March 21, 2022
Rhonda Payne
Montana Department of Environmental Quality
Air Quality Bureau
1520 E 6th Avenue
Helena, MT 59620-0901
Re: Montana’s Regional Haze State Implementation Plan for the 2nd Implementation Period Dear Ms. Payne:
On behalf of the undersigned organizations, we respectfully submit this comment letter on Montana’s Regional Haze State Implementation Plan for the 2nd Implementation Period (RH SIP). As you know, the regional haze program is a time-tested, effective program that has provided real, measurable and noticeable improvements in national park visibility and air quality across the country. The 2nd Implementation Period affords states the opportunity to continue improving air quality in not only our national parks and wilderness areas, but in our communities and cities across the country.
Montanans are familiar with hazy air. Far too often, our summers are ruined by smoke-filled skies that drive people indoors and to emergency rooms. Winter inversions in many of our valleys can create some of the most dangerous levels of air pollution all year. We can’t immediately prevent winter inversions or mega-forest fires – other than reverse course on the climate crisis – so when there is an opportunity to limit harmful pollution that worsens haze pollution, we should eagerly embrace it.
Unfortunately, we believe that the Montana Department of Environmental Quality (DEQ) has proposed a ‘do nothing’ regional haze plan for the 2nd Implementation Period which will not lead to increased air quality in Montana or our surrounding states. By requiring nothing of major industrial pollution sources for this planning cycle, and instead kicking the can to the next planning cycle, DEQ is failing Montanans and the millions of people who visit our state each year to enjoy our incredible outdoor resources.
Moreover, the pollutants at issue for the regional haze program are also harmful to public health, especially communities living near the pollution sources such as the people of the Northern Cheyenne and Crow Agency, Billings, Helena, and Bozeman. The Colstrip Steam Electric Station, in Rosebud County, is a top 10 worst haze polluter in the whole country and impacts parks and communities as far as Southern Colorado.
We hope you’ll consider our below recommendations for improvements to the RH SIP before submitting it to the U.S. Environmental Protection Agency (EPA).
Recommended Improvements to Montana’s Regional Haze SIP
While DEQ selected 16 pollution sources for review of emission-reducing measures, DEQ determined that no new reductions in emissions are warranted at any of the sources. This decision means that close to 30,000 tons of SO2 and NOx will continue to pollute Montana’s air for the next decade. We believe this is unacceptable and recommend the following improvements to the plan:
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- Require cost-effective emissions controls for the power plants, refineries and cement kilns DEQ selected for review.
- Establish a cost-effective monetary threshold for each ton of pollution reduction that is at least as strong as Colorado’s threshold of $10,000 per ton of pollution.
- Require Hardin Generating Station to conduct a review of emission-reducing measures given the significant increase in emissions in the past year due to its revival as a cryptocurrency mining energy source.
- Stop using inflated costs for pollution control measures, making those protective controls seem uneconomic when they are not.
- Stop underestimating the benefits that control measures can achieve.
- Thoroughly assess the environmental justice impacts of the RH SIP.
We believe that if the state’s plan is left unchanged, it will not comply with the Federal Clean Air Act and the EPA’s Regional Haze Rule as it does little to limit haze-causing air pollution and fails to help restore naturally clean air. Please do not overlook this once-in-a-decade opportunity to not only preserve viewsheds in our parks and public lands, but to protect the health of Montanans and all who visit our great state.
Sincerely,
| Michelle Uberuaga Executive Director Park County Environmental Council Livingston, MT Colleen Hinds Retired Registered Nurse Cabinet Resource Group Heron, MT Mayre Flowers Board Co-Chair Citizens for a Better Flathead Kalispell, MT Dianne Spotted Elk Northern Cheyenne Tribal Council Northern Cheyenne Lame Deer, MT Amy Cilimburg Executive Director Climate Smart Missoula Missoula, MT Michael B. Murray Chair Coalition to Protect America’s National Parks Washington, D.C. David Rommereim Clergy ELCA Lutheran Whitefish, MT Derek Goldman Northern Rockies Representative Endangered Species Coalition Missoula, MT Winona Bateman Director Families for a Livable Climate Missoula, MT Barbara Gulick Minister of Spiritual Direction First Congregational United Church of Christ Billings, MT Gary Matson Science Advisor Friends of 2 Rivers, Inc. Milltown, MT Isabel Shaida Hub Coordinator Gallatin Valley Sunrise Movement Bozeman, MT Scott Christensen Executive Director Greater Yellowstone Coalition Bozeman, MT Steve McArthur Management Consultant McArthur Consulting Missoula, MT Elizabeth M. Harris Co-chair Quality of Life Committee Montana Cancer Coalition Bozeman, MT Whitney Tawney Executive Director Montana Conservation Voters Education Fund Bozeman, MT | Daniel Bennett Upper Missouri River Breaks Audubon Great Falls, MT Barbara Chillcott Senior Attorney Western Environmental Law Center Helena, MT Brian Schott Editor-in-Chief Whitefish Review Whitefish, MT Jeremy Nichols Climate and Energy Program Director WildEarth Guardians Missoula, MT Scott Brennan Montana State Director The Wilderness Society Bozeman, MT Jamie McConnell Deputy Director Women’s Voices for the Earth Missoula, MT Anne Hedges Director of Policy and Legislative Affairs Montana Environmental Information Center Helena, MT Robert Byron Vice-Chair MT Health Professionals for a Healthy Climate Hardin, MT Hannah Hernandez Steering Committee Member Montana Poor People’s Campaign Heron, MT Hunter Losing Interim Executive Director MontPIRG Missoula, MT Betsy Buffington Regional Director National Parks Conservation Association Bozeman, MT Joanie Kresich Board Chair Northern Plains Resource Council Livingston, MT Diego Rivas Sr. Policy Associate NW Energy Coalition Helena, MT Diana Hammer Co-Founder Resilient Helena Helena, MT David Merrill Senior Organizing Representative Sierra Club Missoula, MT Keith Hammer Chair Swan View Coalition Kalispell, MT Reverend Gail Greener Minister United Church of Christ Missoula, MT |
Read the final technical/legal comments and community letter for MT.