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Mr. Synar. Other than that. 



Ms. Nichols. We have the ozone standard which is also under 

 an expedited review, and I believe that as I indicated in my testi- 

 mony, that visibility will be a specific issue that will be addressed 

 in that standard. 



Mr. Synar. She also suggested that you make States keep track 

 of increment consumption as part of having an approved SIP. If a 

 State doesn't keep track of how much of its air quality margin they 

 have used up, she argues that the program is meaningless. Do you 

 agree with that? 



Ms. Nichols. Yes, I think as I often agree with Ms. Shaver that 

 it is correct and that this is a factor that needs 



Mr. Synar. If you agree with her, wouldn't you make it a re- 

 quirement for the SIP? 



Ms. Nichols. I believe that this is, in fact, a requirement that 

 we are in the process of considering applying to States with respect 

 to delegation of their PSD programs. 



Mr. Synar. I am also concerned by reports that one purpose of 

 the new source review working group is to water down the BACT 

 which is required for new sources which affect class I areas. First, 

 could you define top-down BACT for us. 



Ms. NICHOLS. Well, top-down BACT is a decision that is made on 

 a project that involves the decision to use the best available control 

 technology defined as the best. There has been no discussion of 

 that issue, to my knowledge, in the new source review task force. 

 It was not put on the table, and to my knowledge, no member of 

 the committee has raised that as an issue. So if that fear has been 

 expressed by someone, I don't believe it is supported by any evi- 

 dence or any of the record of that committee. 



Mr. Synar. If that is true, then that is a good pledge. 



Let me ask you the question I have asked almost every panel. 

 Explain to me why you are waiting for the Grand Canyon. 



Ms. Nichols. Well, as I have indicated, we don't believe we need 

 to wait for them in order to do the background work to get a rule- 

 making out. And frustrating though it is, I have learned that rules 

 don't come out of EPA in a period even on the most expedited basis 

 in less than about 2 years no matter what you do, even when you 

 have all the data in place. So we are beginning that process, as I 

 indicated, now. I do feel that with respect to strategies to be used 

 for regional haze, there is information coming out of the Grand 

 Canyon discussion processes that will be helpful to us in formulat- 

 ing strategies that will be workable for States and industries and 

 that will enjoy a level of support that will be necessary to get those 

 regulations through a complete rulemaking process and, hopefully, 

 not have them bogged down in the courts when we finally get them 

 out. 



Mr. Synar. Well, let me thank all three of you for being here 

 today. I think it has been very helpful. 



Let me conclude with something which we as Members of Con- 

 gress and particularly Democratic Members of Congress need to 

 make very clear. 



We were pretty tough on Bush and Reagan on these areas. We 

 intend to be just as tough with our own players who wear the same 

 stripes. There is an attitude around here "not on our watch," well, 



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