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6 

 successfully before the permit's issuance. In other cases, 

 including the Old Dominion Electric Cooperative's Clover project 

 and the SEI Birchwood power facility, both in Virginia, the 

 Department reached agreements after submitting final adverse impact 

 determinations. In yet other cases, such as the Multitrade 

 cogeneration project in Virginia, the Healy project in Alaska, and 

 the IMC fertilizer facility in Florida, the Department and the 

 permittee reached agreement only after an appeal had been filed. 



Having reviewed over 450 permits affecting park and refuge areas 

 since 1978, we believe that PSD new source review is an important 

 Class I area protection tool to assure that new sources do not 

 cause or contribute to specific air pollution problems. We also 

 recognize, however, that PSD has serious limitations. EPA is 

 committed to pursuing other measures to address the sources of 

 emissions which create visibility impairments in Class I areas. 



For these reasons, we are involved in efforts both to improve PSD 

 and to move beyond PSD. To improve PSD, the National Park Service 

 and the U.S. Fish and Wildlife Service are participating in EPA's 

 New Source Review Reform efforts as well as the Interagency 

 Workgroup for Air Quality Modeling (IWAQM) . To move beyond PSD, 

 the National Park Service is participating with EPA, the Forest 

 Service, eight southeastern States, and a variety of other 

 stakeholders in the Southern Appalachian Mountain Initiative 

 (SAMI) , whose mission is the following: 



