Diné Citizens Against Ruining the Environment, San Juan Citizens Alliance, Amigos Bravos, Center for Biological Diversity, and Sierra Club (collectively, “Petitioners”) filed a petition with the Environmental Appeals Board (“Board”) seeking review on several grounds of a National Pollutant Discharge Elimination System (“NPDES”) permit renewal issued by Region 9 of the U.S. Environmental Protection Agency to the Arizona Public Service Company (“APS”).