oversight

Protecting Parks and Wilderness From Nearby Air Pollution Sources

Published by the Government Accountability Office on 1990-03-09.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                    United   States General Accounting        Office
                    Testimony
GAO


For release          Protecting  Parks and Wilderness
on Delivery          From Nearby Air Pollution    Sources
Expected    at
9:30 a.m. EST
Friday
March 9, 1990




                      Statement     of
                      Richard    L. Hembra, Director
                      Environmental       Protection    Issues
                      Resources,      Community,     and Economic
                      Development      Division


                      Before   the Environment,   Energy,    and
                      Natural    Resources  Subcommittee
                      Committee    on Government  Operations
                      House of Representatives




                       c +qq &.            1-+083b
 GAO/T-RCED-90-43
                                                                       GAOForm160(12/87)
Mr. Chairman               and Members of the                    Subcommittee:


          I appreciate                the     opportunity               to be here           today        to discuss              our
findings         on federal             and state             efforts        to maintain               clean       air       in
national         parks          and wilderness                areas.l          Our work,             as    you     know,

focused         on the          Prevention            of Significant                  Deterioration,               or PSD,
program         authorized             by the         Clean Air            Act Amendments                 of 1977.            Under
the      PSD program,               major          new stationary             sources          of air          pollution,
such as factories                     or power plants,                   must install            strict           emission
controls          if     they       are located              near       any of the            158 national               parks      or
wilderness              areas       designated           by the          amendments.             The states                 issuing
construction               permits           for     these     facilities              must also           forward           the
permit         applications             to the          responsible             federal         land       management
agencies.               These agencies                are supposed             to review             the       applications
and determine               whether           the proposed               facilities            would       adversely
affect         the      parks       or wilderness              areas.


          You asked             us to examine                several        aspects           of the       PSD program:
let      me briefly             summarize            our findings:


          --    First,          the    stationary             air       pollution            sources       that      are
regulated              under     the        PSD program             comprise          a very      small          portion--
about       1 percent--of                   the     sources         near    the       five     parks       and wilderness
areas      we examined.                 The remaining                   99 percent            are exempt            from      PSD


1 See Air              Pollution:          Protectina   Parks and Wilderness                                     From Nearby
Pollution              Sources         (GAO/RCED-90-10,   Feb. 7, 1990).
                                                                    1
permit         requirements,               either        because         they      were grandfathered                      or
were considered                  minor         sources       under       the      act.


          --    Second,          in looking           at how federal                 land     managers            have
carried         out      their      PSD permit              application            review      responsibilities,
we found         that       the     review          process          has not       been well             implemented.


          --    Lastly,          although           additional           park      and wilderness                 areas         have
been recommended                  for      special          protection            from      new air         pollution
sources,         states          have not           designated           any additional                  areas.           States
cited      a variety             of reasons,             including             the belief          that         these      areas
are already              amply      protected            and a concern               that     additional
protection            would       hamper         state       economic            development.


BACKGROUND


          Before         I elaborate             on these            findings,           I would         like     first         to
provide         some background                  on the        PSD program--what                   it     was meant to
do and how it               was meant to work.                        The PSD program                   was authorized,
in part,         to ensure              that     new development                  would      not        cause     any
significant              deterioration               of air          quality       in relatively                 clean       air
areas.          Although          the      Clean      Air      Act established                minimum            air      quality
standards          for      the     entire          country,          the      PSD program              went beyond             this
to maintain              the     quality         of air        that      was already           cleaner            than
required         by the          standards.



                                                                 2
          The act          gave the             highest             level           of protection                    to 158 national
parks          and wilderness                  areas,            designating                them Class                I areas.           These
areas          included         the     national                 parks           of over         6,000      acres,            national
wilderness              areas         and memorial                  parks           of over         5,000            acres,     and the
international                 parks       that        were in existence                           in     1977,         when the
amendments              were enacted.                      All      other           areas        in the United                 States          that
did      not     exceed         national             air         quality            standards            were designated                   Class
II,      but     the      Congress             gave the             states             and Indian           tribes            authority           to
redesignate               any of these                 Class           II        areas      to Class            I.


