Public Policy Agenda Number 2. CONTACT: Bridget Schwartz-Manock Marie Pearthree (623) 869-2150 (623) 869-2111 [email protected][email protected]MEETING DATE: March 7, 2013 AGENDA ITEM: Report on 2013 State Legislative Session and Possible Consideration of a Recommendation that the Board take Action on State Legislation that Could Affect CAP, Including but not Limited to: SB 1107, SB 1324, SB 1383, SB 1403, Hoover Legislation RECOMMENDATION: See attached document and proposed staff recommendations. FINANCIAL IMPLICATIONS: None RELEVANT POLICY, STATUTE OR GUIDING PRINCIPLE: 2010 CAWCD Strategic Plan • Leadership & Public Trust: Relationships – Other Stakeholders • Water Supply: Reliability of CAP Water Supply PREVIOUS BOARD ACTION/ACTIVITY: October 4, 2012 – Committee discussed proposed 2013 State Legislative Agenda Items January 10, 2013 – Board adopted 2013 State Legislative Agenda
Transcript
Public Policy Agenda Number 2.
CONTACT: Bridget Schwartz-Manock Marie Pearthree (623) 869-2150 (623) 869-2111 [email protected][email protected] MEETING DATE: March 7, 2013 AGENDA ITEM: Report on 2013 State Legislative Session and Possible
Consideration of a Recommendation that the Board take Action on State Legislation that Could Affect CAP, Including but not Limited to: SB 1107, SB 1324, SB 1383, SB 1403, Hoover Legislation
RECOMMENDATION: See attached document and proposed staff recommendations. FINANCIAL IMPLICATIONS: None RELEVANT POLICY, STATUTE OR GUIDING PRINCIPLE: 2010 CAWCD Strategic Plan
• Leadership & Public Trust: Relationships – Other Stakeholders • Water Supply: Reliability of CAP Water Supply
PREVIOUS BOARD ACTION/ACTIVITY: October 4, 2012 – Committee discussed proposed 2013 State Legislative Agenda Items January 10, 2013 – Board adopted 2013 State Legislative Agenda
ISSUE SUMMARY/DESCRIPTION: This report describes CAP's state legislative agenda and provides an update on those issues. In addition, this update requests guidance on bills being considered by the State Legislature. See attached document and issue descriptions. SUGGESTED MOTION: I move that the Public Policy Committee recommend that the Board adopt positions on the following pending state legislation of interest to CAP: (staff recommendations in parentheses) SB 1107 (Monitor) SB 1324 (Support) SB 1383 (Oppose) SB 1403 (Oppose) Hoover Legislation (Support) Attachment.
February 27, 2013
The 51st State Legislature's First Regular Session began on Monday, January 14, 2013. February 27 is the 45th day of the session. 1145 bills have been introduced as of today. Two have passed and been signed into law.
The following State Legislative Issues Update outlines the status of the Board-approved 2013 Legislative Agenda as well as other relevant state legislative bills and issues.
Arizona Department of Water Resources (ADWR) Funding
Monitor the Legislature's budgeting processes and agency rulemaking to ensure the Arizona Department of Water Resources' current level of funding is maintained.
Status as of February 27, 2013:
Nothing to report at this time. _________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
Water Resources Development Commission (WRDC)
Participate in and monitor legislation related to the activities of the Water Resources Development Commission. Status as of February 27, 2013:
H.B. 2338 (Regional Water Augmentation Authorities RWAA), sponsored by House Speaker Andy Tobin, allows for the formation of RWAAs in the state by two or more specified entities, one of which must be a public agency. The bill also authorizes private water companies and other private entities to partner with public agencies to form an authority. Among its powers and duties, an RWAA may lawfully acquire or sell property, easements and rights-of-way for water supplies and projects; acquire or assign water rights; acquire and sell water; treat water; charge fees for services and water sales; issue revenue bonds; and exercise the power of eminent domain in specified circumstances. RWAAs are also authorized to apply for and receive financial assistance from the Water Supply Fund. The bill appropriates $30 million from the State General
Public Policy Agenda Number 2. Attachment 1.
