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fuzzy, leading to repetitive discussion about not just what we need 

 to do but whether we need to do anything, and the consensus ap- 

 proach to decisionmaking that has been adopted comes with no 

 consequences. This works in favor of those who benefit from con- 

 tinuing delay, and may result in the commission being mired in 

 endless debate without any incentive to produce in a timely man- 

 ner. 



Now, EPA could comply with its responsibility to do a regional 

 haze program and provide the commission with the incentive it 

 needs to succeed if it did several things. First, send a strong signal 

 to the Grand Canyon commission that the status quo and main- 

 taining the status quo is not OK EPA should also set clear target 

 objectives for the commission regarding what constitutes reason- 

 able progress. Now that EPA has concluded that there will be no 

 progress unless more is done, they have an obligation to let the 

 commission know what progress means. 



In addition, I think the most effective incentive that EPA could 

 provide to the commission is to conduct concurrent rulemaking. 

 That is, as soon as the commission issues its draft report, which 

 is due about a year from now, EPA could publish proposed regula- 

 tions, solicit comment, and be prepared to issue a final rule as soon 

 as the commission issues its final report and regardless of whether 

 the commission issues a final report in a timely manner. 



EPA could take into account all the information being developed. 

 This would not, I don't think, be an insult to the commission. It 

 would simply be saying that after 17 years of dragging our feet, we 

 are going to do something and we are going to do it as soon as we 

 can. 



In the interim, I think it is extremely important that we not lose 

 sight of what little ability we have under the phase I visibility pro- 

 gram to protect visibility in parks and wilderness areas where indi- 

 vidual sources have been identified as causing or contributing to 

 the problems. 



What I see happening now in States like Colorado, is the States 

 are getting bogged down in lengthy studies over obvious situations, 

 and in fact insisting that regional haze-type approaches be used to 

 deal with existing source problems. This is really frustrating our 

 ability to use the limited tools we have until we develop new ones. 



Visibility is not the only problem in national parks, and in some 

 areas certainly many of the other problems are more serious, and 

 could be more catastrophic. We are tweaking with natural orders 

 and natural systems, and I for one have no confidence that we are 

 going to be able to field the ball when nature keeps swinging in re- 

 sponse to the curve balls that we throw her. 



EPA, I am encouraged to note, seems to have learned how to pro- 

 nounce the phrase "ecosystem protection." What I would like to see 

 now is some commitment to how that can be done and commitment 

 to when it will be done. The best place to demonstrate that commit- 

 ment would be by exercising their existing authorities to provide 

 the types of standards and regulations and mechanisms that we 

 need to protect the parks from existing air quality effects. 



There are several things that EPA can do right now: EPA can 

 establish national ambient air quality standards. In fact, they have 