          The amendments                      set    certain                tests        that     must be             met     before       a
major          new source             of pollution                  could           be built           near          a Class      I area.
To receive              a construction                     permit,               the     owner or operator                     of a
proposed           facility            must demonstrate                           to the         state      regulatory
authority           that        it     will         meet         the        required            emission             standards         and
that      it     will      employ             the best            available               control         technology.                  The
state          agency      is then             required             to          forward         permit      applications                  to the
Environmental                 Protection              Agency                (EPA).          For facilities                    proposed
within          100 kilometers,                     or about                60 miles,            of Class             I areas,            EPA
must notify               the        responsible                 federal            land        management             agency.            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      proposed            facilities                 would           adversely            affect          Class      I areas,
then      the      permits            cannot         be issued.



                                                                            3
FEW SOURCES NEAR CLASS I AREAS
ARE SUBJECT TO PSD PERMIT REOUIREMENTS


          Let me return               now to what we learned                            from       our review.               First
of all,          as I mentioned                 a moment ago,                  PSD permit           requirements              cover
very      few sources               of air       pollution              around         Class       I areas.          We
selected          five      Class        I areas         around          the     country           for     study:           Rocky
Mountain          National           Park and Flat                  Tops Wilderness                  in Colorado,
Shenandoah             National          Park and James River                          Face Wilderness                in
Virginia,          and Cape Romain Wilderness                                  in South        Carolina.
Altogether,              more       than     2,330       stationary              sources           were operating
within         100 kilometers                of these           5    areas       at     the    time        of our review.
Yet only          27 of these               sources--l              percent --were             required             to have PSD
permits.           The remaining                 2,300       or so sources                   did     not     have to obtain
PSD permits,               either        because         they        were       major        sources         that    had been
built       before         1977 and were therefore                             grandfathered               or because           they
emit      less     than         250 tons         a year         of air          pollutants               regulated          under
the      act     (or     in some cases,              100 tons                a year)         and were therefore
considered             minor        sources       under         the      act.


          Collectively,                 these     exempt            sources,           particularly             those        that
were grandfathered,                        account       for        up to 90 percent                     of five     pollutants
emitted          arotind        these       areas.        (See fig.              I.1        in attachment             I.)       These
five --sulfur              dioxide,          nitrogen           oxides,          carbon        monoxide,
particulates,               and ozone-- are pollutants                                for    which        EPA has set
national          standards             under     the     Clean          Air     Act.

                                                                    4
          Around      Shenandoah            National            Park,        for      example,         where          ozone
levels      in 1988 exceeded                    national             standards,          sources            exempt         from PSD
permit      requirements                contributed             95 percent             of the volatile                     organic
compounds          and 83 percent                of the         nitrogen            oxides--two               substances
that      are precursors                to ozone formation--emitted                             near         the      park.
(See fig.          1.2.)         Grandfathered                 sources         accounted             for     most of these
emissions.


          In some cases,                minor     sources             also     contributed                 significant
portions        of total          emissions             around         the     Class         I areas         we examined.
Although        their          share     of total          emissions               was generally                  small,      minor
sources        nevertheless              accounted             for     60 percent             or more of the
particulates             emitted         around         Rocky Mountain                 National             Park and Flat
Tops Wilderness,                 as well         as 64 percent                 of the volatile                     organic
compounds          emitted        around         Flat      Tops.             (See figs.          I.3        and 1.4.)                  This
is not      a situation            unique         to Class             I areas,          I might            add.         In      its
proposed        post-1987              ozone policy,                 EPA reported             that         a significant
portion        of total          emissions          of volatile                organic         compounds              generally
comes from          small        sources.           EPA therefore                   suggested              that     states
consider        lowering          thresholds             for         regulating          new sources                to 25 tons
a year --considerably                    less     than         the     current         PSD threshold.


