cc: Gray, David
Subject: Fw: Fw: Response to your request for San J uan EGU PM2.5 benefits
Date: 08/04/2011 10:03 AM

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
J anet McCabe
----- Original Message -----
From: Janet McCabe
Sent: 08/04/2011 10:52 AM EDT
To: Rob Brenner
Cc: Bryan Hubbell; Lydia Wegman; Neal Fann; Rosalina Rodriguez; Al
Armendariz; Lawrence Starfield; David Gray
Subject: Re: Fw: Response to your request for San Juan EGU PM2.5
benefits
Thanks, Rob and Neal, for running this analysis. these are annual
numbers, right?
looping in the Region 6 folks....
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
Rob Brenner---08/04/2011 10:22:27 AM---Hi J anet,
From: Rob Brenner/DC/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA
Cc: Lydia Wegman/RTP/USEPA/US@EPA, Rosalina
Rodriguez/RTP/USEPA/US@EPA, Bryan Hubbell/RTP/USEPA/US@EPA, Neal
Fann/RTP/USEPA/US@EPA
Date: 08/04/2011 10:22 AM
Subject: Fw: Response to your request for San J uan EGU PM2.5 benefits
Hi J anet,
FOIA Exemption (b)(5) - Deliberative Process Privilege
Rob
Neal Fann
----- Original Message -----
From: Neal Fann
Sent: 08/02/2011 04:56 PM EDT
To: Rob Brenner
Cc: Lydia Wegman; Rosalina Rodriguez; Bryan Hubbell
Subject: Response to your request for San Juan EGU PM2.5
benefits
Rob,
Summarized below are
Please let me know if you have any further questions, or if you need
me to document these results in a formal memo.
Best,
Neal
FOIA Exemption (b)(5) - Deliberative Process Privilege
_______________________________
Neal Fann
USEPA
Office of Air Quality Planning & Standards
Risk and Benefits Group
C539-07
RTP, NC 27711
voice: (919) 541-0209
fax: (919) 541-5315
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: J anet McCabe
To: Al Armendariz
Cc: Andrea Drinkard; David Gray
Subject: Re: New Mexico
Date: 08/04/2011 07:16 AM
I'm sure that's right--just want us to be prepared....
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
Al Armendariz---08/04/2011 06:42:08 AM---Hi, I had my folks look into this, and
we believe that the number of days and degree of improvement
From: Al Armendariz/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA
Cc: Andrea Drinkard/DC/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA
Date: 08/04/2011 06:42 AM
Subject: Re: New Mexico
Hi,
I had my folks look into this, and we believe that the number of
days and degree of improvement will be much greater than PNM is
estimating.
It boils down to being a point of technical disagreement.
Reasons include how best to model background ammonia
concentrations and other factors.
I'll ask the modelers to get david the number of days of
improvement.
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
-----Janet McCabe/DC/USEPA/US wrote: -----
To: David Gray/R6/USEPA/US@EPA, Andrea Drinkard/DC/USEPA/US@EPA,
Al Armendariz/R6/USEPA/US@EPA
From: Janet McCabe/DC/USEPA/US
Date: 08/03/2011 11:02PM
Subject: Re: New Mexico
d say
FOIA Exemption (b)(5) - Deliberative Process Privilege
Al--one of the things bill bumpers has said to me is that the
modeling shows that the plant impacts visibility perceptibly
only a very few days each year. I didn't see that issue in the
FRN, though I might have missed it. Is that something we might
hear from opponents of our decision and do we have a response?
David Gray
----- Original Message -----
From: David Gray
Sent: 08/03/2011 11:53 PM EDT
To: Laura Vaught; Janet McCabe; Andrea Drinkard; "David
Gray" <gray.david@epa.gov>; Al Armendariz
Subject: Re: New Mexico
Laura,
These materials are draft and are currently under review. That
said - I wanted to get you some information this evening.

David
New Mexico Interstate Transport and Regional Haze Federal
Implementation Plan
Communication Strategy
Action Summary
EPA is under a consent decree deadline to sign a final action by
August 5 to issue a visibility transport decision for New
Mexico. EPA is issuing a Federal Implementation Plan (FIP)
under the Clean Air Act for the San Juan Generating Station
power plant, which will significantly reduce harmful emissions
and improve visibility and respiratory health for the
surrounding multi-state area. EPA&#8217;s FIP addresses both the
Visibility Transport and Regional Haze requirements that are
applicable at the San Juan Generating Station power plant. Under
the FIP, the plant&#8217;s operators will be required to install
the best pollution-control technology available for this type of
facility, which uses four coal-fired generating units. EPA found
SCR technology to be a cost effective control to achieve
required emission reductions.
Desk Statement


Topline messages
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege




Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Al Armendariz
To: David Gray
Cc: Andrea Drinkard
Subject: Re: *Confidential: Re: Confidential - Predecision Information
Date: 08/04/2011 05:57 AM















______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
-----David Gray/R6/USEPA/US wrote: -----
To: Andrea Drinkard/DC/USEPA/US@EPA, Janet McCabe/DC/USEPA/US@EPA, Al Armendariz/R6/USEPA/US@EPA
From: David Gray/R6/USEPA/US
Date: 08/03/2011 09:56PM
Subject: *Confidential: Re: Confidential - Predecision Information
Corrected version per comments. Also looping in Al.
Let me know if everyone is comfortable with this version going to the WH.
David
New Mexico Interstate Transport and Regional Haze Federal Implementation Plan
Communication Strategy
Action Summary
EPA is under a consent decree deadline to sign a final action by August 5 to issue a visibility
transport decision for New Mexico. EPA is issuing a Federal Implementation Plan (FIP) under the
Clean Air Act for the San Juan Generating Station power plant, which will significantly reduce
harmful emissions and improve visibility and respiratory health for the surrounding multi-state
area. EPAs FIP addresses both the Visibility Transport and Regional Haze requirements that are
applicable at the San Juan Generating Station power plant. Under the FIP, the plants operators
will be required to install the best pollution-control technology available for this type of
facility, which uses four coal-fired generating units. EPA found SCR technology to be a cost
effective control to achieve required emission reductions.
Desk Statement








FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
Topline messages




















FOIA Exemption (b)(5) - Deliberative Process Privilege
From: J anet McCabe
To: David Gray; Andrea Drinkard; Al Armendariz
Subject: Re: *Confidential: Re: Confidential - Predecision Information
Date: 08/03/2011 10:39 PM
A couple comments via bberry--apologize if they sound short.
I don't think it's right to say that a 30 year old plant is one of thje oldest plants in
the country. There are lots that are older.
David Gray
----- Original Message -----
From: David Gray
Sent: 08/03/2011 09:56 PM CDT
To: Andrea Drinkard; Janet McCabe; Al Armendariz
Subject: *Confidential: Re: Confidential - Predecision Information
Corrected version per comments. Also looping in Al.
Let me know if everyone is comfortable with this version going to the WH.
David
New Mexico Interstate Transport and Regional Haze Federal Implementation
Plan
Communication Strategy
Action Summary
EPA is under a consent decree deadline to sign a final action by August 5 to
issue a visibility transport decision for New Mexico. EPA is issuing a Federal
Implementation Plan (FIP) under the Clean Air Act for the San Juan Generating
Station power plant, which will significantly reduce harmful emissions and
improve visibility and respiratory health for the surrounding multi-state area.
EPAs FIP addresses both the Visibility Transport and Regional Haze
requirements that are applicable at the San Juan Generating Station power plant.
Under the FIP, the plants operators will be required to install the best pollution-
control technology available for this type of facility, which uses four coal-fired
generating units. EPA found SCR technology to be a cost effective control to
achieve required emission reductions.
Desk Statement

Topline messages






FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege

From: Carl Edlund
To: David Gray; Al Armendariz; diggs.thomas@epa.gov; donaldson.guy@epa.gov; Lawrence Starfield; Layla
Mansuri; Suzanne Murray; Suzanne Smith-Roquemore
Subject: Re: San J uan Generating Station -- tone OF RTC
Date: 08/03/2011 12:50 PM
Attachments: NM FIP- complete 82Regionalfinal.CEE.PAGE 50 TO END.docx
And ..here are all of my suggested edits from page 50 to the end of the thing
David Gray---08/03/2011 09:34:36 AM---Here is a quick draft of a plain-language
introduction for the Federal Register Notice. Please revi
From: David Gray/R6/USEPA/US
To: diggs.thomas@epa.gov, Lawrence Starfield/R6/USEPA/US@EPA,
donaldson.guy@epa.gov, Suzanne Murray/R6/USEPA/US@EPA, Suzanne
Smith-Roquemore/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA,
Layla Mansuri/R6/USEPA/US@EPA, Al Armendariz/R6/USEPA/US@EPA
Date: 08/03/2011 09:34 AM
Subject: Re: San J uan Generating Station -- tone
Here is a quick draft of a plain-language introduction for the Federal Register Notice.
Please review and send me your comments. I understand we need a final by noon
today.
[attachment "NM FIP FR INTRO.docx" deleted by Carl Edlund/R6/USEPA/US]
San J uan Generating Station -- tone
San J uan Generating Station -- tone
Lawrence
Starfield
to: Carl Edlund, diggs.thomas, donaldson.guy, Suzanne
Murray, Suzanne Smith-Roquemore, David Gray, Layla
Mansuri
08/02/2011
05:14 PM
Cc: Al Armendariz
From: Lawrence Starfield/R6/USEPA/US
FOIA Exemption (b)(5) - Deliberative Process
Privilege
To: Carl Edlund/R6/USEPA/US@EPA, diggs.thomas@epa.gov, donaldson.guy@epa.gov, Suzanne
Murray/R6/USEPA/US@EPA, Suzanne Smith-Roquemore/R6/USEPA/US@EPA, David
Gray/R6/USEPA/US, Layla Mansuri/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US
DELIBERATIVE PROCESS -- CONFIDENTIAL




Obviously, everyone will have a chance to review any revisions on both
topics. Thanks for your patience and help.
Larry
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Carl Edlund
To: David Gray; Al Armendariz; diggs.thomas@epa.gov; donaldson.guy@epa.gov; Lawrence Starfield; Layla
Mansuri; Suzanne Murray; Suzanne Smith-Roquemore
Subject: Re: San J uan Generating Station -- tone of RTC
Date: 08/03/2011 12:18 PM
Attachments: NM FIP- complete 82Regionalfinal.CEE TO PAGE 80.docx
And here is an installment on toning pages 50 through 80 of the RTC. Still working
on the remainder but I thought that I'd shoot this out
David Gray---08/03/2011 09:34:36 AM---Here is a quick draft of a plain-language
introduction for the Federal Register Notice. Please revi
From: David Gray/R6/USEPA/US
To: diggs.thomas@epa.gov, Lawrence Starfield/R6/USEPA/US@EPA,
donaldson.guy@epa.gov, Suzanne Murray/R6/USEPA/US@EPA, Suzanne
Smith-Roquemore/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA,
Layla Mansuri/R6/USEPA/US@EPA, Al Armendariz/R6/USEPA/US@EPA
Date: 08/03/2011 09:34 AM
Subject: Re: San J uan Generating Station -- tone
Here is a quick draft of a plain-language introduction for the Federal Register Notice.
Please review and send me your comments. I understand we need a final by noon
today.
[attachment "NM FIP FR INTRO.docx" deleted by Carl Edlund/R6/USEPA/US]
San J uan Generating Station -- tone
San J uan Generating Station -- tone
Lawrence
Starfield
to: Carl Edlund, diggs.thomas, donaldson.guy, Suzanne
Murray, Suzanne Smith-Roquemore, David Gray, Layla
Mansuri
08/02/2011
05:14 PM
Cc: Al Armendariz
From: Lawrence Starfield/R6/USEPA/US
FOIA Exemption (b)(5) - Deliberative Process
Privilege
To: Carl Edlund/R6/USEPA/US@EPA, diggs.thomas@epa.gov, donaldson.guy@epa.gov, Suzanne
Murray/R6/USEPA/US@EPA, Suzanne Smith-Roquemore/R6/USEPA/US@EPA, David
Gray/R6/USEPA/US, Layla Mansuri/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US
DELIBERATIVE PROCESS -- CONFIDENTIAL




Obviously, everyone will have a chance to review any revisions on both
topics. Thanks for your patience and help.
Larry
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: David Gray
To: diggs.thomas@epa.gov; Lawrence Starfield/R6/USEPA/US@EPA; donaldson.guy@epa.gov; Suzanne Murray;
Suzanne Smith-Roquemore; Carl Edlund; Layla Mansuri; Al Armendariz/R6/USEPA/US@EPA
Subject: Re: San J uan Generating Station -- tone
Date: 08/03/2011 09:34 AM
Attachments: NM FIP FR INTRO.docx
Here is a quick draft of a plain-language introduction for the Federal Register Notice.
Please review and send me your comments. I understand we need a final by noon
today.
San J uan Generating Station -- tone
San J uan Generating Station -- tone
Lawrence
Starfield
to: Carl Edlund, diggs.thomas, donaldson.guy, Suzanne
Murray, Suzanne Smith-Roquemore, David Gray, Layla
Mansuri
08/02/2011
05:14 PM
Cc: Al Armendariz
From: Lawrence Starfield/R6/USEPA/US
To: Carl Edlund/R6/USEPA/US@EPA, diggs.thomas@epa.gov, donaldson.guy@epa.gov, Suzanne
Murray/R6/USEPA/US@EPA, Suzanne Smith-Roquemore/R6/USEPA/US@EPA, David
Gray/R6/USEPA/US, Layla Mansuri/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US
DELIBERATIVE PROCESS -- CONFIDENTIAL
FOIA Exemption (b)
(5) - Deliberative
Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege




Obviously, everyone will have a chance to review any revisions on both
topics. Thanks for your patience and help.
Larry
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Carl Edlund
To: Lawrence Starfield
Cc: Al Armendariz; David Gray; diggs.thomas@epa.gov; donaldson.guy@epa.gov; Layla Mansuri; Suzanne Murray;
Suzanne Smith-Roquemore
Subject: Re: San J uan Generating Station -- tone
Date: 08/02/2011 10:50 PM
Will look forward to help with the next iteration.
Lawrence Starfield---08/02/2011 05:14:03 PM---DELIBERATIVE PROCESS --
CONFIDENTIAL
From: Lawrence Starfield/R6/USEPA/US
To: Carl Edlund/R6/USEPA/US@EPA, diggs.thomas@epa.gov,
donaldson.guy@epa.gov, Suzanne Murray/R6/USEPA/US@EPA, Suzanne
Smith-Roquemore/R6/USEPA/US@EPA, David Gray/R6/USEPA/US, Layla
Mansuri/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US
Date: 08/02/2011 05:14 PM
Subject: San J uan Generating Station -- tone
DELIBERATIVE PROCESS -- CONFIDENTIAL




Obviously, everyone will have a chance to review any revisions on both
topics. Thanks for your patience and help.
FOIA Exemption (b)(5) - Deliberative Process Privilege
Larry
From: Lawrence Starfield
To: David Gray
Cc: Carl Edlund; Layla Mansuri; Suzanne Murray; Al Armendariz; Suzanne Smith-Roquemore/R6/USEPA/US@EPA
Subject: Re: NM FIP Draft materials
Date: 08/01/2011 10:24 AM
Attachments: NM Haze and San J uan Internal Q&A 07-28-2011 aa ls.docx
David,
I had a few additional comments on the Q's and A's:

I've provided language on most of these points in the attached redline/strikeout.
Larry
Re: NM FIP Draft materials
Re: NM FIP Draft materials
Al
Armendariz
to: David Gray
07/31/2011
10:54 PM
Cc: Carl Edlund, Lawrence Starfield, Layla Mansuri, Suzanne Murray
David,
Attached are my comments on the internal Q/A document. Probably
FOIA Exemption (b)(5) - Deliberative Process
Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
all I'll get to before Monday evening.
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
-----David Gray/R6/USEPA/US wrote: -----
To: Al Armendariz/R6/USEPA/US@EPA, Lawrence
Starfield/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Lawrence
Starfield/R6/USEPA/US@EPA, Layla Mansuri/R6/USEPA/US@EPA, Suzanne
Murray/R6/USEPA/US@EPA
From: David Gray/R6/USEPA/US
Date: 07/31/2011 09:33PM
Subject: NM FIP Draft materials
All - Here are the draft materials for the NM FIP announcement
from the team. They still need some work before going up to HQ.
Please share any comments with me.
David
(See attached file: NM Haze and San Juan Internal Q&A 07-28-
2011.docx)
(See attached file: Comm Strategy - NM FIP.docx)
(See attached file: Cong briefing sheet on NM FIP.docx)
[attachment "NM Haze and San Juan Internal Q&A 07-28-2011.docx"
removed by Al Armendariz/R6/USEPA/US]
[attachment "Comm Strategy - NM FIP.docx" removed by Al
Armendariz/R6/USEPA/US]
[attachment "Cong briefing sheet on NM FIP.docx" removed by Al
Armendariz/R6/USEPA/US][attachment "NM Haze and San Juan
Internal Q&A 07-28-2011 aa.docx" deleted by Lawrence
Starfield/R6/USEPA/US]
From: Lawrence Starfield
To: Al Armendariz
Subject: Re: NM FIP Draft materials
Date: 08/01/2011 08:12 AM
Good point: The visitors are 25M good reasons to clean up the air...
Sent by EPA Wireless E-Mail Services
----- Original Message -----
From: Al Armendariz
Sent: 07/31/2011 11:21 PM CDT
To: David Gray
Cc: Carl Edlund; Lawrence Starfield; Layla Mansuri; Suzanne Murray
Subject: Re: NM FIP Draft materials
some statistics from NPS:
NM --
13 national parks
1,657,550 visitors to national parks (in 2010)
$62,474,000 economic benefit from national park tourism (in 2009)
AZ --
22 national parks
10,546,150 visitors to national parks (in 2010)
$659,180,000 economic benefit from national park tourism (in 2009)
CO --
13 national parks
5,635,307 visitors to national parks (in 2010)
$336,956,000 economic benefit from national park tourism (in 2009)
UT --
13 national parks
8,975,525 visitors to national parks (in 2010)
$565,592,000 economic benefit from national park tourism (in 2009)
see for example:
http://www.nps.gov/state/ut/index.htm
http://www.nps.gov/state/co/index.htm
http://www.nps.gov/state/az/index.htm
http://www.nps.gov/state/nm/index.htm
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
-----David Gray/R6/USEPA/US wrote: -----
To: Al Armendariz/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA,
Lawrence Starfield/R6/USEPA/US@EPA, Layla Mansuri/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA
From: David Gray/R6/USEPA/US
Date: 07/31/2011 09:33PM
Subject: NM FIP Draft materials
All - Here are the draft materials for the NM FIP announcement from the team. They still need some
work before going up to HQ. Please share any comments with me.
David
(See attached file: NM Haze and San Juan Internal Q&A 07-28-2011.docx)
(See attached file: Comm Strategy - NM FIP.docx)
(See attached file: Cong briefing sheet on NM FIP.docx)
[attachment "NM Haze and San Juan Internal Q&A 07-28-2011.docx" removed by Al
Armendariz/R6/USEPA/US]
[attachment "Comm Strategy - NM FIP.docx" removed by Al Armendariz/R6/USEPA/US]
[attachment "Cong briefing sheet on NM FIP.docx" removed by Al Armendariz/R6/USEPA/US]
From: Al Armendariz
To: David Gray
Cc: Carl Edlund; Lawrence Starfield; Layla Mansuri; Suzanne Murray
Subject: Re: NM FIP Draft materials
Date: 07/31/2011 10:54 PM
Attachments: NM Haze and San J uan Internal Q&A 07-28-2011 aa.docx
David,
Attached are my comments on the internal Q/A document. Probably all I'll get to before Monday
evening.
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
-----David Gray/R6/USEPA/US wrote: -----
To: Al Armendariz/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA,
Lawrence Starfield/R6/USEPA/US@EPA, Layla Mansuri/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA
From: David Gray/R6/USEPA/US
Date: 07/31/2011 09:33PM
Subject: NM FIP Draft materials
All - Here are the draft materials for the NM FIP announcement from the team. They still need some
work before going up to HQ. Please share any comments with me.
David
(See attached file: NM Haze and San Juan Internal Q&A 07-28-2011.docx)
(See attached file: Comm Strategy - NM FIP.docx)
(See attached file: Cong briefing sheet on NM FIP.docx)
[attachment "NM Haze and San Juan Internal Q&A 07-28-2011.docx" removed by Al
Armendariz/R6/USEPA/US]
[attachment "Comm Strategy - NM FIP.docx" removed by Al Armendariz/R6/USEPA/US]
[attachment "Cong briefing sheet on NM FIP.docx" removed by Al Armendariz/R6/USEPA/US]
From: RGA
To: Burns J ; Hicks K; Espino S; J ordan J ; Moss F; district3@fortworthgov.org; district4@fortworthgov.org;
Betsy.Price@fortworthgov.org; Burdette C
Subject: EPA gets it. Do you now?
Date: 07/29/2011 10:41 AM
Citizen health and safety.

Nonattainment consequences.

Gordon Appleman


EPA to oil and gas producers: Stop your leaks
Re
Thursday's proposals from the Environmental Protection Agency to cut air pollution from the
oil and natural gas industries are clearly newsworthy for the impact they could have on these
stalwarts of the Texas economy.
They also show a fascinating back story about how environmental activists have learned to
push public policy.
And they show why we have an EPA in the first place.
With Thursday's announcement, the EPA enters a 60-day comment period on proposed
revisions to standards in the Clean Air Act. The revisions apply to the oil and gas industries,
but it's clear that they are aimed at booming natural gas drilling like that in the 23-county
Barnett Shale in North Texas.
The revisions would apply to new facilities and those that undergo major alterations,
including what EPA says has grown to be 25,000 wells undergoing hydraulic fracturing or
refracturing every year. There are more than 15,000 wells in the Barnett Shale, with more
than 1,000 drilling permits issued in the first half of this year alone.
So, these proposed new rules are a pretty big deal in North Texas.
For the EPA, they're about the air we breathe. The message from the EPA to the oil and gas
industries: Stop your leaks, or at least 95 percent of them.
The primary target is what are called volatile organic compounds, or VOCs. When VOCs
become airborne, particularly in the summer, they become a major component in ground-
level ozone, or smog. That's a serious health hazard, especially for children with asthma or
bronchitis or older people with heart conditions.
The changes started in January 2009, the same month President Barack Obama took office.
Two Western-states environment groups, WildEarth Guardians and the San Juan Alliance,
filed a lawsuit against the EPA, saying the agency had failed its responsibility under the
Clean Air Act to periodically review emission standards for the oil and gas industry. The
reviews are required every eight years to keep up with advancements in pollution control
technology.
The lawsuit tactic, used by other groups targeting other environmental protections, paid off.
In February 2010, the U.S. Court of Appeals for the D.C. Circuit issued a consent decree
requiring the EPA to conduct the reviews and setting Thursday as the deadline for the
agency's proposals. New standards must be issued by Feb. 28.
Maybe the Obama EPA would have taken this action without a lawsuit, but WildEarth
Guardians and the San Juan Alliance forced the issue.
A key part of the proposals is that natural gas companies use what's called "green
completion" for new wells. The millions of gallons of water that is forced into wells to
fracture deep rock formations and allow gas to escape doesn't just stay there. It comes back
up, laden with gas bubbles.
The flowback process takes three to 10 days.
"Green completion" uses special equipment to separate gas from the water and capture it,
rather than allowing it to escape or burning it off. The EPA says this and other steps in the
proposed new standards would capture about $783 million worth of natural gas and
condensate (gasoline) by 2015. That's $29 million more than the requirements would cost the
gas companies.
Significant amounts of methane, the primary ingredient in natural gas, wouldn't escape into
the air. The EPA says methane is a "potent" greenhouse gas, 20 times more effective than
carbon dioxide at absorbing Earth's infrared radiation and contributing to global warming.
Some natural gas companies, including Devon Energy in the Barnett Shale, are already heavy
"green completion" users.
Environmental benefits that return more money than they cost -- what's wrong with that?
For one thing, the oil and gas industries don't like the EPA telling them what to do. For
another, hundreds of millions of dollars spent on environmental controls would earn far more
money if it were invested in new wells instead.
That's why we have the EPA, to balance corporate earnings with the public benefit of cleaner
air.
From: RGA
To: Undisclosed-Recipient:;
Subject: EPA to the rescue
Date: 07/29/2011 10:30 AM
"Better late than never."

Thank you, Mike

Gordon


EPA to oil and gas producers: Stop your leaks
Re
Thursday's proposals from the Environmental Protection Agency to cut air pollution
from the oil and natural gas industries are clearly newsworthy for the impact they
could have on these stalwarts of the Texas economy.
They also show a fascinating back story about how environmental activists have
learned to push public policy.
And they show why we have an EPA in the first place.
With Thursday's announcement, the EPA enters a 60-day comment period on
proposed revisions to standards in the Clean Air Act. The revisions apply to the oil
and gas industries, but it's clear that they are aimed at booming natural gas drilling
like that in the 23-county Barnett Shale in North Texas.
The revisions would apply to new facilities and those that undergo major alterations,
including what EPA says has grown to be 25,000 wells undergoing hydraulic
fracturing or refracturing every year. There are more than 15,000 wells in the
Barnett Shale, with more than 1,000 drilling permits issued in the first half of this
year alone.
So, these proposed new rules are a pretty big deal in North Texas.
For the EPA, they're about the air we breathe. The message from the EPA to the oil
and gas industries: Stop your leaks, or at least 95 percent of them.
The primary target is what are called volatile organic compounds, or VOCs. When
VOCs become airborne, particularly in the summer, they become a major component
in ground-level ozone, or smog. That's a serious health hazard, especially for
children with asthma or bronchitis or older people with heart conditions.
The changes started in J anuary 2009, the same month President Barack Obama took
office.
Two Western-states environment groups, WildEarth Guardians and the San J uan
Alliance, filed a lawsuit against the EPA, saying the agency had failed its
responsibility under the Clean Air Act to periodically review emission standards for
the oil and gas industry. The reviews are required every eight years to keep up with
advancements in pollution control technology.
The lawsuit tactic, used by other groups targeting other environmental protections,
paid off. In February 2010, the U.S. Court of Appeals for the D.C. Circuit issued a
consent decree requiring the EPA to conduct the reviews and setting Thursday as
the deadline for the agency's proposals. New standards must be issued by Feb. 28.
Maybe the Obama EPA would have taken this action without a lawsuit, but WildEarth
Guardians and the San J uan Alliance forced the issue.
A key part of the proposals is that natural gas companies use what's called "green
completion" for new wells. The millions of gallons of water that is forced into wells
to fracture deep rock formations and allow gas to escape doesn't just stay there. It
comes back up, laden with gas bubbles.
The flowback process takes three to 10 days.
"Green completion" uses special equipment to separate gas from the water and
capture it, rather than allowing it to escape or burning it off. The EPA says this and
other steps in the proposed new standards would capture about $783 million worth
of natural gas and condensate (gasoline) by 2015. That's $29 million more than the
requirements would cost the gas companies.
Significant amounts of methane, the primary ingredient in natural gas, wouldn't
escape into the air. The EPA says methane is a "potent" greenhouse gas, 20 times
more effective than carbon dioxide at absorbing Earth's infrared radiation and
contributing to global warming.
Some natural gas companies, including Devon Energy in the Barnett Shale, are
already heavy "green completion" users.
Environmental benefits that return more money than they cost -- what's wrong with
that?
For one thing, the oil and gas industries don't like the EPA telling them what to do.
For another, hundreds of millions of dollars spent on environmental controls would
earn far more money if it were invested in new wells instead.
That's why we have the EPA, to balance corporate earnings with the public benefit
of cleaner air.
From: Richard Windsor
To: Al Armendariz; Gina McCarthy; McCabe, J anet; Seth Oster; Arvin Ganesan; Bob Sussman; Diane Thompson;
Scott Fulton; Michael Goo
Cc: Michael Moats
Subject: Re: oil/gas air rules editorial. Editorials & Opinions | Fort Worth Star-Telegram
Date: 07/28/2011 11:15 PM
Importance: High
Let's reuse his wonderful line as often as we can - "That's why we have the EPA, to
balance corporate earnings with the public benefit of cleaner air."
Congrats Gina, J anet, Bob S et al for doing what EPA is supposed to do.
Lisa
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 07/28/2011 10:06 PM EDT
To: Gina McCarthy; "McCabe, Janet" <mccabe.janet@epa.gov>; John Millett;
Seth Oster; Arvin Ganesan; "Sussman, Bob" <sussman.bob@epa.gov>; "Windsor,
Richard" <windsor.richard@epa.gov>
Subject: oil/gas air rules editorial. Editorials & Opinions | Fort
Worth Star-Telegram
Nice editorial from the heart of the Barnett Shale. -- Al
--------
EPA to oil and gas producers: Stop your leaks!
Posted Thursday, J ul. 28, 2011
By MIKE NORMAN
mnorman@ star-telegram.com
Thursday's proposals from the Environmental Protection Agency to cut
air pollution from the oil and natural gas industries are clearly
newsworthy for the impact they could have on these stalwarts of the
Texas economy.
They also show a fascinating back story about how environmental
activists have learned to push public policy.
And they show why we have an EPA in the first place.
With Thursday's announcement, the EPA enters a 60-day comment
period on proposed revisions to standards in the Clean Air Act. The
revisions apply to the oil and gas industries, but it's clear that they are
aimed at booming natural gas drilling like that in the 23-county Barnett
Shale in North Texas.
The revisions would apply to new facilities and those that undergo
major alterations, including what EPA says has grown to be 25,000
wells undergoing hydraulic fracturing or refracturing every year. There
are more than 15,000 wells in the Barnett Shale, with more than 1,000
drilling permits issued in the first half of this year alone.
So, these proposed new rules are a pretty big deal in North Texas.
For the EPA, they're about the air we breathe. The message from the
EPA to the oil and gas industries: Stop your leaks, or at least 95
percent of them.
The primary target is what are called volatile organic compounds, or
VOCs. When VOCs become airborne, particularly in the summer, they
become a major component in ground-level ozone, or smog. That's a
serious health hazard, especially for children with asthma or bronchitis
or older people with heart conditions.
The changes started in J anuary 2009, the same month President
Barack Obama took office.
Two Western-states environment groups, WildEarth Guardians and the
San J uan Alliance, filed a lawsuit against the EPA, saying the agency
had failed its responsibility under the Clean Air Act to periodically
review emission standards for the oil and gas industry. The reviews are
required every eight years to keep up with advancements in pollution
control technology.
The lawsuit tactic, used by other groups targeting other environmental
protections, paid off. In February 2010, the U.S. Court of Appeals for
the D.C. Circuit issued a consent decree requiring the EPA to conduct
the reviews and setting Thursday as the deadline for the agency's
proposals. New standards must be issued by Feb. 28.
Maybe the Obama EPA would have taken this action without a lawsuit,
but WildEarth Guardians and the San J uan Alliance forced the issue.
A key part of the proposals is that natural gas companies use what's
called "green completion" for new wells. The millions of gallons of
water that is forced into wells to fracture deep rock formations and
allow gas to escape doesn't just stay there. It comes back up, laden
with gas bubbles.
The flowback process takes three to 10 days.
"Green completion" uses special equipment to separate gas from the
water and capture it, rather than allowing it to escape or burning it off.
The EPA says this and other steps in the proposed new standards
would capture about $783 million worth of natural gas and condensate
(gasoline) by 2015. That's $29 million more than the requirements
would cost the gas companies.
Significant amounts of methane, the primary ingredient in natural gas,
wouldn't escape into the air. The EPA says methane is a "potent"
greenhouse gas, 20 times more effective than carbon dioxide at
absorbing Earth's infrared radiation and contributing to global warming.
Some natural gas companies, including Devon Energy in the Barnett
Shale, are already heavy "green completion" users.
Environmental benefits that return more money than they cost --
what's wrong with that?
For one thing, the oil and gas industries don't like the EPA telling them
what to do. For another, hundreds of millions of dollars spent on
environmental controls would earn far more money if it were invested
in new wells instead.
That's why we have the EPA, to balance corporate earnings with the
public benefit of cleaner air.
Mike Norman is editorial director of the Star-Telegram
817-390-7830
http://www.star-telegram.com/2011/07/28/3254327/epa-to-oil-and-
gas-producers-stop.html

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: David Gray
To: Al Armendariz
Subject: Re: oil/gas air rules editorial. Editorials & Opinions | Fort Worth Star-Telegram
Date: 07/28/2011 09:47 PM
Thank you. The team did a good job. Lots of thank you to spread
around.
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 07/28/2011 10:34 PM EDT
To: "Gray, David" <gray.david@epa.gov>
Subject: Fw: oil/gas air rules editorial. Editorials &
Opinions | Fort Worth Star-Telegram
Thanks for all the help on this the last few days. Really important for
all 5 of our states.

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
Gina McCarthy
----- Original Message -----
From: Gina McCarthy
Sent: 07/28/2011 10:09 PM EDT
To: Al Armendariz
Subject: Re: oil/gas air rules editorial. Editorials &
Opinions | Fort Worth Star-Telegram
That better than we could have expected. Thanks for the outreach
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 07/28/2011 10:06 PM EDT
To: Gina McCarthy; "McCabe, Janet" <mccabe.janet@epa.gov>;
John Millett; Seth Oster; Arvin Ganesan; "Sussman, Bob"
<sussman.bob@epa.gov>; "Windsor, Richard"
<windsor.richard@epa.gov>
Subject: oil/gas air rules editorial. Editorials & Opinions
| Fort Worth Star-Telegram
Nice editorial from the heart of the Barnett Shale. -- Al
--------
EPA to oil and gas producers: Stop your leaks!
Posted Thursday, J ul. 28, 2011
By MIKE NORMAN
mnorman@ star-telegram.com
Thursday's proposals from the Environmental Protection Agency to cut
air pollution from the oil and natural gas industries are clearly
newsworthy for the impact they could have on these stalwarts of the
Texas economy.
They also show a fascinating back story about how environmental
activists have learned to push public policy.
And they show why we have an EPA in the first place.
With Thursday's announcement, the EPA enters a 60-day comment
period on proposed revisions to standards in the Clean Air Act. The
revisions apply to the oil and gas industries, but it's clear that they are
aimed at booming natural gas drilling like that in the 23-county Barnett
Shale in North Texas.
The revisions would apply to new facilities and those that undergo
major alterations, including what EPA says has grown to be 25,000
wells undergoing hydraulic fracturing or refracturing every year. There
are more than 15,000 wells in the Barnett Shale, with more than 1,000
drilling permits issued in the first half of this year alone.
So, these proposed new rules are a pretty big deal in North Texas.
For the EPA, they're about the air we breathe. The message from the
EPA to the oil and gas industries: Stop your leaks, or at least 95
percent of them.
The primary target is what are called volatile organic compounds, or
VOCs. When VOCs become airborne, particularly in the summer, they
become a major component in ground-level ozone, or smog. That's a
serious health hazard, especially for children with asthma or bronchitis
or older people with heart conditions.
The changes started in J anuary 2009, the same month President
Barack Obama took office.
Two Western-states environment groups, WildEarth Guardians and the
San J uan Alliance, filed a lawsuit against the EPA, saying the agency
had failed its responsibility under the Clean Air Act to periodically
review emission standards for the oil and gas industry. The reviews are
required every eight years to keep up with advancements in pollution
control technology.
The lawsuit tactic, used by other groups targeting other environmental
protections, paid off. In February 2010, the U.S. Court of Appeals for
the D.C. Circuit issued a consent decree requiring the EPA to conduct
the reviews and setting Thursday as the deadline for the agency's
proposals. New standards must be issued by Feb. 28.
Maybe the Obama EPA would have taken this action without a lawsuit,
but WildEarth Guardians and the San J uan Alliance forced the issue.
A key part of the proposals is that natural gas companies use what's
called "green completion" for new wells. The millions of gallons of
water that is forced into wells to fracture deep rock formations and
allow gas to escape doesn't just stay there. It comes back up, laden
with gas bubbles.
The flowback process takes three to 10 days.
"Green completion" uses special equipment to separate gas from the
water and capture it, rather than allowing it to escape or burning it off.
The EPA says this and other steps in the proposed new standards
would capture about $783 million worth of natural gas and condensate
(gasoline) by 2015. That's $29 million more than the requirements
would cost the gas companies.
Significant amounts of methane, the primary ingredient in natural gas,
wouldn't escape into the air. The EPA says methane is a "potent"
greenhouse gas, 20 times more effective than carbon dioxide at
absorbing Earth's infrared radiation and contributing to global warming.
Some natural gas companies, including Devon Energy in the Barnett
Shale, are already heavy "green completion" users.
Environmental benefits that return more money than they cost --
what's wrong with that?
For one thing, the oil and gas industries don't like the EPA telling them
what to do. For another, hundreds of millions of dollars spent on
environmental controls would earn far more money if it were invested
in new wells instead.
That's why we have the EPA, to balance corporate earnings with the
public benefit of cleaner air.
Mike Norman is editorial director of the Star-Telegram
817-390-7830
http://www.star-telegram.com/2011/07/28/3254327/epa-to-oil-and-
gas-producers-stop.html

