Coalition Urges EPA to Fully Approve Hawaiʻi’s Regional Haze Plan to Protect National Park Air and Views

Comments Submitted via regulations.gov: https://www.regulations.gov/commenton/EPA-R09-OAR-2025-0152-0001

April 20, 2026
Michael Dorantes
Geographic Strategies and Modeling Section
EPA Region IX
75 Hawthorne Street
San Francisco, CA 94105
do**************@*pa.gov

Subject: Comments on EPA’s Proposal to Partially Disapprove and Partially Approve Hawaiʻi’s Regional Haze State Implementation Plan Revision for the Second Implementation Period

Dear Mr. Dorantes:

We are writing on behalf of more than 5,000 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 25 members who currently live in Hawaiʻi, as well as hundreds of others who have worked in the state 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 other industrial facilities on Class I airsheds both within and beyond their borders.

We appreciate the opportunity to comment on the EPA’s proposal to partially disapprove and partially approve Hawaiʻi’s Regional Haze State Implementation Plan (SIP) for the Second Implementation Period.¹EPA-R09-OAR-2025-0152; FRL-12584-01-R9; Partial Approval and Partial Disapproval of Air Quality Implementation Plans; Hawaii; Regional Haze State Implementation Plan for the Second Implementation Period; https://www.federalregister.gov/documents/2026/02/17/2026-03072/partial-approval-and-partial-disapproval-of-air-quality-implementation-plans-hawaii-regional-haze# The state of Hawaiʻi submitted a robust regional haze plan revision to the EPA in August 2024, inclusive of strong recommendations made by the National Park Service during multiple required consultation communications.²Hawaii State Dep’t of Health, Regional Haze State Implementation Plan, Revision 1: Second Planning Period (Aug. 2, 2024), Docket No. EPA-R09-OAR-2025-0152-0003_attachment_3, https://www.regulations.gov/document/EPA-R09-OAR-2025-0152-0003. At 16-17 and App. X at 15-17.

The plan included the voluntary retirement of six boiler units at the Kanoelehua-Hill and Kahului Generating Stations, an option to either shutdown or install controls at several diesel engine generators at the Maalaea Generating Station, and a fuel switch at the Puna Power Plant. Hawaiian Electric Company (Hawaiian Electric) agreed to these requirements, so the state included them as federally enforceable in the SIP, in accordance with EPA’s own guidance issued on multiple occasions.

But EPA now claims the retirement deadlines for the Kanoelehua-Hill, Kahului and Maalaea plants in the SIP are “forced” and “unconsented” based on a letter sent to EPA from Hawaiian Electric after Hawaiʻi submitted its SIP to EPA. Nothing in the record before EPA, including Hawaiian Electric’s letter, supports the agency’s claim that the SIP retirement deadlines are “forced.” By relying on Hawaiian Electric’s unsupported claims in the late-submitted letter to partially disapprove Hawaiʻi’s SIP, EPA is opening a loophole for facilities to entirely evade compliance with the Regional Haze Program.

By rejecting Hawaiʻi’s long-term strategy and reasonable progress goals, EPA is allowing for over 8,512 tons of sulfur dioxide (SO₂) and nitrogen oxides (NOₓ) to continue being emitted annually from facilities across Hawaiʻi. This level of pollution already impairs scenic park views and will continue to harm unique national parks like Hawaiʻi Volcanoes and Haleakalā while also negatively affecting the health of nearby communities.

For these reasons, we oppose EPA’s action on Hawaiʻi’s haze plan and urge the agency to reverse course and approve Hawai’i’s strong 2024 plan revision to ensure the state can move forward with air quality and visibility improvements to benefit national parks in Hawaiʻi. Many of our members have dedicated decades of service to protecting national park sites and public lands throughout Hawaiʻi and Region 9. 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 joined in comments on urging the EPA to approve Hawaiʻi’s Regional Haze Plan and Protect Clean Air in National Parks.

• 1
  EPA-R09-OAR-2025-0152; FRL-12584-01-R9; Partial Approval and Partial Disapproval of Air Quality Implementation Plans; Hawaii; Regional Haze State Implementation Plan for the Second Implementation Period; https://www.federalregister.gov/documents/2026/02/17/2026-03072/partial-approval-and-partial-disapproval-of-air-quality-implementation-plans-hawaii-regional-haze#
• 2
  Hawaii State Dep’t of Health, Regional Haze State Implementation Plan, Revision 1: Second Planning Period (Aug. 2, 2024), Docket No. EPA-R09-OAR-2025-0152-0003_attachment_3, https://www.regulations.gov/document/EPA-R09-OAR-2025-0152-0003. At 16-17 and App. X at 15-17.