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E-M:/ isle royale lovers -- comments needed on EPA visibility rule

Enviro-Mich message from davemec@sojourn.com (Dave Dempsey)

Isle Royale National Park and the Seney Wilderness would be big
beneficiaries from new visibility rules proposed by the EPA.  So would
other outstanding areas all ove the nation!

The following is a summary of EPA's proposed rule on regional haze. If
adopted, the rule will have far-reaching benefits by helping to restore and
protect visibility in most of the nation's federally designated wilderness
areas and National Parks.  Please help generate public support for the rule
within your organization and membership. The deadline for written comments
is October 20th. If you know of other groups that have an interest in air
and public lands issues, please forward this alert on to them.  If you are
able to generate coverage by the media,that would be wonderful.  Please
help get the word out!

Mark your calender: Written comments on the rule are due October 20th.  We
hope you will be able to submit written comments to EPA supporting the


        EPA has proposed new regulations that would significantly reduce
air pollution in national parks and wilderness areas across the nation.
Electric utilities, big mining companies, and others are mounting a
full-scale assault on these long-overdue regulations. .

       Across the nation, air pollution affects not only our urban areas
but also our national parks and wilderness areas.  While we've made
significant progress in protecting human health, and EPA's new regulations
on very small particles and ozone will continue that progress, air quality
within our nation's crown jewels continues to suffer.  The National Park
Service estimates that scenic vistas in many our national parks are
negatively affected by air pollution more than 90 percent of the time.  EPA
reports that in the East, visual range -- how well you can see a feature in
the distance -- is one-fifth of what it would be in the absence of air
pollution.  Even in the West, visual range is one-half to one-third of what
it would be without human-caused air pollution.  What does this mean?  If
you visit the south rim of Grand Canyon National Park on a high pollution
day, you may not be able to clearly see the features of the north rim, only
ten miles away.  The problem at many eastern parks is even more severe.

        What does Federal Law Say?   When it adopted the 1977 amendments to
the Clean Air Act, Congress recognized that pristine air quality and scenic
vistas are integral features of our national parks and wilderness areas.
Congress decreed that all national parks of more than 6,000 acres,
wilderness areas, international parks, and memorial parks exceeding 5,000
acres and in existence on August 7, 1977, would be designated as class 1
areas.  Nationwide, there are 156 class 1 areas, from the Great Smokies to
the Grand Canyon to Mount Rainier National Parks.  Then, Congress
established a national goal of remedying any existing visibility impairment
in these class 1 areas, and of preventing any future impairment.

In 1980, EPA issued regulations to protect class 1 areas from air pollution
that could be traced to a specific source.  EPA recognized at the time that
pollution attributable to a specific source (like the Navajo power plant in
northern Arizona) is a serious problem at a few class 1 areas.  But EPA
also conceded that the predominant air pollution problem at parks and
wilderness areas is the 'soup' of pollutants that is emitted from a host of
sources (from cars to power plants to unpaved roads) and then travels far
downwind.  This pollution -- called regional haze -- has been reported by
all of the national park class 1 areas located in the lower 48 states.
Nevertheless, EPA consistently refused to issue regulations to deal with
this regional haze problem.

In the 1990 amendments to the Clean Air Act, Congress once again urged EPA
to address the problem of regional haze within class 1 areas.  And on July
31 of this year, EPA finally issued proposed regulations that would make a
significant dent on air pollution affecting class 1 areas across the

EPA's Regulations:  EPA's regulations have several parts:

- States would expand their air quality monitoring in class 1 areas.

- States would also have to identify old, uncontrolled major pollution
sources such as coal-fired power plants, and evaluate how installation of
pollution controls -- called Best Available Retrofit Technology, or BART --
would help clean up pollution in class 1 areas.

- Then, beginning in four years, each state would have to amend its state
implementation plan (SIP) to incorporate pollution control measures that
would begin reducing air pollution in class 1 areas in that state, and in
downwind states.  This is critically important, since air pollution from
places like the Los Angeles basin can affect air quality as far away as
Canyonlands National Park in southeastern Utah.  (States could work
together to do this on a regional scale.)

- These plans would be then be reviewed in three-year cycles to ensure
states are making progress in cleaning up air pollution in class 1 areas.

- Most important, the regulations establish a quantitative standard for
evaluating whether the pollution control measures are being effective.
Every 10-15 years, the states would have to show that visibility on the 20%
of dirtiest days has improved by at least one 'deciview,' and that
pollution on the 20% of cleanest days has not deteriorated.  (A deciview is
a means of quantifying haziness.  A one-deciview change is a small but
humanly perceptible change in haziness, or visibility, at most class 1

        Industry is planning a full-scale assault on these proposed
regulations.  We need your help.  You can submit comments to EPA at the
address listed below.

- Support EPA's regional haze regulations.  These regulations are long
overdue.  The 1977 Clean Air Act Amendments directed the federal agencies
to clean up air pollution in class 1 areas, yet it took twenty years to get
these regulations on the books.  Without regulations to control regional
haze EPA won't be able to deal with the single largest air pollution
problem in class 1 areas.

- Demand that states be required to show that air quality in class 1 areas
is getting better every ten years -- not every 15 years.

- Insist that the regulations need to be stronger, especially for parks and
wilderness areas in the East.  If air pollution and visibility improve at a
rate of one deciview per decade, it could take 220-330 years to get clean
air at eastern class 1 areas like Shenandoah and Great Smokies National
Parks.  The states in the East are easily capable of achieving a 3 deciview
improvement every decade -- and EPA's regulations should use that as the

Send your comments by October 20 to:

                         Air and Radiation Docket
                             401 M Street, SW
                           Washington, DC  20460
                         ATTN: Docket No. A-95-38

EPA is holding one national hearing on these regulations, on September 18
in Denver.  Industry is mobilizing to deluge EPA with negative comments.
If you can testify, call this number and sign up:
                            Barbara Miles, EPA

Dave Dempsey
Michigan Environmental Council
119 Pere Marquette, Suite 2A
Lansing, MI  48912
(517) 487-9539
(517) 487-9541 (fax)

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