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Comments Submitted via regulations.gov: https://www.regulations.gov/commenton/EPA-R06-OAR-2025-0197-0041

July 23, 2025

Michael Feldman
U.S. Environmental Protection Agency
Region 6, Air and Radiation Division
SO2 and Regional Haze Section
1201 Elm Street
Suite 500
Dallas, TX  75270
Fe*************@*pa.gov

Subject: Comments on EPA’s Proposal on Regional Haze actions for Texas and Oklahoma

Dear Mr. Feldman:

We are writing on behalf of more than 4,500 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 115 members who currently live in Texas, Oklahoma and throughout Region 6, as well as hundreds of others who have worked in Texas or Oklahoma 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 approve numerous regional haze actions for Texas and Oklahoma.1EPA-R06-OAR-2025-0197; FRL-12217-01-R6; Air Plan Approval; Texas and Oklahoma; Texas Regional Haze Plans for the First and Second Implementation Periods and Five-Year Progress Report; Oklahoma Regional Haze Plan for the First Implementation Period; https://www.federalregister.gov/documents/2025/05/23/2025-09293/air-plan-approval-texas-and-oklahoma-texas-regional-haze-plans-for-the-first-and-second Together, these actions would allow for over 250,000 tons of sulfur dioxide (SO₂) and nitrogen oxides (NOₓ) to be emitted annually from facilities in both states. This level of pollution will not only impair scenic views in national parks and wilderness areas across the region but will also negatively affect the health of nearby communities.

Moreover, the regional haze actions identified in EPA’s proposed approval fail to make reasonable progress toward clearer skies in Class I areas in and around Texas and Oklahoma, including, but not limited to: Big Bend and Guadalupe Mountains National Parks in Texas, Wichita Mountains in Oklahoma, Breton Island in Arkansas, Caney Creek and Upper Buffalo Wilderness in Arkansas, Great Sand Dunes National Park and Preserve and Rocky Mountain National Park in Colorado, Hercules-Glades and Mingo in Missouri, and Salt Creek, Wheeler Peak, and White Mountain in New Mexico.

For these reasons, we urge EPA to require Texas and Oklahoma to take stronger action to improve air quality and visibility in national parks and other Class I airsheds, both within and beyond their borders.

Many of our members have dedicated decades of service to protecting national park sites and public lands throughout Texas, Oklahoma, and Region 6. 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,

Philip A. Francis Jr., Chair
Washington, DC

Jerry Rogers
Santa Fe, New Mexico

Al Webster
Lamy, New Mexico

Phillip A Young
New Mexico

Lisa Collins
Grants, New Mexico

Anthony Bonanno
Santa Fe, New Mexico

Bob Krumenaker
Carlsbad, New Mexico

Cherry Payne
Santa Fe, New Mexico

Bill Wade
Marana, Arizona

Elizabeth Hastings
Harper’s Ferry, West Virginia

Bruce Dombrowski
Pine Grove, California

Sharon Miles
Denver, Colorado

David Takemoto-Weerts
Davis, California

Janice D’Urso
Lakeside, Arizona

Jacqueline Steuer
Sonoma, California

Judith Hart
Eagle, Idaho

Aviva Oneil
Durango, Colorado

Mary Riddle Cornell
Kalispell, Montana

Katherine Ziegenfus
Lakewood, Colorado

Daphne Hatch
Novato, California

Derek Wallentinsen
Albuquerque, New Mexico

Sam Weddle
Ringgold, Georgia

Patricia Ashley
Dickinson, North Dakota

Clyde Stonaker
Fort Collins, Colorado

John Reynolds
Crozet, Virginia

Jim Brandi
Salt Lake City, Utah

Tony Sisto
Eagle River, Alaska

Edward Walzer
Hesperia, Michigan

Tonnie Cummings
Vancouver, Washington

David Shaver
Morrison, Colorado

William Rice
Eagle River, Alaska

  • 1
    EPA-R06-OAR-2025-0197; FRL-12217-01-R6; Air Plan Approval; Texas and Oklahoma; Texas Regional Haze Plans for the First and Second Implementation Periods and Five-Year Progress Report; Oklahoma Regional Haze Plan for the First Implementation Period; https://www.federalregister.gov/documents/2025/05/23/2025-09293/air-plan-approval-texas-and-oklahoma-texas-regional-haze-plans-for-the-first-and-second