60 



new pollution eourcee be permitted near Class I araas that are 

 experiencing advaraa impacts on air quality ralatad values unless 

 aaission offssts are obtained. 



This approach has been rather controversial. Industry is 

 concerned that new sourcss are being held hostage unless they can 

 find soma way of atoning for the sins of existing sources. PIMs 

 and the environmental community are concerned that this approach 

 only serves to limit pollution increases and does little to make 

 a dent in the existing problem. Nonetheless, this approach has 

 had the benefit of significantly improving the efficiency of 

 pollution control equipment installed at nev sourcss. Also, as EPA 

 has learned through its New Source Review Subcommittee, the FLMs 

 and environmentalists are not about to give up the one card they 

 have to play unless othsr means for dealing with air pollution 

 problems caused by existing sources are provided. 



BPA Must Esta blish Secondary National Ambient Air Quality 

 standards or other Me asures to Protect Sensitive Resources in 

 Class I Areas 



Alternative methods for addressing existing impacts in parka 

 and wilderness areas are available now, under current Clean Air 

 Act authorities. EPA is already required to establish national 

 ambient air quality standards to protect against known and 

 anticipated adverse effects on public health and welfare. 42 U.S.C. 

 7409. EPA should be directed to adopt secondary ambient air 

 quality standards that would protect sensitive resources (AQRVs) 

 in Class I areas. EPA also has broad authority under section 166 

 of the Clean Air Act to establish measures for protection of AQRVs 

 and to fulfill the goals and purposes of the Act. 42 U.S.C. 

 7476(c). EPA's authority is not limited to establishing 

 "increments". Emissions density zoning or critical pollutant 

 loading approaches could be ussd to establish limits on total 

 pollution concsntrations in Class I areas. 



If either secondary standards or new ssction 166 limits were 

 violated, states would be required to revise their implementation 

 plans to correct the violation, states, or EPA if states failed 

 to act, would have the flexibility to obtain the needed emission 

 reductions in the most cost-effective manner possible. Existing 

 sources, that were exempted or grandfathered from the PSD 

 preconstruction review process, could be required to install 

 pollution control technology. States and EPA would have the handle 

 they need; the parks and wilderness areas would get the relief they 

 need. 



epa Must Enforce the Requirement That State Implementation 

 Plans Be Revised if Increment Excaadancas Have Been Documented 

 and Clarify That SIP Revisions are Needed If Xdvirn Impaeta 

 Are Occurring on AQRVs in Class I Areas 



