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secondary standard. EPA should also consider the use of a 

 stringent increment for nitrogen oxides that would provide for 

 protection from all the various impacts of nitrogen emissions. 



In summary, EPA should move expeditiously to establish a N0 X 

 regulatory program that focuses on reducing overall NO x emissions 

 that affect Class I areas and other valuable resources, and not 

 get bogged down in an effort to Quantify the impact of a 

 particular N0 X source on a particular resource in a Class I area. 



(5) Is it your opinion that some form of regional haze 

 regulation is needed in addition to an effective PSD program in 

 order to protect air gualitv in Class I areas ? 



EPA action on regional haze is long overdue. The National 

 Research Council report on "Protecting Visibility in National 

 Parks and Wilderness Areas" has concluded the "current scientific 

 knowledge is adequate and control technologies are available for 

 taking regulatory action to improve and protect visibility." The 

 report also finds that already adopted or planned emission 

 control programs, including the acid rain control program 

 mandated by the 1990 amendments, "will not solve the nation's 

 visibility problem." The report further finds that progress 

 toward the Clean Air Act's visibility protection goal will 

 require regional haze control programs. These programs should 

 "consider many sources simultaneously on a regional basis." The 

 report warns against relying on programs focused on determining 

 individual source contributions. 



EPA should begin developing regional haze regulations 

 immediately. EPA should not wait for the deliberations of the 

 Southern Appalachian Mountain Initiative or the Grand Canyon 

 Visibility Transport Commission. Rather, EPA, by developing a 

 regional haze program, can provide these regional efforts with 

 the tools to actually improve visibility and meet the national 

 goal of reasonable progress. EPA should target developing the 

 regulations by the end of 1995. 



(6) Should regulatory approaches to eastern and western 

 lands be the same ? 



Visibility in the east is severely impaired. The average 

 annual visual range in the east is only 1/5 of natural conditions 

 in the summer months and episodes, of course, can be worse. The 

 Acid Rain Trading Program hopefully will substantially reduce S0 2 

 emissions in the eastern United States. However, there is no 

 assurance that the emission reduction will translate into 

 achieving the Clean Air Act's goal of "remedying any existing 

 impairment of visibility in Class I areas." Given the severity 

 of the problem in the east, dramatic reductions in sulfates in 

 the air will be necessary to achieve significant improvements in 

 visibility. The trading allowed under the acid rain program also 



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