          Although         we have a fairly                    complete            picture       of the            proportions
of pollutants              emitted        by both          PSD-permitted                 and exempt                facilities,
we know far             less     about      the     extent            to which         these         nearby         sources

                                                                5
account          for      the     air     pollution            that        actually            enters       these       Class         I
areas.           Park Service              information                indicates           that,         under       certain
meteorological                   conditions,               nearby       sources          can account             for        the major
portion          of pollutants                 that        reach      Class      I areas.               In Shenandoah                 and
in Mammoth Cave National                              Park     (Kentucky),               the     Park Service
estimates              that      from     60 to 80 percent                    of sulfur            dioxide          emissions
that      enter          the     parks     come from               local      sources.             More recently,                 the
Park Service                  has been able                to trace         visibility             problems            in Grand
Canyon National                   Park 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
visibility.


          Along          with     pollutants               from     nearby       sources,            some portion                of
pollutants               that     reach        Class        I areas         are carried              through           the
atmosphere               from     long-distance                sources.               The Park Service                  has
estimated              that      high     proportions               of the       airborne            sulfates           within
four      national              parks     in the           eastern         United        States,           including
Shenandoah,               Great         Smoky,        and Mammoth Cave,                   result           from emissions
quite          distant          from the        parks,         in some cases,                   more than             250
kilometers.


          If      nearby         exempt        sources         are causing               air      pollution            problems            in
Class          I areas,          what can be done about                         it?       The Clean             Air     Act
currently              provides          for    the        installation               of retrofit             technology              on

                                                                    6
certain          grandfathered             sources.           This        is the provision--section
169A--under           which        EPA could          require         a power plant                near        the    Grand
Canyon to install                  additional            pollution            controls.            But this
provision           applies        only      in cases         in which              visibility           in Class           I
areas      is     adversely           affected.             We would          like         to point        out,      however,
that      as far       back as 1981,               a National             Academy of Sciences                      study
found      that      visibility            was not          the    only       air      problem        affecting             Class
I areas.          The Academy therefore                      suggested              that     additional            controls
on both          existing         and minor         sources          might          be necessary            to correct
acid      rain      and protect            other      air     quality-related                    values.


          Given      the      consistent           pattern         of exempt               and permitted             sources
among the           five      Class       I areas        we looked            at,      we feel        fairly         confident
that      a similar           proportion           of exempt          and PSD-permitted                     sources             would
be found          elsewhere.              But because             we looked            at only        5 out        of 158
areas,      we obviously               cannot       say this          with          certainty.             More
importantly,               we have no information                     at all           on the      extent          to which
nearby       sources          contribute           to air         pollution             in Class         I areas           other
than      Shenandoah,             Mammoth Cave,              and the          Grand Canyon.


          Considering             what we do know,                 however,            we believe           that      it        would
be worthwhile               for    EPA to examine                 a broader            group      of Class           I areas,
both      to determine             the     extent        to which          exempt           sources        are
contributing               to emissions            and the         extent           to which       air      quality             in
these      areas       is     affected       by these             emissions.                Depending          on the
outcome          of these         studies,         the      Congress          might         want to consider

                                                              7
revising        the      Clean        Air     Act to lower             the      threshold          for      minor      sources
of emissions             or to require                 installation             of additional               controls           on
grandfathered             major        emission           sources.             We believe          that       with     data         on
emissions         maintained                by state       air       quality         offices       and with
currently         available            atmospheric               monitoring           and modeling
capabilities,             such a survey                 could        be completed              relatively            quickly.


PERMIT REVIEW PROCESS IMPROVED
BUT STILL         HAMPERED BY LACK OF DATA


         The second            major         area      covered        in our review               had to do with                the
PSD process            and how effective                    federal          land     managers           have been in
the    review         of PSD permit              applications.                  Put simply,              in its       first
10 years,         the     PSD permit             review          process        was not well                implemented.
EPA regions            did      not     always         forward        all      the    applications             to     federal
land     managers;            and the         land      managers,           with      the      exception          of the
Park Service,             did     not        always       have the           staff      or time          to review            the
applications             they     did        receive.            Most of these              problems,          however,
appear      to have been addressed                          and improvements                   are either            underway
or planned.


