Comments from National Park Service Valerie Naylor, Superintendent, Theodore Roosevelt National Park May 2, 2012 Billings, Montana The North Dakota National Parks downwind of Colstrip are beautiful and important for their historic and cultural value to the nation. The three units of Theodore Roosevelt National Park memorialize the history ofthe president's connection with the west and his unwavering conservation ethic along with important and scenic and natural resources. Theodore Roosevelt National Park boasts badlands geologic formations, outstanding wildlife, and the meandering Little Missouri River. Fort Union Trading Post National Historic Site is near the confluence of the Yellowstone and Missouri Rivers, and straddles the Montana-North Dakota border. It was the most important fur trading post on the Upper Missouri from 1828 through 1867 and a vital outpost of westward expansion. The reconstructed fort lies on the bank of the Missouri River atop the site of the original fort. Knife River Indian Villages National Historic Site is the location of five historic Mandan, Hidatsa, and Arikara Indian Villages. It contains archeological resources dated thousands of years prior to colonization by European Americans. The villages are marked by depressions of hundreds of earthlodge sites located on high spots along the Knife and Missouri Rivers. All three NPS sites are being severely impacted, both directly and indirectly, by heavy energy development in western North Dakota, as well as energy production in eastern Montana. We are pleased that the Environmental Protection Agency has proposed some S02 and NOx emission reductions at the Colstrip Power Plant, but EPA's analysis shows that, even after those reductions occur, Colstrip will still cause impairment of scenic views in Theodore Roosevelt National Park. We believe that it may be reasonable for the EPA to require additional emission reductions at Colstrip and other pollution sources in Montana, and we have several concerns about how EPA is carrying out its responsibility to implement the Regional Haze Rule in Montana and how the EPA proposal delays (by hundreds of years in many cases) achievement of the national goal of natural visibility in our Class I areas by 2064. I shall briefly summarize some of our concerns. • EPA did not provide Federal Land Managers sixty days to review its complete draft proposal prior to publishing its public notice, and we are disappointed that our March 15, 2012 comments submitted to EPA have not been addressed to our satisfaction. Those comments reflect our concerns that EPA has not defined objective criteria for the determinations of Best Available Retrofit Technology and Reasonable Progress that support which emissions controls are cost-effective and what level of visibility improvement is necessary to justify emission control costs. • Due to the very short time available for review since the Federal Register Notice was published on April 20, we are focusing our comments to a limited number of highlighted items. We will comment more fully during the public notice period. • We believe that the cost-effectiveness and visibility modeling analyses conducted by the EPA for the Colstrip Power Plant used baseline emission parameters that are contrary to EPA policy and guidance. In evaluating its results, EPA placed too much emphasis on incremental costs and incremental benefits, while eliminating consideration of cumulative benefits that would be realized in the numerous Class I National Parks, National Wildlife Refuges, and Wilderness Areas impacted by Colstrip. EPA has also improperly and inconsistently applied criteria in its decision-making process that are not supported by EPA policy or actions taken by EPA elsewhere. Our comments address EPA's analysis of the Corette Generating Station, but we also have concerns about the conclusions drawn for several facilities that are located adjacent to our Class I areas. We have recommendations on the presentation and interpretation of the emissions inventory and regional modeling data that are the basis ofthe reasonable progress goals set for Montana Class I areas. EPA must demonstrate how these issues were considered when selecting the Reasonable Progress Goals (RPGs) for the best and worst days for each applicable Class I area. In setting the RPGs, the EPA must also consider the rate of progress needed to reach the national goal of natural visibility conditions by 2064. Under the EPA proposal, no Montana Class I area will meet the 2064 goal. Instead, EPA projects that the national goal will not be met for 135 years at the Cabinet Mountains Wilderness Area, at best, and 437 years at the Medicine Lake Wilderness Area, at worst. Yellowstone is projected to meet the national goal in 161 years, and Glacier in 268 years. (North Dakota has calculated that, under the rate of progress represented by its reasonable progress goals, North Dakota would attain natural visibility conditions in 156 years at Theodore Roosevelt National Park.) Many ofthe same pollutants that impair our visibility also harm the vegetation and water quality in our national parks. From the Western Airborne Contaminants Assessment Project, we have clear evidence that airborne contaminants are being transmitted to our western parks, and some of the sources of those contaminants are referenced here. By improving or restoring clear views of and from within our national park areas, we can also assure better protection of other significant park resources. Together we have considerable challenges in achieving reasonable progress in restoring visibility in this region. We appreciate the opportunity to work with EPA to improve visibility in our Class I areas. .