April 21, 2022
Secretary Deborah Haaland
U.S. Department of Interior
Washington, D.C.
Director Charles F. “Chuck” Sams III
National Park Service
U.S. Department of Interior
Washington, D.C.
Dear Secretary Haaland and Director Sams,
On behalf of our millions of members and supporters nationwide, we, the undersigned 56 organizations, thank you for your commitment to our national parks, public lands and communities. We are encouraged that the Department of the Interior (DOI) and the National Park Service (NPS) are now in good hands as we work together to tackle critical and challenging issues.
We write today to urge you to exhibit this same bold leadership to advance DOI and NPS interests for substantial pollution reducing requirements to restore clean and clear air to national parks and wilderness areas nationwide. As federal partners with the Environmental Protection Agency (EPA), we ask you to ensure that EPA leadership take actions to satisfy the requirements of the Regional Haze Rule and address the concerns and recommendations of Federal Land Managers (FLMs) for the benefit of public lands and communities across the country. The EPA needs to hear from you that the regional haze program is a priority.
Federal Land Manager Role in Haze Planning
As you know, states and the EPA are currently in the second planning phase of the regional haze program, following the Clean Air Act mandate for states to revise their haze plans once a decade until the goal of restoring natural visibility at the 156 Class I areas around the country is achieved. In consultation with your bureau and department staff, state agencies are required to develop plans to reduce air pollution to make reasonable progress towards natural air quality at every Class I area from Badlands to Shenandoah and Crater Lake to Acadia.
The Clean Air Act establishes a unique and important role for FLMs in the regional haze planning process—FLMs are not regular stakeholders. As the Regional Haze Rule declares, the input of FLMs should “meaningfully inform State decisions” about the requirements in their regional haze state implementation plans. These requirements must be measures that limit the pollution that creates haze, predominantly particulate matter, nitrogen oxides and sulfur dioxides that are emitted from thousands of polluting facilities of all kinds: coal-fired power plants, oil and gas development, pulp and paper mills, cement, chemical and plastics manufacturing, other industrial sources, and vehicles.
States Ignoring FLM Feedback
For this round of planning, states across the country as well as industry, FLMs and the public, have demonstrated real opportunities for emissions reductions from polluting facilities. But so far, states have largely decided not to require meaningful pollution reduction measures, not only ignoring FLM recommendations (predominantly those from the National Park Service) but also failing to lock in new clean air gains thereby allowing the continued release of hundreds of thousands of tons of haze pollution into the air over the coming decade.
For example, prior to the release of the Texas draft haze plan for public comment, the NPS provided input to the state agency articulating several significant concerns and recommending haze plan improvements. NPS asked the state to explicitly consider Carlsbad Caverns National Park and Bandelier National Monument in New Mexico as well as Big Bend National Park in Texas in choosing sources to evaluate for pollution control as these Class I areas are negatively harmed by pollution from Texas sources. Additionally, NPS recommended emission reduction measures be required at the state-reviewed sources as well as consideration of additional sources including emission limits on oil and gas operations in the Permian Basin. NPS also recommended the state align its cost calculations with the criteria in the EPA’s Air Pollution Control Cost Manual. Doing so would result in defensible analysis of determinations for emission reducing measures. But in the state’s proposed draft for public comment, the NPS input was completely ignored, and the state found that the 18 sources reviewed for emission reduction measures do not merit any pollution
reductions during this planning period.
Similar examples abound across state haze plans from North Carolina to Washington State and consequently, the emissions reductions that should flow from state haze plan requirements seem anything but promising as a means of restoring clean air to our public lands.
Clean Air for Everyone
The same pollution that mars scenic views in Class I areas also harms people’s health, drives up healthcare costs, and makes it harder for kids to learn and play and adults to work. Consistent with DOI stated priorities to center equity and environmental justice, many of the sources that should be cleaned up through state haze plans are in or next to communities of color and poor neighborhoods who are overburdened by the injustices of pollution of all kinds. According to an ongoing analysis by National Parks Conservation Association (NPCA), 64 sources of haze pollution in just 16 states have an outsized impact on vulnerable communities – communities defined by the environmental justice markers of people of color and people living below the poverty line. These identified sources lack the best pollution controls or control upgrades that would reduce emissions and relieve some of the pollution burden on these communities.
Haze not only degrades clear skies and the health of people in nearby communities, but it threatens local economies that depend on clean, healthy national parks. As you know, national park sites are economic drivers for local communities, providing tens of billions of dollars in economic output each year and supporting hundreds of thousands of jobs nationwide. A 2018 study by Iowa State University and Cornell University shows that park visitation drops when air pollution is high, indicating the direct effect air quality has on the visitor experience. Americans value clean air and expect to breathe clean air and see miles of stunning views, not dirty air pollution, in our parks.
Regional Haze is Top Priority
While the EPA is obligated to ensure state actions further the goal that Congress set for our Class I areas—clean air and clear views in some of our most special places around the country—it is the Federal Land Managers, including the Department of the Interior and National Park Service, that are charged with the duty of care for many of the places the regional haze program is designed to restore. This duty is why we ask for your leadership in ensuring that the EPA understands the value and import of this Rule to you and your department and acts accordingly. We ask you to engage directly with EPA leadership and articulate an expectation that meaningful emissions reductions be required in state regional haze plans.
We know you face many challenges in guiding the protection and stewardship of our cultural, historic and natural spaces, but we urge you to give priority attention to the faithful implementation of this Clean Air Act program. We cannot miss this opportunity that comes once a decade to make real progress towards clean air in our national parks, wilderness areas and communities.
Sincerely,
Alliance of Nurses for a Healthy Environment (Colorado)
Appalachian Mountain Club
Badlands Conservation Alliance
Cabinet Resource Group
Center for Biological Diversity
Central California Asthma Collaborative
Clean Air Task Force
CleanAIRE NC
Coalition to Protect America’s National Parks
Diné Citizens Against Ruining Our Environment
Earthjustice
Endangered Species Coalition
Environmental Defense Fund
Environmental Law & Policy Center
Evergreen Action
Friends of the Boundary Waters
GASP (Greater Birmingham Alliance to Stop Pollution)
Gallatin Valley Sunrise Movement
Georgia Interfaith Power and Light
Great Old Broads for Wilderness
GreenLatinos
HEAL Utah
Hoosier Environmental Council
Just Transition Northwest Indiana
Kentucky Resources Council
Montana Environmental Information Center
Montana Health Professionals for a Healthy Climate
National Parks Conservation Association
Natural Resources Defense Council
New Mexico & El Paso Interfaith Power and Light
New Mexico Climate Justice
North Cascades Conservation Council
Olympic Park Advocates
Oregon Environmental Council
Partnership for Responsible Business
Powder River Basin Resource Council
Public Citizen
Respiratory Health Association
San Juan Citizens Alliance
Sierra Club
Southern Utah Wilderness Alliance
Sowing Justice
Swan View Coalition
Tennessee Citizens for Wilderness Planning
Tennessee Interfaith Power and Light
The Alliance for Appalachia
The Wilderness Society
Tó Nizhóní Ání
Utah Physicians for a Healthy Environment
Voyageurs Conservancy
Waterway Advocates
Western Clean Energy Campaign
Western Environmental Law Center
Wild Alabama
WildEarth Guardians
Womxn from the Mountain
cc:
Rachael Taylor
Susan Farinelli