March 18, 2024
William Kenny
Ohio Environmental Protection Agency
Lazarus Government Center
P.O. Box 1049
Columbus, Ohio 43216-1049
Electronic Filing via Email Wi***********@ep*.gov
Re: Comments on the Ohio Environmental Protection Agency’s Supplement to the Regional Haze State Implementation Plan for the Second Implementation Period
The National Parks Conservation Association (NPCA), Sierra Club, the Coalition to Protect America’s National Parks, and the Ohio Environmental Council (OEC) (collectively, the Conservation Organizations) submit the following comments on the Ohio Environmental Protection Agency’s (Ohio EPA) Supplement to the Regional Haze State Implementation for the Second Implementation Period (SIP Supplement).
The Conservation Organizations are active nationwide in advocating for strong air quality requirements to protect our national parks and wilderness areas. These groups have long participated in Regional Haze SIP comment periods, rulemakings, and litigation across the country to ensure that states and the U.S. Environmental Protection Agency (EPA) satisfy their obligations under the Clean Air Act and the Regional Haze Rule (RHR). The Conservation Organizations’ members—including NPCA’s 59,700+ members and Sierra Club’s over 18,000 members who live in Ohio—use and enjoy Class I areas that are impacted by Ohio’s sources of haze-forming pollution.
With its SIP Supplement, Ohio EPA fails to address the numerous issues raised in the Conservation Organizations’ comments and the technical report submitted from Joe Kordzi on the State’s Regional Haze State Implementation Plan originally submitted to EPA on July 30, 2021 (2021 SIP Revision).12021 SIP Revision, App’x P10, Nat’l Parks Conservation Ass’n, et al., Conservation Organizations Comments on Ohio’s Proposed Regional Haze State Implementation Plan for the Second Planning Period (June 28, 2021) [hereinafter “Conservation Orgs’ 2021 SIP Revision Comments”]; 2021 SIP Revision, App’x P10, Kordzi, Joe, A Review of the Ohio Regional Haze State Implementation Plan (June 2021) [hereinafter “2021 Kordzi Report”]. Rather than correcting the errors the Conservation Organizations previously identified, Ohio EPA adds to the deficiencies with its SIP Supplement. With respect to Gavin, Ohio EPA’s approach still fails to meet the requirements of the Clean Air Act and RHR. Gavin’s SO2 emissions are very high, its existing flue gas desulfurization (FGD) systems have reached the end of their useful lives, and Ohio EPA should require that new FGDs be installed at these massive units. New FGDs at Gavin are cost-effective and would reduce haze at the most iconic parks in the East, including Shenandoah National Park and Great Smoky Mountains National Park. Ohio EPA also failed to adequately document options for improving the performance of Gavin’s dysfunctional FGDs. Further, Ohio EPA failed to demonstrate that Gavin is “effectively controlled for NOx.” Similarly, Ohio EPA still fails to demonstrate that the Cardinal Power Plant and Kyger Creek Station are “effectively controlled,” and its own reliance on existing or newly proposed emission limits for those facilities is misplaced. Along with these comments, the Conservation Organizations submit a report prepared by Joe Kordzi (Kordzi SIP Supplement Report), which is attached and incorporated by reference into these comments.2Kordzi, Joe, A Review of the Ohio Regional Haze State Implementation Plan Supplement of February 2024 (March 2024) [hereinafter “Kordzi SIP Supplement Report”] (attached as Ex. 1). Mr. Kordzi is an independent air quality consultant and engineer with extensive experience in the regional haze program.
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