August 28th’s smoky red midnight moon sure was impressive. With the mountains hidden, we had about 6 to 10 miles of visibility, with Montana Department of Environmental Quality’s (MDEQ) station at Flathead Electric peaked at a Total Suspended Particulate (TSP) level of 59 at 4 p.m. Monday, Aug. 27.
In terms of health, 100 micrograms TSP per cubic meter affects “sensitive groups.” MDEQ’s site (www.deq.mt.gov) also has a chart comparing visibility at various TSP levels: Basically, at 13 miles or more visibility, your air is fine, with TSP under 20. Under 9 miles, the TSP is over the 100 threshold.
Oh, the irony – if such pollution was belching from capitalist smokestacks, citizens would be screaming in outrage, myself included. Wildfire smoke, of course, is “natural” and therefore okey-dokey – even if it isn’t.
But there’s another irony: On Aug. 15, the Environmental Protection Agency (EPA) announced it was implementing an amended “Montana Regional Haze Rule.” The Colstrip and JE Corette power plants, Ash Grove and Holcim cement plants, and several other Montana facilities will have to install “Best Available Retrofit Technology” within five years, with the Colstrip retrofit alone costing at least $89 million.
First question is, why? As EPA states in its rulemaking, the “Regional Haze Rule is not a health-based standard.” EPA is instead protecting “natural visibility” in “pristine” areas.
Second, who let EPA do this? Congress – specifically Clean Air Act (CAA) Section 169, last amended in 1990, mandating the “prevention of any future, and the remedying of any existing, impairment of visibility in mandatory Class I federal areas, which impairment results from manmade air pollution.”
Thus, once public health is addressed by other parts of CAA, EPA enjoys additional power to regulate stationary pollution sources that might affect natural visibility in national parks, refuges and wilderness areas, plus Indian reservations that opted for “Class I airshed” status. There are currently 156 or so of these Class I areas, most in the West. Twelve in Montana are affected by this specific Montana rule and 11 others in adjacent states.
Third, what is EPA trying to do? Implement improvements in visibility measured as a “deciview,” basically the minimum change in visibility perceptible to the human eye. EPA regulations mandate a one-deciview improvement per decade until “natural visibility” is restored. Another 1999 EPA rulemaking set a national goal of “natural visibility” by 2064 unless a state can demonstrate such is “not reasonable.”
Trouble is, visibility isn’t a linear function, but logarithmic: EPA admits this by calling a deciview “analogous to the decibel scale for sound.” That means the second deciview will be 10 times harder than the first. Hmmm … is anyone surprised that Montana passed on designing a state program that EPA could veto?
So, EPA took over. Lo and behold, EPA has now decided natural conditions by 2064 might not be reasonable … for Colstrip, EPA claimed installation of lime injection and a scrubber on Colstrip 2 would improve visibility in Theodore Roosevelt National Park (TRNP) by 0.280 “deciviews” at a cost of $89 million – an invisible result.
Even better, Greens demanded more particulate matter control at Colstrip (cost about $377 million), and EPA refused, responding the result at TRNP, “if all PM were eliminated [basically shutting down Colstrip], is 0.037 deciview.” Again, no see um.
Finally, what will happen in the end? Keep in mind that $89 million is just for part of Colstrip – there are other facilities, including CFAC, subject to BART retrofitting at a potential cost of hundreds of millions. Restart CFAC? Fuggedaboudit.
EPA set itself “reasonable progress goals” that would result in “natural conditions” in 135 years for the Cabinets Wilderness – longer than Montana has been a state. Glacier Park will require 268 years – longer than there has been a United States. The slowest response was Medicine Lake Wilderness, 437 years – only 10 years shy of the first white settlement on the continent (St. Augustine, Florida) in 1565.
Ya know, if EPA folks really expect they’ll still be enforcing “regional haze” 437 years from now – I suggest perhaps 437 days is a more reasonable timeframe.