Division of Air Quality
Department of Environmental Quality
195 North 1950 West
Salt Lake City, Utah 84116
Comments Submitted Electronically
Subject: Comments on Utah’s proposed Regional Haze State Implementation Plan (SIP) Revision
Dear Ms. Lopez and Mr. Mulrooney,
We are writing on behalf of nearly 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 49 members who currently live in Utah, and hundreds of other members who have worked in the state of Utah throughout 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, and a full array of other former employees, volunteers, and supporters. We strongly support efforts to ensure clean air and clear views are protected in our national parks throughout the country. We appreciate the opportunity to comment on the Utah Division of Air Quality’s (UDAQ) proposed revision to the Regional Haze Round 2 State Implementation Plan (proposed SIP revision).1
Utah has five mandatory Federal Class I areas that must be addressed by the Regional Haze long-term strategy for improving air quality: Arches National Park, Bryce Canyon National Park, Canyonlands National Park, Capitol Reef National Park, and Zion National Park. While air quality has improved over the decades, no Class I area in the country has achieved the Clean Air Act goal of natural visibility.
The Clean Air Act requires states to improve visibility in these protected areas, where millions of people each year visit to enjoy spectacular scenery, outstanding natural habitats for native plants and animals, and incredible dark skies at night. The Clean Air Act also requires each state to identify and evaluate the effects of industrial emissions from motor vehicles, power plants, oil and gas development and operations, and other sources on Class I airsheds within, and even in, neighboring states.
Unfortunately, the proposed SIP revision will do nothing to reduce haze pollution in Utah’s Class I areas or others in the region. According to data analyzed by National Parks Conservation Association, the Intermountain Power Plant (IPP) is the 12th worst haze polluter of national parks in the country.2 The removal of the shutdown date for the coal-fired units is unnecessary and will allow for the release of over 1,000 tons of nitrogen oxides (NOx) emissions and over 6,000 tons of sulfur dioxide (SO2) emissions, causing hazy skies and unhealthy air. The justification for removing the shutdown date is weak at best; the proposed SIP revision states that nearly 98% of the power generated at IPP was sold to entities out of state which means it is not vital to Utah’s grid reliability nor does it help provide a reliable supply of energy to Utahns.
Additionally, we believe that UDAQ improperly rejected the most effective NOx pollution controls for the coal units, claiming they were not cost-effective. However, the National Park Service disagreed with that conclusion and “recommends that states require the most rigorous cost-effective emission controls available as reasonable progress…”3 As representatives of the collective experiences of thousands of former park professionals, we deeply respect the knowledge of current NPS staff and agree with their recommendation.
We urge UDAQ to withdraw the proposed SIP revision as it pertains to IPP and reinstate the original requirement that IPP’s coal-fired units shut down. If UDAQ requires the coal-fired units to remain open, UDAQ must require IPP to install the most effective controls for NOx, optimize existing controls, and require lower emission rates for SO2 and PM.
Many of our Coalition members have worked to protect national park sites and public lands in and around Utah for decades. Some of us have also participated in regional haze planning in Utah for decades, providing comment letters and testimonials during previous state comment periods and the 2024 EPA comment period. Many of our recommendations have been largely ignored. It’s time for strong action to protect these irreplaceable spaces for the enjoyment of visitors now and for our future generations.
Thank you for considering our input on this important issue.
September 30, 2026
Jazmine Lopez
ja**********@**ah.gov
Devin Mulrooney
dm********@**ah.gov
Division of Air Quality
Department of Environmental Quality
195 North 1950 West
Salt Lake City, Utah 84116
Comments Submitted Electronically
Subject: Comments on Utah’s proposed Regional Haze State Implementation Plan (SIP) Revision
Dear Ms. Lopez and Mr. Mulrooney,
We are writing on behalf of nearly 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 49 members who currently live in Utah, and hundreds of other members who have worked in the state of Utah throughout 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, and a full array of other former employees, volunteers, and supporters. We strongly support efforts to ensure clean air and clear views are protected in our national parks throughout the country. We appreciate the opportunity to comment on the Utah Division of Air Quality’s (UDAQ) proposed revision to the Regional Haze Round 2 State Implementation Plan (proposed SIP revision).1
Utah has five mandatory Federal Class I areas that must be addressed by the Regional Haze long-term strategy for improving air quality: Arches National Park, Bryce Canyon National Park, Canyonlands National Park, Capitol Reef National Park, and Zion National Park. While air quality has improved over the decades, no Class I area in the country has achieved the Clean Air Act goal of natural visibility.
