173 



We have monitoring information in a number of our parks both 

 on gaseous pollutant and visibility pollutants. 



Mr. Synar. Is there a formula called "significant factor" and if 

 it is tripped, you find an adverse impact? 



Mr. Frampton. We have a working definition of an adverse im- 

 pact, and those are if it would affect the national significance of the 

 area, if it would 



Mr. Synar. Isn't that the way you do it? 



Mr. Christiano. Yes. 



Mr. Synar. How many times did that thing trip? 



Mr. Christiano. I think we have talked about- 



Mr. Synar. Fewer than 1 dozen out of 100; right? 



Mr. Christlano. That is probably appropriate. We review be- 

 tween 20 and 40 permits a year for both Fish and Wildlife Service 

 and Park Service areas. Many of these are for sources that are 

 quite distant from parks or are extremely well-controlled. We do 

 the analysis of the best available control technology and provide 

 comments to the State agencies no matter how far away they are, 

 as far as that goes, because we have, I think, been very successful 

 in getting 



Mr. Synar. Is that why in 1990 you issued a blanket determina- 

 tion of adverse impact regarding Shenandoah instead of proceeding 

 on a case by case? 



Mr. Christiano. We determined at that point that we had 

 enough information that the existing conditions at Shenandoah 

 were such that we probably couldn't tolerate any additional insult 

 to the environment there. 



Mr. Synar. Now, the State of Virginia, as we have learned today, 

 has overruled your permit objections numerous times. Do you real- 

 istically think there is any way we can convince them of the ad- 

 verse impact? 



Be honest. You are under oath. 



Mr. Christiano. I understand that. 



I think the weight of evidence that we are putting together ought 

 to be able to convince them. 



Mr. Synar. Why didn't you appeal in cases like Hadson Buena 

 Vista when they were overruled by Virginia? 



Mr. Christiano. I am going to defer to Molly Ross on this issue. 

 She is much more detailed and has got much more information on 

 the details of these transactions. 



Mr. Synar. Molly, what is the answer? 



Identify yourself for the record. 



Ms. Ross. My name is Molly Ross, I am a Special Assistant to 

 Assistant Secretary Frampton, but I served as the Assistant Chief 

 of the Air Quality Division during 1984 to 1993, and I was on the 

 scene in Washington. 



The Assistant Secretary and the Superintendent of Shenandoah 

 had recommended filing an appeal of the Hadson permit based on 

 deep concerns about that permit. A decision was made at the de- 

 partmental level not to allow the filing of that appeal. 



Mr. Synar. Is it safe to assume it was political pressure in the 

 last administration? 



Ms. Ross. Perhaps a different way of doing things. 



