Comments Submitted via regulations.gov: https://www.regulations.gov/commenton/EPA-R08-OAR-2024-0389-0001
September 18, 2024
Clayton Bean
Air and Radiation Division EPA Region 8
1595 Wynkoop Street
Denver, Colorado 80202-1129
Subject: Comments on EPA’s proposed response to Utah’s Regional Haze State Implementation Plan.
Dear Mr. Bean and Regional Administrator Becker:
We are writing on behalf of more than 2,800 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 45 members who currently live in Utah, and hundreds of other members who have worked in the state of Utah 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 Utah’s Regional Haze State Implementation Plan (SIP) for the second implementation period. 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.
Utah has identified five mandatory Federal Class I areas that must be addressed by their long-term strategy for improving air quality: Arches National Park, Bryce Canyon National Park, Canyonlands National Park, Capitol Reef National Park, and Zion National Park. In addition, Utah acknowledges that in-state sources of emissions and air pollutants affect visibility of forty- five Class I areas outside the State, including Federal Wilderness areas and nine areas managed by the National Park Service consisting of Craters of the Moon National Monument & Preserve in Idaho; Grand Canyon and Petrified Forest National Parks in Arizona; Grand Teton and Yellowstone National Parks in Wyoming; and Black Canyon of the Gunnison, Mesa Verde and Rocky Mountain National Parks, and Great Sand Dunes National Park & Preserve in Colorado.
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 Utah and the affected national parks, and the EPA’s approval of Utah’s monitoring strategy.
Unfortunately, the majority of Utah’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 indicated in the Federal Register Notice,1EPA-R08-OAR-2024-0389; FRL-12173-01-R8, Air Plan Partial Approval and Partial Disapproval; Utah; Regional Haze State Implementation Plan for the Second Implementation Period; Air Plan Disapproval; Utah; Interstate Transport of Air Pollution for the 2015 8-Hour Ozone National Ambient Air Quality Standards; https://www.federalregister.gov/documents/2024/08/19/2024-18462/air-plan-partial-approval-and-partial- disapproval-utah-regional-haze-state-implementation-plan-for#h-61. multiple identified industrial sources cause unacceptably high levels of nitrogen oxides (NOx) and sulfur dioxide (SO2), at five of the NPS units. Harmful pollution can be attributed especially to the Hunter and Huntington Power Plants, as well as the CCI Paradox Lisbon Natural Gas Plant. The State of Utah failed to evaluate pollution control options for the coal-fired power plants and industrial sources within its jurisdiction and did not propose requiring pollution controls on any of these sources.
For these reasons, we support the EPA’s requirement that Utah 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 Utah. 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 within and beyond the Colorado Plateau area.
Many of our Coalition members have worked to protect national park sites and public lands in and around Utah for decades. Some of us have also participated in regional haze planning in Utah, providing comment letters and testimonials during the development of the state’s plan. Unfortunately, those recommendations were ignored. It is timefor 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
Phil Brueck, Utah resident
Retired Deputy Superintendent, Southeast Utah Group,
Member, Coalition to Protect America’s National Parks
Susan L. Fritzke, Utah resident
Retired Superintendent, Capitol Reef National Park
Executive Council Member, Coalition to Protect America’s National Parks
Linda Mazzu, Idaho resident
Retired Superintendent, Bryce Canyon National Park
Executive Council Member, Coalition to Protect America’s National Parks
Bill Wade, Arizona resident
Retired Superintendent, Shenandoah National Park
Member, Coalition to Protect America’s National Parks