April 23, 1998

Mr. Chairman and members of the Subcommittee, I appreciate the opportunity to appear before you today at this oversight hearing on proposed regulations under Section 169A of the Clean Air Act (CAA).

The National Park Service (NPS) manages 48 of the "Class I" areas that will be affected by the proposed regulation. Under the Clean Air Act, Class I areas are the larger national parks and wilderness areas that were established prior to 1978. As noted by the U.S. Environmental Protection Agency (EPA) in its proposed rulemaking, over ten years ago (November 1985), the Federal Land Manager (FLM) for the Department of the Interior (DOI), the Assistant Secretary for Fish and Wildlife and Parks, stated that all of these Class I areas experience visibility impairment in the form of regional haze virtually all the time, in varying degrees. (See attached Figure 1 for map of all mandatory Class I areas).

There were over 275 million recreational visits to units of the National Park System last year. To put this number of recreational visits in perspective, that is roughly one visit for each member of the U.S. population. The economic impact of park visitation is enormous ˙2D the total economic impacts associated with travel˙2Drelated expenditures is estimated to be $10 ˙2D 19 billion and between 144,000 ˙2D 276,000 jobs. These numbers only reflect direct and indirect expenditures and employment. They do not reflect the value people ˙2D including visitors and non˙2Dvisitors ˙2D place on our national parks and the natural, scenic and cultural resources they contain. Surveys indicate that the ability to see_and see clearly_the spectacular scenery of our parks and wilderness areas is very important to the millions of people who visit these areas. Even people who do not visit our national parks and wilderness areas want these resources to be protected.

Although we have an affirmative responsibility under the Clean Air Act and our own organic legislation to protect the resources and values of these areas, we generally lack the regulatory authority to bring about emission reductions needed to carry out our responsibilities, particularly with respect to pollution sources located outside our boundaries.

Therefore, we applaud EPA's decision to develop regional haze regulations and commend the thoughtful way in which EPA has addressed this very complicated issue in the proposed rule. In general, we believe EPA's proposal provides a good foundation and direction for the development of emissions management programs that will be needed to unveil the spectacularly scenic resources that this nation has had the foresight and wisdom to encompass in our park and wilderness systems as part of our national legacy for present and future generations.

We look forward to working with EPA, as well as the States, Tribal governments, and all interested parties, in the development of reasonable, yet protective programs to make "reasonable progress" toward the Clean Air Act's national goal of remedying any existing, and preventing any future, man˙2Dmade visibility impairment in Class I areas.

The Department of the Interior submitted formal comments on EPA's proposal in December.

Visibility Monitoring Efforts

Since 1978, DOI has conducted visibility monitoring in most of the Class I areas we manage. Our current visibility monitoring program includes the monitoring of fine particulate matter in 36 NPS areas, and the monitoring of light extinction (a measure of visibility impairment) in 18 NPS areas.\1\ (See attached Figures 2 and 3 for map of current monitoring sites and visibility conditions). All our monitoring is done in cooperation with the IMPROVE (Interagency Monitoring of Protected Visual Environments) program, and the data are publicly available and routinely reported. Current visibility research efforts include the development and application of analytical methods to identify the airborne particles responsible for visibility impairment, and when possible, determine the source of the particles.

\1\Fine particle monitoring consists of two weekly 24˙2Dhour samples, which provide: undifferentiated mass; specific elemental, ion (sulfate, nitrate and chloride), and organic and inorganic carbon concentrations; and atmospheric adsorption. Visibility monitoring comprises continuous measurement of impairment of either total atmospheric extinction or the fraction due

to scattering.

The current NPS program, in conjunction with the other IMPROVE sites, provides the estimates of "current" conditions in many locations necessary for implementation of EPA's proposed rule. The data can also be used to assess trends over time, since visibility data have been collected at 30 IMPROVE sites for at least nine years. The IMPROVE particulate matter monitors separate the fine particles into their chemical species, including sulfates, nitrates, and organics, thus providing a useful existing database for developing regional haze improvement strategies. The IMPROVE data will also help States with the EPA's Particulate Matter 2.5 National Ambient Air Quality Standards.

The implementation of the proposed rule and the new National Ambient Air Quality standard for fine particulate matter will rely on the NPS visibility monitoring network that can monitor both fine particles and extinction in Class I areas.

