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:

    1. Require cost-effective emissions controls for the power plants, refineries and cement kilns DEQ selected for review.
    2. 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.
    3. 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.
    4. Stop using inflated costs for pollution control measures, making those protective controls seem uneconomic when they are not.
    5. Stop underestimating the benefits that control measures can achieve.
    6. 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.


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
Coalition to Protect America’s National Parks
Washington, D.C.

David Rommereim
ELCA Lutheran
Whitefish, MT

Derek Goldman
Northern Rockies Representative
Endangered Species Coalition
Missoula, MT

Winona Bateman
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
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
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
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
Resilient Helena
Helena, MT

David Merrill
Senior Organizing Representative
Sierra Club
Missoula, MT

Keith Hammer
Swan View Coalition
Kalispell, MT

Reverend Gail Greener
United Church of Christ
Missoula, MT

Read the final technical/legal comments and community letter for MT.