Testimony of Kenneth A. Colburn, Director of the Air Resources Division,
New Hampshire Department of Environmental Services
April 23, 1998

Good day. My name is Ken Colburn. I am the air director for the State of New

Hampshire. I appreciate the opportunity to share with this committee a northeastern state's perspective on the problem of regional haze.

Although this problem has not received the same degree of attention as acid rain and ozone pollution over the last several years, the Northeast states have an equally long history of concern about visibility impairment. In fact, in 1979 the eight northeast states adopted a resolution calling for federal action to address the long range transport of visibility impairing pollutants. In part it reads:

Whereas the northeastern states are particularly susceptible to the effects of pollution transport and have been experiencing significant increases in the acidity of precipitation and decreases in visibility;

The resolution calls on EPA to take several actions including, and again I quote:

Promulgate improved ambient air particulate standards which reflect the health and welfare effects of the respirable and corrosive fractions of the particles [and ...Ensure that environmental consequences beyond those that directly affect a national ambient air quality standard are factored into reviews, evaluations and decisions involving fossil fuel consumption and other contributors to secondary air pollutants and acid precipitation.

The full resolution is attached to my written comments.

That resolution, adopted almost 20 years ago recognized that the problems of regional haze, particulate pollution, ozone, and acid deposition are all connected. Moreover, it recognized that the interstate transport of pollutants, especially sulfur dioxide (SO?) from large coal˙2Dfired power plants, lies at the heart of these problems in the Northeast. Unfortunately, two decades later. these sources continue to harm our public health, damage our natural environment, and impair our tourism˙2Dbased economy.

Haze is typically perceived as a Western concern, but it is actually much worse in the Eastern United States. Visibility impairment 2˙2D3 times worse than in the West is pervasive throughout the East. And while we do not have the concentration of Class I areas found in the West, we do have a large number of wilderness areas that are very important both as a recreational resource for our densely populated region and as a source of tourist revenue. All of our wilderness areas, whether they are designated Class I or not, are significantly impacted by haze and will benefit from regional efforts to improve visibility.

In my own state of New Hampshire, for example. tourism is our second largest industry after manufacturing. I am told that New Hampshire's White Mountain National Forest ˙2D˙2D which contains two of New England's six Class I airsheds ˙2D˙2D receives 7 million visitor days per year, an amount which exceeds that of Yellowstone and Yosemite National Parks combined. This is not surprising since about one˙2Dquarter of the U.S. population lives within one day's drive of the White Mountains. The 48 million tourists who visit New Hampshire each year spend over $2.5 billion dollars in our state. Tourism directly supports one out of every 12 jobs in New Hampshire and contributes almost $150 million annually to our State budget.

Surveys of hikers in the White Mountains indicate that people notice haze and are affected by it. They see it as a visible sign of unhealthy air, and they're right: the small particles that scatter light and cause haze are also the small particles that have been shown in numerous epidemiological studies to cause serious human health impacts. The bottom line is that visibility is a key measure used by the public to discern whether or not we are making progress in cleaning up the air.

That is why New Hampshire and other Northeast states generally support EPA's efforts to address the problem of regional haze. We agree that we should strive for steady, perceptible progress in reducing haze. And we agree with EPA that for these efforts to be successful, they must be broadly regional in scope and must include upwind states throughout the eastern part of the country, not just those with designated Class I areas. We also support EPA's use of the "deciview" metric. The Clean Air Act requires that visibility be protected, and the deciview is a visibility metric. Like ozone reduction, visibility improvement is a non˙2Dlinear (exponential) effort. Unlike linear "parts˙2Dper-billion" metrics commonly applied to ozone, however, deciviews are appropriately logarithmic in nature.

We are concerned, however, that EPA may inappropriately impose the same control requirements on Western states as on Eastern states. Even though regional haze is a problem in both the East and the West, it's a very different problem in these two regions of the country. In the West, the causes of haze are complex and vary from one location to another. In the East, the causes of haze are well understood and are much the same from one place to the next. In fact, haze is a simpler problem in the East because it is dominated by the same sources and types of pollution that we are already dealing with from the standpoint of acid rain, fine particles, and ozone. To put it bluntly, we know how to cost˙2Deffectively reduce haze in the East.

