_--- -_-... --._._” “““~,11”,11 *“,III”U*l”^,“,--.-.l.. ---.- I*‘(*t,ru;try l!b!fO AIR POLLUTION Protecting Parks and Wilderness From Nearby POlution Sources United States GAO General Accounting OfTice Washington, D.C. 20648 Resources, Community, and Economic Development Division B-226223 February 7,199O The Honorable Mike Synar Chairman, Environment, Energy, and Natural ResourcesSubcommittee Committee on Government Operations House of Representatives Dear Mr. Chairman: Following your request, we reviewed federal and state efforts to main- tain clean air in national parks and wilderness areas.As you know, the Clean Air Act Amendments of 1977 authorized the Prevention of Signifi- cant Deterioration (PSD) program. Among other stipulations, the PSD pro- gram required strict emission controls on major new stationary sources of air pollution that are located near the 158 national parks and wilder- nessareas designatedby the amendmentsas ClassI areas (national parks over 6,000 acres,national wilderness areas and memorial parks over 5,000 acres, and international parks.) Under the PSD program, states issuing construction permits are required to forward permit appli- cations for facilities proposed within 100 kilometers, or about 60 miles, of ClassI areasto the Environmental Protection Agency (EPA). EPA, in turn, must notify the responsible federal land managementagency. These agencies- the National Park Service,the U.S. Fish and Wildlife Service, and the U.S. Forest Service-are then required to review the applications. If they find, and can demonstrate to the state, that the pro- posed facilities would adversely affect Class I areas,then the permits cannot be issued. .I In discussionswith your office, we agreedto examine (1) the extent to which stationary sourceslocated near ClassI areas are regulated under the PSD provisions of the Clean Air Act, (2) how federal land managers are carrying out their responsibilities to protect ClassI areas from sta- tionary source emissions,and (3) why states have added no other fed- eral lands to those that originally qualified under the act for ClassI designation. We selected6 of the 158 ClassI areas for review-Rocky Mountain National Park and Flat Tops Wilderness in Colorado, Shenan- doah National Park and JamesRiver FaceWilderness in Virginia, and Cape Romain Wilderness in South Carolina. (Seeapp. I for a more com- plete discussionof our objectives, scope,and methodology.) Page 1 GAO/RCED-M-10 Protecting Parks and Wilderness ..I . :. .‘. 8 B-226228 Results in Brief The permit requirements of the PSD program cover few stationary sourcesof air pollution near Class I areas-only 1 percent of the sources near the five ClassI areas in our review. Sourcesthat are exempt from those requirements- either becausethey are consideredminor sources or becausethey were in existence before the PSDprogram went into effect-account for up to 90 percent of the pollutants emitted near these five areas. Further, although administrative improvements are either underway or planned, federal land managershave not fully met their responsibility to review PSD permit applications because(1) the EPA region originally receiving the permit applications did not forward them all, (2) the fed- eral land managerslacked sufficient staff and time to review the permit applications received, and (3) the managerslacked sufficient data to determine whether the proposed facility would adversely affect the air quality of the nearby Class I area. Finally, although the Interior Department and the Forest Service recom- mended additional federal lands in 14 states for ClassI designation, the states have not designated any new areas, citing a variety of reasons, including the belief that recommendedareas were already amply pro- tected and concern that ClassI designation would hamper state eco- nomic development. PSD permit requirements cover very few sourcesof air pollution around Few SourcesNear Class I areas. As further described in appendix II, 99 percent of the sta- Class I Areas Are tionary sourcesnear the five Class I areas we reviewed were either Subject to PSD Permit grandfathered in or consideredminor sourcesand therefore did not have to obtain permits under the PSD program. These exempt sources, Requirements particularly those that were grandfathered, also account for up to 90 s percent of five pollutants emitted around these areas.These five-sul- fur dioxide, nitrogen oxides, carbon monoxide, particulates, and ozone- are pollutants for which EPA has set national standards under the Clean Air Act. Around ShenandoahNational Park, for example, where ozonelevels in 1988 exceedednational standards, sourcesexempt from PSD permit requirements contributed 96 percent of the volatile organic compounds and 83 percent of the nitrogen oxides- substancesthat are both precur- sors to ozoneformation-emitted near the park. Grandfathered sources accounted for most of these emissions. Page 2 f3AO/RCED=BO-10 Protecting Parks and Wilderness -_ : _’ ; ,,I,.,’ .I ; ,,,r B-226223 Minor sourcesgenerally contributed only small portions of total pollut- ants emitted around the five ClassI areas we reviewed. However, in somecases,their share was significant: They accountedfor 60 percent or more of the particulates emitted around Rocky Mountain National Park and Flat Tops Wilderness and 64 percent of the volatile organic compoundsemitted around Flat Tops Wilderness. EPA and the Park Ser- vice are already concernedabout the contribution of minor sources, nationwide, to emissionsof volatile organic compounds,and both have proposed that states consider lowering current thresholds for minor sources. Under certain meteorological conditions, nearby sourcescan account for the major portion of pollutants that reach ClassI areas, and in a number of national parks someof these pollutants have already begun to exceed national standards. In Shenandoahand in Mammoth Cave National Park (Kentucky), the Park Service estimates that from 60 to 80 percent of sulfur dioxide emissionsthat enter the parks comefrom local sources. The Park Service has also found that impaired visibility in Grand Can- yon National Park (see figs. 1 and 2) which is causedmostly by high concentrations of sulfates (the oxidized form of sulfur dioxide) in the air, is largely attributable to a nearby power plant that is grandfathered under the PSD program. According to an air program official there, Ari- zona believesthat most of its air quality problems in clean air areas are causedby sourcesexempt from PSD permit requirements; for this reason, the state has not attempted to create additional ClassI areas. Nearby sourcesmay not account for all of the emissionsthat eventually enter ClassI areas, however. Atmospheric modeling and monitoring data indicate that, to someextent, air pollutants are also being transported to someClass I areas over long distances from urban areas. Page 3 GAO/RCED-M-10 Protecting Parks and Wilderness (I,( ,. :, :. .I,/ ., .I B-226223 < Note: The visual range in the Grand Canyon, as measured on February 14, 1987, was 231 kilometers Source: National Park Service. Page 4 GAO/RCEDBO-10 Protecting Parks and Wilderness 5226222 Figure 2: Impaired Visibility in the Grand Canyon Note:The visual range in the Grand Canyon, as measured on February 12, 1987, was 46 kilometers. During a 6-week study period, over 40 percent of the visibility impairment, on average, was attributable to a nearby power plant. On winter days with the worst vrsrbrlrty, the power plant is highly likely to cause 70 percent of the visibility degradation. Source: National Park Service The Clean Air Act currently provides for the installation of retrofit tech- nology on grandfathered sources,but this provision applies only in cases in which certain existing facilities are found to be adversely affecting visibility in ClassI areas. In 1981, however, a National Academy of Sci- encesstudy found that visibility was not the only air