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: J ohn Millett
To: Air Division Directors and Deputies; Al Armendariz; Alison Davis; Andrea Drinkard; Anhar Karimjee; Bonnie
Bellow; Carl Edlund; David Gray; Elias Rodriguez; J anet McCabe; J eff Whitlow; J im J ones; J im Martin; J oseph
Goffman; Kate Fay; Lucy Edmondson; Mary Mears; Patrick Egan; Paul Gunning; Peter Tsirigotis; rob
brenner@EPA; Millett.J ohn@epamail.epa.gov
Subject: AP: EPA targets air pollution from gas drilling boom
Date: 07/28/2011 03:58 PM
EPA targets air pollution from gas drilling
boom
By DINA CAPPIELLO
The Associated Press
WASHINGTON Faced with a natural gas drilling boom that has sullied the air in some
parts of the country, the Environmental Protection Agency on Thursday proposed for the first
time to control air pollution at oil and gas wells, particularly those drilled using a method
called hydraulic fracturing.
The proposal, issued to meet a court deadline, addresses air pollution problems reported in
places such as Wyoming, Texas, Pennsylvania and Colorado, where new drilling techniques
have led to a rush to obtain natural gas that was once considered inaccessible. More than
25,000 wells are being drilled each year by "fracking," a process by which sand, water and
chemicals are injected underground to fracture rock so gas can come out.
The proposed regulations are designed to eliminate most releases of smog- and soot-forming
pollutants from those wells. New controls on storage tanks, transmission pipelines and other
equipment at both oil and gas drilling sites on land would reduce by a quarter amounts
of cancer-causing air pollution and methane, the main ingredient in natural gas, but also one
of the most powerful contributors to global warming.
The rules, according to the EPA, actually would save energy companies about $30 million a
year because the companies could sell the gas they are forced to collect.
EPA Assistant Administrator Gina McCarthy said the steps announced Thursday will help
ensure "responsible production" of domestic energy. The agency is also in the process of
studying whether hydraulic fracturing is polluting water, research that also could lead to more
regulations on the practice.
In March, pollution from natural gas drilling in the Upper Green River Basin in western
Wyoming triggered levels of ground-level ozone, the main ingredient in smog, worse than
those recorded in Los Angeles, one of the smoggiest cities in the U.S.
In Dish, Texas, a rural town northwest of Dallas, the state's environmental regulators detected
levels of cancer-causing benzene, sometimes at levels dangerous to human health, likely
coming from industry's 60 drilling wells, gas production pads and rigs, a treating facility and
compressor station.
At the same time, a state study in Pennsylvania of air quality near Marcellus Shale drilling
sites in four counties found no emissions at levels that would threaten the health of nearby
residents or workers.
The gases escape into the atmosphere during drilling, from storage tanks, compressors along
pipelines and other equipment. Until now, the EPA has mainly controlled pollution from
natural gas processing plants. States have started to crack down on some emissions from well
sites, and industry has voluntarily taken steps to reduce pollution.
The American Petroleum Institute, the main lobbying arm of the industry, pressed the agency
to push back by six months its February 2012 deadline for finalizing the rules.
Environmental groups, who sued in 2009 to force the EPA to act, said the action Thursday
was already overdue.
"Solutions for clearing the air mean keeping more product in the pipelines," said Jeremy
Nichols of WildEarth Guardians, an advocacy group.
___
Follow Dina Cappiello on Twitter: (at)dinacappiello
~~~~~~~~~~~~~~~~~~~
J ohn Millett
Office of Air and Radiation Communications
U.S. Environmental Protection Agency
5411 Ariel Rios Building North
Washington, DC 20460
Phone: 202/564-2903
Cell:
From: Lawrence Starfield
To: Al Armendariz
Subject: Fw: Reply to Bumpers on visibility benefit from SCR at SJ GS
Date: 07/28/2011 03:51 PM
Al,
I had asked J oe to help refute Bill Bumpers' assertion that there is only a "6-8 day visibility benefit" from using SCR
at San J uan GS. In his response below, J oe did a nice job of laying out the full story. You may want to share with
J anet as well as Seth, since this issue is likely to come up.
Larry
----- Forwarded by Lawrence Starfield/R6/USEPA/US on 07/28/2011 03:49 PM -----
Reply to Bumpers on visibility benefit from SCR at SJ GS
J oe
Kordzi
to: Lawrence Starfield
07/28/2011
01:32 PM
Cc: Guy Donaldson, snyder.erik, Agustin Carbo-Lugo
Larry,
Here is a response to Mr. Bumpers assertion that the "visibility benefit will be characterized by those who oppose the
BART decision as not that great--only 6-8 days with visibility improvement greater than one deciview." Below is the
War and Peace version I emailed to Guy, but here is the readers digest version of the message:
Our modeling predicts there will be 80 days in which a visibility improvement of at least 1 deciview
will occur at a Class I area as a result of the installation of SCR at the SJ GS. In addition, this
modeling also predicts many more days with lesser amounts of visibility improvement at one or more
of the Class I areas. PNM's modeling and conclusions are based on a Non-Regulatory model.
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
----- Forwarded by J oe Kordzi/R6/USEPA/US on 07/28/2011 01:29 PM -----
From: J oe Kordzi/R6/USEPA/US
To: Guy Donaldson/R6/USEPA/US@EPA
Cc: Agustin Carbo-Lugo/R6/USEPA/US@EPA, Lea Anderson/DC/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA
Date: 07/27/2011 01:27 PM
Subject: Re: Fw: SJ GS
Guy,
I checked with Michael on this. Mr. Bumpers is incorrect in his characterization of the visibility benefit. I assume Mr.
Bumpers is attempting to critique the CALPUFF modeling we did and is trying to artificially narrow the visibility
assessment based on the use of the "98th percentile," which is a modeling results visibility metric. An uninformed
person may conclude that because (100%-98%) X 365 = 7.3, only 6-8 days show improvements > 1 dv. That
aside, first, note we are predicting a visibility improvement of 1 dv or greater at 10 of the 16 Class I areas:

The BART Guidelines state the 98 percentile of the visibility results should be used as follows: "the 98th percentile
value would only be used to determine whether a particular BART-eligible source would be subject to further review
by the State. In determining what, if any, emission controls should be required, the State will have the opportunity
to consider the frequency, duration, and intensity of a sources predicted effect on visibility." Therefore, although we
present our visibility analysis on the basis of the 98th percentile, we are not really constrained by it in assessing the
real visibility benefit. The 98th percentile is a snapshot of one day in the year - the day in each year on which the
8th highest visibility benefit is recorded. Again, the visibility benefit numbers you see summarized in our tables are
based on that metric. There are, of course, 7 other days in each year, for each Class I area, with greater visibility
benefits, that are ignored in this metric. Considering those days would raise the total days in which we predict a 1
dv or greater visibility benefit to 80 days. There are also many, many other days in which lesser visibility benefits
are predicted that are also ignored by using the 98th percentile. It's not that we think those values are erroneous,
its just that they are ignored for the purposes of the visibility metric, which is used to enable a consistent
methodology for comparison. Here is another way to look at the data, from the last page of the TSD:
For example, looking at the second column, you can see that just considering Mesa Verde, the number of days in
which the visibility impact was greater than 1 dv (RHR identifies a 1 dv impairment as "causing" visibility
impairment) drops from 115 to 43 just from installing SCR at the SJ GS. Considering all Class I areas, SCR at the
SJ GS would drop the days in which visibility is impaired by at least 1 dv from 348 to 68.
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
Guy Donaldson---07/27/2011 11:18:17 AM---J oe, Can you answer the visibilty question.
From: Guy Donaldson/R6/USEPA/US
To: J oe Kordzi/R6/USEPA/US@EPA, Agustin Carbo-Lugo/R6/USEPA/US@EPA
Cc: Thomas Diggs/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Lea Anderson/DC/USEPA/US@EPA
Date: 07/27/2011 11:18 AM
Subject: Fw: SJ GS
J oe,
Can you answer the visibilty question.
Agustin, I'm guessing you will get the lead on this. I imagine the easiest thing is to coordinate with Lea because
I'm sure she is putting something together for J anet.
----- Forwarded by Guy Donaldson/R6/USEPA/US on 07/27/2011 11:16 AM -----
From: Lawrence Starfield/R6/USEPA/US
To: Suzanne Murray/R6/USEPA/US@EPA, Suzanne Smith-Roquemore/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, "Tom Diggs"
<diggs.thomas@epa.gov>, "Guy Donaldson" <donaldson.guy@epa.gov>
Cc: Al Armendariz/R6/USEPA/US
Date: 07/27/2011 10:15 AM
Subject: Fw: SJ GS
Suzanne(s) - please share a summary of the American Corngrowers decision (I assume OGC is
preparing).
Carl/Tom/Guy - can you look at the argument that there is only a "6-8 day visibility benefit," and see
what that is based upon.
Thanks.
Larry
Sent by EPA Wireless E-Mail Services
J anet McCabe
----- Original Message -----
From: Janet McCabe
Sent: 07/26/2011 08:19 PM EDT
To: Avi Garbow; Lea Anderson; Sara Schneeberg; Al Armendariz; David Gray; Lawrence
Starfield; Josh Lewis; Laura Vaught; Lorie Schmidt
Cc: Gina McCarthy
Subject: SJGS
All,
I wanted to report to you a call I had with Bill Bumpers this evening about the BART decision.

--he agreed that as a factual matter, there is nothing new in the SIP than what we saw in the comments on the FIP
(thus he agrees that if we had already decided we didn't agree with their facts in consideration of their comments
on the FIP, it is likely that we would not approve their FIP -- except for the most recent submission on costs). His
point is that the submission of a SIP by the state is the thing that makes the difference and should be the basis for
EPA deferring the BART decision.
--he does not think there is much that the company would put on the table in terms of a creative solution, as
happened in Four Corners.
--he argues that the visibility benefit will be characterized by those who oppose the BART decision as not that great-
-only 6-8 days with visibility improvement greater than one deciview
finally, he asked if I could give him a heads up when we're about to announce the decision, and I told him I would.
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: J anet McCabe
To: william bumpers
Cc: Al Armendariz
Subject: Re: San J uan
Date: 07/27/2011 04:02 PM
Thanks for the heads up Bill. Bob is going to be doing a fair amount of traveling soon, though oi'm not
sure of the exact days.
From: [william.bumpers@bakerbotts.com]
Sent: 07/27/2011 01:26 PM EST
To: J anet McCabe
Subject: San J uan
Janet,
Thanks for the call last night. I wanted to give you a heads up that PNM has asked me to seek a
meeting with Bob Perciasepe to discuss the San Juan BART issues. Didn't want you to be caught
unawares. Also, I'll send you a follow up e-mail later with additional thoughts on how EPA might
proceed with the BART issue without imposing undue burdens or risks on PNM.
Bill
Confidentiality Notice: The information contained in this email and any attachments is intended only
for the recipient[s] listed above and may be privileged and confidential. Any dissemination, copying, or
use of or reliance upon such information by or to anyone other than the recipient[s] listed above is
prohibited. If you have received this message in error, please notify the sender immediately at the
email address above and destroy any and all copies of this message.

From: David Gray
To: Miguel Flores; Sam Coleman; David Gray; Carl Edlund; Carroll.Lynda@epamail.epa.gov; J ohn Blevins;
Knudson.Myron@epamail.epa.gov; Suzanne Murray/R6/USEPA/US@EPA; J eannine Hale/R6/USEPA/US@EPA;
Lawrence Starfield/R6/USEPA/US@EPA; Al Armendariz/R6/USEPA/US@EPA; Layla Mansuri
Subject: Fw: Region 6 Weekly Report J uly 25, 2011 [contains PREDECISION INFORMATION]
Date: 07/26/2011 08:21 AM
Region 6 Weekly Report July 25, 2011
[July 25 to August 8]
Contact: David Gray, 214-665-2200
SIGNIFICANT ACTIONS
Title V Petition New Mexico [PREDECISION INFORMATION]
By Monday, August 1, the Administrator will sign a decision on the appeal of a Title V
permit issued by the State of New Mexico to a natural gas compressor station called Sims
Mesa pursuant to Section 505(b)(2) of the Clean Air Act. The petition requests that EPA
object to the air Title V operating permit issued by the New Mexico Environmental
Department on March 19, 2009. This is an existing facility owned by Williams Four Corners,
LLC in Rio Arriba County, New Mexico. The petitioners are Wild Earth Guardians and San
Juan Citizens Alliance.
Baton Rouge Redesignation [PREDECISION INFORMATION]
On Tuesday, August 2, EPA will finalize a proposal to redesignate the five parish Baton
Rouge non-attainment area to attainment of the 1997 8-hour ozone standard. The area has
been in non-attainment of the ozone standard since it was first established in the 1970s. After
publication in the Federal Register, the public comment will be accepted for 30 days.
New Mexico Federal Implementation Plan Regional Haze [PREDECISION
INFORMATION]
On Friday, August 5, pursuant in part to a consent decree deadline with Wild Earth
Guardians, EPA Administrator is expected to take final action on the NM FIP. The FIP
establishes the Best Available Retrofit Technology (BART) for the San Juan Generating
Station, one of the largest power plants in New Mexico. The proposed FIP was published in
the Federal Register for public comment on December 21, 2010. The proposed FIP set limits
for emissions of sulfur dioxide, sulfuric acid and ammonia. The proposed FIP calls for
Selective Catalytic Reduction (SCR) on the plant's four units and results in significant
visibility improvements at 16 Class 1 areas in the Four Corners Area of the West.
Congressional interest has been high.
Pueblo of Laguna TAS [PREDECISION INFORMATION]
On Tuesday, August 5, EPA is scheduled to approve the Pueblo of Lagunas application for
Treatment as a State (TAS) under the Clean Air Act (CAA) in New Mexico. The Pueblo
submitted its TAS application on March 28, 2011 pursuant to the Clean Air Act Section
505(a)(2). The public comment period began on July 2 and closes on August 1. To date, no
significant comments have been received.
GRANT ANNOUNCEMENTS
ARC of Greater New Orleans, Louisiana Job Training Grant
On July 29, the EPA Director Sam Coleman, City of New Orleans and ARC Director will
announce the $300,000 grant award for the Environmental Workforce Development and Job
Training Program in New Orleans, Louisiana. ARC of Greater New Orleans is a 501(c)(3)
non-profit organization that serves people with intellectual disabilities. ARCs project places
residents into environmental jobs after 410 hours of training in solid waste management,
energy efficiency technologies and renewable energy preparation and installation. ARC will
work with local employers to facilitate job placement.
LEGISLATIVE ENGAGEMENT
EPA Regional Administrator Armendariz and Deputy AA Janet McCabe will meet (via
conference call) with Congressman Martin Heinrich regarding EPAs pending action on the
NM FIP and San Juan Generating Station owned by Public Service Company of New Mexico
(PNM). The call is scheduled (tentative) for Thursday, July 28
PUBLIC EVENTS
27th Annual Pretreatment Conference
On Tuesday, August 2, RA Armendariz will be the keynote speaker at the 27th Annual
Pretreatment Conference in Irving, TX.
New Orleans Urban Waters Program
On Wednesday, August 3, Deputy Director William Honker, meet with the Advisory
Council for the Greater New Orleans Water Management System to discuss EPAs Urban
Waters pilot. On Monday, August 4, the New Orleans Urban Waters pilot will officially kick
off with stakeholder meetings. EPA is leading a group of federal agencies that will be
implementing a New Orleans/Lake Ponchartrain pilot program under the Urban Waters
Federal Partnership. The partnerships focus is to enhance the quality, awareness, and use of
water resources in urban areas.
23rd Annual Texas Environmental Conference
On Tuesday, August 5, RA Armendariz will speak at the 23rd Annual Texas Environmental
Conference in Austin, TX. The Regional Administrator will address the Agencys priorities
and specific examples of successful implementation from the regions five state area. EPA
Deputy General Counsel Avi Garbow will also speak at this years conference.
OTHER ACTIVITIES
Healthy Schools Programs Video
On Wednesday, August 3, the University of Texas Southwestern Medical School production
crew will visit the Dallas EPA office to film a video promoting safe chemical management
practices in schools and the EPAs Healthy Schools programs.
From: Deborah Banks
To: Sabrina Hamilton; Gloria Hammond; Martha Faulkner
Cc: Tom Eagles; Venu Ghanta; J ulia Miller; Kirsten King; J ohn Millett; Mariana Cubeddu; Nicole Owens; Philip
Schwartz; Vickie Reed; Darryl Adams; Nathaniel J utras; Eileen Pritchard; J anet McCabe; Adrienne Kirkland;
Alan Rush; J oseph-J Dougherty; Mary Henigin; Al Armendariz; J effrey Robinson
Subject: Deadline for OA Signature 8/1/2011: Object to CAA Title V Permit - Williams Four Corners, LLC - Sims Mesa
Compressor Station. Rio Arriba County, New Mexico
Date: 07/25/2011 01:53 PM
Attachments: Revised Sims Mesa Title V Order 7-20-11 Clean no guidance.docx
Revised Sims Mesa Cover Memo 7-20-11.docx
Title V Permit package delivered to OAR Correspondence Unit this
afternoon. E-files attached.
07/ 25/ 2011 SAN#: N/ A CMS Control #: OAR-11-
001-1200
Object to Clean Air Act Title V Permit
Williams Four Corners, LLC - Sims Mesa
Compressor Station Rio Arriba County,
New Mexico
Tier: N/A RIN#:NA2060 Region06
TO: OAR Correspondence Unit
Title V Petition is ready for
Comments:
Under the terms of a consent decree agreed to
by EPA and WildEarth Guardians (WEG)/San
Juan Citizens Alliance, EPA must respond to this
petition by August 1, 2011
(OAR Point of Contact: Janet McCabe, 202 564-
3206)

Region06 Reg
Contact:
Al Armedariz (214) 665-2211
Region06 Mgmt.
Level Reviewer:
J eff Robinson (214) 665-6435



Communications
Contact:
From: Al Armendariz
To: J anet McCabe
Subject: Re: Re: PNM's San J uan Generating Station
Date: 07/24/2011 10:32 PM
Sounds like a plan...
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: J anet McCabe
Sent: 07/24/2011 08:16 PM EDT
To: Al Armendariz
Subject: Fw: Re: PNM's San J uan Generating Station
Al--after we have our internal discussion tomorrow, I presume you'll contact the state and
then we can see when it would work to contact Bumpers and what we would say....
Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
-----Forwarded by Janet McCabe/DC/USEPA/US on 07/24/2011 08:15PM -----
To: Janet McCabe/DC/USEPA/US@EPA
From: <william.bumpers@bakerbotts.com>
Date: 07/22/2011 05:51AM
Subject: Re: PNM's San Juan Generating Station
Janet,
I'm traveling today but would like to speak with you, and possibly Dr. Armendariz, early next
week to discuss the materials I sent. Would that be possible and/or productive? I know the time
is short for EPA to make some critcal decisions and I want to make sure the you and he have the
opportunity to consider all of the issues and implications of your options.
Regards and thanks,
Bill

From: J anet McCabe [mailto:McCabe.J anet@epamail.epa.gov]
Sent: Wednesday, J uly 20, 2011 06:30 PM
To: Bumpers, William
Subject: Re: PNM's San J uan Generating Station

Thanks Bill
From: [william.bumpers@bakerbotts.com]
Sent: 07/20/2011 04:58 PM EST
To: Al Armendariz
Cc: Janet McCabe; Gina McCarthy; <Patrick.Apodaca@pnmresources.com>
Subject: FW: PNM's San Juan Generating Station
Dr. Armendariz,
Please find attached three documents relevant to EPA's proposed federal implementation plan and
BART determination for the San Juan Generating Station (SJGS). As explained more fully in the
accompanying letters and power point, PNM Resources requested Sargent & Lundy to perform an
independent cost analysis for installing SCR technology at SJGS. I believe this additional information
and analysis should be helpful in EPA's on-going consideration of its proposed action. A hard copy of
these documents is being sent by overnight mail.
Please feel free to contact me if you have any questions or would like to discuss any aspect of the
issue.
Regards,
William Bumpers
Baker Botts LLP
1299 Pennsylvania Ave., NW
Washington, D.C. 20004
202-639-7718

<<S&L Report.pdf>> <<2011.7.20 - S&L Cover Letter.pdf>> <<2011.7.20 - Bumpers Letter to
Armendariz.pdf>>
Confidentiality Notice: The information contained in this email and any attachments is intended only
for the recipient[s] listed above and may be privileged and confidential. Any dissemination, copying,
or use of or reliance upon such information by or to anyone other than the recipient[s] listed above is
prohibited. If you have received this message in error, please notify the sender immediately at the
email address above and destroy any and all copies of this message.

From: J anet McCabe
To: william.bumpers@bakerbotts.com
Cc: Al Armendariz
Subject: Re: PNM's San J uan Generating Station
Date: 07/24/2011 07:14 PM
Bill--we should touch base early in the week. it'd be good if the three of us could get on
the phone at the same time. Al and I will see about some times that could work for both
of us....
Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
-----<william.bumpers@bakerbotts.com> wrote: -----
To: Janet McCabe/DC/USEPA/US@EPA
From: <william.bumpers@bakerbotts.com>
Date: 07/22/2011 05:51AM
Subject: Re: PNM's San Juan Generating Station
Janet,
I'm traveling today but would like to speak with you, and possibly Dr. Armendariz, early next
week to discuss the materials I sent. Would that be possible and/or productive? I know the time
is short for EPA to make some critcal decisions and I want to make sure the you and he have the
opportunity to consider all of the issues and implications of your options.
Regards and thanks,
Bill

From: J anet McCabe [mailto:McCabe.J anet@epamail.epa.gov]
Sent: Wednesday, J uly 20, 2011 06:30 PM
To: Bumpers, William
Subject: Re: PNM's San J uan Generating Station

Thanks Bill
From: [william.bumpers@bakerbotts.com]
Sent: 07/20/2011 04:58 PM EST
To: Al Armendariz
Cc: Janet McCabe; Gina McCarthy; <Patrick.Apodaca@pnmresources.com>
Subject: FW: PNM's San Juan Generating Station
Dr. Armendariz,
Please find attached three documents relevant to EPA's proposed federal implementation plan and
BART determination for the San Juan Generating Station (SJGS). As explained more fully in the
accompanying letters and power point, PNM Resources requested Sargent & Lundy to perform an
independent cost analysis for installing SCR technology at SJGS. I believe this additional information
and analysis should be helpful in EPA's on-going consideration of its proposed action. A hard copy of
these documents is being sent by overnight mail.
Please feel free to contact me if you have any questions or would like to discuss any aspect of the
issue.
Regards,
William Bumpers
Baker Botts LLP
1299 Pennsylvania Ave., NW
Washington, D.C. 20004
202-639-7718

<<S&L Report.pdf>> <<2011.7.20 - S&L Cover Letter.pdf>> <<2011.7.20 - Bumpers Letter to
Armendariz.pdf>>
Confidentiality Notice: The information contained in this email and any attachments is intended only
for the recipient[s] listed above and may be privileged and confidential. Any dissemination, copying,
or use of or reliance upon such information by or to anyone other than the recipient[s] listed above is
prohibited. If you have received this message in error, please notify the sender immediately at the
email address above and destroy any and all copies of this message.

From: Al Armendariz
To: Starfield, Larry; Mansuri, Layla
Subject: Fw: PNM's San J uan Generating Station
Date: 07/22/2011 06:53 AM
Fyi
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: J anet McCabe
Sent: 07/22/2011 06:41 AM EDT
To: "Al Armendariz" <armendariz.al@epa.gov>
Subject: Fw: PNM's San J uan Generating Station
Al, I'll wait to reply until after our meeting with bob this morning.
From: [william.bumpers@bakerbotts.com]
Sent: 07/22/2011 04:51 AM EST
To: J anet McCabe
Subject: Re: PNM's San J uan Generating Station
Janet,
I'm traveling today but would like to speak with you, and possibly Dr. Armendariz, early next week
to discuss the materials I sent. Would that be possible and/or productive? I know the time is short
for EPA to make some critcal decisions and I want to make sure the you and he have the
opportunity to consider all of the issues and implications of your options.
Regards and thanks,
Bill

From: J anet McCabe [mailto:McCabe.J anet@epamail.epa.gov]
Sent: Wednesday, J uly 20, 2011 06:30 PM
To: Bumpers, William
Subject: Re: PNM's San J uan Generating Station

Thanks Bill
From: [william.bumpers@bakerbotts.com]
Sent: 07/20/2011 04:58 PM EST
To: Al Armendariz
Cc: J anet McCabe; Gina McCarthy; <Patrick.Apodaca@pnmresources.com>
Subject: FW: PNM's San J uan Generating Station
Dr. Armendariz,
Please find attached three documents relevant to EPA's proposed federal implementation plan and
BART determination for the San Juan Generating Station (SJGS). As explained more fully in the
accompanying letters and power point, PNM Resources requested Sargent & Lundy to perform an
independent cost analysis for installing SCR technology at SJGS. I believe this additional information
and analysis should be helpful in EPA's on-going consideration of its proposed action. A hard copy of
these documents is being sent by overnight mail.
Please feel free to contact me if you have any questions or would like to discuss any aspect of the
issue.
Regards,
William Bumpers
Baker Botts LLP
1299 Pennsylvania Ave., NW
Washington, D.C. 20004
202-639-7718

<<S&L Report.pdf>> <<2011.7.20 - S&L Cover Letter.pdf>> <<2011.7.20 - Bumpers Letter to
Armendariz.pdf>>
Confidentiality Notice: The information contained in this email and any attachments is intended only
for the recipient[s] listed above and may be privileged and confidential. Any dissemination, copying, or
use of or reliance upon such information by or to anyone other than the recipient[s] listed above is
prohibited. If you have received this message in error, please notify the sender immediately at the
email address above and destroy any and all copies of this message.

From: Lawrence Starfield
To: Suzanne Smith; Al Armendariz; J oe Kordzi
Cc: Tom Diggs; Edlund, Carl; Murray, Suzanne
Subject: Re: Fw: PNM's San J uan Generating Station
Date: 07/21/2011 07:41 AM
What have we heard from Gina?
Does she want us to look at the info to see "if" it is significant enough

Larry
Sent by EPA Wireless E-Mail Services
Suzanne Smith
----- Original Message -----
From: Suzanne Smith
Sent: 07/21/2011 08:26 AM EDT
To: Al Armendariz; Joe Kordzi
Cc: "Diggs, Thomas" <diggs.thomas@epa.gov>; "Edlund, Carl"
<edlund.carl@epa.gov>; "Murray, Suzanne"
<murray.suzanne@epa.gov>; Lawrence Starfield


Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 07/20/2011 11:08 PM EDT
To: Suzanne Smith; Joe Kordzi
Cc: "Diggs, Thomas" <diggs.thomas@epa.gov>; "Edlund, Carl"
<edlund.carl@epa.gov>; "Murray, Suzanne"
<murray.suzanne@epa.gov>; Lawrence Starfield
Subject: Re: Fw: PNM's San Juan Generating Station
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
Suzanne Smith
----- Original Message -----
From: Suzanne Smith
Sent: 07/20/2011 10:42 PM EDT
To: Al Armendariz; Joe Kordzi
Cc: "Diggs, Thomas" <diggs.thomas@epa.gov>; "Edlund, Carl"
<edlund.carl@epa.gov>; "Murray, Suzanne"
<murray.suzanne@epa.gov>; Lawrence Starfield
Subject: Re: Fw: PNM's San Juan Generating Station
J oe is right.
We can work on the exact language.
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 07/20/2011 09:44 PM EDT
To: Joe Kordzi
Cc: "Diggs, Thomas" <diggs.thomas@epa.gov>; "Edlund, Carl"
<edlund.carl@epa.gov>; "Murray, Suzanne"
<murray.suzanne@epa.gov>; Suzanne Smith; Lawrence Starfield
Subject: Re: Fw: PNM's San Juan Generating Station
J oe,
You bring up very valid points. I haven't read the documents sent from
PNM, and as you suggest,
Best,
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
J oe Kordzi
----- Original Message -----
From: Joe Kordzi
Sent: 07/20/2011 07:57 PM CDT
To: Al Armendariz
Cc: "Diggs, Thomas" <diggs.thomas@epa.gov>; "Edlund, Carl"
<edlund.carl@epa.gov>; "Murray, Suzanne"
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
<murray.suzanne@epa.gov>; Suzanne Smith; Lawrence Starfield
Subject: Re: Fw: PNM's San Juan Generating Station
Al,
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
Fw: PNM's San J uan Generating Station
Fw: PNM's San J uan Generating Station
Al
Armendariz
to: Starfield, Larry, Edlund, Carl, Diggs,
Thomas, J oe Kordzi, Murray, Suzanne,
Smith, Suzanne
07/20/2011
05:28 PM
Cc: "McCabe, J anet", "McCarthy, Gina"
Tom and Guy,
Attached are documents I just received about SJGS.
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: [william.bumpers@bakerbotts.com]
Sent: 07/20/2011 04:58 PM EST
To: Al Armendariz
Cc: Janet McCabe; Gina McCarthy; <Patrick.Apodaca@pnmresources.com>
Subject: FW: PNM's San Juan Generating Station
Dr. Armendariz,
Please find attached three documents relevant to EPA's proposed
federal implementation plan and BART determination for the San Juan
Generating Station (SJGS). As explained more fully in the
accompanying letters and power point, PNM Resources requested
Sargent & Lundy to perform an independent cost analysis for installing
SCR technology at SJGS. I believe this additional information and
analysis should be helpful in EPA's on-going consideration of its
proposed action. A hard copy of these documents is being sent by
overnight mail.
Please feel free to contact me if you have any questions or would like to
discuss any aspect of the issue.
Regards,
William Bumpers
Baker Botts LLP
1299 Pennsylvania Ave., NW
Washington, D.C. 20004
202-639-7718

<<S&L Report.pdf>> <<2011.7.20 - S&L Cover Letter.pdf>>
<<2011.7.20 - Bumpers Letter to Armendariz.pdf>>
Confidentiality Notice: The information contained in this email and any
attachments is intended only for the recipient[s] listed above and may
be privileged and confidential. Any dissemination, copying, or use of or
reliance upon such information by or to anyone other than the
recipient[s] listed above is prohibited. If you have received this message
in error, please notify the sender immediately at the email address
above and destroy any and all copies of this message.
[attachment "S&L Report.pdf" deleted by Joe Kordzi/R6/USEPA/US]
[attachment "2011.7.20 - S&L Cover Letter.pdf" deleted by Joe
Kordzi/R6/USEPA/US] [attachment "2011.7.20 - Bumpers Letter to
Armendariz.pdf" deleted by Joe Kordzi/R6/USEPA/US]
From: Suzanne Smith
To: Al Armendariz; J oe Kordzi
Cc: Diggs, Thomas; Edlund, Carl; Murray, Suzanne; Lawrence Starfield
Subject: Re: Fw: PNM's San J uan Generating Station
Date: 07/21/2011 06:52 AM
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 07/20/2011 11:08 PM EDT
To: Suzanne Smith; Joe Kordzi
Cc: "Diggs, Thomas" <diggs.thomas@epa.gov>; "Edlund, Carl"
<edlund.carl@epa.gov>; "Murray, Suzanne"
<murray.suzanne@epa.gov>; Lawrence Starfield
Subject: Re: Fw: PNM's San Juan Generating Station
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
Suzanne Smith
----- Original Message -----
From: Suzanne Smith
Sent: 07/20/2011 10:42 PM EDT
To: Al Armendariz; Joe Kordzi
Cc: "Diggs, Thomas" <diggs.thomas@epa.gov>; "Edlund, Carl"
<edlund.carl@epa.gov>; "Murray, Suzanne"
<murray.suzanne@epa.gov>; Lawrence Starfield
Subject: Re: Fw: PNM's San Juan Generating Station
J oe is right.
We can work on the exact language.
Al Armendariz
----- Original Message -----
From: Al Armendariz
FOIA Exemption (b)(5) - Deliberative Process Privilege
Sent: 07/20/2011 09:44 PM EDT
To: Joe Kordzi
Cc: "Diggs, Thomas" <diggs.thomas@epa.gov>; "Edlund, Carl"
<edlund.carl@epa.gov>; "Murray, Suzanne"
<murray.suzanne@epa.gov>; Suzanne Smith; Lawrence Starfield
Subject: Re: Fw: PNM's San Juan Generating Station
J oe,
You bring up very valid points. I haven't read the documents sent from
PNM, and as you suggest,
Best,
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
J oe Kordzi
----- Original Message -----
From: Joe Kordzi
Sent: 07/20/2011 07:57 PM CDT
To: Al Armendariz
Cc: "Diggs, Thomas" <diggs.thomas@epa.gov>; "Edlund, Carl"
<edlund.carl@epa.gov>; "Murray, Suzanne"
<murray.suzanne@epa.gov>; Suzanne Smith; Lawrence Starfield
Subject: Re: Fw: PNM's San Juan Generating Station
Al,
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
Fw: PNM's San J uan Generating Station
FOIA Exemption (b)(5) - Deliberative Process Privilege
Fw: PNM's San J uan Generating Station
Al
Armendariz
to: Starfield, Larry, Edlund, Carl, Diggs,
Thomas, J oe Kordzi, Murray, Suzanne,
Smith, Suzanne
07/20/2011
05:28 PM
Cc: "McCabe, J anet", "McCarthy, Gina"
Tom and Guy,
Attached are documents I just received about SJGS.
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: [william.bumpers@bakerbotts.com]
Sent: 07/20/2011 04:58 PM EST
To: Al Armendariz
Cc: Janet McCabe; Gina McCarthy; <Patrick.Apodaca@pnmresources.com>
Subject: FW: PNM's San Juan Generating Station
Dr. Armendariz,
Please find attached three documents relevant to EPA's proposed
federal implementation plan and BART determination for the San Juan
Generating Station (SJGS). As explained more fully in the
accompanying letters and power point, PNM Resources requested
Sargent & Lundy to perform an independent cost analysis for installing
SCR technology at SJGS. I believe this additional information and
analysis should be helpful in EPA's on-going consideration of its
proposed action. A hard copy of these documents is being sent by
overnight mail.
Please feel free to contact me if you have any questions or would like to
discuss any aspect of the issue.
Regards,
William Bumpers
Baker Botts LLP
1299 Pennsylvania Ave., NW
Washington, D.C. 20004
202-639-7718

<<S&L Report.pdf>> <<2011.7.20 - S&L Cover Letter.pdf>>
<<2011.7.20 - Bumpers Letter to Armendariz.pdf>>
Confidentiality Notice: The information contained in this email and any
attachments is intended only for the recipient[s] listed above and may
be privileged and confidential. Any dissemination, copying, or use of or
reliance upon such information by or to anyone other than the
recipient[s] listed above is prohibited. If you have received this message
in error, please notify the sender immediately at the email address
above and destroy any and all copies of this message.
[attachment "S&L Report.pdf" deleted by Joe Kordzi/R6/USEPA/US]
[attachment "2011.7.20 - S&L Cover Letter.pdf" deleted by Joe
Kordzi/R6/USEPA/US] [attachment "2011.7.20 - Bumpers Letter to
Armendariz.pdf" deleted by Joe Kordzi/R6/USEPA/US]
From: Al Armendariz
To: Starfield, Larry; Edlund, Carl; Diggs, Thomas; J oe Kordzi; Murray, Suzanne; Smith, Suzanne
Cc: McCabe, J anet; McCarthy, Gina
Subject: Fw: PNM's San J uan Generating Station
Date: 07/20/2011 05:28 PM
Attachments: S&L Report.pdf
2011.7.20 - S&L Cover Letter.pdf
2011.7.20 - Bumpers Letter to Armendariz.pdf
Tom and Guy,
Attached are documents I just received about SJ GS.
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: [william.bumpers@bakerbotts.com]
Sent: 07/20/2011 04:58 PM EST
To: Al Armendariz
Cc: J anet McCabe; Gina McCarthy; <Patrick.Apodaca@pnmresources.com>
Subject: FW: PNM's San J uan Generating Station
Dr. Armendariz,
Please find attached three documents relevant to EPA's proposed federal implementation plan and
BART determination for the San Juan Generating Station (SJGS). As explained more fully in the
accompanying letters and power point, PNM Resources requested Sargent & Lundy to perform an
independent cost analysis for installing SCR technology at SJGS. I believe this additional information
and analysis should be helpful in EPA's on-going consideration of its proposed action. A hard copy of
these documents is being sent by overnight mail.
Please feel free to contact me if you have any questions or would like to discuss any aspect of the
issue.
Regards,
William Bumpers
Baker Botts LLP
1299 Pennsylvania Ave., NW
Washington, D.C. 20004
202-639-7718

<<S&L Report.pdf>> <<2011.7.20 - S&L Cover Letter.pdf>> <<2011.7.20 - Bumpers Letter to
Armendariz.pdf>>
Confidentiality Notice: The information contained in this email and any attachments is intended only
for the recipient[s] listed above and may be privileged and confidential. Any dissemination, copying, or
use of or reliance upon such information by or to anyone other than the recipient[s] listed above is
prohibited. If you have received this message in error, please notify the sender immediately at the
email address above and destroy any and all copies of this message.

From: Carl Edlund
To: Suzanne Murray; Al Armendariz; Lawrence Starfield; David Gray; Wk; diggs thomas; Suzanne Smith; Suzanne
Murray; Layla Mansuri; mann chrissy; Ben Harrison
Subject: Re: San J uan - follow-up
Date: 07/22/2011 06:22 PM
Thanks Suzanne...I agree that modeling is a critical component of our argument and I also know that
we had extreme technical competence in that department. Let's what the weekend reviews reveal at
our Monday coordination meeting.
Sent by EPA Wireless E-Mail Services
From: Suzanne Murray
Sent: 07/22/2011 02:36 PM EDT
To: Al Armendariz; Lawrence Starfield; "David Gray" <gray.david@epa.gov>; "Carl Edlund"
<edlund.carl@epa.gov>; "diggs thomas" <diggs.thomas@epa.gov>; Suzanne Smith; "Suzanne Murray"
<murray.suzanne@epa.gov>; "Layla Mansuri" <mansuri.layla@epa.gov>; "mann chrissy"
<mann.chrissy@epa.gov>; "Ben Harrison" <harrison.ben@epa.gov>
Subject: Re: San J uan - follow-up
I am sending this to a limited group just to make sure that you are aware of critical issues regarding the
modeling.
The modeling is a key linchpin for determining that SCR is BART for the Nox emissions from the San
J uan Generating Station.
The modeling shows a substantially higher impact on visibility protection using SCR versus SNCR. This
modeling impact influences significantly the determination to require SCR.
Thanks,
Suzanne
Sent by EPA Wireless E-Mail Services
From: Al Armendariz
Sent: 07/22/2011 12:14 PM CDT
To: Lawrence Starfield; gray.david@epa.gov; edlund.carl@epa.gov; diggs.thomas@epa.gov; J oe
Kordzi/R6/USEPA/US@EPA@EPA; Bruced J ones; Suzanne Smith; murray.suzanne@epa.gov;
mansuri.layla@epa.gov; mann.chrissy@epa.gov
Subject: San J uan - follow-up
Hi everyone,
Janet and I talked about communication planning over the next few weeks to prepare for the FIP
rollout.
Here are some action items for R6:


______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
----- Forwarded by Al Armendariz/R6/USEPA/US on 07/22/2011 11:57 AM -----
From: Janet McCabe/DC/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, Lea Anderson/DC/USEPA/US@EPA, Avi
Garbow/DC/USEPA/US@EPA, Steve Page/RTP/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Seth
Oster/DC/USEPA/US@EPA, Arvin Ganesan/DC/USEPA/US@EPA, Josh Lewis/DC/USEPA/US@EPA, Andrea
Drinkard/DC/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA, Rhea Jones/RTP/USEPA/US@EPA, Todd
Hawes/RTP/USEPA/US@EPA, Anna Wood/RTP/USEPA/US@EPA
Date: 07/22/2011 11:56 AM
Subject: San Juan
Guys--

Al and I just talked post the call with Bob P,







Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: Thomas Diggs
To: Suzanne Murray
Cc: Al Armendariz; diggs thomas; Carl Edlund; David Gray; Ben Harrison; Lawrence Starfield; mann chrissy; Layla
Mansuri; Suzanne Murray; Suzanne Smith
Subject: Re: San J uan - follow-up
Date: 07/22/2011 02:03 PM
Suzanne:
I agree to the importance of the modeling and the pressure on all of our staffs. Erik
just sent the second set of comments to the team and I am including his email
below. He will be working over the weekend to finish up. As always, thanks for the
tremendous effort of ORC on this project!
Tom
---- Forwarded by Thomas Diggs/R6/USEPA/US on 07/22/2011 01:58 PM -----
From: Erik Snyder/R6/USEPA/US
To: Guy Donaldson/R6/USEPA/US@EPA
Cc: Agustin Carbo-Lugo/R6/USEPA/US@EPA, Barbara Nann/R6/USEPA/US@EPA, Brian
Tomasovic/R6/USEPA/US@EPA, Michael Feldman/R6/USEPA/US@EPA, Suzanne
Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, J oe Kordzi/R6/USEPA/US@EPA
Date: 07/22/2011 01:36 PM
Subject: NM FIP - Modeling comments 2 of 3
Hi,
Here is the second set of comments (coal company comments). I have one coal
company comment to finish and one comment on the model version of CALPUFF
that II will work over the weekend to get the last comment finished up and also
finish edits on the 1st set of comments that was shared earlier. I'll be checking
emails over the weekend if you have questions.
-Erik
Lead Regional Air Quality Modeler
EPA Region 6
Phone: 214-665-7305
Fax: 214-665-7263
email: snyder.erik@epa.gov
Suzanne Murray---07/22/2011 01:36:50 PM---I am sending this to a limited
group just to make sure that you are aware of critical issues regardi
From: Suzanne Murray/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, "David Gray"
<gray.david@epa.gov>, "Carl Edlund" <edlund.carl@epa.gov>, "diggs thomas"
<diggs.thomas@epa.gov>, Suzanne Smith/R6/USEPA/US@EPA, "Suzanne Murray"
<murray.suzanne@epa.gov>, "Layla Mansuri" <mansuri.layla@epa.gov>, "mann chrissy"
<mann.chrissy@epa.gov>, "Ben Harrison" <harrison.ben@epa.gov>
Date: 07/22/2011 01:36 PM
Subject: Re: San J uan - follow-up
I am sending this to a limited group just to make sure that you are aware of
critical issues regarding the modeling.
The modeling is a key linchpin for determining that SCR is BART for the Nox
emissions from the San Juan Generating Station.
The modeling shows a substantially higher impact on visibility protection
using SCR versus SNCR. This modeling impact influences significantly the
determination to require SCR.
Thanks,
Suzanne
Sent by EPA Wireless E-Mail Services
From: Al Armendariz
Sent: 07/22/2011 12:14 PM CDT
To: Lawrence Starfield; gray.david@epa.gov; edlund.carl@epa.gov;
diggs.thomas@epa.gov; Joe Kordzi/R6/USEPA/US@EPA@EPA; Bruced
Jones; Suzanne Smith; murray.suzanne@epa.gov; mansuri.layla@epa.gov;
mann.chrissy@epa.gov
Subject: San Juan - follow-up
Hi everyone,
J anet and I talked about communication planning over the next few
weeks to prepare for the FIP rollout.
Here are some action items for R6:



______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
----- Forwarded by Al Armendariz/R6/USEPA/US on 07/22/2011 11:57 AM -----
From: J anet McCabe/DC/USEPA/US
To:
Al Armendariz/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, Lea Anderson/DC/USEPA/US@EPA,
Avi Garbow/DC/USEPA/US@EPA, Steve Page/RTP/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Seth
Oster/DC/USEPA/US@EPA, Arvin Ganesan/DC/USEPA/US@EPA, J osh Lewis/DC/USEPA/US@EPA, Andrea
Drinkard/DC/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA, Rhea J ones/RTP/USEPA/US@EPA, Todd
Hawes/RTP/USEPA/US@EPA, Anna Wood/RTP/USEPA/US@EPA
Date: 07/22/2011 11:56 AM
Subject:
San J uan
Guys--

Al and I just talked post the call with Bob P,








J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: Al Armendariz
To: Lawrence Starfield; diggs.thomas@epa.gov; donaldson.guy@epa.gov; J oe Kordzi;
Smith.Suzanne@epamail.epa.gov
Subject: Fw: Discuss San J uan Generating Station and Regional Haze
Date: 07/21/2011 11:01 AM
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
----- Forwarded by Al Armendariz/R6/USEPA/US on 07/21/2011 11:01 AM -----
Discuss San Juan Generating Station and Regional Haze
Fri
07/22/2011 10:30
AM - 11:00 AM
Al Armendariz
Chair: Bob
Perciasepe/DC/USEPA/US
Sent By: Teri
Porterfield/RTP/USEPA/US
Location: 3412 ARN 866 299 3188 Access 202 564 4711
This entry has an alarm. The alarm will go off before the entry starts.
Anna Wood/RTP/USEPA/US@EPA, Avi Garbow/DC/USEPA/US@EPA, Gina
McCarthy/DC/USEPA/US@EPA, Janet McCabe/DC/USEPA/US@EPA, Jeffrey
Clark/RTP/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, Lea
Anderson/DC/USEPA/US@EPA, Steve Page/RTP/USEPA/US@EPA
Optional: Al Armendariz/R6/USEPA/US@EPA
Time
zones:
This entry was created in a different time zone. The time in that time zone is: Fri 07/22/2011 11:30 AM
EDT12:00 PM EDT
POC: Janet McCabe
Teri--I'm sure bob's time is really tough between now and when he elaves for
australia, but oar and region 6 have a pretty urgent need to meet with him soon
on the san juan generating station and regional haze. The mtg should include me
and gina, al a, larry starfield and anyone else from R6, avi and lea anderson from
ogc, and steve, anna wood and others from oaqps they want to include
From: J anet McCabe
To: Al Armendariz; Lawrence Starfield; Carl Edlund; J osh Lewis; Arvin Ganesan; Lorie Schmidt; Avi Garbow
Subject: Fw: Region 6 FIP/BART Decision for San J uan Generating Station
Date: 07/19/2011 01:03 PM
Attachments: SanJ uanGS EPAHQsupportLTR 7.19.2011.pdf
The Region 6 folks may have seen this already, but I wanted to make sure everyone
had it....
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
----- Forwarded by J anet McCabe/DC/USEPA/US on 07/19/2011 02:02 PM -----
From: Erik Schlenker-Goodrich <eriksg@westernlaw.org>
To: Gina McCarthy/DC/USEPA/US@EPA
Cc: J anet McCabe/DC/USEPA/US@EPA, Al Armendariz/R6/USEPA/US@EPA
Date: 07/19/2011 11:53 AM
Subject: Region 6 FIP/BART Decision for San J uan Generating Station
Dear Administrator McCarthy-
Please find attached a letter submitted on behalf of Amigos Bravos, the
Coalition for Clean Affordable Energy, Conservation Voters New Mexico,
the National Parks and Conservation Association, Natural Resources
Defense Council, New Mexico Sportsmen, Rio Grande Chapter of the Sierra
Club, San Juan Citizens Alliance, San Juan Quality Waters Coalition, and
WildEarth Guardians. A hard copy of this letter will also be sent to you
today.
This letter strongly encourages the EPA Office of Air and Radiation to
continue to support the prompt finalization of EPA Region 6s proposed
Federal Implementation Plan (FIP) and associated Best Available Retrofit
Technology (BART) determination, which includes the installation of
Selective Catalytic Reduction with a 0.05 lbs/MMBtu NOx limit for the San
Juan Generating Station (SJGS) in New Mexico.
If you have any questions, please do not hesitate to contact me.
Sincerely,
Erik Schlenker-Goodrich
_______________________________
Erik Schlenker-Goodrich
Director, Climate and Energy Program
Western Environmental Law Center
208 Paseo del Pueblo Sur, Unit 602
Taos, New Mexico 87571
(p) 575.613.4197
(f) 575.751.1775
www.westernlaw.org
_______________________________

From: Al Armendariz
To: Starfield, Larry; Diggs, Thomas; Gray, David
Subject: Fw: Region 6 FIP/BART Decision for San J uan Generating Station
Date: 07/19/2011 11:39 AM
Attachments: SanJ uanGS EPAHQsupportLTR 7.19.2011.pdf
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: Erik Schlenker-Goodrich [eriksg@westernlaw.org]
Sent: 07/19/2011 09:53 AM CST
To: Gina McCarthy
Cc: J anet McCabe; Al Armendariz
Subject: Region 6 FIP/BART Decision for San J uan Generating Station
Dear Administrator McCarthy-
Please find attached a letter submitted on behalf of Amigos Bravos, the
Coalition for Clean Affordable Energy, Conservation Voters New Mexico,
the National Parks and Conservation Association, Natural Resources
Defense Council, New Mexico Sportsmen, Rio Grande Chapter of the Sierra
Club, San Juan Citizens Alliance, San Juan Quality Waters Coalition, and
WildEarth Guardians. A hard copy of this letter will also be sent to you
today.
This letter strongly encourages the EPA Office of Air and Radiation to
continue to support the prompt finalization of EPA Region 6s proposed
Federal Implementation Plan (FIP) and associated Best Available Retrofit
Technology (BART) determination, which includes the installation of
Selective Catalytic Reduction with a 0.05 lbs/MMBtu NOx limit for the San
Juan Generating Station (SJGS) in New Mexico.
If you have any questions, please do not hesitate to contact me.
Sincerely,
Erik Schlenker-Goodrich
_______________________________
Erik Schlenker-Goodrich
