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Comment 1 for California’s Regional Haze State Implementation Plan (hazesip2021) - Non-Reg.

First NameKatie
Last NameGoodwin
Email Addresskatie@accessfund.org
AffiliationAccess Fund
SubjectAccess Fund Comments on CA Regional Haze State Implementation Plan
Comment

My name is Katie Goodwin and I am the California Regional Director and Policy Analyst for the non-profit Access Fund. The Access Fund is a national advocacy organization and accredited land trust whose mission keeps climbing areas open and conserves the climbing environment. A 501c(3) nonprofit representing millions of climbers nationwide in all forms of climbing—rock climbing, ice climbing, mountaineering, and bouldering—the Access Fund has over 20,000 members and over 123 local affiliates. California is one of our largest member states.

Climbers from around the world visit California’s national parks and wilderness areas to enjoy some of the world’s best rock climbing, from Yosemite to the high Sierra to Joshua Tree. Clean air is a significant part of the  climbing experience—we need it to breathe and to take in the beautiful scenery of the wild places we seek out.

But over the decades, haze—from cars and trucks, oil and gas operations, and other industrial sources—has degraded visibility and harmed people’s health in national parks and local communities across the country. In fact, nearly 90% of national parks are plagued by haze pollution—visitors to California’s national parks miss out on an average of 90 miles of visibility in parks. 

The Clean Air Act includes a time-tested, effective program designed to protect “Class 1” airsheds including National Parks and wilderness areas that provide outstanding recreational opportunities. This Regional Haze Rule has resulted in real, measurable, and noticeable improvements in visibility and air quality in national parks and in communities across the nation.  

Despite great strides to date, California’s proposed regional haze plan fails to require adequate measures to reduce pollution and falls short on the state’s obligation to improve air quality for our parks and communities.

Poor air quality in our national parks also threatens our local economies. Our national parks provide nearly $42 billion in economic benefits and support hundreds of thousands of jobs across the country. In 2020 California’s recreation economy provides $44.5 billion dollars in consumer spending and provides 488,755 direct jobs. Without strong safeguards protecting the air we breathe, we can’t keep these places and local economies strong, let alone keep people healthy. Every visitor to a national park deserves to experience clean air and clear views. 

The same sources of pollution causing haze in our national parks are also disproportionately affecting communities near those sources—communities that are often living below the poverty line, communities of color, or both. Alongside the National Parks Conservation Association, we’re calling on state agencies and the Environmental Protection Agency (EPA) to account for the benefits that controls on haze-causing pollutants have for disproportionately affected communities and ensure that those benefits are considered and prioritized in developing state or federal implementation plans.

Our top recommendations are:

  • Fully analyze the 42 stationary sources identified as contributing to haze pollution using a four-factor analysis as required by the Regional Haze Rule, including major sources of human made sulfur dioxide pollution. 

  • Implementing strong, significant, and federally enforceable emission reducing measures for oil refineries, cement manufacturing facilities, and other major industrial sources of haze identified through a proper four-factor analysis process.

  • Thoroughly assessing and addressing climate and environmental justice impacts (as EPA recommended) to benefit environmental justice communities near where the major sources of haze are located. These include areas near the port of Los Angeles and Northern Bay Area communities where many oil refineries are located. 

Thank you for your time and consideration.

Sincerely,

Katie Goodwin-Access Fund, California Regional Director


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Date and Time Comment Was Submitted 2022-06-24 08:43:50

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