36 



STATEMENT OF DAVID W. CARR, JR., DIRECTOR, PUBLIC 

 LANDS PROJECT, SOUTHERN ENVIRONMENTAL LAW CEN- 

 TER, CHARLOTTESVILLE, VA 



Mr. Carr. Thank you, Mr. Chairman, and thank you for the op- 

 portunity to be here today. 



The Southern Environmental Law Center is a nonprofit public 

 interest organization dedicated to protecting the special natural re- 

 sources of the South, including the Shenandoah National Park and 

 Great Smoky Mountains National Park. Shenandoah and the 

 Smokies are two of the most polluted national parks in the country. 



At present, the park protection provisions of the Clean Air Act 

 are failing miserably to achieve their purpose of preserving, pro- 

 tecting, and enhancing the air quality of national parks. Further- 

 more, the Clean Air Act amendments of 1990, which do not specifi- 

 cally address class I area protection will not adequately protect the 

 serious problems we have at Shenandoah and the Smokies. 



Scientists at the University of Virginia who are experts on acid 

 deposition and its effects on aquatic resources tell us that even 

 under the best of 1990 amendment reductions scenarios, the SO2 

 reductions will not reverse the acidification trend in the sensitive 

 mountain headwater streams in Shenandoah. 



The situation regarding nitrogen oxides emissions is even more 

 troubling. EPA reported that NO x emissions in the region will 

 begin increasing after the year 2000. EPA also reported that by the 

 year 2010, 65 percent of NO x emissions will come from industry 

 and utilities. 



We already have ozone levels in the parks reaching the ambient 

 human health standard, and vegetation is adversely impacted well 

 below that level. There is now general scientific consensus that 

 NOx emissions are a major factor in ozone formation in rural areas 

 like Shenandoah and the Smokies. Given these circumstances, it is 

 imperative that the National Park Service and EPA aggressively 

 carry out their authorities and responsibilities to protect class I 

 areas. It is also incumbent upon EPA to use all its existing author- 

 ity to move forward to solve the serious problem. 



The Southern Appalachian Mountain initiative was begun rough- 

 ly 2 years ago. It is often referred to as SAMI. I do not believe that 

 SAMI is likely to be successful in improving air quality unless EPA 

 takes an aggressive leadership role and uses its existing authority 

 to provide SAMI with the tools to reduce air pollution. 



I fear that SAMI will continue to be used as a reason for delay 

 by EPA and others. Thus far, the SAMI process has been extremely 

 slow. Since its inception nearly 2 years ago, SAMI has only dis- 

 cussed the process and procedures for the operation of SAMI. 



EPA should establish a deadline for SAMI to produce rec- 

 ommendations no later than the end of 1995. During that time pe- 

 riod, the EPA should develop and implement tools that SAMI can 

 use to address the problem. 



First, EPA should develop an effective regional program that will 

 substantially reduce overall NO x emissions in the East, a cap ap- 

 proach would be the most effective. 



Second, EPA should proceed to develop regional haze regulations 

 by the end of 1995. 