problem then affecting ClassI areas and suggestedthat additional controls on both existing and minor sourcesmight be necessaryto correct acid rain and L protect other air quality-related values. Since our review looked at only 5 of the 158 ClassI areas,we cannot say with certainty that there are similar proportions of exempt sourcesnear all Class I areas. Nor do we know the extent to which nearby sources contribute to air pollution in ClassI areas other than Shenandoah,Mam- moth Cave, and the Grand Canyon. However, we believe that it would be worthwhile for EPA to examine a broader group of ClassI areas to determine the extent to which exempt sourcesare contributing to emis- sions and the extent to which air quality in these areas is affected by these emissions.Dependingon the outcome of these studies, it may be necessaryto revise the Clean Air Act to lower the threshold for minor Page 6 GAO/RCED-90-10 Protecthg Parks and Wilderness B-226223 sourcesof emissionsor to require installation of additional controls on grandfathered major emission sources.We believe that with data main- tained by state air quality offices and with currently available atmos- pheric monitoring and modeling capabilities, such a survey could be completed quickly enough to inform current efforts to reauthorize the Clean Air Act. As discussedfurther in appendix III, the PSD permit review processhas Permit Review Process not been well implemented, although improvements are either underway Improved but Still or planned. EPA regions did not forward all the applications that should Hampered by Lack of have been reviewed by federal land managers,and the land managers, with the exception of the Park Service, did not always have the staff or Data time to review the applications they did receive. Most of these problems, however, appear to have been addressed.EPA plans steps to help ensure that its regions forward PSD permit applications to land managerswith sufficient time for review. The Forest Service and the Fish and Wildlife Service have also devoted more staff to reviewing the applications. Land managers’ reviews continue to be hampered, however, because they do not have enough information about the resourcesthey are try- ing to protect-wildlife, vegetation, and visibility, for example-and the effects of air pollution on those resources.Without this information, land managersbelieve they cannot adequately carry out their responsi- bility under the PSD program, which is to determine whether proposed industrial sourceswill have an adverse effect on park resources. The Park Service, alone amongthe land managementagencies,has been actively gathering information for a number of years. However, Park Service officials believe that they still need more information because their standards for information are highly rigorous: According to agency 1, officials, any adverse impact determination might be legally challenged and would consequently have to be basedon very certain information. By contrast, the Forest Service and Fish and Wildlife Service have col- lected far less information and have had much smaller research pro- grams. The Forest Service now has plans, however, for a lo-year data- gathering and research program for which it has requested over $18 million. On the other hand, the Fish and Wildlife Service, which also has considerable data needs,has provided only a very small portion- $26,000 out of an estimated $10.5 million-of the funds that its air pro- Y gram staff believe is necessaryto provide adequate information. According to an air program official, the Fish and Wildlife Service has Page 6 GAO/RCED-90-10 Protecting Parka and Wilderness 5226223 given higher priority to other data needs-relating to groundwater con- tamination, for one-and refuge managershave requested funding for studies only if they perceive air pollution to be a problem. On the question of designating new ClassI areas (discussedin app. IV), States Have we found that although states have the authority to do so, they have not Designated No New designated any new ClassI areas in addition to those established by the Class I Areas Clean Air Act Amendments. Officials in the 14 states and territories with areas recommendedfor ClassI designation by the Forest Service and the Interior Department in 1979 and 1980 offered a variety of rea- sons, among them a belief that the areas were already adequately pro- tected, the lack of resourcesto conduct the studies necessarybefore redesignation, and a concernthat ClassI designation would hamper eco- nomic development in their state. In somestates, officials believed that there are other, more effective means of controlling their air quality problems. Neither the Interior Department nor the Forest Service has taken an active role in redesignation, having chosennot to encourage the process. The absenceof state designations is not surprising. Without somesort of federal initiative or requirement, it is difficult to imagine why states would chooseto create additional Class I areas. Although it could be used more broadly, ClassI designation is, by and large, a tool to protect federal lands. While those lands lie within state borders, the responsibil- ity for protecting the resourcesof ClassI areas is fundamentally a fed- eral one. It seemsto us that only in exceptional caseswould states chooseto constrain development in order to protect lands for which they are not responsible, IJnlessthe Congresswere to do so, the designa- tion of many more Class I areas appears unlikely. However, the desira- bility of creating additional ClassI areas depends,first, on whether the 4 PSD program can be changedto better control air pollution. We recommendthat the Administrator of EPA, in cooperation with the Recommendations National Park Service,the Fish and Wildlife Service, and the Forest Ser- vice, expeditiously survey a group of ClassI areas where nearby emis- sion sourcesare believed or are known to contribute to air quality degradation. The survey should determine the extent to which sources exempt from PSD permit requirements are contributing to air pollution in Class I areas. At the end of h,isreview, the Administrator should report his findings to the CongresslJSince the Congressis currently considering Page 7 GAO/BCED-fbO=10 Protecting Parks and Wilderness IS226223 I reauthorization of the Clean Air Act, this information should be devel- oped as quickly as possible, perhaps within the next 6 months. We also recommendthat the Secretary of the Interior instruct the Direc- tor of the Fish and Wildlife Service to develop a long-range plan for gathering the information necessaryto support reviews of PSD permit applications,rWhile we do not take issue with the agency’spriorities, we note that the Fish and Wildlife Service has a responsibility to protect air quality-related values in its Class I areas, a responsibility it cannot exer- cise without sufficient information. Matters for Depending upon the results of the EPA survey, the Congressmay wish to consider whether the current thresholds for minor sourcesand Consideration by the exemptions for existing major sourcescontained in the Clean Air Act Congress ought to be revised. Should the survey indicate a need for legislative change,the Congressmay also wish to consider revising the processfor designating Class I areas to make federal land managersresponsible, rather than the states. We have discussedthe factual information in this report with EPA, National Park Service, Fish and Wildlife Service, and Forest Service offi- cials and have incorporated their comments where appropriate. How- ever, as you requested, we did not obtain official agency comments on a draft of this report. As arranged with your office, unless you publicly releaseits contents earlier, we plan no further distribution of this report until 30 days from the date of this letter. At that time, copies will be sent to appropriate congressionalcommittees, the Administrator of EPA, the Secretary of the Interior, the Chief of the Forest Service, and other interested parties. This work was performed under the general direction of Richard L. Hembra, Director, Environmental Protection Issues,who may be reached at (202) 275-6111.Other major contributors are listed in appen- dix V. Sincerely yours, J I J. Dexter Peach Assistant Comptroller General Page 8 GAO/RCED-SO-10 Protecting Parke and Wilderness . 