Testimony on BART Rule

Testimony Before the U.S. Environmental Protection Agency

Regarding the BART Rule

August 21, 2001

Arlington, VA

I am Neil Woodworth, Counsel to the Adirondack Mountain Club and the New York – New Jersey Trail Conference. Today, I represent national and regional outdoor recreation and conservation organizations that have formed an advocacy partnership called Hikers for Clean Air.

Our organizations collectively number more than 200,000 hikers who cherish the mountains of the Eastern United States. These are the special places that 72 million hikers seek out each year for recreation, healthful exercise and renewal of the spirit. In all, some 287 million people visited national parks in 1998.

We are here because your Agency is considering rules on "best available retrofit technology" (BART) for power plants and industrial facilities that contribute to haze in our parks. Strong BART rules will result in significant reductions of haze-forming sulfur dioxide and nitrogen oxide emissions. Substantial emission reductions are necessary to improve the visibility in our national parks and wilderness areas.

Scientists estimate that on the haziest days, atmospheric sulfates contribute about 75 percent of the particulate matter that impairs visibility in the eastern mountains. Data from the IMPROVE monitoring network shows that the sulfate aerosols are the prime cause of diminished visibility in the eastern mountains. In the Class I designated airsheds of Appalachian Mountains, visibility, acid deposition and ozone levels have worsened despite the mandate of the 1977 amendments to the Clean Air Act.

For example, the average natural visual range in Virginia’s Shenandoah National Park and in the Great Smoky Mountains of Tennessee and North Carolina is about 80-90 miles, while average summertime visibility has been reduced to just 12 miles. The Clean Air Task Force reports that in 1999, the Great Smoky Mountains National Park suffered an astounding 52 days in violation of the national health standard for ground-level ozone, rivaling the dirtiest cities in the United States for unhealthy air. In Maine’s Acadia National Park, annual ozone violations rival nearby Boston and even New York City.

It is a national disgrace that the staff of Great Smoky National Park have been forced to issue more than 100 alerts of unhealthy air in the last three years. On a bad day, visibility there is only about 15 miles. On the park's best days, such as after a big storm has temporarily blown the pollution out, visibility can be as far as 55 miles.

In a recent letter from Senator Fred Thompson, Republican of Tennessee, to President Bush, he encouraged the administration to support this agency's air quality clean-up rules.

Describing the deteriorating air quality in the Great Smoky N.P., he added, "Most shocking to me is that, according to park officials, air quality in the Smokies is so poor during the summer months that hiking on back-country trails is more hazardous to your health than walking along the streets of Manhattan."

The same nitrogen oxides that cause smog and haze, also contribute to ozone. Hikers are considered a "sensitive group" in the EPA’s category for describing the ozone levels to the public. Indeed a study conducted by one of our coalition members showed ozone directly impairs the lung function of healthy hikers on the Appalachian Trail.

The Appalachian Trail (AT) is a thread that weaves together some of this nation’s most treasured national and state parks and is a symbol of our country’s grandeur. Yet this designated national scenic trail is often shrouded in man-made haze, a pollution that threatens both human and ecosystem health. Mountain summits and ridges, the most cherished areas to many AT hikers, are hit the hardest, with degraded views, acidified soils, damaged ecosystems and dangerously high ozone concentrations.

The rate of acid deposition at Great Smoky Mountains National Park is three to four times the level at which soil chemistry changes occur that cause serious damage to mountain ecosystems (Schultze et al. 1989). The acid neutralization process strips calcium from mountain soils and replaces it with mercury and nitrogen. This in turn causes fatal stress to many species of trees. This phenomenon has been recently documented by U.S. Geological Survey studies and the Hubbard Brook Research Foundation in New Hampshire.

Most of this damage is caused by sulfates and nitrogen oxides emitted by 51 "grandfathered" power plants now operating in violation of the EPA’s New Source Review regulations. Nowhere is the need for a strong BART regulations demonstrated more than on the magnificent ridgelines of Great Smoky and Shenandoah National Parks.

According to your own studies, these power plants are responsible for over two-thirds of the sulfate particles that are the chief cause of haze in the U.S. Large reductions in sulfur dioxide from old coal and oil burning power plants represents the single most important and cost-effective step in improving visibility in our parklands and wilderness areas.

Specific Comments on the BART Rule:

The Clean Air Act already requires states to identify electrical utility sources that cause or contribute to visibility impairment in any Class I national park, wilderness or national wildlife refuge area. EPA must require states to undertake a rigorous review of power plants that contribute to visibility impairment in parks and wilderness areas.

Fuel switching and/or the retrofitting of the latest emission control technology at these unremediated fossil fuel generating facilities can reduce sulfur dioxide and nitrogen oxide emissions by 90%. The technology exists. Let's use it now.

The Regional Haze BART proposed rule published in the Federal Register on July 20, if adopted and enforced, could result in a reduction of estimated 3.8 million tons of sulfur dioxides beyond Phase II and 1.6 million tons of nitrogen oxides if these tons are permanently retired and the pollution allowances are not allowed to be credited for compliance with other Clean Air Act requirements.

Total haze causing emissions from all units at a power plant should be totaled to determine if the 250 million BTU/hour is exceeded. We do not support applying this threshold to individual units separately. We support a top-down, plant by plant determination of the best available retrofit technology for each power plant with the goal being to require the retrofit that makes the greatest contribution to reducing regional haze. We feel it is necessary and possible to reduce SO2 and NOx emissions by 90% to achieve the BART program visibility improvements and human health benefits.

This nation will not attain the visibility goals of the 1977 amendments to the Clean Air Act by simply reaching national emission reduction targets. The goal of the BART Regional Haze Rule is to ensure that all Class I areas attain substantial improvement, therefore emissions trading must not occur at the expense of achieving BART program goals for each Class I area. We must reduce the emissions of individual plants upwind of Class I parks and wilderness areas so that the actual visibility of each specific Class I area, especially Great Smokies and Shenandoah National Parks, is greatly improved.

Swift and strong action to implement the Regional Haze Rule, with a strong BART rule will clear the air in our precious national parks and wilderness areas and protect the health of millions of hikers and many others, while simultaneously restoring the ecological vitality and quality of life of our nation’s parks and forests.

To contact Hikers For Clean Air please visit our web site or call (518) 449-3870.