Comments submitted via regulations.gov:
https://www.regulations.gov/commenton/EPA-R09-OAR-2024-0459-0001
February 3, 2025
Subject: Comments on EPA’s Proposed Response to California’s Regional Haze State Implementation Plan
Dear Acting Regional Director Cheree Peterson and Ms. Lawrence:
We are writing on behalf of more than 3,200 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 325 members who currently live in California and all of Region 9, and hundreds of other members who have worked in the state of California throughout their National Park Service (NPS) careers.
The Coalition educates, speaks, and acts for the preservation and protection of the National Park System. We are protection rangers and interpreters, scientists and maintenance workers, managers and administrators, and specialists in the full spectrum of the parks’ resources. Our membership also includes former National Park Service directors, deputy directors, regional directors, and park superintendents. 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 EPA’s proposal to partially disapprove California’s 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 development and operations, and other sources on Class I airsheds within, and even in, neighboring states.
California has 29 Federal Class I areas that must be addressed by the state’s long-term strategy for improving air quality, including some of the Park Service’s most iconic park sites, like: Yosemite, Redwoods, Joshua Tree, Lassen Volcanic, Pinnacles, Sequoia and Kings Canyon National Parks, Point Reyes National Seashore, and Lava Beds National Monument. In addition, California acknowledges that in-state sources of emissions and air pollutants affect visibility of eleven Class I areas outside the State, including other beloved park units such as Grand Canyon, Bryce Canyon and Zion National Parks in Arizona and Utah.
Unfortunately, as proposed, California’s 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 and in previous state comments submitted by the Coalition and allies, California failed to meet the requirements of the Clean Air Act and Regional Haze Rule (RHR) in at least the following ways:
- California failed to analyze all pollutants contributing to regional haze, including sulfur dioxide and particulate matter pollution.
- California unjustly screened out all but one of the stationary sources without providing adequate information on emissions, existing control measures, costs and other reasonable further progress requirements under the regional haze rule.
- California failed to conduct an adequate four-factor analysis for mobile sources, including both on-road and off-road vehicles.
- California failed to fully analyze potential reductions from area sources like oil and gas production, agriculture, and wood burning.
For these reasons, we support EPA’s decision to disapprove in part of California’s plan and ask that you act swiftly to finalize this action. 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 California.
Sincerely,
Philip A. Francis, Jr.
Chair of the Executive Council
Coalition to Protect America’s National Parks