40 



As the following answers to the specific questions set forth 

 in the Chairman's April 22, 1994 letter further demonstrate, the 

 PSD program has not been successful in protecting Class I areas 

 from new sources and more aggressive approaches for cleaning up 

 existing sources are necessary to remedy adverse impacts at 

 Class I areas. 



(1) Describe the Clean Air Act Prevention of Significant 

 Deterioration (PSD) permit actions vou have been involved with, 

 including any comments on permit applications and appeals of 

 state permit decisions . 



In 1990, the National Park Service finally took action to 

 rescue the Shenandoah National Park from the disastrous impacts 

 of air pollution. The Deputy Assistant Secretary of the 

 Interior, as the federal land manager, issued a finding of 

 adverse impact under Section 165(d) maintaining that 15 new power 

 plants would have adverse impacts on the Shenandoah National 

 Park. SELC, along with 10 other national, state and local 

 environmental groups, supported the NPS effort. Unfortunately, 

 the PSD process has been rife with political interference from 

 Bush Administration political appointees. If the environmental 

 community had not been there to carry the ball when the Secretary 

 of Interior's office forced the NPS to drop the ball, the PSD 

 program would be in much worse shape than it is now. 



The OPEC Case 



Since 1990, SELC and the Shenandoah Air Coalition that it 

 represents has filed comments on seven PSD permit applications 

 for new power plants and appealed three of those permits to EPA. 

 The three cases appealed clearly demonstrate the political 

 interference to which the process is subject. In the case of Old 

 Dominion Electric Cooperative (ODEC) , a coal-fired 786 megawatt 

 plant proposed for Clover, Virginia, the National Park Service 

 was considering an appeal of the permit in the spring of 1991. 

 However, pressure from the utility industry and the applicants 

 persuaded the Secretary of the Interior and his staff to direct 

 the NPS not to appeal the permit. With their bargaining power 

 gone, NPS settled for a half-baked offset proposal. See 

 Attachment 2 for a more detailed discussion of the political 

 interference in the ODEC case: Statement of David W. Carr, Jr. 

 before the Subcommittee on National Parks and Public Lands, April 

 30, 1992. 



When NPS failed to protect Shenandoah from the proposed ODEC 

 plant, SELC appealed the state-issued air permit to EPA on June 

 3, 1993, seeking EPA's help to protect the park. However, not 

 unexpectedly, EPA's decisions were subject to the same political 

 interference that NPS encountered. 



