55 



rural area* of the eastern U.S. &fifl Rethinking the Ozone Problam 

 In Urban and Regional Air Pollution. {National Academy Press: 

 Washington, D.C. 1991). Also, sensitive resources are adversely 

 affected by ozone concentrations well below the level allowed by 

 the national ambient air quality standards. 



Similarly, the Clean Air Act's acid deposition control program 

 will roduce regional loadings of sulfur dioxide in the eastern u.s. 

 but not to a level needed to prevent acidification of watersheds 

 in Shenandoah National Park. 



In addition, an EPA report published in October 1993 concludes 

 that implementation of the Clean Air Act Amendments of 1990 will 

 result in only moderate visibility improvements in eastern national 

 parks and will not do anything to reduce visibility degradation in 

 the West. Zn fact, the spectacular scenic vistas of our most 

 treasured western national parks ars likely to be ehrouded in an 

 even denser pollution bate in the future. Zn short, the effect of 

 the Clean Air Act is, at best, uncertain; to the extent analyses 

 have been done, they show that the Act will not fix air pollution 

 problems in Class I areas. 



Zt is time to stop feeding scraps to our national parks and 

 wilderness areas. We must fashion effective solutions for 

 pollution problsms that threaten the heart and soul of our natural 

 hsritage. We have a legal mandate and an ethical responsibility 

 to protect these resources in their own right and for future 

 generations. 



EPA HAS A LEGAL DUTY TO DEVELOP A REGIONAL HAZE PROGRAM 



Let me begin with the most insidious and pervasive problsm- 

 - regional haze. Ths Clsan Air Act establishes a national goal of 

 remedying any existing and praventing any future manmada visibility 

 impairment in Class Z arsas. EPA was required to develop 

 regulations to make reasonable progress toward that goal, when EPA 

 promulgated visibility protection regulations in 1980, ths Agency 

 outlined a phassd approach. Specific regulatory mechanisms were 

 established to address sxisting visibility dsgradation if it could 

 be traced to a particular sourcs or small group of sources and to 

 prevent future impairment if a major new sourcs or modif lest ion 

 wsrs determined to have a perceptible impact. EPA deferred 

 development of a regulatory program to address ths larger problem 

 of regional haze on the theory that the stats of ths science was 

 not yst adequate and nssdsd analytical tools were not available. 



Ths National Academy of Sciences report published last year 

 concludes that ths science and toola are sufficient to support a 

 regulatory program. Protecting Visibility in Netional Paries and 

 Wlldarnees Areas (National Academy Prsss, 1993). EPA's excuse for 

 nonaction is no longsr valid. Zn addition, EPA itsslf has 

 concluded that there will bs no reasonable progress toward ths 



