1

November 29 , 2014

Mr. Thomas Webb U.S. EPA, Region 9 Planning Office, Air Division, AIR

– 2

75 Hawthorne Street San Francisco, CA 94105

Via email to webb.thomas@epa.gov

Re: Proposed California Regional Haze State Implementation Plan and Interstate

Tr ansport Plan

Dear Mr. W ebb

,

National Parks Conservation Association respectfully submit s the following comments regarding

California ’s proposed Regional Haze State Implementation Plan Perio dic Progress Report (“Progress Report”). The Progress Report represents an important opportunity for the State to

take stock of whether the Regional H aze S tate I mplementation P lan (“SIP”) is on track to meet the reasonable progress goals at Class I areas in California and other states impacted by visibility impairing pollution from California

. Fortunately, m ost of the state’s 29 Class I national park and

wildernesses have seen improvements in visibility ; however

, to restore natural air quality at the regio n’s Class I areas as mandated by Clean Air Act, additional pollutant reduction is necessary.

As explained below, to ensure that the reasonable progress goals are achieved, visibility improvements thus far are maintained, and the legal requirements for a pr ogress report are satisfied, we ask EPA to include additional information and analysis now and in preparation for

the 2018 SIP revision . In particular, we request EPA include :

 Emissions inventories that distinguish between reductions enforceably required b y the

SIP and those that are the result of non

- enforceable conditions;

 Emissions inventories that i nclude natural emissions, include ammonia, and projected increases in emissions from oil and gas development;

 Enforceable limits on emissions that are not currently constrained; and2

 A clear, consistent approach to assessing impacts from fire, including the interrelated categories of prescribed fires and wildfires.

These revisions will not only ensure progress towards natural visibility conditions at our protected national parks and wilderness areas, but will also benefit public health and ecosystems by reducing emissions of damaging pollution.

I. THE CLEAN AIR ACT’S REGIONAL HAZE PROGRAM

a. Development of a Regional Haze SIP

In the 19 th century, Congress had the foresight to set aside national parks so as to preserve some of the nation’s most spectacular scenery. See, e.g. , John Copeland Nagle, The Scenic Protections of the Clean Air Act, 87 N.D. L. Rev. 571, 576 (2011). With the nation’s rapid industrialization, however, these remarkable scenic views have become increasingly marred by air pollution. See

id. at 573. Today, air pollution is “perhaps the greatest threa t to national parks,” and pollution all too often degrades visibility in these iconic scenic areas. Id.

To reduce this threat to the national parks and other treasured public lands, Congress amended the Clean Air Act in 1977 to set a “national goal” of preventing all visibility impairment caused by human activities in national parks, wilderness areas, and other “Class I” federal areas. 42 U.S.C. § 7491(a)(1). Congress again amended the Clean Air Act in 1990 to further spur reductions of regional haze a fter it concluded that the U.S. Environmental Protection Agency (“EPA”) and the states had not made adequate progress toward reducing haze. Id. § 7492. The Act delegates implementation of the regional haze program to EPA. The Agency set a goal of

achiev ing natural visibility conditions at every Class I area by 2064, and the Agency directed states to make incremental, reasonable progress toward that goal. 40 C.F.R. § 51.308(d)(1)(i)(B), (d)(1)(ii).

To achieve natural visibility conditions by 2064, the goa l set forth in the Clean Air Act’s implementing regulations, 40 C.F.R. §51.308(d)(1)(i)(B), the states are directed to c reate regional haze SIPs, which are then submitted to EPA for its review and approval. See 42 U.S.C. §§ 7410(a), 7491(b)(2). EPA evaluates the SIP and either approves or disapproves it in whole or in part. Id. § 7410(k)(3). If EPA’s evaluation reveals that a SIP does not comply with the Clean Air Act, then EPA must promulgate a FIP that remedies th e shortcomings. Id. § 7410(c)(1).