Impact on Visibility

The Clean Air Act requires EPA to adopt regulations to ensure "reasonable progress" toward the national visibility goal of remedying any existing, and preventing any future, visibility impairment in federal mandatory Class I areas. EPA's proposal includes measurable targets and criteria for assessing the effectiveness of the visibility program, but allows States to propose alternative approaches.

First, we support the concept of having a reasonably consistent method for tracking progress toward the national visibility goal. This would not only provide a check on whether current and future emission management programs are having the expected effect on visibility, but also a benchmark that can be used to let the public know whether visibility is getting better or worse.

Based on a preliminary examination of data from 30 IMPROVE monitoring sites\2\, we predict that all these sites are meeting EPA's proposed presumptive reasonable progress targets of no degradation for "clean" days ( i.e., the best 20 percentile visibility conditions), and over 80 percent of the sites are meeting EPA's proposed presumptive reasonable progress targets of measured improvement on the "dirty" days ( i.e., the worst 20 percentile visibility conditions). This progress is both expected and reassuring, reflecting the progress that has been made nationally in reducing pollution. Far more substantial progress will be needed, however, to remedy the man˙2Dmade visibility impairment experienced at heavily impacted Class I areas, like Shenandoah National Park and Great Smoky Mountains National Park.

\2\The method we used to analyze the data would be acceptable under EPA's proposal; however, any number of methods would be acceptable (e.g., EPA allows use of a 1˙2Dto˙2D9 year period for calculating "baseline"). We understand that others have reached different conclusions using alternative methods for calculating the baseline and trends. This discrepancy suggests the need for a more standardized approach.

If continuing progress can be assured over the long term from already existing and planned air pollution control programs, then the proposed regional haze regulations will have minimal independent impact. However, there may be areas where existing programs will have diminishing impacts on visibility conditions in the future.\3\ Given the value we place on our parks and the importance our visitors place on the ability to see the spectacular scenery, these areas will benefit from the kind of "insurance policy" that EPA's proposal would create.

\3\For example, in the West, health˙2Dbased air quality standards have been met in most urban areas (outside of California, Phoenix and Salt Lake City), and further efforts to reduce pollution may not occur in spite of rapidly growing populations. Therefore, projections suggest a relatively flat progress line for the first part of the next century ˙2D 2005˙2D2035. Still, visibility impairment plagues our scenic western Class I areas.

We have suggested some ways the proposed program could be improved. In order to reduce the administrative burden on states and federal land managers, the NPS commented to EPA on the rule in support of a regional approach to defining current and " natural" conditions, establishing emission reduction objectives that will ensure reasonable progress toward the national visibility goal, and developing a relatively uniform approach for regularly tracking progress. The State˙2Dby˙2DState approach could result in substantial duplication of effort and inconsistencies that might frustrate planning efforts. In particular, some of our Class I areas straddle State boundaries, and all of our Class I areas in the lower 48 United States are affected by interstate transport of pollution. Guidelines might also be helpful to promote consistency across regions.

To ensure that the rate of progress is " reasonable" and to increase our ability to carry out our stewardship responsibilities, we need to consider whether EPA's suggested "no degradation" approach for the best days is adequate in Class I areas where these 20 percent " cleanest" days are now substantially impaired. In addition, the suggested "reasonable progress" target for the most impaired days needs to be closely examined as it would allow 220˙2D330 years to achieve the national visibility goal in those areas, such as Shenandoah and Great Smoky Mountains National Parks, where visibility is currently very degraded. We do not believe this is acceptable to our park visitors. Based on an examination of current trends, we find that the proposed criteria could allow for a slower rate of progress than is actually being achieved in many areas.

We support the use of the "deciview" as a useful metric for expressing and comparing degrees of visibility impairment in a relatively simple way. EPA's recommended tracking of deciview changes over the long term is the best way to evaluate whether emission management strategies are working. However, one could argue that tracking emissions changes provides a useful supplemental measure for evaluating " reasonable progress"

Potential Impacts on NPS Resource Management Programs

Development of Regional Haze Programs: We generally agree with EPA's suggestion that regional haze programs be developed on a regional scale with participation from multiple governmental jurisdictions (State, Local, Tribal, as well as EPA and FLMs) and other interested parties. This type of process has been used to address a variety of air quality problems involving interstate transport of pollution (fig, the Grand Canyon Visibility Transport Commission (GCVTC),\4\ the Southern Appalachian Mountains Initiative (SAMI), and the Ozone Transport Assessment Group.)

