However, the document is intended to support the development or the review of the ambient air quality standards for SO2 and particulate matter.

Those standards are concerned with the ground level concentrations of those compounds and not with the conversion products of those compounds, such as acid rain.

Senator DOMENICI. Then, why was this document heralded as a sulfuric acid rain effects on crop yield if it did not direct its attention to one of the principal problems with acid rain which is outside of the ambient control under the Clean Air Act?

Mr. HAWKINS. Well, the research was undertaken to find out what the effects of simulated acid rain mist on seedlings would be. That information will be of use to the agency in its ambient standard setting process, but it will be of greater use in the continuing research activity in which EPA and other agencies of Government have trying to assemble a total impact of acid rain on our ecosystem.

Senator DOMENICI. So, it won't be a criteria-setting document with reference to the overall problem of acid rain but, rather, within the present State implementation plans and control of the ambient air, as far as a criteria document?

Mr. HAWKINS. Well, the criteria document, as I say, is intended to be a compendium of the information we have got on those compounds or their conversion products.

So, this information is relevant to that criteria document.

However, the standards which we have set deal with the compounds themselves and not with the various conversion products. We are one of the questions we have been asked is could we set a: “Ambient air quality standard for acid rain or for some surrogate for acid rain.

To the extent that sulfur oxide is the surrogate, then, yes, the answer is we could set a standard. But as we have discussed in other testimony, we don't have a very clear and direct route to resolve the acid rain concern by trying to reduce ground level concentrations of sulfur dioxide.

Senator DOMENICI. I note in the forward to this that you say: "The effective regulatory and enforcement action would be virtually impossible without some scientific data on pollutants and their impact on the environmental stability."

Now, your scientists don't intend that this document and the experiments you ran under it furnished that kind of information?

Mr. HAWKINS. Neither our scientists nor our policy makers contend that we know all that is desirable to know about acid rain and, certainly, this document does not provide all the answers to these questions.

This document does not constitute the sum total of the research that we think is necessary to understand about acid rain or to find out what the kind of ultimate resolution of the problem we need is. Senator DOMENICI. Well, if I read this experimental condition correctly and if I read the Washington Post story on April 1, based upon a press release or conference with EPA, correctly, this research addressed 28 different vegetables. In the final analysis, you had one plant per treatment-that is, per variety of mixes of sulfuric acid, various different components.

And I looked at it, and then I asked someone if that was a basis for scientific data that was credible. And the answer was overwhelmingly negative; that is when you have 84 plants of each species and you treat them with 84 different compounds and you only have 1 plant treated, it does not yield anything scientific. Mr. HAWKINS. I would agree completely, Senator. This was a screening study that is intended to be the basis for focus of attention of future work.

Senator DOMENICI. Well, then, why did the EPA indicate that this was a scientific study? What is this a scientific study of? I don't understand.

Mr. HAWKINS. It is a study done by scientists to provide a basis for pursuing whatever additional research is necessary.

In that sense, if you are saying that the implication is that this presents a body of scientifically founded conclusions that people can say, OK, these are the facts on damages to crops, the agency has never said anything resembling that. That is not our view. This is a screening study.

Senator DOMENICI. A screening study?

Mr. HAWKINS. That's right. When you are concerned about a broad area and you have limited research dollars, you undertake screening studies to get a fix on what places you should focus your research dollars.

So, we screened a wide variety of plants with a wide variety of mixtures. From that, we can focus on fewer plants and fewer mixtures and do additional research and see what kind of effect we get.

Senator DOMENICI. There is no scientific conclusion that is reachable as to any of the plants because you only did it on one plant? What did you screen?

Mr. HAWKINS. This is an initial study. We screened 84 plant varieties with 84 different mixtures and, from that, we will be able to design further followup research on this crop effects issue.

Senator DOMENICI. You know, maybe I forgot all the science I knew. I taught it once for a little bit. But I cannot understand why this would even be significant if the scientific result is not conclusive of anything.

