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1 WASHINGTON, DC 20510

February 17,2012
The Honorable LisaP. Jackson Administrator US Environmental Protection Agency 1200 PennsylvaniaAve NW WashinSlon, DistrictofColumbia 20460-000I

Dear AdministratorJackson:
We arc writing with respect to EPA's plans to propose a regional haze fedcrdl implementlltionplan (FIP) for the SIDte afMontan

... We understand that EPA has gathered41nd is considering relevant environmental and economic information from the State ofMontana ;.and regulated facilities. We commend that effort and encourage you to continue yourdialogue with Ihe Slate Ilnd affected facilities. Visibility is important to our outdoorheritage in the West. Montanans arc lucky lhallhc Big Sky \'I,re so cherish is also by llnd large aclear sky. Butthere is more to clarity thanjustluck. The Clean Air Acthas underpinned the environmental progress made by this nation l"Or decades. We lend healthier lives because ofthe Act.
In cralling the statute, Congress wisely differentiated the relative importance ofthe Act's emission reduction programs. Forexample, Congress tied the requirements for best available retront technology under the regional haze program to acost-effectiveness and reasonable progress analysis. Provisions orthe Actthat eslnblish public health-based standards lack such tempering criteria,
Given these relative priorities, we arc concerned about the economic impact ofrequiring expensive conlrol technologies under aprogram that measures progress overdecades. Our concern is deepcned by the fact thal potential requirements in the FIP, such as the inSlaUation of Selective Catalytic Reduction at the Colstrip Steam Electric Generation Station, might result in imperceptible visibility benefits-the SUIlU[ory objective oflhe regional haze program. fn addition, we arc keenly aware ofthe recent and upcoming financially material investments made by Montana lbcilities in clean air lechnology. in particularto comply with final air toxics rules promulgated by this Administration. We note thaI those rules will likely result in significant reductions in surrogate pollutants (sulfurdioxideand particulate mailer) thut overlap with the regional haze program. Finally, we respecrfully point OUI the painful realities ofadepressed economy: theInrgerdownturn has already rorced two oflhe Montana facililies initially identified 

### by EPA as eligible for best available retrofit technology to shutdown,In evaluating the cast effectiveness afthe FIP, the legislative history afthe regional haze pragram is illuminating. One ofus participated in the debates in the 95th Congress thnt resulted in amending the Act to avoid pushing industrial pollution inlo areas lhal were already clean. 

### In seeking to preventthe flight ofindustry from metropolitan areas, Congress enacted several importnntprovisions, including the regional haze program. Congress simultaneously recognized the threat that impaired visibility could pose 10economies that rely on tourism. In 1977, the House Committee on Interstate and Foreign Commerce contemplated the prospectthat national parks and wilderness areas would be '"despoiled orheavily shrouded in dense industrinl pollution." It would have been a perverse outcome indeed ifindustrial migration caused by the Clean Air Act meant that tourists could no longer sec across the chasm ofthc Grand Canyon of the Colorado ordown the chutes oftheGrand Canyon ofthe Yellowstone. Thankfully, we have avoided that outcome. It poses no immincnt threat in oraround Montana.


### In light ofthcse considerations, we note that EPA appears to lack 

### aconsistent national policy with respect to an appropriate costthreshold forbest available rctrofillechnology. We submitthat, at the 

### very least, the

### costs imposed 

### by the regional haze program should 

### not be higher than those required to achieve health·based emission standards.
Forexample, EPA is considering allowing eastern states to meet theirregional haze obligalions by complying with adistinctrulc, the Cross·Statc AirPollution Rulc (CSAPR). EPA estimates that the marginal abatement cost forcomplying with CSAPR ranges from $500 perton in 2012 to $[,800 perIon in 2014. We don'llhink Montanans should pay more to achieve the same fractional improvement in dcciviews. An aesthetic-based standard in Montana should nOI cost multiple times ahealth-based standard in the East, especially when Montana starts with clearerair. This result would Oy in the face ofthe cost-effectiveness evaluation mandated by Congress.
We urgc you to take into account these points as you prepare aregional haze FIP for Montana, and we look forward to remaining informed by EPA as the rulemaking proceeds. Sincerely,

Jon Tester U.S. Senator ax Bnucus U.S. Senator