Each state’s regional haze SIP must include emissions limits on so urces of air pollution within the state as necessary to protect visibility at all impacted Class I areas, both inside and outside

the state. See 42 U.S.C. § 7491(a)(4), (b)(2). The 2064 natural visibility goal is to be achieved through two key elements in a SIP: The first is the requirement that a particular category of sources install the “Best Available Retrofit Controls (BART) and th e second is the requirement for a long

- term strategy to encompass a wholistic look including and beyond BART to identify measures needed to achieve reasonable progress at each Class I area impaired by a state’s

emissions. Id. § 7491(b)(2)(A); 40 C.F.R. § 5 1.308 (d)& (e). BART is required at eligible3

sources 1 that are reasonably anticipated to cause or contribute to visibility impairment at national parks, wilderness areas, wildlife refuges and other “Class I areas” where air quality should be pristine. 42 U.S.C. § 7491(b)(2)(A)

. BART is an essential component of the regional haze program as it compels emissions reductions from older, disproportionately polluting sources that often have escaped cont rol under other Clean Air Act programs. See id.

In addition to requiring BART, each state’s regional haze SIP must also set goals, expressed in deciviews, 2 for each C lass I area located within the state that will ensure reasonable progress toward achieving natural visibility conditions by 2064 (the “reasonable progress goals”). See 42 U.S.C. § 7491(b)(2); 40 C.F.R. § 51.308(d)(1). The reasonable progress goals must provide for improvement in visibility on the most impaired days an d ensure no degradation in visibility on the least impaired days over the period of the implementation plan. 40 C.F.R. § 51.308(d)(1). These goals are set after considering the anticipated visibility reducti ons over the planning period of the SIP from anticipated BART controls and other federal or state programs, as well as controls imposed on non

- BART sources as part of a state’s long

- term strategy section of a regional haze SIP to help achieve reasonable progress. See, e.g., 76 Fed. Reg. at 58,623.

States set the level of additional reasonable progress controls bas ed on “the costs of compliance, the time necessary for compliance, the energy and non

- air quality environmental impacts of compliance, and the remaining useful life of any potentially affected source . . . .” 40 C.F.R. § 51.308(d)(1)(i)(A); 42 U.S.C. § 7491(g)(1). With the emissions reductions anticipated from

t hese cumulative controls in mind, the state establishes the reasonable progress goals for the period of the SIP

 through 2018 in this case.

b. The Role of Five

- Year Progress Reports

Every five years after the submittal of its original SIP , states must evalua te the progress they are making in implementing the control measures included in their haze SIPs and whether they are on track to meet the visibility goals for Class I areas. 40 C.F.R. § 51.309(g). As part of these

five

- year progress reports, each state must assess whether its existing implementation plan is adequate to achieve its established goals for visibility improvement and emissions reductions. 40 C.F.R. § 51.308(h). To determine the adequacy of the haze plan, each state must include in its

progre ss report the following elements:

(1) A description of the status of implementation of all measures included in the implementation plan for achieving reasonable progress goals for mandatory Class I Federal areas both within and outside the State;

(2) A su mmary of the emissions reductions achieved throughout the State through implementation of the measures described in paragraph (d)(10)(i)(A) of this section;

1 A source is BART

- eligible if it is a stationary source within one of 26 enumerated categories, was not in operation before August 7, 1962, but was in existence on August 7, 1977, and has the potential to emit 250 tons per year or more of any pollutant. 42 U.S.C. § 7491(b)(2)(A), (g)(7).

2 EPA uses the deciview as the principal metric for measuring visibility impairment. The deciview scale “expresses uniform changes in haziness in terms of c ommon increments across the entire range of visibility conditions, from pristine to extremely hazy conditions.” 64 Fed. Reg. 35,714, 35,727 (July 1, 1999).4

(3) For each mandatory Class I Federal area within the State, an assessment of the following: the current visibility conditions for the most impaired and least impaired days; the difference between current visibility conditions for the most impaired and least impaired days and baseline visibility conditions; the change in visibility impairment for the most impaired and least impaired days over the past 5 years;