Permit      Review           Process         Imorovinq


            Let me return                   to the       issue       of forwarding              PSD permit
applications             to land            managers.            Within        the    small       group       of PSD
permits         issued        near      the     five      Class       I areas          in our review,                we found

                                                                 8
that          federal          land     managers             had received           the     applications                   for        fewer
than          half      (12 out          of 27).             EPA reviews           also     found       no record                 that
land          managers           had been notified                    of about       30 percent               of the permits
involving               construction                within          100 kilometers           of Class               I areas.                EPA
has not been unmindful                              of this          problem,       however,          and has attempted
to correct               it      through           the      use of a checklist               that       it     transmitted
to      its      regions             in May 1989.               Intended          to help      regional              office
reviewers               ensure         that        states       have properly             handled            PSD permit
applications,                    the     checklist            includes          an item      that       has to do with
whether              federal          land      managers            have been notified                when the
application                   is near         a Class         I area.


              Even when they                  received          applications,              federal           land     managers
did      not         always          review        them and provide                comments to the permitting
agencies.                Of the         total         392 permit           applications              that      were forwarded
to land              managers          between           August       1977,       when the      program              began,            and
August           1987,         comments were provided                         on 261,       or two-thirds.                        (See
table          1.1.)           band managers                 told     us that       they     were not               able         to
provide              comments          on the         remaining           applications          because,              in some
cases,           they         did     not     get     them until           30 to 60 days before                       the permits
were issued,                   which        they      felt      was not        enough time            for      a review                of
emission               impacts.             Here too,           EPA is aware of the problem.                                  The
agency           has had a policy                     in effect           since     1979 that           its     regions
notify           land         managers          of applications                as soon as they                 are received.
Recognizing                   that     this        policy       has not        always       been followed,                    EPA



                                                                      9
plans       to hold     training          courses,             beginning          this         fiscal            year,        that
will     emphasize         the    need for             timely        notification.


         Federal       land      managers             also     did      not     respond         with            comments
because       they     did     not,      in all            cases,     have the           staff          to review               permit
applications.              The Fish            and Wildlife               Service,            for     example,               did         not
have any staff             assigned            to permit            application               review            between
November        1982 and the             end of 1984.                   Since     1985,             however,            it    has had
two full-time           staff          assigned.              The Forest          Service             has also               devoted
more staff           to reviewing              applications.


         On the whole,            the      Park Service                 has had a better                        record        in
reviewing          and commenting                   on permit        applications                   than        the     other
agencies,          reviewing           82 percent             of the       applications                    it    received                and
making       recommendations              to the             permitting          authority                 in more than
two-thirds           of the      cases         it     reviewed.            By contrast,                 the       Forest
Service       recommended              changes         to only          17 percent             of the            applications
it     reviewed.        We cannot              say what the               outcome        of these                reviews                was,
however,        because        the      agencies             were not         always          informed            by the
permitting           agencies          about         the     disposition          of their              recommendations.
The Park        Service,         for     example,             was not         aware of how the                        permitting
authority          had handled           about         44 percent             of the          applications                   on which
it     had made recommendations.                           Moreover,          even in those                     cases        in which
land     managers'         recommendations                    were adopted,              it         is not        clear            if
changes       were made because                      of the      land      manager            review            or if        the



                                                               10
permitting           agencies           would      have required                the      changes          independently
of the       land      manager          review.


Insufficient            Data About           Resources              and Effects               of Pollutants


          Despite       EPA efforts              to improve             certain          aspects          of the          permit
review       process,          land      managers         continue            to be hampered                  by a lack               of
sufficient           information            about        the      resources            they       are trying              to
protect        and the         effects          of air      pollution                on those         resources.                 Once
they      receive       a PSD permit               application,               land      managers             are
responsible            for     determining              whether         anticipated               emissions             will         have
an adverse           impact       on the          air    quality-related                   values         of the          Class        I
area.        These values               are the         scenic,         cultural,             biological,
recreational,                and other          resources,             including           visibility,                that       may
be affected            by changes           in air        quality.              If     the     land       manager
demonstrates            to the permitting                   agency           that      the proposed                  facility
will      adversely           affect       these        values,         the     facility           may not be built.