Director, Climate and Energy Program
Western Environmental Law Center
208 Paseo del Pueblo Sur, Unit 602
Taos, New Mexico 87571
(p) 575.613.4197
(f) 575.751.1775
www.westernlaw.org
_______________________________

From: J anet McCabe
To: Al Armendariz
Subject: Re: San J uan
Date: 07/18/2011 06:57 PM
Great. we should be sure to keep Arvin and Laura Vaught in the loop. much
congressional interest.
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
Al Armendariz---07/18/2011 04:12:54 PM---As a follow-up, my folks are working
on pro/con document about SJ GS. They said by COB tomorrow. Al
From: Al Armendariz/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA
Date: 07/18/2011 04:12 PM
Subject: Re: San J uan
As a follow-up, my folks are working on pro/con document about SJGS. They
said by COB tomorrow.
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: Janet McCabe
Sent: 07/17/2011 07:03 PM EDT
To: Al Armendariz
Subject: Re: San Juan
sounds great.
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
-----Al Armendariz/R6/USEPA/US wrote: -----
To: J anet McCabe/DC/USEPA/US@EPA
From: Al Armendariz/R6/USEPA/US
Date: 07/17/2011 03:48PM
Subject: Re: San J uan
Ok. Since I haven't been involved in the national consent decree
discussions, I'll work with R6 staff to get a briefing together with
pro/con's for Bob and you can add the considerations into it regarding
the national consent decree.
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: J anet McCabe
Sent: 07/17/2011 12:13 PM EDT
To: Al Armendariz
Subject: San J uan
Al--I spoke at length with Gina yesterday about the situation with San
J uan and brought her up to date.


Does this make sense? How do you want to proceed?
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: J anet McCabe
To: Lawrence Starfield
Cc: Al Armendariz; Anna Wood; Carl Edlund; diggs.thomas@epa.gov; Gloria Hammond; Sabrina Hamilton; Steve
Page; Cindy Huang
Subject: Re: legislative letters on San J uan
Date: 07/18/2011 02:08 PM
Gloria, Sabrina--can we make the changes below to all the letter please? (Cindy--
this is the pile of folders I gave back to you this morning).
And guys, I heard from OCIR (J osh Lewis) today that Sen. Udall is now inquiring
about whether we plan to agree to NM;s request to bifurcate and do we plan to
communicate back to the state before Aug.5. I told josh that Al and I had talked
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
Lawrence Starfield---07/18/2011 01:04:03 PM---J anet,

From: Lawrence Starfield/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, Anna Wood/DC/USEPA/US@EPA,
Gloria Hammond/DC/USEPA/US@EPA, Sabrina Hamilton/DC/USEPA/US@EPA,
Steve Page/RTP/USEPA/US@EPA, diggs.thomas@epa.gov, Carl
Edlund/R6/USEPA/US@EPA
Date: 07/18/2011 01:04 PM
Subject: Re: legislative letters on San J uan
J anet,

Hopefully we can close on this, and get the letters out. Let us know if
you'd like to discuss.
Larry
Larry Starfield
Deputy Regional Administrator
EPA Region 6
Dallas, Texas
(214) 665-2125
legislative letters on San J uan
legislative letters on San J uan
J anet
McCabe
to: Lawrence Starfield, Al Armendariz, Steve Page,
Anna Wood
07/18/2011
08:01 AM
Cc: Gloria Hammond, Sabrina Hamilton
Larry--sorry to be back at you on these letters, but I think
Thanks, all.
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: Lawrence Starfield
To: Al Armendariz
Subject: Re: Fw: legislative letters on San J uan
Date: 07/18/2011 12:00 PM
Will do.
Larry
Re: Fw: legislative letters on San J uan
Re: Fw: legislative letters on San J uan
Al
Armendariz
to: Lawrence Starfield
07/18/2011
11:59 AM
Let J anet know that we've discussed and that the language change is
fine by me.
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Lawrence Starfield---07/18/2011 11:57:50 AM--
From: Lawrence Starfield/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US
Date: 07/18/2011 11:57 AM
Subject: Fw: legislative letters on San J uan
Al,
Are you OK with these edits? If so, should I get back to J anet, or will
you?
Larry
----- Forwarded by Lawrence Starfield/R6/USEPA/US on 07/18/2011 11:48 AM -----
legislative letters on San J uan
J anet
McCabe
to: Lawrence Starfield, Al Armendariz, Steve Page,
Anna Wood
07/18/2011
08:01 AM
Cc: Gloria Hammond, Sabrina Hamilton

Thanks, all.
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
----- Forwarded by Lawrence Starfield/R6/USEPA/US on 07/18/2011 11:53 AM -----
Fw: letters on San J uan
Thomas
Diggs
to: Sabrina Hamilton, J anet McCabe, Don Zinger,
J ulia Miller, Kirsten King
07/14/2011
04:34 PM
Cc: Lawrence Starfield, Carl Edlund, Donaldson.Guy, J oe Kordzi, Al Armendariz
Thanks J oe for the edits to the letters. I am forwarding these, as Larry
Starfield requested, to J anet and her staff. Let us know if any
questions. I can be reached at 214-665-3102 and J oe Kordzi can be
reached at 214-665-7186.
[attachment "AL-11-000-9230 Response_2_jjk.docx" deleted by Al
Armendariz/R6/USEPA/US] [attachment "AL-11-000-9997-Filner-06-30-
11_2_jjk.docx" deleted by Al Armendariz/R6/USEPA/US] [attachment
"AL-11-000-0375-Miller-06-30-11_jjk.docx" deleted by Al
Armendariz/R6/USEPA/US]
Tom
Thomas Diggs
Associate Director - Air
US EPA Region 6
214-665-3102
From: Lawrence Starfield
To: Al Armendariz
Subject: Fw: legislative letters on San J uan
Date: 07/18/2011 11:57 AM
Attachments: AL-11-000-9230 Response 2 jjk.docx
AL-11-000-9997-Filner-06-30-11 2 jjk.docx
AL-11-000-0375-Miller-06-30-11 jjk.docx
Al,
Are you OK with these edits? If so, should I get back to J anet, or will you?
Larry
----- Forwarded by Lawrence Starfield/R6/USEPA/US on 07/18/2011 11:48 AM -----
legislative letters on San J uan
J anet
McCabe
to: Lawrence Starfield, Al Armendariz, Steve Page,
Anna Wood
07/18/2011
08:01 AM
Cc: Gloria Hammond, Sabrina Hamilton
Larry--sorry to be back at you on these letters, but I think
Thanks, all.
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
----- Forwarded by Lawrence Starfield/R6/USEPA/US on 07/18/2011 11:53 AM -----
Fw: letters on San J uan
Thomas
Diggs
to: Sabrina Hamilton, J anet McCabe, Don Zinger,
J ulia Miller, Kirsten King
07/14/2011
04:34 PM
Cc: Lawrence Starfield, Carl Edlund, Donaldson.Guy, J oe Kordzi, Al Armendariz
Thanks J oe for the edits to the letters. I am forwarding these, as Larry Starfield
requested, to J anet and her staff. Let us know if any questions. I can be reached
at 214-665-3102 and J oe Kordzi can be reached at 214-665-7186.
Tom
Thomas Diggs
Associate Director - Air
US EPA Region 6
214-665-3102
FOIA Exemption (b)(5) -
Deliberative Process Privilege
FOIA Exemption (b)(5) -
Deliberative Process Privilege
FOIA Exemption (b)(5) -
Deliberative Process Privilege
From: David Gray
To: Al Armendariz; Layla Mansuri
Subject: Udall
Date: 07/18/2011 12:54 PM
Latest question from Udall - FYI
Earlier this year, Sen. Udall did a Q&A w/ Asst. Admin. McCarthy on the back and
forth between EPA and the State of NM re: FIPs & SIPs.
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: Carl Edlund
To: Thomas Diggs; Sabrina Hamilton; J anet McCabe; Don Zinger; J ulia Miller; Kirsten King
Cc: Lawrence Starfield; Donaldson Guy; J oe Kordzi; Al Armendariz
Subject: Re: letters on San J uan
Date: 07/14/2011 07:18 PM
The initial letter still says


Sent by EPA Wireless E-Mail Services
Thomas Diggs
----- Original Message -----
From: Thomas Diggs
Sent: 07/14/2011 04:34 PM CDT
To: Sabrina Hamilton; Janet McCabe; Don Zinger; Julia Miller; Kirsten
King
Cc: Lawrence Starfield; Carl Edlund; Donaldson.Guy@epa.gov; Joe Kordzi;
Al Armendariz
Subject: Fw: letters on San Juan
Thanks J oe for the edits to the letters. I am forwarding these, as Larry
Starfield requested, to J anet and her staff. Let us know if any
questions. I can be reached at 214-665-3102 and J oe Kordzi can be
reached at 214-665-7186.
[attachment "AL-11-000-9230 Response_2_jjk.docx" deleted by Carl
Edlund/R6/USEPA/US]
[attachment "AL-11-000-9997-Filner-06-30-11_2_jjk.docx" deleted by Carl
Edlund/R6/USEPA/US]
[attachment "AL-11-000-0375-Miller-06-30-11_jjk.docx" deleted by Carl
Edlund/R6/USEPA/US]
Tom
Thomas Diggs
Associate Director - Air
US EPA Region 6
214-665-3102
fax 214-665-7263
diggs.thomas@epa.gov
Guy Donaldson---07/12/2011 12:00:12 PM---Please take the lead on review. I
assume Larry meant Fact check. ----- Forwarded by Guy Donaldson/R
From: Guy Donaldson/R6/USEPA/US
To: J oe Kordzi/R6/USEPA/US@EPA
Date: 07/12/2011 12:00 PM
Subject: Fw: letters on San J uan
Please take the lead on review. I assume Larry meant Fact check.
----- Forwarded by Guy Donaldson/R6/USEPA/US on 07/12/2011 11:59 AM -----
From: Lawrence Starfield/R6/USEPA/US
To: Carl Edlund/R6/USEPA/US@EPA, "Tom Diggs" <diggs.thomas@epa.gov>, "Guy Donaldson"
<donaldson.guy@epa.gov>, "J oe Kordzi" <Kordzi.J oe@epamail.epa.gov>
Cc: Al Armendariz/R6/USEPA/US
Date: 07/12/2011 11:45 AM
Subject: Fw: letters on San J uan
Please fact sheet these letters, and provide comments directly to
J anet's office. (I already shared the information about the comment
period and the receipt of the State's SIP.)
Thanks.
Larry
Sent by EPA Wireless E-Mail Services
Sabrina Hamilton
----- Original Message -----
From: Sabrina Hamilton
Sent: 07/12/2011 09:57 AM EDT
To: Lawrence Starfield
Cc: mccabe.janet@epa.gov; zinger.don@epa.gov; Julia Miller;
Kirsten King
Subject: Fw: letters on San Juan
Larry,
Attached are the congressional letters that J anet was referring to in her
email to you yesterday. Please email me the appropriate changes.
Thanks,
Sabrina
[attachment "11-000-9230.pdf" deleted by Carl Edlund/R6/USEPA/US]
[attachment "AL-11-000-9230 Response_2.doc" deleted by Carl
Edlund/R6/USEPA/US]
[attachment "11-000-9997.pdf" deleted by Carl Edlund/R6/USEPA/US]
[attachment "AL-11-000-9997-Filner-06-30-11_2.doc" deleted by Carl
Edlund/R6/USEPA/US]
[attachment "11-001-0375.pdf" deleted by Carl Edlund/R6/USEPA/US]
[attachment "AL-11-000-0375-Miller-06-30-11.doc" deleted by Carl
Edlund/R6/USEPA/US]
Sabrina Hamilton
Air and Radiation Liaison Specialist
Office of Air and Radiation - Correspondence Unit
U.S. Environmental Protection Agency (EPA)
1200 Pennsylvania Avenue, N.W. (6101-A)
Washington, D.C. 20460
Tel: (202) 564-1083
Fax: (202) 501-0600
----- Forwarded by Sabrina Hamilton/DC/USEPA/US on 07/12/2011 09:48 AM -----
From: Don Zinger/DC/USEPA/US
To: Sabrina Hamilton/DC/USEPA/US@EPA
Cc: J ulia Miller/DC/USEPA/US@EPA, Kirsten King/DC/USEPA/US@EPA
Date: 07/12/2011 08:42 AM
Subject: Fw: letters on San J uan
Sabrina,
Are you able to help with this? Larry in J anet's note is Larry Starfield
in Region 6. Thanks.
----- Forwarded by Don Zinger/DC/USEPA/US on 07/12/2011 08:39 AM -----
From: J anet McCabe/DC/USEPA/US
To: Gloria Hammond/DC/USEPA/US@EPA, Don Zinger/DC/USEPA/US@EPA,
Larry Starfield <starfield.lawrence@epamail.epa.gov>, J osh
Lewis/DC/USEPA/US@EPA
Date: 07/11/2011 08:34 PM
Subject: letters on San J uan
I have sevreal correspondence folders in my office to members f
congress responding to a standard letter about San J uan Generating
Station.
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: Thomas Diggs
To: Sabrina Hamilton; J anet McCabe; Don Zinger; J ulia Miller; Kirsten King
Cc: Lawrence Starfield; Carl Edlund; Donaldson.Guy@epa.gov; J oe Kordzi; Al Armendariz
Subject: Fw: letters on San J uan
Date: 07/14/2011 04:34 PM
Attachments: 11-000-9230.pdf
AL-11-000-9230 Response 2.doc
11-000-9997.pdf
AL-11-000-9997-Filner-06-30-11 2.doc
11-001-0375.pdf
AL-11-000-0375-Miller-06-30-11.doc
AL-11-000-9230 Response 2 jjk.docx
AL-11-000-9997-Filner-06-30-11 2 jjk.docx
AL-11-000-0375-Miller-06-30-11 jjk.docx
Thanks J oe for the edits to the letters. I am forwarding these, as Larry Starfield
requested, to J anet and her staff. Let us know if any questions. I can be reached
at 214-665-3102 and J oe Kordzi can be reached at 214-665-7186.
Tom
Thomas Diggs
Associate Director - Air
US EPA Region 6
214-665-3102
fax 214-665-7263
diggs.thomas@epa.gov
Guy Donaldson---07/12/2011 12:00:12 PM---Please take the lead on review. I
assume Larry meant Fact check. ----- Forwarded by Guy Donaldson/R
From: Guy Donaldson/R6/USEPA/US
To: J oe Kordzi/R6/USEPA/US@EPA
Date: 07/12/2011 12:00 PM
Subject: Fw: letters on San J uan
Please take the lead on review. I assume Larry meant Fact check.
----- Forwarded by Guy Donaldson/R6/USEPA/US on 07/12/2011 11:59 AM -----
From: Lawrence Starfield/R6/USEPA/US
To: Carl Edlund/R6/USEPA/US@EPA, "Tom Diggs" <diggs.thomas@epa.gov>, "Guy Donaldson"
<donaldson.guy@epa.gov>, "J oe Kordzi" <Kordzi.J oe@epamail.epa.gov>
Cc: Al Armendariz/R6/USEPA/US
Date: 07/12/2011 11:45 AM
Subject: Fw: letters on San J uan
Please fact sheet these letters, and provide comments directly to
J anet's office. (I already shared the information about the comment
period and the receipt of the State's SIP.)
Thanks.
Larry
Sent by EPA Wireless E-Mail Services
Sabrina Hamilton
----- Original Message -----
From: Sabrina Hamilton
Sent: 07/12/2011 09:57 AM EDT
To: Lawrence Starfield
Cc: mccabe.janet@epa.gov; zinger.don@epa.gov; Julia Miller;
Kirsten King
Subject: Fw: letters on San Juan
Larry,
Attached are the congressional letters that J anet was referring to in her email to you
yesterday. Please email me the appropriate changes. Thanks,
Sabrina
Sabrina Hamilton
Air and Radiation Liaison Specialist
Office of Air and Radiation - Correspondence Unit
U.S. Environmental Protection Agency (EPA)
1200 Pennsylvania Avenue, N.W. (6101-A)
Washington, D.C. 20460
Tel: (202) 564-1083
Fax: (202) 501-0600
----- Forwarded by Sabrina Hamilton/DC/USEPA/US on 07/12/2011 09:48 AM -----
From: Don Zinger/DC/USEPA/US
To: Sabrina Hamilton/DC/USEPA/US@EPA
Cc: J ulia Miller/DC/USEPA/US@EPA, Kirsten King/DC/USEPA/US@EPA
Date: 07/12/2011 08:42 AM
Subject: Fw: letters on San J uan
Sabrina,
Are you able to help with this? Larry in J anet's note is Larry Starfield in Region 6.
Thanks.
----- Forwarded by Don Zinger/DC/USEPA/US on 07/12/2011 08:39 AM -----
From: J anet McCabe/DC/USEPA/US
To: Gloria Hammond/DC/USEPA/US@EPA, Don Zinger/DC/USEPA/US@EPA,
Larry Starfield <starfield.lawrence@epamail.epa.gov>, J osh
Lewis/DC/USEPA/US@EPA
Date: 07/11/2011 08:34 PM
Subject: letters on San J uan
I have sevreal correspondence folders in my office to members f congress
responding to a standard letter about San J uan Generating Station.
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: Lawrence Starfield
To: Al Armendariz
Subject: Fw: letters on San J uan
Date: 07/12/2011 04:45 PM
Al,
Seems like you need to be having this conversation with J anet. I'm happy to join
you, or assist, engage staff, etc. -- whatever would be helpful.
Let me know how you'd like to handle.
Larry
Sent by EPA Wireless E-Mail Services
J anet McCabe
----- Original Message -----
From: Janet McCabe
Sent: 07/12/2011 01:23 PM EDT
To: Lawrence Starfield
Subject: Re: letters on San Juan
I'm one for two then. Not bad....
Larry--I'm still having a bit of a struggle with how to handle this



J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
Lawrence Starfield---07/12/2011 12:44:57 PM---J anet, We now have the letters,
and Carl's folks will provide any specific comments. But on your tw
From: Lawrence Starfield/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA, Gloria
Hammond/DC/USEPA/US@EPA, Don Zinger/DC/USEPA/US@EPA, J osh
Lewis/DC/USEPA/US@EPA
Cc: Carl Edlund/R6/USEPA/US@EPA, "Tom Diggs"
<diggs.thomas@epa.gov>
Date: 07/12/2011 12:44 PM
Subject: Re: letters on San J uan
Janet,
We now have the letters, and Carl's folks will provide any specific comments.
But on your two specific questions:
1. We initially published our proposal on 1/5/11, which started a 60 day
comment period, ending 3/7/11. We later extended that comment period to
4/4/11. We also held a hearing in Farmington on 2/17/11.
2. You are right. We now have received the New Mexico Regional haze SIP
revision in a letter from the governor dated June 24, 2011.
Larry
Sent by EPA Wireless E-Mail Services
From: Janet McCabe
Sent: 07/11/2011 08:34 PM EDT
To: Gloria Hammond; Don Zinger; Lawrence Starfield; Josh Lewis
Subject: letters on San Juan
I have sevreal correspondence folders in my office to members f
congress responding to a standard letter about San J uan Generating
Station.
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: Al Armendariz
To: Gina McCarthy
Cc: mccabe janet
Subject: Re: PSD permitting
Date: 07/12/2011 10:34 PM
Thanks Gina. J ust having been fully 'cleared' Friday on this permit, I feel like I'm
doing 4 months of catching up in a week.
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Gina McCarthy---07/12/2011 09:11:06 PM---Al -
From: Gina McCarthy/DC/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, "mccabe janet" <mccabe.janet@epa.gov>
Date: 07/12/2011 09:11 PM
Subject: Re: PSD permitting
Al -
.
From: Al Armendariz
Sent: 07/12/2011 07:22 PM CDT
To: mccabe.janet@epa.gov; Gina McCarthy
Subject: PSD permitting
Hi Gina,
Hi J anet,
I'm looking forward to seeing J anet tomorrow to talk about a couple of
air issues.
FOIA Exemption (b)(5) - Deliberative Process Privilege
On Friday last week I received guidance from the OGC Ethics office
that I have been in the agency long enough that my "cooling off"
period has lapsed on working on matters that I had previously worked
on before joining the agency.








FOIA Exemption (b)(5) - Deliberative Process Privilege




Thanks.
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
----- Forwarded by Al Armendariz/R6/USEPA/US on 07/12/2011 06:56 PM -----
From: J effrey Robinson/R6/USEPA/US
To:
Al Armendariz/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA,
Carl Edlund/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Layla
Mansuri/R6/USEPA/US@EPA
Date: 07/12/2011 02:53 PM
Subject:
Fw: Briefing materials for Las Brisas GHG GF Gina briefing (yet to be scheduled)
Latest email traffic below.
----- Forwarded by J effrey Robinson/R6/USEPA/US on 07/12/2011 02:50 PM -----
From: Raj Rao/RTP/USEPA/US
To: Kristi Smith/DC/USEPA/US@EPA
Cc:
Anna Wood/DC/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA, J effrey Robinson/R6/USEPA/US@EPA, Melina
Williams/DC/USEPA/US@EPA, Mike Sewell/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA
Date: 07/12/2011 02:39 PM
Subject:
Re: Briefing materials for Las Brisas GHG GF Gina briefing (yet to be scheduled)
Thanks Kristi, Melina and others for your very useful comments. After
FOIA Exemption (b)(5) - Deliberative Process Privilege
I sent the briefing for review yesterday. we also came to the same
conclusion that it was more efficient to combine options 1 and 2.
raj
Raj Rao, P.E.
Group Leader, NSRG
OAQPS/AQPD(MD- C504-03)
109 TW Alexander Drive
RTP, NC 27709
919-541-5344
919-541-5509 fax
Note: Positions or views expressed here do not represent official EPA
policy. Interagency deliberative and Confidential.
From: Kristi Smith/DC/USEPA/US
To: Raj Rao/RTP/USEPA/US@EPA
Cc:
Anna Wood/DC/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA, J effrey Robinson/R6/USEPA/US@EPA, Melina
Williams/DC/USEPA/US@EPA, Mike Sewell/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA
Date: 07/12/2011 01:58 PM
Subject:
Re: Briefing materials for Las Brisas GHG GF Gina briefing (yet to be scheduled)
Raj -
Here is OGC's review.
- Kristi
Kristi M. Smith
US EPA, Office of General Counsel
Air and Radiation Law Office
(202) 564-3068 (office)
(202) 564-5603 (fax)
CONFIDENTIAL communication for internal deliberations only; may
contain deliberative, attorney-client, attorney work product, or
otherwise privileged material; do not distribute outside EPA or DOJ .
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Raj Rao/RTP/USEPA/US
To: Phil Lorang/RTP/USEPA/US@EPA, Anna Wood/DC/USEPA/US@EPA, Brian
Doster/DC/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA, Kristi Smith/DC/USEPA/US@EPA
Cc: J effrey Robinson/R6/USEPA/US@EPA, Mike Sewell/RTP/USEPA/US@EPA
Date: 07/11/2011 04:14 PM
Subject: Briefing materials for Las Brisas GHG GF Gina briefing (yet to be scheduled)
Hi all,
Attached is a draft briefing on Las Brisas that includes preliminary
comments from R6.


[attachment "Gina Briefing - Grandfathering Las Brisas from GHG
requirements 071111.doc" deleted by Kristi Smith/DC/USEPA/US]
raj
Raj Rao, P.E.
Group Leader, NSRG
OAQPS/AQPD(MD- C504-03)
109 TW Alexander Drive
RTP, NC 27709
919-541-5344
919-541-5509 fax
Note: Positions or views expressed here do not represent official EPA
policy. Interagency deliberative and Confidential.
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Al Armendariz
To: J anet McCabe
Subject: Re: PSD permitting
Date: 07/12/2011 09:23 PM
Your place is great. See you soon.
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: J anet McCabe
Sent: 07/12/2011 10:11 PM EDT
To: Al Armendariz
Subject: Re: PSD permitting
thanks--you want to come to my office (5426K) or shall I meet you somewhere else?
Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
-----Al Armendariz/R6/USEPA/US wrote: -----
To: Janet McCabe/DC/USEPA/US@EPA
From: Al Armendariz/R6/USEPA/US
Date: 07/12/2011 10:05PM
Subject: Re: PSD permitting
Yes. 3:30 works for me. See you then.
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Janet McCabe---07/12/2011 08:57:24 PM---Al--we can definitely talk about this--no
decision has been made yet. I know you appreciate the comp
From:
Janet McCabe/DC/USEPA/US
To:
Al Armendariz/R6/USEPA/US@EPA
Cc:
mccabe.janet@epa.gov, Gina McCarthy/DC/USEPA/US@EPA
Date:
07/12/2011 08:57 PM
Subject:
Re: PSD permitting
Al--we can definitely talk about this--no decision has been made yet. I know you
appreciate the complexity of the issues here, which we are still working through, and
I've asked OAQPS to put together a range of options, which I should be getting
tomorrow.

I need to shift the time of our meeting tomorrow--are you free at 3:30 instead of 2?

Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
-----Al Armendariz/R6/USEPA/US wrote: -----
To: mccabe.janet@epa.gov, McCarthy.Gina@epamail.epa.gov
From: Al Armendariz/R6/USEPA/US
Date: 07/12/2011 08:22PM
Subject: PSD permitting
Hi Gina,
Hi Janet,
I'm looking forward to seeing Janet tomorrow to talk about a couple of air issues.
On Friday last week I received guidance from the OGC Ethics office that I have been in
the agency long enough that my "cooling off" period has lapsed on working on matters
that I had previously worked on before joining the agency.












Thanks.
Al
FOIA Exemption (b)(5) - Deliberative Process Privilege
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
----- Forwarded by Al Armendariz/R6/USEPA/US on 07/12/2011 06:56 PM -----
From: Jeffrey Robinson/R6/USEPA/US
To:
Al Armendariz/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA,
Suzanne Smith/R6/USEPA/US@EPA, Layla Mansuri/R6/USEPA/US@EPA
Date: 07/12/2011 02:53 PM
Subject:
Fw: Briefing materials for Las Brisas GHG GF Gina briefing (yet to be scheduled)
Latest email traffic below.
----- Forwarded by Jeffrey Robinson/R6/USEPA/US on 07/12/2011 02:50 PM -----
From: Raj Rao/RTP/USEPA/US
To: Kristi Smith/DC/USEPA/US@EPA
Cc:
Anna Wood/DC/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA, Jeffrey Robinson/R6/USEPA/US@EPA,
Melina Williams/DC/USEPA/US@EPA, Mike Sewell/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA
Date: 07/12/2011 02:39 PM
Subject:
Re: Briefing materials for Las Brisas GHG GF Gina briefing (yet to be scheduled)
Thanks Kristi, Melina and others for your very useful comments. After I sent the
briefing for review yesterday. we also came to the same conclusion that it was more
efficient to combine options 1 and 2.
raj
Raj Rao, P.E.
Group Leader, NSRG
OAQPS/AQPD(MD- C504-03)
109 TW Alexander Drive
RTP, NC 27709
919-541-5344
919-541-5509 fax
Note: Positions or views expressed here do not represent official EPA policy.
Interagency deliberative and Confidential.
From: Kristi Smith/DC/USEPA/US
To: Raj Rao/RTP/USEPA/US@EPA
Cc:
Anna Wood/DC/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA, Jeffrey Robinson/R6/USEPA/US@EPA,
Melina Williams/DC/USEPA/US@EPA, Mike Sewell/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA

Date: 07/12/2011 01:58 PM
Subject:
Re: Briefing materials for Las Brisas GHG GF Gina briefing (yet to be scheduled)
Raj -
Here is OGC's review.

- Kristi
Kristi M. Smith
US EPA, Office of General Counsel
Air and Radiation Law Office
(202) 564-3068 (office)
(202) 564-5603 (fax)
CONFIDENTIAL communication for internal deliberations only; may contain deliberative,
attorney-client, attorney work product, or otherwise privileged material; do not
distribute outside EPA or DOJ.
From: Raj Rao/RTP/USEPA/US
To: Phil Lorang/RTP/USEPA/US@EPA, Anna Wood/DC/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA,
Melina Williams/DC/USEPA/US@EPA, Kristi Smith/DC/USEPA/US@EPA
Cc: Jeffrey Robinson/R6/USEPA/US@EPA, Mike Sewell/RTP/USEPA/US@EPA
Date: 07/11/2011 04:14 PM
Subject: Briefing materials for Las Brisas GHG GF Gina briefing (yet to be scheduled)
Hi all,
Attached is a draft briefing on Las Brisas that includes preliminary comments from R6.


FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
[attachment "Gina Briefing - Grandfathering Las Brisas from GHG requirements
071111.doc" deleted by Kristi Smith/DC/USEPA/US]
raj
Raj Rao, P.E.
Group Leader, NSRG
OAQPS/AQPD(MD- C504-03)
109 TW Alexander Drive
RTP, NC 27709
919-541-5344
919-541-5509 fax
Note: Positions or views expressed here do not represent official EPA policy.
Interagency deliberative and Confidential.
[attachment "Gina Briefing - Grandfathering Las Brisas from GHG requirements 071111
+ OGC review 1 pm.doc" removed by Janet McCabe/DC/USEPA/US]
From: Al Armendariz
To: mccabe.janet@epa.gov; McCarthy.Gina@epamail.epa.gov
Subject: PSD permitting
Date: 07/12/2011 07:22 PM
Attachments: Gina Briefing - Grandfathering Las Brisas from GHG requirements 071111 + OGC review 1 pm.doc
Hi Gina,
Hi J anet,
I'm looking forward to seeing J anet tomorrow to talk about a couple of air issues.
On Friday last week I received guidance from the OGC Ethics office that I have been
in the agency long enough that my "cooling off" period has lapsed on working on
matters that I had previously worked on before joining the agency.
FOIA Exemption (b)(5) - Deliberative Process Privilege

Thanks.
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
----- Forwarded by Al Armendariz/R6/USEPA/US on 07/12/2011 06:56 PM -----
From: J effrey Robinson/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA,
Suzanne Smith/R6/USEPA/US@EPA, Layla Mansuri/R6/USEPA/US@EPA
Date: 07/12/2011 02:53 PM
Subject: Fw: Briefing materials for Las Brisas GHG GF Gina briefing (yet to be scheduled)
Latest email traffic below.
----- Forwarded by J effrey Robinson/R6/USEPA/US on 07/12/2011 02:50 PM -----
From: Raj Rao/RTP/USEPA/US
To: Kristi Smith/DC/USEPA/US@EPA
Cc: Anna Wood/DC/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA, J effrey
Robinson/R6/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA, Mike
Sewell/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA
Date: 07/12/2011 02:39 PM
Subject: Re: Briefing materials for Las Brisas GHG GF Gina briefing (yet to be scheduled)
FOIA Exemption (b)(5) - Deliberative Process Privilege
Thanks Kristi, Melina and others for your very useful comments. After I sent the
briefing for review yesterday. we also came to the same conclusion that it was more
efficient to combine options 1 and 2.
raj
Raj Rao, P.E.
Group Leader, NSRG
OAQPS/AQPD(MD- C504-03)
109 TW Alexander Drive
RTP, NC 27709
919-541-5344
919-541-5509 fax
Note: Positions or views expressed here do not represent official EPA policy.
Interagency deliberative and Confidential.
Kristi Smith---07/12/2011 01:58:37 PM---Raj - Here is OGC's review.
From: Kristi Smith/DC/USEPA/US
To: Raj Rao/RTP/USEPA/US@EPA
Cc: Anna Wood/DC/USEPA/US@EPA, Brian Doster/DC/USEPA/US@EPA, J effrey
Robinson/R6/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA, Mike
Sewell/RTP/USEPA/US@EPA, Phil Lorang/RTP/USEPA/US@EPA
Date: 07/12/2011 01:58 PM
Subject: Re: Briefing materials for Las Brisas GHG GF Gina briefing (yet to be scheduled)
Raj -
Here is OGC's review.
- Kristi
Kristi M. Smith
US EPA, Office of General Counsel
Air and Radiation Law Office
(202) 564-3068 (office)
(202) 564-5603 (fax)
CONFIDENTIAL communication for internal deliberations only; may contain
deliberative, attorney-client, attorney work product, or otherwise privileged material;
FOIA Exemption (b)(5) - Deliberative Process Privilege
do not distribute outside EPA or DOJ .
Raj Rao---07/11/2011 04:14:29 PM---Hi all, Attached is a draft briefing on Las
Brisas that includes preliminary comments from R6. Kno
From: Raj Rao/RTP/USEPA/US
To: Phil Lorang/RTP/USEPA/US@EPA, Anna Wood/DC/USEPA/US@EPA,
Brian Doster/DC/USEPA/US@EPA, Melina Williams/DC/USEPA/US@EPA, Kristi
Smith/DC/USEPA/US@EPA
Cc: J effrey Robinson/R6/USEPA/US@EPA, Mike
Sewell/RTP/USEPA/US@EPA
Date: 07/11/2011 04:14 PM
Subject: Briefing materials for Las Brisas GHG GF Gina briefing (yet to be
scheduled)
Hi all,
Attached is a draft briefing on Las Brisas that includes preliminary comments from
R6.
[attachment "Gina Briefing - Grandfathering Las Brisas from GHG requirements
071111.doc" deleted by Kristi Smith/DC/USEPA/US]
raj
Raj Rao, P.E.
Group Leader, NSRG
OAQPS/AQPD(MD- C504-03)
109 TW Alexander Drive
RTP, NC 27709
919-541-5344
919-541-5509 fax
Note: Positions or views expressed here do not represent official EPA policy.
Interagency deliberative and Confidential.
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: David Gray
To: Lawrence Starfield/R6/USEPA/US@EPA; Al Armendariz/R6/USEPA/US@EPA
Subject: Fw: Regional Haze SIP
Date: 07/12/2011 09:16 AM
FYSA - here are Drew (Bingaman) questions
Cynthia:
I hope you had a good weekend.
Below are some recent discussion points provided by PNM in regard to the
San Juan FIP. This seems to differ from our understanding of the deadline for
the Regional Haze SIP.
Is there someone in Region 6 I could talk to about this?
Thanks
Dan alpert
202.224.1808

On June 2, 2011, the New Mexico Environmental Improvement Board
adopted revisions to three State Implementation Plans (SIPs): one for the
Interstate Transport Rule requirements and two associated with Regional Haze
Rule requirements. These SIPs were officially submitted to EPA for approval
on June 29, 2011. Only one of the SIP revisions addresses BART for San
Juan.

PNM believes this Regional Haze SIP is not subject to the August 5, 2011
deadline under the Consent Decree between EPA and WildEarth Guardians.

According to PNM, although EPA Region 6 could have issued three separate
Federal Implementation Plans (FIPs) for each of the regulatory requirements,
as the State of New Mexico has done, EPA Region 6 instead combined all
three regulatory requirements into a single FIP.

EPA, however, is treating that deadline as if it also were applicable to the
Regional Haze requirement for BART for San Juan. PNM believes that the
EPAs approach disregards the states right to implement and regulate the
Regional Haze Rule in New Mexico as contemplated by the federal Clean Air
Act and also could place an unnecessary economic burden on the states
citizens.

In order to meet the August 5 deadline and at the same time give due
consideration to a decision that could have a serious financial impact on New
Mexico ratepayers, PNM is asking EPA to separate the three requirements,
finalize the one associated with the Interstate Transport Rule by August 5, and
stay any action on the proposed FIP for Regional Haze until New Mexicos
SIP revisions have been fully considered and either approved or disapproved.

PNM believes this course of action is entirely within EPAs discretion and
that there is no legal prohibition or requirement that would prevent EPA from
taking those actions. According to PNM, the impact to New Mexico
ratepayers is especially critical since the EPA-proposed BART is Selective
Catalytic Reduction (SCR), which we estimate will cost approximately
between $750 million and $1 billion ten times the cost of the SNCR
technology. EPAs own cost estimate, which is significantly lower, neglected
to include site-specific considerations that are a major factor in the cost
estimate. Although EPAs consultant recently visited the site, a revised
estimate has not been provided.

PNM has formally asked EPA to honor state primacy and open a separate
docket to allow comment by the public and others who may be impacted by
the FIP, and to fully consider approval of the New Mexico SIP Regional Haze
Rule revisions before taking any further action on the FIP.
From: David Gray
To: Al Armendariz; Lawrence Starfield
Subject: NM FIP - Bingaman
Date: 07/12/2011 08:59 AM
FYSA -
In coordination with Dianne Frantz in OCIR, we have scheduled a conference call
with Dan Alpert of Sen. Bingaman's DC staff to discuss several positions advanced
by PNM, an owner of the San J uan Generating Station. The call is for 2:00 pm
central today (3:00 pm eastern).
David
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: David Gray
To: Al Armendariz/R6/USEPA/US@EPA
Subject: Fw: NM and OK FIP actions
Date: 07/11/2011 04:41 PM
New Mexico FIP (Confidential/Deliberative)
Background: On December 21, 2010, EPA proposed a Federal Implementation
Plan (FIP) establishing the Best Available Retrofit Technology (BART) for the San
Juan Generating Station, one of the largest power plants in New Mexico. The plant is
located in the Northwest portion of the state commonly referred to as Four Corners.
The proposed FIP sets limits for emissions of sulfur dioxide, sulfuric acid and
ammonia. The proposed FIP calls for Selective Catalytic Reduction (SCR) on the
plant's 4 units and results in significant visibility improvements at 16 Class 1 areas in
the Four Corners Area of the West. The facility, various part owners in New Mexico
and California, Senators Bingaman and Udall, Congressman Lujan and several
California congressmen have raised concerns about the costs of control and the time
for compliance.
EPA has been responsive to the facilitys concerns. EPA extended the original
comment period for the FIP proposal. EPA added a field visit to follow up on
comments, which showed a willingness to understand their proposal and consider
their arguments on cost.



Oklahoma FIP (Confidential/Deliberative)
Background: On March 22, 2011, EPA published in the Federal Register a
proposed Federal Implementation Plan (FIP) to limit air emissions which cause
regional haze from three coal-burning power plants in Oklahoma: the Oklahoma Gas
and Electric (OG&E) plant near Muskogee, the OG&E Sooner plant in north central
Oklahoma, and the American Electric Power/Public Service Company of Oklahoma
plant northeast of Tulsa.
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege



FOIA Exemption (b)(5) - Deliberative Process Privilege
From: David Gray
To: Al Armendariz/R6/USEPA/US@EPA
Subject: Info for HQ
Date: 07/08/2011 05:28 PM
Al - HQ asked for an update. Since I am certain these will end up in Diane Thompson's
hands - I wanted you to see them. I promised them early Monday morning.
David
New Mexico FIP (Confidential/Deliberative)
Background:

Oklahoma FIP (Confidential/Deliberative)
Background:
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege




From: Mark Sather
To: Al Armendariz; Amir Poursamadi; blambeth@tceq.state.tx.us; Camila.Tao@LA.GOV; Carl Edlund; Carl Young;
Carrie Paige; Chrissy Mann; Clifford.Stevens@deq.ok.gov; Connie Suttice; curt.goeller@deq.ok.gov; Cynthia
Fanning; Daniel.Ross@deq.ok.gov; David Bary; David Gray; David Neleigh; dmcmurre@tceq.state.tx.us; Ellen
Belk; Erik Snyder; fmacias@cabq.gov; Guy Donaldson; J ack Arias; J ames Yarbrough; J effrey Riley; J effrey
Robinson; joe.mashburn@deq.ok.gov; J oseph Hubbard; Kara Allen; kent.stafford@deq.ok.gov; Lawrence
Starfield; Layla Mansuri; Lynda Carroll; mabaker@tceq.state.tx.us; Maria Martinez; Mark Ford;
mark.J ones@state.nm.us; mary.hilbert@state.nm.us; mhotchki@tceq.state.tx.us; Michael Feldman; Miguel
Flores; miriam@adeq.state.ar.us; Rick McMillin; ryan-callison@cherokee.org; Sandra Rennie;
terry.hertel@state.nm.us; Thomas Diggs; Trisha Curran; Tyler.Muxworthy@state.nm.us;
vennetta.hayes@la.gov; William Luthans; William Rhea
Subject: Region 6 8-hour ozone exceedance day report (through 7/7/2011)
Date: 07/08/2011 07:58 AM
Attachments: 1oupdate11.xls
8oupdate11.xlsx
Elevated ozone concentrations were recorded on multiple days this week in north
Texas, Oklahoma, and Arkansas. The DFW area recorded three orange exceedance
days which resulted in the DFW area's preliminary 2009-2011 8-hour ozone design
value rising another 2 ppb on Thursday (7/7) to 88 ppb, over the 1997 8-hour ozone
standard of 84 ppb. There were also three orange exceedance days apiece in Tulsa,
OKC, Cherokee Tribal sites in Oklahoma, Shelby County, TN, and Crittenden County,
Arkansas (the last two counties part of the Memphis MSA). The exceedance days in
Crittenden County, AR have resulted in a 2009-2011 preliminary 8-hour ozone design
value of 77 ppb, back over the 2008 8-hour ozone standard of 75 ppb. This week
there were also four orange exceedance days in Little Rock and one orange
exceedance day apiece in Houston, Longview, Shreveport, Quapaw Tribal and San
J uan County, NM. This update catches everything up for the past two weeks. Let
me know of any questions.
Mark
From: Al Armendariz
To: Diggs, Thomas; Gray, David; Mansuri, Layla; Mann, Chrissy
Subject: Fw: PNM / San J uan Generating Station BART Determination - Delegation Letter
Date: 07/05/2011 02:24 PM
Attachments: Letter to Sen Udall 7-1-11.pdf
2011 7 1 - NMED BART Analysis.pdf
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: J anet McCabe
Sent: 07/04/2011 05:55 PM EDT
To: Arvin Ganesan; Gina McCarthy; Al Armendariz; Lawrence Starfield; Avi Garbow
Cc: J oseph Goffman; Michael Goo; Rob Brenner; J anet McCabe; Steve Page
Subject: Fw: PNM / San J uan Generating Station BART Determination - Delegation Letter
The attached note and documents have to do with an issue in New Mexico, specifically the
BART SIP under the Regional Haze program as it affects the San Juan Generating
Station.





I apologize for the length of this note, but thought it would be helpful if I laid out these
points in some detail. Larry, Al--please feel free to add or correct, and I expect we'll be
discussing this week. (I have not gotten back with Bumpers, and we should probably talk
internally before I do).

Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
-----Forwarded by Janet McCabe/DC/USEPA/US on 07/04/2011 05:23PM -----
To: Joseph Goffman/DC/USEPA/US@EPA, Janet McCabe/DC/USEPA/US@EPA, Michael
Goo/DC/USEPA/US@EPA
From: "Pablo, Jeanette" <jeanette.pablo@pnmresources.com>
Date: 07/04/2011 04:16PM
Subject: PNM / San Juan Generating Station BART Determination - Delegation Letter
(See attached file: Letter to Sen Udall 7-1-11.pdf)
(See attached file: 2011 7 1 - NMED BART Analysis.pdf)
> Attached are a copy of a letter to the NM Delegation from PNM Resources CEO, Pat Collawn, and
the Approvability Analysis of NMED's BART Determination for Public Service Company of New
Mexico's San Juan Generating Station, prepared by our counsel Bill Bumpers and Michael Heister
at the law firm of Baker Botts. Please let me know if you have any questions.
Warm regards,
Jeanette
Jeanette Pablo
Federal Affairs
PNM Resources
5505 Connecticut Avenue, NW
#216
Washington, DC 20015
202-468-9688
Jeanette.Pablo@PNMResources.com
>
>
>
From: Carl Edlund
To: Al Armendariz; Lawrence Starfield
Subject: Re: PNM / San J uan Generating Station BART Determination - Delegation Letter
Date: 07/04/2011 08:48 PM
I've been hiding out in Big Bend country with my grandson (no electronic reception for 4 days) but
arrived today in Ft Davis where my blackberry started to work again.

From: Al Armendariz
Sent: 07/04/2011 08:20 PM EDT
To: Lawrence Starfield
Cc: Carl Edlund
Subject: Re: PNM / San J uan Generating Station BART Determination - Delegation Letter
Oh. Miscommunication.
Carl: can you call J oe to clarify?
Thanks
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: Lawrence Starfield
Sent: 07/04/2011 08:10 PM EDT
To: Al Armendariz
Cc: Carl Edlund
Subject: Re: PNM / San J uan Generating Station BART Determination - Delegation Letter
Al,
J anet's summary, plus your points, tell the story.
Please advise.
Larry
Sent by EPA Wireless E-Mail Services
From: Al Armendariz
Sent: 07/04/2011 06:05 PM EDT
To: J anet McCabe; Arvin Ganesan; Gina McCarthy; Lawrence Starfield; Avi Garbow
Cc: J oseph Goffman; Michael Goo; Rob Brenner; Steve Page; "Edlund, Carl" <edlund.carl@epa.gov>;
"Diggs, Thomas" <diggs.thomas@epa.gov>; Lawrence Starfield; "Gray, David" <gray.david@epa.gov>
Subject: Re: PNM / San J uan Generating Station BART Determination - Delegation Letter
J anet: a perfect summary.
Two additional points: this plant is very old (circa-1975) and is located near a large number of class 1
areas in the vicinity of the 4-corners. SCR will result in substantial visibility improvements. SJ GS is the
textbook example of what the regional haze provisions were intended to address.

(Carl: anything else?)
Best to all,
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: J anet McCabe
Sent: 07/04/2011 05:55 PM EDT
To: Arvin Ganesan; Gina McCarthy; Al Armendariz; Lawrence Starfield; Avi Garbow
Cc: J oseph Goffman; Michael Goo; Rob Brenner; J anet McCabe; Steve Page
Subject: Fw: PNM / San J uan Generating Station BART Determination - Delegation Letter
The attached note and documents have to do with an issue in New Mexico, specifically the
BART SIP under the Regional Haze program as it affects the San Juan Generating
Station.





Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
-----Forwarded by Janet McCabe/DC/USEPA/US on 07/04/2011 05:23PM -----
To: Joseph Goffman/DC/USEPA/US@EPA, Janet McCabe/DC/USEPA/US@EPA, Michael
Goo/DC/USEPA/US@EPA
From: "Pablo, Jeanette" <jeanette.pablo@pnmresources.com>
Date: 07/04/2011 04:16PM
Subject: PNM / San Juan Generating Station BART Determination - Delegation Letter
(See attached file: Letter to Sen Udall 7-1-11.pdf)
(See attached file: 2011 7 1 - NMED BART Analysis.pdf)
> Attached are a copy of a letter to the NM Delegation from PNM Resources CEO, Pat Collawn, and
the Approvability Analysis of NMED's BART Determination for Public Service Company of New
Mexico's San Juan Generating Station, prepared by our counsel Bill Bumpers and Michael Heister
at the law firm of Baker Botts. Please let me know if you have any questions.
Warm regards,
Jeanette
Jeanette Pablo
Federal Affairs
PNM Resources
5505 Connecticut Avenue, NW
#216
Washington, DC 20015
202-468-9688
Jeanette.Pablo@PNMResources.com
>
>
>
From: Lawrence Starfield
To: Al Armendariz
Subject: Re: PNM / San J uan Generating Station BART Determination - Delegation Letter
Date: 07/04/2011 07:34 PM
Well, it's good that it came up again.
Larry
Sent by EPA Wireless E-Mail Services
From: Al Armendariz
Sent: 07/04/2011 08:20 PM EDT
To: Lawrence Starfield
Cc: Carl Edlund
Subject: Re: PNM / San J uan Generating Station BART Determination - Delegation Letter
Oh. Miscommunication.
Carl: can you call J oe to clarify?
Thanks
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: Lawrence Starfield
Sent: 07/04/2011 08:10 PM EDT
To: Al Armendariz
Cc: Carl Edlund
Subject: Re: PNM / San J uan Generating Station BART Determination - Delegation Letter
Al,
J anet's summary, plus your points, tell the story.
u were -- so I told J oe Kordzi to use 5 years. Do
you want to go back to a "3-5 year" schedule?
Please advise.
Larry
Sent by EPA Wireless E-Mail Services
From: Al Armendariz
Sent: 07/04/2011 06:05 PM EDT
To: J anet McCabe; Arvin Ganesan; Gina McCarthy; Lawrence Starfield; Avi Garbow
Cc: J oseph Goffman; Michael Goo; Rob Brenner; Steve Page; "Edlund, Carl" <edlund.carl@epa.gov>;
"Diggs, Thomas" <diggs.thomas@epa.gov>; Lawrence Starfield; "Gray, David" <gray.david@epa.gov>
Subject: Re: PNM / San J uan Generating Station BART Determination - Delegation Letter
J anet: a perfect summary.
Two additional points: this plant is very old (circa-1975) and is located near a large number of class 1
areas in the vicinity of the 4-corners. SCR will result in substantial visibility improvements. SJ GS is the
textbook example of what the regional haze provisions were intended to address.
Also, this plant has a nearby cousin on Navajo Lands (the 4-Corners Plant) for which SCR has been

(Carl: anything else?)
Best to all,
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: J anet McCabe
Sent: 07/04/2011 05:55 PM EDT
To: Arvin Ganesan; Gina McCarthy; Al Armendariz; Lawrence Starfield; Avi Garbow
Cc: J oseph Goffman; Michael Goo; Rob Brenner; J anet McCabe; Steve Page
Subject: Fw: PNM / San J uan Generating Station BART Determination - Delegation Letter
The attached note and documents have to do with an issue in New Mexico, specifically the
BART SIP under the Regional Haze program as it affects the San Juan Generating
Station.





Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
-----Forwarded by Janet McCabe/DC/USEPA/US on 07/04/2011 05:23PM -----
To: Joseph Goffman/DC/USEPA/US@EPA, Janet McCabe/DC/USEPA/US@EPA, Michael
Goo/DC/USEPA/US@EPA
From: "Pablo, Jeanette" <jeanette.pablo@pnmresources.com>
Date: 07/04/2011 04:16PM
Subject: PNM / San Juan Generating Station BART Determination - Delegation Letter
(See attached file: Letter to Sen Udall 7-1-11.pdf)
(See attached file: 2011 7 1 - NMED BART Analysis.pdf)
> Attached are a copy of a letter to the NM Delegation from PNM Resources CEO, Pat Collawn, and
the Approvability Analysis of NMED's BART Determination for Public Service Company of New
Mexico's San Juan Generating Station, prepared by our counsel Bill Bumpers and Michael Heister
at the law firm of Baker Botts. Please let me know if you have any questions.
Warm regards,
Jeanette
Jeanette Pablo
Federal Affairs
PNM Resources
5505 Connecticut Avenue, NW
#216
Washington, DC 20015
202-468-9688
Jeanette.Pablo@PNMResources.com
>
>
>
From: J anet McCabe
To: Al Armendariz
Subject: Re: PNM / San J uan Generating Station BART Determination - Delegation Letter
Date: 07/04/2011 05:43 PM
Thanks for the additions, Al, and for including your staff. no problem missing the call.
Larry said you were in a meeting it might be tough to break away from.
Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
-----Al Armendariz/R6/USEPA/US wrote: -----
To: Janet McCabe/DC/USEPA/US@EPA, Arvin Ganesan/DC/USEPA/US@EPA, Gina
McCarthy/DC/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, Avi
Garbow/DC/USEPA/US@EPA
From: Al Armendariz/R6/USEPA/US
Date: 07/04/2011 06:05PM
Cc: Joseph Goffman/DC/USEPA/US@EPA, Michael Goo/DC/USEPA/US@EPA, Rob
Brenner/DC/USEPA/US@EPA, Steve Page/RTP/USEPA/US@EPA, "Edlund, Carl"
<edlund.carl@epa.gov>, "Diggs, Thomas" <diggs.thomas@epa.gov>, "Starfield, Larry"
<starfield.lawrence@epamail.epa.gov>, "Gray, David" <gray.david@epa.gov>
Subject: Re: PNM / San Juan Generating Station BART Determination - Delegation Letter
Janet: a perfect summary.
Two additional points: this plant is very old (circa-1975) and is located near a large
number of class 1 areas in the vicinity of the 4-corners. SCR will result in substantial
visibility improvements. SJGS is the textbook example of what the regional haze
provisions were intended to address.

(Carl: anything else?)
Best to all,
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: Janet McCabe
Sent: 07/04/2011 05:55 PM EDT
To: Arvin Ganesan; Gina McCarthy; Al Armendariz; Lawrence Starfield; Avi Garbow
Cc: Joseph Goffman; Michael Goo; Rob Brenner; Janet McCabe; Steve Page
Subject: Fw: PNM / San Juan Generating Station BART Determination - Delegation
Letter
The attached note and documents have to do with an issue in New Mexico, specifically
the BART SIP under the Regional Haze program as it affects the San Juan Generating
Station.






Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
-----Forwarded by Janet McCabe/DC/USEPA/US on 07/04/2011 05:23PM -----
To: Joseph Goffman/DC/USEPA/US@EPA, Janet McCabe/DC/USEPA/US@EPA, Michael
Goo/DC/USEPA/US@EPA
From: "Pablo, Jeanette" <jeanette.pablo@pnmresources.com>
Date: 07/04/2011 04:16PM
Subject: PNM / San Juan Generating Station BART Determination - Delegation Letter
(See attached file: Letter to Sen Udall 7-1-11.pdf)
(See attached file: 2011 7 1 - NMED BART Analysis.pdf)
> Attached are a copy of a letter to the NM Delegation from PNM Resources CEO, Pat Collawn,
and the Approvability Analysis of NMED's BART Determination for Public Service Company of New
Mexico's San Juan Generating Station, prepared by our counsel Bill Bumpers and Michael Heister