The Clean Air Act requires states to improve visibility in these protected areas, where millions of people each year visit to enjoy spectacular scenery, outstanding natural habitats for native plants and animals, and incredible dark skies at night. The Clean Air Act also requires each state to identify and evaluate the effects of industrial emissions from motor vehicles, power plants, oil and gas development and operations, and other sources on Class I airsheds within, and even in, neighboring states.
Unfortunately, the proposed SIP revision will do nothing to reduce haze pollution in Utah’s Class I areas or others in the region. According to data analyzed by National Parks Conservation Association, the Intermountain Power Plant (IPP) is the 12th worst haze polluter of national parks in the country.2 The removal of the shutdown date for the coal-fired units is unnecessary and will allow for the release of over 1,000 tons of nitrogen oxides (NOx) emissions and over 6,000 tons of sulfur dioxide (SO2) emissions, causing hazy skies and unhealthy air. The justification for removing the shutdown date is weak at best; the proposed SIP revision states that nearly 98% of the power generated at IPP was sold to entities out of state which means it is not vital to Utah’s grid reliability nor does it help provide a reliable supply of energy to Utahns.
Additionally, we believe that UDAQ improperly rejected the most effective NOx pollution controls for the coal units, claiming they were not cost-effective. However, the National Park Service disagreed with that conclusion and “recommends that states require the most rigorous cost-effective emission controls available as reasonable progress…”3 As representatives of the collective experiences of thousands of former park professionals, we deeply respect the knowledge of current NPS staff and agree with their recommendation.
We urge UDAQ to withdraw the proposed SIP revision as it pertains to IPP and reinstate the original requirement that IPP’s coal-fired units shut down. If UDAQ requires the coal-fired units to remain open, UDAQ must require IPP to install the most effective controls for NOx, optimize existing controls, and require lower emission rates for SO2 and PM.
Many of our Coalition members have worked to protect national park sites and public lands in and around Utah for decades. Some of us have also participated in regional haze planning in Utah for decades, providing comment letters and testimonials during previous state comment periods and the 2024 EPA comment period. Many of our recommendations have been largely ignored. It’s time for strong action to protect these irreplaceable spaces for the enjoyment of visitors now and for our future generations.
Thank you for considering our input on this important issue.
Sincerely,
Castle Valley, UT
Salt Lake City, UT
Saratoga Springs, UT
Moab, UT
Salt Lake City, UT
South Jordan, UT
Ogden, UT
Salt Lake City, UT
Salt Lake City, UT
Grand Canyon, AZ
Marana, AZ
Prescott, AZ
Scottsdale, AZ
Tubac, AZ
Bayfield, CO
Crawford, CO
Howard, CO
Lakewood, CO
Lakewood, CO
Mancos, CO
Montrose, CO
Ridgway, CO
Salida, CO
Colorado
Fairbanks, AK
Birmingham, AL
Inverness, CA
Mineral, CA
Morgan Hill, CA
Newbury Park, CA
Nipomo, CA
Orange, CA
Petaluma, CA
San Francisco, CA
Vallejo, CA
Punta Gorda, FL
Sandy Springs, GA
Captain Cook, HI
West Branch, IA
Boise, ID
Idaho
Edwardsville, IL
Minooka, IL
Newburgh, IN
Valparaiso, IN
Olathe, KS
Bowling Green, KY
Wellfleet, MA
Potomac, MD
Maryland
Michigan
Grand Rapids, MI
Hesperia, MI
Lake Ann, MI
Munising, MI
St. Louis, MO
Montana
Santa Fe, NM
Grimesland, NC
Silver Lake, OH
Broken Arrow, OK
Ashland, OR
Bend, OR
Medford, OR
Portland, OR
Dallas, PA
Gettysburg, PA
Custer, SD
San Antonio, TX
Alexandria, VA
Bedford, VA
McLean, VA
Monroe, VA
Oakton, VA
Winchester, VA
Virginia
Lincoln County, WA
Mazama, WA
Mazama, WA
Sequim, WA
Sequim, WA
Wapiti, WY
Evanston, WY
Footnotes