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accompanying technical support document presented substantial and 

 sufficient evidence (e.g., areavide emissions inventory, nadeling 

 analyses, sulfur isotops data) to support a finding that these 

 plants emit air pollutants that may reasonably be anticipated to 

 cause or contribute to visibility impairment and acid deposition 

 in the Claas I wilderness area. However, the state of Colorado, 

 has become embroiled in a political battle, fueled by the affected 

 utilities insistence that additional studies be conducted to 

 quantify the impact of all potential contributors to the documented 

 problem before additional pollution controls are required at the 

 two plants. This is clearly not what congress intended when it 

 established the BART requirement for major stationary sources, that 

 contribute to visibility impairment in Class I arsas. EPA must not 

 allow states to undermine the protection afforded by the Phase X 

 program requirements. 



EPA MUST CREATE INCENTIVES TO INSURE PROTECTION OF ALL AIR 

 QUALITY RELATED VALUES ZN CLASS I AREAS 



Visibility impairment is, in many cases, the first sign that 

 air pollution has intruded into a natural environment. It is a 

 problem in all Class I areas. Other pollution effects may not be 

 as visible, but they are equally— if not more — severe. It is 

 difficult to prsdiot the course of the chain reaction that occurs 

 when we disrupt a natural ecosystem by introducing poisonous gases 

 into the atmosphere for plants to absorb or depositing acidic 

 substances in the soils and water. It is impossible to know juet 

 how much we can tweak these systems before producing catastrophic 

 results. Some argue that we shouldn't do anything until we kno* 

 everything. That we can afford to wait until sound science 

 provides us with the csrtainty we need before we act. Others are 

 not so confident in our ability to field the ball every time nature 

 swings in rssponse to the curve balls we keep throwing. I advocate 

 a cautious approach— we must srr on the side of protection of 

 natural resources and systems. 



flms of Clsss I areas have an affirmative responsibility to 

 protsct all air quality related values (including visibility) from 

 the adverse effects of air pollution. Adverse impacts have been 

 documented on terrestrial and aquatic resources in numerous Class 

 I areas, including, in particular, Shenandoah National Park and 

 Great Smoky Mountains National Park. The primary culprit was 

 correctly identified by the General Accounting Office in its 

 February 7, 1990, report to this Subcommittee on "Air Pollution: 

 Protecting Parks and Wilderness From Nearby Pollution Sources." 

 Existing sources, whieh never vent through pre-const ruction review 

 under the prevention of significant dstsrioration of air quality 

 requirements because of their size or age, are responsible for the 

 bulk of the pollution problems in parks and wilderness areas. Yet 

 the only mechanism the Flits have to address these problems is the 

 new source review process. As a result, the FLMs, with support 

 from the environmental community, have taken the position that no 



