57 



Commission has had a reasonable opportunity to complete its 

 aassssBsnt of various options. The Commission's work plan and 

 decision-making structure reflect an elaborate and unprecedented 

 effort to bring all the interestsd public and private parties to 

 the table in an attempt to reach consensus on whether additional 

 measuree are warranted to protect visual air quality, and if so, 

 how emissions will be managed. I am not suggesting that EPA ignore 

 what the Commission is doing. I believe, however, that the 

 Commission should be given a fighting chance to succeed. 



ZhA ££And Canyon Visibility Transport Commiaeion Needs 



BUfflgCH. and an Incentive to Sueceed 



After 17 yeare of footdragging, the public interest demands 

 that we make every effort to expedite implementation a regional 

 haze program by, inter alia , ensuring that the Grand Canyon 

 Commission's objectives are clear and consistent with the law, that 

 there is an incentive to develop timely recommendations to meet 

 those objectives, and that adequate resources are available. 



With respect to direction and objectives, SPA must send a 

 clear message to the Commission that maintaining the status quo is 

 not acceptable. EPA, in consultation with the FlMs, should also 

 provide a target objective regarding what would constitute 

 reasonable progress; otherwise, the Commission may become 

 needlessly mired in a never-ending debate about whether additional 

 measures are needed. The Commission's "consensus without 

 consequences" philosophy rewards those who benefit from delay. The 

 Commission needs an incentive to complete its work in a timely 

 manner. For this rsason, EPA should conduct its rulemaking 

 concurrently with the commission's process. That is, EPA should 

 publish proposed regulations shortly after the Commission issues 

 its draft report next summer. EPA could solicit comments on 

 alternative programs, drawing on the Commission's assessment of 

 management optione and supplementing them, if necessary. EPA 

 should also commit to publishing final rules by the end of 1995. 



With reepect to resources, the Commission's progress and 

 process has been hampered severely by inadequate funding. EPA 

 gives $250,000/year to the Commission, and last ysar, Congress 

 appropriated an additional $375,000. The estimated oost of the 

 work remaining to be done is over $2 million. Because of resource 

 constraints, the Commission has had to rely on in-kind services 

 provided by verious participants. Although on paper the committees 

 that are carrying out the work plan appear to have balanced 

 repreaentation from all affected sectors, in reality the lion's 

 share of the work is being done by those with the most time and 

 resources to devote— in this case, industry. Their level of 

 participation ia laudable, but it is having the unfortunate effect 

 of raising the ante for other Interested players to a prohibitively 

 high level. And while we have managed to move forward, I am very 

 concerned about who appeare to be driving the bue. 



