Comments Submitted Via submitted via regulations.gov:
https://www.regulations.gov/commenton/EPA-R08-OAR-2023-0489-0001
September 3, 2024
Jaslyn Dobrahner
Air and Radiation Division
EPA Region 8
Mailcode 8ARD-IO
1595 Wynkoop Street
Denver, CO 80202-1129
Subject: Comments on EPA Region 8’s proposed response to Wyoming’s Regional Haze Plan.
Dear Ms. Dobrahner and Regional Administrator Becker:
I am writing on behalf of more than 2,700 members of the Coalition to Protect America’s National Parks (Coalition), who collectively represent more than 50,000 years of national park management and stewardship experience. Our membership includes over 20 members who currently live in Wyoming, and hundreds of other members who have worked in the state of Wyoming throughout their National Park Service (NPS) careers.
The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. Among our members are former NPS directors, regional directors, superintendents, resource specialists, park rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters. We strongly support efforts to ensure clean air and clear views are protected in our national parks throughout the country.
We appreciate the opportunity to comment on the EPA’s proposal to partially approve and partially disapprove the state of Wyoming’s Regional Haze State Implementation Plan. The Clean Air Act requires states to improve visibility in protected areas, where millions of people each year visit to enjoy spectacular scenery, outstanding natural habitats for native plants and animals, and incredible dark skies at night. The Clean Air Act also requires each state to identify and evaluate the effects of industrial emissions from motor vehicles, power plants, oil and gas developments and operations, and other sources on Class I airsheds within, and even in, neighboring states.
Wyoming has identified 23 Class I areas that must be addressed by their long-term strategy for improving air quality, including both Grand Teton and Yellowstone National Parks, as well as adjoining wilderness areas in national forests within the state boundaries. In addition, Wyoming acknowledges that in-state sources of emissions and air pollutants affect eight other national park or monument areas in five states: Rocky Mountain National Park in Colorado; Craters of the Moon National Monument in Idaho; Theodore Roosevelt National Park in North Dakota; Badlands and Wind Cave National Parks in South Dakota; and Arches, Canyonlands, and Capitol Reef National Parks in Utah.
The Western Regional Air Partnership (WRAP), which represents the NPS, other federal partners, twenty-eight tribal governments, and fifteen states, supports the IMPROVE network of monitoring stations that provide data on air quality in the parks and other Class I airsheds. We appreciate the progress made through these partnerships toward improvements in air quality and visibility within Wyoming and the affected national parks, and the EPA’s approval of Wyoming’s monitoring strategy.
Unfortunately, the majority of Wyoming’s proposed regional haze plan fails to make reasonable progress toward clearer skies in Class I areas and we commend EPA for partially disapproving of the plan. As summarized in Table 32 of Federal Register Notice,1EPA–R08–OAR–2023–0489; FRL–12135– 01–R8, Air Plan Partial Approval and Partial Disapproval; Wyoming; Regional Haze Plan for the Second Implementation Period; https://www.regulations.gov/document/EPA-R08-OAR-2023-0489-0001. multiple identified industrial sources cause unacceptably high levels of nitrogen oxides (NOx), sulfur dioxide (SO2), and particulate matter (PM10) at nine of the NPS units. Harmful pollution can be attributed especially to the Jim Bridger, Naughton, and Dave Johnston Power Plants, as well as the Laramie River Station and Wyodak Power Plants. The State of Wyoming failed to evaluate pollution control options for four of those coal-fired power plants and did not propose requiring pollution controls on any of the plants or other industrial sources.
For these reasons, we support the EPA’s requirement that Wyoming do more – through a revised State Implementation Plan and required consultation with federal land managers – to achieve improvements in air quality that will benefit national parks and other Class I airshed within and beyond Wyoming. A stronger long-term strategy to reduce regional haze will benefit the health and enjoyment of millions of regional residents and visitors to national parks and wilderness areas from the Dakotas to the Great Basin.
Many of our Coalition members have worked to protect national park sites and public lands in and around Wyoming for decades. We will continue to urge strong action to protect these irreplaceable spaces for the enjoyment of visitors now and for our future generations.
Thank you for considering our input on this important issue.
Sincerely,
Philip A. Francis, Jr.
Chair of the Executive Council
Coalition to Protect America’s National Parks
Sue Consolo-Murphy
Wyoming resident
Executive Council Member, Coalition to Protect America’s National Parks
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436, Washington, DC 20013
Phone: (202) 819-8622
[1] EPA–R08–OAR–2023–0489; FRL–12135– 01–R8, Air Plan Partial Approval and Partial Disapproval; Wyoming; Regional Haze Plan for the Second Implementation Period; https://www.regulations.gov/document/EPA-R08-OAR-2023-0489-0001.