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OAR Box 1793 

Prepped by Keeia Richards 

Document Number: 

11) ll-F-53 

Docket Number: 

A-90-37 

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United States Department of the Interior ^ - F- fj 

NATIONAL PARK SERVICE 

RO.BOX 37127 

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Rationale: 

Why NPS and USFWS oppose SAMI Establishing AQRV Targets 

The National Park Service (NPS) and U.S. Pish and wildlife 

Service (USFWS) broadly define AQRVs as all values possessed by 

an area except those that are not affected by changes in air 

quality. These specifically include visibility, flora, fauna, 

soils, water, odor, culture and historic resources. While all 

these resources need to be protected and enhanced from the 

impacts of human-induced impairment, we focus on the sensitive 

receptors or sensitive AQRVs of each Class I area; i.e.. those 

resources most sensitive to air pollution (e.g,. species of 

plants or invertebrates, particular streams or lakes). 

After all, the legislative history of the Clean Air Act 1977 

Prevention of Significant Deterioration Amendments explicitly 

instruct us to "err on the side of protecting the air qualityrelated values for future generations." S. Rep. No. 95-127, 95th 

Cong, 1st Sess. 36 (1977) . The NPS Organic Act requires us to 

preserve and protect r.ll resources of the national park system 

"in such manner and by such means as will leave them unimpaired 

for the enjoyment of future generations." 16 U.S.C. Sec. 1 

(1916). In additior. the Wilderness Act of 1964 instructs NPS 

and USFWS, as well ao a-.- Federal Land Managers, to preserve 

designated wilderness areas in their natural conditions "where 

the influence of people is substantially unnoticeable." 16 

U.S.C. Sec. 113 (1982). 

Nevertheless, despite our attempts to protect sensitive AQRVs, 

extensive research and monitoring over more than a decade attests 

to existing, widespread adverse impacts to AQRVs in the Class I 

areas of the Southern Appalachians managed by NPS; i.e.. 

Shenandoah National Park and Great Smoky Mountains National Park. 

Resources known to be impacted include visibility, streams, 

soils, and vegetation. 1990 and 1992 Federal Register notices 

and technical support documents alerted the public at large to 

these effects; subsequent and continuing research and monitoring 

further support the earlier studies. 

The formation of SAMI was understood as a positive step toward 

seeking regional solutions to reduce the emissions of concern 

causing these widely recognized adverse impacts in the Class I 

areas. To that end, we strongly encourage: l) SAMI to recommend 

emission management options that will reduce the emissions of 

concern, as ranked by the SAMI Policy Committee; 2) the 

appropriate officials in charge to implement those 

recommendations; and 3) the measurement of progress through postimplementation research and monitoring. As a means of grouping 

EMOs to help ensure progress in reducing emissions, we support 

regional emissions caps for the primary pollutants identified by 

the PC, starting with nitrogen oxides. 
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10/18/95 10:58 O202 208 4620 WASO NR/AQ NPS $003/00 4 

Please understand we recognize the benefits involved in 

identifying sensitive AQRVs and establishing unquestionable 

effects thresholds or targets or levels. Federal Land Managers 

(FLMs) have worked, and will continue to work, with air pollution 

effects scientists to develop lists of sensitive resources and 

sensitivity thresholds. However, air pollution effects research 

is a relatively young field; and the complexity and changing 

dynamics of the natural world makes compiling and updating 

comprehensive, accurate, resource specific lists and thresholds 

difficult, expensive, and extremely time-consuming. 

In addition to technical feasibility concerns, we share several 

legal and policy concerns related to SAMI's proposed setting of 

targets or levels for AQRVs. Congress, in passing the 1977 Clean 

Air Act Amendments, provided for case-by-case FLM adverse impact 

determinations to protect AQRVs from emission increases 

associated with new and modified projects seeking Prevention of 

Significant Deterioration (PSD) permits from state and EPA 

permitting authorities: The Act charges the Secretary of 

Interior with an "affirmative responsibility" to protect AQRVs, 

making adverse impact determinations, as appropriate, and 

"satisfying" permitting authorities with those determinations. 

Since the criteria for such satisfaction is not defined, a 

potential exists for SAMI "targets" to be misused to undermine 

the FLMs' ability to carry out their mandates and protect AQRVs 

on a case-by-base basis. For example, applicants and permitting 

authorities frequently have misused PSD increment significance 

levels by applying those levels to AQRV impact analyses. 

Although EPA repeatedly has stated that increment and AQRV 

adverse impact are separate tests required under the Clean Air 

Act and implementing regulations, the misuse is still pervasive. 

More broadly, the Act explicitly "declares as a national goal the 

prevention of any future, and the remedying of any existing, 

impairment of visibility in mandatory class I Federal areas which 

impairment results from manmade air pollutants." 42 U.S.C. Sec. 

7492. Since the goal is clear, SAMI participants should work 

together to achieve emission reductions that make reasonable 

further progress toward achieving that goal. A deciview metric 

may be employed to visually show how reductions improve 

visibility. However, any ultimate "target" which accepts a level 

of manmade impairment, without seeking progress toward further 

reductions, would seem to contradict the intent of the statute. 

AQRVs have been the subject of considerable discussion over the 

past two years in connection with EPA's New Source Review Reform 

Subcommittee, of the Clean Air Act Advisory Act, established 

under the Federal Advisory committee Act. 
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1 0 /18/9 5 10:59 **202 208 4620 WAS0_NR/AQ NPS _ _ BI004/0Q4 

The New Source Review Reform Subcommittee recommendations and 

EPA's draft new source review regulations provide that FLMs 

should continue to be responsible for defining the sensitive 

AQRVs for each of the areas they manage. They also suggest that 

FLMs continue to define the critical loads of air pollution that 

can be tolerated in each class I area or by each AQRV. The 

specific AQRVs and critical loads selected for each Class I area 

should be selected and updated, as necessary, based on best 

available science with full disclosure and consideration of 

management objectives for the area in question. Having SAMI set 

predetermined targets for AQRVs in the Southern Appalachians 

seems counter to the recommendations of EPA and the NSR 

Subcommittee. 

Given the lack of site-and resource-specific information on 

sensitivity and effects thresholds, as well as legal and policy 

concerns, it would be inappropriate for SAMI to set targets. For 

all of the reasons discussed above, the Department of the 

Interior and its bureaus, NPS and USFWS, oppose SAMI setting "air 

quality targets." We urge the Governing Body to adopt the 

position NPS presented before the Operations Committee, as 

drafted in the November 25, 1994, memorandum from John Bunyak and 

Karen Malkin (copy attached).