14 



Nevertheless, while federal land managers are able to 

 negotiate reduced emission levels for some proposed PSD permits, 

 state permitting authorities have approved some permits despite 

 the Park Service's recommendations that the permits not be 

 approved unless increases in emissions were offset by reductions 

 from other sources. For example, in 1990 the Park Service 

 recommended to Virginia that the state not issue permits for new 

 pollution sources near the Shenandoah National Park unless the 

 additional emissions would not adversely affect air quality in 

 the park or emission reductions were achieved elsewhere. In 

 1992, the Park Service made a similar recommendation for the area 

 surrounding the Great Smoky Mountains National Park. In both 

 cases, states bordering the parks have continued to issue permits 

 despite the Park Service's recommendations. 



Provisions to Reduce Emissions From Existing 

 Individual Sources Are Difficult And Costly 



Although the PSD program generally exempts sources 

 constructed prior to the implementation of the program, the 1977 

 amendments allow regulators to require these sources to install 

 best available retrofit technology (BART), if they can 

 demonstrate that these sources are causing or contributing to 

 visibility impairment in class I areas. However, this authority 

 has only been used once in the 14 years in which the BART program 

 has existed. According to EPA and Park Service officials, BART 

 is not an effective way of controlling visibility impairment 

 because of the extensive time and money needed to develop legally 

 sufficient studies which attribute specific emissions of 

 individual pollution sources to visibility impairment. According 

 to Park Service officials, in the one case in which BART was 

 used, approximately 10 years was required and an estimated $5 

 million was spent on studies of air pollution entering Grand 

 Canyon National Park from the nearby Navajo Generating Station. 

 While the Navajo Generating Station is a primary contributor to 