4 Page 9 GAO/RCED-90-10 Protecting Parke and Wilderness Conknts Letter Appendix I 12 Background and Background 12 Objectives,Scope,and Methodology 14 Methodology Appendix II 16 Few SourcesNear Non-PSDPermitted Facilities 16 Sourcesof Pollutants Entering ClassI Areas 23 Class I Areas Are Subject to PSD Permit Requirements Appendix III 26 Permit Review Process Permit Applications Not Forwarded 26 Permit A pplications Not Reviewed 26 Improved but Still !nt Information Insufficie--- --.- -~~~- for Land Manager Review 28 Hampered by Lack of Data Appendix IV 32 States Have Designated No New Class I Areas 4 Appendix V 36 Major Contributors to This Report Figures Figure 1: Clear Visibility in the Grand Canyon 4 Figure 2: Impaired Visibility in the Grand Canyon 6 Figure II. 1: Pollutants Emitted by PSD-Permitted and 17 PSD-ExemptSources Figure 11.2:Pollutants Emitted Near Cape Romain 18 Wilderness Page 10 GAO/RCED-90-10 Protecting Parka and Wilderness Contenta Figure 11.3:Pollutants Emitted Near Rocky Mountain 19 National Park Figure 11.4:Pollutants Emitted Near James River Face Wilderness Figure 11.5:Pollutants Emitted Near ShenandoahNational Park Figure 11.6:Pollutants Emitted Near Flat Tops Wilderness 22 Table Table III. 1: Federal Land Manager PSDPermit 26 Application Review, August 1977 to August 1987 4 Abbreviations EPA Environmental Protection Agency GAO General Accounting Office PSD prevention of significant deterioration Page 11 GAO/RCEDM-10 Protecting Parks and Wilderness Appendix I Background and Methodology The Clean Air Act Amendments of 1977 authorized the PSD program to Background ensure, among other things, that new development would not causeany significant deterioration of air quality in relatively clean air areas. Although the act established minimum air quality standards for the entire country, the PSD program goesbeyond this to maintain the quality of air that was already cleaner than required by the standards. The amendmentsgave the highest level of protection to 158 national parks and wilderness areas, designating them Class I areas.These areas, which make up about 1 percent of all U.S. lands, included the national parks over 6,000 acres,national wilderness areas and memorial parks over 5,000 acres, and the international parks that were in existence in 1977, when the amendmentswere enacted.All other areas in the United States that did not exceednational air quality standards were desig- nated Class II. The Congressconferred authority on the states and Indian tribes to redesignate any of these ClassII areas to ClassI and directed federal land managersto determine if any other federal lands, including national monuments and preservesor primitive areas, should be redesignatedClass I. The amendmentsset certain tests that must be met before a major new source of pollution can be built near a ClassI area. First, the owner or operator of the new source must demonstrate that it will not causethe National Ambient Air Quality Standards to be exceeded.These stan- dards are for six “criteria” pollutants: sulfur dioxide, nitrogen oxides, lead, carbon monoxide, particulates, and ozone.In addition, for two of the criteria pollutants-particulates and sulfur dioxide-a new source near a ClassI area may not emit more than a small amount beyond existing levels, allowable increments that are specified in the amend- ments. The amendmentsauthorized EPA to develop allowable increments for nitrogen oxides, carbon monoxide, and ozoneprecursors, but as of 4 September 1989, EPA had done so only for nitrogen oxides. To receive a construction permit under the program, the owner or opera- tor of a proposed facility must demonstrate to the state regulatory agency that it will meet the required emission standards and that it will employ the best available control technology. Under section 165(d) of the Clean Air Act, the state agency is required to send to EPA a copy of the permit application. EPA, in turn, must notify the responsible federal land manager of any permit application it receivesthat may affect a Class I area; EPA guidance requires federal land managersto be notified of a major source permit application within 100 kilometers, or about 60 miles, of a ClassI area. Page 12 GAO/RCED-90-10 Protecting Parks and Wilderness . Appendix I Rackground and Methodology Oncethey receive a PSDpermit application, federal land managers are responsible for determining whether emissionsfrom new sourcesnear Class I areas will have an adverse impact on the air quality-related val- ues of the park or wilderness area. Thesevalues are the scenic,cultural, biological, recreational and other resources,including visibility, that may be affected by changesin air quality. If the federal land manager demonstrates to the state agencythat the proposed facility will adversely affect these values, the facility may not be built, even if the allowable increments would not be exceeded. The land managementagenciesthat administer ClassI areas include two agenciesin the Department of the Interior: the National Park Service, which manages48 Class I areas totalling 14.2 million acres, and the U.S. Fish and Wildlife Service, which manages21 ClassI wilderness areas totalling 2.3 million acres.The U.S. Forest Service, in the Department of Agriculture, manages88 Class I wilderness areastotalling 13 million acres.One additional ClassI area-the Roosevelt-CampobelloInterna- tional Park, which is in the United States and Canada-is administered by the Roosevelt-CampobelloInternational Park Commission. The PSD permit requirements apply to major stationary sourcesof pollu- tion built after the law was enacted and to major modifications of already existing facilities. The act defines as “major” any facility with the capacity to emit at least 260 tons a year of any of the pollutants regulated under the act; for certain types of facilities, such as fossil fuel- fired steam electric power plants, petroleum refineries, and ore smelters, the threshold is 100 tons a year. Facilities emitting less than these amounts are consideredminor sourcesand do not have to obtain PSD permits. Major modifications, which must also meet PSD permit requirements, are b defined as changesto a facility or its methods of operation that increase emissionsby more than certain minimal levels, which vary by pollutant. A modification that would result in an increase of 100 tons or more per year of carbon monoxide, for example, or 40 tons or more per year of nitrogen oxides, would require a PSD permit. However, EPA exempts from this requirement any increasesthat result from fuel switching, routine maintenance and other procedures, changesin ownership, and any increasesthat are offset by decreasesin emissionsthat occurred in the previous 5-year period. Page 13 GAO/RCED-90-10 Protecting Parks and Wilderness Appendix I Background and Methodology Following Chairman Synar’s request and discussionswith his office, we Objectives, Scope,and focused our review on (1) the extent to which stationary sourceslocated Methodology near Class I areas are regulated under the Clean Air Act, (2) how federal land managersare carrying out their responsibilities to protect ClassI areas from stationary sourceemissions,and (3) why states have added no other federal lands to those that originally qualified under the act for ClassI designation. To determine the extent to which stationary sourcesare regulated under the PSD program, we focused on five ClassI areas in three states: Shen- andoah National Park and