at the law firm of Baker Botts. Please let me know if you have any questions.
Warm regards,
Jeanette
Jeanette Pablo
Federal Affairs
PNM Resources
5505 Connecticut Avenue, NW
#216
Washington, DC 20015
202-468-9688
Jeanette.Pablo@PNMResources.com
>
>
>
From: Al Armendariz
To: J anet McCabe
Subject: Re: PNM / San J uan Generating Station BART Determination - Delegation Letter
Date: 07/04/2011 05:06 PM
And sorry I missed the Friday call with the team. I was in a noisy place and couldn't break away. I
called Tom shortly after and he filled me in...
Best,
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: J anet McCabe
Sent: 07/04/2011 05:55 PM EDT
To: Arvin Ganesan; Gina McCarthy; Al Armendariz; Lawrence Starfield; Avi Garbow
Cc: J oseph Goffman; Michael Goo; Rob Brenner; J anet McCabe; Steve Page
Subject: Fw: PNM / San J uan Generating Station BART Determination - Delegation Letter
The attached note and documents have to do with an issue in New Mexico, specifically the
BART SIP under the Regional Haze program as it affects the San Juan Generating
Station.






Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
-----Forwarded by Janet McCabe/DC/USEPA/US on 07/04/2011 05:23PM -----
To: Joseph Goffman/DC/USEPA/US@EPA, Janet McCabe/DC/USEPA/US@EPA, Michael
Goo/DC/USEPA/US@EPA
From: "Pablo, Jeanette" <jeanette.pablo@pnmresources.com>
Date: 07/04/2011 04:16PM
Subject: PNM / San Juan Generating Station BART Determination - Delegation Letter
(See attached file: Letter to Sen Udall 7-1-11.pdf)
(See attached file: 2011 7 1 - NMED BART Analysis.pdf)
> Attached are a copy of a letter to the NM Delegation from PNM Resources CEO, Pat Collawn, and
the Approvability Analysis of NMED's BART Determination for Public Service Company of New
Mexico's San Juan Generating Station, prepared by our counsel Bill Bumpers and Michael Heister
at the law firm of Baker Botts. Please let me know if you have any questions.
Warm regards,
Jeanette
Jeanette Pablo
Federal Affairs
PNM Resources
5505 Connecticut Avenue, NW
#216
Washington, DC 20015
202-468-9688
Jeanette.Pablo@PNMResources.com
>
>
>
From: J oyce Runyan
To: Al Armendariz
Subject: call Stephanie Kodish
Date: 07/05/2011 01:07 PM
Stephanie Kodish
National Park Conserv. Assoc.
re: San J uan
O: 865-329-2424 ext 28
cell:
Please call. She said it is time sensitive
Thanks,
J oyce Runyan
EPA Region 6
Office of the Regional Administrator (6RA)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202
(214) 665-2100 Main
(214) 665-2150 Direct
(214) 665-6648 Fax
runyan.joyce@epa.gov
From: Lawrence Starfield
To: Al Armendariz
Subject: Can you call me?
Date: 07/01/2011 03:25 PM
Al,
Please give me a call when you have a minute re: San J uan GS, and budget.
Thanks.
Larry
Sent by EPA Wireless E-Mail Services
From: Lawrence Starfield
To: Al Armendariz
Cc: Carl Edlund; Tom Diggs; Suzanne Murray; Suzanne Smith-Roquemore/R6/USEPA/US@EPA; Guy Donaldson;
Connie Sanchez; Agustin Carbo-Lugo
Subject: Re: San J uan and NM RH SIP
Date: 06/30/2011 08:22 PM
The call with J anet McCabe on the Regional Haze FIP for NM will be tomorrow (Friday) at 2 pm Central,
3 pm Eastern, for 30 minutes.
Let's use our call-in number:
Connie - pls send out a Lotus notes scheduler.
Thanks.
Larry
Sent by EPA Wireless E-Mail Services
From: Al Armendariz
Sent: 06/29/2011 12:43 PM EDT
To: Lawrence Starfield
Cc: Carl Edlund
Subject: Re: San J uan and NM RH SIP
Yes. Friday's good.
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: Lawrence Starfield
Sent: 06/29/2011 12:39 PM EDT
To: Al Armendariz
Cc: Carl Edlund
Subject: Fw: San J uan and NM RH SIP
Al,
Sounds like a call with J anet would be useful. Friday?
Larry
Sent by EPA Wireless E-Mail Services
From: J anet McCabe
Sent: 06/29/2011 12:24 AM EDT
To: Lawrence Starfield
Subject: San J uan and NM RH SIP
Larry--

I spoke to Bill Bumpers yesterday. He's been hired by San Juan to help them get
Regional Haze sorted out and, i presume to help them help NM get us to approve their
SIP rather than impose a FIP.

He confirmed that the NM Board did approve the BART SIP and 110(a) interstate SIP
rules earlier this month. He expected the SIP would be submitted to Region 6 yet this
week. He thinks the BART analysis is solid and that we would have a hard time not
approving it.

His ask is that we consider splitting off the 110(a) approval from the BART approval--that
we go ahead and finalize a FIP by our deadline this summer that imposes the less strict
NOx limit required by the modeling for interstate transport and then do a separate
approval for BART which, he hopes, would be the state's submittal, after we've been able
to review it. He gets that we don't have time to do that review before the Consent
Decree deadline, but argues that the Consent Decree, which comes from the interstate
transport obligation, does not require as strict a reduction, per the modeling, as the BART
SIP does.

We should discuss....are you around this week?
Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: Lawrence Starfield
To: Al Armendariz
Cc: Carl Edlund
Subject: Re: San J uan and NM RH SIP
Date: 06/29/2011 05:34 PM
Al,
to think that it doesn't
represent BART." I'd be surprised if J anet disagrees.
Larry
Re: San J uan and NM RH SIP
Re: San J uan and NM RH SIP
Al
Armendariz
to: Lawrence Starfield
06/29/2011
03:14 PM
Cc: Carl Edlund
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: Al Armendariz
Sent: 06/29/2011 12:43 PM EDT
To: Lawrence Starfield
Cc: Carl Edlund
Subject: Re: San Juan and NM RH SIP
Yes. Friday's good.
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: Lawrence Starfield
Sent: 06/29/2011 12:39 PM EDT
To: Al Armendariz
Cc: Carl Edlund
Subject: Fw: San Juan and NM RH SIP
Al,
Sounds like a call with Janet would be useful. Friday?
Larry
Sent by EPA Wireless E-Mail Services
From: Janet McCabe
Sent: 06/29/2011 12:24 AM EDT
To: Lawrence Starfield
Subject: San Juan and NM RH SIP
Larry--

I spoke to Bill Bumpers yesterday. He's been hired by San J uan to
help them get Regional Haze sorted out and, i presume to help them
help NM get us to approve their SIP rather than impose a FIP.

He confirmed that the NM Board did approve the BART SIP and 110(a)
interstate SIP rules earlier this month. He expected the SIP would be
submitted to Region 6 yet this week. He thinks the BART analysis is
solid and that we would have a hard time not approving it.

His ask is that we consider splitting off the 110(a) approval from the
BART approval--that we go ahead and finalize a FIP by our deadline
this summer that imposes the less strict NOx limit required by the
modeling for interstate transport and then do a separate approval for
BART which, he hopes, would be the state's submittal, after we've
been able to review it. He gets that we don't have time to do that
review before the Consent Decree deadline, but argues that the
Consent Decree, which comes from the interstate transport obligation,
does not require as strict a reduction, per the modeling, as the BART
SIP does.

We should discuss....are you around this week?
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: Carl Edlund
To: armendariz.al@epa.gov; Lawrence Starfield
Cc: Thomas Diggs; Guy Donaldson
Subject: Fw: San J uan and NM RH SIP
Date: 06/29/2011 02:59 PM
----- Forwarded by Carl Edlund/R6/USEPA/US on 06/29/2011 02:55 PM -----
From: Guy Donaldson/R6/USEPA/US
To: Carl Edlund/R6/USEPA/US@EPA
Cc: "Joe Kordzi" <Kordzi.Joe@epamail.epa.gov>, "Suzanne Murray" <murray.suzanne@epa.gov>, "SuzanneR Smith"
<Smith.SuzanneR@epamail.epa.gov>, Thomas Diggs/R6/USEPA/US@EPA, Lucinda Watson/R6/USEPA/US@EPA
Date: 06/29/2011 01:14 PM
Subject: Re: Fw: San Juan and NM RH SIP
I am going to be out Friday but as we are thinking about this, here are some things to consider.










From: Carl Edlund/R6/USEPA/US
To: Thomas Diggs/R6/USEPA/US@EPA, "Guy Donaldson" <Donaldson.Guy@epamail.epa.gov>, "Joe Kordzi"
<Kordzi.Joe@epamail.epa.gov>
Cc: "Suzanne Murray" <murray.suzanne@epa.gov>, "SuzanneR Smith" <Smith.SuzanneR@epamail.epa.gov>
Date: 06/29/2011 11:57 AM
Subject: Fw: San Juan and NM RH SIP
Sent by EPA Wireless E-Mail Services
From: Al Armendariz
Sent: 06/29/2011 12:43 PM EDT
To: Lawrence Starfield
Cc: Carl Edlund
Subject: Re: San J uan and NM RH SIP
Yes. Friday's good.
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
From: Lawrence Starfield
Sent: 06/29/2011 12:39 PM EDT
To: Al Armendariz
Cc: Carl Edlund
Subject: Fw: San J uan and NM RH SIP
Al,
Sounds like a call with J anet would be useful. Friday?
Larry
Sent by EPA Wireless E-Mail Services
From: J anet McCabe
Sent: 06/29/2011 12:24 AM EDT
To: Lawrence Starfield
Subject: San J uan and NM RH SIP
Larry--

I spoke to Bill Bumpers yesterday. He's been hired by San Juan to help them get Regional Haze
sorted out and, i presume to help them help NM get us to approve their SIP rather than impose a FIP.

He confirmed that the NM Board did approve the BART SIP and 110(a) interstate SIP rules earlier this
month. He expected the SIP would be submitted to Region 6 yet this week. He thinks the BART
analysis is solid and that we would have a hard time not approving it.

His ask is that we consider splitting off the 110(a) approval from the BART approval--that we go ahead
and finalize a FIP by our deadline this summer that imposes the less strict NOx limit required by the
modeling for interstate transport and then do a separate approval for BART which, he hopes, would be
the state's submittal, after we've been able to review it. He gets that we don't have time to do that
review before the Consent Decree deadline, but argues that the Consent Decree, which comes from
the interstate transport obligation, does not require as strict a reduction, per the modeling, as the
BART SIP does.

We should discuss....are you around this week?
Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: Lawrence Starfield
To: J anet McCabe
Cc: Al Armendariz
Subject: Re: NM Regional Haze FIP
Date: 06/27/2011 09:04 AM
Attachments: NM Regl haze SIP comments by EPA 5 13 11.pdf
J anet,
Here's some updated information on the New Mexico Regional Haze situation.
The Board has, in fact, adopted the replacement SIP for New Mexico, although we
haven't received the package yet from the Governor.




Let me know if you have any further questions.
Larry
From: Lawrence Starfield
To: Al Armendariz
Subject: Re: NM Regional Haze FIP
Date: 06/27/2011 08:11 AM
Will do, and I'll clean it up a bit.
Larry
Sent by EPA Wireless E-Mail Services
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 06/26/2011 11:42 PM EDT
To: Lawrence Starfield
Subject: Re: NM Regional Haze FIP
Feel free to respond. I'm kind of tied up.
However, try to clarify Guy's response. He uses pronouns, and switches
between sentences and paragraphs between our FIP and the potential
new state SIP without being clear exactly what he is referring to.
Thanks
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA - Region 6
armendariz.al@epa.gov
214-665-2100
twitter: @al_armendariz
Lawrence Starfield
----- Original Message -----
From: Lawrence Starfield
Sent: 06/26/2011 09:58 PM CDT
To: Al Armendariz
Subject: Fw: NM Regional Haze FIP
Al,
J anet McCabe sent me a note inquiring about the NM FIP status. I
asked Guy for details, which he provided. Do you want to respond to
J anet, or should I?
Larry
----- Forwarded by Lawrence Starfield/R6/USEPA/US on 06/26/2011 09:56 PM -----
Re: NM Regional Haze FIP
06/26/2011
Guy
Donaldson
to: Lawrence Starfield
04:13 PM
Cc: Carl Edlund, "Tom Diggs", "Guy Donaldson", J oe Kordzi, Michael Feldman
The board has adopted the SIP. I don't think it has been submitted
yet from the governor.




[attachment "EPA Comments 5-13-2011.pdf" deleted by Al
Armendariz/R6/USEPA/US]
From: Carl Edlund
To: Al Armendariz
Cc: Lawrence Starfield
Subject: RE: You requested follow-up (1) on a phased SCR timetable and (2) a plant wide NOx average
Date: 06/17/2011 06:02 PM
Thanks for the endorsement Al.


I sincerely hope you weren't reading this on vacation!!!
Sent with Good (www.good.com)
Ggggggg
-------- Original Message --------
From : Al Armendariz/R6/USEPA/US
To : Carl Edlund/R6/USEPA/US@EPA, J oe Kordzi/R6/USEPA/US@EPA
Cc : Guy Donaldson/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA,
Michael Feldman/R6/USEPA/US@EPA
Sent on : 06/16/2011 10:40:46 PM
Subject : Re: You requested follow-up (1) on a phased SCR timetable and (2) a
plant wide NOx average
Thanks for replying quickly Carl while I'm out on vacation in Florida.
As you and I agreed, J oe and the team should move forward
Thanks to everyone.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Carl Edlund
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption
(b)(5) -
Deliberative

----- Original Message -----
From: Carl Edlund
Sent: 06/16/2011 10:09 PM EDT
To: Joe Kordzi; Al Armendariz
Cc: Guy Donaldson; Thomas Diggs; Michael Feldman
Subject: RE: You requested follow-up (1) on a phased SCR timetable and
(2) a p
J oe: I

Please move forward with these approaches.
Sent with Good (www.good.com)
Ggggggg
-------- Original Message --------
From : J oe Kordzi/R6/USEPA/US
To : Al Armendariz/R6/USEPA/US@EPA
Cc : Guy Donaldson/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA,
Carl Edlund/R6/USEPA/US@EPA, Michael Feldman/R6/USEPA/US@EPA
Sent on : 06/16/2011 05:44:41 PM
Subject : You requested follow-up (1) on a phased SCR timetable and (2) a plant
wide NOx average
Hi Al,
During our briefing on our NM RH FIP, you requested follow-up on (1)
on a phased SCR construction timetable and (2) a plant wide NOx
average.
I have re-analyzed the space constraints at the SJ GS and consulted
with our contractor, Dr. Fox.


FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative
Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
Pls let me know if these approaches are OK.
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Thomas Diggs
To: Al Armendariz
Cc: diggs.thomas@epa.gov; Smith.Suzanne@epamail.epa.gov
Subject: Re: Fw: Docket No. EPA-R06-OAR-2010-0846
Date: 06/16/2011 05:49 PM
Attachments: NMUSA_EPA-R06-OAR-2010-0846Armendariz.pdf
Al:
Thanks. As you are aware, the comment period has long ago closed on this rulemaking. I will visit
with Suzanne and our team on how best to respond.
Tom
Al Armendariz---06/16/2011 05:41:30 PM---Fyi. Attachments and email. Al
From: Al Armendariz/R6/USEPA/US
To: diggs.thomas@epa.gov, Smith.Suzanne@epamail.epa.gov
Date: 06/16/2011 05:41 PM
Subject: Fw: Docket No. EPA-R06-OAR-2010-0846
Fyi. Attachments and email.
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
----- Forwarded by Al Armendariz/R6/USEPA/US on 06/16/2011 06:40 PM -----
From: "Carla J . Sonntag" <nmusa@rt66.com>
To: Al Armendariz/R6/USEPA/US@EPA
Date: 06/16/2011 06:11 PM
Subject:
Docket No. EPA-R06-OAR-2010-0846
Dr. Armendariz:

Attached and below are the comments of the New Mexico Utility Shareholders Alliance (NMUSA) on
EPA Docket No. EPA-R06-OAR-0846.

Thank you for your consideration.
Carla J. Sonntag

Carla J. Sonntag
Executive Director
NMUSA
(505) 836-4223


Dr. Al
Armendariz
June 16, 2011
Regional Administrator
EPA Region 6
1445 Ross Avenue
Suite 1200
Dallas, Texas 75202

RE: New Mexico Regional Haze State Implementation Plan and PNM San Juan Generating
Station BART Determination
Docket No. EPA-R06-OAR-2010-0846

Dear Dr. Armendariz:

The New Mexico Utility Shareholders Alliance (NMUSA) represents over 7,000 shareholders of gas
and electric utility companies operating in New Mexico. Most of
our members live in New Mexico and many own stock in PNM, the majority owner and operator of the
San Juan Generating Station (SJGS).

An internal survey of our members shows that most of our members are retirees on a fixed income.
Over 72 percent are 65 years or older and 47 percent have an annual household income of less than
$50,000. This is not a lot of money in light of already rising energy, fuel, medical and food costs. In
addition, New Mexico is the third poorest state in the nation with 25 percent of its population living at
150 percent of the poverty level and 40 percent living at 200 percent of the poverty level.

The NMUSA is very concerned about the plans now being considered by the Environmental
Protection Agency (EPA) for Best Available Retrofit Technology (BART) at the SJGS. PNM has
already invested $320,000,000 in environmental upgrades that have significantly reduced pollutants
and improved visibility in the region. That upgrade, completed in 2009, reduced haze-causing
emissions including nitrogen oxides by 44 percent, SO2 by 71 percent, and particulates by 72 percent.
In addition, the plant installed mercury removal controls which are removing 99% of the mercury in
the flue gas.

The state of New Mexico, along with PNM, the majority owner and operator of the plant, developed a
State Implementation Plan (SIP) for the installation of BART that included Selective Non-catalytic
Reduction (SNCR) technology. The SNCR will further reduce emissions at SJGS and improve
regional visibility with NOx reduced by an additional 20 percent. This would be a total combined NOx
reduction of 73 percent from 2006 levels. PNM has also agreed to a reduction in the plants SO2
emissions limit by 20 percent. The State Implementation Plan (SIP) is estimated to cost $77 million or
approximately $11 per household.

The EPA designed a Selective Catalytic Reduction (SCR) technology plan that would cost from $750
million to $1 billion dollars to install, or approximately $85 per household. The SCR technology would
provide with very little additional visibility benefit. With computer generated modeling of how the two
systems (the state's recommended SNCR and the EPA's recommended SCR technology) would
affect visibility in the area, the unaided eye can detect almost no difference!

The cost of this retrofit will be incremental to the costs of many other services and commodities.
When utility rates increase, the costs of all services and goods produced in the state will also rise.
New Mexicans simply cannot afford the EPA's recommended SCR technology.

It is also important to consider that the SJGS, and the San Juan Coal Mine that supplies its fuel, are
major employers in the Four Corners region and contribute to the economic health of the region and
the state. This plant's continued operations are important to provide the following economic benefit to
the area:

- SJGS employs 394 full-time workers, 20 percent of whom are Native American
- The San Juan mine employs 526 people, of whom 46 percent are Native American.
-The plant pays millions of dollars a year in government taxes, including $54.8 million annually in
coal royalties and taxes to governments and tribes and $6.4 million annually in property
taxes to San Juan County.
- San Juan also purchases about $30 million in materials and supplies each year and holds
approximately $122 million in contracts for outside services. The plant pays $280 million each year for
coal and ash removal.

The NMUSA believes that the analysis conducted by the EPA for this BART determination is flawed.
EPA failed to account for site-specific characteristics of SJGS and the unique circumstances at the
plant that make installation of SCRs extremely complex and difficult. In addition, the exclusive use of
the EPA Cost Control Manual grossly underestimates the expected SCR installation costs. The
manual is outdated (last updated in the early 2000s) and fails to account for SCR-specific factors as
they relate to SJGS. We do not feel these factors were taken into consideration in the EPA's
analysis.

The SJGS plant cannot be retrofitted with a standard plan commonly used for newer plants, nor will
the cost be the same. The EPA estimate did not come close to current costs for material, labor, and
equipment transportation. This plant is located in a land-locked area that will require equipment to be
transported by truck, which is quite costly in light of current fuel prices.

The New Mexico Environmental Improvement Board (EIB) unanimously approved the state's SIP for
installation of SNCR technology at SJGS on 6/2/11. The NMUSA supports New Mexico's SIP as the
more cost effective method of addressing the regional haze regulations.

We urge the EPA to support New Mexico's SIP and provide an economical means for our state to
address visibility regulations.

Thank you for your consideration.
Carla J. Sonntag
Executive Director

From: Al Armendariz
To: J ared Blumenfeld
Subject: Fw: OIL AND GAS: BP, Colo. strike deal to allow San J uan Basin drilling (06/09/2011)
Date: 06/14/2011 08:20 AM
Another potential option in your discussions with DOI and the Navajo.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Rob Lawrence
----- Original Message -----
From: Rob Lawrence
Sent: 06/14/2011 08:06 AM CDT
To: Al Armendariz; Michael Overbay
Subject: Fw: OIL AND GAS: BP, Colo. strike deal to allow San Juan Basin
drilling (06/09/2011)
At least part of the Navajo Nation is within the San J uan basin
according to this map.
Rob Lawrence
Senior Policy Advisor - Energy Issues
lawrence.rob@epa.gov
214.665.6580 (Desk)
214.665.7263 (FAX)
----- Forwarded by Rob Lawrence/R6/USEPA/US on 06/14/2011 08:04 AM -----
From: Ruben Casso/R6/USEPA/US
To: Mark Sather/R6/USEPA/US@EPA, Rob Lawrence/R6/USEPA/US@EPA
Date: 06/13/2011 08:14 AM
Subject: OIL AND GAS: BP, Colo. strike deal to allow San J uan Basin drilling (06/09/2011)
OIL AND GAS: BP, Colo. strike deal to allow San J uan Basin
drilling (06/09/2011)
Scott Streater, E&E reporter
The state of Colorado is expanding a groundbreaking effort to balance oil and
gas drilling with natural resource protection in some of the most
environmentally sensitive areas along the Western Slope.
Under terms of an agreement announced last week, BP America Production
Co., has agreed to a number of wildlife conservation measures to offset
impacts from a planned 68-well development in the state's rugged San Juan
basin.
Among the terms are that BP will purchase property to mitigate the impacts of
drilling, use automated equipment and reduce vehicle traffic at its well-pad
sites. The company also agreed to incorporate a closed-loop drilling system
that eliminates the need for open storage pits that can inadvertently trap and
kill birds and other wildlife.
Drilling firms have long sought access to oil and natural gas deposits in Colorado's portion of the San Juan basin. Under a new agreement
between the state of Colorado and BP America Production Co., as many as 68 new wells will be drilled in the rugged region. Map courtesy of
U.S. Geological Survey.
In addition, BP will contribute $475,000 over the next six years for various
studies to evaluate the effects of natural gas development on wildlife in the
state.
"The agreement shows that it is possible to develop natural gas resources and
preserve Colorado's wildlife," said Tom Remington, director of the Colorado
Division of Wildlife. "This is an ideal model for planning natural resource
development and conservation on a landscape scale."
Jerry Austin, BP's San Juan Area Operations Manager, said in a statement that
the company is "proud to enter into a plan that not only incorporates
operational changes, but also provides actual land preservation."
The agreement, covering portions of La Plata and Archuleta counties, was
devised by representatives of BP and the Division of Wildlife, along with the
Nature Conservancy. It also received input from the Bureau of Land
Management, the Forest Service and the Army Corps of Engineers.
The parties worked together to identify the most suitable mitigation sites in the
basin, eventually creating an inventory of 11 high-quality habitat areas that
merit long-term preservation.
BP will choose lands from this inventory as the project develops and the
specific acreage for mitigation is determined, said Jon Holst, the Division of
Wildlife's energy liaison in southwest Colorado.
"We've used the best available science to identify impacted species and
priority mitigation areas," said Holst.
Record of compromise
The San Juan Basin agreement follows nine similar agreements announced last
year between the state and companies like Exxon Mobil Corp., Encana Corp.
and Marathon Oil Co., which allow the companies to drill in sensitive sections
of northwest Colorado's resource-rich Piceance basin -- one of the most active
oil and gas drilling regions in the West and home to a wide array of wildlife,
including greater sage grouse and big-game species like elk and mule deer.
The key to the agreements is surveying proposed development sites early,
identifying areas where drilling could negatively affect natural resources, and
then devising strategies to avoid or mitigate those impacts, said Joe Kiesecker,
the Nature Conservancy's lead scientist in Fort Collins, Colo.
"Proactive planning helps reduce conflicts between development and wildlife
conservation," Kiesecker said. "By identifying conflicts between conservation
and development early, we can provide effective, balanced options."
Industry officials like the approach because agreement terms can be applied to
multiple drilling operations across a wide region, instead of companies having
to acquire individual permits on a site-by-site basis.
Tom Spezze, southwest regional manager for the Colorado Division of
Wildlife, said this makes the effort "unique" because it "allows for mitigation
banking to address future impacts from development, and focuses mitigation
efforts on habitat protection to offset impacts to wildlife."
The agreements also could help soften the sting for industry from tough new
oil and gas regulations implemented by Colorado in 2009, including
requirements for increased use of lined pits to protect groundwater, improved
stormwater management to protect surface water, and various measures to
protect wildlife.
The agreements also come as industry representatives and regulators,
particularly on the federal level, have publicly sparred over land-use policies
that some say favor conservation over energy development and jobs.
The Western Energy Alliance, an oil and gas drilling trade group, released a
survey last year in which oil and natural gas industry officials said they are
now avoiding drilling on federal land in the mineral-rich Rocky Mountain
region due to tougher regulations (Land Letter, April 29, 2010).
The Interior Department, meanwhile, has pointed to data showing that the oil
and gas industry holds nearly 7,200 unused permits to drill on public lands,
suggesting that a downturn in drilling activity may have more to do with the
poor economy than excessive regulation (Greenwire, March 25).
Streater writes from Colorado Springs, Colo.
From: Thomas Diggs
To: edlund.carl@epa.gov; Anthony Talton; Guy Donaldson; J effrey Robinson; Maria Martinez; Al Armendariz; Layla
Mansuri; Suzanne Murray; Lawrence Starfield; J ohn Blevins; J avier Balli; Bill Luthans
Cc: Robinson J eff; Donaldson.Guy@epa.gov; Martinez.Maria@epa.gov; talton.anthony@epa.gov
Subject: Fw: air contract dollars
Date: 05/23/2011 08:02 AM
Attachments: Options paper - contract tasks for air work 5.19.11.docx
Here are ideas for contractor work using the Air dollars referenced in the emails below.
Tom
----- Forwarded by Thomas Diggs/R6/USEPA/US on 05/23/2011 07:58 AM -----
From: Carl Edlund/R6/USEPA/US
To: Thomas Diggs/R6/USEPA/US@EPA
Cc: Anthony Talton/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Jeffrey Robinson/R6/USEPA/US@EPA, Maria
Martinez/R6/USEPA/US@EPA, "Al Armendariz" <armendariz.al@epa.gov>, "Layla Mansuri"
<Mansuri.Layla@epamail.epa.gov>, "Suzanne Murray" <murray.suzanne@epa.gov>, Lawrence
Starfield/R6/USEPA/US@EPA, John Blevins/R6/USEPA/US@EPA, "Javier Balli" <Balli.Javier@epamail.epa.gov>, "Bill
Luthans" <luthans.william@epa.gov>
Date: 05/21/2011 01:51 PM
Subject: Re: air contract dollars
Good job all...I reviewed these and think the are good to share with the rest of the air leadership group.
One point that I' want to check out is the last work assignment and whether it will be covered by the
management assistant for which we are currently conducting interviews.
Sent by EPA Wireless E-Mail Services
----- Original Message -----
From: Thomas Diggs
Sent: 05/19/2011 04:38 PM CDT
To: Carl Edlund
Cc: Anthony Talton; Guy Donaldson; Jeffrey Robinson; Maria Martinez
Subject: Fw: air contract dollars
Carl:
Our Air team has been actively working on a .
Attached is a two page table with 11 ideas for contractor work options. We met last week as a team
with the Section Chiefs and their staff who are experienced and knowledgeable in contracts and scopes
of work. This work product is the results of a lot of thought by our team. These are meant to be
suggestions for use of the funds and the scope of work can certainly be written to give more direction
and clarity of the task. This is a draft so we certainly have liberty to add or drop tasks as well.
Ellen Belk and Jeff Robinson have both been in touch with OAQPS's contracting office and both RTI
and EC/R have sufficient hours on their contracts to take on these efforts. I am running this by the Air
Chiefs for any additional comments and welcome your comments. We can forward it up to Al or set up
a briefing after we are all comfortable with the product.
Tom
[attachment "Options paper - contract tasks for air work 5.19.11.docx" deleted by Carl
Edlund/R6/USEPA/US]
FOIA Exemption (b)(5) - Deliberative Process
----- Forwarded by Thomas Diggs/R6/USEPA/US on 05/19/2011 04:25 PM -----
From: Carl Edlund/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Lynda Carroll/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA
Cc: Thomas Diggs/R6/USEPA/US@EPA
Date: 05/08/2011 07:54 PM
Subject: Re: air contract dollars
Good ideas ...we're drafting a number of work assignments and will incorporate ideas. We also have
in-house talent that may be preferred over a contractor for developing web sites (will check that
out).
Sent by EPA Wireless E-Mail Services
----- Original Message -----
From: Al Armendariz
Sent: 05/08/2011 06:14 PM CDT
To: Lynda Carroll; Carl Edlund; Lawrence Starfield
Cc: Thomas Diggs
Subject: air contract dollars
Larry, Lynda, and Carl,
Last week we had several meetings to talk about budget, and we'll undoubtedly have a few more in
coming weeks and months.
Best to all,
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Al Armendariz
To: Carl Edlund; Larry Starfield
Subject: Fw: air contract dollars
Date: 05/21/2011 03:41 PM
Thanks Carl,
I appreciate Tom's offer, but I myself don't need to be briefed on the
specifics. The two of you and Larry can decide how to use the contract
funds.
Best
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Carl Edlund
----- Original Message -----
From: Carl Edlund
Sent: 05/21/2011 02:51 PM EDT
To: Thomas Diggs
Cc: Anthony Talton; Guy Donaldson; Jeffrey Robinson; Maria
Martinez; "Al Armendariz" <armendariz.al@epa.gov>; Layla Mansuri;
"Suzanne Murray" <murray.suzanne@epa.gov>; Lawrence Starfield;
John Blevins; Javier Balli; "Bill Luthans"
<luthans.william@epa.gov>
Subject: Re: air contract dollars
Good job all...I reviewed these and think the are good to share with
the rest of the air leadership group. One point that I' want to check out
is the last work assignment and whether it will be covered by the
management assistant for which we are currently conducting
interviews.
Sent by EPA Wireless E-Mail Services
Thomas Diggs
----- Original Message -----
From: Thomas Diggs
Sent: 05/19/2011 04:38 PM CDT
To: Carl Edlund
Cc: Anthony Talton; Guy Donaldson; Jeffrey Robinson; Maria
Martinez
Subject: Fw: air contract dollars
Carl:
Our Air team has been actively working on a proposal
. Attached is a two page table with 11
ideas for contractor work options. We met last week as a team with
the Section Chiefs and their staff who are experienced and
FOIA Exemption (b)(5) - Deliberative Proc
FOIA Exemption (b)(5) - Deliberative Process Privilege
knowledgeable in contracts and scopes of work. This work product is
the results of a lot of thought by our team. These are meant to be
suggestions for use of the funds and the scope of work can certainly
be written to give more direction and clarity of the task. This is a draft
so we certainly have liberty to add or drop tasks as well.
Ellen Belk and J eff Robinson have both been in touch with OAQPS's
contracting office and both RTI and EC/R have sufficient hours on their
contracts to take on these efforts. I am running this by the Air Chiefs
for any additional comments and welcome your comments. We can
forward it up to Al or set up a briefing after we are all comfortable with
the product.
Tom
[attachment "Options paper - contract tasks for air work 5.19.11.docx"
deleted by Carl Edlund/R6/USEPA/US]
----- Forwarded by Thomas Diggs/R6/USEPA/US on 05/19/2011 04:25 PM -----
From: Carl Edlund/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Lynda Carroll/R6/USEPA/US@EPA, Lawrence
Starfield/R6/USEPA/US@EPA
Cc: Thomas Diggs/R6/USEPA/US@EPA
Date: 05/08/2011 07:54 PM
Subject: Re: air contract dollars
Good ideas ...we're drafting a number of work assignments and
will incorporate ideas. We also have in-house talent that may be
preferred over a contractor for developing web sites (will check
that out).
...
Sent by EPA Wireless E-Mail Services
----- Original Message -----
From: Al Armendariz
Sent: 05/08/2011 06:14 PM CDT
To: Lynda Carroll; Carl Edlund; Lawrence Starfield
Cc: Thomas Diggs
Subject: air contract dollars
Larry, Lynda, and Carl,
Last week we had several meetings to talk about budget, and
we'll undoubtedly have a few more in coming weeks and months.
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
Best to all,
Al

______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Lynda Carroll
To: Al Armendariz; Carl Edlund; Lawrence Starfield
Cc: Thomas Diggs
Subject: Re: air contract dollars
Date: 05/08/2011 08:20 PM
Tuesday may be fine. It allows us to be more coordinated and precise. However, if you're
confident in what you have by tomorrow afternoon, then the sooner the better. I haven't heard
again from David Bloom
Lynda Carroll
----- Original Message -----
From: Al Armendariz
Sent: 05/08/2011 09:16 PM EDT
To: Lynda Carroll; Carl Edlund; Lawrence Starfield
Cc: Thomas Diggs
Subject: Re: air contract dollars
Lynda,
I have some time to get to the 3 questions tomorrow around 1 pm. And another block of time late
Tuesday afternoon.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
----- Original Message -----
From: Lynda Carroll
Sent: 05/08/2011 08:32 PM EDT
To: Al Armendariz; Carl Edlund; Lawrence Starfield
Cc: Thomas Diggs
Subject: Re: air contract dollars
Let me give it some thought and get back with everyone on tomorrow. Al, when do you plan to
submit your responses for the three questions to Barb?
Lynda Carroll
----- Original Message -----
From: Al Armendariz
Sent: 05/08/2011 06:14 PM CDT
To: Lynda Carroll; Carl Edlund; Lawrence Starfield
Cc: Thomas Diggs
Subject: air contract dollars
Larry, Lynda, and Carl,
Last week we had several meetings to talk about budget, and we'll undoubtedly have a few more in
coming weeks and months.





Best to all,
Al

______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
FOIA Exemption (b)(5) - Deliberative Process Privilege
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
From: Randy Gee
To: Agustin Carbo-Lugo; Al Armendariz; Carl Edlund; Guy Donaldson; J eannine Hale; J oe Kordzi; Lawrence
Starfield; Suzanne Murray; Thomas Diggs; Tina Arnold
Subject: Re: Draft Agenda for Navajo Nation Consultation
Date: 05/20/2011 09:11 AM
All:
Update on ending time. The consultation will end at noon MDT (1pm CDT).
Thank you,
Randy Gee, Associate Director of Tribal Affairs
Office of Environmental J ustice and Tribal Affairs
U.S. Environmental Protection Agency Region 6
phone (214) 665-8355
cell (972) 400-8264
fax (214) 665-2124
gee.randy@epa.gov
Randy Gee---05/19/2011 06:33:53 PM---Draft agenda for tomorrow's Navajo
Nation consultation. Note the request from Navajo Nation to end t
From: Randy Gee/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, J eannine
Hale/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA,
Thomas Diggs/R6/USEPA/US@EPA, Tina Arnold/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, J oe Kordzi/R6/USEPA/US@EPA, Agustin Carbo-
Lugo/R6/USEPA/US@EPA
Date: 05/19/2011 06:33 PM
Subject: Draft Agenda for Navajo Nation Consultation
[attachment "Agenda Region 6 Consultation re SJ GS.docx" deleted by
Randy Gee/R6/USEPA/US]
Draft agenda for tomorrow's Navajo Nation consultation. Note the
request from Navajo Nation to end the consultation at 12:30 pm.
U.S. EPA, Region 6 and Navajo Nation
Government to Government Consultation
May 20, 2011
10:00 -Noon (MDT)
Subject: US Environmental Protection Agency Proposal for Best
Available Retrofit Technology (BART) for San Juan Generating
Station (SJGS)
Draft Agenda
Welcome
Introductions
Opening Remarks, Goals for this Meeting - President Shelly, Al Armendariz
Navajo Nation: Consultation/Discussion on Topics of Interest - President
Shelly (Lead)
Review Follow-up Items
Next Steps
Tentative Topics:
Navajo Nation Overview
EPA Trust Responsibility
BART for SJGS
Economic Impacts to Navajo Nation
Health Considerations
New Mexico BART SIP for SJGS
Regional Cumulative Effects of BART for SJGS
Navajo Nation Attendees:
1. President Ben Shelly
2. Martha Shelly, First Lady
3. Arnold Silversmith, Executive Protection Services
4. Michele Morris, Director, Policy & Management
5. Stephen Etsitty, Executive Director, NN EPA
6. Eugenia Quintana, Environmental Department Manager, NN EPA Air &
Toxics Department
7. Anoop Sukumaran, Environmental Engineer, Operating Permit Program,
NNEPA
7. Fred White, Executive Director, NN Division of Natural Resources
8. Harrison Tsosie, Attorney General
9. Sam Woods, Policy Analyst
U.S. Environmental Protection Agency Attendees (In-person)
1. Al Armendariz, Regional Administrator
2. Jeannine Hale, Director, Office of Environmental Justice and Tribal
Affairs
3. Joe Kordzi, Air Planning Section
U.S. Environmental Protection Agency Attendees (Video Teleconference)
1. Larry Starfield, Deputy Regional Administrator
2. Carl Edlund, Director, Multimedia Planning and Permitting Division
3. Suzanne Murray, Regional Counsel
4. Tom Diggs, Associate Director, Multimedia Planning and Permitting
Division
5. Tina Arnold, Office of Regional Counsel
6. Agustin Carbo-Lugo, Office of Regional Counsel
Randy Gee, Associate Director of Tribal Affairs
Office of Environmental J ustice and Tribal Affairs
U.S. Environmental Protection Agency Region 6
phone (214) 665-8355
cell (972) 400-8264
fax (214) 665-2124
gee.randy@epa.gov
From: Randy Gee
To: Al Armendariz; Lawrence Starfield; J eannine Hale/R6/USEPA/US@EPA; Carl Edlund; Suzanne Murray; Thomas
Diggs; Tina Arnold; Guy Donaldson; J oe Kordzi; Agustin Carbo-Lugo
Subject: Draft Agenda for Navajo Nation Consultation
Date: 05/19/2011 06:33 PM
Attachments: Agenda Region 6 Consultation re SJ GS.docx
Draft agenda for tomorrow's Navajo Nation consultation. Note the request from
Navajo Nation to end the consultation at 12:30 pm.
U.S. EPA, Region 6 and Navajo Nation
Government to Government Consultation
May 20, 2011
10:00 -12:30 PM
Subject: US Environmental Protection Agency Proposal for Best Available
Retrofit Technology (BART) for San Juan Generating Station (SJGS)
Draft Agenda
Welcome
Introductions
Opening Remarks, Goals for this Meeting - President Shelly, Al Armendariz
Navajo Nation: Consultation/Discussion on Topics of Interest - President Shelly (Lead)
Review Follow-up Items
Next Steps
Tentative Topics:
Navajo Nation Overview
EPA Trust Responsibility
BART for SJGS
Economic Impacts to Navajo Nation
Health Considerations
New Mexico BART SIP for SJGS
Regional Cumulative Effects of BART for SJGS
Navajo Nation Attendees:
1. President Ben Shelly
2. Martha Shelly, First Lady
3. Arnold Silversmith, Executive Protection Services
4. Michele Morris, Director, Policy & Management
5. Stephen Etsitty, Executive Director, NN EPA
6. Eugenia Quintana, Environmental Department Manager, NN EPA Air & Toxics
Department
7. Anoop Sukumaran, Environmental Engineer, Operating Permit Program, NNEPA
7. Fred White, Executive Director, NN Division of Natural Resources
8. Harrison Tsosie, Attorney General
9. Sam Woods, Policy Analyst
U.S. Environmental Protection Agency Attendees (In-person)
1. Al Armendariz, Regional Administrator
2. Jeannine Hale, Director, Office of Environmental Justice and Tribal Affairs
3. Joe Kordzi, Air Planning Section
U.S. Environmental Protection Agency Attendees (Video Teleconference)
1. Larry Starfield, Deputy Regional Administrator
2. Carl Edlund, Director, Multimedia Planning and Permitting Division
3. Suzanne Murray, Regional Counsel
4. Tom Diggs, Associate Director, Multimedia Planning and Permitting Division
5. Tina Arnold, Office of Regional Counsel
6. Agustin Carbo-Lugo, Office of Regional Counsel
Randy Gee, Associate Director of Tribal Affairs
Office of Environmental J ustice and Tribal Affairs
U.S. Environmental Protection Agency Region 6
phone (214) 665-8355
cell (972) 400-8264
fax (214) 665-2124
gee.randy@epa.gov
From: Al Armendariz
To: Lawrence Starfield; Diane Taheri
Subject: Re: Al: CAN I USE YOUR ELECTRONIC SIGNATURE ON THIS? -- Navajo Nation
Date: 05/19/2011 10:11 AM
Ok.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Lawrence Starfield
----- Original Message -----
From: Lawrence Starfield
Sent: 05/19/2011 09:06 AM CDT
To: Diane Taheri
Cc: Al Armendariz
Subject: Re: Al: CAN I USE YOUR ELECTRONIC SIGNATURE ON THIS? --
Navajo Nation
Al,
I'd suggest that
Larry
Al: CAN I USE YOUR ELECTRONIC SIGNATURE ON THIS? -- Navajo Nation
Al: CAN I USE YOUR ELECTRONIC SIGNATURE ON THIS? -- Navajo
Nation
Diane
Taheri
to: Al Armendariz
05/19/2011
08:46 AM
Cc: Lawrence Starfield
FOIA Exemption (b)(5) - Deliberative Process Privilege
Al:
Evidently this letter was tied up in concurrences. We need to get this
emailed to the tribe today since your meeting is tomorrow.

The Honorable Ben Shelly
President
The Navajo Nation
Post Office Box 7440
Window Rock, Arizona 86515
Dear President Shelly:
Thank you for the May 3, 2011, request to the U.S. Environmental Protection
Agency
for a government-to-government consultation to discuss potential impacts to
the Navajo Nation resulting from the proposed Best Available Retrofit
Technology (BART) determination for the San Juan Generating Station
(SJGS). In addition to this request, we appreciate your submission of
comments and concerns by a letter dated April 11, 2011. As you know, in
coordination with the Navajo Nation Environmental Protection Agency, we
have scheduled the requested consultation meeting for May 20, 2011, from 10
AM until noon in Albuquerque.
I understand from your letters that the Navajo Nation is fundamentally
supportive of our January 5, 2011, proposal for BART at SJGS because it will
result in an improvement of visibility and public health within the Four
Corners region. However, the letter states the Navajo Nation is also concerned
about the proposed compliance schedule and non-air quality impacts
potentially resulting from the proposed rulemaking. Additionally, I understand
that you are interested in information about any planned health strategies for
the collection of data to determine the effectiveness of Clean Air Act
rulemakings that have improved public health. I look forward to hearing more
about this request to better understand your concerns and information needs.
My staff and I look forward to consultation with the Navajo Nation on these
issues.
If you have questions, please contact me at (214) 665-2100, or your staff may
contact
Ms. Jeannine Hale at (214) 665-2136.
Sincerely yours,
Al Armendariz
Regional Administrator
FOIA Exemption (b)(5) - Delib
From: Al Armendariz
To: Diane Taheri
Subject: Re: Al: CAN I USE YOUR ELECTRONIC SIGNATURE ON THIS? -- Navajo Nation
Date: 05/19/2011 10:09 AM
Yes. That would be fine.
Email to me and J eannine a pdf of the final version.

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Diane Taheri
----- Original Message -----
From: Diane Taheri
Sent: 05/19/2011 08:46 AM CDT
To: Al Armendariz
Cc: Lawrence Starfield
Subject: Al: CAN I USE YOUR ELECTRONIC SIGNATURE ON THIS? -- Navajo
Nation
Al:
Evidently this letter was tied up in concurrences. We need to get this
emailed to the tribe today since your meeting is tomorrow.

The Honorable Ben Shelly
President
The Navajo Nation
Post Office Box 7440
Window Rock, Arizona 86515
Dear President Shelly:
Thank you for the May 3, 2011, request to the U.S. Environmental Protection
Agency
for a government-to-government consultation to discuss potential impacts to
the Navajo Nation resulting from the proposed Best Available Retrofit
Technology (BART) determination for the San Juan Generating Station
(SJGS). In addition to this request, we appreciate your submission of
comments and concerns by a letter dated April 11, 2011. As you know, in
coordination with the Navajo Nation Environmental Protection Agency, we
have scheduled the requested consultation meeting for May 20, 2011, from 10
AM until noon in Albuquerque.
FOIA Exemption (b)(5) - Delib
I understand from your letters that the Navajo Nation is fundamentally
supportive of our January 5, 2011, proposal for BART at SJGS because it will
result in an improvement of visibility and public health within the Four
Corners region. However, the letter states the Navajo Nation is also concerned
about the proposed compliance schedule and non-air quality impacts
potentially resulting from the proposed rulemaking. Additionally, I understand
that you are interested in information about any planned health strategies for
the collection of data to determine the effectiveness of Clean Air Act
rulemakings that have improved public health. I look forward to hearing more
about this request to better understand your concerns and information needs.
My staff and I look forward to consultation with the Navajo Nation on these
issues.
If you have questions, please contact me at (214) 665-2100, or your staff may
contact
Ms. Jeannine Hale at (214) 665-2136.
Sincerely yours,
Al Armendariz
Regional Administrator
From: Carl Edlund
To: J oe Kordzi
Cc: Agustin Carbo-Lugo; Al Armendariz; Brian Tomasovic; diggs.thomas@epa.gov; donaldson.guy@epa.gov; J avier
Balli; Lawrence Starfield; Rob Lawrence; Suzanne Murray; hale.jeannine@epa.gov
Subject: Re: PNM site visit
Date: 05/10/2011 05:07 PM
J oe ..with the travel budget squeeze we were thinking that this would be something
that you and Agustin could handle. I know that J eannine was also interested in
participating in the Navajo consultation but that may be by telephone. Let's discuss
...
J oe Kordzi---05/10/2011 04:22:34 PM---Larry, It looks like the site visit will be on
the morning of 5/19. Rob is out this afternoon but
From: J oe Kordzi/R6/USEPA/US
To: Lawrence Starfield/R6/USEPA/US@EPA
Cc: Agustin Carbo-Lugo/R6/USEPA/US@EPA, Al Armendariz/R6/USEPA/US@EPA, Brian
Tomasovic/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, diggs.thomas@epa.gov,
donaldson.guy@epa.gov, Suzanne Murray/R6/USEPA/US@EPA, Rob Lawrence/R6/USEPA/US@EPA,
J avier Balli/R6/USEPA/US@EPA
Date: 05/10/2011 04:22 PM
Subject: Re: PNM site visit
Larry,
It looks like the site visit will be on the morning of 5/19. Rob is out
this afternoon but I've left him a message asking him if he can
accompany me. A staff level person from NMED will also attend, plus
our contractor Dr. Fox.
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
Lawrence Starfield---05/06/2011 10:05:17 AM---Al and I spoke to NMED Deputy
Secretary Raj Solomon about our planned site
From: Lawrence Starfield/R6/USEPA/US
To: Kordzi.J oe@epamail.epa.gov, Agustin Carbo-Lugo/R6/USEPA/US@EPA, Brian
Tomasovic/R6/USEPA/US@EPA, donaldson.guy@epa.gov
Cc: Suzanne Murray/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, diggs.thomas@epa.gov, Al
Armendariz/R6/USEPA/US
Date: 05/06/2011 10:05 AM
Subject: PNM site visit
Al and I spoke to NMED Deputy Secretary Raj Solomon about our planned site visit.

So you should plan to go as soon as you can set it up with PNM.
Larry
From: Lawrence Starfield
To: Al Armendariz
Subject: Re: Reg'l haze - Okla
Date: 05/04/2011 08:59 AM
Will do. Left you a voice mail --
Larry
Re: Reg'l haze - Okla
Re: Reg'l haze - Okla
Al
Armendariz
to: Lawrence Starfield
05/04/2011
08:34 AM
Yes. Let's postpone the call until next week. I need some time to
evaluate the specifics and consider the options.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Lawrence Starfield
----- Original Message -----
From: Lawrence Starfield
