October 10, 2024
Submitted to EPA Docket No. EPA-R04-OAR-2023-0220-0001 via regulations.gov: https://www.regulations.gov/commenton/EPA-R05-OAR-2021-0544-0141
Subject: Environmental Protection Agency’s (EPA) proposed approval of Ohio’s Regional Haze State Implementation Plan
Dear Regional Administrator Shore and Ms. Liu,
I am 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 20 members who currently live in Ohio, and hundreds of other members who have worked in the state of Ohio 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 and communities throughout the country.
I am a former NPS employee and had the privilege of working in national parks across the country. I have seen firsthand how pollution and regional haze can impact visibility and public health. Now, I am a resident of Ohio. Not only am I the Deputy Director of the Coalition, but I’m also the mother of two young children who spend much of their time exploring and playing outside. I’m incredibly concerned about the proposed approval of Ohio’s regional haze plan not just because of my professional background and commitment to protecting our parks and public lands – but because my family, friends, and hundreds of thousands of Ohio residents could be impacted by Ohio’s flawed plan.
Ohio has 18 industrial facilities that potentially affect not only our communities throughout Ohio, but also at least 29 regional Class I areas like Great Smoky Mountains and Shenandoah National Parks. Ohio’s facilities emit more than 71,000 tons of sulfur dioxide (SO2) and nitrogen oxides (NOx) pollution per year—ranking Ohio as the 3rd worst SO2 and NOx polluter in the country behind Texas and Missouri. While these emissions may impact my family, they disproportionally impact communities of color and low-income communities that more often live near the polluting sources. It is past time for these facilities to be cleaned up.
This past summer, Ohio’s Environmental Protection Agency (OH EPA) submitted a regional haze plan and supplemental information to the federal EPA that fails to reduce haze pollution, falling short on the state’s obligation to improve air quality for our parks and communities. OH EPA made no meaningful efforts to reduce the huge amount of haze-causing pollution emitted from our state’s facilities. It is disappointing that OH EPA missed this once-a-decade opportunity to clear the air for its residents and communities across the Midwest.
Now, it is even more egregious that EPA Region 5 has proposed to approve in full this highly flawed and problematic plan. I strongly urge you to reverse the proposed approval of Ohio’s regional haze plan and instead, disapprove of the inadequate plan and complete a Federal Implementation Plan (FIP) that will result in real reductions in haze-causing pollution that impacts Ohioans and states across the region.
It’s important that EPA Region 5 finalize a strong action that will actually improve visibility and air quality in parks and our communities.
Sincerely,
Emily Thompson
Deputy Director, Coalition to Protect America’s National Parks
Ohio Resident
The Coalition also signed on to a community letter, linked here.