James River FaceWilderness in Virginia, Cape Romain Wilderness in South Carolina, and Rocky Mountain National Park and Flat Tops Wilderness in Colorado. These include two areas managedby the National Park Service,two managedby the Forest Service, and one managedby the Fish and Wildlife Service. From the Park Service, we obtained information on air quality in its Class I areas, including Mammoth Cave National Park in Kentucky and Grand Canyon National Park in Arizona. From each of the three state air quality agencies,we obtained the most recent annual inventory of stationary source emissions,developed by the states, in part, as a means of determining compliance with national air quality standards. Sincethese inventories do not include data on lead, we collected information on just five of the six criteria pollutants. Using these lists, we identified sourceslocated within 100 kilometers of the Class I areas-the distance established by EPA as requiring federal land manager review- and determined the level of air pollutants annu- ally emitted by these sources.For the two ClassI areas in Virginia, this lOO-kilometer range extends into portions of West Virginia, Maryland, and the District of Columbia, but we did not include any sourcesin these states and the District becausethe relatively small area did not justify 8 the extra effort involved in collecting data from their emissionsinvento- ries. We also obtained from state agency officials a listing of the nearby stationary sourcesthat were exempt from PSD requirements and, in most cases,the reasonsfor these exemptions. We determined the extent to which federal land managers carried out their PSD program responsibilities largely through information compiled by the agenciesat our request. These data included information on the numbers of permit applications they had received for review and their Y disposition. Agencies also supplied information on funding for data col- lection efforts and the need for additional research and information and its costs. Page 14 GAO/RCED-90-10 Protecting Parks and Wilderness ?“. ,: ,,, . : ,’ ., ‘.,i,,“’ AQpe- 1 Background and Methodology To examine EPA'S implementation of its PSD permit responsibilities, we interviewed responsible EPA officials and examined PSD program policies and procedures.We also used the results of EPA'S audits of state air pro- grams for 1986 and 1986-87. In order to addressthe redesignation issue, we conducted a structured telephone interview with officials of the air pollution agenciesin the 14 states and territories in which lands had been identified by federal land managers as suitable for redesignation. These included Alaska, Arizona, California, Colorado, Florida, Idaho, Montana, Nevada, New Mexico, Oregon,South Dakota, Utah, Wyoming, and the Virgin Islands. In addi- tion to asking officials why these areas had never been redesignated,we asked about any plans for redesignating other federal lands that had not been recommendedin the earlier studies. We also interviewed federal land managersto determine whether they had followed up their initial efforts with other attempts to have additional ClassI areas designated. Following generally acceptedgovernment auditing standards, we con- ducted our review between August 1987 and August 1988, with some information updated to May 1989. Page 16 GAO/RCED-80-10 Protecting Parks and Wilderness hpendix II Few SourcesNear ClassI Areas Are Subjectto PSDPermit Requirements Of the 2,332 stationary sourcesoperating within 100 kilometers of the 6 Class I areas in our review,’ only 27-l percent-were required to have permits under the PSD program. The remaining 2,306 sourcesdid not have to obtain PSD permits for the following reasons: . Ninety percent, or 2,106 facilities, were minor sourcesof pollution as defined by the act; . Nine percent, or 200 facilities, were “grandfathered,” that is, they were major sourcesbuilt before 1977 when the amendmentswere enacted. Among these, sevenfacilities had undergone major modifications, but they were exempt from PSD permit requirements becausethey could demonstrate that emission increaseswould be offset by previous decreases. Collectively, non-psnpermitted facilities contribute from 63 to 90 per- Non-PSDPerrnitted cent of five2 of the six criteria pollutants emitted within a lOO-kilometer Facilities radius of each of the five Class I areas. (Seefig. 11.1.) ‘Although four additional sources were listed in Virginia’s inventory, the state’s listing did not con- tain enough information on these sources to allow us to determine their status. ‘These are sulfur dioxide, nitrogen oxides, carbon monoxide, particulates, and volatile organic com- pounds (measured as precursors to the formation of ozone.) Page 16 GAO/RCELMO-10 Protecting Parks and Wilderness . NW-n FewSonrcmNeuclaseIAreasAreSubJeet to PSD Permit Requlrementa Flguro 11.1:Pollutant8 Emitted by PSD- Permitted and PSD-Exempt Sources Pollutants El PSD-Permitted Sources PSD-Exempted Sources Note: Volatile organic compounds are measured as precursors to ozone, one of the criteria pollutants Grandfathered Sources As shown in figures II.2 through 11.6,most of the emissions around all five areas comefrom grandfathered facilities. Their contribution is par- ticularly great to sulfur dioxide emissions,accounting for more than 76 8 percent in all five areas and more than 90 percent of the sulfur dioxide emissions around Cape Romain Wilderness and Rocky Mountain National Park (figs. II.2 and 11.3).Closeto 90 percent of the nitrogen oxide emissionsaround Rocky Mountain National Park also comesfrom existing major sources,as does about 80 percent of the nitrogen oxide emissions around James River FaceWilderness and Shenandoah National Park (figs. II.4 and 11.6). Page 17 GAO/RCEDM-10 Protecting Parks and Wilderness Appendix II FewSo6burc(9NearClaamIArcllleAreSubJect ta PSD Permit Ihpiremenm Flgure 11.2:Pollutants Emltted Near Cape loo Porcom of Pollutmlts 90 00 70 60 60 40 30 20 10 0 I PSDPermitted Sources Minor Sources m Grandfathered Major Sources Note: Volatile organic compounds are measured as precursors to ozone, one of the criteria pollutants. Page 18 GAO/ICED-90.10 Protecting Parks and Wilderness Few 8ources Near Chee I Areas Are Subject to PSD Permit Requimmenta Flaw-e 11.3:Pollutant8 Emltted Near R&ky Mounteln National Park Polwnl ol Pollutmta loo 90 00 70 60 60 40 30 20 10 0 Pollutmta I PSD-Permitted Sourcas Note: Volatile organic compounds are measured as precursors to ozone, one of the criteria pollutants. Page 19 GAO/RCED-9040 Protecting Parka and Wilderness Appe- D Few-NearClawIArwwAreSabject to PSD Penoit Itequlrementa Flgute 11.4;Pollutant6 Emitted Near James River Face Wlldernebs 100 Rem of Poll~nm 80 80 70 80 80 40 30 20 10 0 Pollutants I PSDPenitted Sources Minor Sources I Grandfathered Major Sources Note: Volatile organic compounds are measured as precursors to ozone, one of the criteria pollutants Page 20 GAO/RCED-90-10 Protecting Parks and Wilderness Few fhrcea Near Class I Areas Are Subject to PSD Permit Requirementa Flgun 11.5:Pollutantcl Emlttod Near Shenandoah Natlonsl Park loo Pomml of Pollut8nts 80 80 70 80 80 40 30 20 10 0 I PSPPermitted Sources Minor Sources I Grandfathered Major Sources Note: Volatile organic compounds are measured as precursors to ozone, one of the criteria pollutants Page 21 GAO/RCED-90-10 Protectiug Parks and Wilderness Appendix II Few Sources Near Class I Areas Are Subject to PSD Permit Requirements Flguro 11.8:Pollutant8 Emltted Near Flat Top8 Wlldernem8 100 Pwwnl of Potlutanta I PSD-Permitted Sources Mlnor Sources Grandfathered Major Sources Note: Volatile organic compounds are measured as precursors to ozone, one of the criteria pollutants. Around ShenandoahNational Park, grandfathered sourcesare contrib- uting to what has becomea significant air pollution problem. These sourcescontribute 86 percent of the volatile organic compounds and 79 a percent of the nitrogen