Sent: 05/04/2011 09:28 AM EDT
To: Al Armendariz
Subject: Reg'l haze - Okla
Al,
We had a pre-call discussion yesterday with R10 on Reg'l haze

We have a call with Steve to discuss at 3 pm/4 pm Eastern (Thursday
was booked and Friday J oe and Guy are out). Do you want to call in?
Would you prefer we delay the call until next week when you can be
fully briefed and on the call?
Let me know.
Larry
Sent by EPA Wireless E-Mail Services
From: Lawrence Starfield
To: Al Armendariz
Subject: Fw: INSIDE EPA: Oklahoma Pursues Lawsuit, Bill To Overturn EPA Rejection Of Haze Plan
Date: 05/04/2011 08:33 AM
FYI
Sent by EPA Wireless E-Mail Services
Thomas Diggs
----- Original Message -----
From: Thomas Diggs
Sent: 05/03/2011 04:32 PM CDT
To: Lawrence Starfield; Carl Edlund
Cc: Joe Kordzi; Guy Donaldson; Agustin Carbo-Lugo; Suzanne Smith
Subject: Fw: INSIDE EPA: Oklahoma Pursues Lawsuit, Bill To Overturn EPA
Rejection Of Haze Plan
Useful background piece from Inside EPA. It includes a link to Sen
Inhofe's discussion draft legislation.
Tom
----- Forwarded by Thomas Diggs/R6/USEPA/US on 05/03/2011 04:26 PM -----
From: Ruben Casso/R6/USEPA/US
To: Thomas Diggs/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA
Date: 05/03/2011 02:32 PM
Subject: INSIDE EPA: Oklahoma Pursues Lawsuit, Bill To Overturn EPA Rejection Of Haze Plan
Oklahoma Pursues Lawsuit, Bill To
Overturn EPA Rejection Of Haze Plan
Posted: May 3, 2011
Oklahoma state and federal officials are pursuing legislation and litigation to
block EPA's proposed rejection of the state's plan for reducing regional haze,
with the bill aiming to limit the agency's authority to reject state air plans and
the suit challenging EPA's bid to craft a federal air plan for the state before
finalizing its proposed rejection.
The state officials are challenging EPA's decision, published in the March 22
Federal Register, to partially reject Oklahoma's state implementation plan
(SIP) outlining the pollution reduction measures the state intended to take to
comply with EPA's regional haze program, which outlines goals for improving
air quality in national parks and wilderness areas. The agency is taking
comment on the proposed partial disapproval until May 23.
EPA rejected Oklahoma's plan to allow facilities to switch fuel from coal to
natural gas as an alternate compliance option under the haze program. The
state would not require conversion until 2026, which EPA in the proposed rule
says is far too long and would miss statutory deadlines for states to reduce
haze under its program.
In the same proposal, EPA proposed a replacement federal implementation
plan (FIP) that would impose agency-crafted pollution reduction measures
directly on the state. The FIP would give three coal-fired plants in the state
three years to add sulfur dioxide controls, switch to natural gas, or some
combination of the two options.
Haze SIPs require states to introduce best available retrofit technology
emissions controls where necessary to cut air pollution and associated haze
that impairs visibility in national parks and wilderness areas.
EPA is under pressure to approve or disapprove a slew of state haze SIPs by
May 10 under a consent decree with WildEarth Guardians reached as part of
broader settlement aimed at forcing the agency to impose FIPs on 37 states
and the District of Columbia that as of January 2009 had yet to have EPA-
approved haze SIPs in place.
Oklahoma Sen. James Inhofe (R), a leading critic of the agency's proposed SIP
rejection, April 14 floated a discussion draft of legislation that would restrict
EPA's ability to reject a state haze SIP and implement a FIP.
Among other things, the bill would place the determination of whether or not a
SIP is making "reasonable progress" toward visibility improvement "at the sole
discretion of the state after considering factors described in this section and
providing adequate opportunity for public comment." Under the air law,
compliance costs, "energy and nonair quality environmental impacts of
compliance" and other factors are considered in determining whether
"reasonable progress" toward improving visibility is being made by states in
meeting the goals of the haze program.
Beyond these factors, the legislation would also allow states to consider "the
degree of improvement in visibility that may reasonably be anticipated to
result from measures described in the applicable implementation plan" and
"the economic impacts to the state (including the people of the State)" in
determining whether they are making reasonable progress toward visibility
improvement.
The bill would as well require EPA to find that the state failed to consider
specific criteria, such as compliance time and costs, when developing their SIP
before the agency would have authority to write and impose a FIP.
In an April 14 editorial in the Tulsa World Inhofe criticized EPA for imposing
"a more stringent and less flexible" federal haze plan that he claimed "will cost
Oklahomans more on their monthly electric bills, without any additional
environmental benefits." Later in the editorial, Inhofe wrote, "We can have
affordable energy while continuing the state's progress in reducing emissions -
- and we can do it without an EPA takeover."
In a separate challenge to the proposed haze rejection, Oklahoma Attorney
General E. Scott Pruitt (R) on March 23 announced the state's intent to
sue over EPA's decision. Pruitt argues that the agency cannot develop and
implement a FIP before it issues a final rule on the partial rejection of the SIP.
"EPA was not authorized to propose a [FIP] for regional haze in Oklahoma . . .
as no final action has been taken" regarding Oklahoma's SIP, according to the
state's notice of intent to sue.
The state charges that because EPA did not promulgate a FIP by Jan. 15 -- two
years after EPA issued a finding that the state and 36 others had failed to
submit complete haze SIPs to EPA -- it did not have "authority" or
"discretion" under the Clean Air Act to propose a FIP. The notice also argues
that the FIP is not authorized given that, under the air law, "the disapproval of
all or part of the proposed Oklahoma SIP is a prerequisite to promulgation of a
FIP."
Pruitt in the notice of intent to sue also argues, "[I]t is especially important for
EPA to finish the SIP approval process for regional haze before proposing a
FIP in light of the significant authority and discretion that the Clean Air Act
gives to the State in establishing regional haze requirements."
Elsewhere in the notice, Pruitt defends the SIP by arguing that "Oklahoma
developed a sound regional haze plan that reflected input from a wide range of
interested parties." -- Bobby McMahon
From: Guy Donaldson
To: Lawrence Starfield
Cc: Al Armendariz; Carl Edlund; diggs.thomas@epa.gov; donaldson.guy@epa.gov; Suzanne Murray; Suzanne
Smith; J oe Kordzi
Subject: Re: Regional haze - Oklahoma CONFIDENTIAL
Date: 04/25/2011 07:41 AM
On your first question, we mentioned in open house and in our opening Statements
that Natural Gas was a viable option and we were soliciting comment on the timing
for installation.









J oe Kordzi---03/08/2011 11:30:32 AM--
From: J oe Kordzi/R6/USEPA/US
To: Guy Donaldson/R6/USEPA/US@EPA
Cc: Thomas Diggs/R6/USEPA/US@EPA
Date: 03/08/2011 11:30 AM
Subject: Re: Fw: Washington Power Plant
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
Guy Donaldson---03/08/2011 10:58:29 AM--

From: Guy Donaldson/R6/USEPA/US
To: Thomas Diggs/R6/USEPA/US@EPA
Cc: J oe Kordzi/R6/USEPA/US@EPA
Date: 03/08/2011 10:58 AM
Subject: Re: Fw: Washington Power Plant

Thomas Diggs---03/08/2011 09:39:26 AM---Guy and J oe: This came up in the
Regional report part of the ADD call yesterday. Wanted you to be a
From: Thomas Diggs/R6/USEPA/US
To: Guy Donaldson/R6/USEPA/US@EPA, J oe Kordzi/R6/USEPA/US@EPA
Date: 03/08/2011 09:39 AM
Subject: Fw: Washington Power Plant
Guy and J oe:
This came up in the Regional report part of the ADD call yesterday. Wanted you to
be aware of it since this
Tom
----- Forwarded by Thomas Diggs/R6/USEPA/US on 03/08/2011 09:38 AM -----
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Carl Edlund/R6/USEPA/US
To: Rick Albright/R10/USEPA/US@EPA
Cc: Thomas Diggs/R6/USEPA/US@EPA, "Deborah J ordan" <J ordan.Deborah@epamail.epa.gov>
Date: 03/07/2011 09:27 PM
Subject: Re: Washington Power Plant
Thanks Rick..

Sent by EPA Wireless E-Mail Services
Rick Albright
----- Original Message -----
From: Rick Albright
Sent: 03/07/2011 04:08 PM PST
To: Carl Edlund
Cc: Thomas Diggs
Subject: Re: Washington Power Plant
There are two coal units at the 1300 MW facility; one will close in 2020, and the
other in 2025.
Rick Albright
Director, Office of Air, Waste & Toxics
EPA Region 10
(206) 553-1847
FAX (206)553-8509
albright.rick@epa.gov
Carl Edlund---03/07/2011 01:56:00 PM---
From: Carl Edlund/R6/USEPA/US
To: "Rick Albright" <Albright.Rick@epamail.epa.gov>
Cc: Thomas Diggs/R6/USEPA/US@EPA
Date: 03/07/2011 01:56 PM
Subject: Washington Power Plant
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
Lawrence Starfield---04/22/2011 02:42:23 PM---DELIBERATIVE PROCESS --
PRIVILEGED & CONFIDENTIAL I wanted to share two ideas broached by ODEQ's St
From: Lawrence Starfield/R6/USEPA/US
To: Carl Edlund/R6/USEPA/US@EPA, diggs.thomas@epa.gov, donaldson.guy@epa.gov, Suzanne
Murray/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US
Date: 04/22/2011 02:42 PM
Subject: Regional haze - Oklahoma CONFIDENTIAL
DELIBERATIVE PROCESS -- PRIVILEGED & CONFIDENTIAL
I wanted to share two ideas broached by ODEQ's Steve Thompson over
the last week on Regional haze.


FOIA Exemption (b)(5) - Deliberative Process Privilege



Thanks.
Larry
From: David McIntosh
To: Lawrence Starfield
Cc: Al Armendariz; J anet McCabe
Subject: Re: Letter to NMED on Regional Haze
Date: 04/20/2011 03:44 PM
Attachments: Sec Martin NM Regional Haze letter 2d ver 4 20 11.doc
Sec Martin NM Regional Haze letter 4 20 11.doc
Looks very good to me. Thanks much.
Lawrence Starfield---04/20/2011 04:40:15 PM---Here's a clean, easier to read
version: J anet and David, Attached is a revised letter to NMED conce
From: Lawrence Starfield/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA, David
McIntosh/DC/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA
Date: 04/20/2011 04:40 PM
Subject: Letter to NMED on Regional Haze
Here's a clean, easier to read version:
__________________
J anet and David,
Attached is a revised letter to NMED concerning their request for more
time on our Regional Haze FIP.
Please let me know if you have any additional comments or concerns.
I'll like to get this out today, if possible.
David, I am assuming we'd PDF the signed version to you, and you'd
share it with folks on the Hill.
Larry
Larry Starfield
Deputy Regional Administrator
EPA Region 6
Dallas, Texas
(214) 665-2125
From: Lawrence Starfield
To: Al Armendariz
Subject: blackberry friendly version of NM letter
Date: 04/20/2011 03:41 PM

Dear Secretary. Martin:







Sincerely,
Al Armendariz
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Lawrence Starfield
To: David McIntosh
Cc: Al Armendariz; J anet McCabe
Subject: Re: Response to NMED letter - For your Review
Date: 04/16/2011 06:20 PM
David,
Understood. We're in touch with Scott Fulton, have calls into the litigants for an
extension, and will do everything possible to wrap this up on Monday.
Thanks.
Larry
Re: Response to NMED letter - For your Review
Re: Response to NMED letter - For your Review
David
McIntosh
to: Lawrence Starfield
04/15/2011
01:13 PM
Cc: Al Armendariz, J anet McCabe
Thanks Larry
Lawrence Starfield---04/15/2011 02:08:29 PM---Thanks, J anet. I like that idea,
and we can re-order the points as you suggest.
From: Lawrence Starfield/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US
Cc: David McIntosh/DC/USEPA/US@EPA, Al Armendariz/R6/USEPA/US
Date: 04/15/2011 02:08 PM
Subject: Re: Response to NMED letter - For your Review
Thanks, J anet. I like that idea, and we can re-order the points as you
suggest.
Larry
J anet McCabe
----- Original Message -----
From: Janet McCabe
Sent: 04/14/2011 07:32 PM EDT
To: Lawrence Starfield
Cc: David McIntosh
Subject: Re: Response to NMED letter - For your Review
Thanks, Larry.
including David here to keep him in the loop....
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
Lawrence Starfield---04/14/2011 02:45:10 PM---J anet, We are close to finalizing
our response to NMED Secretary Martin's letter regarding our prop
From: Lawrence Starfield/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US
Date: 04/14/2011 02:45 PM
Subject: Response to NMED letter - For your Review
J anet,
We are close to finalizing our response to NMED Secretary Martin's
letter regarding our proposed Regional Haze FIP.
Please let me know if you have any concerns or suggested edits.
Thanks.
Larry
[attachment "NMED ltr response 4 13 11 v4.docx" deleted by Lawrence
Starfield/R6/USEPA/US]
From: Lawrence Starfield
To: Al Armendariz
Subject: Re: Response to NMED letter - For your Review
Date: 04/15/2011 01:57 PM
Will do

Larry
Re: Response to NMED letter - For your Review
Re: Response to NMED letter - For your Review
Al
Armendariz
to: David McIntosh
04/15/2011
01:20 PM
Cc: J anet McCabe, Lawrence Starfield, Scott Fulton, Suzanne Murray
Thanks David.
Larry: can you call Scott today,
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
David McIntosh---04/15/2011 02:13:58 PM---Thanks Larry.
From: David McIntosh/DC/USEPA/US
To: Lawrence Starfield/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, J anet McCabe/DC/USEPA/US@EPA
Date: 04/15/2011 02:13 PM
Subject: Re: Response to NMED letter - For your Review
Thanks Larry
Lawrence Starfield---04/15/2011 02:08:29 PM---Thanks, J anet. I like that idea,
and we can re-order the points as you suggest.
From: Lawrence Starfield/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US
Cc: David McIntosh/DC/USEPA/US@EPA, Al Armendariz/R6/USEPA/US
Date: 04/15/2011 02:08 PM
Subject: Re: Response to NMED letter - For your Review
Thanks, J anet. I like that idea, and we can re-order the points as you
suggest.
Larry
J anet McCabe
----- Original Message -----
From: Janet McCabe
Sent: 04/14/2011 07:32 PM EDT
To: Lawrence Starfield
Cc: David McIntosh
Subject: Re: Response to NMED letter - For your Review
Thanks, Larry. I didn't realize we had approached Wild Earth
including David here to keep him in the loop....
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
Lawrence Starfield---04/14/2011 02:45:10 PM---J anet, We are close to finalizing
our response to NMED Secretary Martin's letter regarding our prop
From: Lawrence Starfield/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US
Date: 04/14/2011 02:45 PM
Subject: Response to NMED letter - For your Review
J anet,
We are close to finalizing our response to NMED Secretary Martin's
letter regarding our proposed Regional Haze FIP. As promised, I
wanted to see if you had any comments on the draft.
Please let me know if you have any concerns or suggested edits.
Thanks.
Larry
[attachment "NMED ltr response 4 13 11 v4.docx" deleted by Lawrence
Starfield/R6/USEPA/US]
From: Al Armendariz
To: Suzanne Murray; Larry Starfield
Subject: Re: Response to NMED letter - For your Review
Date: 04/15/2011 01:27 PM
Not sure we have a couple of days.

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Suzanne Murray
----- Original Message -----
From: Suzanne Murray
Sent: 04/15/2011 02:25 PM EDT
To: Al Armendariz; David McIntosh
Cc: Janet McCabe; Lawrence Starfield; Scott Fulton
Subject: Re: Response to NMED letter - For your Review
Al,
I am not sure we need Scott just yet.
Suzanne
Suzanne Murray, Regional Counsel, R6
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 04/15/2011 01:20 PM CDT
To: David McIntosh
Cc: Janet McCabe; Lawrence Starfield; Scott Fulton; Suzanne
Murray
Subject: Re: Response to NMED letter - For your Review
Thanks David.
Larry: can you call Scott today,
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
David McIntosh---04/15/2011 02:13:58 PM---Thanks Larry.
From: David McIntosh/DC/USEPA/US
To: Lawrence Starfield/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, J anet McCabe/DC/USEPA/US@EPA
Date: 04/15/2011 02:13 PM
Subject: Re: Response to NMED letter - For your Review
Thanks Larry.
Lawrence Starfield---04/15/2011 02:08:29 PM---Thanks, J anet. I like that idea,
and we can re-order the points as you suggest.
From: Lawrence Starfield/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US
Cc: David McIntosh/DC/USEPA/US@EPA, Al Armendariz/R6/USEPA/US
Date: 04/15/2011 02:08 PM
Subject: Re: Response to NMED letter - For your Review
Thanks, J anet. I like that idea, and we can re-order the points as you
suggest.
Larry
J anet McCabe
----- Original Message -----
From: Janet McCabe
Sent: 04/14/2011 07:32 PM EDT
To: Lawrence Starfield
Cc: David McIntosh
Subject: Re: Response to NMED letter - For your Review
Thanks, Larry.
including David here to keep him in the loop....
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
Lawrence Starfield---04/14/2011 02:45:10 PM---J anet, We are close to finalizing
our response to NMED Secretary Martin's letter regarding our prop
From: Lawrence Starfield/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US
Date: 04/14/2011 02:45 PM
Subject: Response to NMED letter - For your Review
J anet,
We are close to finalizing our response to NMED Secretary Martin's
letter regarding our proposed Regional Haze FIP. As promised, I
wanted to see if you had any comments on the draft.
Please let me know if you have any concerns or suggested edits.
Thanks.
Larry
[attachment "NMED ltr response 4 13 11 v4.docx" deleted by Lawrence
Starfield/R6/USEPA/US]
From: Lawrence Starfield
To: Suzanne Smith
Cc: Al Armendariz; Carl Edlund; Carl Young; gray.david@epa.gov; Suzanne Murray; Thomas Diggs
Subject: Re: Revised draft response to NMED concerning their March 21 requests on the Regional Haze proposal (Control
R6-11-000-4516 Martin)
Date: 04/15/2011 09:58 AM
Importance: High
ATTORNEY CLIENT COMMUNICATION - PRIVILEGED AND CONFIDENTIAL
Suzanne,
Thanks for your email.




FOIA Exemption (b)(5) - Attorney-Client Privilege

Larry
Re: Revised draft response to NMED concerning their March 21 requests on the
Regional Haze proposal (Control R6-11-000-4516 ...
Re: Revised draft response to NMED concerning their March 21
requests on the Regional Haze proposal (Control R6-11-000-4516
Martin)
Suzanne
Smith
to: Lawrence Starfield
04/14/2011
02:02 PM
Cc: Al Armendariz, Carl Edlund, Carl Young, gray.david, Suzanne Murray, Thomas Diggs
ATTORNEY CLIENT COMMUNICATION



Suzanne J . Smith
Chief, Multimedia Counseling Branch
Office of Regional Counsel
214-665-8027
Re: Revised draft response to NMED concerning their March 21 requests on the
Regional Haze proposal (Control R6-11-000-4516 ...
Re: Revised draft response to NMED concerning their March 21
requests on the Regional Haze proposal (Control R6-11-000-4516
Martin)
Lawrence
Starfield
to: Carl Edlund
04/13/2011
09:38 PM
Cc: Al Armendariz, Carl Young, gray.david, Suzanne Murray, Suzanne Smith, Thomas Diggs
Carl,


Larry
Re: Revised draft response to NMED concerning their March 21 requests on the
Regional Haze proposal (Control R6-11-000-4516 ...
Re: Revised draft response to NMED concerning their March 21
requests on the Regional Haze proposal (Control R6-11-000-4516
Martin)
Carl
Edlund
to: Thomas Diggs, Al Armendariz, Carl Young,
Lawrence Starfield
04/13/2011
05:23 PM
Cc: Suzanne Murray, Suzanne Smith, gray.david
I couldn't help myself ..I tried my hand at making the letter even more
friendly ...here's my version
[attachment "Draft Response to Mar 21 NMED letter 4 13 11 v4.docx"
deleted by Lawrence Starfield/R6/USEPA/US]
Thomas Diggs---04/13/2011 02:48:15 PM---Larry: We discussed during today's
Air meeting the status of expediting a response to Secretary Mart
From: Thomas Diggs/R6/USEPA/US
To: Lawrence Starfield/R6/USEPA/US@EPA, Al Armendariz/R6/USEPA/US@EPA, Carl
Edlund/R6/USEPA/US@EPA
Cc: Carl Young/R6/USEPA/US@EPA
Date: 04/13/2011 02:48 PM
Subject: Re: Revised draft response to NMED concerning their March 21 requests on the Regional Haze
proposal (Control R6-11-000-4516 Martin)
Larry:
We discussed during today's Air meeting the status of expediting a
response to Secretary Martin, NMED. You also mentioned that J anet
McCabe would like to review our draft.
Attached is the current draft with edits that Al mentioned during our
meeting. also, attached is the incoming letter. My thanks to Carl
Young for his extra efforts to move this along quickly.
Tom
[attachment "Draft Response to Mar 21 NMED letter 4 13 11 v3.docx"
deleted by Carl Edlund/R6/USEPA/US] [attachment "NMED Sec Martin
Ltr Reg'l haze 3 21 11.pdf" deleted by Carl Edlund/R6/USEPA/US]
Thomas Diggs
Associate Director - Air
US EPA Region 6
214-665-3102
fax 214-665-7263
diggs.thomas@epa.gov
Carl Young---04/13/2011 02:27:42 PM---Hi Tom, Attached is the current draft
along with the incoming letter. I understand that J anet McCab
From: Carl Young/R6/USEPA/US
To: Thomas Diggs/R6/USEPA/US@EPA
Cc: Suzanne Smith/R6/USEPA/US@EPA, Lucinda Watson/R6/USEPA/US@EPA, Carrie
Paige/R6/USEPA/US@EPA, Cary Martindale/R6/USEPA/US@EPA
Date: 04/13/2011 02:27 PM
Subject: Revised draft response to NMED concerning their March 21 requests on the Regional Haze proposal
(Control R6-11-000-4516 Martin)
Hi Tom,
Attached is the current draft along with the incoming letter. I
understand that J anet McCabe would like to look at our draft response.
The current draft is also on the share directory.
Carl
Carl Young
EPA Region 6 Air Planning Section
214-665-6645
[attachment "Draft Response to Mar 21 NMED letter 4 13 11 v2.doc"
deleted by Thomas Diggs/R6/USEPA/US] [attachment "NMED Sec
Martin Ltr Reg'l haze 3 21 11.pdf" deleted by Thomas
Diggs/R6/USEPA/US]
From: J oe Kordzi
To: Carl Edlund
Cc: Al Armendariz; diggs thomas; Wk; David Gray; Guy Donaldson; J oyce Runyan; Lawrence Starfield; Margaret
Oldham; Suzanne Murray; Suzanne Murray
Subject: Re: Trip to PNM/SJ GS
Date: 04/13/2011 11:31 PM


Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
Carl Edlund---04/13/2011 09:38:22 PM---Agree...I just didn't have the team's
availability since they are in Oklahoma. Today Sent by EPA Wir
From: Carl Edlund/R6/USEPA/US
To: Lawrence Starfield/R6/USEPA/US@EPA
Cc: Al Armendariz/R6/USEPA/US@EPA, "diggs thomas" <diggs.thomas@epa.gov>, "Wk"
<edlund.carl@epa.gov>, "David Gray" <gray.david@epa.gov>, Guy Donaldson/R6/USEPA/US@EPA,
J oe Kordzi/R6/USEPA/US@EPA, J oyce Runyan/R6/USEPA/US@EPA, Margaret
Oldham/R6/USEPA/US@EPA, "Suzanne Murray" <murray.suzanne@epa.gov>, Suzanne
Murray/R6/USEPA/US@EPA
Date: 04/13/2011 09:38 PM
Subject: Re: Trip to PNM/SJ GS
Agree...I just didn't have the team's availability since they are in
Oklahoma. Today
Sent by EPA Wireless E-Mail Services
Lawrence Starfield
----- Original Message -----
From: Lawrence Starfield
Sent: 04/13/2011 05:37 PM CDT
To: Carl Edlund
Cc: Al Armendariz; diggs.thomas@epa.gov; "Carl Edlund"
<edlund.carl@epa.gov>; "David Gray" <gray.david@epa.gov>; Guy
Donaldson; Joe Kordzi; Joyce Runyan; Margaret Oldham; "Suzanne
Murray" <murray.suzanne@epa.gov>; Suzanne Murray
Subject: Re: Trip to PNM/SJGS
Carl,
Larry
Re: Trip to PNM/SJ GS
Re: Trip to PNM/ SJ GS
Carl
Edlund
to: Al Armendariz
04/13/2011
09:58 AM
Cc: "Carl Edlund", "David Gray", J oyce Runyan, Lawrence Starfield, "Suzanne Murray",
Suzanne Murray, J oe Kordzi, diggs.thomas, Guy Donaldson, Margaret Oldham
Good idea to do the visit to PSNM. Tom and I will need to be in Baton
Rouge re: NUCOR on Tuesday but others [e.g. J oe or Guy] need to see
the thing.
Al Armendariz---04/12/2011 09:10:43 PM---Probably not enough time to setup for
this Monday (Taos day). I thought you liked going to NM as muc
From: Al Armendariz/R6/USEPA/US
To: Suzanne Murray/R6/USEPA/US@EPA, "Carl Edlund" <edlund.carl@epa.gov>, "David Gray"
<gray.david@epa.gov>, Lawrence Starfield/R6/USEPA/US@EPA, "Suzanne Murray"
<murray.suzanne@epa.gov>
Cc: J oyce Runyan/R6/USEPA/US@EPA
Date: 04/12/2011 09:10 PM
Subject: Re: Trip to PNM/SJ GS
Probably not enough time to setup for this Monday (Taos day).
I thought you liked going to NM as much as possible...
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Suzanne Murray
----- Original Message -----
From: Suzanne Murray
Sent: 04/12/2011 10:08 PM EDT
To: Al Armendariz; "Carl Edlund" <edlund.carl@epa.gov>;
"David Gray" <gray.david@epa.gov>; Lawrence Starfield; "Suzanne
Murray" <murray.suzanne@epa.gov>
Cc: Joyce Runyan
Subject: Re: Trip to PNM/SJGS
Can you combine with the Taos trip?
Suzanne Murray, Regional Counsel, R6
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 04/12/2011 10:04 PM EDT
To: "Carl Edlund" <edlund.carl@epa.gov>; "David Gray"
<gray.david@epa.gov>; Lawrence Starfield; "Suzanne Murray"
<murray.suzanne@epa.gov>
Cc: Joyce Runyan
Subject: Trip to PNM/SJGS
David,
Carl and I talked this afternoon,
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
From: David Gray
To: Lawrence Starfield; Carl Edlund
Cc: Al Armendariz; diggs thomas; Carl Edlund; David Gray; Guy Donaldson; J oe Kordzi; J oyce Runyan; Margaret
Oldham; Suzanne Murray; Suzanne Murray
Subject: Re: Trip to PNM/SJ GS
Date: 04/13/2011 05:48 PM
Once we have details confirmed, I will notify the delegation.
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: Lawrence Starfield
Sent: 04/13/2011 05:37 PM CDT
To: Carl Edlund
Cc: Al Armendariz; diggs.thomas@epa.gov; "Carl Edlund" <edlund.carl@epa.gov>; "David Gray"
<gray.david@epa.gov>; Guy Donaldson; J oe Kordzi; J oyce Runyan; Margaret Oldham; "Suzanne
Murray" <murray.suzanne@epa.gov>; Suzanne Murray
Subject: Re: Trip to PNM/SJ GS
Carl,
Larry
Re: Trip to PNM/SJGS Link
Carl Edlund to: Al Armendariz
04/13/2011 09:58 AM
Cc:
"Carl Edlund", "David Gray", Joyce Runyan, Lawrence Starfield, "Suzanne Murray", Suzanne Murray, Joe Kordzi,
diggs.thomas, Guy Donaldson, Margaret Oldham
Good idea to do the visit to PSNM. Tom and I will need to be in Baton Rouge re:
NUCOR on Tuesday but others [e.g. Joe or Guy] need to see the thing.
From: Al Armendariz/R6/USEPA/US
To: Suzanne Murray/R6/USEPA/US@EPA, "Carl Edlund" <edlund.carl@epa.gov>, "David Gray" <gray.david@epa.gov>,
Lawrence Starfield/R6/USEPA/US@EPA, "Suzanne Murray" <murray.suzanne@epa.gov>
Cc: Joyce Runyan/R6/USEPA/US@EPA
Date: 04/12/2011 09:10 PM
Subject: Re: Trip to PNM/SJGS
Probably not enough time to setup for this Monday (Taos day).
I thought you liked going to NM as much as possible...
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
----- Original Message -----
From: Suzanne Murray
Sent: 04/12/2011 10:08 PM EDT
To: Al Armendariz; "Carl Edlund" <edlund.carl@epa.gov>; "David Gray" <gray.david@epa.gov>;
Lawrence Starfield; "Suzanne Murray" <murray.suzanne@epa.gov>
Cc: Joyce Runyan
Subject: Re: Trip to PNM/SJGS
Can you combine with the Taos trip?
Suzanne Murray, Regional Counsel, R6
----- Original Message -----
From: Al Armendariz
Sent: 04/12/2011 10:04 PM EDT
To: "Carl Edlund" <edlund.carl@epa.gov>; "David Gray" <gray.david@epa.gov>; Lawrence Starfield;
"Suzanne Murray" <murray.suzanne@epa.gov>
Cc: Joyce Runyan
Subject: Trip to PNM/SJGS
David,
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
From: David Gray
To: Al Armendariz; Carl Edlund; David Gray; Lawrence Starfield; Suzanne Murray
Cc: J oyce Runyan
Subject: Re: Trip to PNM/SJ GS
Date: 04/13/2011 08:25 AM
Will do. Congress should recess starting next week for 2 weeks.
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 04/12/2011 10:04 PM EDT
To: "Carl Edlund" <edlund.carl@epa.gov>; "David Gray"
<gray.david@epa.gov>; Lawrence Starfield; "Suzanne Murray"
<murray.suzanne@epa.gov>
Cc: Joyce Runyan
Subject: Trip to PNM/SJGS
David,
Carl and I talked this afternoon, and he suggested, and I now agree,
that I myself should go up to SJ GS sometime soon.
David and Carl:
David:
Suzanne:
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
FOIA Exemption (b)(5) - Deliberative Process Privilege
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
From: Suzanne Murray
To: Al Armendariz
Subject: Re: Trip to PNM/SJ GS
Date: 04/12/2011 09:13 PM
I live to serve
Suzanne Murray, Regional Counsel, R6
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 04/12/2011 10:10 PM EDT
To: Suzanne Murray; "Carl Edlund" <edlund.carl@epa.gov>;
"David Gray" <gray.david@epa.gov>; Lawrence Starfield; "Suzanne
Murray" <murray.suzanne@epa.gov>
Cc: Joyce Runyan
Subject: Re: Trip to PNM/SJGS
Probably not enough time to setup for this Monday (Taos day).
I thought you liked going to NM as much as possible...
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Suzanne Murray
----- Original Message -----
From: Suzanne Murray
Sent: 04/12/2011 10:08 PM EDT
To: Al Armendariz; "Carl Edlund" <edlund.carl@epa.gov>;
"David Gray" <gray.david@epa.gov>; Lawrence Starfield; "Suzanne
Murray" <murray.suzanne@epa.gov>
Cc: Joyce Runyan
Subject: Re: Trip to PNM/SJGS
Can you combine with the Taos trip?
Suzanne Murray, Regional Counsel, R6
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 04/12/2011 10:04 PM EDT
To: "Carl Edlund" <edlund.carl@epa.gov>; "David Gray"
<gray.david@epa.gov>; Lawrence Starfield; "Suzanne Murray"
<murray.suzanne@epa.gov>
Cc: Joyce Runyan
Subject: Trip to PNM/SJGS
David,
Carl and I talked this afternoon, and he suggested, and I now agree,
that I myself should go up to SJ GS sometime soon.
David and Carl:
David:
Suzanne:
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
From: J oe Kordzi
To: Al Armendariz; Lawrence Starfield; Carl Edlund; Thomas Diggs; Guy Donaldson; Rob Lawrence
Subject: Proposal on coal to liquids for the San J uan Generating Station
Date: 03/25/2011 11:22 AM
Attachments: EPALetter110323.doc
We received this as a comment to our NM proposal that included requiring SCR on
the SJ GS. It is a short report that advocates replacing the coal fired boilers at the
SJ GS with a 50,000 barrel/day coal to liquids plant that captures waste heat to
produce 1200 MW of electricity. NOx, SO2, etc. are very low and the captured CO2
would be run into an existing CO2 pipeline that is nearby and supplied the West TX
oil fields. I thought you would be interested in reading it.
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
----- Forwarded by J oe Kordzi/R6/USEPA/US on 03/24/2011 08:43 AM -----
From: Bill Rollins <brollins@noveledge.com>
To: Guy Donaldson/R6/USEPA/US@EPA
Cc: J oe Kordzi/R6/USEPA/US@EPA, J erry Lynch <lyncoinc@aol.com>
Date: 03/23/2011 03:06 PM
Subject: Comments for EPA Docket No. EPA-R06-OAR-2010-0846
Mr. Donaldson,
Attached please find a Word Document with our comments regarding the San Juan
Generating Facility, and EPA Docket No. EPA-R06-OAR-2010-0846.
We believe that the option that is described in this attached document describes the BART
for this coal-fueled facility, and represents a solution that is politically correct, demonstrates
the utmost in environmental stewardship, yet still provides exemplary economics.
We apologize for the length of this response, but felt it necessary to provide background
information and supporting documentation.
Thank you for this opportunity to present our solutions to this issue.
Regards,
Bill Rollins, PE
NovelEdge Technologies, LLC
From: Carl Edlund
To: Al Armendariz; Layla Mansuri; David Gray
Cc: Lawrence Starfield
Subject: Re: Request for signature - Rep. Heinrich Response re: Supporting extension on NM FIP
Date: 03/23/2011 07:54 PM
Thanks all...the system we set up to be responsive to elected officials
does not include an assessment of who/when by program offices (I
frankly couldn't handle that with current staffing) SO...thanks Layla for
catching this, it's a real value for us all.
Sent by EPA Wireless E-Mail Services
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 03/23/2011 08:28 PM EDT
To: Layla Mansuri; Carl Edlund; David Gray
Subject: Re: Request for signature - Rep. Heinrich Response
re: Supporting extension on NM FIP
I would prefer to sign in person. And given the general public
awareness of the deadline extension, I believe holding the formal
written reply to the congressman's office until Friday will be fine.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Layla Mansuri
----- Original Message -----
From: Layla Mansuri
Sent: 03/23/2011 10:49 AM CDT
To: Al Armendariz
Subject: Request for signature - Rep. Heinrich Response re:
Supporting extension on NM FIP
Al,
A control came to our office today that PD wants to get out before
Friday regarding the comment extension on the NM FIP. I thought
you might like to review and put an e-signature on rather than sending
down to Lynda for signature.
I've attached the incoming controlled letter from Rep. Heinrich and the
proposed response. I don't think there is anything that rises to the
level of needing revisions.
[attachment "R6-11-000-3777 Heinrich FIP Determining BART at San
J uan Generating Station.pdf" deleted by Al Armendariz/R6/USEPA/US]
[attachment "R6-11-000-3777 Heinrich FIP Determining BART at San
J uan Generating Station.pdf.doc" deleted by Al
Armendariz/R6/USEPA/US]
I've also attached the earlier response on this to Bingaman, Udall and
Lujan - the two responses are consistent.
[attachment "R6-11-000-2549 Bingaman-Udall-Lujan Draft FIP for San
J uan Generating Station Final Response.pdf" deleted by Al
Armendariz/R6/USEPA/US]
OEJ TA has notified the Navajo Nation of the extension to April 4.
----- Forwarded by Layla Mansuri/R6/USEPA/US on 03/23/2011 10:39 AM -----
From: Cary Martindale/R6/USEPA/US
To: Layla Mansuri/R6/USEPA/US@EPA
Date: 03/23/2011 10:37 AM
Subject: Re: Bingaman-Udall-Lujan Letter
Hi Layla,
Here is the incoming letter for Congressman Heinrich, and the
response.
Thanks and let me know if you need anything else.
Cary Martindale
Public Affairs Specialist
U.S. EPA, 6XA
martindale.cary@epa.gov
214-665-8147
[attachment "R6-11-000-3777 Heinrich FIP Determining BART at San
J uan Generating Station.pdf" deleted by Al Armendariz/R6/USEPA/US]
[attachment "R6-11-000-3777 Heinrich FIP Determining BART at San
J uan Generating Station.pdf.doc" deleted by Al
Armendariz/R6/USEPA/US]
Layla Mansuri---03/23/2011 10:32:43 AM---Thanks, Cary. In addition to a quick
update on Tribal notification, can you send me an email with th
From: Layla Mansuri/R6/USEPA/US
To: Cary Martindale/R6/USEPA/US@EPA
Date: 03/23/2011 10:32 AM
Subject: Re: Bingaman-Udall-Lujan Letter
Thanks, Cary.
In addition to a quick update on Tribal notification, can you send me
an email with the incoming Heinrich letter and our response. I'll
forward this to Al for approval and request an electronic signature on
it.
Thanks,
Layla
Cary Martindale---03/23/2011 10:27:24 AM---Hi Layla, Here is the letter from
March 3, 2011. Let me know if you need anything else.
From: Cary Martindale/R6/USEPA/US
To: Layla Mansuri/R6/USEPA/US@EPA
Date: 03/23/2011 10:27 AM
Subject: Bingaman-Udall-Lujan Letter
Hi Layla,
Here is the letter from March 3, 2011. Let me know if you need
anything else.
Thanks,
Cary Martindale
Public Affairs Specialist
U.S. EPA, 6XA
martindale.cary@epa.gov
214-665-8147
[attachment "R6-11-000-2549 Bingaman-Udall-Lujan Draft FIP for San
J uan Generating Station Final Response.pdf" deleted by Layla
Mansuri/R6/USEPA/US]
From: Al Armendariz
To: Layla Mansuri
Subject: Re: Request for signature - Rep. Heinrich Response re: Supporting extension on NM FIP
Date: 03/23/2011 02:40 PM
Can this wait until Friday?

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Layla Mansuri
----- Original Message -----
From: Layla Mansuri
Sent: 03/23/2011 02:33 PM CDT
To: Al Armendariz
Subject: Re: Request for signature - Rep. Heinrich Response re:
Supporting extension on NM FIP
And - can we get an e-signature for this?
The Honorable Martin Heinrich
House of Representatives
Washington, D.C. 20515

Dear Congressman Heinrich:







FOIA Exemption (b)(5) - Deliberative Process Privilege


Layla Mansuri---03/23/2011 10:49:18 AM---Al, A control came to our office
today that PD wants to get out before Friday regarding the commen
From: Layla Mansuri/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA
Date: 03/23/2011 10:49 AM
Subject: Request for signature - Rep. Heinrich Response re: Supporting extension on NM FIP
Al,
A control came to our office today that PD wants to get out before
Friday regarding the comment extension on the NM FIP. I thought
you might like to review and put an e-signature on rather than sending
down to Lynda for signature.
I've attached the incoming controlled letter from Rep. Heinrich and the
proposed response. I don't think there is anything that rises to the
level of needing revisions.
[attachment "R6-11-000-3777 Heinrich FIP Determining BART at San J uan
Generating Station.pdf" deleted by Al Armendariz/R6/USEPA/US]
[attachment "R6-11-000-3777 Heinrich FIP Determining BART at San J uan
Generating Station.pdf.doc" deleted by Al Armendariz/R6/USEPA/US]
I've also attached the earlier response on this to Bingaman, Udall and
Lujan - the two responses are consistent.
[attachment "R6-11-000-2549 Bingaman-Udall-Lujan Draft FIP for San J uan
Generating Station Final Response.pdf" deleted by Al Armendariz/R6/USEPA/US]
OEJ TA has notified the Navajo Nation of the extension to April 4.
----- Forwarded by Layla Mansuri/R6/USEPA/US on 03/23/2011 10:39 AM -----
From: Cary Martindale/R6/USEPA/US
To: Layla Mansuri/R6/USEPA/US@EPA
Date: 03/23/2011 10:37 AM
Subject: Re: Bingaman-Udall-Lujan Letter
Hi Layla,
Here is the incoming letter for Congressman Heinrich, and the
response.
Thanks and let me know if you need anything else.
Cary Martindale
Public Affairs Specialist
U.S. EPA, 6XA
martindale.cary@epa.gov
214-665-8147
[attachment "R6-11-000-3777 Heinrich FIP Determining BART at San J uan
Generating Station.pdf" deleted by Al Armendariz/R6/USEPA/US]
[attachment "R6-11-000-3777 Heinrich FIP Determining BART at San J uan
Generating Station.pdf.doc" deleted by Al Armendariz/R6/USEPA/US]
Layla Mansuri---03/23/2011 10:32:43 AM---Thanks, Cary. In addition to a quick
update on Tribal notification, can you send me an email with th
From: Layla Mansuri/R6/USEPA/US
To: Cary Martindale/R6/USEPA/US@EPA
Date: 03/23/2011 10:32 AM
Subject: Re: Bingaman-Udall-Lujan Letter
Thanks, Cary.
In addition to a quick update on Tribal notification, can you send me
an email with the incoming Heinrich letter and our response. I'll
forward this to Al for approval and request an electronic signature on
it.
Thanks,
Layla
Cary Martindale---03/23/2011 10:27:24 AM---Hi Layla, Here is the letter from
March 3, 2011. Let me know if you need anything else.
From: Cary Martindale/R6/USEPA/US
To: Layla Mansuri/R6/USEPA/US@EPA
Date: 03/23/2011 10:27 AM
Subject: Bingaman-Udall-Lujan Letter
Hi Layla,
Here is the letter from March 3, 2011. Let me know if you need
anything else.
Thanks,
Cary Martindale
Public Affairs Specialist
U.S. EPA, 6XA
martindale.cary@epa.gov
214-665-8147
[attachment "R6-11-000-2549 Bingaman-Udall-Lujan Draft FIP for San
J uan Generating Station Final Response.pdf" deleted by Layla
Mansuri/R6/USEPA/US]
From: Layla Mansuri
To: Al Armendariz
Subject: Re: Request for signature - Rep. Heinrich Response re: Supporting extension on NM FIP
Date: 03/23/2011 02:33 PM
Attachments: R6-11-000-3777 Heinrich FIP Determining BART at San J uan Generating Station.pdf
R6-11-000-3777 Heinrich FIP Determining BART at San J uan Generating Station.pdf.doc
R6-11-000-2549 Bingaman-Udall-Lujan Draft FIP for San J uan Generating Station Final Response.pdf
R6-11-000-3777 Heinrich FIP Determining BART at San J uan Generating Station.pdf
R6-11-000-3777 Heinrich FIP Determining BART at San J uan Generating Station.pdf.doc
And - can we get an e-signature for this?
The Honorable Martin Heinrich
House of Representatives
Washington, D.C. 20515

Dear Congressman Heinrich:









Layla Mansuri---03/23/2011 10:49:18 AM---Al, A control came to our office
today that PD wants to get out before Friday regarding the commen
From: Layla Mansuri/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA
Date: 03/23/2011 10:49 AM
Subject: Request for signature - Rep. Heinrich Response re: Supporting extension on NM FIP
Al,
A control came to our office today that PD wants to get out before
Friday regarding the comment extension on the NM FIP. I thought
FOIA Exemption (b)(5) - Deliberative Process Privilege
you might like to review and put an e-signature on rather than sending
down to Lynda for signature.
I've attached the incoming controlled letter from Rep. Heinrich and the
proposed response. I don't think there is anything that rises to the
level of needing revisions.
I've also attached the earlier response on this to Bingaman, Udall and
Lujan - the two responses are consistent.
OEJ TA has notified the Navajo Nation of the extension to April 4.
----- Forwarded by Layla Mansuri/R6/USEPA/US on 03/23/2011 10:39 AM -----
From: Cary Martindale/R6/USEPA/US
To: Layla Mansuri/R6/USEPA/US@EPA
Date: 03/23/2011 10:37 AM
Subject: Re: Bingaman-Udall-Lujan Letter
Hi Layla,
Here is the incoming letter for Congressman Heinrich, and the response.
Thanks and let me know if you need anything else.
Cary Martindale
Public Affairs Specialist
U.S. EPA, 6XA
martindale.cary@epa.gov
214-665-8147
Layla Mansuri---03/23/2011 10:32:43 AM---Thanks, Cary. In addition to a quick
update on Tribal notification, can you send me an email with th
From: Layla Mansuri/R6/USEPA/US
To: Cary Martindale/R6/USEPA/US@EPA
Date: 03/23/2011 10:32 AM
Subject: Re: Bingaman-Udall-Lujan Letter
Thanks, Cary.
In addition to a quick update on Tribal notification, can you send me an email with
the incoming Heinrich letter and our response. I'll forward this to Al for approval
and request an electronic signature on it.
Thanks,
Layla
Cary Martindale---03/23/2011 10:27:24 AM---Hi Layla, Here is the letter from
March 3, 2011. Let me know if you need anything else.
From: Cary Martindale/R6/USEPA/US
To: Layla Mansuri/R6/USEPA/US@EPA
Date: 03/23/2011 10:27 AM
Subject: Bingaman-Udall-Lujan Letter
Hi Layla,
Here is the letter from March 3, 2011. Let me know if you need anything else.
Thanks,
Cary Martindale
Public Affairs Specialist
U.S. EPA, 6XA
martindale.cary@epa.gov
214-665-8147
[attachment "R6-11-000-2549 Bingaman-Udall-Lujan Draft FIP for San J uan
Generating Station Final Response.pdf" deleted by Layla Mansuri/R6/USEPA/US]
From: Carl Edlund
To: Lawrence Starfield
Cc: Al Armendariz; Suzanne Murray
Subject: Re: Fw: Regional Haze pertaining to San J uan Generation Station
Date: 03/22/2011 09:39 AM
Sure ..ORC was in the call
From: Lawrence Starfield/R6/USEPA/US
To: Carl Edlund/R6/USEPA/US@EPA
Cc: "Al Armendariz" <armendariz.al@epa.gov>, Suzanne Murray/R6/USEPA/US@EPA
Date: 03/21/2011 03:48 PM
Subject: Re: Fw: Regional Haze pertaining to San Juan Generation Station
Carl,
If they are asking for an extension of the final FIP date, that would have to be negotiated with the
litigants at WildEarth Guardians. So you may want to include on the call someone from ORC or OGC
who is familiar with the litigation.
Larry
Fw: Regional Haze pertaining to San Juan Generation Station
Carl Edlund to: Lawrence Starfield, Al Armendariz
03/21/2011 09:12 AM
FYI...I thought that you were cc'ed on this note.
Sent by EPA Wireless E-Mail Services
----- Original Message -----
From: Janet McCabe
Sent: 03/17/2011 07:29 PM EDT
To: Addie Johnson; Cynthia Browne
Cc: Carl Edlund; Scott Mathias; Rhea Jones; Steve Page; Joseph Goffman
Subject: Fw: Regional Haze pertaining to San Juan Generation Station
It looks from my calendar like this meeting is just between me and Jeannette, so this note is to make
sure we have Region 6 (Carl Edlund at least) and OAQPS (Rhea Jones, Scott Mathias, Todd Hawes--
whatever combination they want) also scheduled in.
I've learned (Joe Goffman knows Jeanette Pablo and spoke with her today) that there will be people
from the New Mexico agency in the meeting as well and that the purpose of the meeting is to see
whether we can extend the timeline for a final FIP to give them time to submit a SIP. I don't know
more about it than that---perhaps Carl does---but I wanted to make you guys aware. Carl--is this
something you are aware of, and have you guys discussed whether there is any possibility that we
would move in this direction?
She has also, on behalf of the state, requested a meeting with Gina for 3/29. Joe told her not to be
surprised if Gina waited to see what comes out of our discussion monday before she reponds to a
meeting request.
Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
----- Forwarded by Janet McCabe/DC/USEPA/US on 03/17/2011 07:22 PM -----
Regional Haze pertaining to San Juan Generation Station
Mon 03/21/2011 5:00 PM - 6:00 PM
Chair: Janet McCabe/DC/USEPA/US
Sent By: Addie Johnson/DC/USEPA/US
No Location Information
Required: jeanette.pablo@pnmresources.com
From: Suzanne Smith
To: Guy Donaldson; Carl Edlund
Cc: Al Armendariz; J oe Kordzi; Lawrence Starfield; Suzanne Murray; Robinson J eff; Thomas Diggs; Agustin Carbo-Lugo
Subject: Re: Fw: Regional Haze pertaining to San J uan Generation Station
Date: 03/18/2011 09:41 AM
ORC is in
Guy Donaldson
----- Original Message -----
From: Guy Donaldson
Sent: 03/17/2011 08:37 PM CDT
To: Carl Edlund
Cc: "Al Armendariz" <armendariz.al@epa.gov>; Joe Kordzi; Lawrence Starfield; "Suzanne Murray"
<murray.suzanne@epa.gov>; "Robinson Jeff" <robinson.jeffrey@epa.gov>; Suzanne Smith; Thomas Diggs
Subject: Re: Fw: Regional Haze pertaining to San Juan Generation Station
Thanks J oe

Carl Edlund---03/17/2011 08:22:29 PM---Thanks J oe. Sent by EPA Wireless E-Mail Services
From: Carl Edlund/R6/USEPA/US
To: J oe Kordzi/R6/USEPA/US@EPA
Cc: "Al Armendariz" <armendariz al@epa.gov>, Guy Donaldson/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, "Suzanne Murray"
<murray suzanne@epa gov>, "Robinson J eff" <robinson.jeffrey@epa.gov>, Suzanne Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA
Date: 03/17/2011 08:22 PM
Subject: Re: Fw: Regional Haze pertaining to San J uan Generation Station
Thanks J oe.
Sent by EPA Wireless E-Mail Services
J oe Kordzi
----- Original Message -----
From: Joe Kordzi
Sent: 03/17/2011 08:21 PM CDT
To: Carl Edlund
Cc: "Al Armendariz" <armendariz.al@epa.gov>; Guy Donaldson; Lawrence Starfield; "Suzanne Murray"
<murray.suzanne@epa.gov>; "Robinson Jeff" <robinson.jeffrey@epa.gov>; Suzanne Smith; Thomas Diggs
Subject: Re: Fw: Regional Haze pertaining to San Juan Generation Station
Don't know about Guy, but I'll be there. Writing up a fact sheet now that I'll send out later this evening.
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
Carl Edlund---03/17/2011 08:17:02 PM---We can't do this without Tom/Guy, J oe and ORC Sent by EPA Wireless E-Mail
Services
From: Carl Edlund/R6/USEPA/US
To: Thomas Diggs/R6/USEPA/US@EPA, "Robinson J eff" <robinson.jeffrey@epa.gov>, "Suzanne Murray" <murray.suzanne@epa.gov>, "Suzanne Smith"
<Smith.Suzanne@epamail.epa.gov>, "J oe Kordzi" <Kordzi.J oe@epamail.epa gov>, "Guy Donaldson" <Donaldson.Guy@epamail.epa.gov>
Cc: Lawrence Starfield/R6/USEPA/US@EPA, "Al Armendariz" <armendariz.al@epa gov>
Date: 03/17/2011 08:17 PM
Subject: Fw: Regional Haze pertaining to San J uan Generation Station
We can't do this without Tom/Guy, J oe and ORC
Sent by EPA Wireless E-Mail Services
J anet McCabe
----- Original Message -----
From: Janet McCabe
Sent: 03/17/2011 07:29 PM EDT
To: Addie Johnson; Cynthia Browne
Cc: Carl Edlund; Scott Mathias; Rhea Jones; Steve Page; Joseph Goffman
FOIA Exemption (b)(5) - Deliberative Process Privilege
Subject: Fw: Regional Haze pertaining to San Juan Generation Station
It looks from my calendar like this meeting is just between me and J eannette, so this note is to make sure we have
Region 6 (Carl Edlund at least) and OAQPS (Rhea J ones, Scott Mathias, Todd Hawes--whatever combination they
want) also scheduled in.
I've learned (J oe Goffman knows J eanette Pablo and spoke with her today) that there will be people from the New
Mexico agency in the meeting as well and that the purpose of the meeting is to see whether we can extend the
timeline for a final FIP to give them time to submit a SIP. I don't know more about it than that---perhaps Carl
does---but I wanted to make you guys aware. Carl--is this something you are aware of, and have you guys
discussed whether there is any possibility that we would move in this direction?
She has also, on behalf of the state, requested a meeting with Gina for 3/29. J oe told her not to be surprised if
Gina waited to see what comes out of our discussion monday before she reponds to a meeting request.
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