Fund for these purposes. HB 2338 was introduced on January 22 and was heard in the House Water and Agriculture Committee on February 19 and held after several hours of testimony.
CAP Position: SUPPORT _________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
Multi-Species Conservation Program (MSCP) Funding
Support the Arizona Game and Fish Department's efforts to collect and maintain revenues sufficient to continue its annual contribution toward the costs of the MSCP. Status as of February 27, 2013:
Nothing to report at this time. _________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
Arizona Water Protection Fund
Monitor the status of the Arizona Water Protection Fund and efforts to maintain sufficient levels of State funding. Status as of February 27, 2013: H.B. 2429 (Water Protection Fund; Annual Funding), sponsored by Representative Kate Brophy McGee, restores the annual $5 million state General Fund appropriation to the Arizona Water Protection Fund that existed prior to 2011. The annual appropriation is $5 million, minus the CAWCD property tax equivalency funds deposited into the Water Protection Fund in the previous year. Although a statutory appropriation existed prior to 2011, the Water Protection Fund line item in the state budget had been zeroed out since FY 2000. CAP is represented on the Water Protection Fund Commission. HB 2429 passed the House Agriculture and Water Committee on February 12 with a vote of 6 - 1.
CAP Position: MONITOR
Modification of Groundwater Code and Underground Storage Statutes
Monitor proposed changes to the Arizona Groundwater Code and Underground Storage Statutes to ensure CAP operations are not negatively impacted. Status as of February 27, 2013: Nothing to report at this time. _________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
Hualapai Water Rights Settlement
Monitor legislation necessary and appropriate to implement the Hualapai settlement. Status as of February 27, 2013:
Nothing to report at this time. _________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
Arizona Power Authority
Monitor proposed changes to the Arizona Power Authority's statutes and efforts to reallocate Hoover Power to ensure CAP's Hoover allocation is not changed.
Status as of February 27, 2013:
Nothing to report at this time. _________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
PREVIOUS LEGISLATION OF INTEREST
H.C.R. 2005 (Public Retirement Systems), sponsored by Rep. John Kavanagh, proposes to amend the state Constitution at the 2014 general election to allow increases in member contributions or reductions in member benefits in the state's public retirement systems so long as they are consistent with generally accepted actuarial standards and are in the interest of the financial stability of the system. Article 29 of the Arizona Constitution currently protects members in Arizona's
public retirement systems, including ASRS, with a prohibition on the diminishment or impairment of member benefits. H.C.R. 2005 is still awaiting committee assignment in the House and appears dead at this time.
CAP Position: OPPOSE _________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
S.B. 1288 (Arizona Water Protection Fund; Projects), sponsored by Sen. Gail Griffin, prohibits a federal agency from receiving Water Protection Fund monies and reduces the number of commissioners on the Water Protection Fund Commission, from 15 to 9. CAWCD's representative is one of the six seats being removed.
On February 21, SB 1288 was successfully amended in the Senate Committee of the Whole to return the CAWCD representative to the Commission, as well as the Salt River Project representative and a CAP municipal Customer representative.
CAP Position: AMEND & MONITOR IF NOT AMENDED, OPPOSE _________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
H.B. 2331 (Bonding; Taxation; Expenditures; District Limitations), sponsored by Rep. Steve Montenegro, states that the ad valorem tax and expenditure limitations in the Arizona Constitution applicable to counties, cities and towns and community college districts would now be deemed to incorporate the taxes collected and expenditures made by special taxing districts which include CAP.
HB 2331 passed the House Reform and Human Services Committee on February 7, 2013. The bill still awaits a hearing in the House Ways and Means Committee and appears dead at this time.
CAP Position: OPPOSE
S.C.R. 1012 (EPA Actions; Haze), sponsored by Sen. Gail Griffin, states that the members of the Arizona State Legislature express opposition to the Federal Implementation Plan for the Apache, Cholla, and Colorado coal-fired power plants and support the State Implementation Plan as a reasonable and viable solution to address and reduce regional haze.
SCR 1012 passed the Senate, 17-11, on February 25, 2013.
