June 17, 2021

Karen Hays
Branch Chief, Air Protection Branch
Georgia Environmental Protection Division
4244 International Parkway, Suite 120
Atlanta, GA 30354-3906

Richard E. Dunn, Director
Georgia Environmental Protection Division
2 Martin Luther King Jr. Drive, SE
14th Floor East Tower – Suite 1456
Atlanta, GA 30334-9000

Dear Director Dunn and Chief Hays,

On behalf of the undersigned community, health and conservation groups, we are concerned that Georgia is missing key opportunities to restore visibility in protected areas like Cohutta Wilderness Area, Okefenokee Wilderness Area, and Wolf Island Wilderness Area. Should the state not correct the course as recommended below, it will fall short of its duties under the Clean Air Act and miss important opportunities not only to improve conditions in these treasured places but also to achieve other benefits of protecting communities from harmful air pollution and reducing climate pollution.

The Clean Air Act’s regional haze provisions, 42 U.S.C. § 7491, protect public lands and communities from harmful air pollution by requiring states to make reasonable progress toward restoring natural visibility at designated national parks and wildlife refuges. Under this program, Georgia must regularly assess its progress toward restoring visibility, analyze possible reductions from air pollution sources, and present an implementation plan that incorporates additional measures to improve visibility to EPA for approval. If the plan does not meet federal standards, EPA cannot approve it and must instead issue a federal implementation plan for the state.
For the selection of sources to be evaluated for emission reducing measures under the regional haze program, APB is relying on the regionally coordinated VISTAS approach.

According to an independent analysis sponsored by NPCA, several issues were identified in the VISTAS methodology and application that unreasonably restrict the number of sources and types of pollution that the state chose to pursue. The VISTAS approach only identified three sources in GA, two paper and pulp plants and one power plant. While we support APB in evaluating these three sources, there are three other coal-fired power plants and seven other pulp and paper mills emitting high levels of pollution that are affecting multiple regional Class I areas that need to be reconsidered. There are also sources of pollution that we are concerned about near Georgia’s special Okefenokee National Wildlife Refuge and urge the state to take a closer look at those sources.

We also ask that APB request from sources analyses of nitrogen oxides (NOx) and particulate matter (PM) pollution reduction options, instead of exclusively and improperly focusing only on sulfur dioxide (SO2). Nitrogen oxides and PM (as well as Volatile Organic Compounds) are all contributors to the formation of haze. GA’s approach to narrowly focusing on SO2 is leading the state to avoid consideration of large, polluting sources of haze emissions and needs to be adjusted.

Many of our members live near these power plants and pulp and paper facilities and have lived with the negative consequences of their air pollution for decades. The pollutants mentioned above contribute to or worsen asthma, bronchitis, and other respiratory illnesses, and are linked with increased death rates from COVID-19. Yet APB has requested “four-factor analyses” of pollution control options from just three sources, only one of which is a power plant. This limited approach unreasonably takes possible visibility improvements off the table without even considering them.

It is not enough for APB to say it is merely following methodology and modeling it has developed in coordination with other Southeastern states (VISTAS). APB has the jurisdiction and authority to go above and beyond the restrictive, limited scope proposed through the VISTAS process to include a more thorough list of sources for consideration that better reflect pollution contributions to Class I areas. EPA has made clear that states must choose a reasonable methodology, and reasonably explain their decision. EPA has recommended that states include sources that account for roughly 80 percent of visibility impacts. Georgia’s selection of three sources is nowhere near this benchmark. Indeed, a reasonable approach to selecting sources would also capture additional non-coal sources throughout the state that significantly harm visibility, instead of the three sources APB identified.

National Parks Conservation Association commissioned an expert modeler to better understand the VISTAS approach and found critical problems with the VISTAS model itself as well as the approach recommended to Southeastern states. Based on the assessment of the independent expert, separate NPCA analysis and information provided by states and federal land managers, we believe Southeastern states are omitting review and consideration of controls for numerous sources that emit a significant level of visibility impairing pollution in their second-round regional haze plans.

Problems include reliance on outdated nitrogen oxide and sulfur dioxide pollution inputs, modeling assumptions based on expected but not required or assured changes in industrial facility operations and use of unreasonably high thresholds to screen out large polluters. A threshold based on the percentage any single source contributes to visibility pollution at a Class 1 area is not reasonable where, as in the Southeast, hundreds of polluting sources each contribute to pollution. APB cannot justify an approach that leads it to look at just one pollutant and three sources. We urge APD to go above and beyond VISTAS modeling to fully account for the pollution harming Class I areas.

Additionally, there are environmental justice concerns that have gone unaddressed by Georgia’s state implementation plan process. We have found that fifteen unselected emissions sources are in communities of color, and more than half of those communities live below the poverty line. Georgia has the opportunity to reduce harmful emissions in these communities, yet there has been no acknowledgment of these sources thus far.

We thank you for your attention to this important issue and appreciate the willingness of you and your staff to continue dialogues about this critical rulemaking process.


Brett Hartl
Government Affairs Director
Center for Biological Diversity
Tucson, Arizona

Phil Francis, Chair
Coalition to Protect America’s National Parks
Washington, DC

Brionte McCorckle
Executive Director
Georgia Conservation Voters
Atlanta, Georgia

Codi Norred
Executive Director
Georgia Interfaith Power and Light
Decatur, Georgia

Rachael Thompson
Executive Director
Glynn Environmental Coalition
Brunswick, Georgia

Almeta Cooper
Georgia Field Coordinator
Moms Clean Air Force
Atlanta, Georgia
Veronica Butcher
Executive Director
Mothers & Others for Clean Air
Atlanta, Georgia

Stephanie Kodish
Senior Director & Counsel, Clean Air and Climate Programs
National Parks Conservation Association
Knoxville, Tennessee

David Rogers
Deputy Regional Director
Sierra Club, Beyond Coal Campaign
Durham, North Carolina

Kurt D. Ebersbach
Senior Attorney
Southern Environmental Law Center
Atlanta, Georgia

Alex Kearns
St. Marys EarthKeepers
St. Marys, Georgia