106 



Ms. Shaver. EPA and the States are not enforcing those require- 

 ments right now. 



Mr. SYNAR. Why? 



Ms. Shaver. I think you would have to ask them. 



Mr. Synar. Do you have a guess? 



Ms. Shaver. Likely, resources; and likely, priorities. 



Mr. Synar. You recommend that if States don't correct these 

 exceedences by changing their implementation plans, then Federal 

 plans should go into effect. Even further, you would deny any more 

 PSD permits and require the applicant to basically demonstrate to 

 the land manager that the facility wouldn't cause or contribute to 

 an adverse impact on air quality-related values. 



So what you are doing by that recommendation is reversing the 

 burden and putting it on the permit applicant, right? 



Ms. Shaver. Exactly. We are trying to create some incentive and 

 consequence for the failure to act to make sure that something hap- 

 pens. 



Mr. Synar. You go on to suggest that EPA should add a new re- 

 quirement for judging the adequacies of the SIPs. If the State SIP 

 doesn't deal with adverse impacts in class I areas, then the imple- 

 mentation plan should be rejected by EPA. Have you gotten any re- 

 sponse to these suggestions from EPA or any other members on the 

 resource review? 



Ms. Shaver. There has been a lot of discussion. I don't see con- 

 sensus emerging. There have been members of the committee who 

 say this approach would be conceptually attractive. EPA lawyers 

 say it appears they have the authority to do this. 



Mr. Synar. I am under the understanding that you and Mr. Carr 

 met with the Assistant Administrator at EPA, Mary Nichols, last 

 October on ways to include the class I area protection. Have you 

 gotten any commitments to beefing up the program? 



Ms. Shaver. I think the main thing we got out of that was the 

 special committee that EPA has set up to examine existing impacts 

 in class I areas. However, there has been no commitment on EPA's 

 part to actually deal with that problem as part of their rulemaking. 



Mr. Synar. In your testimony you also support reviewing the na- 

 tional ambient air quality standard program for particulate matter 

 to distinguish between particles on the basis of size. 



Ms. Shaver, isn't it true that not only that action would revise 

 downward to improve visibility, but it would also save some lives? 



Ms. Shaver. Sure. We keep thinking visibility is an esthetic 

 issue. In this case EPA is now recognizing the very fine particles 

 in the air, 2V-2 microns in diameter to smaller size range are having 

 serious adverse effect on public health, including premature deaths 

 in cities around the country. 



EPA is going to take several years to consider and revise that 

 standard. In the meantime, people are suffering. Those same fine 

 particles are the ones contributing to visibility impairment. 



If we had regional haze regulations, regional haze standards out 

 there, the States would have an incentive now to start alleviating 

 the pain that is being caused to large portions of the population. 



Mr. Synar. Let me ask you the same thing I asked Professor 

 White. Does it make sense that what the Grand Canyon commis- 

 sion comes up with is going to apply to the East, and is there any 