----- Forwarded by J anet McCabe/DC/USEPA/US on 03/17/2011 07:22 PM -----
Regional Haze pertaining to San Juan Generation Station
Mon
03/21/2011 5:00
PM - 6:00 PM
/P86AAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAUAAAAAAAAAAQAAAAAAAAAAAAAAAAAA
AA==
Chair: Janet
McCabe/DC/USEPA/US
Sent By: Addie
Johnson/DC/USEPA/US
/P86AAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAEAAAACAAAAAQAAAAAAAAAAAAAAAAAA AA==
jeanette pablo@pnmresources com
From: J anet McCabe
To: Al Armendariz
Subject: Re: Request for Conference Call Monday
Date: 03/21/2011 10:30 PM


I guess they're having another, similar meeting with Larry tomorrow. We'll see what
comes out of that....
Janet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
-----Al Armendariz/R6/USEPA/US wrote: -----
To: Janet McCabe/DC/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA
From: Al Armendariz/R6/USEPA/US
Date: 03/21/2011 12:30PM
Cc: Addie Johnson/DC/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, David
Gray/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Joe
Kordzi/R6/USEPA/US@EPA, Joseph Goffman/DC/USEPA/US@EPA, Lawrence
Starfield/R6/USEPA/US@EPA, mcintosh.david@epa.gov, Rhea
Jones/RTP/USEPA/US@EPA, Scott Mathias/RTP/USEPA/US@EPA, Steve
Page/RTP/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Todd Hawes/RTP/USEPA/US@EPA
Subject: Re: Request for Conference Call Monday
Hi Janet,
As you know, NM (like all other states) are well late on the original deadline to get SIPs
in and approved.
NM is a state where we were sued by WEG and which has a court-settlement deadline to
get a SIP or FIP in place.
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
Some quick thoughts. I know Carl and Tom will be more thorough.
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Janet McCabe---03/16/2011 09:28:20 PM---Great..Thanks Al and Carl.
From:
Janet McCabe/DC/USEPA/US
To:
Carl Edlund/R6/USEPA/US@EPA, Joseph Goffman/DC/USEPA/US@EPA,
Addie Johnson/DC/USEPA/US@EPA, Rhea Jones/RTP/USEPA/US@EPA,
Scott Mathias/RTP/USEPA/US@EPA, Steve Page/RTP/USEPA/US@EPA,
Todd Hawes/RTP/USEPA/US@EPA
Cc:
Al Armendariz/R6/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA,
Lawrence Starfield/R6/USEPA/US@EPA, Suzanne
Smith/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Joe Kordzi/R6/USEPA/US@EPA,
mcintosh.david@epa.gov
Date:
03/16/2011 09:28 PM
Subject:
Re: Request for Conference Call Monday
Great..Thanks Al and Carl.

We don't have the time set yet--Addie, can you please work that out with Jeanette
Pablo (in the note below) and the R6 and OAQPS folks to get a time set for the call on
monday? Thanks.
Janet McCabe
FOIA Exemption (b)(5) - Deliberative Process Privilege
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
-----Carl Edlund/R6/USEPA/US wrote: -----
To: Al Armendariz/R6/USEPA/US@EPA, Janet McCabe/DC/USEPA/US@EPA, "David
McIntosh" <mcintosh.david@epa.gov>
From: Carl Edlund/R6/USEPA/US
Date: 03/16/2011 09:19PM
Cc: Lawrence Starfield/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, David
Gray/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA, "Guy Donaldson"
<Donaldson.Guy@epamail.epa.gov>, "Joe Kordzi" <Kordzi.Joe@epamail.epa.gov>
Subject: Re: Request for Conference Call Monday
Sure...we'd be happy to have the call..I didn't see a time or a number. Let us know; we'll be
ready.
Sent by EPA Wireless E-Mail Services
----- Original Message -----
From: Al Armendariz
Sent: 03/16/2011 08:10 PM EDT
To: Janet McCabe; "David McIntosh" <mcintosh.david@epa.gov>
Cc: Lawrence Starfield; Carl Edlund; Thomas Diggs; David Gray; Suzanne Smith
Subject: Re: Request for Conference Call Monday
Hi Janet,
Yes and yes. We can have R6 staff on the call. I'll leave it up to Carl and Tom to decide the
appropriate staff.
And we can send up appropriate background.
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
----- Original Message -----
From: Janet McCabe
Sent: 03/16/2011 05:48 PM EDT
To: "Al Armendariz" <armendariz.al@epa.gov>; Lawrence Starfield; Joseph Goffman; "Steve Page"
<page.steve@epa.gov>; Addie Johnson
Cc: Scott Mathias; Rhea Jones; Todd Hawes; David McIntosh
Subject: Fw: Request for Conference Call Monday
Al, Larry, Steve--
We've received the request below for a meeting on the San Juan plant. We of course would
include whoever from Region 6 would want to join us and oaqps as well. This is a meeting where
we would be in listening mode of course.
Can you let us know who you'd like to have participate and if you have a preference for time
FOIA Exemption (b)(5) - Deliberative Process Privilege
and we'll set it up.
And if you could send around whatever background materials you have, that would be helpful.
David--just so you know we're following up...
----- Original Message -----
From: Joseph Goffman
Sent: 03/16/2011 05:09 PM EDT
To: "Pablo, Jeanette" <jeanette.pablo@pnmresources.com>; Janet McCabe
Subject: Re: Request for Conference Call Monday
Hi, Jeanette. Thanks very much for the outreach. Janet and I will put our heads together and do
our best to organized a call on Monday. Back to you shortly. Thanks, again.
----- Original Message -----
From: "Pablo, Jeanette" [jeanette.pablo@pnmresources.com]
Sent: 03/16/2011 04:03 PM AST
To: Joseph Goffman
Subject: Request for Conference Call Monday
Hi Joe
This email is a follow up to my voicemail. I apologize for the short notice but have been
asked to request a conference call with you and Janet McCabe for Monday, March 21 preferably at
either 11 am or 5 pm EST for about an hour. The purpose of the call is to discuss the BART
determination for the San Juan Generating Station under Regional Haze and the State SIP and
process.
I look forward to speaking with you.
Jeanette
From: Thomas Diggs
To: J anet McCabe; J oseph Goffman; Steve Page
Cc: Lawrence Starfield; Al Armendariz; Scott Mathias; Rhea J ones; Todd Hawes; David McIntosh; Guy Donaldson;
Carl Edlund; Addie J ohnson; J oe Kordzi
Subject: Fw: Request for Conference Call Monday
Date: 03/18/2011 01:35 PM
Attachments: McCabe NM briefing 3-17-11.docx
Resending since I did not include J oe Kordzi on the cc list. Please forward to anyone
else as you see appropriate.
Tom
----- Forwarded by Thomas Diggs/R6/USEPA/US on 03/18/2011 01:31 PM -----
From: Thomas Diggs/R6/USEPA/US
To: J anet McCabe/DC/USEPA/US@EPA, J oseph Goffman/DC/USEPA/US@EPA, Steve
Page/RTP/USEPA/US@EPA
Cc: Lawrence Starfield/R6/USEPA/US@EPA, Al Armendariz/R6/USEPA/US@EPA, Scott
Mathias/RTP/USEPA/US@EPA, Rhea J ones/RTP/USEPA/US@EPA, Todd Hawes/RTP/USEPA/US@EPA,
David McIntosh/DC/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Carl
Edlund/R6/USEPA/US@EPA, Addie J ohnson/DC/USEPA/US@EPA
Date: 03/18/2011 01:14 PM
Subject: Re: Fw: Request for Conference Call Monday
As requested, attached is the fact sheet on the New Mexico Transport and Regional
Haze FIP proposal for the San J uan Generating Station as background for the
upcoming meeting with Public Service of New Mexico. Thanks especially to J oe
Kordzi, our staff lead, for developing this material.
Thanks,
Tom
Thomas Diggs
Associate Director - Air
US EPA Region 6
214-665-3102
fax 214-665-7263
diggs.thomas@epa.gov
Lawrence Starfield---03/16/2011 06:18:49 PM---Carl/Tom/Guy: See the note
below. PNM Resources has a conf call with J anet McCabe on Monday to disc
From: Lawrence Starfield/R6/USEPA/US
To: "Tom Diggs" <diggs.thomas@epa.gov>, "Carl Edlund" <edlund.carl@epa.gov>, "Guy Donaldson"
<donaldson.guy@epa.gov>
Cc: Al Armendariz/R6/USEPA/US
Date: 03/16/2011 06:18 PM
Subject: Fw: Request for Conference Call Monday
Carl/Tom/Guy:
See the note below. PNM Resources has a conf call with Janet McCabe on
Monday to discuss our proposed Reg'l Haze FIP.
Please send up any fact sheet and background materials to Janet (cc: Al and
me) by COB Friday.
Thanks.
Larry
Sent by EPA Wireless E-Mail Services
----- Original Message -----
From: Janet McCabe
Sent: 03/16/2011 05:48 PM EDT
To: "Al Armendariz" <armendariz.al@epa.gov>; Lawrence Starfield; Joseph
Goffman; "Steve Page" <page.steve@epa.gov>; Addie Johnson
Cc: Scott Mathias; Rhea Jones; Todd Hawes; David McIntosh
Subject: Fw: Request for Conference Call Monday
Al, Larry, Steve--
We've received the request below for a meeting on the San Juan plant. We of
course would include whoever from Region 6 would want to join us and oaqps
as well. This is a meeting where we would be in listening mode of course.
Can you let us know who you'd like to have participate and if you have a
preference for time and we'll set it up.
And if you could send around whatever background materials you have, that
would be helpful.
David--just so you know we're following up...
----- Original Message -----
From: Joseph Goffman
Sent: 03/16/2011 05:09 PM EDT
To: "Pablo, Jeanette" <jeanette.pablo@pnmresources.com>; Janet McCabe
Subject: Re: Request for Conference Call Monday
Hi, Jeanette. Thanks very much for the outreach. Janet and I will put our
heads together and do our best to organized a call on Monday. Back to you
shortly. Thanks, again.
----- Original Message -----
From: "Pablo, Jeanette" [jeanette.pablo@pnmresources.com]
Sent: 03/16/2011 04:03 PM AST
To: Joseph Goffman
Subject: Request for Conference Call Monday
Hi Joe
This email is a follow up to my voicemail. I apologize for the short notice
but have been asked to request a conference call with you and Janet McCabe
for Monday, March 21 preferably at either 11 am or 5 pm EST for about an
hour. The purpose of the call is to discuss the BART determination for the
San Juan Generating Station under Regional Haze and the State SIP and
process.
I look forward to speaking with you.
Jeanette
From: Carl Edlund
To: J anet McCabe
Cc: Suzanne Murray; Suzanne Smith
Bcc: Al Armendariz
Subject: Re: meeting on San juan monday
Date: 03/17/2011 08:21 PM
I don't see how we could not have our legal talent involved ..please assume they are
in (unless I find out otherwise in which case I'll notify all).
Sent by EPA Wireless E-Mail Services
J anet McCabe
----- Original Message -----
From: Janet McCabe
Sent: 03/17/2011 08:24 PM EDT
To: Carl Edlund
Subject: meeting on San juan monday
Will you have ORC on this call monday? We ought to have them
and/or OGC....
J anet McCabe
Principal Deputy Assistant Administrator
Office of Air and Radiation, USEPA
Room 5426K, 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-564-3206
mccabe.janet@epa.gov
From: Al Armendariz
To: J oe Kordzi; Carl Edlund; Thomas Diggs; Guy Donaldson
Cc: Erik Snyder; Rob Lawrence
Subject: Re: A really alternative plan for the SJ GS
Date: 03/11/2011 09:05 AM
Hi J oe. Thanks. Interesting idea for sjgs.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
J oe Kordzi
----- Original Message -----
From: Joe Kordzi
Sent: 03/10/2011 02:20 PM CST
To: Al Armendariz; Carl Edlund <edlund.carl@epa.gov>; Thomas Diggs; Guy
Donaldson
Cc: Erik Snyder; Rob Lawrence
Subject: A really alternative plan for the SJGS
This man, who is the president of NovelEdge Technologies, called me
wanting to find out more information on our two recent NM and OK
proposals. He wants to approach OG&E and AEP about converting the
six OK units to combined cycle turbines. His company sells more
efficient models, he says can be installed for less than the cost of the
scrubbers. However, the conversation really got interesting when he
starting about his vision for the SJ GS. He'd like to see the boilers
decommissioned and a coal to liquids plant built in their place.
Apparently, his firm can engineer a 50,000 barrel per day coal to
liquids plant, that would as a by product generate 1,100 MW of much
cleaner electricity. He also said he thought there was a nearby CO2
pipeline that could carry the CO2 generated to enhanced recovery
projects. I did a quick check and it looks like he's right:
http://www.kindermorgan.com/business/co2/article_052001.pdf
He did some quick calculations over the phone and says the profit
margin on converting the coal to liquids is much greater than burning it
FOIA Exemption (b)(5) - Deliberative Process Privilege
to make electricity and the electricity generated from the waste heat
and syn gas is almost a bonus. He's received some funding from DOE
and says the military is really interested in CTL for security reasons. I
told him how to submit comments, but wanted to know if you folks
thought it would be a good idea to take this a bit further.
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
----- Forwarded by J oe Kordzi/R6/USEPA/US on 03/10/2011 01:15 PM -----
From: Bill Rollins <brollins@noveledge.com>
To: J oe Kordzi/R6/USEPA/US@EPA
Date: 03/10/2011 10:24 AM
Subject: Repowering
Joe,
Thank you for taking the time to talk with me yesterday
regarding the
EPA's recent proposal on Oklahoma coal plants. We believe that
repowering to clean and efficient natural gas fired combined
cycle for
these plants could be an excellent solution..
Besides commenting on these plants in Oklahoma, I also intended
to
submit comments on the Four Corners Generating Station as well.
Should
I also comment on San Juan?
If you see the attached brochure, it highlights our solution for
coal.
It is politically correct (retains jobs, reduces our dependence
on oil
imports), environmentally correct (approaches the emissions of
an NGCC,
only with half the CO2 emissions), and is economically correct,
especially in the light of recent oil price trends.
This truly is BACT when it comes to coal, as it has ultra-low
emissions
and employs CCS. We are currently working with NETL, a division
of the
DOE, on this technology.
Again, I saw this as pertinent to the Four Corners plant, but
wasn't
sure it would be as applicable to the San Juan plant. I would
appreciate your feedback.
Regards,
Bill Rollins
NovelEdge Technologies, LLC
Tel: 603-487-3074
[attachment "Brochure081203.doc" deleted by Al Armendariz/R6/USEPA/US]
From: J oe Kordzi
To: Al Armendariz; Carl Edlund; Thomas Diggs; Guy Donaldson
Cc: Erik Snyder; Rob Lawrence
Subject: A really alternative plan for the SJ GS
Date: 03/10/2011 02:20 PM
Attachments: Brochure081203.doc
This man, who is the president of NovelEdge Technologies, called me wanting to find
out more information on our two recent NM and OK proposals. He wants to
approach OG&E and AEP about converting the six OK units to combined cycle
turbines. His company sells more efficient models, he says can be installed for less
than the cost of the scrubbers. However, the conversation really got interesting
when he starting about his vision for the SJ GS. He'd like to see the boilers
decommissioned and a coal to liquids plant built in their place. Apparently, his firm
can engineer a 50,000 barrel per day coal to liquids plant, that would as a by
product generate 1,100 MW of much cleaner electricity. He also said he thought
there was a nearby CO2 pipeline that could carry the CO2 generated to enhanced
recovery projects. I did a quick check and it looks like he's right:
http://www.kindermorgan.com/business/co2/article_052001.pdf
He did some quick calculations over the phone and says the profit margin on
converting the coal to liquids is much greater than burning it to make electricity and
the electricity generated from the waste heat and syn gas is almost a bonus. He's
received some funding from DOE and says the military is really interested in CTL for
security reasons. I told him how to submit comments, but wanted to know if you
folks thought it would be a good idea to take this a bit further.
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
----- Forwarded by J oe Kordzi/R6/USEPA/US on 03/10/2011 01:15 PM -----
From: Bill Rollins <brollins@noveledge.com>
To: J oe Kordzi/R6/USEPA/US@EPA
Date: 03/10/2011 10:24 AM
Subject: Repowering
Joe,
Thank you for taking the time to talk with me yesterday regarding the
EPA's recent proposal on Oklahoma coal plants. We believe that
repowering to clean and efficient natural gas fired combined cycle for
these plants could be an excellent solution..
Besides commenting on these plants in Oklahoma, I also intended to
submit comments on the Four Corners Generating Station as well. Should
I also comment on San Juan?
If you see the attached brochure, it highlights our solution for coal.
It is politically correct (retains jobs, reduces our dependence on oil
imports), environmentally correct (approaches the emissions of an NGCC,
only with half the CO2 emissions), and is economically correct,
especially in the light of recent oil price trends.
This truly is BACT when it comes to coal, as it has ultra-low emissions
and employs CCS. We are currently working with NETL, a division of the
DOE, on this technology.
Again, I saw this as pertinent to the Four Corners plant, but wasn't
sure it would be as applicable to the San Juan plant. I would
appreciate your feedback.
Regards,
Bill Rollins
NovelEdge Technologies, LLC
Tel: 603-487-3074
From: Carl Edlund
To: Guy Donaldson
Cc: Agustin Carbo-Lugo; Al Armendariz; J oe Kordzi; Lawrence Starfield; Suzanne Murray; Suzanne Smith; Thomas
Diggs; Connie Sanchez; J oyce Runyan
Bcc: Al Armendariz
Subject: Re: Fw: PNM_EPA Region VI Meeting
Date: 03/03/2011 03:41 PM
Agree that meeting would be good [with proper documentation, of course] ..problem
may be availability of Larry and Al. I know that on the 11th they'll both be in
Corpus, Larry has a heavy travel schedule and Al will be in Baton Rouge the next
week.
J oyce/Connie ...Lotus Notes seems to say that there is ONLY one hour slot available
for both next Tuesday at 4:00 that is open for them both. Can we schedule that??
PS PNM is short for Public Service of New Mexico .. a power plant in NM
Guy Donaldson---03/03/2011 02:23:25 PM---PNM would like a meeting with the
RA. It appears they would like to come in and talk about their ne
From: Guy Donaldson/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Lawrence
Starfield/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, J oe Kordzi/R6/USEPA/US@EPA,
Suzanne Smith/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA, Agustin Carbo-
Lugo/R6/USEPA/US@EPA
Date: 03/03/2011 02:23 PM
Subject: Fw: PNM_EPA Region VI Meeting
PNM would like a meeting with the RA. It appears they would like to
come in and talk about their new proposal which is for selective non
catalytic reduction instead of selective catalytic reduction.
I understand from counsel that we can listen to what they have to say
as long as we keep a record of who was there and summarize what
was said. We can not indicate what we might do in the final rule.
Please let me know if you would like to meet. My inclination would be
to go ahead and meet with them if possible. We are asking them to
spend a bunch of money.
----- Forwarded by Guy Donaldson/R6/USEPA/US on 03/03/2011 02:06 PM -----
From: "Gannon, Maureen" <Maureen.Gannon@pnmresources.com>
To: Guy Donaldson/R6/USEPA/US@EPA
Cc: J oe Kordzi/R6/USEPA/US@EPA
Date: 03/03/2011 12:39 PM
Subject: PNM_EPA Region VI Meeting
FOIA Exemption (b)(5) - Deliberative P
Guy- I know EPA has many reasons for granting the extension beyond accommodating PNMs request but we
do appreciate the additional time. Thank you for letting me know and we will look for this in the Federal
Register.

As you are aware, NMED has filed a new draft petition for their RH SIP with the NM Environmental
Improvement Board. PNM requests a meeting with the EPA Region VI Administrator and appropriate staff to
discuss this latest development and steps going forward. We would propose a meeting next week (week of
March 7 thru 11) at your offices in Dallas if that would work for EPA. PNM is currently available Tuesday,
Wednesday, Thursday or Friday next week. At this point, I believe PNMs group would include Pat Themig, VP
Generation, our legal counsel and me although that is subject to change.

I look forward to hearing from you. Thank you.

Maureen
Maureen Gannon
Director, Environmental Services
PNM Resources
Alvarado Square, MS 2104
Albuquerque, NM 87158
(office) 505.241.2974
(fax) 505.241.2384
(cell) 505.249.8301
maureen.gannon@pnmresources.com
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From: David Gray
To: Al Armendariz
Subject: Note from Arvin
Date: 03/01/2011 01:12 PM
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
Arvin Ganesan
----- Original Message -----
From: Arvin Ganesan
Sent: 03/01/2011 01:59 PM EST
To: David Gray
Cc: David Gray; Joyce Frank; Sarah Pallone
Subject: Re: UPDATE Re: Region 6 Weekly Report February 28, 2011
[CONTAINS DELIBERATIVE INFORMATION - CONFIDENTIAL]
Perciasepe just got a letter on this topic. Is there a court deadline to
make this date? I think we're going to want to have a conversation
about it.
Thanks.
--------------------------------------------
ARVIN R. GANESAN
Deputy Associate Administrator
Office of the Administrator
United States Environmental Protection Agency
Ganesan.Arvin@epa.gov
(p) 202.564.5200
(f) 202.501.1519
David Gray---03/01/2011 01:56:15 PM---
From: David Gray/R6/USEPA/US
To: David Gray/R6/USEPA/US@EPA, Arvin Ganesan/DC/USEPA/US@EPA,
J oyce Frank/DC/USEPA/US@EPA, Sarah Pallone/DC/USEPA/US@EPA
Date: 03/01/2011 01:56 PM
Subject: UPDATE Re: Region 6 Weekly Report February 28, 2011
[CONTAINS DELIBERATIVE INFORMATION - CONFIDENTIAL]
David Gray
Director
External and Government Affairs
FOIA Exemption (b)(5) - Deliberative Process Privilege
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
David Gray
----- Original Message -----
From: David Gray
Sent: 03/01/2011 08:58 AM EST
To: David Gray; Arvin Ganesan; Joyce Frank; Sarah Pallone
Subject: Region 6 Weekly Report February 28, 2011
[CONTAINS DELIBERATIVE INFORMATION - CONFIDENTIAL]
Region 6 Weekly Report February 28, 2011
[February 28 to March 14]
Contact: David Gray, 214-665-2200



FOIA Exemption (b)(5) - Deliberative Process Privilege



David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
From: David Gray
To: J oyce Runyan; Al Armendariz
Subject: Fw: Call-in info for noon today on San J uan
Date: 03/01/2011 10:30 AM
Set for 11
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
Cynthia Fanning
----- Original Message -----
From: Cynthia Fanning
Sent: 03/01/2011 10:25 AM CST
To: "Ward, Stephen (Bingaman)" <Stephen_Ward@bingaman.senate.gov>
Cc: "Wallace, Andrew (Tom Udall)" <Andrew_Wallace@tomudall.senate.gov>;
"'angela.ramirez@mail.house.gov'" <angela.ramirez@mail.house.gov>; "Alpert,
Dan (Bingaman)" <Dan_Alpert@bingaman.senate.gov>; David Gray;
"'terrinikole.baca@mail.house.gov'" <terrinikole.baca@mail.house.gov>;
"Nagle, Tom (Tom Udall)" <Tom_Nagle@tomudall.senate.gov>
Subject: Call-in info for noon today on San Juan
I have received confirmation from Drew Wallace of Sen. Udall's office,
Stephen Ward and Dan Alpert of Sen. Bingaman's office and Terri
Nikole Baca of Cong. Lujan's office. Al Armendariz and David Gray of
EPA's Region 6 office will be on the call.
Please call 866-299-3188 and enter code 2146652100 at noon eastern
today. Thank you for your flexibility and responsiveness!
~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ *
Cynthia Fanning
Congressional Liaison
US EPA, Region 6
214-665-2142
fax 214-665-2118
~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ *
"Ward, Stephen (Bingaman)" ---03/01/2011 10:05:46 AM---I can, but for only 15
or so minutes --------------------------
From: "Ward, Stephen (Bingaman)" <Stephen_Ward@bingaman.senate.gov>
To: Cynthia Fanning/R6/USEPA/US@EPA, "Nagle, Tom (Tom Udall)" <Tom_Nagle@tomudall.senate.gov>,
"'angela.ramirez@mail.house.gov'" <angela.ramirez@mail.house.gov>
Cc: "Alpert, Dan (Bingaman)" <Dan_Alpert@bingaman.senate.gov>, "Wallace, Andrew (Tom Udall)"
<Andrew_Wallace@tomudall.senate.gov>, "'terrinikole.baca@mail.house.gov'"
<terrinikole.baca@mail.house.gov>, David Gray/R6/USEPA/US@EPA
Date: 03/01/2011 10:05 AM
Subject: Re: Call re San J uan extension request -- please reply ASAP
I can, but for only 15 or so minutes
--------------------------
Sent from my BlackBerry Wireless Handheld

From: Fanning.Cynthia@epamail.epa.gov
[mailto:Fanning.Cynthia@epamail.epa.gov]
Sent: Tuesday, March 01, 2011 10:52 AM
To: Nagle, Tom (Tom Udall); Ward, Stephen (Bingaman);
angela.ramirez@mail.house.gov <angela.ramirez@mail.house.gov>
Cc: Alpert, Dan (Bingaman); Wallace, Andrew (Tom Udall);
terrinikole.baca@mail.house.gov <terrinikole.baca@mail.house.gov>;
Gray.David@epamail.epa.gov <Gray.David@epamail.epa.gov>
Subject: Call re San J uan extension request -- please reply ASAP

Tom, Stephen and Angela -
My boss, Regional Administrator Al Armendariz, would like a few
minutes of your time today to discuss the attached letter. Would you
be available for a 15 min call to discuss the San J uan extension
request at noon your time today? Please let me know ASAP so I can
propose an alternate time if needed.
~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ *
Cynthia Fanning
Congressional Liaison
US EPA, Region 6
214-665-2142
fax 214-665-2118
~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ * ~ *
From: Diane Taheri
To: Al Armendariz; Lawrence Starfield; Chrissy Mann; Thomas Diggs; Guy Donaldson; Carl Edlund
Cc: David Gray
Subject: Updated list of NM FIP Extensions Requests
Date: 02/25/2011 04:40 PM
Since this issue is still under discussion, here's a revision with new information.
Another request received today:
UPDATED LIST:
R6-11-000-1372 Themig - Request for Extension of Public Comment BART San J uan
Generating Station DR COMPLETE
(Public Service Company of New Mexico - Albuquerque,
NM) 2/ 18/ 11
R6-11-000-1216 Bakken EPA Docket No. EPA-R06-OAR 2010 0846 (76 FR 491; J an
5, 2011) Due 2/09
(Tucson Electric Power Company)
R6-11-000-1371 Walz Proposed FIP on BART San J uan Generating
Station Due 2/28
(TriState Generation and Transmission Association - Denver, CO)
R6-11-000-2462 Hunter Proposed FIP to establish BART for San J uan Generating
Station Due 3/18
(Utah Associated Municipal Power Systems - Salt Lake City, UT)
R6-11-000-2463 Helgeson Proposed FIP to establish BART San J uan Generating
Station (SCPPA) Due 3/18
(Southern California Public Power Co. - Pasedena, CA)
R6-11-000-2549 Bingaman-Udall-Lujan Draft FIP for San J uan Generating
Station Due 3/18
(write on behalf of stake holders and local officials in New Mexico)
R6-11-000-2591 Hopper - Request for Extension of Public Comment Period
FIP Due 3/22
(MSR Public Power Agency - Modesto, CA)
R6-11-000-2592 Atkinson - Draft FIP for San J uan Generating Station (San J uan
County) Due 3/22
R6-11-000-2631 Roberts - Proposed FIP for San J uan Generating Station (City of
Farmington NM) Due 3/22
R6-11-000-2997 Hare - Draft FIP for San J uan Generating Station
(San J uan Economic Development Service - Farmington,
NM) Due 3/25
Diane Taheri
Deputy Director
Office of External Affairs
Office: (214) 665-2200
Direct: (214) 665-7460
Blackberry: (214) 864-7241
taheri.diane@epa.gov
From: Al Armendariz
To: Chrissy Mann; Layla Mansuri
Subject: Fw: regional haze
Date: 02/21/2011 05:41 PM
Attachments: 0-5 dv discussion from BART final rule.pdf
Stuff dug up during FOIA nonsense...
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
----- Forwarded by Al Armendariz/R6/USEPA/US on 02/21/2011 05:40 PM -----
Re: regional haze
J oe
Kordzi
to: Al Armendariz
04/20/2010
11:03 AM
Cc: Carl Edlund, Thomas Diggs, Guy Donaldson, Erik Snyder
Hi Al,
Pls see me responses below
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
Al Armendariz---04/20/2010 10:08:19 AM---Hi J oe, I was looking back again at
the briefing you gave to me back in March about R6 regional haze
From: Al Armendariz/R6/USEPA/US
To: J oe Kordzi/R6/USEPA/US@EPA
Cc: Carl Edlund/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA
Date: 04/20/2010 10:08 AM
Subject: regional haze
Hi J oe,
I was looking back again at the briefing you gave to me back in March
about R6 regional haze. I had two questions:
FOIA Exemption (b)(5) - Deliberative Process Privilege
Here is a page cut from the preamble that discusses this
in more detail:


Thanks
Al
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Al Armendariz
To: J oe Kordzi
Subject: Re: regional haze
Date: 04/20/2010 11:12 AM
Thanks.
J oe Kordzi---04/20/2010 11:03:05 AM---Hi Al, Pls see me responses below
From: J oe Kordzi/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA
Cc: Carl Edlund/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Guy
Donaldson/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA
Date: 04/20/2010 11:03 AM
Subject: Re: regional haze
Hi Al,
Pls see me responses below
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
Al Armendariz---04/20/2010 10:08:19 AM---Hi J oe, I was looking back again at
the briefing you gave to me back in March about R6 regional haze
From: Al Armendariz/R6/USEPA/US
To: J oe Kordzi/R6/USEPA/US@EPA
Cc: Carl Edlund/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA
Date: 04/20/2010 10:08 AM
Subject: regional haze
Hi J oe,
I was looking back again at the briefing you gave to me back in March
about R6 regional haze. I had two questions:
FOIA Exemption (b)(5) - Deliberative Process Privilege
Here is a page cut from the preamble that discusses this
in more detail:
[attachment "0-5 dv discussion from BART_final_rule.pdf" deleted by
Al Armendariz/R6/USEPA/US]
FOIA Exemption (b)(5) - Deliberative Process Privilege
Thanks
Al
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Al Armendariz
To: David Gray; Miguel Flores; Larry Starfield
Cc: J oyce Runyan
Subject: Fw: Request for Meeting
Date: 02/14/2011 02:53 PM
I am available I believe on most days.
David and Miguel: can you work with Joyce to setup?
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
----- Original Message -----
From: Bryan Bird [bbird@wildearthguardians.org]
Sent: 02/14/2011 01:16 PM MST
To: Al Armendariz; David Gray; Miguel Flores
Subject: Request for Meeting
Dear Mr. Armendariz and Mr. Flores,
John Horning, Executive Director of WildEarth Guardians, and myself
would like to meet with you both regarding the pending waster quality
standards changes in New Mexico, in particular the new ONRW
designation. We are prepared to travel to Dallas. Are you both
available the first week of March to meet regarding this matter in
Dallas?
--
Bryan Bird
Wild Places Program Director
WildEarth Guardians
312 Montezuma
Santa Fe, NM 87501
505.988.9126 x 1157
505.501.4488 Cell
505.989.8623 Fax
bbird@wildearthguardians.org
www.wildearthguardians.org
Sign up here: http://wg.convio.net/site/Survey?
ACTION_REQUIRED=URI_ACTION_USER_REQUESTS&SURVEY_ID=1241
Manage your WG account OR go paperless here:
http://wg.convio.net/site/PageServer?pagename=home
View our Four Star rating from Charity Navigator at
http://www.charitynavigator.org/index.cfm?bay=search.summary&orgid=9974
From: Layla Mansuri
To: Al Armendariz; Chrissy Mann
Subject: Fw: Fw: Earthjustice conflict question follow up
Date: 02/13/2011 04:18 PM
Lawrence Starfield
----- Original Message -----
From: Lawrence Starfield
Sent: 02/13/2011 03:30 PM EST
To: Layla Mansuri
Cc: Michael Barra; Suzanne Murray
Subject: Fw: Fw: Earthjustice conflict question follow up
Layla,
I think we're OK for the meeting.
Thanks.
Larry
Sent by EPA Wireless E-Mail Services
Michael Barra
----- Original Message -----
From: Michael Barra
Sent: 02/13/2011 01:56 PM CST
To: Lawrence Starfield
Cc: Suzanne Murray
Subject: Re: Fw: Earthjustice conflict question follow up
I agree with you.
Michael C. Barra
USEPA Region 6
Office of Regional Counsel
(214)665-2143
barra.michael@epa.gov
Lawrence Starfield---02/12/2011 12:46:10 AM---Another ethics question. This
relates to EarthJ ustice -- Al has no covered relation with them, but
From: Lawrence Starfield/R6/USEPA/US
To: Michael Barra/R6/USEPA/US
Cc: Suzanne Murray/R6/USEPA/US@EPA
Date: 02/12/2011 12:46 AM
Subject: Fw: Earthjustice conflict question follow up
Another ethics question. This relates to EarthJ ustice -- Al has no
covered relation with them, but they do often represent Sierra Club
(with whom Al does have a covered relation).
FOIA Exemption (b)(5) - Deliberative Process Privilege
As long as we don't discuss specific cases in which EarthJ ustice is
representing Sierra Club, I wouldn't think this would be a problem.
Let me know what you think.
Larry
Sent by EPA Wireless E-Mail Services
Layla Mansuri
----- Original Message -----
From: Layla Mansuri
Sent: 02/11/2011 01:40 PM CST
To: Lawrence Starfield
Subject: Earthjustice conflict question follow up
Larry,
I want to follow up with you about the Earthjustice question and
whether their representation of Sierra Club (one of Al's covered
relationships) would prevent Al from engaging in a conversation with
Earthjustice. I'm including a recent email conversation between
myself and Stephanie Kodish, attorney for the National Parks
Conservation Association, about the particular scenario. If we need
more specifics on any of the facts to make a determination, just let me
know.
As I mentioned Stephanie is working with an attorney at Earthjustice
and would like for that attorney to participate in a conversation with Al.
National Parks Conservation Association (NPCA) is
represented by Earthjustice on some set of Regional Haze
issues.
Earthjustice also represents Sierra Club on some set of
Regional Haze issues.
Sierra Club and NPCA are signatories parties to a NOI to
file a deadline suit/suit filed on regional haze SIPs across
the country, including Texas.
Thanks.
Layla
----- Forwarded by Layla Mansuri/R6/USEPA/US on 02/11/2011 01:32 PM -----
From: Stephanie Kodish <skodish@npca.org>
To: Layla Mansuri/R6/USEPA/US@EPA
Date: 02/11/2011 01:31 PM
Subject: RE: follow-up
Hi Layla- yes, you have the facts correct. I will send you some April date options in
about a week.
Many thanks,
Stephanie

From: Mansuri.Layla@epamail.epa.gov
[mailto:Mansuri.Layla@epamail.epa.gov]
Sent: Friday, February 11, 2011 2:22 PM
To: Stephanie Kodish
Subject: Re: follow-up

Stephanie,
Thanks for the information. I will share it here at the Region.
I've talked with our Deputy Ethics Officer at the region about whether or
not Al can engage in a discussion with Earthjustice regarding the
substance of the Texas Regional Haze Proposal. Let me make sure I
have the facts straight and I'll get back to you with an answer.
National Parks Conservation Association (NPCA) is
represented by Earthjustice on some set of Regional Haze
issues.
Earthjustice also represents Sierra Club on some set of
Regional Haze issues.
Sierra Club and NPCA are signatories parties to a NOI to
file a deadline suit/suit filed on regional haze SIPs across
the country, including Texas.
Let's go ahead and get a meeting date set up. An early April time frame
sounds fine. Please send me a couple of date options as soon as you
have some.
Thanks,
Layla
From: Stephanie Kodish <skodish@npca.org>
To: Layla Mansuri/R6/USEPA/US@EPA
Date: 02/10/2011 03:44 PM
Subject:
follow-up

Layla, again my many thanks for arranging yesterdays discussion.

Attached you will find Federal Land Manager (both National Park
Service and Forest Service) comments on Texass 2007 regional haze
SIP submission. While a number of issues remain outstanding, note that
the State addressed several issues in its revised proposal. For example,
the revised SIP included the requested information/analysis about
impacts on Class I areas in other states.

After our call, I had the opportunity to more closely review which
states/regions conducted a cumulative impact assessment, or said
another way, the total impact of a source across all Class I areas within
its vicinity. I realized that I misspoke on our call, so want to provide you
and your colleagues with the correct information.

Cumulative impacts were assessed either directly (labeled as
cumulative visibility impacts) or indirectly (deciview impact totaled
across all Class I areas impaired by a sources emissions, but not
termed cumulative visibility impact) in the following instances, in
addition to Region VIs proposed FIP for San Juan Generating Station:
- Wyoming
- Oregon
- ANPR for Four Corners and Navajo Generating Station (tables 26
and 35 - visibility impacts totaled)
- EPA Region 7 to Nebraska (letter attached- see section 5b)

With regard to the Region 7 letter and also to add to the dollar per
deciview ($/dV) discussion, I attach a May 2010 coalition letter to AA
Gina McCarthy regarding implementation of the regional haze program
(see Section 5). A number of states use the $/dV approach, which when
used to augment a $/ton calculation, can be a useful tool. States that
have appropriately used this method include Oregon and Wisconsin.

Also with respect to an in-person meeting in Dallas, I wonder if we might
look to early April to continue our discussion. Does that timeframe work
for you all?

Best,
Stephanie
From: Mansuri.Layla@epamail.epa.gov
[mailto:Mansuri.Layla@epamail.epa.gov]
Sent: Wednesday, February 09, 2011 10:36 AM
To: Stephanie Kodish
Subject: Call in number

Hi Stephanie,
As it turns out, we are all home bound today due to ice in a City that is
totally out of de-icer stuff.
Anyhow, I have a call in number for the 1 pm CST today.
Dial: 866-299-3188
Access: 665-2100#
Please send me a note to let me know you received this.
Thanks,
Layla[attachment "USFS comments TX RH SIP_01102008.pdf" deleted
by Layla Mansuri/R6/USEPA/US] [attachment "DOI Comments Texas
Haze SIP_01_11_2008.pdf" deleted by Layla Mansuri/R6/USEPA/US]
[attachment "EPA letter to NE regarding comment on proposed SIP 01-
21-11.pdf" deleted by Layla Mansuri/R6/USEPA/US] [attachment "2010-
5-20 NPCA Regional Haze ltr.pdf" deleted by Layla
Mansuri/R6/USEPA/US]
From: Layla Mansuri
To: Chrissy Mann; Al Armendariz
Cc: Lawrence Starfield
Subject: NPCA, TX Regional Haze SIP follow up
Date: 02/11/2011 01:47 PM
Attachments: USFS comments TX RH SIP 01102008.pdf
DOI Comments Texas Haze SIP 01 11 2008.pdf
EPA letter to NE regarding comment on proposed SIP 01-21-11.pdf
2010-5-20 NPCA Regional Haze ltr.pdf
Chrissy, Al:
Please see the information from Stephanie.
I'm coordinating a response with Larry on the Earthjustice ethics question.
Stephanie and I are working to set up a meeting in early April. More to come.
----- Forwarded by Layla Mansuri/R6/USEPA/US on 02/11/2011 01:40 PM -----
From: Stephanie Kodish <skodish@npca.org>
To: Layla Mansuri/R6/USEPA/US@EPA
Date: 02/10/2011 03:44 PM
Subject: follow-up
Layla, again my many thanks for arranging yesterdays discussion.

Attached you will find Federal Land Manager (both National Park Service and Forest
Service) comments on Texass 2007 regional haze SIP submission. While a number
of issues remain outstanding, note that the State addressed several issues in its
revised proposal. For example, the revised SIP included the requested
information/analysis about impacts on Class I areas in other states.

After our call, I had the opportunity to more closely review which states/regions
conducted a cumulative impact assessment, or said another way, the total impact of a
source across all Class I areas within its vicinity. I realized that I misspoke on our
call, so want to provide you and your colleagues with the correct information.

Cumulative impacts were assessed either directly (labeled as cumulative visibility
impacts) or indirectly (deciview impact totaled across all Class I areas impaired by a
sources emissions, but not termed cumulative visibility impact) in the following
instances, in addition to Region VIs proposed FIP for San Juan Generating Station:
- Wyoming
- Oregon
- ANPR for Four Corners and Navajo Generating Station (tables 26 and
35 - visibility impacts totaled)
- EPA Region 7 to Nebraska (letter attached- see section 5b)

With regard to the Region 7 letter and also to add to the dollar per deciview ($/dV)
discussion, I attach a May 2010 coalition letter to AA Gina McCarthy regarding
implementation of the regional haze program (see Section 5). A number of states use
the $/dV approach, which when used to augment a $/ton calculation, can be a useful
tool. States that have appropriately used this method include Oregon and Wisconsin.

Also with respect to an in-person meeting in Dallas, I wonder if we might look to early
April to continue our discussion. Does that timeframe work for you all?

Best,
Stephanie
From: Mansuri.Layla@epamail.epa.gov [mailto:Mansuri.Layla@epamail.epa.gov]
Sent: Wednesday, February 09, 2011 10:36 AM
To: Stephanie Kodish
Subject: Call in number

Hi Stephanie,
As it turns out, we are all home bound today due to ice in a City that is totally out of
de-icer stuff.
Anyhow, I have a call in number for the 1 pm CST today.
Dial: 866-299-3188
Access: 665-2100#
Please send me a note to let me know you received this.
Thanks,
Layla
From: Al Armendariz
To: David Gray
Subject: Re: NM Haze response
Date: 02/08/2011 12:49 PM
David,
I added two sentences. Can you get Carl/Tom/Guy to fill in the blanks? Not
absolutely critical, if it has to go out right now, but would be better to add in
additional info if we can get it.
Al
_____
Region 6/9 response:

______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
FOIA Exemption (b)(5) - Deliberative Process Privilege
office: 214-665-2100
twitter: @al_armendariz
David Gray---02/08/2011 11:59:15 AM---Al - would you take a quick read of this
response to Senator Bingamam Incoming from Bingaman staff
From: David Gray/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA
Date: 02/08/2011 11:59 AM
Subject: NM Haze response
Al - would you take a quick read of this response to Senator Bingamam
Incoming from Bingaman staff
Ive been reading through the NOx emission proposals on regional haze from
Region 6 for San Juan and Region 9 for the Four Corners Plant. If Im reading
these right, Region 6s proposed emission rate for NOx is 0.05 lb/mmBTU.
Region 9 proposed a rate for Four Corners of 0.11 lb/mmBTUor about twice
as much. The current emission rates are 0.3 lb/mmBTU for San Juan and
0.55lb/mmBTU for Four Corners. Am I reading the two proposals correctly? If
so, is there a logical explanation for the difference in the proposed emission
rates for the two plants?
Region 6/9 response:

FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Carl Edlund
To: Al Armendariz
Subject: Re: Request for Additional Public Hearings, San J uan BART FIP
Date: 01/30/2011 06:24 AM
Mike Barra will chair the hearing; Tom and several staff will attend. It is in good hands
without us.
Sent by EPA Wireless E-Mail Services
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 01/29/2011 09:57 PM CST
To: Carl Edlund
Subject: Re: Request for Additional Public Hearings, San Juan BART FIP
Hi Carl,
About 1 week ago you asked about the public hearing. No, I wasn't
planning on going up. So we should plan on another chair (you, Tom, or
guy?).
Best,
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Carl Edlund---01/20/2011 10:27:31 AM---Well, I am a very inclusive kind of guy
and I would be very open to meetings of all kind to get topi
From: Carl Edlund/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA
Cc: "Carl Edlund" <edlund.carl@epa.gov>, Guy Donaldson/R6/USEPA/US@EPA, J oe
Kordzi/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, "Chrissy Mann"
<mann.chrissy@epa.gov>, "Layla Mansuri" <mansuri.layla@epa.gov>
Date: 01/20/2011 10:27 AM
Subject: Re: Request for Additional Public Hearings, San J uan BART FIP
Well, I am a very inclusive kind of guy and I would be very open to
meetings of all kind to get topics fully understood ...BUT ...this is a
formal public comment period and I think we'll need to need to take
special care that all comments are recorded at the open house already
scheduled to happen before the public hearing
Therefore, I'd say 'no' to additional venues
before we make a decision on the FIP.
Perhaps we could offer to have workshops after the FIP rule-making to
explain our logic.
PS- Were you planning to chair the public hearing or would that be me
[or Tom]?
Al Armendariz---01/19/2011 09:18:47 PM---In general, I think multi-stakeholder
engagements are good ideas, including maybe this open house. A
From: Al Armendariz/R6/USEPA/US
To: J oe Kordzi/R6/USEPA/US@EPA
Cc: "Carl Edlund" <edlund.carl@epa.gov>, Guy Donaldson/R6/USEPA/US@EPA, "Chrissy Mann"
<mann.chrissy@epa.gov>, "Layla Mansuri" <mansuri.layla@epa.gov>, Lawrence
Starfield/R6/USEPA/US@EPA
Date: 01/19/2011 09:18 PM
Subject: Re: Request for Additional Public Hearings, San J uan BART FIP
In general, I think multi-stakeholder engagements are good ideas,
including maybe this open house.
Carl, what are your thoughts here?
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
J oe Kordzi
----- Original Message -----
From: Joe Kordzi
Sent: 01/19/2011 03:48 PM CST
To: Al Armendariz
Cc: "Carl Edlund" <edlund.carl@epa.gov>; Guy Donaldson;
"Chrissy Mann" <mann.chrissy@epa.gov>; "Layla Mansuri"
<mansuri.layla@epa.gov>; Lawrence Starfield
Subject: Re: Request for Additional Public Hearings, San Juan
BART FIP
FOIA Exemption (b)(5) - Deliberative Process Privilege
Relatedly, I just got an email from PNM requesting details on how we are
planning to structure our open house, that precedes the hearing. It
seems they would like to know to what extent we would be winning to
engage them or vice versa.
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
Al Armendariz---01/19/2011 03:41:08 PM---
From: Al Armendariz/R6/USEPA/US
To: "Carl Edlund" <edlund.carl@epa.gov>
Cc: J oe Kordzi/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, "Layla Mansuri"
<mansuri.layla@epa.gov>, "Chrissy Mann" <mann.chrissy@epa.gov>, "Larry Starfield"
<starfield.lawrence@epamail.epa.gov>
Date: 01/19/2011 03:41 PM
Subject: Re: Request for Additional Public Hearings, San J uan BART FIP
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
From: Jeremy Nichols [jnichols@wildearthguardians.org]
Sent: 01/19/2011 01:50 PM MST
To: Al Armendariz
Cc: Joe Kordzi; Guy Donaldson; Mike Eisenfeld <meisenfeld@frontier.net>
FOIA Exemption (b)(5) - Deliberative Process Privilege
Subject: Request for Additional Public Hearings, San Juan BART FIP
Dear Regional Administrator Armendariz:
Attached, please find a request from several organizations and agencies
requesting additional public hearings in the matter of EPA's proposed Best
Available Retrofit Technology Federal Implementation Plan for the San Juan
Generating Station. Thank you for considering this request.
Jeremy
--
Jeremy Nichols
Climate and Energy Program Director
WildEarth Guardians
1536 Wynkoop, Suite 301 - Denver, CO 80202
303-573-4898 x 1303
www.wildearthguardians.org
Read my blog on the Huffington Post http://www.huffingtonpost.com/jeremy-
nichols/
Join our e-mail list today http://wg.convio.net/site/Survey?
ACTION_REQUIRED=URI_ACTION_USER_REQUESTS&SURVEY_ID=1241
WildEarth Guardians has earned a Four Star rating from Charity Navigator.
View our profile http://www.charitynavigator.org/index.cfm?
bay=search.summary&orgid=9974
From: Guy Donaldson
To: Al Armendariz
Cc: Carl Edlund; J oe Kordzi; Lawrence Starfield; Chrissy Mann; Layla Mansuri; J oe Kordzi; Thomas Diggs; Lucinda
Watson; Agustin Carbo-Lugo
Subject: Re: Request for Additional Public Hearings, San J uan BART FIP
Date: 01/19/2011 10:02 PM
I'll get with my guys tomorrow and talk about it but I have some reservations.
Things to consider are
1) we have to provide 30 days of comment after the last public hearing so this will
extend the comment period and make it harder to meet our deadline.
2) Travel wise this could be an expensive endeavor especially if we have to make two
trips out there. We have been planning to send 5 people. Three for the panel, the
hearing office and one to handle logistics of comments. This year's travel is already
tight.
3) The same people that work on logistics are doing the Oklahoma notice and FOIA's.
We really aren't looking for more things to do.
I think we would need to figure out how to tie a second hearing into the same trip but
I'm not sure we can do it because I'm not sure we will provide sufficient notice.
Al Armendariz---01/19/2011 09:18:47 PM---In general, I think multi-stakeholder
engagements are good ideas, including maybe this open house. A
From: Al Armendariz/R6/USEPA/US
To: J oe Kordzi/R6/USEPA/US@EPA
Cc: "Carl Edlund" <edlund.carl@epa.gov>, Guy Donaldson/R6/USEPA/US@EPA, "Chrissy Mann"
<mann.chrissy@epa.gov>, "Layla Mansuri" <mansuri.layla@epa.gov>, Lawrence
Starfield/R6/USEPA/US@EPA
Date: 01/19/2011 09:18 PM
Subject: Re: Request for Additional Public Hearings, San J uan BART FIP
In general, I think multi-stakeholder engagements are good ideas,
including maybe this open house.
Carl, what are your thoughts here?
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
FOIA Exemption (b)(5) - Deliberative Process Privilege
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
