January 27, 2025
Pearlene Williams-Miles
Multi-Air Pollutant Coordination Section
Air Planning and Implementation Branch
Air and Radiation Division
U.S. Environmental Protection Agency
Region 4
61 Forsyth Street SW
Atlanta, Georgia 30303–8960
Electronic Filing via Regulations.gov
Re: Comments on Proposed Air Plan Approval; Florida; Second Period Regional Haze Plan [EPA Docket No. EPA–R04–OAR–2021–0930]
Dear Ms. Williams-Miles,
The National Parks Conservation Association (NPCA), Sierra Club, the Coalition to Protect America’s National Parks, and Friends of the Everglades (collectively, the Conservation Groups) submit the following comments and four expert reports (i.e., Kordzi 2021 Report, Kordzi 2024 Report, Kordzi 2025 Report, and Gebhart VISTA Report)1Joe Kordzi, “A Review of EPA’s Proposed Approval of the Florida Regional Haze State Implementation Plan” (attached as Ex. 1) [hereinafter “Kordzi 2025 Report”]; Joe Kordzi, “A Review of the Florida Regional Haze State Implementation Plan” (July 2021) (attached as Ex. 2) [hereinafter “Kordzi 2021 Report”]; Joe Kordzi, “A Review of the Florida Regional Haze State Implementation Plan Supplement of January 2024” (Feb. 2024) (attached as Ex. 3) [hereinafter “Kordzi 2024 Report”]; D. Howard Gebhart, “Technical Review of VISTAS Visibility Modeling for the Second Round of Regional Haze State Implementation Plans” (May 2021) (attached as Ex. 4) [hereinafter “Gebhart VISTAS Report”]. Mr. Kordzi is an independent air quality consultant and engineer with extensive experience in the regional haze program. Mr. Gebhart is a recognized expert in air quality modeling. All exhibits to these reports are attached as exhibits to these comments and included in the index of exhibits. on the Environmental Protection Agency’s (EPA) proposal to approve Florida’s Regional Haze State Implementation Plan (SIP) for the Second Planning Period (SIP 2021 Revision, SIP 2024 Revision Supplement), 89 Fed. Reg. 105,506 (Dec. 27, 2024).2Air Plan Approval; Florida; Second Period Regional Haze Plan, 89 Fed. Reg. 105,506 (proposed Dec. 27, 2024) [hereinafter “EPA FL Proposal”]; State Of Florida Department Of Environmental Protection, “Final Submittal, Florida Regional Haze Plan For Second Implementation Period For Florida Class I Areas” (Oct. 8, 2021) (338 pages), https://www.regulations.gov/document/EPA-R04-OAR-2021-0930-0003 [hereinafter “FL SIP Submittal Oct. 2021”]; State Of Florida Department Of Environmental Protection, “Final SIP Submittal, Submittal Number 2021-01 Regional Haze Plan” (Oct. 8, 2021) (34 pages) https://www.regulations.gov/document/EPA-R04-OAR-2021-0930-0002; [hereinafter “FL SIP Submittal Oct. 2021-Part 2”]; State of Florida Department of Environmental Protection, “Supplement to the Florida Regional Haze Plan for the Second Planning Period for Florida Class I Areas, Final Submittal” (June 14, 2024), https://www.regulations.gov/document/EPA-R04-OAR-2021-0930-0046 (17 pages) [hereinafter “FL SIP Submittal June 2024”]; State Of Florida Department Of Environmental Protection, “Proposed Revision to State Implementation Plan, Submittal Number 2024-01, Part II Supplement to the Florida Regional Haze Implementation Plan, Final Submittal” (Oct. 28, 2024) (53 pages), https://www.regulations.gov/document/EPA-R04-OAR-2021-0930-0058 [hereinafter “FL SIP Submittal Oct. 2024”]; State Of Florida Department Of Environmental Protection, “Proposed Revision to State Implementation Plan, Submittal Number 2024-01, Supplement to the Florida Regional Haze Implementation Plan, Submittal Number 2024-01, Supplement to the Florida Regional Haze Plan, Final Submittal” (June 14, 2024) (59 pages), https://www.regulations.gov/document/EPA-R04-OAR-2021-0930-0050 [hereinafter “FL SIP Submittal No. 2024- 01”]. The Conservation Groups submitted public comments to Florida on the State’s draft SIP Revision on July 9, 2021, as well as on the State’s Supplemental Amendment on March 8, 2024. The Conservation Groups’ prior comments and expert reports submitted by the Conservation Groups regarding the Florida draft SIP Revisions, along with relevant exhibits, are incorporated into these comments.3Nat’l Parks Conservation Ass’n, et al., Conservation Groups Comments on Florida’s Proposed Revisions Regional Haze Plan for the Second Implementation Period (July 9, 2021) (attached as Ex. 5) [hereinafter “Conservation Groups 2021 State Comments”]. The comments included the Kordzi 2021 Report; Nat’l Parks Conservation Ass’n, et al., Conservation Groups Comments on Florida’s Supplemental Amendment to Previously Proposed Regional Haze Plan for the Second Implementation Period (March 8, 2024) (attached as Ex. 6) [hereinafter “Conservation Groups 2024 State Comments”], which included the Kordzi 2024 Report. Despite the fact that the Conservation Groups raised numerous errors with Florida’s SIP Revision and Supplemental Amendment in our prior comments, EPA largely fails to acknowledge or address any of the significant errors raised in those comments.
Florida failed to satisfy the requirements of the Clean Air Act and RHR by ignoring its obligations to properly select, analyze, and propose controls for haze polluting sources in the State. Yet, in its proposal, EPA largely fails to acknowledge or address any of the significant errors the Conservation Groups raise in these comments or their comments to the State on its draft SIP Revision. Thus, for the reasons discussed above, EPA must revise its proposal and disapprove of Florida’s SIP Revision. We look forward to further action from EPA to gain needed emission reductions to benefit our treasured national parks and wilderness areas during the second planning period.
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