Allegheny County Clean Air Now (ACCAN) * Allegheny-Blue Ridge Alliance Appalachian Mountain Advocates * Appalachian Voices * Breathe Project Carnegie Mellon University, CREATE Lab * Center for Coalfield Justice Christians For The Mountains * Coalition to Protect America’s National Parks Eight Rivers Council * Elks Run Watershed Group Greenbrier River Watershed Association, Inc. * National Parks Conservation Association Ohio Valley Environmental Advocates, Inc. Pittsburghers Against Single-Use Plastic (PASUP) Physicians for Social Responsibility Pennsylvania * Protect PT Rail Pollution Protection Pittsburgh (RP3) * Speak For The Trees Too West Virginia Citizen Action * West Virginia Highlands Conservancy West Virginia Rivers Coalition * West Virginians for Energy Freedom

February 20, 2025

Dear Mr. Yarina,

On behalf of the undersigned organizations across West Virginia and the Mid-Atlantic, we write to support EPA’s proposed disapproval of West Virginia’s Regional Haze plan for the second planning period. The organizations represented on this letter are concerned with the pollution from coal plants and other industrial facilities operating in West Virginia that emit haze-causing pollution that mars scenic vistas in our parks and wilderness areas and also harms the health of our communities. We applaud the EPA for proposing a disapproval of West Virginia’s flawed regional haze plan.

The only state completely in the Appalachian Mountain range, West Virginia is home to rugged and hilly landscapes, wild and winding rivers, and some of the darkest starry skies. Protecting our air in the Mountain State means helping to preserve an invaluable asset to the thriving tourism and outdoor recreation economy, including West Virginia’s national parks and public lands. In 2023, tourism at New River Gorge National Park and Preserve, Gauley River National Recreation Area, and Bluestone National Scenic River contributed $96.5 million to the local economy.1National Park Service, National Park Visitor Spending Effects, 2023: https://www.nps.gov/neri/learn/news/tourism-at-the-three-national-parks-in-southern-west-virginia-contributed-96- 5-million-to-local-economy.htm These parks in southern West Virginia are popular destinations for a bustling outdoor recreation industry including whitewater rafting, fishing, hiking, climbing, and even B.A.S.E. jumping once a year on Bridge Day. Cutting pollution that dirties the air from our state is important for West Virginians, our mountain scenic landscapes and our families now and for generations to come.

The West Virginia Department of Environmental Protection (WVDEP) produced a plan that will do nothing to clear the air of haze pollution in West Virginia, communities and Class I areas across the Mid-Atlantic. In developing its haze plan, WVDEP relied on a shared, flawed modeling system, created by the regional planning organization called VISTAS. In relying on the VISTAS approach, WVDEP ignored nitrogen oxide (NOx) emissions and huge polluters across the state that emit harmful pollution that degrades the air quality in our parks and wilderness areas. WVDEP improperly concluded that no new reductions in pollution were warranted even though many polluting facilities were not even analyzed.

EPA’s strong proposed disapproval of WVDEP’s weak and deficient plan will help ensure West Virginia’s polluters are held accountable for the pollution they emit that mars scenic views and dirties our air. EPA correctly identifies how WVDEP’s Regional Haze plan fails to meet the requirements of the Clean Air Act and Regional Haze Rule and how it is ineffective at achieving reasonable progress. We urge you to promptly finalize the disapproval to ensure improved visibility and air quality in parks and our communities.

This is a once-in-a-decade opportunity to preserve scenic vistas for future generations, keep West Virginia’s tourism thriving, and protect the health of all who live here and enjoy West Virginia’s treasured public lands.

Sincerely,

Barbara Lee Pace, Board Member
Angelo Taranto, Secretary/Treasurer
Allegheny County Clean Air Now (ACCAN)
Pittsburgh, Pennsylvania

Derek Teaney
Deputy Director
Appalachian Mountain Advocates
Lewisburg, West Virginia

Matthew Mehalik, Ph.D.
Executive Director
Breathe Project
Pittsburgh, Pennsylvania

Sarah Martik
Executive Director
Center for Coalfield Justice
Washington, Pennsylvania

Philip A. Francis, Jr.
Chair
Coalition to Protect America’s National Parks
Washington, DC

David Lillard
Steering Committee Member
Elks Run Watershed Group
Shepherdstown, West Virginia

Samantha Nygaard
West Virginia Program Manager
National Parks Conservation Association
Charleston, West Virginia

Dianne Peterson
Steering Committee Member
Pittsburghers Against Single-Use Plastic (PASUP)
Pittsburgh, Pennsylvania

Tom Pike
Environmental Policy Advocate
Protect PT
Penn Township, Pennsylvania

John Coleman
Director
Speak For The Trees Too
Parsons, West Virginia

Marilyn Shoenfeld
President
West Virginia Highlands Conservancy
Charleston, West Virginia

Shawna Phillips
Community Coordinator
West Virginians for Energy Freedom
Charleston, West Virginia

 

Andrew Young
Staff Attorney
Allegheny-Blue Ridge Alliance
Monterey, Virginia

Quenton King
Federal Resource Outreach Manager
Appalachian Voices
Charleston, West Virginia

Ana Hoffman
Air Quality Program Director
Carnegie Mellon University, CREATE Lab
Pittsburgh, Pennsylvania

Allen Johnson
Coordinator
Christians For The Mountains
Dunmore, West Virginia

Allen Johnson
President
Eight Rivers Council
Hillsboro, West Virginia

Louanne Fatora
Coordinator
Greenbrier River Watershed Association, Inc.
Lewisburg, West Virginia

Frank Rocchio
President
Ohio Valley Environmental Advocates, Inc.
Follansbee, West Virginia

Tonyehn Verkitus
Executive Director
Physicians for Social Responsibility Pennsylvania
Philadelphia, Pennsylvania

Glenn Olcerst
General Counsel
Rail Pollution Protection Pittsburgh (RP3)
Pittsburgh, Pennsylvania

Morgan King
Climate and Energy Program Manager
West Virginia Citizen Action
Charleston, West Virginia

Jennie Smith
Executive Director
West Virginia Rivers Coalition
Charleston, West Virginia

Click here to read submitted Techincal Comments.

  • 1
    National Park Service, National Park Visitor Spending Effects, 2023: https://www.nps.gov/neri/learn/news/tourism-at-the-three-national-parks-in-southern-west-virginia-contributed-96- 5-million-to-local-economy.htm