J oe Kordzi
----- Original Message -----
From: Joe Kordzi
Sent: 01/19/2011 03:48 PM CST
To: Al Armendariz
Cc: "Carl Edlund" <edlund.carl@epa.gov>; Guy Donaldson;
"Chrissy Mann" <mann.chrissy@epa.gov>; "Layla Mansuri"
<mansuri.layla@epa.gov>; Lawrence Starfield
Subject: Re: Request for Additional Public Hearings, San Juan
BART FIP
Relatedly, I just got an email from PNM requesting details on how we are
planning to structure our open house, that precedes the hearing. It
seems they would like to know to what extent we would be winning to
engage them or vice versa.
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
Al Armendariz---01/19/2011 03:41:08 PM---
From: Al Armendariz/R6/USEPA/US
To: "Carl Edlund" <edlund.carl@epa.gov>
Cc: J oe Kordzi/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, "Layla Mansuri"
<mansuri.layla@epa.gov>, "Chrissy Mann" <mann.chrissy@epa.gov>, "Larry Starfield"
<starfield.lawrence@epamail.epa.gov>
Date: 01/19/2011 03:41 PM
Subject: Re: Request for Additional Public Hearings, San J uan BART FIP
Al
____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
FOIA Exemption (b)(5) - Deliberative Process Privilege
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
From: Jeremy Nichols [jnichols@wildearthguardians.org]
Sent: 01/19/2011 01:50 PM MST
To: Al Armendariz
Cc: Joe Kordzi; Guy Donaldson; Mike Eisenfeld <meisenfeld@frontier.net>
Subject: Request for Additional Public Hearings, San Juan BART FIP
Dear Regional Administrator Armendariz:
Attached, please find a request from several organizations and agencies
requesting additional public hearings in the matter of EPA's proposed Best
Available Retrofit Technology Federal Implementation Plan for the San Juan
Generating Station. Thank you for considering this request.
Jeremy
--
Jeremy Nichols
Climate and Energy Program Director
WildEarth Guardians
1536 Wynkoop, Suite 301 - Denver, CO 80202
303-573-4898 x 1303
www.wildearthguardians.org
Read my blog on the Huffington Post http://www.huffingtonpost.com/jeremy-
nichols/
Join our e-mail list today http://wg.convio.net/site/Survey?
ACTION_REQUIRED=URI_ACTION_USER_REQUESTS&SURVEY_ID=1241
WildEarth Guardians has earned a Four Star rating from Charity Navigator.
View our profile http://www.charitynavigator.org/index.cfm?
bay=search.summary&orgid=9974
From: J eremy Nichols
To: Al Armendariz/R6/USEPA/US@EPA
Cc: J oe Kordzi/R6/USEPA/US@EPA; Guy Donaldson/R6/USEPA/US@EPA; Mike Eisenfeld
Subject: Request for Additional Public Hearings, San J uan BART FIP
Date: 01/19/2011 02:50 PM
Attachments: 2011-1-19 Request for Additional Public Hearings.pdf
Dear Regional Administrator Armendariz:
Attached, please find a request from several organizations and agencies requesting
additional public hearings in the matter of EPA's proposed Best Available Retrofit
Technology Federal Implementation Plan for the San J uan Generating Station.
Thank you for considering this request.
J eremy
--
J eremy Nichols
Climate and Energy Program Director
WildEarth Guardians
1536 Wynkoop, Suite 301 - Denver, CO 80202
303-573-4898 x 1303
www.wildearthguardians.org
Read my blog on the Huffington Post http://www.huffingtonpost.com/jeremy-
nichols/
J oin our e-mail list today http://wg.convio.net/site/Survey?
ACTION REQUIRED=URI ACTION USER REQUESTS&SURVEY ID=1241
WildEarth Guardians has earned a Four Star rating from Charity Navigator. View our
profile http://www.charitynavigator.org/index.cfm?bay=search.summary&orgid=9974
From: Al Armendariz
To: Carl Edlund; Suzanne Murray; Thomas Diggs; Suzanne Smith; Larry Starfield
Subject: Fw: SJ GS - EPA FIP Comment Period Extension - WEST Associates Letter
Date: 01/25/2011 07:15 PM
Attachments: 20110125 WEST Associates Comments EPA-FIP San J uan GS.pdf
____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
From: "Eklund, Gwen (Austin,TX-US)" [GEklund@trcsolutions.com]
Sent: 01/25/2011 07:27 PM EST
To: Al Armendariz; Sam Coleman; Guy Donaldson
Subject: SJGS - EPA FIP Comment Period Extension - WEST Associates Letter
Gentlemen:

Attached please find a letter from WEST Associates for your consideration.

WEST Associates is a coalition of 13 public- and investor-owned electric utilities that
operate over 60% of the fossil-fueled electricity generation capacity in 11 western United
States, providing about 300,000 GWHs annually to 12.8 million customers. WESTs 13
member utilities have undergone, or are undergoing, BART Determinations for over 60
BART eligible power plant units operating and providing electric power in the west. These
BART determinations when implemented, will add significant costs to western electric utility
customers in the western states.

WEST Associates (WEST) requests a 60-day extension of the public comment period for the
proposed Federal Implementation Plan (FIP) to impose Best Available Retrofit Technology
(BART) at the San Juan Generating Station (SJGS). Currently, EPA requests comments be
submitted within 60 days of publication of the Federal Register notice on January 5, 2011 (76
FR 491). However, EPAs proposed FIP contains a complex set of technical issues due to its
significantly more stringent and costly departure from PNM Resources (PNM) BART
analysis previously submitted for the SJGS to the New Mexico Environmental Department
(NMED). Therefore, WEST strongly supports a 60-day extension to the comment period.

As the WEST business manager, I would appreciate your confirming receipt of the attached
letter. If you have comments or questions concerning this letter, please direct your inquiries
to me. Thank you for your consideration in this matter.

Sincerely,

A. Gwen Ekund
Business Manager, WEST Associates
505 East Huntland Drive, Suite 250
Austin, TX 78752

Direct Line: 512.684.3106
Cell Phone: 512.567.7284

geklund@trcsolutions.com

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From: Al Armendariz
To: Layla Mansuri
Subject: Re: FOIA requests for the NM and OK FIPs
Date: 01/20/2011 08:07 PM
Thanks.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Layla Mansuri
----- Original Message -----
From: Layla Mansuri
Sent: 01/20/2011 04:30 PM CST
To: Al Armendariz; Chrissy Mann; Lawrence Starfield; Javier Balli
Cc: Carrie Clayton
Subject: Fw: FOIA requests for the NM and OK FIPs
FYI.
----- Forwarded by Layla Mansuri/R6/USEPA/US on 01/20/2011 04:29 PM -----
From: Agustin Carbo-Lugo/R6/USEPA/US
To: Layla Mansuri/R6/USEPA/US@EPA
Date: 01/20/2011 04:11 PM
Subject: Re: Fw: FOIA requests for the NM and OK FIPs
Layla,
After talking to J oe Kordzi, we have decided to request additional time
for both NM and OK's FOIAs. I am requesting an additional time of 30
days from today. Still have no reply from the attorneys. We are only
limiting the scope for the OK FOIA, for questions 3 and 4. You may
want to wait until I receive confirmation on this one. Most of NM's
requests are already in the e docket for the NPRM. We decided to
continue uploading in the box all the emails related just to the San
J uan Generating Station (as stated in the request).
Hope this helps :)
Agustin F. Carbo-Lugo
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6-RC-M)
Dallas, TX 75202
Tel: (214) 665-8037
Fax: (214) 665-2182
-----Layla Mansuri/R6/USEPA/US wrote: -----
To: Agustin Carbo-Lugo/R6/USEPA/US@EPA
From: Layla Mansuri/R6/USEPA/US
Date: 01/20/2011 04:01PM
Cc: Chrissy Mann/R6/USEPA/US@EPA, Leticia
Lane/R6/USEPA/US@EPA, Yerusha Beaver/R6/USEPA/US@EPA
Subject: Re: Fw: FOIA requests for the NM and OK FIPs
Agustin:
Hi. J ust following up.
I have a couple of questions.
1. What are the current deadlines?
2. Was there any narrowing to the requests? Is this in the works?
Thanks.
Layla
Agustin Carbo-Lugo---01/18/2011 10:11:57 AM---Layla, I'll be helping
PD with both FOIA requests. In December we requested an extension
of time on
From: Agustin Carbo-Lugo/R6/USEPA/US
To: Layla Mansuri/R6/USEPA/US@EPA
Date: 01/18/2011 10:11 AM
Subject: Fw: FOIA requests for the NM and OK FIPs
Layla,
I'll be helping PD with both FOIA requests. In December we
requested an extension of time on the OK FOIA and it appears it was
granted. This morning I had a meeting with PD and we will be
requesting to narrow the scope of the request. I should have more
information this afternoon. I'll get back to you.

Agustin F. Carbo-Lugo
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6-RC-M)
Dallas, TX 75202
Tel: (214) 665-8037
Fax: (214) 665-2182
----- Forwarded by Agustin Carbo-Lugo/R6/USEPA/US on 01/18/2011
10:07 AM -----
From: Lucinda Watson/R6/USEPA/US
To: Suzanne Smith/R6/USEPA/US@EPA, Ben Harrison/R6/USEPA/US@EPA
Cc: Agustin Carbo-Lugo/R6/USEPA/US@EPA, Yerusha
Beaver/R6/USEPA/US@EPA, Carrie Thomas/R6/USEPA/US@EPA
Date: 01/13/2011 04:40 PM
Subject: Re: Fw: FOIA requests for the NM and OK FIPs
OGC (Kevin and Geoff) and I think we need to assign Agustin and
Yerusha to handle the FOIA coordination for the NM and OK FIPs
documents.
It is my understanding that J oe worked with Richard Wessels and is
getting the LotusNotes links prepared for R6, RTP, and DC.
But we believe that we need a lawyer, e.g., Agustin, to call the
requestors and narrow the scope.
Agustin also could work with J oe to get the time estimates and work
with whomever in RTP and DC to get their time estimates.
Agustin and J oe could draft now the letter suspending the request
until we get a sufficient fee commitment.
Since it will be Agustin's first huge FOIA assignment, I am sure he will
need to turn to Yerusha for assistance.
OGC is willing to offer any legal assistance from their FOIA experts
since much of the information concerns business information,
contractor information, although I feel like Paul already has explained
EPA's position on these materials and PD seems to understand.
Re: Fw: FOIA requests for the NM and OK FIPs
FOIA Exemption (b)(5) - Deliberative Process Privilege
Re: Fw: FOIA requests for the NM and OK FIPs
Carrie Thomas to: Lucinda
Watson
01/13/2011 02:48 PM
Cc: Agustin Carbo-Lugo, Suzanne Smith, Yerusha Beaver
Hi Lucinda,
I agree with Geoff's comments.
For the original QF/FP FOIA, we did suspend the request in writing
until we were able to get a sufficient fee commitment from the
requestor ($10,000 for the R6 response). We suggested that amount
based on a cost estimate after we asked everyone with responsive
documents to guess how long it would take them to respond. We are
continuing to send rolling responses until we hit that amount, which
we are very close to doing. We are also going to contact the
requestor to ask if they would like to commit additional fees to cover
the remainder of the response and a denial log of what we are
withholding and why.
We also asked the requestor to narrow the scope, but they were
under no obligation to do so. They did, in fact, narrow it slightly
(hence the list of excluded records in the instructions e-mail).
Yerusha - correct me if I've misstated anything. Thanks,
Carrie K. Thomas
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 6
1445 Ross Ave. (6-RC-M)
Dallas, TX 75202
Tel: (214) 665-7121
Fax: (214) 665-2182
NOTICE: This communication may contain privileged or other
confidential information. If you are not the intended recipient, or
believe you have received this communication in error, please delete
the copy you received, and do not print, copy, re-transmit,
disseminate or otherwise use the information. Thank you.
Lucinda Watson---01/13/2011 12:49:49 PM---For the QF/FP FOIA, did
we first contact them to try to narrow the request? Next, did we send
a let
From: Lucinda Watson/R6/USEPA/US
To: Carrie Thomas/R6/USEPA/US@EPA, Suzanne
Smith/R6/USEPA/US@EPA
Cc: Agustin Carbo-Lugo/R6/USEPA/US@EPA
Date: 01/13/2011 12:49 PM
Subject: Fw: FOIA requests for the NM and OK FIPs
For the QF/FP FOIA, did we first contact them to try to narrow the
request?
Next, did we send a letter suspending our response until they agreed
to pay the estimated amount?
Of course, I cannot figure out how we would have an estimate until
everyone has finished their search for responsive documents?
Bottom line - how do I answer OGC's e-mail so we sound like we
know what we are doing?
----- Forwarded by Lucinda Watson/R6/USEPA/US on 01/13/2011
12:47 PM -----
Re: Fw: FOIA requests for the NM and OK FIPs
Geoffrey
Wilcox
to: Joe Kordzi 01/12/2011 05:22 PM
Cc: Lea Anderson, Todd Hawes, Kevin McLean, Lucinda
Watson, Agustin Carbo-Lugo
PRIVILEGED COMMUNICATION
J oe:
Let's have a chat about this topic.
Unless something has changed, my understanding is that there are
some standard protocols we usually follow in such FOIA requests.
One of the first steps is to alert the requestor that they need to
narrow their request because it is overbroad, and secondarily that it
will probably cost more than the amount of $ they agreed to pay.
Unless and until they respond to that, and tell us they will pay more,
we usally tell them in writing that we are suspending our response to
their request until they get back to us.
Lucinda and Augustin may have more recent experience than me in
dealing with such things.
If not, we may want to call one of the OGC FOIA gurus for a
consultation.
G
J oe Kordzi---01/12/2011 04:09:20 PM---yes thanks - I've called Mr.
Orkin to inform him I think the bill would exceed $500. He hasn't resp
From: Joe Kordzi/R6/USEPA/US
To: Lea Anderson/DC/USEPA/US@EPA
Cc: Geoffrey Wilcox/DC/USEPA/US@EPA, Todd
Hawes/RTP/USEPA/US@EPA
Date: 01/12/2011 04:09 PM
Subject: Re: Fw: FOIA requests for the NM and OK FIPs
yes thanks - I've called Mr. Orkin to inform him I think the bill would
exceed $500. He hasn't responded yet.
Regards,
FOIA Exemption (b)(5) - Deliberative Process Privilege
J oe
" ... and miles to go before I sleep."
-- Robert Frost
Lea Anderson---01/12/2011 02:13:06 PM---J oe, I assume (hopefully)
that we are at least charging the requestor for our search time?
Please
From: Lea Anderson/DC/USEPA/US
To: Joe Kordzi/R6/USEPA/US@EPA
Cc: Geoffrey Wilcox/DC/USEPA/US@EPA, Todd
Hawes/RTP/USEPA/US@EPA
Date: 01/12/2011 02:13 PM
Subject: Re: Fw: FOIA requests for the NM and OK FIPs
J oe,
I assume (hopefully) that we are at least charging the requestor for
our search time? Please let me know if I should keep track of the time
spend on the search.
thanks,
Lea
M. Lea Anderson
EPA Office of General Counsel
Phone: (202) 564-5571
J oe Kordzi---01/12/2011 01:58:30 PM---Welcome to my FOIAs. I will
separately send you some Lotus Notes buttons and instructions so you
ca
From: Joe Kordzi/R6/USEPA/US
To: Geoffrey Wilcox/DC/USEPA/US@EPA, Lea
Anderson/DC/USEPA/US@EPA, Todd Hawes/RTP/USEPA/US@EPA
Date: 01/12/2011 01:58 PM
Subject: Fw: FOIA requests for the NM and OK FIPs
Welcome to my FOIAs. I will separately send you some Lotus Notes
buttons and instructions so you can load your emails.
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
----- Forwarded by J oe Kordzi/R6/USEPA/US on 01/12/2011 12:52 PM
-----
From: Joe Kordzi/R6/USEPA/US
To: R6 6PD-L
Cc: Lucinda Watson/R6/USEPA/US@EPA, Agustin Carbo-
Lugo/R6/USEPA/US@EPA
Date: 01/04/2011 11:19 AM
Subject: FOIA requests for the NM and OK FIPs
Enclosed are two extensive FOIA requests. The first one is related to
our just proposed NM regional haze SIP-FIP, and mainly concerns the
San J uan Generating Station. The second one basically requests
everything we have concerning the OK regional haze SIP-FIP which we
are currently working on.
I looked into getting drop boxes set up for you to submit
your emails, but balked at the 33 page set of instructions that
accompanied it, and the lack of an easy, workable way to get those
emails to the requestor, so we will do it the old fashioned way. If you
have anything that is responsive, pls print it off and give it to me. If
that includes documents, pls put them on a CD and name them in
such a way the requestor will know which email they go with. I
cannot provide guidance on what can be released. According to ORC,
we should have all taken that training and are apparently on our
own. I'm sorry for not starting this earlier, but I was busy with the
FIPs and my efforts to get clarification/help on this didn't work out.
1. The due date for the NM FOIA was 12/30/10. This is the second
FOIA on this subject from the same person. A request has been made
to get an extension, but as before, the requestor has not been
responsive to that request. I think much of what is requested will
actually be in the docket in a day or so. However, you may have
emails that are responsive.
2. The due date for the OK regional haze SIP-FIP has been extended
to 1/15/11, but the requestor expected we would do a rolling
submittal, that for the reasons outlined above, didn't work out.
Therefore, pls also assume we are also late on this one as well.
Because we have not yet proposed our decision on this action, I
expect much of what is requested will not be able to be released, but
that if you to decide. Here is something that may help:
foia.navy.mil/Exemptionb5Slides.ppt
Pls have everything to me by noon, 1/ 11/ 11. If that's not
possible, pls let me know ASAP.
[attachment "SJ GS FOIA.pdf" deleted by Lea Anderson/DC/USEPA/US]
[attachment "OK SIP-FIP FOIA.pdf" deleted by Lea
Anderson/DC/USEPA/US]
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
From: Al Armendariz
To: Guy Donaldson
Cc: Thomas Diggs; Carl Edlund; Lawrence Starfield; Carl Young; Suzanne Smith; Lucinda Watson; Layla Mansuri;
Chrissy Mann
Subject: Re: Questions about Oklahoma's PM2.5 110 SIP
Date: 01/12/2011 11:19 PM
very very helpful.
Thanks Guy.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Guy Donaldson
----- Original Message -----
From: Guy Donaldson
Sent: 01/12/2011 11:15 PM CST
To: Al Armendariz
Cc: Thomas Diggs; Carl Edlund; Lawrence Starfield; Carl Young; Suzanne
Smith; Lucinda Watson
Subject: Questions about Oklahoma's PM2.5 110 SIP
Al,
You sent a note regarding the Notice of Intent to sue provided by Wild
Earth Guardians in response to us failing to put in place a FIP for
Oklahoma for the 110(a)(2) as triggered by the 1997 PM2.5 standard. You
asked what does Oklahoma need to do to get their SIP in order for PM2.5
and whether its a big deal or not? The answer is I dont think we know
for sure as yet but it might be.
110(a)(2) contains the infrastructure elements of the SIP. Interpreted
broadly, it can be read to mean that virtually any flaw in the SIP should be
corrected before we approve these SIPs.
In Oklahomas case, my initial impression is the biggest question will be
FOIA Exemption (b)(5) - Deliberative Process Privilege

We need to put our heads together and come up with a recommended
approach. We are currently trying to evaluate each States SIP against the
checklist and identify the issues and start figuring out appropriate
approaches. I would like to try to get a reasonably comprehensive picture
of what we are facing on the 110 SIPs in Region 6 before we come up with
recommendations for any one State. HQs is also trying to understand the
picture nationally as well.
I hope this helps. We will be talking to you more about these issues soon.
From: Al Armendariz
To: Carl Edlund; Guy Donaldson; Suzanne Murray
Subject: Fw: Request for Extension of Public Comment Period on Proposed Federal Implementation Plan - EPA-R06-
OAR-2010-0846 - San J uan Generating Station
Date: 01/06/2011 02:57 PM
Attachments: EPA-R06-OAR-2010-0846-PNM-Themig.PDF
____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
From: "Themig, Patrick" [Patrick.Themig@pnmresources.com]
Sent: 01/06/2011 01:06 PM MST
To: Al Armendariz
Subject: Request for Extension of Public Comment Period on Proposed Federal Implementation Plan -
EPA-R06-OAR-2010-0846 - San J uan Generating Station
The Hon. Alfred Armendariz
Regional Administrator, Region 6
United States Environmental Protection Agency
1445 Ross Avenue, Suite 1200
Dallas, Texas 75202

January 6, 2011

Honorable Dr. Armendariz:

Please find attached a letter requesting an extension of the Public Comment Period on
Proposed Federal Implementation Plan EPA-R06-OAR-2010-0846 on the San Juan
Generating Station.

Thank you for your time and personal attention to this request.


Patrick Themig
Vice President, Generation
PNM Resources, Inc.

From: Al Armendariz
To: Carl Edlund
Cc: David Gray; J oe Kordzi; Guy Donaldson; Thomas Diggs
Subject: Re: PNM is upset with part of the: press release
Date: 12/21/2010 03:26 PM
Thanks for the update.
And to J oe and the team -- thank you again for all the good work.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Carl Edlund
----- Original Message -----
From: Carl Edlund
Sent: 12/21/2010 03:20 PM CST
To: Al Armendariz
Cc: David Gray; Joe Kordzi; Guy Donaldson; Thomas Diggs
Subject: Fw: PNM is upset with part of the: press release
Here's their reaction....complying with haze rules will cost PSNM $230
million. The $330 that they cite was to satisfy suits that we weren't a
part of [e.g. low NOX burners, baghouses, and other improvements].
----- Forwarded by Carl Edlund/R6/USEPA/US on 12/21/2010 03:12 PM -----
From: J oe Kordzi/R6/USEPA/US
To: David Gray/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA
Date: 12/21/2010 02:40 PM
Subject: PNM is upset with part of the: press release
I really don't have a problem with the notice as it's written and don't
recommend we change it. As Ron Curry states, "We are disappointed
in PNM's shortsightedness in failing to plan to reduce its emissions in
accordance with long-standing federal requirements."
http://www.istockanalyst.com/article/viewiStockNews/articleid/4407596
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
----- Forwarded by J oe Kordzi/R6/USEPA/US on 12/21/2010 02:33 PM -----
From: "Gannon, Maureen" <Maureen.Gannon@pnmresources.com>
To: J oe Kordzi/R6/USEPA/US@EPA
Cc: "Norem, Nancy" <Nancy.Norem@pnmresources.com>
Date: 12/21/2010 01:31 PM
Subject: press release
Please note the language in bolded redit is very concerning that EPA would make
such a statement especially after we just completed a $330 M environmental pollution
control upgrade at SJGS.
EPA Proposes Two Major Actions to Improve New Mexicos
Environment
Moves will cleanup Molycorp Superfund Site and reduce air pollution from the
San Juan Generating Station Power Plant in San Juan County
(DALLAS December 21, 2010) The U.S. Environmental Protection Agency
(EPA) took two major actions that will bring significant environmental
benefits to the people of New Mexico. In the first action, EPA announced an
$500 million clean up plan for the Molycorp Superfund site near Questa. In
the second action, EPA announced a clean air plan which will significantly
protect public health and improve visibility by reducing pollution at a San Juan
County power plant.
EPAs first action is the clean up plan, formally known as a Record of
Decision (ROD), for the Molycorp, Inc., site. The Superfund site is owned by
Chevron Mining Inc. (CMI). The remedy selected by EPA includes the
excavation of contaminated soil and waste rocks, interception of water
draining from waste rock piles at the mine site, underground mine dewatering
and water treatment, covering contaminated material at the tailings facility,
and treating ground water at the tailings facility. EPA estimates the clean-up
will cost over $500 and could reach $800 million. Chevron Mining Inc. is
expected to carry out the clean-up.
The site includes an operational mine and milling facility, a tailing facility and
a tailing pipeline running from the mill to the tailing facility. Contaminated
material from the Molycorp site includes about 328 million tons of acid-
generating waste rock, over 100 million tons of tailing, and acid-rock drainage
at the mine and seepage at the tailing facility. The site is near Questa, New
Mexico.

EPAs second action is the Federal Implementation Plan proposed under the
Clean Air Act for the San Juan Generating Station power plant which will
significantly reduce harmful emissions and improve visibility and respiratory
health for the surrounding area. The plants operators will be required to
install the best pollution-control technology available for this type of facility,
which uses four coal-fired generating units. The controls are expected to
reduce emissions of nitrogen oxides (NOx) by approximately 83 percent.
Nitrogen oxides can react with other chemicals to form ozone and small
particles, both harmful to public health.
In addition to public health benefits, the reduced nitrogen oxides emissions
will also help improve visibility in the area by about 65 percent and decrease
by over 80 percent the numbers of days the plant causes noticeable visibility
impairment. The Plan would require San Juan Generating Station to install
and operate additional controls to reduce nitrogen oxides emissions. This
could be achieved through installation of selective catalytic reduction or other
similar technology on all four coal-fired generating units at the plant.
Selective catalytic reduction is a cost-effective technology and will bring
about the greatest improvements. EPA proposes that the plant have three years
to add the pollution controls.
EPA is protecting public health and improving scenic visibility under the
requirements of the Clean Air Act's Regional Haze program. This program
targets some of the oldest pollution sources in the country. The San Juan
Generating Station was constructed more than 30 years ago and has not
yet updated its pollution control technology to meet current air quality
goals. The San Juan Generating Station is the only source in New Mexico
covered by this action. Another nearby power plant on Navajo Lands was
covered by a different EPA action earlier this year.
Publication of the EPA proposal in the Federal Register begins a 60 day public
comment period. Additionally, EPA will hold a public hearing on the proposal
in Farmington, New Mexico. The public hearing will be announced at a later
date.
Upon publication in the Federal Register, additional information on the
proposed rulemaking and opportunities to provide input will be available at
http://regulations.gov (docket number EPA-R06-OAR-2010-0846). A copy is
immediately available at http://www.epa.gov/region6.
More about activities in EPA Region 6 is available at
http://www.epa.gov/region6
EPA audio file is available at
http://www.epa.gov/region6/6xa/podcast/dec2010.html
Maureen Gannon
Environmental Services
PNM Resources
(505) 241-2974 (work)
(505) 249-8301 (cell)
maureen.gannon@pnmresources.com
From: Al Armendariz
To: David Gray
Subject: Re: FINAL PR
Date: 12/21/2010 09:19 AM
Totally good. Let's rock and roll.

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
David Gray
----- Original Message -----
From: David Gray
Sent: 12/21/2010 09:10 AM CST
To: Al Armendariz
Subject: FINAL PR
Here is the final - unless you have any changes

FOIA Exemption (b)(5) - Deliberative Process Privilege





FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Al Armendariz
To: David Gray
Subject: Re: PA Proposes Two Major Actions to Improve New Mexicos Environment
Date: 12/20/2010 04:08 PM
He has a good point.


____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
David Gray
----- Original Message -----
From: David Gray
Sent: 12/20/2010 03:47 PM CST
To: Al Armendariz
Subject: Re: PA Proposes Two Major Actions to Improve New Mexicos
Environment
Al - here is Carl's comment in response to the new paragraph.
Thoughts?
David

Re: PA Proposes Two Major Actions to Improve New Mexicos Environment
Re: PA Proposes Two Major Actions to Improve New Mexicos
Environment
Al to: David Gray
12/20/2010
03:20 PM
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
Armendariz

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
David Gray
----- Original Message -----
From: David Gray
Sent: 12/20/2010 02:56 PM CST
To: Al Armendariz
Subject: PA Proposes Two Major Actions to Improve New
Mexicos Environment
Please give this version a quick read and comment. We plan to
announce today.
David
Near final pr -
FOIA Exemption (b)(5) - Deliberative Process Privilege






FOIA Exemption (b)(5) - Deliberative Process Privilege
From: David Gray
To: Al Armendariz; David Gray
Subject: NM draft PR 2
Date: 12/17/2010 09:12 AM
Al - here is the current draft. I will send to HQ today for Monday release.
David






FOIA Exemption (b)(5) - Deliberative Process Privilege




David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: David Gray
To: Al Armendariz
Subject: Re: New Mexico Visibility Federal Register Notice
Date: 12/20/2010 12:49 PM
I sent note to them for a time slot.
David Gray
Director
External and Government Affairs
US EPA
(214) 665-2200 office
(214) 789-2619 mobile
gray.david@epa.gov
Sent from Blackberry
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 12/20/2010 11:59 AM EST
To: David Gray
Cc: Carl Young; Cynthia Fanning; David Bary; "Guy Donaldson"
<donaldson.guy@epa.gov>; "Carl Edlund" <edlund.carl@epa.gov>;
Ellen Belk; Erik Snyder; Javier Balli; Joe Kordzi; Joseph
Hubbard; LaWanda Thomas; Lawrence Starfield; Michael Feldman;
Thomas Diggs
Subject: Re: New Mexico Visibility Federal Register Notice
Ok - Let's have Sam sign the FR and then the packet can be sent up to
DC.
David - when would you like to try and call both NMED and the gov-
elect? Gov Richardson is in Asia I believe.
I am free of meetings and calls all afternoon.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
David Gray
----- Original Message -----
From: David Gray
Sent: 12/20/2010 10:32 AM CST
To: Al Armendariz
Cc: Carl Young; Cynthia Fanning; David Bary; "Guy Donaldson"
<donaldson.guy@epa.gov>; "Carl Edlund" <edlund.carl@epa.gov>;
Ellen Belk; Erik Snyder; Javier Balli; Joe Kordzi; Joseph
Hubbard; LaWanda Thomas; Lawrence Starfield; Michael Feldman;
Thomas Diggs
Subject: Re: New Mexico Visibility Federal Register Notice
Al,
Sam C. is acting today. It is probably easiest to have him sign the FR
as acting RA.
David
Re: New Mexico Visibility Federal Register Notice
Re: New Mexico Visibility Federal Register Notice
Al
Armendariz
to: Carl Young, David Gray
12/20/2010
09:07 AM
Cc: "Guy Donaldson", "Carl Edlund", J avier Balli, J oe Kordzi, Lawrence Starfield, Thomas
Diggs, Cynthia Fanning, David Bary, Ellen Belk, J oseph Hubbard, LaWanda Thomas,
Michael Feldman, Erik Snyder
From: Al Armendariz/R6/USEPA/US
To: Carl Young/R6/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA
Cc: "Guy Donaldson" <donaldson.guy@epa.gov>, "Carl Edlund" <edlund.carl@epa.gov>, J avier
Balli/R6/USEPA/US@EPA, J oe Kordzi/R6/USEPA/US@EPA, Lawrence
Starfield/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA, Cynthia
Fanning/R6/USEPA/US@EPA, David Bary/R6/USEPA/US@EPA, Ellen Belk/R6/USEPA/US@EPA,
J oseph Hubbard/R6/USEPA/US@EPA, LaWanda Thomas/R6/USEPA/US@EPA, Michael
Feldman/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA
Carl, David, and Carl,
I am in El Paso today, so we have a couple of options for signature.
The easiest is to have the acting RA (Carl?) sign.
Or, I can print the FIP here in El Paso, sign it, and get it mailed to HQ.
Or, I can print only the signature page, and email to you a pdf of it.
Lots of options. No preference on my end.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Carl Young
----- Original Message -----
From: Carl Young
Sent: 12/20/2010 09:02 AM CST
To: David Gray
Cc: Al Armendariz; "Guy Donaldson" <donaldson.guy@epa.gov>;
"Carl Edlund" <edlund.carl@epa.gov>; Javier Balli; Joe Kordzi;
Lawrence Starfield; Thomas Diggs; Cynthia Fanning; David Bary;
Ellen Belk; Joseph Hubbard; LaWanda Thomas; Michael Feldman; Joe
Kordzi; Erik Snyder
Subject: Re: New Mexico Visibility Federal Register Notice
Hi David,
Attached is a Word document of the Federal Register proposal for the
San J uan Generating Station Federal Implementation Plan that is to be
signed. The paper copy is with your office.
We would need the original signed document to send to HQ.
Carl
Carl Young
EPA Region 6 Air Planning Section
214-665-6645
[attachment "FRN NM Vis BART FIP for RA signature 12 17 10.doc"
deleted by Al Armendariz/R6/USEPA/US]
Carl Edlund---12/16/2010 09:28:08 AM---No ..I think that would be a great idea
to package these two ...the final haze package should route
From: Carl Edlund/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA
Cc: Carl Young/R6/USEPA/US@EPA, "Guy Donaldson" <donaldson.guy@epa.gov>, "Carl Edlund"
<edlund.carl@epa.gov>, J avier Balli/R6/USEPA/US@EPA, J oe Kordzi/R6/USEPA/US@EPA, Lawrence
Starfield/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA
Date: 12/16/2010 09:28 AM
Subject: Re: New Mexico Visibility Federal Register Notice
No ..I think that would be a great idea to package these two ...the
final haze package should route through me today.
Al Armendariz---12/15/2010 09:18:21 PM---Hi Carl -- in order to properly discuss
the issue with the incoming gov-elect and to help coordinate
From: Al Armendariz/R6/USEPA/US
To: "Carl Edlund" <edlund.carl@epa.gov>, "Guy Donaldson" <donaldson.guy@epa.gov>
Cc: Carl Young/R6/USEPA/US@EPA, J avier Balli/R6/USEPA/US@EPA, J oe Kordzi/R6/USEPA/US@EPA,
Lawrence Starfield/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA
Date: 12/15/2010 09:18 PM
Subject: Re: New Mexico Visibility Federal Register Notice
Hi Carl -- in order to properly discuss the issue with the incoming gov-
elect and to help coordinate messaging with the Molycorp ROD, David
and I discussed having me sign the NM FIP on Monday. Please let me
know if there is a good reason not to do this. Thanks to you, Guy, and
the rest of the team.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Guy Donaldson
----- Original Message -----
From: Guy Donaldson
Sent: 12/15/2010 02:11 PM CST
To: Al Armendariz
Cc: Carl Edlund; Carl Young; Javier Balli; Joe Kordzi;
Lawrence Starfield; Thomas Diggs
Subject: Re: New Mexico Visibility Federal Register Notice
The WEG date is December 22. However as we discussed, we are
targeting signature and roll out for Friday the 17th.
Al Armendariz---12/15/2010 02:05:59 PM---Thank you. What is the WEG-
settlement deadline for signature?
From: Al Armendariz/R6/USEPA/US
To: Carl Young/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, Carl
Edlund/R6/USEPA/US@EPA
Cc: Thomas Diggs/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, J oe
Kordzi/R6/USEPA/US@EPA, J avier Balli/R6/USEPA/US@EPA
Date: 12/15/2010 02:05 PM
Subject: Re: New Mexico Visibility Federal Register Notice
Thank you.
What is the WEG-settlement deadline for signature?
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Carl Young
----- Original Message -----
From: Carl Young
Sent: 12/15/2010 01:59 PM CST
To: Al Armendariz; Lawrence Starfield; Carl Edlund
Cc: Thomas Diggs; Guy Donaldson; Joe Kordzi; Javier Balli
Subject: New Mexico Visibility Federal Register Notice
Attached please find the notice being routed for concurrence.
Carl
Carl Young
EPA Region 6 Air Planning Section
214-665-6645
[attachment "NM Vis BART FIP FRN w GDonaldson concurrence 12 15
10.doc" deleted by Al Armendariz/R6/USEPA/US]
From: J oe Kordzi
To: Al Armendariz
Cc: Carl Young; Cynthia Fanning; David Bary; David Gray; Guy Donaldson; Carl Edlund; Ellen Belk; Erik Snyder;
J avier Balli; J oseph Hubbard; LaWanda Thomas; Lawrence Starfield; Michael Feldman; Thomas Diggs; Cary
Martindale
Subject: Re: New Mexico Visibility Federal Register Notice
Date: 12/20/2010 09:22 AM
Hi Al,
My own preference is for you to sign it and pdf it back to us so we can email out
signed copies. You could then pouch mail the original back to us via the El Paso
office. If David Gray has another preference, that would be fine.
Regards,
J oe
" ... and miles to go before I sleep."
-- Robert Frost
Al Armendariz---12/20/2010 09:07:32 AM---Carl, David, and Carl, I am in El Paso
today, so we have a couple of options for signature. The easi
From: Al Armendariz/R6/USEPA/US
To: Carl Young/R6/USEPA/US@EPA, David Gray/R6/USEPA/US@EPA
Cc: "Guy Donaldson" <donaldson.guy@epa.gov>, "Carl Edlund" <edlund.carl@epa.gov>, J avier
Balli/R6/USEPA/US@EPA, J oe Kordzi/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA,
Thomas Diggs/R6/USEPA/US@EPA, Cynthia Fanning/R6/USEPA/US@EPA, David
Bary/R6/USEPA/US@EPA, Ellen Belk/R6/USEPA/US@EPA, J oseph Hubbard/R6/USEPA/US@EPA,
LaWanda Thomas/R6/USEPA/US@EPA, Michael Feldman/R6/USEPA/US@EPA, Erik
Snyder/R6/USEPA/US@EPA
Date: 12/20/2010 09:07 AM
Subject: Re: New Mexico Visibility Federal Register Notice
Carl, David, and Carl,
I am in El Paso today, so we have a couple of options for signature.
The easiest is to have the acting RA (Carl?) sign.
Or, I can print the FIP here in El Paso, sign it, and get it mailed to HQ.
Or, I can print only the signature page, and email to you a pdf of it.
Lots of options. No preference on my end.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
twitter: @al_armendariz
Carl Young
----- Original Message -----
From: Carl Young
Sent: 12/20/2010 09:02 AM CST
To: David Gray
Cc: Al Armendariz; "Guy Donaldson" <donaldson.guy@epa.gov>;
"Carl Edlund" <edlund.carl@epa.gov>; Javier Balli; Joe Kordzi;
Lawrence Starfield; Thomas Diggs; Cynthia Fanning; David Bary;
Ellen Belk; Joseph Hubbard; LaWanda Thomas; Michael Feldman; Joe
Kordzi; Erik Snyder
Subject: Re: New Mexico Visibility Federal Register Notice
Hi David,
Attached is a Word document of the Federal Register proposal for the
San J uan Generating Station Federal Implementation Plan that is to be
signed. The paper copy is with your office.
We would need the original signed document to send to HQ.
Carl
Carl Young
EPA Region 6 Air Planning Section
214-665-6645
[attachment "FRN NM Vis BART FIP for RA signature 12 17 10.doc"
deleted by Al Armendariz/R6/USEPA/US]
Carl Edlund---12/16/2010 09:28:08 AM---No ..I think that would be a great idea
to package these two ...the final haze package should route
From: Carl Edlund/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA
Cc: Carl Young/R6/USEPA/US@EPA, "Guy Donaldson" <donaldson.guy@epa.gov>, "Carl Edlund"
<edlund.carl@epa.gov>, J avier Balli/R6/USEPA/US@EPA, J oe Kordzi/R6/USEPA/US@EPA, Lawrence
Starfield/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA
Date: 12/16/2010 09:28 AM
Subject: Re: New Mexico Visibility Federal Register Notice
No ..I think that would be a great idea to package these two ...the
final haze package should route through me today.
Al Armendariz---12/15/2010 09:18:21 PM---Hi Carl -- in order to properly discuss
the issue with the incoming gov-elect and to help coordinate
From: Al Armendariz/R6/USEPA/US
To: "Carl Edlund" <edlund.carl@epa.gov>, "Guy Donaldson" <donaldson.guy@epa.gov>
Cc: Carl Young/R6/USEPA/US@EPA, J avier Balli/R6/USEPA/US@EPA, J oe Kordzi/R6/USEPA/US@EPA,
Lawrence Starfield/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA
Date: 12/15/2010 09:18 PM
Subject: Re: New Mexico Visibility Federal Register Notice
Hi Carl -- in order to properly discuss the issue with the incoming gov-
elect and to help coordinate messaging with the Molycorp ROD, David
and I discussed having me sign the NM FIP on Monday. Please let me
know if there is a good reason not to do this. Thanks to you, Guy, and
the rest of the team.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Guy Donaldson
----- Original Message -----
From: Guy Donaldson
Sent: 12/15/2010 02:11 PM CST
To: Al Armendariz
Cc: Carl Edlund; Carl Young; Javier Balli; Joe Kordzi;
Lawrence Starfield; Thomas Diggs
Subject: Re: New Mexico Visibility Federal Register Notice
The WEG date is December 22. However as we discussed, we are
targeting signature and roll out for Friday the 17th.
Al Armendariz---12/15/2010 02:05:59 PM---Thank you. What is the WEG-
settlement deadline for signature?
From: Al Armendariz/R6/USEPA/US
To: Carl Young/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, Carl
Edlund/R6/USEPA/US@EPA
Cc: Thomas Diggs/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, J oe
Kordzi/R6/USEPA/US@EPA, J avier Balli/R6/USEPA/US@EPA
Date: 12/15/2010 02:05 PM
Subject: Re: New Mexico Visibility Federal Register Notice
Thank you.
What is the WEG-settlement deadline for signature?
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Carl Young
----- Original Message -----
From: Carl Young
Sent: 12/15/2010 01:59 PM CST
To: Al Armendariz; Lawrence Starfield; Carl Edlund
Cc: Thomas Diggs; Guy Donaldson; Joe Kordzi; Javier Balli
Subject: New Mexico Visibility Federal Register Notice
Attached please find the notice being routed for concurrence.
Carl
Carl Young
EPA Region 6 Air Planning Section
214-665-6645
[attachment "NM Vis BART FIP FRN w GDonaldson concurrence 12 15
10.doc" deleted by Al Armendariz/R6/USEPA/US]
From: Carl Young
To: David Gray
Cc: Al Armendariz; Guy Donaldson; Carl Edlund; J avier Balli; J oe Kordzi; Lawrence Starfield; Thomas Diggs;
Cynthia Fanning; David Bary; Ellen Belk; J oseph Hubbard; LaWanda Thomas; Michael Feldman; J oe Kordzi; Erik
Snyder
Subject: Re: New Mexico Visibility Federal Register Notice
Date: 12/20/2010 09:02 AM
Attachments: FRN NM Vis BART FIP for RA signature 12 17 10.doc
Hi David,
Attached is a Word document of the Federal Register proposal for the San J uan
Generating Station Federal Implementation Plan that is to be signed. The paper
copy is with your office.
We would need the original signed document to send to HQ.
Carl
Carl Young
EPA Region 6 Air Planning Section
214-665-6645
Carl Edlund---12/16/2010 09:28:08 AM---No ..I think that would be a great idea
to package these two ...the final haze package should route
From: Carl Edlund/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA
Cc: Carl Young/R6/USEPA/US@EPA, "Guy Donaldson" <donaldson.guy@epa.gov>, "Carl Edlund"
<edlund.carl@epa.gov>, J avier Balli/R6/USEPA/US@EPA, J oe Kordzi/R6/USEPA/US@EPA, Lawrence
Starfield/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA
Date: 12/16/2010 09:28 AM
Subject: Re: New Mexico Visibility Federal Register Notice
No ..I think that would be a great idea to package these two ...the final haze
package should route through me today.
Al Armendariz---12/15/2010 09:18:21 PM---Hi Carl -- in order to properly discuss
the issue with the incoming gov-elect and to help coordinate
From: Al Armendariz/R6/USEPA/US
To: "Carl Edlund" <edlund.carl@epa.gov>, "Guy Donaldson" <donaldson.guy@epa.gov>
Cc: Carl Young/R6/USEPA/US@EPA, J avier Balli/R6/USEPA/US@EPA, J oe Kordzi/R6/USEPA/US@EPA,
Lawrence Starfield/R6/USEPA/US@EPA, Thomas Diggs/R6/USEPA/US@EPA
Date: 12/15/2010 09:18 PM
Subject: Re: New Mexico Visibility Federal Register Notice
Hi Carl -- in order to properly discuss the issue with the incoming gov-
elect and to help coordinate messaging with the Molycorp ROD, David
and I discussed having me sign the NM FIP on Monday. Please let me
know if there is a good reason not to do this. Thanks to you, Guy, and
the rest of the team.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Guy Donaldson
----- Original Message -----
From: Guy Donaldson
Sent: 12/15/2010 02:11 PM CST
To: Al Armendariz
Cc: Carl Edlund; Carl Young; Javier Balli; Joe Kordzi;
Lawrence Starfield; Thomas Diggs
Subject: Re: New Mexico Visibility Federal Register Notice
The WEG date is December 22. However as we discussed, we are targeting
signature and roll out for Friday the 17th.
Al Armendariz---12/15/2010 02:05:59 PM---Thank you. What is the WEG-
settlement deadline for signature?
From: Al Armendariz/R6/USEPA/US
To: Carl Young/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, Carl
Edlund/R6/USEPA/US@EPA
Cc: Thomas Diggs/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, J oe
Kordzi/R6/USEPA/US@EPA, J avier Balli/R6/USEPA/US@EPA
Date: 12/15/2010 02:05 PM
Subject: Re: New Mexico Visibility Federal Register Notice
Thank you.
What is the WEG-settlement deadline for signature?
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Carl Young
----- Original Message -----
From: Carl Young
Sent: 12/15/2010 01:59 PM CST
To: Al Armendariz; Lawrence Starfield; Carl Edlund
Cc: Thomas Diggs; Guy Donaldson; Joe Kordzi; Javier Balli
Subject: New Mexico Visibility Federal Register Notice
Attached please find the notice being routed for concurrence.
Carl
Carl Young
EPA Region 6 Air Planning Section
214-665-6645
[attachment "NM Vis BART FIP FRN w GDonaldson concurrence 12 15
10.doc" deleted by Al Armendariz/R6/USEPA/US]
From: Gina McCarthy
To: Al Armendariz
Subject: Re: New Mexico Visibility Federal Register Notice
Date: 12/15/2010 11:35 PM
Thx Al. Let me know if we can help.
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 12/15/2010 10:30 PM EST
To: "Gina McCarthy" <mccarthy.gina@epa.gov>; "Janet McCabe"
<mccabe.janet@epa.gov>
Cc: "Carl Edlund" <edlund.carl@epa.gov>; "David Gray"
<gray.david@epa.gov>; Jared Blumenfeld; Seth Oster
Subject: Fw: New Mexico Visibility Federal Register Notice
Hi Gina,
Best
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Guy Donaldson
----- Original Message -----
From: Guy Donaldson
Sent: 12/15/2010 02:11 PM CST
To: Al Armendariz
Cc: Carl Edlund; Carl Young; Javier Balli; Joe Kordzi;
Lawrence Starfield; Thomas Diggs
Subject: Re: New Mexico Visibility Federal Register Notice
The WEG date is December 22. However as we discussed, we are
targeting signature and roll out for Friday the 17th.
FOIA Exemption (b)(5) - Deliberative Process Privilege
Al Armendariz---12/15/2010 02:05:59 PM---Thank you. What is the WEG-
settlement deadline for signature?
From: Al Armendariz/R6/USEPA/US
To: Carl Young/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, Carl
Edlund/R6/USEPA/US@EPA
Cc: Thomas Diggs/R6/USEPA/US@EPA, Guy Donaldson/R6/USEPA/US@EPA, J oe
Kordzi/R6/USEPA/US@EPA, J avier Balli/R6/USEPA/US@EPA
Date: 12/15/2010 02:05 PM
Subject: Re: New Mexico Visibility Federal Register Notice
Thank you.
What is the WEG-settlement deadline for signature?
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Carl Young
----- Original Message -----
From: Carl Young
Sent: 12/15/2010 01:59 PM CST
To: Al Armendariz; Lawrence Starfield; Carl Edlund
Cc: Thomas Diggs; Guy Donaldson; Joe Kordzi; Javier Balli
Subject: New Mexico Visibility Federal Register Notice
Attached please find the notice being routed for concurrence.
Carl
Carl Young
EPA Region 6 Air Planning Section
214-665-6645
[attachment "NM Vis BART FIP FRN w GDonaldson concurrence 12 15
10.doc" deleted by Al Armendariz/R6/USEPA/US]
From: Lawrence Starfield
To: Al Armendariz
Subject: Re: Couple of things
Date: 12/04/2010 04:42 PM
1) Great news about J eremy -- I'm glad you two talked.
2) Yes, let's discuss the awards. Good point.
3) What can I say -- we live in a strange world....
Couple of things
Couple of things
Al
Armendariz
to: Larry Starfield
12/03/2010
09:19 PM
(1) Chrissy and I spoke to J eremy Nichols at WildEarth Guardians.
(2) Next week, can you work with me to get the special act award
paperwork processed? I'd like to move before awards potentially get
cut under budget pressures.
I think I get it.

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
FOIA Ex
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Chrissy Mann
To: Al Armendariz/R6/USEPA/US@EPA
Subject: Re: Fw: San J uan Generating Station Title V Petition
Date: 12/02/2010 03:44 PM
I have us at 4:30 CST, 3:30 MST tomorrow Friday December 3rd with J eremy.
Your posted Agenda looked free, but I don't have access to your calendar.
Let me know if this works and I'll confirm with him.
Chrissy Mann
Special Assistant to the Regional Administrator
EPA Region 6
214-665-7295
mann.chrissy@epa.gov
Al Armendariz---12/02/2010 03:13:08 PM---Hi Chrissy, Can you reach out to jeremy
and see if there is a time Friday where he and I can talk ab
From: Al Armendariz/R6/USEPA/US
To: Chrissy Mann/R6/USEPA/US@EPA
Date: 12/02/2010 03:13 PM
Subject: Fw: San J uan Generating Station Title V Petition
Hi Chrissy,
Can you reach out to jeremy and see if there is a time Friday where he
and I can talk about SJ GS?
Thanks
Al
______________________
Al Armendariz
Regional Administrator
Environmental Protection Agency
Region 6
Dallas, Texas
armendariz.al@epa.gov
office: 214-665-2100
----- Forwarded by Al Armendariz/R6/USEPA/US on 12/02/2010 03:12 PM -----
From: J eremy Nichols <jnichols@wildearthguardians.org>
To: LisaP J ackson/DC/USEPA/US@EPA
Cc: "Uhl, Mary, NMENV" <mary.uhl@state.nm.us>, "Kimbrell, J oseph, NMENV"
<joseph.kimbrell@state.nm.us>, Al Armendariz/R6/USEPA/US@EPA, J effrey
Robinson/R6/USEPA/US@EPA, Mike Eisenfeld <meisenfeld@frontier.net>, joanie berde
<joanieberde@yahoo.com>
Date: 11/19/2010 04:02 PM
Subject: San J uan Generating Station Title V Petition
Dear Administrator Jackson:
Attached, please find a petition from WildEarth Guardians, San Juan Citizens
Alliance, and Carson Forest Watch requesting the Administrator object to the