CAP Position: MONITOR _________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
OTHER LEGISLATION OF INTEREST S.B. 1403 (United Nations Rio Declaration; Prohibition), sponsored by Sen. Judy Burges, prohibits the state and political subdivisions (CAP) from adopting or implementing the creed, doctrine, principles or any tenet of the United Nations Rio Declaration on Environment and Development and the Statement of Principles for Sustainable Development adopted at the United Nations Conference on Environment and Development held in Rio de Janeiro, Brazil in June, 1992 or any other international law that contravenes the United States Constitution or the Constitution of Arizona.
SB 1403 passed the Senate Government and Environment Committee by a vote of 4 – 3 on February 18, 2013. Having also passed the Rules Committee and Caucus, the bill awaits Senate Floor action.
S.B. 1383 (Property Tax Limits; Local Districts), sponsored by Sen. Al Melvin, limits taxes levied by special taxing districts (CAP) to an increase of two percent annually.
SB 1383 was held in the Senate Finance Committee on February 20, 2013 and appears dead at this time.
Recommended Position: OPPOSE
New vehicle bill number pending (Energy Generation Projects; Financing), language provides for the refinancing of Arizona's proportionate share of the federal debt associated with the Hoover Dam Visitor's Center by the Arizona Power Authority (APA). The current interest rate is over 8 percent. Authorization of refinancing with APA bonds expected to have a substantially lower interest rate could result in a savings of $700,000 to $800,000 per year, which is approximately a $250,000 per year savings for CAP since CAP pays roughly a third of APA's total budget through rates.
Recommended Position: SUPPORT _________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
S.B. 1107 (Yuma Desalting Plant Study Committee), sponsored by Sen. Don Shooter, creates a three-member Yuma Desalting Plant Study Committee consisting of three state Senators appointed by the Senate President. The Committee is required to do the following: collect information on the plant's history and development; review data collected during its pilot run; and study opportunities to enhance and to increase operations. Findings and recommendations must be submitted to the Governor and Senate President by December 31, 2013.
S.B. 1324 (Critical Infrastructure; Information Disclosure), sponsored Sen. Chester Crandell), expands the exemption from public disclosure of critical infrastructure information to include certain information provided to or in the possession of any state agency or political subdivision. This includes information that is protected by the federal Critical Infrastructure Information Act of 2002 and that is provided to or in the possession of any state agency or political subdivision of the state, rather than to just the Arizona Department of Public Safety or a local government under current law.
Recommended Position: SUPPORT _________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
If you have any questions or would like more information regarding any of the issues contained in this report, please contact
CAP Business Planning and Governmental Programs, 623-869-2150.
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Public Policy Agenda Number 2. Attachment 2.
2
The WRDC was formed in 2010 to assess the current and future water needs of Arizona and identify potential mechanisms for financing the acquisition, treatment and delivery of water supplies. The CAP General Manager, David Modeer, served on this Commission.
CAP Position: Participate in and monitor legislation related to the activities of the Water Resources Development Commission.
Update: HB 2338 was heard in the House Agriculture and Water Committee on February 19, but was held.
Board’s Position: SUPPORT
3
The Arizona Legislature established the Arizona Water Protection Fund in 1994 to provide monies for implementation of projects that will maintain, enhance and restore rivers, streams and associated riparian resources through a yearly competitive public grant process. In recent years, State funding of the Fund has diminished.
CAP Position: Monitor the status of the Arizona Water Protection Fund and efforts to maintain sufficient levels of State funding.
Update:HB 2429 passed the House Agriculture and Water Committee and has been scheduled for a hearing in House Appropriations on February 27.
Board’s Position: MONITOR
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SB 1288 – Arizona water protection fund; projects, sponsored by Sen. Gail Griffin. The bill, as amended by the Senate Government and Environment Committee on February 4, would prohibit a federal agency from receiving Water Protection Fund monies, and would also reduce the number of commissioners on the Water Protection Fund Commission, from 15 to 9. CAWCD's representative was one of the six seats being removed.
