March 16, 2023
Re: Conservation Organizations’ Comments on Iowa’s Draft State Implementation Plan Regional Haze Second Implementation Period (2019-2028)
Dear Mr. Johnson:
Sierra Club, National Parks Conservation Association, Coalition to Protect America’s National Parks, Iowa Interfaith Power & Light (“Conservation Organizations”) submit the following comments regarding the Iowa Department of Natural Resources’ (“IDNR”) Draft State Implementation Plan Regional Haze Second Implementation Period (2019-2028) (“Draft SIP”). We also submit the report of Victoria R. Stamper (“Stamper Report”), which is attached and incorporated by reference into these comments.1Attached to the comments is “Review and Comments on Reasonable Progress Controls for the Iowa Regional Haze Plan for the Second Implementation Period,” which was prepared for Sierra Club by Victoria R. Stamper (March 14, 2023) (Enclosure 1, “Stamper Report”). Ms. Stamper is an independent air quality consultant and engineer with extensive experience in the regional haze program. The exhibits to the Stamper Report are available in the folder at this location: https://drive.google.com/drive/folders/1_LP1IICja8jLmgywfzxIPY3QBXgeg6uB?usp=sharing
Sierra Club is a national nonprofit organization with 67 chapters and more than 832,000 members 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. Sierra Club’s Iowa Chapter, which represents Iowa, has over 5,200 members. 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.
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, with its main office in Washington, D.C. and 24 regional and field offices. NPCA has over 1.7 million members and supporters nationwide and more than 17,600 in Iowa. NPCA is active nationwide 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, climate change impacts on parks, and emissions from power plants, oil and gas operations 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 Iowa’s sources.
The Coalition to Protect America’s National Parks (“Coalition”) is a non-profit organization composed of more than 2,100 retired, former and current employees of the National Park Service. 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.
As described in our comments, the Conservation Organizations’ have serious concerns with IDNR’s Draft SIP. For example,
- IDNR’s screening method contains a fatal flaw, which arbitrarily results in IDNR ignoring two sources with visibility impacts greater than the sources it selected for regulation.
- IDNR allows for use of an unreasonably high interest rate, truncated life of emission control equipment, low cost threshold and unreasonably high cost estimates to screen out cost-effective controls for its large coal-burning power plants.
- IDNR fails to consider all emissions control options for the Walter Scott Jr. and Louisa coal-burning power plants, including requiring better optimization of existing equipment.
- IDNR wrongfully exempts the George Neal North and George Neal South coal-burning power plants from controls based on erroneous use of visibility as a fifth factor and purported compliance by other states with the Uniform Rate of Progress.
- IDNR’s interstate consultation consists of meetings to share updates, rather than engaging in the joint planning process as required by the Regional Haze Rule.
- IDNR inadequately considers and ignores the Federal Land Managers’ comments.
- IDNR entirely failed to evaluate environmental justice impacts and issue a plan, which reduces emissions and minimize harms to disproportionately impacted communities, as EPA’s regulations and guidance urge it to do.
The Regional Haze program offers a significant opportunity to improve visibility at the Class I areas impacted by Iowa’s sources, and also improve air quality for Iowa’s most vulnerable communities. Despite these opportunities, IDNR’s Draft SIP does neither. Moreover, the Draft SIP fails to satisfy the requirements of the Clean Air Act. IDNR must revise its plan to address the fundamental flaws identified in these comments.
Download the report here.
The organizations appreciate the opportunity to review Iowa’s Draft Regional Haze SIP, and we look forward to seeing a revised plan that takes our comments into consideration. Please do not hesitate to reach out if you have any questions.
Counsel for Sierra Club
- 1Attached to the comments is “Review and Comments on Reasonable Progress Controls for the Iowa Regional Haze Plan for the Second Implementation Period,” which was prepared for Sierra Club by Victoria R. Stamper (March 14, 2023) (Enclosure 1, “Stamper Report”). Ms. Stamper is an independent air quality consultant and engineer with extensive experience in the regional haze program. The exhibits to the Stamper Report are available in the folder at this location: https://drive.google.com/drive/folders/1_LP1IICja8jLmgywfzxIPY3QBXgeg6uB?usp=sharing