Title V Permit proposed to be issued by the State of New Mexico for Public
Service Company of New Mexico to operate the San Juan Generating Station in
San Juan County, New Mexico. Also attached are Exhibits 1-9 of that petition.
Hard copies are being sent via certified mail, return receipt requested, to the
Administrator, the Regional Administrator, the State of New Mexico, and the
permittee. Thank you.
Jeremy Nichols.
--
Jeremy Nichols
Climate and Energy Program Director
WildEarth Guardians
1536 Wynkoop, Suite 301 - Denver, CO 80202
303-573-4898 x 1303
www.wildearthguardians.org
Read my blog on the Huffington Post http://www.huffingtonpost.com/jeremy-
nichols/
Join our e-mail list today http://wg.convio.net/site/Survey?
ACTION_REQUIRED=URI_ACTION_USER_REQUESTS&SURVEY_ID=1241
WildEarth Guardians has earned a Four Star rating from Charity Navigator.
View our profile http://www.charitynavigator.org/index.cfm?
bay=search.summary&orgid=9974[attachment "Exhibit 1 - PERMIT_Proposed
(P062R2)markup.pdf" deleted by Al Armendariz/R6/USEPA/US] [attachment
"Exhibit 2 - SOB(P062R2-AR2).pdf" deleted by Al Armendariz/R6/USEPA/US]
[attachment "Exhibit 3 - Joe Kimbrell E-mail.pdf" deleted by Al
Armendariz/R6/USEPA/US] [attachment "Exhibit 4 - 2010-5-7 WG Comments
San Juan GS Title V.pdf" deleted by Al Armendariz/R6/USEPA/US] [attachment
"Exhibit 5 - ROC-09-15-10(P062R2)-1.pdf" deleted by Al
Armendariz/R6/USEPA/US] [attachment "Exhibit 6 - PNM- San Juan
Generating Station.pdf" deleted by Al Armendariz/R6/USEPA/US] [attachment
"Exhibit 7 - Reply to ROC-10-29-10(P062R2).pdf" deleted by Al
Armendariz/R6/USEPA/US] [attachment "Exhibit 8 - SJGS NMED Response to
WE Guardians comments_080410-2.pdf" deleted by Al
Armendariz/R6/USEPA/US] [attachment "Exhibit 9 - 2005_5-
10_San_Juan_final_decree_as_entered.pdf" deleted by Al
Armendariz/R6/USEPA/US] [attachment "2010-11-19 WG San Juan GS Title V
Petition.pdf" deleted by Al Armendariz/R6/USEPA/US]
From: Thomas Diggs
To: Al Armendariz; Carl Edlund
Cc: J effrey Robinson; Catherine Penland
Subject: Re: Fw: San J uan Generating Station Title V Petition
Date: 11/19/2010 04:36 PM
Al and Carl:
Thanks for getting the petition to us this afternoon on the San J uan Generating Station
Title V. I can tell from the materials J eremy attached that Catherine Penland, the New
Mexico Air Permit coordinator, is well aware of this project and has given comments to
NMED as well. We will be informing Headquarters and including this in line with the
other Title V petitions in the que.
Tom
Al Armendariz---11/19/2010 04:21:19 PM---
From: Al Armendariz/R6/USEPA/US
To: "Carl Edlund" <edlund.carl@epa.gov>, Thomas Diggs/R6/USEPA/US@EPA
Date: 11/19/2010 04:21 PM
Subject: Fw: San J uan Generating Station Title V Petition
____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
From: Jeremy Nichols [jnichols@wildearthguardians.org]
Sent: 11/19/2010 02:59 PM MST
To: LisaP Jackson
Cc: "Uhl, Mary, NMENV" <mary.uhl@state.nm.us>; "Kimbrell, Joseph,
NMENV" <joseph.kimbrell@state.nm.us>; Al Armendariz; Jeffrey Robinson;
Mike Eisenfeld <meisenfeld@frontier.net>; joanie berde
<joanieberde@yahoo.com>
Subject: San Juan Generating Station Title V Petition
Dear Administrator Jackson:
Attached, please find a petition from WildEarth Guardians, San Juan Citizens
Alliance, and Carson Forest Watch requesting the Administrator object to the
Title V Permit proposed to be issued by the State of New Mexico for Public
Service Company of New Mexico to operate the San Juan Generating Station in
San Juan County, New Mexico. Also attached are Exhibits 1-9 of that petition.
Hard copies are being sent via certified mail, return receipt requested, to the
Administrator, the Regional Administrator, the State of New Mexico, and the
permittee. Thank you.
Jeremy Nichols.
--
Jeremy Nichols
Climate and Energy Program Director
WildEarth Guardians
1536 Wynkoop, Suite 301 - Denver, CO 80202
303-573-4898 x 1303
www.wildearthguardians.org
Read my blog on the Huffington Post http://www.huffingtonpost.com/jeremy-
nichols/
Join our e-mail list today http://wg.convio.net/site/Survey?
ACTION_REQUIRED=URI_ACTION_USER_REQUESTS&SURVEY_ID=1241
WildEarth Guardians has earned a Four Star rating from Charity Navigator.
View our profile http://www.charitynavigator.org/index.cfm?
bay=search.summary&orgid=9974[attachment "Exhibit 1 - PERMIT_Proposed
(P062R2)markup.pdf" deleted by Thomas Diggs/R6/USEPA/US] [attachment
"Exhibit 2 - SOB(P062R2-AR2).pdf" deleted by Thomas Diggs/R6/USEPA/US]
[attachment "Exhibit 3 - Joe Kimbrell E-mail.pdf" deleted by Thomas
Diggs/R6/USEPA/US] [attachment "Exhibit 4 - 2010-5-7 WG Comments San
Juan GS Title V.pdf" deleted by Thomas Diggs/R6/USEPA/US] [attachment
"Exhibit 5 - ROC-09-15-10(P062R2)-1.pdf" deleted by Thomas
Diggs/R6/USEPA/US] [attachment "Exhibit 6 - PNM- San Juan Generating
Station.pdf" deleted by Thomas Diggs/R6/USEPA/US] [attachment "Exhibit 7 -
Reply to ROC-10-29-10(P062R2).pdf" deleted by Thomas
Diggs/R6/USEPA/US] [attachment "Exhibit 8 - SJGS NMED Response to WE
Guardians comments_080410-2.pdf" deleted by Thomas Diggs/R6/USEPA/US]
[attachment "Exhibit 9 - 2005_5-10_San_Juan_final_decree_as_entered.pdf"
deleted by Thomas Diggs/R6/USEPA/US] [attachment "2010-11-19 WG San
Juan GS Title V Petition.pdf" deleted by Thomas Diggs/R6/USEPA/US]
From: Al Armendariz
To: Larry Starfield; Suzanne Murray
Subject: Fw: San J uan Generating Station Title V Petition
Date: 11/19/2010 04:15 PM
Attachments: Exhibit 1 - PERMIT Proposed (P062R2)markup.pdf
Exhibit 2 - SOB(P062R2-AR2).pdf
Exhibit 3 - J oe Kimbrell E-mail.pdf
Exhibit 4 - 2010-5-7 WG Comments San J uan GS Title V.pdf
Exhibit 5 - ROC-09-15-10(P062R2)-1.pdf
Exhibit 6 - PNM- San J uan Generating Station.pdf
Exhibit 7 - Reply to ROC-10-29-10(P062R2).pdf
Exhibit 8 - SJ GS NMED Response to WE Guardians comments 080410-2.pdf
Exhibit 9 - 2005 5-10 San J uan final decree as entered.pdf
2010-11-19 WG San J uan GS Title V Petition.pdf
____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
From: J eremy Nichols [jnichols@wildearthguardians.org]
Sent: 11/19/2010 02:59 PM MST
To: LisaP J ackson
Cc: "Uhl, Mary, NMENV" <mary.uhl@state.nm.us>; "Kimbrell, J oseph, NMENV"
<joseph.kimbrell@state.nm.us>; Al Armendariz; J effrey Robinson; Mike Eisenfeld
<meisenfeld@frontier.net>; joanie berde <joanieberde@yahoo.com>
Subject: San J uan Generating Station Title V Petition
Dear Administrator J ackson:
Attached, please find a petition from WildEarth Guardians, San J uan Citizens Alliance,
and Carson Forest Watch requesting the Administrator object to the Title V Permit
proposed to be issued by the State of New Mexico for Public Service Company of
New Mexico to operate the San J uan Generating Station in San J uan County, New
Mexico. Also attached are Exhibits 1-9 of that petition. Hard copies are being sent
via certified mail, return receipt requested, to the Administrator, the Regional
Administrator, the State of New Mexico, and the permittee. Thank you.
J eremy Nichols.
--
J eremy Nichols
Climate and Energy Program Director
WildEarth Guardians
1536 Wynkoop, Suite 301 - Denver, CO 80202
303-573-4898 x 1303
www.wildearthguardians.org
Read my blog on the Huffington Post http://www.huffingtonpost.com/jeremy-
FOIA Exemption (b)(5) - Deliberative Process Privilege
nichols/
J oin our e-mail list today http://wg.convio.net/site/Survey?
ACTION_REQUIRED=URI_ACTION_USER_REQUESTS&SURVEY_ID=1241
WildEarth Guardians has earned a Four Star rating from Charity Navigator. View our
profile http://www.charitynavigator.org/index.cfm?bay=search.summary&orgid=9974
From: Suzanne Murray
To: Rich Ossias
Bcc: Al Armendariz
Subject: Time sensitive
Date: 11/23/2010 03:58 PM
Rich,
My staff tells me
I sent you a note seeing if we could meet mid-December. Can you let me know
what OGC is requesting from the Region on ghg and then let's talk next week?
Have a safe and Happy Thanksgiving.
Suzanne
Suzanne Murray, Regional Counsel, R6
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Al Armendariz
To: Chrissy Mann
Subject: Re: New Mexico SIP
Date: 11/09/2010 03:44 PM
Thanks.

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Chrissy Mann
----- Original Message -----
From: Chrissy Mann
Sent: 11/09/2010 03:20 PM CST
To: Al Armendariz; Lawrence Starfield
Subject: New Mexico SIP
My summary has not changed. In the response to comments, EPA is
maintaining its ability to choose an alternative method to define
maintenance, identify maintenance areas, and choose an attainment
date of 2012 to determine whether the area is appropriately identified
as a maintenance area. The method chosen is consistent with the
methodology in the Transport rule. The clean, final version is
attached. A hard copy is available for Larry's signature tomorrow.

[attachment "The NM Transport SIP Final FRN 11 9 10.doc" deleted by Al
Armendariz/R6/USEPA/US]
Chrissy Mann
Special Assistant to the Regional Administrator
EPA Region 6
214-665-7295
mann.chrissy@epa.gov
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Chrissy Mann
To: Al Armendariz/R6/USEPA/US@EPA; Lawrence Starfield/R6/USEPA/US@EPA
Subject: New Mexico SIP
Date: 11/09/2010 03:21 PM
Attachments: The NM Transport SIP Final FRN 11 9 10.doc
My summary has not changed. In the response to comments, EPA is maintaining its
ability to choose an alternative method to define maintenance, identify maintenance
areas, and choose an attainment date of 2012 to determine whether the area is
appropriately identified as a maintenance area. The method chosen is consistent with
the methodology in the Transport rule. The clean, final version is attached. A hard
copy is available for Larry's signature tomorrow.
Chrissy Mann
Special Assistant to the Regional Administrator
EPA Region 6
214-665-7295
mann.chrissy@epa.gov
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Lawrence Starfield
To: Al Armendariz
Cc: Michael Barra
Subject: Re: IMPORTANT - new Complaint for infrastructure SIPs for 1997 8-hour ozone NAAQS - information needed
for CD negotiation
Date: 11/07/2010 10:06 AM
Al,
I did check with Mike. We agree that you can work on the infrastructure SIP and
decide the substantive issue of SIP approval/disapproval (since it's a matter of
general applicability). However, we believe that you are recused from involvement
in the resolution of the deadline suit because it is a particular matter involving Sierra
Club.
Let us know if you'd like to discuss.
Larry
Re: IMPORTANT - new Complaint for infrastructure SIPs for 1997 8-hour ozone
NAAQS - information needed for CD negotiation
Re: IMPORTANT - new Complaint for infrastructure SIPs for 1997
8-hour ozone NAAQS - information needed for CD negotiation
Al
Armendariz
to: Lawrence Starfield
11/04/2010
06:25 PM
Please check with Mike B and J ustina. The infrastructure SIPs are a
matter of "general applicability". If needed, I can call J eremy at WEG
and grab R6 an extended deadline.

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Lawrence Starfield
----- Original Message -----
From: Lawrence Starfield
Sent: 11/04/2010 06:11 PM CDT
To: Al Armendariz
Subject: Fw: IMPORTANT - new Complaint for infrastructure
SIPs for 1997 8-hour ozone NAAQS - information needed for CD
negotiation
Al,
Although you're recused from this new case, I thought you ought to be
aware of it. This could be yet another major workload for our air team.
Larry
----- Forwarded by Lawrence Starfield/R6/USEPA/US on 11/04/2010 06:11 PM -----
Fw: IMPORTANT - new Complaint for infrastructure SIPs for 1997
8-hour ozone NAAQS - information needed for CD negotiation
Thomas
Diggs
to: Lawrence Starfield, Carl Edlund
11/04/2010
06:02 PM
Cc: Guy Donaldson
FYI -
J ust got in a new complaint from Sierra Club and WildEarth Guardian
bringing a mandatory duty suit on the 8-hour ozone infrastructure
SIPs. For Region 6, this involves Arkansas, New Mexico, Oklahoma and
Texas. The complaint targets 21 States, Washington D.C. and 3
Territories. Guy and Suzanne and their team will be working to sort
this out in order to respond to OGC and DOJ .
Tom
From: Lawrence Starfield
To: Al Armendariz
Subject: Re: IMPORTANT - new Complaint for infrastructure SIPs for 1997 8-hour ozone NAAQS - information needed
for CD negotiation
Date: 11/05/2010 09:14 AM
I will. I assume you are fully able to decide the substantive issue, but not be
involved in resolution of the deadline suit. But I'll check. It would help to have your
voice at the table.
Larry
Re: IMPORTANT - new Complaint for infrastructure SIPs for 1997 8-hour ozone
NAAQS - information needed for CD negotiation
Re: IMPORTANT - new Complaint for infrastructure SIPs for 1997
8-hour ozone NAAQS - information needed for CD negotiation
Al
Armendariz
to: Lawrence Starfield
11/04/2010
06:25 PM
Please check with Mike B and J ustina. The infrastructure SIPs are a
matter of "general applicability". If needed, I can call J eremy at WEG
and grab R6 an extended deadline.

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Lawrence Starfield
----- Original Message -----
From: Lawrence Starfield
Sent: 11/04/2010 06:11 PM CDT
To: Al Armendariz
Subject: Fw: IMPORTANT - new Complaint for infrastructure
SIPs for 1997 8-hour ozone NAAQS - information needed for CD
negotiation
Al,
Although you're recused from this new case, I thought you ought to be
aware of it. This could be yet another major workload for our air team.
Larry
----- Forwarded by Lawrence Starfield/R6/USEPA/US on 11/04/2010 06:11 PM -----
Fw: IMPORTANT - new Complaint for infrastructure SIPs for 1997
8-hour ozone NAAQS - information needed for CD negotiation
Thomas
Diggs
to: Lawrence Starfield, Carl Edlund
11/04/2010
06:02 PM
Cc: Guy Donaldson
FYI -
J ust got in a new complaint from Sierra Club and WildEarth Guardian
bringing a mandatory duty suit on the 8-hour ozone infrastructure
SIPs. For Region 6, this involves Arkansas, New Mexico, Oklahoma and
Texas. The complaint targets 21 States, Washington D.C. and 3
Territories. Guy and Suzanne and their team will be working to sort
this out in order to respond to OGC and DOJ .
Tom
From: Suzanne Murray
To: Al Armendariz
Subject: Re: IMPORTANT - new Complaint for infrastructure SIPs for 1997 8-hour ozone NAAQS - information needed
for CD negotiation
Date: 11/04/2010 06:37 PM
:)
Suzanne Murray, Regional Counsel, R6
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 11/04/2010 07:19 PM EDT
To: Lawrence Starfield
Cc: "Suzanne Murray" <murray.suzanne@epa.gov>; "Layla
Mansuri" <mansuri.layla@epa.gov>
Subject: Re: IMPORTANT - new Complaint for infrastructure
SIPs for 1997 8-hour ozone NAAQS - information needed for CD
:)

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Lawrence Starfield
----- Original Message -----
From: Lawrence Starfield
Sent: 11/04/2010 06:11 PM CDT
To: Al Armendariz
Subject: Fw: IMPORTANT - new Complaint for infrastructure
SIPs for 1997 8-hour ozone NAAQS - information needed for CD
negotiation
Al,
Although you're recused from this new case, I thought you ought to be
aware of it. This could be yet another major workload for our air team.
Larry
----- Forwarded by Lawrence Starfield/R6/USEPA/US on 11/04/2010 06:11 PM -----
Fw: IMPORTANT - new Complaint for infrastructure SIPs for 1997
8-hour ozone NAAQS - information needed for CD negotiation
Thomas
Diggs
to: Lawrence Starfield, Carl Edlund
11/04/2010
06:02 PM
FOIA Exemption (b)(5) - Deliberative Process Privilege
Cc: Guy Donaldson
FYI -
J ust got in a new complaint from Sierra Club and WildEarth Guardian
bringing a mandatory duty suit on the 8-hour ozone infrastructure
SIPs. For Region 6, this involves Arkansas, New Mexico, Oklahoma and
Texas. The complaint targets 21 States, Washington D.C. and 3
Territories. Guy and Suzanne and their team will be working to sort
this out in order to respond to OGC and DOJ .
Tom
From: Al Armendariz
To: David Gray
Subject: Fw: FIP for Arizona Public Service and schedule with WildEarth Guardian
Date: 11/06/2010 03:55 PM
David,
This email reminds me that should send letters of congratulations to all the new
Governors, congressmen, and senators.
In each, let's refer to a cleanup or ARRA or SRF projects that we did in the district
or state as an example of working together.
For the new Gov in NM, we also might want to schedule a meeting before the end
of the year, so that I can explain the likely upcoming regional haze FIP action.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Lawrence Starfield
----- Original Message -----
From: Lawrence Starfield
Sent: 11/04/2010 06:12 PM CDT
To: Al Armendariz
Subject: Re: FIP for Arizona Public Service and schedule with WildEarth
Guardian
You're exactly right.
I hope tomorrow goes well. Should be interesting.
Larry
Re: FIP for Arizona Public Service and schedule with WildEarth Guardian
Re: FIP for Arizona Public Service and schedule with WildEarth
Guardian
Al
Armendariz
to: Lawrence Starfield
11/04/2010
06:08 PM
Thanks Larry.
At this point, I don't think I need to call him, and it sounds like we are
on the right track.
While the new governor might not like this action to be her first
experience with EPA, I'm not sure I can help it.
Thanks
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Lawrence Starfield
----- Original Message -----
From: Lawrence Starfield
Sent: 11/04/2010 04:45 PM CDT
To: Al Armendariz
Cc: Carl Edlund; Guy Donaldson; Thomas Diggs
Subject: Re: FIP for Arizona Public Service and schedule
with WildEarth Guardian
CONFIDENTIAL - DELIBERATIVE PROCESS
Al,
Let me know if you'd like to discuss this further.
Larry
Re: FIP for Arizona Public Service and schedule with WildEarth Guardian
Re: FIP for Arizona Public Service and schedule with WildEarth
FOIA Exemption (b)(5) - Deliberative Process Privilege
Guardian
Al
Armendariz
to: Thomas Diggs, Carl Edlund
11/04/2010
12:49 PM
Cc: Guy Donaldson, Lawrence Starfield
Thank you.
Larry: can you call Ron, let him know I am traveling continuously until
next week, but that I am happy to connect tomorrow in the evening.
I'll call him from my cell phone from Maryland.
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Thomas Diggs
----- Original Message -----
From: Thomas Diggs
Sent: 11/04/2010 12:46 PM CDT
To: Al Armendariz; Carl Edlund
Cc: Guy Donaldson; Lawrence Starfield
Subject: FIP for Arizona Public Service and schedule with
WildEarth Guardian
Al:

FOIA Exemption (b)(5) - Deliberative Process Privilege

I'm here today and tomorrow if you have questions.
Tom
Thomas Diggs
Associate Director - Air
US EPA Region 6
214-665-3102
fax 214-665-7263
diggs.thomas@epa.gov
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: David Gray
To: Al Armendariz/R6/USEPA/US@EPA
Cc: David Gray; Thomas Diggs
Subject: Re: Fw: FIP for Arizona Public Service and schedule with WildEarth Guardian
Date: 11/04/2010 01:06 PM
Al,
Yes. Tom and I will stay up-to-date on this one. I'll start drafting up some text for
everyone.
David
Fw: FIP for Arizona Public Service and schedule with WildEarth Guardian
Fw: FIP for Arizona Public Service and schedule with WildEarth
Guardian
Al
Armendariz
to: David Gray, Thomas Diggs
11/04/2010
12:56 PM
David,
Thanks
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
FOIA Exemption (b)(5) - Deliberative Process Privilege
Thomas Diggs
----- Original Message -----
From: Thomas Diggs
Sent: 11/04/2010 12:46 PM CDT
To: Al Armendariz; Carl Edlund
Cc: Guy Donaldson; Lawrence Starfield
Subject: FIP for Arizona Public Service and schedule with
WildEarth Guardian
Al:



I'm here today and tomorrow if you have questions.
Tom
Thomas Diggs
Associate Director - Air
US EPA Region 6
214-665-3102
fax 214-665-7263
diggs.thomas@epa.gov
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Thomas Diggs
To: Al Armendariz; Chrissy Mann
Cc: Al Armendariz; Carl Edlund; Carl Young; Emad Shahin; J avier Balli; Lawrence Starfield; Layla Mansuri; Lucinda
Watson; Suzanne Smith
Subject: Re: New Mexico and Oklahoma transport SIP final federal registers.
Date: 11/03/2010 05:36 PM
Attachments: RA briefing on NM Transport SIP.doc
RA briefing Oklahoma SIP..doc
2010-10-18 WG Oklahoma Interstate Transport SIP Comments.pdf
2010-9-27 WG New Mexico SIP Comments.pdf
Sierra Club Comments on OK Transport SIP 10 18 10.pdf
Thanks Guy for your email. Al, you asked for the pdf files for the WEG comment
letters. Their comment letters are in the file below. One is dated October 18th and
the other September 27th. I am sending these this afternoon to you and Chrissy to
save her time rather than looking in the docket.
Tom
--- Forwarded by Thomas Diggs/R6/USEPA/US on 11/03/2010 05:31 PM -----
From: Al Armendariz/R6/USEPA/US
To: Guy Donaldson/R6/USEPA/US@EPA
Cc: Thomas Diggs/R6/USEPA/US@EPA, "Carl Edlund" <edlund.carl@epa.gov>, "Chrissy Mann"
<Mann.Chrissy@epamail.epa.gov>
Date: 11/03/2010 01:49 PM
Subject: Re: New Mexico and Oklahoma transport SIP final federal registers.
Thank you Guy. I appreciate the heads up.
Only request I have is if someone in your office could pdf me the WEG comment
letters, or send Chrissy the Docket number and she can pull them.
Thanks again,
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Guy Donaldson---11/03/2010 01:04:01 PM---Al, We have a November 10
deadline to finalize actions concerning transport in New Mexico and Oklaho
From: Guy Donaldson/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA
Cc: Layla Mansuri/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Lucinda Watson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA,
Carl Young/R6/USEPA/US@EPA, Emad Shahin/R6/USEPA/US@EPA, Lawrence
Starfield/R6/USEPA/US@EPA, J avier Balli/R6/USEPA/US@EPA
Date: 11/03/2010 01:04 PM
Subject: New Mexico and Oklahoma transport SIP final federal registers.
Al,
We have a November 10 deadline to finalize actions concerning
transport in New Mexico and Oklahoma. The comment periods for
these actions closed on 9/27 and 10/18 respectively.
We received adverse comments on both actions.
In New Mexico we a proposed that emissions in New Mexico don't
interfere with maintenance or PSD programs in other States. We
received adverse comments on the interfere with maintenance piece
from Wild Earth Guardians.
For Oklahoma, we proposed that emissions in Oklahoma don't interfere
with PSD programs in other States and we received adverse comments
from Wild Earth Guardians and Sierra Club (represented by the
Washington University legal Clinic).
After the Texas SSM experience, we recognize you would like a some
advance notice on what adverse comments we have received on our
actions. Unfortunately, we are again under a tight deadline and do not
have much time. I apologize but these proposals were the model for
similar actions in other Regions and because of the need for national
coordination we did not get the proposals out the door as soon as I
had hoped. As a result we haven't had these comments all that
long.
We have discussed the comments with OAQPS and and OGC and we
believe we have appropriate responses for the comments and we are
frantically drafting the Federal Registers. I believe, however, you will
have particular interest in the issues raised in the Oklahoma notice by
WEG and Sierra club. The attached briefing sheets summarize the
comments and our recommended response. We would be happy to
give you full briefing on these as your schedule permits.
I have also attached the comment letters for your convenience.
From: Chrissy Mann
To: Guy Donaldson; Al Armendariz
Subject: Re: New Mexico and Oklahoma transport SIP final federal registers.
Date: 11/03/2010 02:34 PM
Thanks. I will have a read soon.
Sent by EPA Wireless Email Services
Guy Donaldson
----- Original Message -----
From: Guy Donaldson
Sent: 11/03/2010 02:31 PM CDT
To: Al Armendariz; Chrissy Mann
Subject: Fw: New Mexico and Oklahoma transport SIP final federal
registers.
Al, Chrissy:
the comment letters are at the very bottom of the E-mail.
----- Forwarded by Guy Donaldson/R6/USEPA/US on 11/03/2010 02:30 PM -----
From: Guy Donaldson/R6/USEPA/US
To: Al Armendariz/R6/USEPA/US@EPA
Cc: Layla Mansuri/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA, Lucinda Watson/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA,
Carl Young/R6/USEPA/US@EPA, Emad Shahin/R6/USEPA/US@EPA, Lawrence
Starfield/R6/USEPA/US@EPA, J avier Balli/R6/USEPA/US@EPA
Date: 11/03/2010 01:04 PM
Subject: New Mexico and Oklahoma transport SIP final federal registers.
Al,
We have a November 10 deadline to finalize actions concerning
transport in New Mexico and Oklahoma. The comment periods for
these actions closed on 9/27 and 10/18 respectively.
We received adverse comments on both actions.
In New Mexico we a proposed that emissions in New Mexico don't
interfere with maintenance or PSD programs in other States. We
received adverse comments on the interfere with maintenance piece
from Wild Earth Guardians.
For Oklahoma, we proposed that emissions in Oklahoma don't interfere
with PSD programs in other States and we received adverse comments
from Wild Earth Guardians and Sierra Club (represented by the
Washington University legal Clinic).
After the Texas SSM experience, we recognize you would like a some
advance notice on what adverse comments we have received on our
actions. Unfortunately, we are again under a tight deadline and do not
have much time. I apologize but these proposals were the model for
similar actions in other Regions and because of the need for national
coordination we did not get the proposals out the door as soon as I
had hoped. As a result we haven't had these comments all that
long.
We have discussed the comments with OAQPS and and OGC and we
believe we have appropriate responses for the comments and we are
frantically drafting the Federal Registers. I believe, however, you will
have particular interest in the issues raised in the Oklahoma notice by
WEG and Sierra club. The attached briefing sheets summarize the
comments and our recommended response. We would be happy to
give you full briefing on these as your schedule permits.
[attachment "RA briefing on NM Transport SIP.doc" deleted by Chrissy
Mann/R6/USEPA/US]
[attachment "RA briefing Oklahoma SIP..doc" deleted by Chrissy
Mann/R6/USEPA/US]
I have also attached the comment letters for your convenience.
[attachment "2010-10-18 WG Oklahoma Interstate Transport SIP Comments.pdf"
deleted by Chrissy Mann/R6/USEPA/US]
[attachment "2010-9-27 WG New Mexico SIP Comments.pdf" deleted by Chrissy
Mann/R6/USEPA/US]
[attachment "Sierra Club Comments on OK Transport SIP 10 18 10.pdf" deleted by
Chrissy Mann/R6/USEPA/US]
From: Layla Mansuri
To: J oyce Runyan
Cc: Al Armendariz
Subject: Addition to Al's calendar - Friday 4 pm
Date: 09/29/2010 05:43 PM
J oyce,
Please put a call on Al's calendar for Friday at 4 CST.
We are calling J eremy Nicols with WildEarth Guardians.
It will just be me and Al on the call. We are calling 303-437-7663.
Thanks,
Layla

From: Al Armendariz
To: Guy Donaldson; J oe Kordzi; Larry Starfield
Subject: Fw: Discussions with Secretary Curry tomorrow
Date: 09/09/2010 05:31 AM
Fyi

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
J ared Blumenfeld
----- Original Message -----
From: Jared Blumenfeld
Sent: 09/09/2010 01:21 AM EDT
To: Al Armendariz
Best,
J ared Blumenfeld
Sent by EPA Wireless E-Mail Services
Al Armendariz
----- Original Message -----
From: Al Armendariz
Sent: 09/08/2010 11:10 PM EDT
To: Jared Blumenfeld
Cc: Lawrence Starfield
Subject: Fw: Discussions with Secretary Curry tomorrow
Hi J ared,
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
Guy Donaldson
----- Original Message -----
From: Guy Donaldson
Sent: 09/08/2010 09:59 PM CDT
To: Thomas Diggs; Carl Edlund; Al Armendariz
FOIA Exemption (b)(5) - Deliberative Process Privilege
FOIA Exemption (b)(5) - Deliberative Process Privilege
Cc: Joe Kordzi; Agustin Carbo-Lugo; Carl Young
Subject: Discussions with Secretary Curry tomorrow
J oe and I had a discussion with Mary Uhl and others at NMED.
FOIA Exemption (b)(5) - Deliberative Process Privilege
From: J avier Balli
To: Al Armendariz
Cc: Lawrence Starfield
Subject: items for Administrator's video conference
Date: 09/07/2010 11:51 AM
Good morning Al:
Larry suggested the four following items for the Administrator's call from our Senior
Staff meeting this morning.
1. Citizen Potawatomi Hearing.
Today (Sept. 7) there will be a public hearing regarding a Cooperative
Agreement between Citizen Potawatomi Nation and the State of Oklahoma under the
terms of Section 10211(b)(2) of Public Law 109-59 from 10am 2pm and 7pm 9pm at the
Citizen Potawatomi Nation Heritage Center in Shawnee, OK. Approval of the Cooperative
Agreement is required for the EPA Regional Administrator to treat the Citizen Potawatomi
Nation in the same manner as a State for the purpose of administering regulatory
programs under federal environmental laws administered by EPA should the Citizen
Potawatomi Nation apply for such treatment.
2. Public Hearing on the Proposed Rule for Coal Combustion Residuals Disposal.
Tomorrow (Sept. 8), Region 6 will be hosting one of the seven public
hearings on the agency's proposal to regulate the disposal and management of coal
ash from coal-fired power plants. 167 people have registered to attend the Dallas
session, and have 131 have stated they wish to speak.
3. Briefing the Administrator on Title VI Investigation.
Tomorrow (Sept. 8), Region 6 will brief Lisa J ackson on a title Title VI case
the OCR has accepted for investigation. The Southern Migrant Legal Services
(SMLS) filed the suit against the Louisiana Department of Agriculture and Forestry
(LDAF). SMSL is claiming discrimination against fourteen temporary agricultural
workers who were exposed to pesticides and how LDAF handled the situation
afterwards.
4. Ron Curry visit.
On Thursday (Sept. 9), Secretary Ron Curry of the New Mexico Environment
Department, along with his deputy and several managers will visit Region 6. Primary
topic will be a discussion of the acid mist emissions from Public Service of New
Mexico (PNM) for the San J uan Generating Station and the BART analysis that has
been submitted by PNM. PNM has asked for more time to comply with federal
standards.

Let us know if there is anything else you need. Have a safe trip.
- J avier.
J avier M. Ball
Special Assistant to the Deputy Regional Administrator
U.S. EPA Region 6 / 1445 Ross Ave. / Dallas, TX 75202
214.665.7261 / fax 214.665.6488 balli.javier@epa.gov
From: Thomas Diggs
To: Cheryl Nolan
Cc: Al Armendariz; Beau Brock; Bryan J ohnston; Carl Edlund; Herman Robinson; J ackie Marve; J effrey Robinson;
Lawrence Starfield; Peggy Hatch; Shannon Snyder; Suzanne Murray; William Luthans; J anet McCabe; Anna
Wood; Dan Deroeck; Chet Wayland; Tyler Fox; Brian Doster; J im Havard; Erik Snyder; Suzanne Smith
Subject: Re: Information Update - There are multiple changes: Conference Call w/LDEQ re:Nucor; 866-299-3188;
2146652100 #
Date: 08/27/2010 01:52 PM
Thanks.
Here are the EPA attendees.
Al Armendariz
Larry Starfield
Tom Diggs
Jeff Robinson
Shannon Snyder
Erik Snyder
Suzanne Smith
EPA Headquarters
Janet McCabe (OAR)
Anna Wood (OAQPS)
Dan Deroeck (OAQPS)
Chet Wayland (OAQPS)
Tyler Fox (OAQPS)
Brian Doster (OGC)
Jim Havard (OGC)
Cheryl Nolan ---08/27/2010 01:27:09 PM---LDEQ attendees: Peggy Hatch,
Secretary
From: Cheryl Nolan <Cheryl.Nolan@LA.GOV>
To: Carl Edlund/R6/USEPA/US@EPA, Al Armendariz/R6/USEPA/US@EPA, J effrey
Robinson/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, Peggy Hatch
<Peggy.Hatch@LA.GOV>, Shannon Snyder/R6/USEPA/US@EPA, Suzanne Murray/R6/USEPA/US@EPA,
Thomas Diggs/R6/USEPA/US@EPA, William Luthans/R6/USEPA/US@EPA, Beau Brock
<Beau.Brock@LA.GOV>, Herman Robinson <Herman.Robinson@LA.GOV>, J ackie Marve
<J ackie.Marve@LA.GOV>, Bryan J ohnston <Bryan.J ohnston@LA.GOV>
Date: 08/27/2010 01:27 PM
Subject: Information Update - There are multiple changes: Conference Call w/LDEQ re:Nucor; 866-299-3188;
2146652100 #
LDEQ attendees:
Peggy Hatch, Secretary
Cheryl Nolan, Asst Sect
Beau Brock, Asst Sect
Herman Robinson, Exec Counsel
Bryan Johnston, Administrator, Air Permits
Jackie Marve, Legal Supervisor
--------------------------
Thanks,
Cheryl S. Nolan
Sent from my BlackBerry Wireless Handheld

From: Guy Donaldson
To: Al Armendariz
Cc: Lawrence Starfield
Subject: Re: New Mexico Transport SIP (interfere with maintenance and Interfere with PSD).
Date: 08/22/2010 08:44 PM
Thanks I understand Sam signed it acting for you guys.
Re: New Mexico Transport SIP (interfere with maintenance and Interfere with
PSD).
Re: New Mexico Transport SIP (interfere with maintenance and
Interfere with PSD).
Al
Armendariz
to: Guy Donaldson
08/20/2010
12:37 AM
Cc: Lawrence Starfield
Thanks Guy.
Larry and I will keep our eyes open, and get it signed as
quickly as possible.
Thanks for the work up there.
Al
-----Guy Donaldson/R6/USEPA/US wrote: -----
To: Al Armendariz/R6/USEPA/US@EPA, Lawrence
Starfield/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA, Thomas
Diggs/R6/USEPA/US@EPA
From: Guy Donaldson/R6/USEPA/US
Date: 08/19/2010 10:13AM
Cc: Emad Shahin/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA,
Carl Young/R6/USEPA/US@EPA, Edward Martelle/R6/USEPA/US@EPA,
Suzanne Smith/R6/USEPA/US@EPA
Subject: New Mexico Transport SIP (interfere with maintenance
and Interfere with PSD).
I'm on the road today in Denver getting ready to talk about
Regional Haze and 309 trading programs. I am told that a the
Federal Register proposing to find that New Mexico does not
interfere with maintenance in other states and does not
interfere with other States PSD programs is in your office for
signature.
As usual these days. we are on a consent decree. In this case,
we have to go final by the November 10. So the sooner this
proposal can get out the door, the sooner we can get through the
comment period and hopefully finalize by November 10. I am
hoping that it can get signed early today so it can get mailed
to the FR this afternoon.
The notice is the culmination of work by a bunch of people. In
the Region, Emad Shahin, Cathy Penland, Carl Young, Erik Snyder,
Mark Ford, and Lucinda Watson all had crucial roles. Outside
the Region, we had considerable support from OGC and OAQPS.
The notice is the first to address the interfere with
maintenance prong and is serving as a model for all of the other
Regions affected by the Wild Earth Guardians litigation. As
such, it has gotten considerable scrutiny from OGC, OAQPS and
other Regions and as a result took longeer to complete than I
had planned.
Sorry, to always be pestering you guys but it seems like its
going to be norm for a while. I should tell you now that a
similar notice for Oklahoma will be coming your way very soon.
From: Lawrence Starfield
To: Al Armendariz
Subject: Re: New Mexico Transport SIP (interfere with maintenance and Interfere with PSD).
Date: 08/20/2010 07:34 AM
Thanks. I'll take care of it.
Sent by EPA Wireless E-Mail Services
----- Original Message -----
From: Al Armendariz
Sent: 08/20/2010 08:26 AM EDT
To: Lawrence Starfield
Subject: Re: New Mexico Transport SIP (interfere with maintenance and Interfere with PSD).
Yes.

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
----- Original Message -----
From: Lawrence Starfield
Sent: 08/20/2010 08:23 AM EDT
To: Al Armendariz
Subject: Re: New Mexico Transport SIP (interfere with maintenance and Interfere with PSD).
I'm not in today either (medical issue), but I think in the interest of time, we should ask the
Division Director who is Acting to sign it. Are you ok with that?
Larry
Sent by EPA Wireless E-Mail Services
----- Original Message -----
From: Al Armendariz
Sent: 08/20/2010 12:37 AM CDT
To: Guy Donaldson
Cc: Lawrence Starfield
Subject: Re: New Mexico Transport SIP (interfere with maintenance and Interfere with PSD).
Thanks Guy.
Larry and I will keep our eyes open, and get it signed as quickly as possible.
Thanks for the work up there.
Al
-----Guy Donaldson/R6/USEPA/US wrote: -----
To: Al Armendariz/R6/USEPA/US@EPA, Lawrence Starfield/R6/USEPA/US@EPA, Carl Edlund/R6/USEPA/US@EPA,
Thomas Diggs/R6/USEPA/US@EPA
From: Guy Donaldson/R6/USEPA/US
Date: 08/19/2010 10:13AM
Cc: Emad Shahin/R6/USEPA/US@EPA, Erik Snyder/R6/USEPA/US@EPA, Carl Young/R6/USEPA/US@EPA, Edward
Martelle/R6/USEPA/US@EPA, Suzanne Smith/R6/USEPA/US@EPA
Subject: New Mexico Transport SIP (interfere with maintenance and Interfere with PSD).
I'm on the road today in Denver getting ready to talk about Regional Haze and 309 trading
programs. I am told that a the Federal Register proposing to find that New Mexico does not
interfere with maintenance in other states and does not interfere with other States PSD programs
is in your office for signature.
As usual these days. we are on a consent decree. In this case, we have to go final by the
November 10. So the sooner this proposal can get out the door, the sooner we can get through the
comment period and hopefully finalize by November 10. I am hoping that it can get signed early
today so it can get mailed to the FR this afternoon.
The notice is the culmination of work by a bunch of people. In the Region, Emad Shahin, Cathy
Penland, Carl Young, Erik Snyder, Mark Ford, and Lucinda Watson all had crucial roles. Outside
the Region, we had considerable support from OGC and OAQPS.
The notice is the first to address the interfere with maintenance prong and is serving as a model
for all of the other Regions affected by the Wild Earth Guardians litigation. As such, it has
gotten considerable scrutiny from OGC, OAQPS and other Regions and as a result took longeer to
complete than I had planned.
Sorry, to always be pestering you guys but it seems like its going to be norm for a while. I
should tell you now that a similar notice for Oklahoma will be coming your way very soon.
From: David Gray
To: Al Armendariz/R6/USEPA/US@EPA; Lawrence Starfield/R6/USEPA/US@EPA
Subject: ECOS Hot Issues
Date: 08/20/2010 05:04 PM
HQ requested hot issues for the upcoming ECOS meeting. Here are the ones we pulled
together. They will go up on Monday.
David




FOIA Exemption (b)(5) - Deliberative Process Privilege




FOIA Exemption (b)(5) - Deliberative Process Privilege
From: Al Armendariz
To: J ohn Blevins; Carl Edlund; David Garcia; Patricia Welton; Layla Mansuri; Lawrence Starfield; Suzanne Murray
Subject: Re: Texas Emissions Rule May Spur Clash With EPA Over 'Aggregation' Policy
Date: 08/20/2010 08:05 AM
I am laughing.
"...mark the latest split between the Texas Commission on
Environmental Quality (TCEQ) and the Obama administration over
Clean Air Act rules and policies..."
I had no idea there was a "latest split". My mind is so numb from
flexible permits. This issue was totally not on my radar screen.
And I had lunch with J eremy just last week.
Its good to know I get into fights with states, and for a while have no
idea that we are even fighting about something.
:)
Al

____________________
Al Armendariz
Regional Administrator
U.S. EPA
Region 6
armendariz.al@epa.gov
office: 214-665-2100
J ohn Blevins
----- Original Message -----
From: John Blevins
Sent: 08/20/2010 08:58 AM EDT
To: Carl Edlund; David Garcia; Patricia Welton; Layla
Mansuri; Lawrence Starfield
Cc: Al Armendariz
Subject: Fw: Texas Emissions Rule May Spur Clash With EPA
Over 'Aggregation' Policy
FYI
J ohn Blevins
CAED
US EPA REGION 6
214-665-2210 (w)
214-437-9810 (c)
Kenneth Gigliello
----- Original Message -----
From: Kenneth Gigliello
Sent: 08/19/2010 08:32 AM EDT
To: Mike Gaydosh; Cindy Beeler; Bernadette Rappold; John
Blevins; Stephen Gilrein; Samantha Beers; Rick Duffy; Jon
Silberman; Barbara McGarry; Cynthia Reynolds; Mamie Miller;
Scott Throwe; Marcia Mia
Subject: Texas Emissions Rule May Spur Clash With EPA Over
'Aggregation' Policy
Texas Emissions Rule May Spur Clash With EPA
Over 'Aggregation' Policy
Posted: August 18, 2010
Texas officials are floating permitting rules that adopt a revoked Bush-era policy on "aggregation" of oil and gas
facilities' emissions to determine whether they are major pollution sources, setting up a possible clash with the
Obama EPA's attempts to define aggregation based on a more comprehensive test than the revoked policy.
The recently proposed rules mark the latest split between the Texas Commission on Environmental Quality
(TCEQ) and the Obama administration over Clean Air Act rules and policies. EPA has already rejected Texas'
"flexible" air permitting program for conventional pollutants, while the state recently warned the agency it has no
intention of implementing EPA's "tailoring" rule establishing first-time greenhouse gas limits in air permits.
TCEQ Chairman Bryan Shaw in a July 28 statement said that the state is proposing changes to its permitting
rules for the oil and gas industry in order to "minimize emissions and ensure that public health is protected"
given a massive growth in drilling in the Barnett Shale, a hydrocarbon-producing geological formation in the
state.
The proposal updates administrative and technical requirements, and includes enforceable monitoring, sampling
and record-keeping requirements, according to TCEQ. But a source with the environmental group WildEarth
Guardians says the proposed rules would also enshrine into state regulation the Bush EPA method of
aggregating oil and gas facilities that critics say would trigger few, if any, strict major source pollution controls for
the facilities.
EPA has long used a three-factor approach to determine when to aggregate emissions from sources for the
purposes of air act permitting requirements: whether activities are under control of the same person, whether
activities belong to the same industrial grouping, and whether activities are contiguous or adjacent.
But in 2007, former Bush EPA acting air chief William Wehrum issued a policy memo saying the distance
between sources at oil and gas facilities -- such as wells -- should be a key factor for determining whether to
aggregate emissions. Activists say this let oil and gas facilities avoid triggering definition as a major source of
pollution subject to stringent pollution controls, leaving them instead subject to weaker minor source pollution
limits.
In September, EPA air chief Regina McCarthy revoked Wehrum's memo, saying it attempted to "simplify" the
permitting analysis. "In practice, however, I find individual facts warrant a close examination" of all three criteria
EPA should use, not just an emphasis on distance, McCarthy wrote at the time.
EPA is also quietly drafting guidance to encourage states to better "aggregate" emissions from oil and gas
facilities to assess whether they are major pollution sources, after the Obama administration decision to revoke
the Wehrum policy failed to result in any major permitting changes, sources say.
Reviewing Oil/Gas Rules
EPA is also looking closely at the issue of emissions from oil and gas sites, and is reviewing its rules on the
sector to see if changes are necessary at the urging of environmentalists, who favor a revision of federal new
source performance standards (NSPS) for the oil and gas sector to achieve emissions reductions.
Environmentalists want EPA to issue an NSPS that adopts a strict approach to aggregation. Without strict rules
on aggregation, activists argue, small wells can fall below emissions thresholds that trigger regulation, even
though there may be many of them in a relatively small area producing damaging emissions.
But industry argues that grouping widely dispersed sources is unfair and defies common sense. Industry tried to
downplay the impact of McCarthy's Sept. 22 memo. Texas' proposed rule, activists say, would enshrine the
criticized Wehrum approach to aggregating facilities that could help industry avoid strict controls.
Texas' proposed rule "is pretty worrisome," as Texas appears to be basing its determination of aggregation
primarily on whether facilities are more than one quarter mile apart, the WildEarth Guardians source says,
adding that this contrasts with EPA's current three-step process.
If facilities are located more than one quarter mile apart, they would likely escape onerous major source
permitting under the Texas proposal, the source says. "This seems directly at odds with the federal definition of
a stationary source and EPA guidance on the matter," the source says. The source notes that TCEQ's own
permitting guidance says that properties more than this distance apart can still be aggregated if they are
interdependent.
"In this case, TCEQ seems to be attempting to lock in its quarter-mile distance to avoid permitting truly
interdependent oil and gas operations that probably should be major sources" under federal air rules. The
source also notes the rule would only apply to new and modified sources, and not existing unaltered facilities.
WildEarth Guardians has recently taken steps to try to address what it says are flaws in other state's
aggregation policies. For example, the group petitioned EPA July 22 to sanction Colorado for not enforcing
aggregation provisions included in its state implementation plan (SIP), an air quality blueprint for meeting federal
air standards.
The group wants EPA to use Clean Air Act authority to impose harsh financial penalties on the state, including
withholding federal highway dollars and grant funding that states use to implement pollution control programs.
Also, the group wants EPA to revoke the state's delegated Title V air permitting authority.
Warning To Other States
Because aggregation is a national issue, WildEarth Guardians targeted Colorado, a major natural gas producer,
in an an attempt to warn other states not to avoid permitting major sources in the same way or face similar
formal challenges, the group said at the time. Texas' proposed rule confirms the suspicions of environmentalists
that a negative precedent has taken hold among states with regard to aggregation, the source says.
A spokesman for TCEQ denies, however, that the state has any interest in setting a precedent for other states
and also downplays a clash with EPA's aggregation policy.
A local clean air activist in Texas adds that "I certainly know that we need aggregation" to address air toxics
emissions from a multitude of small wells. For example, citizens in the Texas town of DISH on the outskirts of
Fort Worth claim they are being sickened by emissions from small oil and gas drilling wells.
EPA did not respond to a request for comment by press time.
From: J eremy Nichols
To: LisaP J ackson/DC/USEPA/US@EPA; Gina McCarthy/DC/USEPA/US@EPA; Al Armendariz/R6/USEPA/US@EPA
Subject: Letter of Support, New Mexico Clean Air Act BART Proposal
Date: 08/04/2010 06:15 PM
Attachments: 2010-8-4 Support for SJ GS BART Proposal.pdf
Dear Administrator J ackson, Assistant Administrator McCarthy, and Regional
Administrator Armendariz:
Attached, please find a letter from several organizations submitted today to the
Governor of New Mexico and the Secretary of the New Mexico Environment
Department in support of the State's Best Available Retrofit Technology proposal for
the San J uan Generating Station and the State's decision to submit its Regional Haze
State Implementation Plan under 40 CFR 51.308. Thank you and we look forward
to future interactions with the EPA regarding this matter.
Sincerely,
J eremy Nichols
--
J eremy Nichols
Climate and Energy Program Director
WildEarth Guardians
1536 Wynkoop, Suite 301 - Denver, CO 80202
303-573-4898 x 1303
www.wildearthguardians.org
From: J eremy Nichols
To: Al Armendariz/R6/USEPA/US@EPA
Subject: Re: change of plans
Date: 07/24/2010 03:04 PM
Hi Al -
No worries, let's shoot for meeting after the first session, I think that would work
better for my schedule. I'll see you at the afternoon session. Thanks, Al.
J eremy
On Sat, J ul 24, 2010 at 10:07 AM, <Armendariz.Al@epamail.epa.gov> wrote:
Hi J eremy,
Change of plans. I was originally going to participate in the evening portion of the
oil/gas MACT public meeting (6 to 10 pm), but I think it would be best for me to
be there at the afternoon session (12 to 4pm).
From my office to Arlington city hall is about 30 minutes, so I'll probably have to
leave my office at 11 or so.
Not sure what your plans are, but if you wish, we could leave the public meeting
at 4 pm, and go somewhere nearby for an early dinner and to talk? Or maybe we
could meet in Arlington a little early before the meeting.
Either way would be fine for me.
Al
-----Al Armendariz/R6/USEPA/US wrote: -----
To: "J eremy Nichols" <jnichols@wildearthguardians.org>
From: Al Armendariz/R6/USEPA/US
Date: 07/23/2010 10:16AM
Subject: Re: Congrats
Hi J eremy,
How are things? I wanted to check on our plans for meeting up week from
Monday, on Aug 2nd. Are we still on for lunch? If so, what if we meet at my office
a