SB 1288 was amended on the Senate Floor to restore CAP representation on the Commission. Sen. Griffin also reinstated SRP and a CAP municipal customer representation. The bill has since passed the Senate, 17-11, and is awaiting assignment in the House.
Board’s Position: AMEND & MONITOR. If not amended, OPPOSE.
5
SB 1107 (Yuma desalting plant study committee), sponsored by Sen. Don Shooter, creates a three-member Yuma Desalting Plant Study Committee consisting of three state Senators appointed by the Senate President. The Committee is required to do the following: collect information on the plant's history and development; review data collected during its pilot run; and study opportunities to enhance and to increase operations. Findings and recommendations must be submitted to the Governor and Senate President by December 31, 2013. Strike-everything amendment was adopted to S.B. 1107 by the Senate Natural Resources and Rural Affairs Committee and passed committee, 5-0.
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SB 1324 (critical infrastructure; information disclosure), sponsored Sen. Chester Crandell, expands the exemption from public disclosure of critical infrastructure information to include certain information provided to or in the possession of any state agency or political subdivision, rather than to just the Arizona Department of Public Safety or a local government under current law. This includes information that is protected by the federal Critical Infrastructure Information Act of 2002 and that is provided to or possessed by any state agency or political subdivision of the state. SB 1324 passed the Senate, 28-0, and is awaiting assignment in the House.
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SB 1383 (property tax limits; local districts), sponsored by Sen. Al Melvin, prohibits, beginning in tax year 2014, the maximum amount of the annual property tax levy by any special taxing district from exceeding an amount two percent greater than the amount levied in the preceding tax year. The limit is increased each year to the maximum permissible, whether the district actually levies taxes to that amount. The bill does not apply to property taxes levied to pay bonded indebtedness or other long-term obligations incurred prior to 2014. District voters may allow property taxation in excess of the limit for a single tax year by a 2/3 vote.
The Arizona Constitution currently exempts special taxing districts from the constitutional 2% limit. The bill was held in the Senate Finance Committee on February 20 and appears to be dead at this time.
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SB 1403 (United Nations Rio declaration; prohibition), sponsored by Sen. Judy Burges, prohibits Arizona or its political subdivisions from adopting or implementing the United Nations Rio Declaration on Environment and Development (Rio Declaration) or any other international law that contravenes the U.S. Constitution or the Constitution of Arizona. The bill also prohibits any expending of monies to implement programs or providing any financial aid to organizations that promote Rio Declaration principles. There were 178 governments, including the U.S., that signed on to three agreements adopted at the United Nations Conference on Environment and Development in Rio de Janiero in 1992. Agenda 21 is a comprehensive, nonbinding, and voluntary plan of action that was designed to help the world become more sustainable, while still meeting global needs. Another agreement, the Rio Declaration, contains 27 guiding principles that were created to reaffirm the declaration that was adopted in Stockholm in 1972.
S.B. 1403 passed the Senate Government and Environment Committee, 4-3, and awaits Floor action.
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Bill number pending (energy generation projects; financing), language provides for the refinancing of Arizona's proportionate share of the federal debt associated with the Hoover Dam Visitor's Center by the Arizona Power Authority (APA). The current interest rate is over 8 percent. Authorization of refinancing with APA bonds expected to have a substantially lower interest rate could result in a savings of $700,000 to $800,000 per year, which is approximately a $250,000 per year savings for CAP since CAP pays roughly a third of APA's total budget through rates.
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www.CentralArizonaProject.com February 2013
CAPConnectionswith Legislative Partners
In Brief: The CAWCD BoardThe Central Arizona Project is governed by the 15-member Central Arizona Conservation District (CAWCD) Board of Directors. The CAWCD Board is responsible for establishing CAP policy and
usually meets once per month. CAWCD Board members are popularly-elected from CAP’s three-county service area of Maricopa, Pinal and Pima counties, and serve staggered, six-year terms. This results in five seats coming up for re-election every two years. State law requires that 10 members represent Maricopa County on the Board, while four members are from Pima County and one member represents Pinal County. Boards of Directors’ votes are also weighted depending on the popu-
lation of the county they represent. Board members receive no compensation for their service.
