109 



With regard to the adverse impact finding in the class I area, the 

 appeals board agreed that Virginia did not have a rational basis for 

 ignoring the Federal land manager's findings and remanded it to 

 the State to fully reconsider those findings. As a result, the plan 

 is not going to be built because the plan lost its contract with Vir- 

 ginia Power. 



Mr. Synar. Do you believe the State of Virginia will ever be sat- 

 isfied that the land manager has made a case for an adverse im- 

 pact on air quality-related values? 



Mr. Carr. Will the State ever be satisfied with the Federal land 

 manager's finding? 



Mr. Synar. Right. 



Mr. Carr. I think there is potential for that. The problem is with 

 the plans we have been dealing with primarily, they are beyond 

 100 kilometers and the modeling is not there to tie that plant to 

 the class I area. Under the current law 



Mr. SYNAR. How successful have land managers in Virginia been 

 in general in getting Virginia to install tougher controls? 



Mr. Carr. As far as tighter pollution control technology, the Fed- 

 eral land managers in the environmental community have been 

 successful. Over time, Virginia has now required selective reduc- 

 tion, the best known control technology available on these new coal 

 fired plants. That is an improvement. Hopefully, we can maintain 

 that. 



I am concerned with some things I am hearing from the new ad- 

 ministration of Virginia that they may not stick with the tough 

 standards that we have developed over these years. 



Mr. Synar. Would you make offsets a requirement for sighting 

 resouices near national parks? 



Mr. Carr. Where you have existing adverse impacts, yes. At a 

 minimum, you should have full offsets for any new PSE source that 

 comes in. And you should not have to get into the details of show- 

 ing exactly what the impact of that plant would be and whether 

 the offset would do it. There should just be fully missions offsets, 

 and a regional model to determine if that would benefit the class 

 I area. 



Mr. Synar. Do you also agree with Ms. Shaver who says it is the 

 duty of the State to look at cumulative impacts from new sources 

 locating in class I areas by tracking increments of additional pollu- 

 tion? 



Mr. Carr. Yes. That has been a failure of the process so far, to 

 look at the cumulative impacts of permits. In Virginia there have 

 been permits for 26 new power-generating facilities issued since 

 1986, and not all those have been built. But nobody has looked at 

 the total impact of all those new sources on the class I areas. 



Mr. Synar. One final question. Do you think that SAMI is likely 

 to produce anything useful? 



Mr. Carr. I remain hopeful, but the past 2 years of only looking 

 at process is slowing my optimism, and without leadership from 

 EPA, without tools, SAMI is not going to succeed. The problem is 

 very severe in the southern Appalachians, and without that leader- 

 ship, without the products that SAMI can use, it is not going to 

 happen. 



