Coalition to Protect America’s National Parks
Epiphany United Church of Christ Franklin County Rural Coalition Labadie Environmental Organization (LEO)
Midwest Building Decarbonization Coalition
Missouri Chapter, Sierra Club
Missouri Coalition for the Environment
National Parks Conservation Association
Sierra Club
September 3, 2026
Missouri Department of Natural Resources
Air Pollution Control Program
ATTN: Air Quality Planning Section Chief
P.O. Box 176
Jefferson City, MO 65102‐0176
ap*****@****mo.gov
Submitted via electronic mail
To Whom it May Concern:
On behalf of the undersigned organizations across Missouri, we write from our deep shared value for clean air in our public lands and communities. We are extremely concerned with the Proposed Update to the Missouri Regional Haze Plan for the Second Planning Period (proposed SIP Update) issued by the Missouri Department of Natural Resources (MoDNR).1Missouri Department of Natural Resources, Proposed Update to Missouri Regional Haze Plan for the Second Planning Period and Notice of Public Hearing: https://dnr.mo.gov/calendar/event/308241, “Proposed Update.” The proposed SIP Update further weakens the already insufficient Missouri 2022 Regional Haze Plan, leaving over 67,000 thousands of tons of haze pollutants uncontrolled. The proposed SIP Update fails to reduce air pollution and improve visibility in beloved places like Hercules-Glade and Mingo Wilderness Areas and our communities across the state, where haze pollution regularly strips up to 70 miles of scenic views from these special places, negatively affecting visitors’ experiences.
The organizations represented in this letter are concerned with Missouri’s coal-fired power plants that are some of the worst haze polluters in the country – MoDNR’s proposed SIP Update removes previous agreements entered into with polluting facilities that would reduce harmful pollution from these sources. According to 2023 emissions data analyzed by National Parks Conservation Association (NPCA), Ameren’s Labadie power plant is the 5th worst haze polluter in the country2National Parks Conservation Association, Top 50 Worst Regional Haze Polluters, January 23, 2025; https://www.npca.org/resources/3351-top-50-worst-regional-haze-polluters. and degrades air quality not only in our communities and local Wilderness Areas but also in places as far away as Great Smoky Mountains National Park in Tennessee and North Carolina. In 2025, the Labadie plant had the highest sulfur dioxide (SO2) emissions of any single facility in the country and AECI’s New Madrid power plant had the highest nitrogen oxide (NOx) emissions of any single facility in the country.3Clean Air Markets Program Data; https://campd.epa.gov/data/custom-data-download; accessed August 11, 2026. See also, Proposed Update, Appendix B-1, page 83.
The rankings above are not just numbers without consequence. Communities near Missouri’s coal-fired power plants, particularly in Labadie, Marston and St. Louis, disproportionately experience negative health impacts from the pollution emitted from these sources. People living in Marston and Labadie are at extremely high risk of cancer from the air toxics emitted from local coal-fired power plants.495th percentile in Missouri and 80-90th percentile nationally per EPA’s EJ Screen, accessed January 23, 2023. Haze pollution dramatically affects St. Louis City as there are three large, polluting Ameren power plants surrounding the city. The American Lung Association’s State of the Air 2026 Report gives St. Louis City a failing grade for annual particle pollution and an F grade for high ozone pollution days, pollution which is particularly dangerous for people to breathe. Of the city’s over 279,000 residents, nearly 25 percent have asthma (adult and pediatric cases), chronic obstructive pulmonary disease (COPD), lung cancer or cardiovascular disease.5State of the Air Report Cards: Missouri: St. Louis City (2026). American Lung Association. Available at: https://www.lung.org/research/sota/city-rankings/states/missouri/st-louis-city. MoDNR’s proposed SIP Update will do nothing to change these health outcomes while allowing controllable pollution to continue dirtying the air and harming Missourians’ health.
MoDNR is proposing an update to the 2022 Regional Haze Plan that removes the limited consent agreements and continues to do nothing about Missouri power plants’ 55,000 tons of controllable sulfur dioxide emissions. In 2022, MoDNR said the consent agreements were necessary to set and maintain the state’s reasonable progress goals towards natural visibility. But now the proposed SIP Update violates the Clean Air Act’s and Regional Haze Rule’s requirements that if an emission reduction measure is necessary to make reasonable progress, it must be included in a SIP; removing the consent agreement violates these requirements.
For MoDNR to fulfill its Regional Haze obligations under the Clean Air Act and make reasonable progress, MoDNR must withdraw the proposed SIP Update and correct the deficiencies in the original 2022 plan that EPA identified in its 2024 partial disapproval. A notable change should be correcting its control cost analyses that artificially inflated the costs of readily available and feasible pollution controls for the state’s largest polluters. This change, among others, would produce a regional haze plan that could reduce upwards of 67,000 tons of haze-causing pollution.
We oppose MoDNR’s proposed SIP Update as it fails to fulfill the state’s regional haze obligations, while ignoring a significant opportunity to improve scenic views for future generations and protect the health of all who live here and enjoy Missouri’s treasured public lands.
Sincerely,
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Cheryl Schreier Kelsie Eversmeyer Marnese Jackson Jared Opsal Jenn DeRose |
Jeanette Mott Oxford Patricia Schuba Gretchen Waddell Barwick Crystal M.C. Davis |