          In order           to evaluate           whether          a proposed             facility           will
adversely           affect       air     quality-related                  values,          land       managers            believe
they      need to know what these                        values         or resources               are,       the       current
condition           of those           resources,         the       effect           of anticipated                pollution
levels       on resources,               and whether              these       effects          are adverse.                     band
managers        believe          that     the      burden         of proof            rests      with        them,        that
they      must demonstrate                to the permitting                    authority              that     the
emissions           from      a proposed           source       will         have an adverse                  impact            on

                                                               11
air      quality-related               values.            However,         they      feel     that      they    do not
now have enough                 information              to adequately             determine          adverse          impacts
in all        cases.


            The Park Service,                alone        among the         land      management          agencies,
has been actively                  gathering             information           for    a number of years.
Nevertheless,                agency       officials            believe      that      the     Park Service               still
lacks        enough         information           to determine,             in all          cases,      whether          a
proposed         facility          will      have an adverse                impact          on park      resources.
This        is particularly               true     in cases           involving         ozone,        where      it         is
difficult            to establish            a source-receptor                    relationship           because             ozone
is not        directly          emitted.           It     has also         been difficult               to determine
precisely            what constitutes                   an adverse         impact--whether               spots         on
leaves        can be considered                   an adverse             impact      or whether          some more
drastic         effect,         like      a change             in an entire          ecosystem,          must be
demonstrated.                 Park Service               officials         acknowledge           that      their
standards            for     information           are highly             rigorous,          based on their
belief        that         any adverse           impact         determination           might        be legally
challenged            and would           consequently               have to be based on very                         certain
information.


            By contrast,           the      Forest        Service         and the       Fish     and Wildlife
Service         have collected               far        less     information          and have had much
smaller         research         programs.               The Fish         and Wildlife           Service,             for
example,         does not have a complete                            inventory        of air         quality-related
values         in any of its              Class         I areas       and has studied                causes        and

                                                                12
effects             of air         pollution          in only              3 of its            21 Class           I areas.
According                 to agency         officials,               only       one class             I area         has been
characterized                    well     enough to provide                       an adequate                basis       for
approving                 or denying           PSD permit               applications,                 and only            in terms             of
visibility.                     The agency           has provided                 only         a    very     small       portion--
$25,000             out      of an estimated                     $10.5       million--of              the     funds           that     its
air    program               staff       believe           is necessary                 to provide            adequate
information.                     According           to an air               program           official,           the        Fish     and
Wildlife                 Service        has given           higher           priority              to other        data        needs--
relating                 to groundwater              contamination,                     for        one--and        refuge            managers
have requested                       funding        for         studies       only       if        they     perceive           air
pollution                 to be a problem.


           Until           recently,           the        Forest          Service        also        devoted         little           effort
to its             air     resource         management               program.                 As of 1987,            none of its
Class         I areas            had been completely                         inventoried,                  and none had been
adequately                 characterized                  for     the      purposes            of reviewing               Class        I
permit             applications.                   backing          this       information,                 the    Forest            Service
found         that         permit        applications                were handled                   inconsistently,                   with
regional                 foresters         sometimes              recommending                 approval           of an
application                  because         of inadequate                   information                  and in other               regions
recommending                    denial       for     the         same      reason.             However,           the     agency            now
has plans                 for    a lo-year           data-gathering                     and research               program            for
which         it         has requested              over         $18 million.




