Air Pollution: EPA Data Gathering Efforts Would Have Imposed a Burden on
States (Letter Report, 08/07/95, GAO/AIMD-95-160).

The Clean Air Act Amendments of 1990 require the states to collect,
analyze, and report information to the Environmental Protection Agency
(EPA).  An EPA draft regulation implementing the 1990 amendments would
have required states to begin submitting more detailed emissions data to
EPA's Aerometric Information Retrieval System that would have exceeded
the agency's minimum air pollution program needs.  EPA has since
suspended the development of the draft regulation and is considering
alternative reporting options.  Most heavy emission states do not use
the Aerometric Information Retrieval System to track air pollution, even
though EPA designed the system for them to do so.  For example, of the
10 states that are the source of nearly half of the critical pollutants
emitted in this country, only one state uses the Aerometric Information
Retrieval System's Facility Subsystem to monitor air pollution emissions
from factories and plants.  Instead, emission states rely on systems
that have developed independently.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  AIMD-95-160
     TITLE:  Air Pollution: EPA Data Gathering Efforts Would Have 
             Imposed a Burden on States
      DATE:  08/07/95
   SUBJECT:  Environmental monitoring
             Air pollution control
             Reporting requirements
             Motor vehicle pollution control
             Federal/state relations
             Environmental law
             Data bases
             Information systems
             Data collection
IDENTIFIER:  EPA Aerometric Information Retrieval System
             EPA National Ambient Air Quality Standards
             California
             Florida
             Georgia
             Illinois
             Indiana
             Michigan
             New York
             Ohio
             Pennsylvania
             Texas
             
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Cover
================================================================ COVER


Report to the Ranking Minority Member, Committee on Government Reform
and Oversight, House of Representatives

August 1995

AIR POLLUTION - EPA DATA GATHERING
EFFORTS WOULD HAVE IMPOSED A
BURDEN ON STATES

GAO/AIMD-95-160

Air Pollution


Abbreviations
=============================================================== ABBREV

  AIRS - Aerometric Information Retrieval System
  CFC - Chlorofluorocarbon
  EPA - Environmental Protection Agency
  GAO - General Accounting Office
  NAAQS - National Ambient Air Quality Standards

Letter
=============================================================== LETTER


B-261512

August 7, 1995

The Honorable Cardiss Collins
Ranking Minority Member
Committee on Government Reform
 and Oversight
House of Representatives

Dear Ms.  Collins: 

This report conveys the results of our evaluation of selected data
collection and reporting requirements of the Clean Air Act Amendments
of 1990.  The 1990 amendments require the states to collect, analyze,
and report information to the Environmental Protection Agency (EPA). 
After the amendments were passed, the Chairman of the former
Environment, Energy, and Natural Resources Subcommittee expressed
concern that EPA and the states could be overwhelmed by the
collection and reporting requirements of the law and might not be
able to make appropriate use of the information. 

Our objectives were to determine whether (1) EPA's planned state
emissions reporting requirements exceed the agency's program needs
and (2) states use EPA's Aerometric Information Retrieval System
(AIRS) to monitor emissions data. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

An EPA draft regulation implementing the 1990 amendments would have
required states to begin submitting more detailed emissions data to
AIRS that would have exceeded EPA's minimum air pollution program
needs.  EPA has since suspended the development of the draft
regulation and is considering alternative reporting options. 

Most heavy emission states do not use AIRS to track air pollution,
even though EPA designed the system for them to do so.  For example,
of the 10 states that are the source of almost half of the critical
pollutants emitted in this country, only one state uses the AIRS
Facility Subsystem to monitor air pollution emissions from factories
and plants.  Instead, these heavy emission states use systems they
have independently developed. 


   BACKGROUND
------------------------------------------------------------ Letter :2

The Clean Air Act gives EPA authority to set national standards to
protect human health and the environment from emissions that pollute
ambient (outdoor) air.  The act assigns primary responsibility for
ensuring adequate air quality to the states. 

