66 



Third, the scope of the analysis is too large to deal with in-kind 

 services, and we are forced to deal with our in-kind services. It 

 would be very difficult for us to meet our statutory deadline which 

 right now we are planning to meet. 



Our second concern has been the lack of research support from 

 the EPA. The National Resource Council report says there is 

 enough information to act now, but indicated also that there are fu- 

 ture research needs, and the way we are dealing with future re- 

 search needs right now is to identify the uncertainty that might 

 exist in our analysis. 



It would be very unfortunate at the end of our process if we had 

 certain areas that had large uncertainty bounds that might delay 

 implementation of regulations to deal with the issue we are talking 

 about. In sum, on this issue we do not believe that EPA has carried 

 out the research agenda envisioned in the 1990 Clean Air Act 

 Amendments. 



The third issue we would like to address is the issue of when 

 EPA should issue their regional haze regulations, and I turn to 

 Roger Clark from Grand Canyon Trust to offer those comments. 



[The prepared statement of Mr. Leary and Mr. Souby follows:] 