oxides emitted near the park (fig. 11.6).Both of these substancesare consideredozoneprecursors, reacting together in the presenceof heat and sunlight to form ozone.Sincethe Park Service began monitoring ozonein Shenandoahin 1980, concentrations have approached the national standard, and in 1988, the standard was exceeded.Shenandoah’sozoneproblem is not unique, however: Since 1982, ozonelevels at sevenother ClassI parks and monuments-Aca- dia, Mammoth Cave, Joshua Tree, Yosemite, Pinnacles,Guadalupe Mountains, and Sequoia-have also exceededthe national standard. Page 22 GAO/RCED-90-10 Protecting Parks and Wilderness Appendix n Few Sources Near Class I Areas Are Subject to PSD Permit Requirements Minor Sources Minor sources,while large in number, generally contribute relatively small quantities of pollutants to the total. However, they account for nearly 30 percent of the particulates emitted around all five Class I areas, and in Rocky Mountain National Park and Flat Tops Wilderness, they account for over 60 percent. Minor sourcesaround Flat Tops also account for 64 percent of the volatile organic compoundsemitted by sta- tionary sourceswithin 100 kilometers. Both EPA and Park Service officials have already expressedsomecon- cerns about the contribution, nationwide, of small sourcesto total emis- sions of volatile organic compounds.In its proposed post-1987 ozone policy, EPA noted that a significant portion of total emissionsof volatile organic compounds generally comesfrom small sources.The agency sug- gested that as part of an overall ozonecontrol strategy, states might want to consider lowering thresholds for regulating new sourcesto 25 tons of volatile organic compoundsa year. EPA acknowledged, however, that even this level might be too high, citing a study that had shown that modifications and new sourcesemitting less than 5 tons a year com- pose 55 percent of total new volatile organic compound emissions.In commenting on the proposed policy, the Park Service expressedsimilar concernsabout small sourcesand supported lowering the threshold to 25 tons a year. These exempt sourcescould account for most of the pollutants emitted Sourcesof Pollutants near Class I areas. The Park Service has found that, under certain mete- Entering Class I Areas orological conditions, nearby sourcesare the primary source of air pol- lutants in Class I areas.According to an air program official, the Park Service estimates that local sourcesmay account for 60 percent of the sulfur dioxide that enters ShenandoahNational Park. Similarly, the Park Service has found that local sourcescan contribute about 70 to 80 6 percent of the sulfur dioxide in Mammoth Cave National Park in Ken- tucky, according to the air program official. In Grand Canyon National Park, the Park Service has traced visibility problems to a nearby coal- burning power plant. The agency has estimated that, at times, the power plant has contributed from 60 to 78 percent of the sulfur in the park, which, in the form of sulfates, is largely responsible for impaired visibil- ity. On winter days with the worst visibility, the power plant is highly likely to cause70 percent of the visibility degradation, according to the Park Service. Becausethe plant was built before 1977, it was not permit- ted under the PSD program, and it doesnot have any sulfur dioxide controls. Page 23 GAO/RCED-90-10 Protecting Parks and Wilderness Appendix II Few Sources Near Class I Areaa Are Subject to PSD Permit Requirements Under section 169A of the Clean Air Act, if EPA or a state regulatory authority finds that certain grandfathered sourcesare adversely affect- ing visibility in Class I areas,the agency can require the source to install retrofit technology to correct the problem. This retrofit provision applies only to casesof impaired visibility, however, and doesnot extend to other air pollution problems. Nevertheless,in a 1981 report on the implementation of the PSDprovisions, the National Academy of Sci- encesfound that impaired visibility was not then the only air pollution problem affecting ClassI areas and warned that controlling only new sourceswould not deal adequately, in this century, with acid rain or the protection of other air quality-related values. The Academy study also concluded that minor sourcescould, cumulatively, causesignificant deterioration of air quality and suggestedthat the administrative con- venience and other factors that support the distinction between major and minor sourcesshould not be allowed to subvert the basic intent of PSD, which is to regulate emissionscausing significant deterioration, regardless of the type or source. Information developed by the Park Service over the last several years indicates that, in addition to pollutants from nearby sources,somepor- tion of certain types of pollutants that reach Class I areas are carried through the atmosphere from long-distance sources.For example, using data collected during the summer of 1978, the Park Service has esti- mated that high proportions of the airborne sulfates within four national parks in the eastern United States are the result of emissions quite distant from the parks. At ShenandoahNational Park, the Park Service estimates that about 75 percent of airborne sulfates result from emissionsgenerated more than 100 kilometers from the park. Similarly, it estimates that approximately 90 percent of the sulfate concentrations in Great Smoky National Park is attributable to sourcesmore than 250 kilometers from the park, and that at Mammoth Cave National Park, 40 a to 60 percent of sulfates comefrom sourcesmore than 150 kilometers away. Page 24 GAO/RCRD-90-10 Protecting Parks and Wilderness Appendix III Permit Review ProcessImproved but Still Hamperedby Lack of Data On the whole, federal land managershave not fully carried out their responsibility to review PSD permit applications, either because(1) EPA did not forward all applications to them, (2) they did not have the staff or time to review the permit applications when they were forwarded, or (3) they lacked sufficient information to determine whether the pro- posed facility would adversely affect the resources,or air quality- related values, of their ClassI areas.Although many of these problems have been or are likely to be resolved, land managementagencies-par- ticularly the Fish and Wildlife Service- still do not have adequate infor- mation for determining the effects of proposed emission sourceson the natural resourcesof Class I areas Permit Applications Since August 1977, when the PSD program began, 27 PSD permits have been issued in the 5 ClassI areas we reviewed. Of these, federal land Not Forwarded managers had received the applications for 12. The remaining 15 had not been forwarded to them by the EPA regions. Although EPA established a policy in 1979 to notify land managersof proposed facilities within 100 kilometers of a ClassI area, the EPA regional PSD coordinators we spoke with said that at the time many of the permits were issued, in the early days of the program, EPA'S policy was not well known. In addition, these staff decided, on the basis of the data submitted with the applica- tion, that the projected emissionswould not reach the ClassI area. One case,however, involved a facility that would be located 10 to 15 miles from Rocky Mountain National Park. EPA'S regional PSD coordinator said that neglecting to send the application to the Park Service had simply been an oversight. EPA'S reviews have yielded similar findings. In its fiscal year 1985 and 1986-87 audits of the air program, EPA could find no record that land managers had been notified of approximately 30 percent of the permits involving construction within 100 kilometers of a Class I area. EPA'S report did not explain why these omissionsmight have occurred. To addressthis and other problems, EPA'S Assistant Administrator for air programs informed the EPA regions that they were to make sure that state