56 



national visibility goal in tha Wast without additional ramadial 

 and pravantiva action* and that tha progreee likaly to ba aada in 

 tha East will fall far short of raaching tha national goal. 

 Tharafora, EPA haa a lagal duty— right now— to davalop nav rulas. 



gpx Must Not Continue to Dalav Raoional Haza Rulemaking 



It appears that EPA plana to ignora its rasponsibility to 

 davalop ragional haze ragulationa for aavaral yaars, parhaps so 

 that tha Grand Canyon Visibility Transport Commission (Commission) 

 can coaplata its work and provida racomaandations. As raquirad by 

 tha Claan Air Act Aaendaente of 1990, EPA astablishad tha Grand 

 Canyon visibility Transport Commission in Kovambar 1991. Tha 

 Commission, which is coaposad of aight wastsrn Governors, SPA, 

 various fadaral land managing agencies, and tribal raprassntativss 

 has until November 1995 to make racomaandations to EPA on what 

 aaasurss, if any, ara naadad to rsasdy and pravsnt visibility 

 impairment in tha Colorado Plateau. 



Tha existence of the Commission does not negate EPA's 

 underlying duty to develop regional haze regulations. The 

 commission's report and recommendations will have no affect on 

 ragional haza problems in national parks and wilderness areas in 

 the East, Midwest, or Great Plaina. In addition, because the 

 commission has decided to focus on tha Colorado Plateau region, 

 its recommendations will likely have little impact— and may even 

 have a negative impact— on other western parks and wildernesses. 

 Finally, given that EPA has concluded that no reasonable progrsss 

 will bo aade toward the national visibility goal in the Colorado 

 Plateau region without additional measures, EPA arguably has a duty 

 to take immediate action to fill tha void. 



By moving forward with regional haza regulations, EPA could 

 jumps tart the development of aore cost-effective programs to raduce 

 concentrations of fine particulate matter (less than 1-2.5 microns 

 in diameter) . These finer particles cause visibility impairment. 

 There is overwhelming and highly disturbing evidence that these 

 finer particles contribute disproportionately to serious health 

 effects in urban araas, even when the PM-10 standard is not bsing 

 violated. EPA has acknowledged the need to revise or supplement 

 the current PM-10 standard, but a final decision is years away. 

 In the interim, public health will continue to euffer, costs of 

 medical cars and lost wages will continue to mount, and states will 

 likely continue to design pollution control strategies that do no 

 discriminate between large (2.5-10 microns) and fine particles. 

 If states wera stssred toward reducing concentrations of finsr 

 particles, they would likely focus on different types of sources 

 and strategies and bs able to maximize the cost-effectiveness of 

 their program by protecting both public health and visibility. 



Perhaps it sssas unrealistic to expect EPA to leap frog over 

 the Grand Canyon Commission and propose regulations before the 



