April 19, 2021

Mark Hammond, Director
Bureau of Air Quality
Pennsylvania Department of Environmental Protection
Rachel Carson State Office Building
400 Market Street
Harrisburg, PA 17101

Re: Regional Haze, Second Planning Period

Dear Mr. Hammond:

We are writing regarding the Department of Environmental Protection’s implementation plan for regional haze in the second planning period, which the Department must submit to EPA by July 31, 2021. Our organizations urge Pennsylvania to provide for reasonable progress measures in its haze plan that will significantly reduce visibility impairing pollution from sources in the state that contribute to regional haze in Class I areas like Shenandoah National Park and
the Brigantine Wilderness Area. These same measures will reduce pollution in Pennsylvania communities that have long suffered health harms from excessive emissions from the same sources.

Haze plans must meet Clean Air Act requirements for reasonable progress, taking into consideration the costs of compliance, the time necessary for compliance, and the energy and nonair quality environmental impacts of compliance, and the remaining useful life of any existing source subject to such requirements. 42 U.S.C. § 7491(g)(1); 40 C.F.R. § 51.308. Many emission reductions requirements are needed at the sources the state is evaluating, and at additional sources that the state must also review.

Enclosed with this letter is an analysis of air pollution controls at Pennsylvania electric generating units and other industrial facilities for consideration by Pennsylvania. This analysis demonstrates that the Department should investigate, and in some cases require, advanced pollution controls at these facilities. For example, at various plants, the Department should:

  • Investigate wet scrubber upgrades;
  • Investigate upgrades to selective catalytic reduction controls;
  • Prohibit the combustion of high-polluting coal and No. 2 fuel oil at some plants;
  • Investigate combustion improvements;
  • Require a four-factor reasonable progress analysis; and
  • Provide additional information to support consideration of controls.

The details of these and other issues, and to which plants they apply, appear in the attached summary, analysis, and supporting documentation. We also include general comments on control cost analyses regarding the facilities subject to the Department’s review.

By this letter, we also request that the Department explain why it selected some facilities for a four-factor analysis, and not others.

Thank you for your attention to this matter. We would like to discuss this issues raised in the attached analysis, and will contact your office to request a teleconference.

Stephanie Kodish
National Parks Conservation Association
777 6th St. NW, Suite 700
Washington, DC 20001-3723
skodish@npca.org

Rob Altenburg
Senior Director for Energy & Climate
PennFuture
610 N. Third St.
Harrisburg, PA 17101
altenburg@pennfuture.org

Rachel Filippini
Executive Director
Group Against Smog and Pollution
1133 South Braddock Ave., Suite 1A
Pittsburgh, PA 15218
rachel@gasp-pgh.org

Philip A. Francis, Jr.
Chair
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436
Washington, DC 20013
Editor@protectnps.org

Brooke Petry (she/her)
Field Organizer, Pennsylvania
Moms Clean Air Force
1103 Latona St.
Philadelphia, PA 19147
bpetry@momscleanairforce.org

Joseph Otis Minott
Executive Director and Chief Counsel
Clean Air Council
135 S. 19th St., Suite 300
Philadelphia, PA 19103
joe_minott@cleanair.org

Charles McPhedran
Earthjustice
1617 JFK Boulevard, Suite 1130
Philadelphia, PA 19103
cmcphedran@earthjustice.org

cc:
John Krueger, Assistant Director
Bryan Oshinski, Air Quality Program Specialist

READ: A Preliminary Review and Recommendations for Selected Pennsylvania Regional Haze Sources