Michael Gordon
U.S. Environmental Protection Agency
Region 3
1600 John F. Kennedy Boulevard
Philadelphia, Pennsylvania 19103–2852
Electronic Filing via Regulations.gov
Re: Comments on Proposed Air Plan Approval; West Virginia; Regional Haze State Implementation Plan for the Second Implementation Period, 90 Fed. Reg. 16,478 (Apr. 18, 2025) [Docket ID No. EPA–R03–OAR 2025–0174]
The National Parks Conservation Association (NPCA), Sierra Club, the Coalition to Protect America’s National Parks, Appalachian Mountain Advocates, Appalachian Mountain Club, and Earthjustice (collectively, the Conservation Groups) submit the following comments in opposition to the Environmental Protection Agency’s (EPA) proposal to approve190 Fed. Reg. 16,478 (Apr. 18, 2025). West Virginia’s Regional Haze State Implementation Plan (SIP) for the Second Planning Period (SIP Revision).2WV Dep’t Env’t Prot., West Virginia Regional Haze Second Period (2028) State Implement Plan to Preserve, Protect, and Improve Visibility in Class I Federal Areas (Aug. 2021) [hereinafter “SIP Revision”]. The Conservation Groups also resubmit and attach (1) our prior comments, and attachments thereto,3Nat’l Parks Conservation Ass’n, et al., Comments on Proposed Air Plan Disapproval; West Virginia; Regional Haze State Implementation Plan for the Second Implementation Period, 90 Fed. Reg. 6932 (Jan. 21, 2025) [Docket ID No. EPA-R03-OAR-2024-0625] (Feb. 20, 2025) [hereinafter “Conservation Groups’ Feb. 2025 Comments”] (attached as Ex. 1). The accompanying exhibits to Conservation Groups’ Feb 2025 Comments are hereto attached as Exhibits 1a to Exhibit 1ll. Exhibits 1a-iv and 1v are also available at: https://downloads.regulations.gov/EPA-R03- OAR-2024-0625-0057/attachment_3.xlsx and https://downloads.regulations.gov/EPA-R03-OAR-2024-0625- 0057/attachment_4.xlsx, respectively. supporting EPA’s original proposal to disapprove490 Fed. Reg. 6,932 (Jan. 21, 2025). West Virginia’s deficient SIP Revision; and (2) our comments submitted to the State on its draft SIP Revision.5 Nat’l Parks Conservation Ass’n, et al., Conservation Organizations’ Comments on the Proposed Regional Haze State Implementation Plan (Jan. 10, 2022) [hereinafter “Conservation Orgs’ State-Level Comments”] (attached as Ex. 2).
The Conservation Groups are active nationwide in advocating for strong air quality requirements to protect our national parks and wilderness areas. These groups have long participated in Regional Haze SIP comment periods, rulemakings, and litigation across the country to ensure that states and EPA satisfy their obligations under the Clean Air Act and the Regional Haze Rule (RHR). The Conservations Organizations’ members who live in West Virginia—including NPCA’s over 7,800 members and Sierra Club’s 2,011 members, as well as the other Conservation Groups’ members—use and enjoy regional Class I areas that are impacted by West Virginia’s sources of haze-forming pollution.
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