At the most recent general election on November 6, Maricopa County voters re-elected Lisa At-kins and Pamela Pickard to the CAWCD Board, and elected three new Directors: Guy Carpenter, Terry Goddard, and Heather Macre. The incoming Directors began their terms on January 1.
The Board also has several committees that handle various CAP business-related subject mat-ter: • Finance,AuditandPowerCommittee,ChairmanWarrenTenney;• CentralArizonaGroundwaterReplenishmentDistrictandUndergroundStorage
TheCAWCDBoard’snextmeetingisonMarch7atCAPHeadquartersinPhoenix.Formoreinformation on Board members, including biographies, please visit www.cap-az.com.
State Legislation THE CAP BOARD TOOK ACTION ON THE FOLLOWING BILLS:HB2338 (SpeakerTobin)—allowsthecreationofregionalauthoritiesforwateracquisitionandinfrastructure:SUPPORT
David Modeer, General ManagerMarie Pearthree, Assistant General Manager, Business Planning & Governmental RelationsKathryn Royer, Associate General Manager, Communications & Public Affairs Bridget Schwartz-Manock, Manager, Legislative Affairs
CAP Connection is a publication of Central Arizona Project.
Central Arizona Project
PO Box 43020 Phoenix, AZ 85080
623-869-2333
Take Action! CAP encourages you to email comments to the EPA and tell the agency to:
D Give more consideration to the economic impacts that the ruling will have on water users, agriculture, Tribal interests and water policy in Arizona.
D RequesttheEPAtakeacloserlookatthescientificstudies,includingthosefromtheU.S.DepartmentofEnergy,showingthatNGSdoes not have a significant impact on regional haze as the EPA has stated in its rule.
D RecognizethatthereareothersourcesofemissionswithfargreaterimpactsonvisibilityintheareaoftheGrandCanyonthanNGS.
D Provide more time for people to review and understand the impacts of the rule and to provide comment to EPA.
CAP Perspectives on Proposed NGS RuleTheU.S.EnvironmentalProtectionAgency(EPA)hasreleasedits proposed rule establishing a standard that will require new emissionscontrolstoreducehaze-formingnitrogenoxides(NOx)at Navajo Generating Station (NGS). The only technol-ogy currently available that can meet this standard is SelectiveCatalyticReduc-tion(SCR)atacostofatleast $500 million and nearly double that, $1.1 billion, if new baghouse filters are required to remove the particulates formed by the SCRprocess.AlthoughCAPis disappointed that the EPA didnotrecognizethatNOxreductiontechnologyinstalledbetween2009and2011meetsEPA’s current regional haze requirements, the new EPA rule does provide the owners with an additional five years for compliance in
Next StepsCAP will work with the regu-latory community, our state and Congressional leadership and our other partners to find effective and cost-efficient solutions to the complex challenges presented by the proposed rule. CAP will also work with the EPA, the De-partmentsofInteriorandEn-
ergyunderthetermsoftheirJanuary4,2013JointFederalAgencyStatement regarding NGS. Prior to this, however, we need more timethana90-daycommentperiod,andCAPwilljoinwithotherstakeholders in asking the EPA to extend the comment period.
www.CentralArizonaProject.com February 2013
CAPConnectionswith Municipal Partners
Mayor of Gilbert, John Lewis, and State Representative Warren Petersen toured CAP in January. Pictured from left to right is, Lewis, CAP General Manager David Modeer, and Petersen.
If you are interested in a tour of CAP, call CAP’s Legislative Affairs Manager Bridget Schwartz-Manock, 623-869-2150. CAP officials appreciate the op-portunity to better understand how our municipal customers operate and deliver CAP water, and would enjoy coming to your city or town as well.
Tour CAP...