The pollutants regulated under the act can be grouped into two
categories--"criteria" pollutants and "hazardous air" pollutants. 
While small in number, criteria pollutants are discharged in
relatively large quantities by a variety of sources across broad
regions of the country.\1 Because of their widespread dispersion, the
act requires EPA to determine national standards for these
pollutants.  These national standards are commonly referred to as the
National Ambient Air Quality Standards (NAAQS).  The NAAQS specify
acceptable air pollution concentrations that should not be exceeded
within a geographic area.\2 States are required to meet these
standards to control pollution and to ensure that all Americans have
the same basic health and environmental protection.  NAAQS are
currently in place for six air pollutants:  ozone, carbon monoxide,
sulfur dioxide, nitrogen dioxide, lead, and particulate matter. 

The second category, referred to as "hazardous air pollutants" or
"air toxics," includes chemicals that cause serious health and
environmental hazards.  For the most part, these pollutants emanate
from specific sources, such as auto paint shops, chemical factories,
or incinerators.  Prior to its amendment in 1990, the act required
EPA to list each hazardous air pollutant that was likely to cause an
increase in deaths or in serious illnesses and establish emission
standards applicable to sources of the listed pollutant.  By 1990,
EPA had listed seven pollutants as hazardous:  asbestos, beryllium,
mercury, vinyl chloride, arsenic, radionuclides, and benzene. 
However, the agency was not able to establish emissions standards for
other pollutants because EPA, industry, and environmental groups
disagreed widely on the safe level of exposure to these substances. 


--------------------
\1 These pollutants are called "criteria air pollutants" because the
agency sets permissible levels for them based on "criteria" or
information on the effects on public health or welfare that may be
expected from the presence of such pollutants. 

\2 A geographic area that meets or does better than the standard is
called an "attainment area." Areas that do not meet the standard are
called "nonattainment areas."


      THE CLEAN AIR ACT AMENDMENTS
      OF 1990 REQUIRE A LARGE
      AMOUNT OF DATA
---------------------------------------------------------- Letter :2.1

The 1990 amendments established new information gathering, storage,
and reporting demands on EPA and the states.  Required information
ranged from that on ground-level to atmospheric pollutants.  For
example, states with ozone nonattainment areas must require owners or
operators of stationary sources of nitrogen oxides or volatile
organic compounds\3 to submit to the state annual statements showing
actual emissions of these pollutants.  Also, the amendments expanded
the air toxics category to include a total of 189 hazardous air
pollutants that are to be controlled through technology-based
emission standards,\4 rather than health-based standards as the
previous law had required.  To establish technology-based standards,
EPA believes that it needs to collect information on emissions of
these hazardous air pollutants. 

In addition, the amendments initiated a national operating permit
program that requires new information to be collected from sources
that release large amounts of pollutants into the air.  Further, the
amendments require new information about acid rain,\5 stratospheric
ozone-depleting chemicals,\6

and ecological and health problems attributed to air pollutants. 
Appendix I identifies titles of the act and selected additional data
collection requirements imposed by the new law.\7


--------------------
\3 Volatile organic compounds are a group of chemicals that in the
presence of heat and sunlight react with nitrogen oxides in the
atmosphere to form ozone, a primary constituent of smog. 

\4 Public Law 102-187, enacted on December 4, 1991, deleted hydrogen
sulfide from this list. 

\5 Acid rain air pollution is produced when acid chemicals are
incorporated into rain, snow, fog, or mist.  The "acid" in acid rain
comes from sulfur oxides and nitrogen oxides (products of burning
coal and other fuels) and from certain industrial processes.  Wind
carries these pollutants far from their sources. 

\6 High concentrations of ozone gas are found in a layer of the
atmosphere--the stratosphere--high above the Earth.  Stratospheric
ozone shields the Earth against harmful rays from the sun. 
Stratospheric ozone thinning has been linked to destruction of this
protective layer by chlorofluorocarbons (CFCs) and related chemicals. 

\7 Implementation of many of the programs required by the 1990
amendments was staggered so that they began at different times.  Some
of the requirements have yet to be fully implemented. 


