Press Release Aug 4, 2020

NPCA, Chesapeake Bay Foundation Oppose EPA Proposal to Devalue Co-Benefits of Air Pollution Rules

Our nation should be moving towards a cleaner, safer future, not gutting commonsense health and safety solutions.

Washington, DC — The Chesapeake Bay Foundation (CBF) and the National Parks Conservation Association (NPCA) have filed comments opposing EPA’s reliance on questionable legal authority to create a dangerously unbalanced approach to analyzing the costs and benefits of air pollution limits.

EPA’s proposal seeks to devalue a rule’s “co-benefits” to human health, the environment, and local economies simply because they are not directly associated with reducing emissions of the pollutant targeted by the rule.

At the same time, EPA would overemphasize the cost to polluters of complying with the rule. This could result in significantly weaker clean air safeguards that would undermine ongoing efforts to restore the Chesapeake Bay and improve air quality in national parks.

“When pollution is reduced for one reason, like to clear hazy skies from Rocky Mountain National Park, there are numerous other benefits that occur, such as cleaner air and water for people to breathe and drink. But the administration’s proposal disregards vital co-benefits like these,” said Stephanie Kodish, Clean Air Program Director for National Parks Conservation Association.

“Addressing air pollution is a win-win for national parks, our climate, and the health of communities, especially those that are already disproportionately affected. Our nation should be moving towards a cleaner, safer future, not gutting commonsense health and safety solutions,” Kodish said.

“Minimizing co-benefits would deliver a devastating one-two punch to the Chesapeake Bay by undercutting efforts to restore the watershed and accelerating the damage climate change is already doing,” said CBF Interim Vice President of Environmental Protection and Restoration Alison Prost.

“We’re running out of time to turn things around for the Bay,” Prost said. “EPA, the six states in the Bay watershed, and the District of Columbia face a 2025 deadline for cutting nitrogen pollution in the Bay. This counterproductive proposal and the weaker air standards it could spawn would take the Bay cleanup in the wrong direction at the wrong time.”

CBF and NPCA collaborated with Harvard Law School’s Emmitt Environmental Law and Policy Clinic to prepare their comments. The Emmett Clinic submitted the comments on behalf of CBF and NPCA. They are attached to this release.

National Parks

Air pollution remains one of the most serious threats facing national parks. In fact, nearly 90 percent of our more than 400 national parks are plagued by haze pollution, which obscures incredible views in our national parks and threatens the health of park visitors, wildlife and neighboring communities.

The Clean Air Act’s Regional Haze Rule is a time-tested, effective program that requires federal and state agencies as well as stakeholders to work together to restore clear skies at Class I areas, like Yosemite, Grand Canyon and Great Smoky Mountains National Parks.

Despite progress in reducing air pollution, the administration’s proposed regulation would greatly undermine this and other efforts to improve the air quality in national parks. Air quality improvements are critical not only to reduce regional haze from parks, but also to reduce climate disrupting pollution and benefit public health, ecosystem, and wildlife protection.

Chesapeake Bay

Air-borne nitrogen contributes nearly one-third of the excess nitrogen in the Chesapeake Bay and the local rivers and streams across six states and the District of Columbia that feed into it. The Chesapeake Clean Water Blueprint for restoring the health of the Bay and its waterways requires a 25 percent reduction in nitrogen pollution across the 64,000 square-mile watershed from 2010 levels by 2025.

To meet that nitrogen-reduction target by the deadline, EPA and the seven jurisdictions involved in the cleanup need the federal government to maintain strong limits on a variety of air pollutants in addition to nitrogen. Not counting the co-benefits of reducing nitrogen deposition into the Bay watershed in these other standards would undermine the partners’ progress towards meeting their nitrogen-reduction commitment by 2025.

Reducing nitrogen pollution in the watershed is also a co-benefit of limiting greenhouse gas emissions. Discounting this co-benefit could result in weaker greenhouse gas controls that would exacerbate the devastating effects of climate change, including sea-level rise, warming water temperatures, extreme weather, and ocean acidification, on the Bay region.

These effects pose a serious threat to the Bay’s multibillion dollar commercial fishing and tourism industries and to the ecosystem’s ability to naturally manage flooding and erosion in low-lying coastal communities, protect water quality, and provide habitat for the marine life and water fowl central to the region’s seafood and tourism sectors.


About The National Parks Conservation Association: Since 1919, the nonpartisan National Parks Conservation Association has been the leading voice in safeguarding our national parks. NPCA and its nearly 1.4 million members and supporters work together to protect and preserve our nation’s most iconic and inspirational places for future generations. For more information, visit

About the Chesapeake Bay Foundation: For more than half a century, the Chesapeake Bay Foundation has led a landmark effort to save the Chesapeake Bay—a national treasure on which the health and wellbeing of nearly 20 million people and 3,600 species of plants and animals depend. Grounded in science and focused on local waterways, we educate tens of thousands of people each year, advocate for better public policy, hold governments and polluters accountable, and perform essential hands-on restoration. For more information, visit

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