36 Community Groups to EPA: Don’t Weaken Regional Haze Protections for Parks and Communities

350 Colorado * Access Fund * AFGE Local 704 * Alpine Lakes Protection Society Archaeology Southwest * Breathe Project * Central California Asthma Collaborative Central Valley Air Quality Coalition * Coalition to Protect America’s National Parks Environmental Law & Policy Center * Families for a Livable Climate * Friends of Acadia Goldman School of Public Policy, University of California, Berkeley Healthy Environment Alliance of Utah (HEAL Utah) * Iowa Environmental Council Labadie Environmental Organization (LEO) * League of Conservation Voters
Mi Familia en Acción * Mid-Ohio Valley Climate Action Montana Environmental Information Center * MountainTrue National Parks Conservation Association * New Mexico Wild Northeast Community Resilience Centre * Outdoor Alliance Park County Environmental Council * Public Land Solutions Respiratory Health Association * San Juan Citizens Alliance * Sierra Club Swan View Coalition * Tennessee Citizens for Wilderness Planning
Toxic Free North Carolina * Utah Physicians for a Healthy Environment Virginia Conservation Network * Western Slope Conservation Center

December 1, 2025

Paige Wantlin
Air Quality Policy Division
Office of Air Quality Planning and Standards
Environmental Protection Agency
109 TW Alexander Drive
Research Triangle Park, NC 27711
Wa***********@*pa.gov

 Submitted via: https://www.regulations.gov/commenton/EPA-HQ-OAR-2025-1477-0001 

Dear Ms. Wantlin: 

On behalf of our millions of members and supporters nationwide, we write to share comments on the open regulatory docket EPA-HQ-OAR-2025-1477, Visibility Protection: Regional Haze State Plan Requirements Rule Revision.¹90 FR 47677 (October 2, 2025). We strongly urge the Environmental Protection Agency to ensure that any revisions or changes to the Regional Haze Rule safeguard: 1) the Rule’s primary goal to reduce visibility impairing pollution in Class I areas and 2) the requirement for states to make continued, reasonable progress toward natural visibility in Class I areas. We are concerned the EPA is headed in a direction that will run contrary to the visibility goals of the Clean Air Act, weaken the Regional Haze Rule and undermine years of consistent agency interpretation and progress toward cleaner air in parks and wilderness areas. 

 From coast to coast, national parks and wilderness areas protect and conserve the country’s most unique and diverse landscapes, wildlife habitats, cultural resources and ecosystems. From the  soaring peaks in Rocky Mountain National Park to the swamp of Okefenokee National Wildlife Refuge, to the high desert of Joshua Tree National Park to the stunning vistas at Dolly Sods Wilderness Area, Class I areas around the country attract visitors from all over the world to enjoy their splendor. These areas also safeguard our country’s stories and cultural resources, educating visitors on our shared history. But apart from their value to our national story, these landscapes preserve an invaluable asset to the thriving tourism and outdoor recreation public lands economy. The future of these places depends on healthy ecosystems and positive visitor experiences. In 2023 alone, outdoor recreation added over $639 billion to the national economy and supported nearly 5 million jobs.²Bureau of Economic Analysis, Outdoor Recreation Satellite Account, 2023. https://apps.bea.gov/regional/orsa/

While most air pollution doesn’t originate in our beloved national parks or wilderness areas, it can travel hundreds of miles from its original source, affecting parks and communities near and far. Air pollution from coal plants, oil and gas development, chemical and plastics manufacturers, pulp and paper mills, vehicles, and other industrial facilities, is one of the most serious threats facing national parks, threatening the health of park visitors, wildlife, and neighboring communities, compromising our views with hazy skies and driving the climate crisis. 

The Regional Haze Rule is a time-tested, effective program that requires federal and state agencies, federal land managers and stakeholders to work together to restore clear skies in 156 national parks and wilderness areas (Class I areas). The Haze Rule has delivered significant cost-effective clean air benefits to national parks, wilderness areas and communities across the nation in the past 15 years—over 1.4 million tons of visibility impairing pollution has been reduced, improving scenic views and making air healthier to breathe across the nation. In places like Great Smoky Mountains National Park, visibility has increased by nearly 40 miles from haze pollution reductions. But there is still a lot of work to do as visitors regularly miss out on over 50 miles of scenic views and experience unhealthy air when visiting these treasured places.