(4) An analysis tracking the change over the past 5 years in emissions of pollutants contributing to visibility impairment from all sources and activities within the State. Emissions changes sho uld be identified by type of source or activity. The analysis must be based on the most recent updated emissions inventory, with estimates projected forward as necessary and appropriate, to account for emissions changes during the applicable 5

- year period ;
(5) An assessment of any significant changes in anthropogenic emissions within or outside the State that have occurred over the past 5 years that have limited or impeded progress in reducing pollutant emissions and improving visibility;

(6) An assessment of whether the current implementation plan elements and strategies are sufficient to enable the State, or other States with mandatory Federal Class I areas affected by emissions from the State, to meet all established reasonable progress goals; and

(7) A review of the State's visibility monitoring strategy and any modifications to the strategy as necessary.

40 C.F.R. § 51.308(g)(1)

- (7). If, after considering the above elements, a state determines that its SIP is or may be inadequate to ensure reasonable progress, it must provide notification to the EPA, develop additional strategies to address the implementation plan deficiencies, collaborate with other States whose emissions may be impeding its progress, and revise the plan no later than one year from th e date that the progress report was due. Id. § 51.308(h)(3)

- (4).

II. CO

- BENEFITS OF REDUCING HAZE POLLUTION

Addressing haze pollution impacting Class I areas has the critical co

- benefit of protecting public health. Haze pollutants include nitrogen oxides, sulfur dioxide, particulate matter (“PM”), ammonia, and sulfuric acid, each of which poses a threat to public health. Nitrogen oxide is a precursor to ground level ozone, which is associated with respiratory diseases, asthma attacks, and decreased lung fun ction. In addition, nitrogen oxide reacts with ammonia, moisture, and other compounds to form particulates that can cause and worsen respiratory diseases, aggravate heart disease, and lead to premature death. Similarly, sulfur dioxide increases asthma sy mptoms, leads to increased hospital visits, and can form particulates that aggravate respiratory and heart diseases and cause premature death. Particulate matter can penetrate deep into the lungs and cause a host of health problems, such as aggravated asth ma, chronic bronchitis, and heart attacks.

Reducing these pollutants will have tremendous public health benefits , particularly in California, which has numerous areas in nonattainment with EPA’s National Ambient Air Quality Standards (“NAAQS”)

. EPA estimat ed that in 2015, full implementation of the Regional Haze Rule nationally will prevent 1,600 premature deaths, 2,200 non

- fatal heart attacks, 960 hospital5

admissions, and over 1 million lost school and work days. Nationally, the Regional Haze Rule

will res ult in health benefits valued at $8.4 to $9.8 billion annually. Investing in technologies that will reduce the pollutants that cause these asthma attacks, hospitalizations, heart attacks, emergency room visits and premature deaths is the right choice for C alifornia and the rest of the

nation.

These same haze

- causing emissions also harm terrestrial and aquatic plants and animals, soil health, and moving and stationary waterbodies

– entire ecosystems

– by contributing to acid rain, ozone formation, and nitrog en deposition. Nitrogen deposition, caused by wet and dry deposition of nitrates derived from NOx emissions, causes well known adverse impacts on ecological systems; in some places, saturation of the soil already exceeds the “critical load” the ecosystem

c an tolerate. 3 Acid rain causes acidification of lakes and streams and can damage certain types of trees and soils. In addition, acid rain accelerates the decay of building materials and paints, including irreplaceable buildings, statues, and sculptures tha t are part of our nation's cultural heritage.” 4 Further, haze

- causing pollutants are precursors to ozone. Ground

- level ozone formation impacts plants and ecosystems by: “interfering with the ability of sensitive plants to produce and store food, making the m more susceptible to certain diseases, insects, other pollutants, competition and harsh weather; damaging the leaves of trees and other plants, negatively impacting the appearance of urban vegetation, as well as vegetation in national parks

and recreation areas; and reducing forest growth and crop yields, potentially impacting species diversity in ecosystems.” 5