                                                                        13
STATES WAVE DESIGNATED
NO NEW CLASS I AREAS


            On the       question          of designating                   new Class          I areas,             we found
that       although          states       have the         authority               to do so,          they       have not
designated             any new Class              I areas         in addition               to those          established
by the        Clean      Air     Act Amendments.                     This         has not      been for             lack         of
suitable            areas.        In 1979 and 1980,                    the        Forest      Service         and the
Interior            Department,           as directed             by the           act,     reviewed          110 areas                and
recommended             59 for         redesignation,                on the basis              of the         presence                of
air     quality-related                 values.           In addition               to these          59 eligible
areas,        over      260 national              parks         and wilderness                areas      have been
created         since        1977 that        meet the            original            acreage         criteria             for
Class       I areas.


           To find       out why the              states         did    not        act     to redesignate                  any of
these       eligible           areas,      we interviewed                   air     program         officials              in the
14 states            and territories               in which            the        59 recommended              areas         are
located:             Alaska,       Arizona,          California,                  Colorado,         Florida,              Idaho,
Montana,            Nevada,      New Mexico,              Oregon,           South         Dakota,      Utah,         Wyoming,
and the Virgin                 Islands.           We found           a variety             of reasons.               One that
officials            often      cited      was a lack             of resources                or expertise                 to
perform         the     redesignation              studies           required             by the      Clean         Air     Act;           in
some       cases,       states         believed       they        were not            responsible             for
conducting             these     studies.            Although           the        act     does not          state         who
should        conduct          these      studies,         it     requires            an analysis             of the

                                                                14
health,          environmental,                  economic,            social,            and energy              effects        of
redesignation;                   and it      requires             that      public         hearings              be held        before
the    states         can redesignate                     any area.


          In other           cases,         state         officials             claimed          that      redesignation                  had
not    occurred             because         the        state's        air       quality          program          already
adequately            protected             the        recommended              areas:       this        was reported                by
Alaska,          Montana,           Nevada,            and New        Mexico.             Some state              officials           also
believed          that       the        PSD program              was not the              most      effective              way to
deal      with      air      quality         problems.                In Colorado,                for      example,           an air
program          official           said     that         the     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             problems,           and it          has not put
much effort               into      redesignation.                    Arizona            also     believes           that       the       PSD
program          is not          adequate         to solve            air       quality          problems           in the
state's          clean       air        areas,         which      come      from sources                  that      are exempt
from regulation,                    including             grandfathered                  and minor           sources.


          In other           cases,         state         officials             did      not pursue              redesignation
because          of concerns               about        the      effects         on economic               development               in
the    surrounding                 areas.          In Utah,           for       example,          which          has seven areas
that      were recommended                   for        redesignation,                   state      air      program
officials           said         that      the     state         dropped         further          plans          after      they      were
met with           intense          opposition              from      industry            and elected               officials
during       public          hearings            on redesignating                     one of the             areas.



                                                                   15
                In a couple               of states,                 officials              told         us that          they        had not
pursued         redesignation,                 in part,               because              federal            land       managers              had
not     been more aggressive                         in recommending                        redesignation.                         Florida's
air     program       official,               for      example,                  said      that         the     state         had given
redesignation                 a low priority                   because              the     Park Service                  had not
pressed         the   state.              The Alaska                 air         program          official           said          that        in
his     view,     the         federal         land      manager                  would      have to actually                        recommend
redesignation                 and conduct              the      necessary                  studies            before          the     state
would      proceed.              Neither            Interior               nor the          Forest            Service          has taken
an active         role         in redesignation,                           however,              having         chosen         not to
encourage         the         process.


          In our view,                the     absence           of state                 designations                is not
surprising.              Without             some      sort          of federal                  initiative              or
requirement,             it      is difficult                  to     imagine              why states               would          choose           to
create      additional                Class         I areas.                Although              it      could      be used more
broadly,         Class         I designation                   is,         by and large,                   a tool         to protect
federal         lands.           While        those        lands            lie         within          state       borders,              the
responsibility                 for      protecting              the         resources                  of Class          I areas           is
fundamentally                 a federal             one.        It         seems to us that                       only        in
exceptional           cases           would         states           choose             to constrain                development                 in
order      to protect                lands     for      which              they         are not           responsible.                    Unless
the     Congress         were to do so,                    the designation                             of many more Class                       I
areas      appears            unlikely.              But whether                    or not             additional             Class        I
areas      should        be created                 depends,               first,          on whether               the       PSD program
can be changed                 to better             control               air      pollution.

