August 18, 2023
Mississippi Department of Environmental Quality
Office of Pollution Control, Air Division
P.O. Box 2261, Jackson, MS 39225
Attn: Carla Brown
Re: Conservation Organizations Comments on the Pre-Hearing Draft Mississippi Regional Haze State Implementation Plan
Dear Ms. Brown,
The National Parks Conservation Association, Coalition to Protect America’s National Parks and Sierra Club (“Conservation Organizations”) submit the following comments and attached expert report regarding the Mississippi Department of Environmental Quality’s (“MDEQ”) Pre-Hearing Draft Mississippi Regional Haze State Implementation Plan dated June 19, 2023 (“Proposed SIP”).
As discussed in these comments and in the attached expert report, we have serious concerns regarding MDEQ’s Proposed SIP. As detailed below, MDEQ’s Proposed SIP will not improve visibility at the Class I areas its sources impact.
Despite the thousands of tons of controllable pollution from Mississippi sources including coal-fired power plants, pipeline transportation of natural gas, lime manufacturing, paperboard mills, among others, and the many opportunities for cost-effective controls, Mississippi improperly concludes that no new reductions in pollution are warranted. Indeed, MDEQ selected only two sources, and erroneously “opted to show they are already effectively controlled for [sulfur dioxide] SO2 in lieu of a [F]our-[F]actor [A]nalysis”,1“Mississippi’s State Implementation Plan for Regional Haze,” Pre-Hearing Draft (June 19, 2023), (“Proposed SIP”) Proposed SIP at 136. Available at: https://www.mdeq.ms.gov/wp- content/uploads/2023/06/MS-Regional-Haze-Plan-Revision-Prehearing-V ersion-06-19-2023.pdf. despite viable, cost- effective control options. Moreover, MDEQ must also do Four-Factor Analyses for additional sources and ensure pollution controls are required to cut emissions from the polluting sources. MDEQ failed to properly consider a number of sources that could potentially negatively affect the visibility at Sipsey Wilderness Area and Breton National Wildlife Refuge. There are well established controls that could be considered for the sources omitted by MDEQ for review.2In so doing, MDEQ should consider a recent report that addresses controls for source categories applicable to the oil and gas industry, including compressor stations. Natural Gas-Fired Engines Natural Gas-Fired Turbines Diesel-Fired Engines Natural Gas-Fired Heaters and Boilers Flaring and Incineration, Prepared for National Parks Conservation Association by Vicki Stamper & Megan Williams, March 5, 2020. Available at: https://drive.google.com/file/d/1XqawjExzEgJ8nwfj1X6RNoDSB0PxOiBV/view?usp=drive_link
Click here to read the complete letter to the Mississippi Department of Environmental Quality.