The key, as I indicated before, is sulfates. Sulfates formed from sulfur dioxide (SO,) emissions, primarily from coal˙2Dfired power plants, are typically responsible for more than half of the visibility impairment found in our part of the country. We are making an important dent in SO2 emissions under the Acid Rain Program, but it is becoming clear to us in the Northeast that further reductions will be necessary even after the second phase of the program is implemented. The fact is that very significant quantities of SO2 ˙2D˙2D 10 to 15 million tons per year ˙2D˙2D will still be going into the atmosphere at that point, creating continued problems of acid rain, fine particulates. and regional haze throughout the East. The NOx reductions sought in EPA's 22˙2D state Transport SIP call, while essential for lowering ozone concentrations, will do relatively little for visibility in the East because nitrates are a comparatively small fraction of Me particulate matter in the East. In addition. it is not clear that the new PM2.5 standard will help reduce visibility substantially, since it is likely to apply primarily to urban areas, and not to large sulfur emission sources located in cleaner areas upwind. The good news is that SO2 emission reductions are one of the best buys in pollution control to be had right now; further substantial SO2 cuts are not only available, they are quite cost˙2Deffective.

In this context, I want to say a couple of words about EPA's proposed regional haze rule. First, the rule represents a good step toward finally taking haze seriously. The fact is that a national goal of no man˙2Dmade visibility impairment in Class I areas has been on the books for decades, and we have never really done much about it. Nevertheless, the progress targets EPA has proposed are quite modest for the Eastern U.S. If they are followed, it will take longer for many Eastern parts of the country to achieve the Clean Air Act's goal than the United States has existed as a nation! Since we in the East can make greater visibility improvements more quickly by going after further SO2 reductions, reduction requirements in the hazier East should reflect more rapid progress (e.g., 2˙2D3 deciviews per decade) than in the clearer West (e.g., 1 deciview per decade).

Alternatively, EPA could implement a visibility improvement target of 10 percent per decade ˙2D˙2D measured in deciviews ˙2D˙2D over existing visibility conditions. This target would allow for more rapid improvement in the East, where our visibility impairment approaches 30 deciviews on the haziest days, while automatically providing a less aggressive target in the West, where baseline visibility conditions are considerably cleaner.

Second, while the Northeast states are generally supportive of the haze program, they are feeling the combined burden of multiple regulatory obligations very keenly at this time. Fortunately, there are a few things that Congress and EPA can do to help out. First, give states the flexibility to integrate our efforts on regional haze with our efforts on fine particles, acid rain, and ozone since all these programs target many of the same pollutants. Second, keep visibility improvement the measure of SIP success, but don't make SIP cycles unnecessarily rapid or burdensome; a five year cycle should be adequate. Third, give us the added resources and support we'll need to implement an effective regional haze program. Fourth, develop a federal presumptive BART (Best Available Retrofit Technology) program at a national or at least OTAG˙2Dwide level. This would relieve states of the burden of individual BART assessments and would finally begin to address the problem of "grandfathered" old facilities which have been allowed to continue polluting at rates far in excess of technically feasible, cost˙2Deffective emissions control levels. Finally, provide strong federal leadership where appropriate, as in the case of national control measures such as lower˙2Dsulfur fuels.

In closing, I'd like to amplify a bit on the need for federal leadership. EPA's proposed haze rule puts a lot of emphasis on regional solutions. That's appropriate because haze is a regional problem. But the fact is that federal leadership is sometimes needed to make regional solutions work. That's proven to be the case in the OTAG context with respect to the long˙2Drange transport of ozone and ozone precursors. EPA action has been necessary to ensure that the regional NOx reductions we need to deal with ozone throughout the East will be realized ˙2D˙2D and, as we all know ˙2D˙2D that fight isn't over yet. The federal Acid Rain program ˙2D˙2D which is currently doing more to reduce regional haze in the East than any other pollution control program ˙2D˙2D provides another case in point. In fact, this program may provide the best model for future efforts to address regional haze in the East. The fine particulate matter that makes up regional haze is sufficiently stable in the atmosphere to enable it to be transported over much greater distances than ozone and ozone precursors. In such circumstances, a strong federal role to facilitate interstate cooperation ˙2D˙2D and if it becomes necessary, to make culpability assignments ˙2D˙2D is essential in ensuring that each state's sources do their part in reducing visibility impairment.

Thank you again for the opportunity to share these views. I look forward to answering your questions.