107 



reason for us to wait until that occurs to do the other things that 

 we need to be doing? 



Ms. Shaver. Certainly the data for the Grand Canyon are irrele- 

 vant to the East. Some of the management approaches under con- 

 sideration would be available in the East as well as in the West. 

 But they are available now. Assessments of the effects of different 

 approaches would have to be regionally specific. 



Mr. Synar. I am told that you are involved in the Mount Zirkel 

 issue in Colorado where the Forest Service is in the midst of a pro- 

 ceeding under the best available retrofit technology program. Is 

 that right? 



Ms. Shaver. Yes, I am. 



Mr. Synar. During the last few weeks it seems to have entered 

 the State political arena as the Colorado Legislature figures out the 

 appropriate standard to apply. After the Ninth Circuit Court of Ap- 

 peals decision in the Navajo case, what amount of evidence do you 

 believe is needed to make a case? 



Ms. Shaver. The Ninth Circuit, and I believe Congress, estab- 

 lished an extremely low triggering threshold for requiring best 

 available retrofit technology on any source that emits any pollutant 

 that is recently thought to contribute to the problem. The informa- 

 tion available is substantial and sufficient to show that that con- 

 nection exists. 



Yet, the State of Colorado, in particular the legislature, is estab- 

 lishing a series of tests that must be gone through and require- 

 ments for studies that haven't even begun yet, before anything will 

 be done. And it is a sign of what happens when programs are dele- 

 gated to States without direction as to how to do it. The EPA has 

 failed to provide guidance there as well. 



Mr. Synar. You are a member of the EPA's committee to review 

 their new source program as it affects, class I areas. Who is in that 

 group and what are they supposed to be doing? 



Ms. Shaver. Representatives from a variety of different groups, 

 and we are supposed to be making recommendations to EPA. 



Mr. Synar. Who? 



Ms. Shaver. On the subcommittee there are numerous rep- 

 resentatives of different industries. 



Mr. Synar. How many? 



Ms. Shaver. About 10 people, 10-12 people. 



Mr. Synar. How often do you meet? 



Ms. Shaver. We mainly meet on the phone. You are talking 

 about the subcommittee on existing impacts as opposed to the full 

 committee, right? 



Mr. Synar. Right. What are you supposed to be doing? 



Ms. Shaver. We are doing process. We are up to our ears in 

 process. We are discussing options and trying to come to some reso- 

 lution. I don't see much hope of that, because many members of the 

 committee question, I think, the underlying objective, which is that 

 we need to do something to protect national parks and wilderness 

 areas. Other members think we definitely do need to do something. 



The other problem we have is, unlike some consensus making 

 arenas, there is nothing in place now. We are trying to create 

 something where there is nothing. So there isn't something that ev- 



