Arizona Climate Action Coalition * Cascabel Working Group
Coalition to Protect America’s National Parks * Elders Climate Action – Arizona Chapter * Friends of Ironwood Forest * Grand Canyon Trust * Moms Clean Air Force – AZ National Parks Conservation Association * Sierra Club – Grand Canyon Chapter *  Sky Island Alliance *
Tucson Audubon * Xplore Outside

July 15, 2024

Dear Administrator Regan and Regional Administrator Guzman:

On behalf of the undersigned organizations and businesses, we write to support EPA’s proposed partial approval and partial disapproval of Arizona’s regional haze state implementation plan for the second implementation period. The organizations represented on this letter are concerned with the pollution from coal plants, mines and other industrial facilities operating in Arizona that emit haze-causing pollution that not only mar scenic vistas in our parks and wilderness areas, but
also harms the health of our communities.

Arizona is known for its vast landscapes, night skies, diversity of people and cultures and breadth of lands and waterways for recreation and peaceful enjoyment. Having clean and clear air across our state is important for so many reasons, including protecting the health of our communities, maintaining our ability to recreate outdoors and finding calm in the scenic views across the state. The quality of the air we breathe affects Arizonans and visitors to the state as well. Arizona’s economy benefits greatly from tourists to our state—in 2022, outdoor recreation alone contributed $11 billion in value to Arizona’s economy and supported 106,500 jobs.1 Bureau of Economic Analysis, Outdoor Recreation, 2022: https://apps.bea.gov/data/special-topics/orsa/summary- sheets/ORSA%20-%20Arizona.pdf This is a once-in-a-decade opp

We applaud the EPA for proposing a partial disapproval of Arizona’s flawed regional haze plan. The Arizona Department of Environmental Quality (ADEQ) produced a plan that will do nothing to clear the air of haze pollution in Arizona and in communities and Class I areas across the Southwest. The EPA’s proposal goes a long way to correct a weak and deficient plan, but we urge EPA to make the following improvements before finalizing the proposal:

  • Confirm the polluting facilities that ADEQ improperly excluded from analysis in the state’s plan;
  • Confirm the specific errors in each of the selected source’s review of pollution controls; and
  • Consider the equity and environmental justice impacts of the state’s plan and maximize the environmental justice co-benefits of haze pollution reduction opportunities.

This is a once-in-a-decade opportunity to preserve scenic vistas for future generations, keep Arizona’s tourism thriving, and protect the health of all who live here and enjoy Arizona’s treasured public lands.

We look forward to supporting a strong final action from EPA that will deliver improved visibility and air quality in parks and our communities.

Sincerely,

Hazel Chandler
Coordinator
Arizona Climate Action Coalition
Phoenix, Arizona

Philip A. Francis, Jr.
Chair
Coalition to Protect America’s National Parks
Washington, DC

Tom Hannagan
President of the Board
Friends of Ironwood Forest
Tucson, Arizona

Hazel Chandler
AZ Regional Coordinator
Moms Clean Air Force – AZ
Phoenix, Arizona

Sandy Bahr
Chapter Director
Sierra Club – Grand Canyon (Arizona) Chapter
Phoenix, Arizona

Melissa Fratello
Executive Director
Tucson Audubon
Tucson, Arizona
Anna Lands
Chairperson
Cascabel Working Group
Benson, Arizona

M. Jennifer Chandler
Director
Elders Climate Action – Arizona Chapter
Prescott, Arizona

Amanda Podmore
Grand Canyon Director
Grand Canyon Trust
Flagstaff, Arizona

Sanober Mirza
Arizona Program Manager
National Parks Conservation Association
Tucson, Arizona

Emil Burns
Program Director
Sky Island Alliance
Tucson, Arizona

Jim Dublinski
Owner
Xplore Outside
Scottsdale, Arizona
  • 1
    Bureau of Economic Analysis, Outdoor Recreation, 2022: https://apps.bea.gov/data/special-topics/orsa/summary- sheets/ORSA%20-%20Arizona.pdf This is a once-in-a-decade opp