                                                                      16
RECOMMENDEDACTIONS


          All     of     these     findings          suggest          to us several                 actions        that
should          be taken         and that       we have,             in fact,        recommended                 in our
report.           As I mentioned              earlier,            we believe          it      would         be worthwhile
for     EPA, in cooperation                   with        the National            Park Service,                   the     Fish
and Wildlife              Service,         and the         Forest       Service,            to examine             a broader
group       of Class           I areas.         Such a survey               could          verify          the    numbers            of
sources          that     are covered           under        the      PSD program             and,         more
importantly,              would      establish            the     extent        to which            air     quality            in
these       areas        is affected          by nearby              emission        sources.


          Depending            upon the        results           of the     survey,           the         Congress        may
want      to consider             whether         to revise           the   current           thresholds                for     minor
sources          and exemptions             for      major        sources        contained                in the       Clean Air
Act.        Should        the     survey       indicate           a need for          legislative                 change,            the
Congress          may also         want to consider                   making      federal             land       managers
responsible              for     designating             Class       I areas,        rather          than        the     states.


          Finally,         we believe             that     the       Fish   and Wildlife                   Service            needs
to develop              a long-range           plan       for     gathering          the      information
necessary              to support         reviews         of PSD permit              applications.                     While         we
do not          take     issue     with     the       agency's         priorities,              we note           that         the
Fish      and Wildlife             Service         also         has a responsibility                       to protect               air



                                                                17
quality-related         values     in its    class      I areas,      a responsibility             it
cannot     exercise     without     sufficient         information.




         Mr.    Chairman,   this    concludes         my prepared      remarks.          I would        be
pleased        to respond   to any questions.




                                                 18
ATTACHMENT I                                                                ATTACHMENT I



                                          FIGURES AND TABLES

Figure    1.1:               Pollutants   Emitted   by PSD-Permitted   and PSD-Exempted
Sources



                       -.-                     :         i
          loo       -0tPog~

           90

           a0

           70

           00

           so

           40

           30

           20

           10

                0




                                                    19
ATTACHMENT I                                                                                        ATTACHMENT I




Figure   1.2:      Pollutants           Emitted        Near Shenandoah                  National       Park




         Vddle   organic mmpounds   am measured as preatrson   to ozone. one d lhe criteria poMwk




                                                       20
ATTACHMENT I                                                    ATTACHMENT I




Figure   1.3:   Pollutants   Emitted   Near Rocky Mountain   National   Park


         100

          W

          00

          70

          00

          00

          40

          90

          20

          10




                                       21
ATTACHMENT I                                                                                          ATTACHMENT I




Figure   1.4:           Pollutants         Emitted        Near Flat          Tops Wilderness



                m

                a

                70

                00

                W

                40

                30

                20

                10

                    0




                Vdatile   organic compounds are measured as pea~rsws   to OLC+W.one of he criteria pdlutan~




                                                           22
         ATTACHMENT I                                                                    ATTACHMENT I




         Table 1.1:  Federal Land Manager                 PSD Permit      Application       Review,
         August 1977 to August 1987
                                                                               Disposition of federal land manager
                                                                                          recommendations
                              Number of permit applications                  Acceotedl
                                   Reviewed and Recommended                     paitially
                                  commented, as changes, as %           accepted, as % Rejected aa % UnknowEi ;icz
Agency                  Received    % of received       of reviewed        of recomms.        of recommr.
F$sFed Wildlife                40
                                                &h                2%               4%             EL%            2L
Forest                        245              148                25                                              4
Sarwce                                          60%               17%              2%             4%             16%
National Park                 107                                                                  6
Service                                         ii%               8%               ii%            13%            %!!
TOtsI                         392              261               100               46             20             34




                                                        23