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News :: Miscellaneous |
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Student Speakers Sought for EPA Chicago Hearings on Clean Air in National Parks |
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by Ilinois Student Environmental Network
Email: isen (nospam) prairienet.org (unverified!)
Phone: 217-384-0830
Address: 110 S. Race Suite 202 Urbana, IL 61801 |
14 Aug 2001
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On Monday, August 27 the Environmental Protection Agency will hold hearings on air quality in National Parks. Student environmentalists are needed to testify before the EPA on this issue. The Illinois Environmental Council will pay transportation costs. |
On Monday, August 27 the US Environmental Protection Agency (EPA) will be holding a public hearing in downtown Chicago to address visibility problems in national parks across the country. The EPA has proposed a rule called BART (Best Available Retrofit Technology) to limit air pollution from
power plants and other large sources to increase visibility in major national parks.
It is important to note that the EPA is only holding 2 hearings on the proposed BART rule, and one of them is in Chicago. Student activists from across Illinois need to come out in support of clean air in national parks. It is not often that we get EPA public hearings so close to home, so please take advantage of this opportunity.
The Illinois Environmental Council is offering to pay for your travel costs to Chicago (sorry, no lodging) for you and other members of your student group to attend the hearing -- from anywhere in Illinois! Since the hearing is on a Monday, if you want to travel to Chicago on Friday or Saturday,
you\'re getting a free trip home or to see friends!
While you\'re at the hearing, it\'s imperative that you provide testimony, or public input. You\'ll be limited to 5 minutes, so plan to go up and talk about how you want our national parks to have good visibility, and that you support cleaning up air pollution from power plants. Personal experiences work
wonderfully -- talk about a trip you made, especially if your visibility in the park was impaired. Below is a fact sheet to help you craft your message and learn more about the event and issue.
Here\'s the catch: You must register in order to testify at the hearing, and the deadline for registration is next Monday, August 20. Here\'s how to register:
1. Contact Nancy Perry at EPA at perry.nancy (at) epa.gov to testify, or register by phone at 919-541-5628. Do this ASAP, as the deadline to register to testify is Monday, August 20.
2. The hearing will begin at 10 am at the Metcalfe Federal Building, Room 331, 77 W. Jackson Blvd, Chicago. here will likely be an evening session too, with things concluding by 9 pm.
3. Contact John Thompson at the Illinois Environmental Council at Thompjw (at) aol.com to let him know you have registered so he can keep a count on participants.
An ISEN representative will be at the hearing to help you through the process. This is wonderful experience, and a very powerful forum in which to make an impact. We hope to see you there.
- Laura Huth, ISEN Executive Director
BACKGROUND ON THE ISSUE:
The scenic vistas in America\'s national parks and wilderness areas are suffering from air pollution. Pollution from power plants and other stationary
sources, has, over the past half century, obscured the magnificent vistas replacing them a colorless and unhealthy haze. In some parks, visibility is about
one quarter or less of what it could be under near natural conditions. Disturbingly, in a number of important parks throughout the US (eg, Big Bend,
TX, Badlands, SD, Great Smoky Mountains TN/NC, Rocky Mountain CO, Bryce Canyon, UT and others) visibility is actually deteriorating.
Moreover, in the class I areas of the southern Appalachians, sulfate particulate matter-predominantly from old power plants-- is responsible for 85% of
the haze on the worst days.
Congress established a national goal in the 1977 amendments to the Clean Air Act: \"the prevention of any future and the remedying of any existing
impairment of visibility\" in mandatory class I federal areas. The 156 class I areas include 48 national parks and 108 wilderness areas and national wildlife
refuges exceeding approximately 5,000 acres in existence at the time of the 1977 amendments.
The 1977 amendments to the Clean Air Act also required that EPA promulgate guidelines to states to review and clean up stationary sources (power
plants and 25 other source categories) that cause visibility impairment in a class I area. This guidance was established in 1980 and is referred to as
attributable BART. The 1980 attributable BART
guidelines apply only to a single source or a small group of sources that are reasonably anticipated to cause or contribute to visibility impairment in a class
I area. Because of the relatively high burden of proof to identify culpable sources applied by EPA, attributable BART has rarely been applied and has had
limited benefit in meeting the national visibility goal. For this reason, EPA is proposing a second BART program.