      AIRS DESIGNED TO HELP EPA
      AND STATES MONITOR AIR
      POLLUTION
---------------------------------------------------------- Letter :2.2

EPA designed AIRS in stages during the 1980s to be a national
repository of air pollution data.  EPA believed that having this
information would help it and the states monitor, track, and improve
air quality.  The system is managed by EPA's Information Transfer and
Program Integration Division in the Office of Air Quality Planning
and Standards.  The Office of Air Quality Planning and Standards,
under the Assistant Administrator of Air and Radiation, manages the
air quality program. 

AIRS was enhanced in response to the 1990 amendments, when additional
gathering, calculating, monitoring, storing, and reporting demands
were placed on the system.  AIRS currently consists of four modules
or subsystems: 

  Facility Subsystem:  This database, which became operational in
     1990, contains emission, compliance, enforcement, and permit
     data on air pollution point sources\8 that are monitored by EPA,
     state, and local regulatory agencies. 

  Air Quality Subsystem:  This database, which became operational in
     1987, contains data on ambient air quality for criteria, air
     toxic, and other pollutants, as well as descriptions of each
     monitoring station. 

  Area and Mobile Source Subsystem:  This is a database for storing
     emission estimates and tracking regulatory activities for mobile
     air pollution sources, such as motor vehicles; small stationary
     pollutant emitters, such as dry cleaners; and natural sources,
     such as forest fires.  The subsystem became operational in 1992
     and is scheduled to be phased out by September 1995 due to
     budget cuts and low utilization. 

  Geo-Common Subsystem:  This database, which became operational in
     1987, contains identification data such as code descriptions
     used to identify places, pollutants, and processes; populations
     of cities and/or counties; and numerical values that pertain to
     air quality standards and emission factors that are used by all
     the other subsystems. 

Information provided by EPA, which we did not independently verify,
indicates that the total cost to develop and operate the system from
1984 through 1995 will be at least $52.6 million.  Budgeted operating
and maintenance costs for fiscal year 1996 are projected to be $2.7
million.  Neither of these estimates include states' personnel costs. 
The Facility Subsystem accounted for the largest portion of subsystem
costs.  Appendix II provides a more detailed breakdown of estimated
subsystem costs for fiscal years 1984 through 1995.  Budgeted
subsystem costs were not available for fiscal year 1996. 


--------------------
\8 A point is a physical piece of equipment or a process within a
facility, such as an industrial plant, that produces emissions. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :3

To determine whether EPA's planned state emissions reporting
requirements exceeded the agency's actual program needs, we reviewed
the Clean Air Act, and we analyzed various information reporting
requirements of the 1990 amendments and EPA documents interpreting
requirements of the amendments.  We also analyzed a draft EPA
emissions reporting regulation and compared its reporting
requirements with an EPA emissions reporting options paper examining
several alternative reporting levels.  Further, we evaluated state
and state air pollution association comments on the draft regulation. 
Finally, we reviewed other EPA emission reporting guidance documents
and interviewed EPA, state, and local air pollution officials to
obtain their comments on the draft regulation.  EPA officials
interviewed were from the Information Transfer and Program
Integration Division and the Emissions, Monitoring, and Analysis
Division in the Office of Air Quality Planning and Standards.  State
representatives interviewed were from Arizona, California, Michigan,
New Hampshire, Tennessee, and Wisconsin.  Local officials interviewed
were from Ventura County, California, and the South Coast Air Quality
District, Diamond Bar, California. 

To determine whether states use AIRS to monitor emissions data, we
reviewed early AIRS design and development documents and examined EPA
documents evaluating AIRS Facility Subsystem use by all the states. 
Further, we examined comments and/or analyses provided to EPA by
seven states on their use of AIRS.  We also evaluated original user
requirements and other AIRS documents to determine the original
purpose and anticipated users of AIRS.  In addition, we interviewed
EPA, state, and vendor information system officials on states' use of
AIRS and state information systems.  Vendor representatives
interviewed were from Martin Marietta Technical Services, Inc., and
TRC Environmental Corporation. 

We performed our work at the EPA AIRS program offices in Research
Triangle Park and Durham, North Carolina, and at the AIRS 7th Annual
Conference in Boston, Massachusetts.  Our work was performed from
October 1994 through May 1995, in accordance with generally accepted
government auditing standards.  We requested comments on a draft of
this report from the Administrator of the Environmental Protection
Agency.  In response, on June 29, 1995, we received comments from the
Acting Director for the Office of Air Quality Planning and Standards. 