and local regulatory agenciesfollow certain notification proce- dures, including notifying the regions of all PSD permit applications they received for major sources.To aid this effort, EPA devised a checklist for regional reviewers to use to help ensure that the state has properly han- dled the application. One of the items included in the checklist has to do Page 25 GAO/RCED-90-10 Protecting Parks and Wilderness Appendix III Permit Review Process Improved but Still Hampered by Lack of Data with whether federal land managershave been notified when the appli- cation is near a ClassI area. EPA transmitted the checklist to the regions in May 1989. Even when they have received applications for review, federal land Permit Applications managershave not always reviewed them and provided commentsto Not Reviewed the permitting agencies.From August 1977 to August 1987, nationwide, 392 permit applications had been forwarded to federal land managers. (Seetable 111.1.)Of these, commentswere provided on 261, or two- thirds. Land managers did not provide commentson the remaining 131 permit applications, for a couple of reasons.For one thing, federal land managers did not receive a number of the permit applications until 30 to 60 days before they were issued, at the sametime they were made avail- able for public comment. According to the Park Service, about one-quar- ter of the applications it received arrived at this time; about half the applications sent to the Fish and Wildlife Service also arrived at this point. (The Forest Service could not furnish us with similar informa- tion.) Federal land managersbelieve this is not enough time for them to complete a review of emission impacts. Table 111.1:Federal Land Manager PSD Permit Application Review, August 1977 to August 1987 Disposition of federal land manager recommendations Number of permit applications Accepted/ Reviewed and Recommended partially commented, as changes, as % accepted, as % Rejected as % Unknown, as % Agency Received % of received __I__.~- of reviewed of recomms. of recomms. of recs. l?s?s$ Wildlife 40 E% 2% 2Z% 5A% 27% Forest 245 148 25 4 Service 60% 17% 2% 2Z% 16% l Nat&al Park 107 26 8 Service Tota, ..- ..-.-..-..----...- ~--- E% ki% 43% 13% E% 392 261 100 46 20 34 67% 30% 46% 20% 34% EPA’S 1979 notification policy required that EPA regions notify federal land managers as soon as an application is received. Recognizing,how- ever, that its notification policy has not always been followed, EPA has taken steps to addressthis problem. According to the EPA official in charge of new source review, the agency plans to hold training courses, beginning in fiscal year 1990, for regional staff that will emphasizethe need for timely notification. Page 26 GAO/RCED-90-10 Protecting Parks and Wilderness . . Appendix III Permit Review Procese Improwxl but &Ill Hampered by Lack of Data To help deal with the problem of insufficient time, the Forest Service plans to institute a screeningprocedure that will help its managersuse their time more efficiently. By using estimates of expected pollutant concentrations, Forest Service managerscould screenout those applica- tions that are not likely to causeadverse impacts and concentrate on obtaining additional, more detailed information from the other projects. Published as a proposal in April 1989, the screeningprocedure is expected to be developed over the next year. Federal land managers also did not respond with comments because they did not have the staff to review permit applications. The Fish and Wildlife Service, for example, did not have any staff assignedto permit application review between November 1982 and the end of 1984, according to a member of the agency’s air program staff. Since 1986, however, the agency has had two full-time staff members assignedto review PSD permit applications, among other things, working under an interagency agreement with the National Park Service’s air program office and receiving technical support from that office. The Forest Ser- vice has also had problems with insufficient staff. However, it requested funds to enlarge its air program staff in fiscal year 1988 to 12 full-time equivalent positions, and it planned to increasethe number to 21 in fis- cal year 1989 and to 30 in fiscal year 1990. As shown in table III. 1, the Park Service has had a somewhat better record in reviewing and commenting on permit applications than the other agencies.It reviewed 82 percent of the applications it received and made recommendationsto the permitting authority in 69 percent of the casesit reviewed, recommending, among other things, that applicants install better control technology. For example, in its review of an appli- cation to construct and operate an energy/resource recovery facility b near ShenandoahNational Park, the Park Service recommendedthat the state agency not issue the permit as drafted unless the applicant employed a dry scrubber/baghousesystem to reduce emissions.In another case,involving a permit application to modify a Department of Energy fuel-processing restoration facility near Craters of the Moon National Monument in Idaho, the Park Service recommendedthat nitro- gen oxide controls be installed to mitigate and perhaps eliminate any visibility impacts. The Fish and Wildlife Service and Forest Service each reviewed about 60 percent of the applications. While the Fish and Wildlife Service rec- ommendedchangesto 66 percent of the applications, the Forest Service recommendedchangesto only 17 percent of the applications. We were Page 27 GAO/RCED-90-10 Protmting Parke and Wilderness Appendix III Pemdt Review Process Improved but Still Hampered by Lack of Data not always able to evaluate the outcome of these reviews, however, in part becauseagencieswere not always informed by the permitting agen- cies about the disposition of their recommendations.The Park Service, for example, was not aware of how the permitting authority had han- dled about 44 percent of the applications on which it had made recom- mendations. In addition, even in those caseswhere land managers’ recommendationswere adopted, it is not clear whether changeswere made becauseof the land manager review or whether the permitting agencieswould have required the changesindependently of the land manager review. In order to evaluate whether a proposed facility will adversely affect air Insufficient quality-related values in a ClassI area, land managersbelieve they need Information for Land to know what these values are-that is, the vegetation, wildlife and Manager Review other natural resourcesof the area-the current condition of those val- ues (or resources),the effect of anticipated pollution levels on those resources,and whether these effects are adverse.According to land managers,they have the burden of persuading the permitting authority that the emissions from a proposed source will have an adverse impact on air quality-related values. Therefore, assessmentsbasedon incom- plete data or inadequate tools are likely to compromisethe managers’ ability to be persuasive. However, agency officials feel that they do not now have enough information to adequately determine adverse impacts in all cases. Fish and Wildlife Service The Fish and Wildlife Service, for example, doesnot have a complete inventory of air quality-related values in any of its ClassI areas, and has studied causesand effects of air pollution in only 3 of its 21 Class I b areas. According to the Fish and Wildlife Service,only one Class I area has been characterized (i.e., inventoried and assessed)well enough to provide an adequate basis for approving or denying FSD permit applica- tions, and only in terms of visibility. To obtain complete information about all its Class I areas,the Fish and Wildlife Service estimates that it would require nearly $1.6 million over 5 to 10 years for inventories of air quality-related values and about $8.9 million more, and 8 to 10 years, to adequately