The EPA included in its 1999 final Regional Haze Rule requirements for establishing Regional Haze BART. Regional haze is the result of the collective
contribution of many sources over a broad region rather than the result of a single or small group of sources near a park or wilderness area. Regional haze
BART is very important because it applies
to larger groups of sources that \"may reasonably be anticipated to cause or contribute to any impairment of visibility in any class I area.\" The Regional
Haze BART proposed rule published in the Federal Register July 20, 2001, p 38108. (The Federal Register can be accessed at:
http://www.access.gpo.gov/su_docs/aces/aces140.html ).
The BART rule could mean major SO2 reductions-CATF / MSB Energy Associates have estimated a potential maximum reductions of 3.8 million tons
SO2 beyond Phase II and 1.6 million tons NOX post-Clean Air Act if the tons are permanently retired and allowances /credits are not issued for the
reductions for use in other Clean Air Act programs.
Curbing SO2 means cutting sulfate and the particulate matter it forms. Sulfate particulate matter not only causes haze but acid rain and health impacts.
Sulfate has been associated with respiratory and cardiac disease such as asthma and heart attacks, as well as premature death in many major studies. If
you can see it you are breathing it.
BART SOURCE ELIGIBILITY
* BART targets \"grandfathered\" utility and industrial boilers, pulp mills, refineries, smelters, cement plants, and other stationary sources, those facilities
that were already in existence before the legislation was created. Do date, they have been allowed to operate \"out of compliance\" as a matter of right.
* Requires states to adopt visibility SIPs to reduce haze in any class I airshed in any state.
Comment: The proposal that all states are \"in\" should be strongly supported.
* BART applies to about 583 power plant units of Aug 7, 1962-Aug 7 1977 vintage with potential to emit 250 tons per year of visibility-impairing
pollution (e.g. SO2, NOX , PM, VOCs).
Comment: Total haze-causing pollutants from all units of a power plant should be summed to meet 250-ton criteria rather than on a pollutant-by-pollutant
basis. Also any power plant that has at least one unit \"in\" should be \"in\" or subject to BART for ALL its units.
* The BART analysis also applies specifically to all electric plants that are greater than 250 million BTU/hour.
Comment: This threshold should be in aggregate-in other words, all units at a source should be totaled to see if 250 million BTU/hr is exceeded, rather than
the second proposed option that the threshold criteria would apply to individual units separately.
PROPOSED BART METHODOLOGY
* Sources must first identify all control options available. Two options are offered for comment in the proposal:
A) A plant-by-plant determination of the \"Best Available Retrofit Technology\" using \"top-down\"
(BACT) method of review. Top-down means reviewing available technology starting with the best.
B) A weaker methodology beginning with minimum or mid-range technology and looking at feasibility
of better technology from that point.
Comment: The environmental community should reject option B. Best available should be just that-the best. Option A needs strong vocal support.
*The proposal includes a presumption that SO2 can be controlled at a 90-95% level.
Comment: This must be reinforced in all comments. A similar presumption should be stipulated in the rule for NOX at 90%.
* The BART analysis required of the states must also take into account the cost of compliance and remaining useful life of the source.
Comment: If some power plants are determined to have little remaining useful life, then the environmental community should demand a binding and
enforceable commitment to shut down.
* Cap and Trade program option: The rule provides for an alternative cap and trade mechanism with the stipulation that the results must be better.
Comment: The environmental community should demand that the visibility results be better. It is not enough to simply reduce tons of emissions nationwide, as
the locations of emissions reductions are critical to improving visibility in specific parks and wilderness areas.
Will the reductions be permanent? From the proposed rule is unclear whether BART reductions must be permanent under than the cap or would create
allowances under other emissions reductions programs. If a cap and trade alternative is allowed, the caps set must be above and beyond the emissions
caps established for the Title IV and NOX SIP Call. |
See also:
www.isenonline.org
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