III. CLASS I AREAS IN AND NEAR CALIFORNIA

California has more protected Class I areas than any other state. Emissions from California impact visibility at all of its 29 Class I areas :

1. Redwood National Park; 2. Marble Mountain Wilderness; 3. Lava Beds National Monument; 4. South Warner Wilderness; 5. Thousand Lakes Wilderness; 6. Lassen Volcanic National Park; 7. Caribou Wilderness; 8. Yolla Bolly Mid dle Eel Wilderness; 9. Point Reyes National Seashore; 10. Ventana Wilderness; 11. Pinnacles National Monument; 12. Desolation Wilderness; 13. Mokelumne Wilderness; 14. Emigrant Wilderness; 15. Hoover Wilderness;

3 See, e.g., discussion of impacts on Rocky Mountain National Park. http://www.nature.nps.gov/air/permits/aris/romo/impacts.cfm

. 4 http://www.epa.gov/acidrain/effects/index.html

5 http://www.epa.gov/glo/health.html6

16. Yosemite National Park;

17. Ansel Adams Wilderness; 18. Kaiser Wilderness; 19. John Muir Wilderness; 20. Kings Canyon National Park; 21. Sequoia National Park; 22. Dome Lands Wilderness; 23. San Rafael Wilderness; 24. San Gabriel Wilderness; 25. Cucamonga Wilderness; 26. San Gorgonio Wilderness; 27. San Jacinto Wilderness; 28. Agua Tibia Wilderness; and,

29. Joshua Tree National Park

.

In addition, emissions from California impact Class I areas in other states, such as Crater Lake National Park in Oregon and Grand Canyon National Park in Arizona. These Class I areas preserve the region’s inspiring landscapes, rare geologic formations, and diverse wildlife and vegetation. They also serve as living museums of our nation’s history. Visitors from across the nation and globe are drawn to these lands an d their tourist dollars benefit state and local

economies.

IV. CALIFORNIA’S PROPOSED FIVE

- YEAR PROGRESS REPORT MUST BE REVISED TO MEET 40 CFR 51.308(g) AND (h)

California submitted its first proposed haze plan to EP A in March 2009 . As each state must

submit a progress report five years after initial plan submittal, 40 C.F.R. § 51.308(g), California

was required to submit its progress report by March 2014, and submitted the proposed version to

EPA in June 2014. While in general the draft Progress Report offers an important accounting of how the haze SIP is being implemented, there are a number of areas in which it should be improved , including emissions inventories, enforceable limits, and assessment of impacts from

fire.

To clarify its regulatory requirements, in April 2013 EPA issued guidance regarding progress reports, entitled General Principles for the 5

- Year Regional Haze Progress Reports for the Initial Regional Haze State Implementation Plans (Intended to Assist Sta tes and EPA Regional Offices in Development and Review of the Progress Reports) (“EPA April 2013 Guidance”). Among other elements, EPA’s April 2013 Guidance includes a checklist, mirroring the regulatory requirements, for evaluating progress report submitt als. 6 Each of the item s noted above is discussed in detail below, in relation to the corre sponding regulatory requirement.

6 p. 24

- 25.7 a. EPA Checklist for 40 C.F.R § 51.308(g)(2): Does the Report Include

Estimated Reduction Estimates for these Measures?

40 C.F.R § 51. 308(g)(2) requires each progress report to include a “summary of the emissions reductions achieved throughout the State through implementation of the measures described in paragraph (g)(1) of this section.” While Sections 2.4 and 2.5 of the Progress Report account for

emissions reductions achieved in California

, they do not summarize the emissions reductions achieved through implementation of the measures contained in the California haze SIP, as required by 40 C.F.R § 51.308(g)(2). That is, the Progress Rep ort does not distinguish between

emissions reductions achieved as a result of the haze SIP versus emissions reductions achieved as a result of other enforceable requirements or voluntary measures.

