Good morning,
my name is Natalie Levine and I am the Climate and Conservation
Program Manager at National Parks Conservation Association (NPCA).
Thank you for the opportunity to comment today on
California’s Second Regional Haze State Implementation Plan.
NPCA is the oldest and largest nonpartisan nonprofit advocacy
organization for our national parks. We have over 1.7 million
members and supporters across the country with over 207,000 here in
California. Along with my testimony, I have submitted 636 comments
from national park advocates to the Board comment log.
As you know,
California boasts some of the nation’s most treasured
national parks and public lands, many of which are considered Class
I areas under the Regional Haze Rule. I’ve been lucky to have
been able to travel to amazing treasures like Yosemite, Redwood and
Joshua Tree National Parks as well as pristine wilderness areas in
the Lake Tahoe Basin.
I currently
live in the Bay Area, not only about 20 driving miles from Class I
area Point Reyes National Seashore but also 20 to 30 driving miles
from oil refineries along San Pablo Bay that are polluting our air,
making our communities sick and hastening climate change. I worry
about the air my two small children breathe in every
day.
California
has the opportunity now to clean up air pollution from these oil
refineries, and dozens of other industrial sources in the state,
through the state’s Second Regional Haze State Implementation
Plan. The Regional Haze Rule is a time-tested and effective program
to not only clear haze pollution from national parks and wilderness
areas, but from our neighborhoods and communities. The opportunity
that our state has right now to clean up pollution from specific
industrial sources cannot be missed.
The State
Implementation Plan, or SIP, currently proposed by the California
Air Resources Board falls significantly short of the state’s
obligation to restore clean air in our Class I areas. The state
improperly concludes that no new reductions in pollution are
warranted. If CARB submits the current plan as-is to the U.S. EPA,
it will not comply with the Clean Air Act and the Regional Haze
Rule as it does nothing new to limit haze-causing air
pollution.
Of the 42
pollution sources that CARB selected for review, staff only
selected one single source for further analysis and concluded that
no new emissions reductions were needed for that source. Moreover,
CARB staff decided to only focus on nitrogen oxide pollution in
their review and not other manmade pollutants that contribute to
haze like sulfur dioxide. NPCA believes all of these decisions by
CARB are unacceptable – California’s haze plan leaves
numerous opportunities to cut pollution from stationary industrial
facilities off the table, failing to adequately reduce haze
pollution in our parks and limiting additional co-benefits that
could be achieved through the haze rule.
Furthermore,
failure to fully analyze more industrial facilities in California
contributes to the state’s inaction on environmental
injustices of air pollution in low-income communities and
communities of color where many of the worst polluting sources are
located.
NPCA
appreciates CARB’s four-factor analysis of mobile sources
like cars and trucks, making California the first state to include
control measures for this sector in the haze plan. Though we are
disappointed that CARB relied on existing programs to curb mobile
source emissions and did not specify new control measures for the
sector.
Before CARB
submits their haze plan to the EPA, NPCA requests that the state
significantly revises its draft SIP to fulfill its obligations
under the Clean Air Act. Specifically, we request you:
1.
Fully analyze the 42 stationary sources identified as
contributing to haze pollution using a four-factor analysis,
including major sources of humanmade SO2 pollution.
2.
Implement strong, significant, and federally enforceable
emission reducing measures for industrial sources of haze
identified through a proper four-factor analysis process.
3.
Thoroughly assess and address climate and environmental
justice impacts (as EPA recommends) to benefit environmental
justice communities near where the major sources of haze are
located.
The Clean Air
Act’s Regional Haze Rule is an effective program that has
resulted in real, measurable, and noticeable improvements in
national park visibility and air quality. I hope CARB strongly
considers making improvements to the plan to not only restore clean
and clear skies to our parks and wilderness areas, but to also
clear the air for our communities and next generations.
Thank you for
your time and I look forward to reviewing improvements to this
plan.
Sincerely,
Natalie Levine
nlevine@npca.org