assessambient air qual- ity, visibility and biological conditions. By contrast, in the 10 years fol- lowing the Clean Air Act Amendments (to August 1987), the Fish and Wildlife Service spent a total of $145,818 on related data-gathering Page 28 GAO/RCEDBO-10 Protecting Parks and Wilderness Appendix III Permit Review Process Improved but Still Hampered by Lack of Data efforts. Nevertheless,the agency did not request any funds for inven- tory purposes for fiscal year 1988 and requested and received only $26,000 in fiscal year 1989. Also in fiscal year 1988, the air program staff requested $64,000 for air pollution cause-and-effectstudies in 2 of the agency’s 21 ClassI areas,but the studies were not funded by the Fish and Wildlife Service. According to the Fish and Wildlife Service official in charge of the day- to-day operations of the agency’s air quality program and one of his staff members, air quality issueshave been a low priority within the Fish and Wildlife Service, falling below groundwater contamination and other concerns.They explained that funds for studies were made availa- ble only when refuge managerswere concernedabout air pollution and requested funds through the normal regional budget process,There has been no Service-wide budget initiative to support the air quality pro- gram, they added, especially for ambient and biological effects monitor- ing, in order to fulfill PSD responsibilities. National Park Service The Park Service, by contrast, has spent considerably more to monitor and evaluate air pollution effects and believes it has at least partially inventoried or assessedall its ClassI areas for the purposes of F%Dper- mit application reviews. At th.etime of a permit review, the agency says, the Park Service reviews available information and may supplement it with additional studies as necessary.Between 1977 and 1987, the Park Service spent about $4.6 million on inventory and monitoring activities, focusing on visibility and vegetation resourcesas indicators of air qual- ity-related values. The agency also spent about $11.8 million on cause- and-effect studies during this sameperiod. According to officials of the Park Service’sAir Quality Division, the agency still lacks sufficient information to determine, in all cases, whether a proposed facility will have an adverse impact on park resources.This is particularly true in casesinvolving ozone,where it is difficult to establish a source-receptorrelationship becauseozoneis not directly emitted. It is also difficult in the caseof ozoneto determine pre- cisely what constitutes an adverse impact, that is, whether spots on leaves can be considered an adverse effect, or whether somemore dras- tic effect, like a changein an entire ecosystem,must be demonstrated. Park Service officials acknowledged that they have set highly rigorous standards for information, anticipating that any adverse impact deter- mination might be legally challenged and would therefore have to be basedon very certain information. Page 29 GAO/RCED-90-10 Protecting Parka and Wilderness Appendix ITI Permit Review Procew~ Improved but Still Hampered by Lack of Data Although Park Service officials believe the agency’sair quality data are good, they believe more information is neededon the resourcesof Class I areas, along with additional research on the biological effects of air pol- lution. The Park Service estimates it will need about $11 million over the next 10 years for inventory and monitoring activities and another $16 million for cause-and-effectstudies, again focusing just on visibility and vegetation. For an adequate inventory of additional air quality-related values, including visibility and vegetation, the Park Service estimates it would need a total of $14.4 million over a c-year period, or $300,000 for each of the 48 ClassI areas. Park Service officials believe that the current level of staff and resourcesis more or less adequate and will ultimately yield the neces- sary information if funding levels are maintained. According to its fiscal year 1988 action program, the Park Service plans to develop inventory and monitoring programs for at least 20 parks a year over the next 5 years, beginning in fiscal year 1989. Officials said that the Park Service also plans to continue its biological effects research program at least at current funding levels, although the agency is currently in the processof reviewing its program and anticipates someinternal redirection. Forest Service Although it did relatively little in the past, the Forest Service has begun to expand its air resource managementprogram. Between 1977 and 1987, the agency spent $1.5 million on efforts to inventory air quality- related values, with no ClassI area completely inventoried. Moreover, according to the Forest Service’swatershed and air managementdirec- tor, none of the ClassI areas had been adequately characterized for the purposes of reviewing Class I permit applications. During this same lo- year period, the Forest Service spent closeto $10 million on research related to effects of air pollution, research it characterizes as applicable a to numerous ClassI areas. In 1986, however, the Forest Service beganto reevaluate its air resourcesprogram and its compliance with the Clean Air Act. According to its August 1987 draft report, the natural resourcesat risk from potential development around ClassI areas were unknown. The Forest Service noted that becauseof this lack of information, permit applica- tions were handled inconsistently, with regional foresters sometimes recommending approval of an application becauseof inadequate infor- mation, and in other regions, recommending denial for the samereason, Page 30 GAO/RCED-90-10 Protecting Parka and Wilderness . Appendix III Permit Review Process Improved but Stffl Hampered by Lack of Data Following the evaluation, the Chief of the Forest Service decided to strengthen the agency’sprogram by committing additional funds and staff to inventory and monitor the condition of air quality-related values in Class I areas.The Forest Service’sgoal is to inventory all ClassI areas by the year 2000 and to monitor the 60 or so areas that are threatened. The Forest Service therefore added funds to its fiscal year 1988 and fis- cal year 1989 air program budgets and requested $3.6 million for fiscal year 1990-more than twice the amount it spent on inventory activities in the entire preceding decade.The Forest Service plans to seek similar funding levels for inventory and monitoring purposes for each of the next 10 years. In addition, the Forest Service has undertaken a long- range research program on atmospheric effects on forest ecosystems. Although not aimed specifically at ClassI areas,the Forest Service believes that research results are well suited for application to these areas. For fiscal year 1990, the Forest Service requested $14.7 million for the program and believes that the same amount (in constant dollars) would be required over each of the next 10 to 20 years to complete the studies necessaryto adequately protect all ClassI areas. Page 31 GAO/RCED-90-10 Protecting Parks and Wilderness ’ , Appendix IV StatesHave DesignaM No New ClassI Areas ” In keeping with the states’ overall responsibility for the PSD program, section 164 of the Clean Air Act authorized states and Indian tribes to designate any areas they deem appropriate as ClassI areas. In addition, the act directed federal land managersto review national monuments, primitive areas, and national preserves,and recommendto the states and the Congressany areas appropriate for redesignation from ClassII to ClassI becauseof important air quality-related values. In 1979 and 1980, land managersrecommended59 areas to be redesignated.In addi- tion, over 260 new national parks and wilderness areas have been cre- ated that meet the original acreagecriteria for ClassI areas. Nevertheless,the states have not designated any additional ClassI