7 Directions of Service * Blue Ridge Outdoors Magazine
Center for Biological Diversity * CleanAIRE NC
Coalition to Protect America’s National Parks * Dogwood Alliance
Forest Keeper * Friends of Big Ivy * I Heart Pisgah * MountainTrue
National Parks Conservation Association * North Carolina Black Alliance
Toxic Free North Carolina

September 19, 2024

Dear Acting Regional Administrator Gettle and Ms. Notarianni,

On behalf of the undersigned organizations, we write to strongly oppose the EPA’s proposed approval in part and conditional approval in part of the regional haze State Implementation Plan (SIP) revision submitted by the North Carolina Department of Environmental Quality, Division of Air Quality (NC DAQ). The organizations represented on this letter are concerned with the pollution from coal-fired power plants, pulp and paper mills and numerous industrial facilities operating in North Carolina that emit haze-causing pollution that mar scenic vistas in our national parks and wilderness areas and harm the health of nature and our communities.

North Carolina is home to 22 industrial facilities that degrade the air quality not only in our own Great Smoky Mountains National Park and Joyce-Kilmer-Slickrock, Linville Gorge, Shining Rock, and Swanquarter Wilderness Areas, but also in at least 17 surrounding regional Class I areas like Shenandoah and Mammoth Cave National Parks, and communities along the way.

North Carolina’s facilities emit more than 53,000 tons of haze-causing sulfur dioxide (SO2) and nitrogen oxides (NOx) pollution per year, disproportionately impacting communities of color and low-income communities that often live close to the polluting sources.

North Carolina boasts some of the most unique and treasured public lands in the South – from the calm marshes and ocean waves of Cape Hatteras to the deep 2,000-foot Linville Gorge to portions of the world-famous Appalachian National Scenic Trail with its stunning scenic views of the Blue Ridge Mountains, drawing visitors from inside and outside of the state. In 2022, outdoor recreation activities in the state contributed nearly $15 billion in value to North Carolina’s economy, supporting more than 146,000 jobs.1Bureau of Economic Analysis, North Carolina, 2022: https://apps.bea.gov/data/special-topics/orsa/summary- sheets/ORSA%20-%20North%20Carolina.pdf Tourism and enjoying the outdoors is a lifeblood of our state and vital to many of our organizations.

In August 2021, NC DAQ submitted a regional haze plan to EPA that fails to reduce pollution, falling short on the state’s obligation to improve air quality for protected parks, wilderness areas and communities. The plan relied on a flawed modeling system prepared by the Regional Planning Organization, Visibility Improvement State and Tribal Association of the Southeast (VISTAS). The VISTAS approach used decade-old data and does not accurately represent nor include nitrogen oxide (NOx) emissions contributing to haze pollution; nor does it include many of the biggest polluting facilities in the state that are exacerbating haze pollution.

Moreover, NC DAQ’s flawed source selection excluded coal units from a full review. Duke Energy’s coal plants are some of the biggest haze polluters in the state, but NC DAQ’s failure to analyze these facilities in its haze plan means that four out of the top five biggest haze polluters in North Carolina were wrongly omitted from analysis. We are disappointed that the EPA has proposed to approve this highly flawed and problematic plan that will do nothing to make reasonable progress to continue clearing the air of haze pollution in North Carolina and in communities across the Southeast. The EPA has:

  • Ignored the significant flaws in the VISTAS modeling;
  • Approved of NC DAQ’s unreasonably high source selection thresholds;
  • Incorrectly allowed for the exclusion of NOx controls in the state’s four factor analyses of sources;
  • Wrongfully supported NC DAQ’s exclusion of Duke Energy’s five coal-fired power plants from any control analyses or requirements;
  • Shirked its duty to review NC DAQ’s source-specific four factor analyses;
  • Deferred to a highly deficient environmental justice analysis done by NC DAQ; and
  • Proposed an action that is inconsistent with the agency’s proposals for other state haze plans, such as Arizona, Missouri, North Dakota, Wyoming and Utah, where EPA has proposed to disapprove of weak plans or major sections of the plans.

We strongly urge EPA to reverse its approval and swiftly disapprove of North Carolina’s flawed plan. Then, we urge EPA to promptly issue either a Federal Implementation Plan (FIP) for North Carolina or a FIP for all states in Region 4 given that all Region 4 states relied on invalid VISTAS modeling and source selection processes and therefore all states unreasonably screened out significant sources of haze pollution that contribute to impairment at Class I areas throughout the southeast region. A regional FIP would correct these deficiencies and ensure all Region 4 states are abiding by the requirements of the Clean Air Act and the Regional Haze Rule. Issuing a North Carolina FIP or regional FIP will avoid the cycle of repeated state plan submissions that frustrates the Clean Air Act goal of expeditiously improving visibility and air quality in parks.

Right now, we have a once-in-a-decade opportunity to preserve scenic vistas for future generations, clean the air in our unique Southeast natural areas, keep North Carolina’s tourism thriving and protect the health of all who live here and enjoy North Carolina’s treasured public lands.

We look forward to seeing a strong final action from EPA that will improve visibility and deliver clean air for our national parks, wilderness areas and our communities.

Sincerely,

Dr. Crystal Cavalier
7 Directions of Service
Mebane, North Carolina

Will Harlan
Senior Editor
Blue Ridge Outdoors Magazine
Asheville, North Carolina

Will Harlan
Southeast Director and Senior Scientist
Center for Biological Diversity
Asheville, North Carolina

Brittany Griffin
Advocacy Manager
CleanAIRE NC
Charlotte, North Carolina

Phil Francis
Chair
Coalition to Protect America’s National Parks
Washington, DC

Adam Colette
Program Director
Dogwood Alliance
Asheville, North Carolina

Emily Diznoff
Program Manager
Forest Keeper
Asheville, North Carolina

Jill Pyrz
Program Manager
Friends of Big Ivy
Barnardsville, North Carolina

River Harlan
Program Director
I Heart Pisgah
Asheville, North Carolina

Gray Jernigan
Deputy Director & General Counsel
MountainTrue
Asheville, North Carolina

Eboni Preston Goddard, Ph.D
Southeast Regional Director
National Parks Conservation Association
Asheville, North Carolina

Dr. Jovita Lee
Program Director
North Carolina Black Alliance
Raleigh, North Carolina

Alexis Luckey
Executive Director
Toxic Free North Carolina
Durham, North Carolina

  • 1
    Bureau of Economic Analysis, North Carolina, 2022: https://apps.bea.gov/data/special-topics/orsa/summary- sheets/ORSA%20-%20North%20Carolina.pdf