The fundamental purpose of a progress report is to assess the efficacy of the haze SIP. It is difficult to render such an accounting if the State does not attempt to determine the emissions reductions required specifically by the haze SIP rather than by other programs. Accordingly, we

urge EPA to require a revis ion of the draft Progress Report to quantify the emissions reductions achieved specifically as a result of the regional haze SIP. As EPA guidance notes, “progress reports should identify and est imate emissions reductions to date in visibility

- impairing pol lutants from the SIP measures .” (emphasis added). 7

In particular, we encourage EPA to include emission reductions associated with the implementation of BART at the state’s only BART

- regulated source, the Valero refinery in Benicia, California

. EPA should also include a direct comparison of the emission projections relied on in the WRAP modeling underlying California’s reasonable progress goals versus the most recent emissions inventory, and to explain any discrepancies and projected changes to

2018.

b. EPA Checklist for 40 C.F.R § 51.308(g)(3): Does the report include the

summaries of monitored visibility data as required by the Regional Haze

Rule?

We encourage EPA to revise Section 3 of the Progress Report to include natural conditions and the uniform rate of progress (URP) milestones set by California’s haze SIP, both in graphical and tabular form, since those are the goals by which visibility progress is measured. The URP milestone indicates the progress that must be made if California’s C lass I areas are to stay on track towards achieving natural visibility by 2064. In its initial SIP, California committed to including this comparison in the Progress Report

. 8

7 EPA April 2013, Gene ral Principles for the 5

- Year Regional Haze Progress Reports for the Initial Regional Haze State Implementation Plans (Intended to Assist States and EPA Regional Offices in Development and Review of the Progress Reports), p. 7.

8 California committed to “ compare the actual deciview calculations against progress towards reaching the RPGs and the uniform rate of progress...(CRHP, Section 9.3, page 9

– 2)” in its 5 year progress report. 76 FR 13961.8

Our own comparisons of the progress thus far to the 2018 URP is shown below.

20 00

- 2004 Worst Days Baseline (dv) 2018 Reasonable

Progress Goal (dv) 2018 U niform

R ate of P rogress (dv) 2008

- 2012

Worst Days (dv) Visibility

Improvement to URP By 2012

TRIN 17.4 16.4 15.2 15.8 73%

LABE 15.1 14.4 13.4 13.7 82%

LAVO 14.1 13.3 12.6 15.6

- 100%

BLIS 12.6 12.3 11.1 12.2 27%

HOOV 12.9 12.5 11.7 10.9 167%

YOSE 17.6 16.7 15.3 15.2 104%

KAIS 15.5 14.9 13.6 14.2 68%

SEQU 25.4 22.7 21.2 21.5 93%

DOME 19.4 18.1 16.6 17.5 68%

REDW 18.5 17.8 17.4 18.1 36%

PORE 22.8 21.3 21.2 21.2 100%

PINN 18.5 16.7 16 16.9 64%

RAFA 18.8 17.3 16.2 17.1 65%

SAGA 19.9 17.4 16.9 16.1 127%

SAGO 22.2 19.9 18.7 17.6 131%

AGTI 23.5 21.6 19.8 18.9 124%

JOSH 19.6 17.9 16.7 15.4 145%

As the table above shows, several of California’s Class I areas are currently meeting or exceeding the improvement required to attain the URP ; however, some are not and would need to make additional progress in order to be on track

.

It would also be helpful for EPA to include the 5 year rolling averages of species extinction in graphical and tabular form for each Class I area . These depictions wo uld more clearly illustrate the impacts associated with each pollutant species at the Class I areas and provide more conte xt for changes in visibility thus far and the additional progress necessary to meet natural conditions. Finally, given the significant discussion of the impacts of out

- of

- jurisdiction sources on California’s Class I areas, we suggest that EPA clearly inclu de estimates of emissions trends

from relevant out of state sources as well.

c. EPA Checklist for 40 C.F.R § 51.308(g)(4): Does the report provide

emissions trends acros s the entire inventory for a 5

- year period as required by the Regional Haze Rule?

