Clean-Air Rules Protecting Parks Set to Be Eased

More Bush Administration fun and games:

The Bush administration is on the verge of implementing new air quality rules that will make it easier to build power plants near national parks and wilderness areas, according to rank-and-file agency scientists and park managers who oppose the plan.

The new regulations, which are likely to be finalized this summer, rewrite a provision of the Clean Air Act that applies to "Class 1 areas," federal lands that currently have the highest level of protection under the law. Opponents predict the changes will worsen visibility at many of the nation's most prized tourist destinations, including Virginia's Shenandoah, Colorado's Mesa Verde and North Dakota's Theodore Roosevelt national parks.

Nearly a year ago, with little fanfare, the Environmental Protection Agency proposed changing the way the government measures air pollution near Class 1 areas on the grounds that the nation needed a more uniform way of regulating emissions near protected areas. The agency closed the comment period in April and has indicated it is not making significant changes to the draft rule, despite objections by EPA staff members.

Jeffrey R. Holmstead, who now heads the environmental strategies group at the law firm Bracewelll & Giuliani, helped initiate the rule change while heading the EPA's air and radiation office. He said agency officials became concerned that the EPA's scientific staff was taking "the most conservative approach" in predicting how much pollution new power plants would produce.

"The question from a policy perspective was: Do you need to have models based on the absolute worst-case conditions that were unlikely to ever occur in the real world?" Holmstead said in an interview Thursday. "This has to do with what [modeling] assumptions you're required to do. This is really a legal issue and a policy issue."

The initiative is the latest in a series of administration efforts going back to 2003 to weaken air quality protections at national parks, including failed moves to prohibit federal land managers from commenting on permits for new pollution sources more than 31 miles away from their areas and to protect air resources only for parks that are big and diverse enough to "represent complete ecosystems."

For 30 years, regulators have measured pollution levels in the parks, over both three-hour and 24-hour increments, to capture the spikes in emissions that occur during periods of peak energy demand. The new rule would average the levels over a year so that spikes in pollution levels would not violate the law.

A slew of National Park Service and EPA officials have challenged the rule change, arguing that it will worsen visibility in already-impaired areas, according to internal documents obtained by the House Committee on Oversight and Government Reform.

...Yesterday, the National Parks Conservation Association, an advocacy group, issued a report estimating that the rule would ease the way for the construction of 28 new coal-fired power plants within 186 miles of 10 national parks. In each of the next 50 years, the report concludes, the new plants would emit a total of 122 million tons of carbon dioxide, 79,000 tons of sulfur dioxide, 52,000 tons of nitrogen oxides, and 4,000 pounds of toxic mercury into the air over and around the Great Smoky Mountains, Zion and eight other national parks.

"It's like if you're pulled over by a cop for going 75 miles per hour in a 55 miles-per-hour zone, and you say, 'If you look at how I've driven all year, I've averaged 55 miles per hour,' " said Mark Wenzler, director of the National Parks Conservation Association's clean-air programs. "It allows you to vastly underestimate the impact of these emissions."

What is my take, as an air quality modeler?:

It’s a bit hard for me to figure out exactly what this is just based on the newspaper article, since it apparently deals with the emission side of things, where I typically don’t get involved.

Nevertheless, from my point of view, emissions estimates should be based on the shortest period of time practicable, because visibility is virtually an instantaneous measure. The speed of light is 186,000 miles per second, and requires very, very little time to zip between the typical power plant plume, and the typical eyeball.

Under current practice, 24-hour average measures are usually used. To me, this is already an arbitrary and irrational practice, because shorter averaging periods (1 & 3-hr) can be used, in principle. Nevertheless, use of 24-hour average measures is usually justified as a practical matter, because ambient particulate matter measurements are traditionally made on a 24-hour average basis, and because it takes a number of hours (12 to 24) for most power plant plumes to reach Class I areas like national parks and wilderness areas.

To head in the opposite direction, however, and use annual emission estimates, is to compound the existing irrationality. It simply ignores the fact that light doesn’t need a year to travel 80 or 120 miles across your typical viewscape.

So, the Bush Administration has had an opportunity to address an existing irrationality, and as one might expect, has decided to make matters even more irrational than they already are.

But there is the benefit that it is likely to make it considerably easier to site power plants and other industrial sources near to Class I areas, if no other changes are made to threshold measures to compensate for the change.