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)

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                                                   AIR POLLUTION
                                                   Protecting Parks and
                                                   Wilderness From
                                                   Nearby POlution
           United States
GAO        General Accounting OfTice
           Washington, D.C. 20648

           Resources, Community, and
           Economic Development Division

           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.
           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

                                 .      :.

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

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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
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

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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

Figure 2: Impaired Visibility in the Grand

                                             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

                        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-
                        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

                    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,

                       I J. Dexter Peach
                         Assistant Comptroller General

                         Page   8                           GAO/RCED-SO-10   Protecting   Parke and Wilderness


    Page 9   GAO/RCED-90-10   Protecting   Parke and Wilderness

Appendix I                                                                                               12
Background and          Background                                                                       12
                        Objectives,Scope,and Methodology                                                 14
Appendix II                                                                                              16
Few SourcesNear         Non-PSDPermitted Facilities                                                      16
                        Sourcesof Pollutants Entering ClassI Areas                                       23
Class I Areas Are
Subject to PSD Permit
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
Appendix IV                                                                                              32
States Have
Designated No New
Class I Areas
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
                        Figure 11.2:Pollutants Emitted Near Cape Romain                                   18

                        Page 10                          GAO/RCED-90-10   Protecting   Parka and Wilderness

        Figure 11.3:Pollutants Emitted Near Rocky Mountain                                19
            National Park
        Figure 11.4:Pollutants Emitted Near James River Face
        Figure 11.5:Pollutants Emitted Near ShenandoahNational
        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



        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
    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
                        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

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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

                      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
                                         to PSD Permit Requlrementa

Flguro 11.1:Pollutant8 Emitted by PSD-
Permitted and PSD-Exempt Sources


                                               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
                                            ta PSD Permit Ihpiremenm

Flgure 11.2:Pollutants Emltted Near Cape
                                           loo   Porcom   of Pollutmlts











                                                 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












                                              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
                                      to PSD Penoit Itequlrementa

Flgute 11.4;Pollutant6 Emitted Near
James River Face Wlldernebs
                                      100    Rem       of Poll~nm












                                                        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











                                            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

                         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

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
                                 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
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
              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

              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
Development Division,   Carol Ruchala, Evaluator

Washington, DC,

(080397)                Page 35                        GAO/RCRD-M-10   Protecting   Parks and Wilderness


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