40 C.F .R § 51.308(g)(4) requires, among other things, an analysis covering the most current 5

- year period “based on the most recent updated emissions inventory, with estimates projected forward as necessary and appropriate.” Sections 2.4 and 2.5 of the Progress Report address this requirement. However, it appears that the inventory presented does not include natural sources. Given the significant

– and increasing

– role of wildfire in visibility impairment in California, we9

ask EPA to include emissions from natur al sources in this emissions inventory, including projected future values.

Similarly, it is not clear that California’s emission inventory includes several growing sources of anthropogenic emissions, including emissions related to increased oil and gas pr oduction (e.g. emissions from high

- intensity production techniques such as fracking; projected increases in transportation of crude oil through California by rail; see discussion below).

Additionally, the Progress Report fails to discuss emissions of ammonia, a precursor to visibility impairing ammonium nitrate and ammonium sulfate. We ask EPA to include emissions inventory information for ammonia.

d. EPA Checklist for 40 C.F.R § 51.308(g)(5 ): Does the Report include an explicit statement of whether there are anthropogenic emissions changes impeding progress?

40 C.F.R § 51.308(g)(5) obligates each progress report to include an “assessment of any significant changes in anthropogenic emissions within or outside the State that have occurred over the past 5 years that have limited or impeded progress in reducing pollutant emissions and improving visibility.”

California appropriately discusses the impacts of wildfire, shipping emissions beyond

C alifornia’s jurisdiction, and Asian dust. We have suggestions for EPA on each of these categories, as well as other anthropogenic changes not discussed by California.

Fire Emissions

With regard to wildfire, we appreciate California’s discussion, and belie ve that it highlights the need for EPA to develop a nationally consistent methodology for accounting for fire with regard to regional haze. Although it is not entirely clear, we believe California’s Progress Report treats emissions from prescribed burns as anthropogenic (and therefore controllable) emissions, and emissions from wildfires as natural (and therefore uncontrollable) emissions. This is an accurate, but conflicted, representation for several reasons. First, prescribed fires are largely intended t o reduce

the incidence of natural fires ; they are inherently linked categories . Second, in addition to prescribed burns, there are many other huma n activities that influence the frequency and intensity with which natural fires occur (e.g. land management, campfire policies, general development, climate change, etc.)

. The statutory definition describes hu man made pollution as emissions resulting “directly or indirectly from human activities .” 42 U.S. C. § 7491

. Thus, to the extent that natural fires are in part a result of human activity , they must be discussed as anthropogenic impacts to Class I areas.

Additionally, it may not always be clear, from monitored data, whether impacts are due to wildfire versus other types of burning. Like wise, in the absence of a systemic approach, it is difficult to consistently assess the impact of fire not just in the most recent years, but also in the baseline (we note, for instance, that California’s discussion of wildfire impacts at LAVO does not app ear to remove elevated wildfire impacts from 2002 from the baseline).10

We ask EPA to develop and implement a clear, nationally applicable policy with regard to accounting for impacts from wildfire, prescribed fires, and other fire activity (e.g. agricultur al burning), as appropriate considering i ts statutory responsibilities.

Shipping and Asian Dust

We also appreciate California’s discussion of shi pping emissions and Asian dust, including California’s efforts to reduce emissions from shipping that are with in its jurisdiction. We encourage EPA to separately address emissions from federally regulated sources and to consult with other countries as appropriate to address transnational

sources ; we believe EPA has a statutory obligation to do so, considering its mandate to

eliminate hu man made pollution in our protected public lands.

Oil and Gas Emissions

We discuss above our concerns that some of the emission reductions relied on by California for progress seen thus far may not be enforceable moving forward, and thus may be temporary. In particular, we are concerned with the potential for increased emissions related to oil and gas development and production.

We are concerned that some of California’s progress may be offset if significant

emissions result from in creased development of oil and gas resources, particularly through fracking and other high intensity production methods, both in California and off shore. Although projections of recoverable oil from the Monteray Shale formation in

California were reduced recently, 9 the potential for increased development

– and associated increases in NOx, VOCs, methane, and other gases

– exists and must be regulated with haste.

