Testimony of Lynn M. Terry
Deputy Executive Officer, Air Resources Board
California Environmental Protection Agency
April 23, 1998

Thank you for the opportunity to provide testimony regarding the U.S. Environmental Protection Agency's (U.S. EPA's) proposal for new regional haze regulations to improve visibility in Class I national parks and wilderness areas.

California is home to some of the most beautiful scenery and vistas in the world. As a result, one˙2D fifth of the areas affected by the proposed visibility regulations are in California, spanning the state from Redwoods National Park on the North Coast to Joshua Tree in the Southern Desert.

In California, the Air Resources Board (ARB) is charged with overseeing the State's implementation of the federal Clean Air Act, as well as our own California Clean Air Act. ARB is committed to protecting and improving visibility in both our scenic wild areas and our urban landscapes, in concert with our efforts to meet health˙2Dbased air quality standards.

While we support efforts to improve visibility, we strongly oppose the regulatory framework as outlined in U.S. EPA's December 1997 proposed regional haze regulation.

Visibility improvement programs must gain public support to succeed. To garner this support, the regulatory framework must be sensible, scientifically sound, and complement efforts to meet health˙2Dbased standards. In our evaluation, the proposed regional haze regulation fails to meet these criteria.

Today, I would like to highlight some of our concerns and identify four key recommendations which need to be implemented in the final regulation to allow states to build successful visibility programs at the lowest cost.

First, the most critical issue ˙2D˙2D drop the deciview approach as the test for visibility progress and replace it with steady reductions in emissions of pollutants shown to contribute to regional haze.

As part of the Grand Canyon Visibility Transport Commission, California and 7 other western states, 5 tribes, and 6 federal entities wrestled with the question ˙2D what is reasonable progress? The Commission ultimately defined reasonable progress as "continuous emission reductions. . .," parallel to the Clean Air Act's approach for progress towards the health˙2Dbased air quality standards.

Although the proposed regulation purports to offer states the flexibility to choose an appropriate progress target, states must demonstrate to the satisfaction of U.S. EPA that even obvious alternatives are justified. California knows all too well how difficult and how expensive it can be to pursue U.S. EPA approval for alternatives to federally prescribed approaches, no matter how innovative or effective those alternatives may be.

In California, regional haze, fine particulate matter, and ozone share some common components. So, our existing and planned air quality programs to address ozone pollution will also cut particulate levels and improve visibility throughout the State and beyond. California, and other states in similar situations, should be able to satisfy reasonable progress for haze by reducing emissions to meet the progress requirements for the health˙2Dbased standards, until those standards are attained.

The deciview metric is too subjective to be the basis for holding states accountable for visibility improvement. The technical tools necessary for translating emissions into increments of visibility improvement are just not available.

Congress created the Grand Canyon Visibility Transport Commission to advise U.S. EPA on strategies for improving visibility at national parks and wilderness areas on the Colorado Plateau. The Commission process resulted in the conclusion that emission reductions are the appropriate progress target for visibility. U.S. EPA should not ignore this conclusion.

Second, change the timing for planning and implementation of the regional haze program to parallel and complement the schedule for fine particles.

The timelines in the proposed regulation would preclude a thoughtful, efficient approach to visibility improvement. Most of the extensive technical work needed for fine particles is also critical to support visibility planning. The schedule should allow states to integrate these efforts to capitalize on the overlap between the sources of fine particles and haze.

Third, provide new funding to support state, local, and tribal efforts to meet federal requirements for regional haze.

Visibility plans will be extremely resource˙2Dintensive, with monitoring, inventory, modeling, technology assessment, control measure development, public review, and agency adoption and implementation. States, tribes and local agencies should not be asked to divert funds from existing programs focused on meeting health˙2Dbased air quality standards to instead implement the regional haze program.

Finally, ensure that federal agencies are full partners in visibility solutions.

National emission standards for sources under federal control are key to meeting all of our air quality goals. While we are encouraged by the federal government's actions to require lower˙2Demitting heavy˙2Dduty diesel engines in trucks, off˙2Droad equipment, and locomotives, a more proactive federal approach is needed to make progress on cleaner engines for ships and aircraft.

We also need improved coordination between federal land managers and air agencies to accommodate increased burning for public safety and forest health, without "smoking out" downwind communities. California intends to continue to improve the State's smoke management programs to address both visibility and public health concerns. Federal land managers must be a partner in that process.


U.S. EPA has an opportunity to create a sound framework that will support visibility improvement through the next century; but the structure must be rebuilt to ensure common˙2D sense implementation that is integrated with existing air quality programs. We appreciate this opportunity to share our recommendations to achieve that goal.

California will continue to implement the state's clean air plan for achieving health˙2Dbased air quality standards and incorporate additional strategies to meet the new ozone and fine particulate standards. These efforts will improve visibility as well. We all want to restore and preserve the scenic vistas in our nation's most beautiful places for future generations to enjoy.