I mean, what did you screen? You screened that there is no effect which you could have known statistically. But with one plant being tested, there is no statistical data coming from that.

Mr. HAWKINS. The laboratory scientist, however, can get some information about where to put their future efforts by undertaking this kind of a screening effort even though the results should not be used for policy purposes to come up with any program that says, all right, this is what our view of the acid rain impacts on crops

are.

We are not saying that that study says that, and we don't intend to use it for that purpose.

Senator DOMENICI. Well, it seems to me that at least you attempted to leave the conclusion that, as a result of this test, we don't know enough about acid rain to draw a conclusion.

And I would guarantee you that that is the result, and I would guarantee you that statistically that is going to be the result.

So, what did you do it for and what effect does it have on the issue at hand? It's neutral. We don't know whether acid rain is damaging or not, but this is an official study saying we did this big vegetable, 84 different species, study.

Am I interpretting it wrong?

Mr. HAWKINS. I think I sense what may be troubling you which is-let me see if I've got it right-which is that it sounds like somebody made big news out of this study the results of which are obvious; that when you have a wide variety of crops that you are surveying with a wide variety of chemicals, you are not likely to get any startling results to constitute proof one way or the other. I would agree with you completely. In fact, I am not aware of the genesis of the Washington Post article. I was not disturbed by it. I didn't regard it as news either.

Senator DOMENICI. Well, let me tell you what disturbs me about it. It seems to come out at a time when we are obviously at a stage that we don't know enough about acid rain.

So, we are going to go under an administration bill full speed ahead to convert between 107 plants and 71 plants without any environmental control on them.

And this study comes out saying full speed ahead because we don't know enough about it. We just did a research project and it tells us we don't know enough about it.

Mr. HAWKINS. Well, OK. That is an even more direct statement of concern. And I can assure you that I was responsible and am responsible for coordinating the agency activities on the relationship of the various administration proposals to acid rain.

And this study was published and available some time back in January or December or something like that.

As I say, the genesis of the Washington Post article had nothing to do with EPA or the administration feeling for or against the various proposals that are on Capitol Hill. It is totally unrelated, and that is all I can offer to you.

Senator DOMENICI. If it is relevant to anything, it is not relevant to the issue at hand.

Mr. HAWKINS. It is a piece of preliminary research and, as my testimony will indicate, EPA's up-front statement is that we don't know everything about acid rain but we know enough to know that we should be looking for ways now to start reducing emissions. That is it in a nutshell.

And this study does not change that conclusion.
Senator DOMENICI. Thank you.

Mr. HAWKINS. Perhaps I should now go into a somewhat longer summary of my statement, but I will try not to make it too long. Senator TSONGAS. I would like to ask you, as you do that, to focus on two issues: One, your agency's position, if you want to go into it, on constant emissions; and, second, the rather remarkable divergence between your testimony and DOE's on the tons per year of sulfur dioxide emissions attributable to the utility oil backout bill. Mr. HAWKINS. I would be happy to discuss that. Perhaps the best way to do that would be in the questions and answers since my prepared testimony does not have a great deal of detail on that.

STATEMENT OF HON. DAVID G. HAWKINS, ASSISTANT ADMINISTRATOR FOR AIR, NOISE AND RADIATION, ENVIRONMENTAL PROTECTION AGENCY

Mr. HAWKINS. What I would like to do, Mr. Chairman, is simply start off by telling you what we do know about acid rain. And I think it fits in rather nicely with Senator Domenici's line of questioning.

We do know that acid deposition is primarily caused by gaseous emissions of sulfur and nitrogen oxides which are converted in the atmosphere to strong acid compounds, and they eventually fall to Earth, often hundreds of miles from their sources.

Senator TSONGAS. Could I interrupt you? We have already been told that in previous testimony. If we could just get to those areas I mentioned. It is unfair to the later witnesses to ask you to delete that which has been said by those who came before but those of us who give speeches often have that problem.

