Comments on EPA’s Proposed Partial Disapproval of Colorado’s Regional Haze Plan

Comments Submitted via regulations.gov: https://www.regulations.gov/commenton/EPA-R08-OAR-2024-0607-0001

September 15, 2025

Jaslyn Dobrahner
Air and Radiation Division
EPA Region 8
1595 Wynkoop Street
Denver, CO 80202
do**************@*pa.gov

Subject: Comments on EPA’s Proposed Partial Disapproval of Colorado’s Regional Haze Plan

Dear Ms. Dobrahner:

We are writing on behalf of more than 4,600 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 250 members who currently live in Colorado, as well as hundreds of others who have worked in Colorado during 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, volunteers and other supporters. We strongly support efforts to ensure that clean air and clear views are protected in our national parks across the country.

The Clean Air Act requires states to improve visibility in protected areas visited by millions of people each year to enjoy spectacular scenery, vital natural habitats, and exceptional night skies. It also requires each state to identify and evaluate the effects of industrial emissions from sources such as motor vehicles, power plants, and oil and gas operations on Class I airsheds both within and beyond their borders.

We appreciate the opportunity to comment on the EPA’s proposal to partially disapprove of Colorado’s haze plan.¹EPA-R08-OAR-2024-0607; FRL-12598-01-R8; Air Plan Partial Approval and Partial Disapproval; Colorado; Regional Haze Plan for the Second Implementation Period; https://www.federalregister.gov/documents/2025/07/16/2025-13342/air-plan-partial-approval-and-partial- disapproval-colorado-regional-haze-plan-for-the-second The state of Colorado submitted a strong regional haze plan to the EPA that included the voluntary retirement of seven coal-fired and gas-fired power plants, retirements put forth by the utilities themselves. The closure of these units would decrease haze pollution by nearly 15,000 tons annually and significantly help Colorado make reasonable progress towards the regional haze goal of restoring natural visibility to Colorado’s 12 stunning Class I areas and numerous regional Class I areas like Badlands National Park in South Dakota and Grand Canyon National Park in Arizona. EPA’s proposal to disapprove of these retirements is unsubstantiated in the proposal’s docket.

Moreover, part of EPA’s justification of its partial disapproval of Colorado’s plan rests on a ‘new EPA policy’ that violates the Clean Air Act’s plain language and procedural requirements. The new policy reverses EPA’s longstanding position that the “uniform rate of progress” (URP) is not a safe harbor and states must make reasonable progress towards the goal of remedying visibility impairment.²82 Fed. Reg. 3,078, 3,091 (Jan. 10, 2017).

For these reasons, we oppose EPA’s action on Colorado’s haze plan and urge the agency to ensure it is improving air quality and visibility in national parks and other Class I airsheds not only in Colorado but across the country.

Many of our members have dedicated decades of service to protecting national park sites and public lands throughout Colorado and Region 8. It is time to take bold, effective action to safeguard these irreplaceable resources for current visitors and future generations.

Thank you for considering our input on this important issue.

Sincerely,

The Coalition also signed on to joint comments regarding the EPA’s partial disapproval of CO’s haze plan, which can be found here.

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  EPA-R08-OAR-2024-0607; FRL-12598-01-R8; Air Plan Partial Approval and Partial Disapproval; Colorado; Regional Haze Plan for the Second Implementation Period; https://www.federalregister.gov/documents/2025/07/16/2025-13342/air-plan-partial-approval-and-partial- disapproval-colorado-regional-haze-plan-for-the-second
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  82 Fed. Reg. 3,078, 3,091 (Jan. 10, 2017).