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pollution that is preventable, avoidable, and controllable. 



while va are short on substance and leadership, we axe up to 

 our ears in "process". Seme Class I area air quality issues have 

 been relegated to various consensus-building fora that have been 

 set up nationally (e.g., ERA'S Subcommittee on New Source Review 

 Reform), regionally (e.g., Grand Canyon Visibility Transport 

 Commission, southern Appalachian Mountain Initiative) and locally 

 (e.g., bill pending in Colorado legislature to appoint a task force 

 on visibility and air quality related valuee in national parks and 

 wilderness areas) . Although this approach reflects a poeitive 

 ehlft evey from a "one-size-fits-all" regulatory mentality, in moat 

 casss it has bssn rsplacsd with an "any-aita-will-do" philosophy. 

 EPA has not just delegated ita responsibility, it has abrogated it 

 by not providing sufficisnt leaderahip and direction. 



This collaborative approach to decision-making does not work 

 unlsss there ere clear objectives, adequate resources, balanced 

 representation, deadlines for action, and an incentive to succeed. 

 Zf these parameters are not defined, whet is touted as consensus- 

 building becomes a delay tectic in disguise. This is particularly 

 a likely outcome in cases where "the group" is aaked to come up 

 with recommendations to addreee a problem that is not currently 

 being addreeeed. Inertia and the quest for conseneus rewarda those 

 who like the status quo/do nothing program by ensuring that nothing 

 happens until agreement is reached. There must be eome incentive 

 to produce reeults. Clearly spelled out conssquences can be a 

 powerful incentive. 



Current Regulatory Program is Ineffective 



The current regulatory program provides a mechanism for 

 addressing only a small subset of the pollution sources that 

 contribute to adveree air pollution affects in class I areas. We 

 are simply putting tiny band-aids on gaping wounds. With respect 

 to new sources, the program is merely designed to limit the amount 

 of some types of new pollution that can be added to Class I area 

 airshsds by major new sources and major modifications. With 

 respect to exieting sources, a regulatory mechanism for requiring 

 installation of the best available retrofit technology (BART) is 

 available only if visibility impairment in a Class I area is 

 "reasonably attributable" to an existing sourcs or small group of 

 sources. 



For other pollution problems in Class I areas , we rely on the 

 hope that other provisions of ths clean Air Act will have some 

 trickle-down effect. We ere offered assurances, but provided no 

 insurance, that the pollution control efforts aimed at 

 nonattainment areas will reduce ozone concentrations in national 

 parks and wilderness areas. But the improvements that may occur 

 could easily bs offsst by increassd pollution nearer the Class I 

 areas— particularly increases in nitrogen oxide concentrations in 



