39 



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 reduction scenarios, the S0 2 reductions will not 

 reverse the acidification trend in the sensitive mountain 

 headwater streams in the Shenandoah National Park. See testimony 

 of James N. Galloway, Professor, Environmental Sciences 

 Department, University of Virginia, to the House Subcommittee on 

 National Parks and Public Lands dated Thursday, April 30, 1992, 

 Attachment 1. Furthermore, it is likely that some southern 

 utilities will buy allowances rather than reduce their S0 2 

 emissions thereby continuing to pollute at or close to current 

 levels. For example, Carolina Power & Light which operates coal- 

 fired plants due south of Shenandoah and roughly 200 kilometers 

 away, has purchased 85,000 tons per year of allowances that would 

 allow them to continue to run these dirty facilities. 



The situation regarding nitrogen oxides (NO x ) emissions is 

 even more troubling. In a study done for EPA in 1991, Pechan and 

 Associates projects that NO x emissions in Virginia will increase 

 significantly by the year 2010 despite the Clean Air Act 

 Amendment's provisions. Furthermore, EPA reported at the 

 November 15, 1993 meeting of the Southern Appalachian Mountain 

 Initiative that its projections show 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. EPA also noted that while the 

 CAAA require less than a 10 percent cut in N0 X by the year 2000, 

 Germany is proposing to reduce S0 2 and N0 X by 90 percent by the 

 year 2000. 



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 NO x emissions are a major factor in ozone 

 formation in rural areas like the Shenandoah or Great Smoky 

 Mountains parks. Moreover, there are serious concerns whether 

 the ambient health standard for ozone adequately protects human 

 health. 



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 

 provided for in Section 165 of the Clean Air Act. It is also 

 incumbent upon EPA to use all of its existing authority to move 

 forward to solve this serious problem. Furthermore, it is 

 important that this subcommittee and Congress as a whole 

 seriously consider new legislation that would require the 

 reductions in N0 X , S0 2 and other pollutants, necessary to remedy 

 adverse impacts in Class I areas. 



