49 



patience and believes EPA must take the lead in order to achieve 

 results. 



Thus far, the SAMI process has been extremely slow, since 

 its inception nearly two years ago, SAMI has only discussed the 

 process and procedures for the operation of SAMI. In July of 

 1993, the environmental community called for SAMI to make 

 recommendations for regulatory and non-regulatory control 

 strategies by August 1, 1995, two years later. As it turns out, 

 SAMI has spent another year talking procedure. 



Moreover, there is currently little incentive for states and 

 industry to take action to clean up. They are currently 

 engrossed in dealing with the 1990 Amendments. Furthermore, the 

 states and industry often contend that the 1990 Amendments will 

 address much of the Class I problem. While, for the reasons 

 discussed above, we are confident this is not true, industry 

 claims we must wait until we know the effects of the 1990 

 Amendments before taking any additional action. Industry seeks 

 further assessments of the problem and the effect of the 

 Amendments, before any solutions can be developed and 

 recommended . 



Again, we believe that the only way SAMI will make real 

 progress is if EPA takes an aggressive leadership role and 

 provides SAMI with tools to address the problem. It is critical 

 that EPA not use SAMI as a reason for delay in taking its own 

 actions. EPA should establish a deadline for SAMI to produce 

 recommendations, no later than the end of 1995. During that time 

 period, EPA should develop and implement tools that SAMI can use 

 to address the problem. EPA has delayed addressing the Class I 

 area issue in a substantial way for nearly 20 years now. There 

 is no more time for delay. 



If EPA does not act, Congress should revisit the Class I 

 area issue and mandate actions that will address this critical 

 problem. See Attachment 4 and Attachment 5 regarding actions 

 Interior and EPA can take and the need to proceed without delay 

 despite the existence of SAMI, letter from Southern Environmental 

 Law Center to George T. Frampton, Jr., June 4, 1993 (Attachment 

 4) and letter from Environmental Defense Fund to Carol Browner, 

 June 25, 1993 (Attachment 5). 



[The attachments referred to have been filed for the record in the office 

 of the Subcommittee.] 



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