In Brief: The CAWCD BoardThe Central Arizona Project is governed by the 15-member Central Arizona Conservation District (CAWCD) Board of Directors. The CAWCD Board is responsible for establishing CAP policy and
usually meets once per month. CAWCD Board members are popularly-elected from CAP’s three-county service area of Maricopa, Pinal and Pima counties, and serve staggered, six-year terms. This results in five seats coming up for re-election every two years. State law requires that 10 members represent Maricopa County on the Board, while four members are from Pima County and one member represents Pinal County. Boards of Directors’ votes are also weighted depending on the popu-
lation of the county they represent. Board members receive no compensation for their service.
At the most recent general election on November 6, Maricopa County voters re-elected Lisa At-kins and Pamela Pickard to the CAWCD Board, and elected three new Directors: Guy Carpenter, Terry Goddard, and Heather Macre. The incoming Directors began their terms on January 1.
The Board also has several committees that handle various CAP business-related subject matter: • Finance,AuditandPowerCommittee,ChairmanWarrenTenney;• CentralArizonaGroundwaterReplenishmentDistrictandUndergroundStorage
TheCAWCDBoard’snextmeetingisonMarch7atCAPHeadquartersinPhoenix.Formoreinformation on Board members, including biographies, please visit www.cap-az.com.
2013-2014 Board of Directors
Pam Pickard, Maricopa President
Warren Tenney, Pima Vice President
Lisa Atkins, Maricopa Secretary
~Gayle Burns, Maricopa
Guy Carpenter, Maricopa
FrankFairbanks,Maricopa
Terry Goddard, Maricopa
Jim Hartdegen, Pinal
Jim Holway, Maricopa
Pat Jacobs, Pima
Mark Lewis, Maricopa
Heather Macre, Maricopa
Sharon Megdal, Pima
Cynthia Moulton, Maricopa
CarolZimmerman,Pima
David Modeer, General ManagerMarie Pearthree, Assistant General Manager, Business Planning & Governmental RelationsKathryn Royer, Associate General Manager, Communications & Public Affairs Bridget Schwartz-Manock, Manager, Legislative Affairs
CAP Connection is a publication of Central Arizona Project.
Central Arizona Project
PO Box 43020 Phoenix, AZ 85080
623-869-2333
Take Action! CAP encourages you to email comments to the EPA and tell the agency to:
D Give more consideration to the economic impacts that the ruling will have on water users, agriculture, Tribal interests and water policy in Arizona.
D RequesttheEPAtakeacloserlookatthescientificstudies,includingthosefromtheU.S.DepartmentofEnergy,showingthatNGSdoes not have a significant impact on regional haze as the EPA has stated in its rule.
D Recognize that there are other sources of emissions with far greater impacts on visibility in the area of the Grand Canyon than NGS.
D Provide more time for people to review and understand the impacts of the rule and to provide comment to EPA.
Submit your comments online, via email or mail, identified by docket number EPA–R09–OAR–2013–0009:FederalRulemakingPortal:www.regulations.govandfollowtheinstructions
CAP Perspectives on Proposed NGS RuleTheU.S.EnvironmentalProtectionAgency(EPA)hasreleaseditsproposed rule establish-ing a standard that will require new emissions controls to reduce haze-forming nitrogen oxides (NOx) at Navajo Generat-ing Station (NGS). The only technology currently available that can meet this standard is Selective Catalytic Reduction (SCR) at a cost of at least $500 million and nearly double that, $1.1 billion, if new baghouse filters are required to remove the particulates formed by the SCR process. Although CAP is disappointed that the EPA did not recognize that NOx reduction technology installed between 2009 and 2011 meets EPA’s current regional haze requirements, the new EPA rule does provide the owners with an additional five years for compliance in recognition of the voluntary installation
of Low-NOx burners and tribal issues. A 90-day comment period on the proposed emissions rule beganonFebruary5whentheproposed rule was published in theFederalRegister.
Next StepsCAP will work with the regula-tory community, our state and Congressional leadership and our other partners to find effective and cost-efficient solutions to the complex challenges present-ed by the proposed rule. CAP
will also work with the EPA, the Departments of Interior and En-ergyunderthetermsoftheirJanuary4,2013JointFederalAgencyStatement regarding NGS. Prior to this, however, we need more time than a 90-day comment period, and CAP will join with other stakeholders in asking the EPA to extend the comment period.