Mr. HAWKINS. I don't have any problem in responding to that. I will just summarize that we have effects on aquatic systems, lakes damaged, fish kills documented. This was put out in the testimony.

We have concentrations of heavy metals in some surface waters which causes some concern. Dr. Cowling has mentioned-Dr. Hendrey, I guess, mentioned that we have heavy metals in drinking water.

We have a concern about soil damages because of leaching of minerals and nutrients, and we have the concern which the previous witnesses mentioned about the impact on buildings and structures, as well as the reduction of visibility.

Let me just say that while there is no consensus on all of the facets of the acid rain problem and we know that areas of scientific debate include questions concerning the causes of acid rain, the severity of the impacts and the various means for control, what is clear, however, is that we are faced with an already serious environmental problem which, if allowed to grow unchecked, could carry substantial economic costs as well.

Currently, we believe that the way to reduce acid deposition, practically speaking, is to reduce emissions of sulfur and nitrogen oxides, the pollutants that cause the problem.

Although we are not certain of the extent of the emission reductions that will be necessary to bring about a satisfactory amelioration of the problem, we do believe that enough is known about the severity of the problem for us to try to find ways now to begin to reduce emissions.

Senator TSONGAS. Isn't it ironic that we should be talking about reduction of emissions when constant emissions is not a policy agreement within the administration?

Mr. HAWKINS. Well, the President, in dealing with the constant emissions issue, recognized that this was part of the acid rain. problem.

And as part of the problem, he felt that it would be appropriate to try to work with Congress comprehensively on that, rather than try to deal with it in the context of this one particular proposal. Among the major sources of these pollutants are utility powerplants. And as Senator Domenici mentioned earlier, new plants will be well controlled.

However, there are hundreds of older powerplants that are not subject to these new emission standards. The control options that we are now considering to reduce acid deposition include requiring reduced emissions from these older plants.

We did quantify the emissions increases that are allowable under the powerplant conversions to coal under the proposed utility oil backout legislation, and we estimated that, under the current state implementation plan regulations, the sulfur oxide emissions from the original proposal could increase by about 330,000 tons per year and NO, emissions could increase by about 200,000 tons per year.

Now, I will just try to address your question about the disparity of the DOE and the EPA estimates. I believe the DOE testimony was approximately 190,000-let's say 200,000 tons of sulfur dioxide increases.

The difference-our estimate of approximately 300,000 and their estimate of approximately 200,000-has to do with an assessment of what the actual emissions will be from those plants when converted to coal.

Our assumption assumes that they will operate at the maximum allowable levels under the State and local regulations. The DOE assessment assumes that they will operate at approximately 80 percent of those levels.

The argument to support the DOE estimate, is that there is some margin of safety that is employed by powerplant operators and that they will be somewhere below the total allowable emissions under the law.

I think we agree that there will be some margin of safety. Our data did not suggest that it will be as great as 20 percent. Moreover, our feeling is that it is a reasonable estimate to use the maximum allowable as the basis for the assumption because of the fact that there are likely to be some relaxations of these State and local regulations and any relaxations could more than consume any margin of safety.

But I think what we are saying is that somewhere between 200,000 and 300,000 tons is both agencies' estimates of what it will be.

And DOE would acknowledge that 80 percent is an assumption and we would acknowledge that 100 percent is an assumption. And it probably is somewhere in between.

As I mentioned, SIP relaxations could permit larger increases. Most of this increase would be concentrated in the northeastern United States which is a region disproportionately affected by and sensitive to acid rain.

The administration's oil backout proposal does provide $400 million in grants for projects which would reduce sulfur emissions, and the money, if it were spent in a cost effective manner, could achieve emission reductions equivalent to the increase from the conversions mandated by the bill, again not assuming SIP relaxation.

We do recognize that the Government, even it pays the full capital costs, will still leave the operating costs to be borne by the utilities, and this could have an effect on the willingness of the utilities to participate in that program.