July 9, 2021

Ashley Kung
Florida Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL 32301

Re: Conservation Organizations’ Comments on Florida’s Proposed Revisions Regional Haze State Implementation Plan for the Second Implementation Period

Dear Ms. Kung:

The National Parks Conservation Association, Coalition to Protect America’s National Parks and Sierra Club (“Conservation Organizations”) thank you for accepting these comments on the Florida Department of Environmental Protection’s (“FL DEP”) Proposed Revisions to Regional Haze State Implementation Plan for the Second Implementation Period.1The attachment comments include, “A Review of the Florida Regional Haze State Implementation Plan,” which was prepared for NPCA by Joe Kordzi (July 2021) (Enclosure 1, “Kordzi Report”). Mr. Kordzi is an independent air quality consultant and engineer with extensive experience in the regional haze program.

National Parks Conservation Association (“NPCA”) is a national organization whose mission is to protect and enhance America’s National Parks for present and future generations. NPCA performs its work through advocacy and education. NPCA and its nearly 1.6 million members and supporters nationwide work together to protect our nation’s most iconic and inspirational places for future generations. NPCA’s Sun Coast regional office is based in South Florida; we work together with over 100,000 members and supporters in Florida to advance protections for treasured ecosystems and the species they provide refuge for. NPCA has carried out our important work to help preserve our national park units and surrounding landscapes since our founding in 1919. NPCA is active nation-wide in advocating for strong air quality requirements to protect our parks, including submission of petitions and comments relating to visibility issues, regional haze State Implementation Plans, global warming and mercury impacts on parks, and emissions from individual power plants and other sources of pollution affecting National Parks and communities. NPCA’s members live near, work at, and recreate in all the national parks, including those directly affected by emissions from Florida’s sources.

The Coalition to Protect America’s National Parks (“Coalition”) is a non-profit organization composed of over 1,900 retired, former and current employees of the National Park Service (“NPS”). The Coalition studies, speaks, and acts for the preservation of America’s National Park System. As a group, we collectively represent over 40,000 years of experience managing and protecting America’s most precious and important natural, cultural, and historic resources.

The Sierra Club is a national nonprofit organization with approximately 830,000 members nationwide dedicated to exploring, enjoying, and protecting the wild places of the earth; to practicing and promoting the responsible use of the earth’s ecosystems and resources; to educating and enlisting humanity to protect and restore the quality of the natural and human environment; and to using all lawful means to carry out these objectives. The Sierra Club has long participated in Regional Haze rulemaking and litigation across the country in order to advocate for public health and our nation’s national parks. The Florida Chapter of the Sierra Club has approximately 240,000 members and supporters.

As detailed below, FL DEP’s proposed SIP will not result in reasonable progress towards improving visibility at the Class I Areas its sources impact. These Class I Areas include the Everglades National Park, which is “the largest subtropical wilderness in the United States Everglades National Park protects an unparalleled landscape that provides important habitat for numerous rare and endangered species like the manatee, American crocodile, and the elusive Florida panther.”2 To satisfy the Clean Air Act (“Act”) and Regional Haze Rule (“RHR”) the flaws identified in these comments and in the attached technical report by Joe Kordzi must be corrected before submittal to EPA, including:

● Inappropriately screening sources from the required four-factor analysis;
● Technical analyses that are inconsistent with the Act and RHR requirements;
● Lack of required practically enforceable emission limitations;
● Disregarding environmental justice impacts, resulting in a proposed SIP that does not reduce emissions and minimize harms to disproportionately impacted communities.


Read the complete letter and technical report here (PDF).