March 21, 2022
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:
- 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.
Park County Environmental Council
Retired Registered Nurse
Cabinet Resource Group
Citizens for a Better Flathead
Dianne Spotted Elk
Northern Cheyenne Tribal Council
Lame Deer, MT
Climate Smart Missoula
Michael B. Murray
Coalition to Protect America’s National Parks
Northern Rockies Representative
Endangered Species Coalition
Families for a Livable Climate
Minister of Spiritual Direction
First Congregational United Church of Christ
Friends of 2 Rivers, Inc.
Gallatin Valley Sunrise Movement
Greater Yellowstone Coalition
Elizabeth M. Harris
Co-chair Quality of Life Committee
Montana Cancer Coalition
Montana Conservation Voters Education Fund
Upper Missouri River Breaks Audubon
Great Falls, MT
Western Environmental Law Center
Climate and Energy Program Director
Montana State Director
The Wilderness Society
Women’s Voices for the Earth
Director of Policy and Legislative Affairs
Montana Environmental Information Center
MT Health Professionals for a Healthy Climate
Steering Committee Member
Montana Poor People’s Campaign
Interim Executive Director
National Parks Conservation Association
Northern Plains Resource Council
Sr. Policy Associate
NW Energy Coalition
Senior Organizing Representative
Swan View Coalition
Reverend Gail Greener
United Church of Christ