According to National Parks Conservation Association’s Polluted Parks 2024 analysis, 97% of national parks continue to suffer from unsatisfactory levels of hazy skies, indicating they are far from achieving naturally clean air. And since air pollution knows no boundaries, communities across the country are negatively affected by the same air pollution that harms Class I areas. Air pollution causes illnesses, drives up healthcare costs, and has harmful and disproportionate consequences on communities of color and low-income communities that often live closest to the polluting sources and already face chronic environmental injustices.

While EPA’s Advanced Notice of Proposed Rulemaking (ANPRM) outlines three broad topic areas, our comments are overarching in nature. Overall, we urge EPA to abandon many of the noted “alternative approaches” as they run contrary to the text and purpose of the Clean Air Act and EPA’s prior interpretations of the Act’s regional haze requirements. Additionally, the “alternative approaches” could drastically modify the essential elements of the Regional Haze Rule. We reject any efforts by EPA that would weaken the effectiveness of the program by:

• Allowing states to evade installing cost effective controls to clean up controllable park-harming pollution and to claim that no pollution reductions are necessary.
• Eliminating requirements for states to develop regular and much-needed regional haze plans to identify how they will advance their state toward air quality improvements to benefit parks and wilderness areas with the goal of restoring natural visibility.
• Allowing states to avoid identifying necessary emission reduction measures based on the four reasonable progress factors set forth by Congress.
• Allowing states to claim that past achievements in visibility impairment or emissions reductions are sufficient for satisfying current obligations.

If EPA pursues revisions to the Regional Haze Rule, we offer the following recommendations to ensure that states, decisionmakers and industrial facilities that emit haze pollutants are held accountable to the national, bipartisan goal of achieving natural visibility in Class I areas:

• Requiring all dominant pollutants (NOx, SO2 and PM) that contribute to haze and visibility impairment are assessed in haze plans. Previously, states have been allowed to focus only on one dominant pollutant and have skipped analysis of others, even when controlling other pollutants could be cost effective and demonstrably improve visibility in parks and wilderness areas.
• Clarifying that a Class I area’s Uniform Rate of Progress (URP) glidepath is not a safe harbor against further reasonable progress, meaning that states cannot declare victory before the end goal of natural visibility is achieved. Amidst additional easing of other air pollution regulations by this administration, we believe states must still analyze available control measures to reduce emissions from in-state facilities; they cannot reject controls that are reasonable just because Class I areas impacted by that state’s pollution were previously projected to be at or below their URP glidepaths.
• Clarifying and providing clear direction on source selection and evaluation by states. In previous planning periods, states have failed to evaluate all haze pollution sources, including mobile and area sources, which allows for some sectors and facilities to be left off the hook for cleaning up their emissions.
• Improve and strengthen state-to-state consultation requirements and Federal Land Manager consultation requirements to ensure feedback is meaningfully addressed.
• Protect and maintain comprehensive air monitoring and scientifically sound, best practices for measuring haze impairment that are the essential foundations for tracking visibility improvement. Ensure that consistent, short- and long-term air pollution data gathering is maintained to safeguard park visitors and staff.

Although progress has been made in many Class I areas around the country, no Class I area has achieved the goal of natural visibility and we cannot allow good momentum to be halted. Furthermore, many sources of air pollution that were expected to retire, clean up or otherwise reduce emissions can no longer be assumed to be on that same course given dramatic changes in the last year to clean air policies, facility or pollution control operations and pollution exemptions granted by presidential decree.

Americans and people from around the world love and cherish our national parks and wilderness areas. We must ensure continued reductions in haze pollution in the years and decades to come to benefit these treasured places and our communities.

Thank you for considering our comments. 

Sincerely,

• 1
  90 FR 47677 (October 2, 2025).
• 2
  Bureau of Economic Analysis, Outdoor Recreation Satellite Account, 2023. https://apps.bea.gov/regional/orsa/