\4\The implementation of the GCVTC recommendations is the focus of the recently established Western Regional Air Partnership, initiated and organized by the GCVTC in cooperation with the Western Governors' Association and National Tribal Environmental Council.

These processes have substantial benefits, particularly if consensus can be achieved in a timely manner. Like hundreds of others, the NPS has devoted significant time and resources to, in particular, the GCVTC and SAMI. The suggested regional planning fore would clearly benefit from our participation, because we are the collector and keeper of most of the visibility data, and provide expertise nationally through our visibility research program and policy activities. Were several such stakeholder processes to be initiated, or were State˙2Dby˙2DState consultations to intensify, NPS might need to direct more of its available staff and resources to meet these challenges.

Impact on NPS Fire Programs: EPA has proposed to require States to consider, at a minimum, several factors during the development of long˙2Dterm strategies, including ˙2D smoke management techniques for agricultural and forestry management purposes including such plans as currently exist for these purposes." As a practical matter, wildland fires cannot be eliminated. While NPS suppresses fire to protect public safety and to prevent unacceptable impacts on property and resources, NPS also uses fire for ecological purposes (many ecosystems are fire˙2D dependent), habitat protection and creation, and safety reasons (to reduce fuel loadings and prevent catastrophic wildfires). We recognize that the implementation of regional haze programs may affect the Federal Government's land management activities. With respect to the Department of the Interior, this includes a potential need (1) to develop and maintain a better inventory of fire emissions, (2) to increase visibility monitoring, (3) to prepare more detailed reports, (4) to conduct additional training requirements, and (5) to implement a more vigorous smoke management program or to consider alternatives to burning. The Department of the Interior has already committed to implementing the GCVTC recommendations regarding fire emissions and smoke management ˙2D˙2D not only within the Colorado Plateau. but nationally. We are also participating in EPA's Wildland Fires Issues Group, which is developing a national policy on how best to improve the quality of wildland ecosystems and to reduce threats of catastrophic fires through increased use of planned or managed fire, while achieving national clean air goals. Among other things, this group is examining a variety of emission reduction techniques that land managers can use to reduce smoke impacts from managed fires to the maximum extent possible.

In implementing the visibility protection requirements of the Clean Air Act, we encourage EPA, regions, and States to include all fire users (Federal, State, or other publicly owned or managed wildlands, Indian lands, and privately owned agricultural and other lands, in the smoke management provisions of the long˙2Dterm strategy.

The Grand Canyon Visibility Transport Commission Recommendations

DOI was actively involved in the GCVTC process, devoting significant time and resources to help forge the consensus that emerged. We support the "reasonable progress" objectives adopted by the GCVTC ("achieving continuous emissions reductions necessary to reduce existing impairment and attain steady improvement of visibility and managing emissions growth so as to prevent perceptible degradation of clean air days."). We believe the "reasonable progress" targets and metrics proposed by EPA are consistent with the GCVTC recommendations.

Like the States, Tribes, and other stakeholders who devoted similar resources to the GCVTC process, we do not want those efforts to be diminished or dismissed. We believe that EPA has made it clear in its proposal that the States included in the GCVTC are welcome and encouraged to submit SIP revisions that incorporate actions consistent with the GCVTC recommendations.

Before deciding whether the GCVTC participants should be given carte blanche to proceed, however, it is important to remember that the recommendations ˙2D˙2D while comprehensive and far˙2Dreaching ˙2D˙2D are just that: recommendations. The GCVTC report specifically highlighted that some recommendations were presented as options, some as things to be studied or further fleshed out, and some as actions to be implemented.

We encourage EPA to embrace the GCVTC recommendations, but to provide some incentive for the States and Tribes to proceed expeditiously with ongoing efforts to turn the recommendations into enforceable actions. One approach EPA might take would be to incorporate into the EPA final rule an " action plan," based on the GCVTC recommendations, that would hold the States and Tribes accountable for the activities and actions they agreed to pursue and for the "continuous emissions reductions" they committed to produce. This could take the form of an enforceable schedule, with specific milestones, work products, decision points, and expected "reasonable progress" outcomes.

This concludes my prepared testimony. I would be pleased to respond to any questions you might have.