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makes uncertain the degree of any improvement in visibility in 

 Class I areas. In order to ensure reasonable progress toward 

 meeting the national goal, we believe that EPA must develop 

 regional haze programs for both the east and west. EPA should 

 establish a national standard for improvements in visibility that 

 applies in both the east and west. EPA should not abrogate its 

 responsibility and rely on regional commissions or initiatives to 

 provide these solutions. Rather, EPA should provide tools for 

 the regional efforts to use. 



(7) What methods do vou recommend for reducing the 

 contribution of existing sources to impairment of air quality- 

 related values ? 



See the discussion of N0 X control programs and regional haze 

 programs above. There are other approaches for addressing 

 existing sources that EPA could pursue immediately. First of 

 all, EPA should enforce existing regulations that reguire state 

 implementation plan revisions if Class I increment exceedances 

 occur. Similarly, EPA could use its authority under the Clean 

 Air Act to reguire state implementation plan revisions to correct 

 adverse impacts at Class I areas. Thus, wherever a Class I area 

 is experiencing adverse impacts, the SIP would have to be revised 

 to reduce emissions so that the adverse impact would be 

 eliminated. This would, no doubt, reguire multi-state SIP 

 revisions. 



(8) Do you view the Southern Appalachian Mountain 

 Initiative as likely to yield an effective method for protecting 

 air quality in the region ? 



While I believe that the Southern Appalachian Mountain 

 Initiative (or SAMI) has some potential if only because it has 

 brought a number of the players together with the acknowledgement 

 that their is a serious air pollution problem in the Southern 

 Appalachians, I do not believe that SAMI is likely to be 

 successful in improving air guality unless EPA takes an 

 aggressive leadership role and uses its existing authority 

 discussed earlier in this testimony 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. 



It is important to realize certain basic parameters of the 

 SAMI effort. First, the effort is totally voluntary and were it 

 not for funding from EPA and Congress, it is unlikely the states 

 would have come together. Second, we believe that states and 

 industry agreed to participate primarily because they were 

 seeking a way to avoid the difficult and time-consuming PSD 

 permitting struggles that occurred in Virginia in the early 

 1990s. Environmentalists have been willing to participate 

 because they are looking for ways to clean up existing sources. 

 However, the environmental community does not have unlimited 



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