areas. Following the act, federal land managersevaluated 110 areas alto- gether: 82 national monuments, 2 national preserves,and 11 primitive areas administered by the Interior Department, and 15 Forest Service primitive areas The Forest Service,in 1979, recommendedthat all 15 of its areas be redesignated as ClassI. In 1980, the Secretary of the Interior published a final list of 44 areas recommendedfor redesignation, based solely on the presenceof air quality-related values. However, none of the 14 states and territories in which these 59 areas are located- Alaska, Arizona, California, Colorado, Florida, Idaho, Montana, Nevada, New Mexico, Oregon,South Dakota, Utah, Wyoming, and the Virgin Islands-ultimately redesignated any of these areas, for a variety of reasons. According to officials of the air quality agenciesin 10 of these states,’ the states often did not pursue redesignation becausethey lacked the resourcesor expertise to perform the redesignation studies required by the Clean Air Act, or becausethey did not believe they were responsible for conducting them. Although the act doesnot state who should con- & duct these studies, it requires an analysis of the health, environmental, economic,social and energy effects of redesignation, and it requires that public hearings be held before the states can redesignate any area.2 In Florida, which has three areas recommendedby the National Park Service, an official of the state air quality office said that the state ‘Air quality officials in Idaho and the Virgin Islands were not familiar with redesignation recommen- dations and could not respond to our questions, In South Dakota, the air program administrator had been unaware that the portion of Badlands National Monument recommended for Class I designation was not already a Class I area, along with the rest of the monument. 21na June 1983 opinion, the U.S. Court of Appeals for the Ninth Circuit stated its view that the act required the state of California to conduct these studies. Page 32 GAO/RCED-90-10 Protecting Parks and Wilderness . Appendix IV States Have Designated No New Claw I Areaa believes that it is up to the Park Service to conduct the environmental studies since the state has neither the responsibility nor the ability. Offi- cials in both Wyoming and Montana reported that their states require by law that the party seeking redesignation perform the necessarystudies. In 1981, a citizens coalition petitioned the state of Wyoming to redesig- nate the Cloud Peak Wilderness, but the state denied the petition, according to its air program administrator, in part becausethe citizens had not conducted the required studies. In other cases,state officials claimed that redesignation had not occurred becausethe state’s air quality program already adequately protected the recommendedareas;this was reported by Alaska, Mon- tana, Nevada and New Mexico. Somestate officials also believed that the PSD program was not the most effective way to deal with air quality problems. In California, for example, the state Air ResourcesBoard began in 1980 to conduct redesignation studies for those areas recom- mended by federal land managers as well as for other Class II areas in the state (such as areas that had been designatedwilderness after the 1977 amendmentsto the Clean Air Act.) However, according to a staff member of the Board, the state’s ozoneproblem shifted priorities and resourcesaway from the redesignation studies. This staff member said that the state currently believes that solving urban ozoneproblems would also solve air pollution problems in remote areas that were caused by atmospheric transport of pollutants. According to a state air program official, Arizona also did not pursue redesignation for the nine areas in the state that were recommended becausethe state believes that the PSD program is not adequate to solve air quality problems in the state’s clean air areas, which come from sourcesthat are exempt from regulation, including grandfathered and minor sources.Similarly, a Colorado air program official said that the a state believes that the PSD program is not adequate to deal with regional haze and acid deposition, two of the state’s biggest air pollution prob- lems, and it has therefore not put much effort into redesignation. He said the state believes that an EPA standard for fine particulates is a less complex and less controversial tool for dealing with visibility problems than is redesignation. For a number of areas recommendedby federal land managers,state officials did not pursue redesignation becauseof concernsabout the effects on economicdevelopment in the surrounding areas. In Utah, for example, which has seven areas that were recommendedfor redesigna- tion, state air program officials said that the state dropped further plans Page 33 GAO/RCED-90-10 Protecting Parks and Wilderness Appendix IV States Have Designated No New Class I Areas after they were met with intense opposition from industry and elected officials during public hearings on redesignating one of the areas. In the caseof Death Valley National Monument, which is located in both Cali- fornia and Nevada, the state of California undertook a redesignation study, but a Nevada air program official said that Nevada was opposed to redesignation becauseit claimed that it would causeeconomichard- ship to nearby industries if they were required to reduce emissions.Sim- ilarly, according to an air program official, the state of Colorado dropped its plans to redesignate Dinosaur National Monument, which lies in both Colorado and Utah, after the state of Utah objected. In a couple of states, officials told us that they had not pursued redesig- nation, in part, becausefederal land managershad not been more aggressivein recommending redesignation, Florida’s air program offi- cial, for example, said that the state had given redesignation a low prior- ity becausethe Park Service had not pressedthe state. The Alaska air program official we interviewed said that he regarded Interior’s recom- mendation as a finding of suitability rather than a recommendation for the state to act. He said that in his view, the federal land manager would have to actually recommendredesignation and conduct the necessary studies before the state would proceed. Neither Interior nor the Forest Service, however, have taken an active role in redesignation. The Forest Service’spolicy is to provide assistanceand to consult with states con- sidering redesignation but not to initiate redesignation. While Interior doesnot have a formal policy statement on redesignation, it has, in the past, discouraged Park Service officials from pursuing redesignation for wilderness areas in Alaska. For the samereasonsthat kept them from redesignating areas to ClassI status in the past, almost all of these states have no plans to pursue redesignation in the future. However, the state of Oregonbegan work in a 1987 to redesignate 29 ClassII areas in the state, most of which became wilderness areas after 1977. The state believes that a Class I designation would better protect these areas from possible new industrial sources and also from Forest Service burning practices. Formal action is not expected before the Spring of 1991, Page 34 GAO/RCEDM-10 Protecting Parks and Wilderness Appendix V Major Contributors to This Report Peter F. Guerrero, Associate Director Resources, William McGee,Assistant Director Community, and Bernice Steinhardt, Assignment Manager Douglas Isabelle, Evaluator-In-Charge Economic Development Division, Carol Ruchala, Evaluator Washington, DC, (080397) Page 35 GAO/RCRD-M-10 Protecting Parks and Wilderness b a :’ .““I” ..__.I..” “I_.-. .--......”. 1‘ttitt4 slilltv4 C;c~tlt~r;ki ,i\c~wt~r~t
Air Pollution: Protecting Parks and Wilderness From Nearby Pollution Sources
Published by the Government Accountability Office on 1990-02-07.
Below is a raw (and likely hideous) rendition of the original report. (PDF)