Additionally, it is not clear that California’s emissions estimates include the impact of signif icantly increased importation of crude oil by rail. These imports have increased significantly since 2009, when they totaled 45,491 barrels Indeed, since 2012

– the last year for which California analyzes visibility data

– crude by rail imports have increa sed from roughly 1 million barrels annually to more than 6 million barrels in 2013, 4 million barrels in 2014 through September, and over 1 million barrels imported by rail in

December 2013 alone. 10 New proposed projects indicate the potential for future

in creases. In addition to emissions resulting from the processing of this oil at California’s refineries, the increase in locomotive traffic associated with crude by rail has significant associated emissions, including of NOx, VOCs, and particulate matter. W e ask EPA to take necessary actions to require that the emissions from these projects (along with any alternative methods of transportation of oil 11 ) will not offset emission reductions and visibility progress achieved thus far.

9 http://www.reuters.com/article/2014/05/21/eia

- monterey

- shale

- idUSL1N0O713N20140521

10 Crude by rail import data available at http://energyalmanac.ca.gov/ petroleum/statistics/

. 11 Crude by barge importation may be increasing as a result of opposition to crude by rail. See http://www.reuters.com/article /2014/10/23/us

- california

- bakken

- barge

- idUSKCN0IC17L20141023 . This form of import likewise has emission implications for regional haze.11

Indirect Impacts of Climate Change

Emissions of greenhouse gases also impact regional haze, though indirectly, and the impact of climate change on regional haze must be taken into account in state planning to ensure that adequate progress towards visibility restoration be made in l ight of the exacerbating effects of climate change on visibility. Multiple studies have documented the indirect impact of CO2 pollution on surface air quality. The warmer temperatures of climate change alter atmospheric chemistry and dynamics in ways that lead to generally higher ground

- level ozone and PM2.5

concentrations.

In particular, a recent study from Princeton University indicates that the United States is or will experience increases in ozone and PM2.5 a ssociated with climate change; 12 this conclu sion is generally consistent with other research on this topic. 13 The analysis isolates the effects of climate change alone on surface air quality (as opposed to changes due to population growth, variations in emissions, etc.). In the U.S., it documents increases in PM2.5 of up to 2 ug/m3 annually

– roughly 17% of the current PM2.5 National Ambient Air Quality Standards ( “ NAAQS ” ). The highest increases are in the eastern U.S. Changes in ozone concentration are more varied, but the Princeton findings sugge st increases of up to 2 ppbv in the northeast United States (nearly 3% of the current ozone NAAQS).

In addition to threatening the attainment and maintenance of the NAAQS, these climate

- change

induced increases in ozone and PM2.5 impact regional haze. PM 2.5 is the major source of haze pollution in the country. Additionally, projected increases in humidity would further exacerbate

the haze

- producing effects of any sulfate (or nitrate) present. Increases in ozone are also associated with lower visibility. 14

Most significantly, these CO2

- related changes in surface air quality cause increased mortality and other health impacts. In North America, PM2.5 and ozone increases due to climate change are expected to increase related mortality by 8% and 2%, respective ly

– in total an increase of nearly 13,000 deaths annually. The indirect impacts of climate change on air quality in
California’s national parks

– including impacts to visitor health and experience

– are already being felt and will be further exacerbated without intervention. We encourage EPA to consider

the e ffect of greenhouse gases on California’s efforts to mitigate visibility impairing pollution and act as needed to compensate for related impacts as a part of the state’s regional haze plan.

e. EPA Checklist for 40 C.F.R § 51.308(g)(6): Does the Report include an assessment of whether the state’s haze plan is on track to meet reasonable progress goals?

40 C.F.R § 51.308(g)(6) mandates an “assessment of whether the current implementation plan

element s and strategies are sufficient to enable the State, or other States with mandatory Federal

12 Y. Fang (2013), “Impacts of 21 st Century Climate Change on Global Air Pollution

- Related Premature Mortality,”

Climate Change 121:239

- 253.

