Coalition Members Comment on the EPA’s Proposed Response to Texas’ Regional Haze State Implementation Plan

Comments Submitted via regulations.gov:
https://www.regulations.gov/commenton/EPA-R06-OAR-2021-0539-0048

December 3, 2024

Jennifer Huser
EPA Region 6
1201 Elm St.
Suite 500
Dallas, Texas 75270
Hu************@ep*.gov

Subject: Comments on EPA’s proposed response to Texas’ Regional Haze State Implementation Plan.

Dear Ms. Huser and Dr. Nance:

We are writing on behalf of more than 3,000 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 115 members who currently live in Texas and all of Region 6, and hundreds of other members who have worked in the state of Texas 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 Texas’ Regional Haze State Implementation Plan (SIP) for the second implementation period. The Clean Air Act (CAA) 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.

Texas has identified two mandatory Federal Class I areas that must be addressed by their long-term strategy for improving air quality: Big Bend National Park and Guadalupe Mountains National Park. In addition, Texas acknowledges that in-state sources of emissions and air pollutants affect visibility of eleven Class I areas outside the State, including Federal Wilderness areas: Breton Island in Arkansas, Caney Creek and Upper Buffalo Wilderness in Arkansas, Wichita Mountains in Oklahoma, Hercules-Glades and Mingo in Missouri, and Salt Creek, Wheeler Peak and White Mountain in New Mexico, and other National Park Service-managed areas: Great Sand Dunes National Park and Preserve and Rocky Mountain National Park in Colorado.

Unfortunately, the majority of Texas’ 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-R06-OAR-2021-0539; FRL-12282-01-R6, Air Quality State Implementation Plans; Partial Approval, Partial Disapproval and Promulgation; Texas; Regional Haze; https://www.federalregister.gov/documents/2024/10/15/2024-23341/air-quality-state-implementation-plans-partial-approval-partial-disapproval-and-promulgation-texas  Texas failed to meet the requirements of the Clean Air Act and Regional Haze Rule (RHR) in at least the following ways:

1. Texas did not adequately identify all of the Class I areas that are likely affected by in-state sources. Texas failed to justify or explain why it didn’t identify Bosque del Apache Wilderness Area in New Mexico as a Class I area impacted by in-state sources.
2. Texas unreasonably refused to analyze some of the state’s largest sources of pollution.
3. Texas failed to follow EPA’s method for estimating the cost of controls.
4. Texas did not require any new pollution controls.
5. Texas did not conduct Federal Land Manager and State-to-State consultations to meet the requirements of CAA and RHR.

For these reasons, we support the EPA’s requirement that Texas 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 airsheds within and beyond Texas. 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 Texas.

Many of our Coalition members have worked to protect national park sites and public lands in and around Texas for decades. It is time for 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,

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  EPA-R06-OAR-2021-0539; FRL-12282-01-R6, Air Quality State Implementation Plans; Partial Approval, Partial Disapproval and Promulgation; Texas; Regional Haze; https://www.federalregister.gov/documents/2024/10/15/2024-23341/air-quality-state-implementation-plans-partial-approval-partial-disapproval-and-promulgation-texas