-13 presents an unreasonable risk to health. To proceed under the present Clean Air Act philosophy of zero risk is inappropriate since it incorrectly assumes that a risk-free society is attainable. Second, determine which emissions must be regulated to achieve the necessary standard and develop strategies for both existing and new sources which will achieve the required reductions in a rational manner, taking into account technological and economic considerations. In this regard it may be established that the photochemical oxidant standard must be treated as a long-term goal rather than a short-term deadline. It may be established that it is not in the best public interest to attempt to achieve such a standard in an inflexible, unduly short and arbitrary time frame. Third, ensure that after a proper standard has been established and after a control strategy which is at least fairly certain to attain and maintain the standard has been developed, the strategy is implemented as expeditiously as practicable. This we believe is a sensible, fair way to find workable, socially acceptable solutions to a complex, major environmental problem for which there are still more questions than answers. It is a way for the government, industry and the general public to work together to establish meaningful goals and rational means of achieving those goals. It is a way in which we believe real -14 results will be achieved in restoring, protecting and enhancing our air quality resources. Very truly yours, Robert A. Roland President The National Parks and Conservation Association is grateful for the opportunity to present its views before this committee. NPCA is a private, non-profit organization founded in 1919 with a membership of approximately 40,000 nationwide. Our primary purpose is the protection, preservation, and expansion of the national park system and the restoration of the entire environOf particular concern to us is the deteriorating air quality in the national parks that is destroying some of their natural and scenic qualities. ment. While NPCA believes that the national parks can be adequately It is clear that some units of the park system are more susceptible to degradation in air quality than others. NPCA commends the efforts of this subcommittee to protect some of the most fragile, and pristine areas by placing them in the National Parks & Conservation Association, 1701 Eighteenth Street, NW, Washington, DC. 20009 telephone (202) 265-2717 printed on recycled paper -2 Class I category. However, we feel that some clarification in language is needed to protect all of those areas that deserve it and to permit ease in administering the act. It would probably be helpful to review the purposes and characteristics of some of the administrative areas of the national park system that should be protected under the Clean Air Act. Natural Areas are those areas whose unique scenic beauty and scientific value have been recognized by the American people as deserving of preservation for the enjoyment of future generations. They are areas where natural processes are allowed to continue undisturbed and are wild areas where modern man can escape for refreshment of mind and spirit. Most national parks, some national monuments and both national preserves and WatertonGlacier International Peace Park are classified as natural areas. Historical Areas preserve the cultural heritage of the continent from prehistoric times to the recent past. Most of these areas are comparatively small and many are located in urbanized areas. However, there are a number that are many thousands of acres in size whose natural beauty and scenic splendor should continue to be protected as an integral part of their historical significance. Some of the most outstanding areas contain remains of ancient native civilizations and relics of this nation's westward movement. Mesa Verde National Park, several national monuments, and Theodore Roosevelt National Memorial Park are classified as historical areas along with the many national historical parks, national historical sites, and national memorials. Recreational Areas provide recreation opportunities for millions of Americans in a natural environment. Many of these too, are located near densely settled areas where they cannot acheive truly clean air. However, there are many areas in this category whose clean air can and should be protected as necessary to their natural character and to human enjoyment of their health and recreationals benefits. Recreational areas include such designations as national recreation areas, national seashores, national lakeshores, national trails, national parkways, national riverways, and national forest parks and mountain parks. Many of these national park areas along with wilderness areas, wilderness study areas, and primitive areas should be protected from destructive deterioration in their air quality. Spectacular scenery should not be blocked by increased emissions from power plants or smog. The benefits derived from recreation in these areas should not be diminished by dirty air. However, it is obvious that some of these areas cannot be expected to attain the clean air standards that other must have. Forthermore, some of the areas are so small that rigid standards for air quality could inequitably and adversely effect responsible local development. -3 The National Parks and Conservation Association therefore proposes the following classifications: Natural area units of the national park system over 6,000 acres mandatory Class I Historic areas of the national park system over National wilderness areas mandatory Class I Recreational areas of the national park system National primitive areas Class I. However, states National wilderness study areas Class I. However, We feel that the above designation provides the most comprehensive protection for the important natural, scenic, historical, and recreational areas while offering flexibility in those cases where it is needed. In addition, such an action could save tax payers thousands of dollars. The National Park Service has estimated that under current EPA regulations it would cost approximately $50,000 per park unit to reclassify from Class II to Class I. Many times fewer units would undergo reclassification under the suggested formula than under existing rules. The Federal Land Manager While S. 252 states that "the Federal Land Manager...shall have an affirmative responsibility to protect the air quality." (Sec. 6, Section 110 (g) (5) (B) page 14, line 21-24 of the bill) no real mechanism is provided for his carrying out this mandate. Rather, it is left up to the individual states to decide whether or not a polluting source will be permitted near federal lands. The Federal Land Manager can do nc more than recommend against such actions. These lands belong to the American people, therefore the U.S. government, through its agent the Federal Land Manager, is responsible for their maintenance. To give this authority up to the states is to ignore the responsibility the federal government has taken on. The draft reclassification plan published by the state of Utah at the beginning of this year is an example of some of the abuses that could result from such a |