13 See, e.g., M. Z. Jacobson (2008), “On the Causal Link Between Carbon Dioxide and Air Pollution M ortality ,” Department of Civil and Environmental Engineering, Stanford University

. 14 V.P. Aneja (2004), “Ozone and Other Air Quality

- Re lated Variables Affecting Visibility in the Southeast United States,” J. Air & Waste Manage. Assoc. 54:681

– 688

.12

Class I areas affected by emissions from the State, to meet all established reasonable progress

g oals.” While California appears to be on track to meet its reasonab le progress goals in most of

its Class I areas (LAVO is an obvious exception, discussed below) , it is not clear that this progress is enforceable or permanent. To retain this progress, we encourage EPA to revise California’s reasonable progress goals downw ard to reflect the p rogress thus far. We note that California previously committed to “ reevaluat[ing] the RPGs ” as a part of the Progress Report

“ to determine if they should be adjusted to better reflect achievable improvements in visibility,

as future con trol measures are adopted and implemented...(CRHP, Section 9.3, page 9

– 2).” 76

FR 13961. We believe this is an appropriate juncture at which to assess California’s reasonable progress goals.

f. EPA Checklist for 40 C.F.R § 51.308(h): Determination of Adequacy: Does the report (or the transmittal materials) provide the explicit determination required by the Regional Haze Rule?

T his final step in the regulatory requirements for progress reports compels states to take one of

four actions based on the information i n the progress report. The first option, designed for situations where “visibility and emissions trends indicate substantial progress,” allows states to

declare that further revision is not needed at this time. 15 The remaining three options deal with

situ ations where emissions

– from other states, other countries, or the state itself, respectively

– are or may be inadequate to ensure reasonable progress.

Given California’s identification of wildfire, shipping emissions, and Asian dust as relatively signif icant factors

– particularly with regard to the LAVO monitor, which has seen degradation of visibility on the worst days

– EPA should not approve California’s determination of adequacy. It is clear that this monitor is not on track to meet its reasonable p rogress goals and that the SIP as it stands is not sufficient to meet the established visibility goals.

g. EPA Checklist for 40 C.F.R § 51.308(g)(7 ): Does the report review the monitoring plan including any non

- IMPROVE monitors the state is using?

We encour age EPA to continue, if not increase, funding for the IMPROVE monitoring network. We note that many of California’s Class I areas are not monitored themselves but rely on data from another Class I area. To the extent feasible we encourage EPA to increase m onitoring such

that each Class I area has at least one dedicated monitor and at a minimum, the existing monitoring network should be maintained.

V. SOURCES TO EVALUATE IN FUTURE REVISIONS

We encourage EPA and California to begin to identify potential sources of emission reductions for the 2018 SIP revision, including identifying where monitoring or inventory gaps exist, such that additional information can be developed. For instance, there were a number of BART eligible sour ces that were determined not to be subject to BART because their impacts were less

than 0.5 deciviews. Some of these sources nonetheless had non

- negligible impacts that California

15 EPA April 2013, General Principles for the 5

- Year Regional Haze Progress Reports for the Initial Regional Haze State Implementation Plans (Intended to Assist States and EPA Regional Offices in Development and Review of the Progress Reports), p. 18.13

should revisit in 2018. Likewise, California does not appear to have perform ed single

- source analysis for non

- BART point sources. We encourage it to do so.

Finally, we are aware that the transportation and agricultural sectors are collectively large

sources of visibility impairing emissions

. We encourage EPA and the State to beg in assess ment, identification of mitigation options

, and a plan for mitigating emissions from these source categories in the 2018 SIP. As part of this, we encourage any monitoring or refinement necessary to ensure that the myriad agricultural emission sour ces are accurately captured.

Thank you for the opportunity to comment on EPA’s proposed approval of California’s determination that its current regional haze plan is adequate to meet existing visibility goals.

Sincerely,

Nathan Mi ller Engineering and Science Manager, Clean Air Program

National Parks Conservation Association nmiller@npca.org