   PROPOSED REPORTING REQUIREMENTS
   EXCEEDED EPA MINIMUM PROGRAM
   NEEDS
------------------------------------------------------------ Letter :4

EPA's draft regulation on states' reporting of air pollution
emissions exceeded what was needed by EPA to meet minimum agency air
pollution program needs.  EPA has suspended its promulgation of the
regulation and has recently begun studying alternative reporting
options. 

EPA began work on the now suspended emissions regulation in order to
consolidate and standardize several state emissions reporting
requirements (i.e., emission statements, periodic emission
inventories, and annual statewide point source reporting) and to
align these requirements with the mandates in the 1990 amendments. 
Draft versions of the regulation were circulated in late 1993 and
early 1994 to obtain preliminary comments from several states. 

Three states commented to EPA on the draft regulation and one
provided written comments.  This state concluded that the level of
detail required by the proposed regulation was not necessary.  The
state also noted that the draft regulation required data on each
emission point within a plant, rather than aggregate data for each
facility, and on items related to a factory's process and equipment,
such as process rate units, annual process throughput, and typical
daily seasonal throughput.  Further, this state also asserted that
annual reporting of hazardous air pollution emissions, as required by
the draft regulation, is not required by the amendments.  The state
said that because of the additional complexity of toxic air pollutant
data compared to criteria pollutant data, annual reporting to AIRS
would not be feasible. 

In addition, in a letter to EPA addressing several AIRS issues, seven
states also mentioned the draft regulation.  These states said that
the draft regulation would require them to submit more highly
detailed data items into AIRS than called for under the amendments
and other EPA mandated programs.  Further, these states noted that
providing the additional data sought in the draft regulation
concerning hazardous air pollutant emissions would require developing
more complicated toxic chemical databases, which are very costly to
develop.  The states noted that additional resources to develop these
databases were not available. 

EPA acknowledged these concerns and has suspended the regulation.  In
December 1994, EPA issued a study that stated that minimum program
needs could be met with a fraction of the data that would have been
required by the suspended regulation.  Our analysis of the study
revealed that, in one case, EPA only needed to collect about 20
percent of the volatile organic compounds data requested in the
suspended regulation to meet minimum program needs.  The study showed
that, in this case, an estimated 1,323,540 of these data items would
have to be reported by California under the draft regulation, while
only 241,574 data items would be reported under the minimum program
needs option. 

According to representatives in EPA's Emissions, Monitoring, and
Analysis Division, most other states could reduce the amount of data
submitted to EPA by a similar proportion and still meet minimum
program needs.  (See appendix III for additional state examples). 
However, officials in EPA's Office of Air Quality and Standards noted
that while the reduced level of data would meet minimum program
needs, other important data that the agency believes could contribute
to a more effective program would not be collected.  Nevertheless,
collection of these additional data would place an extra burden on
the states.  EPA has now begun reevaluating the information it needs
from states and is considering various reporting alternatives. 


   USE OF AIRS SUBSYSTEM BY HEAVY
   EMISSION STATES IS LIMITED
------------------------------------------------------------ Letter :5

The use of the AIRS Facility Subsystem by heavy emission states for
tracking air pollution emissions is limited.  When AIRS was
originally designed, states were expected to be one of its primary
users; however, most heavy emission states now use their own systems
because these systems are more efficient and easier to use than AIRS. 

The Facility Subsystem is the official repository for emission
inventory, regulatory compliance, and permit data.\9

It contains annual emissions estimates for criteria pollutants and
daily emissions estimates.  The subsystem was developed by EPA to
track, monitor, and assess state progress in achieving and
maintaining national ambient air quality standards and is also used
to report the status of these efforts to the Congress.  It was also
developed to allow state and local air pollution control agencies to
monitor and track emissions and make midcourse adjustments, as
necessary, to achieve air quality standards. 

EPA requires that states submit data to the subsystem either in an
AIRS compatible format or directly to the subsystem.  The states
receive these data from thousands of sources around the country.  For
the 1990 base year inventory, over 52,000 sources reported data
through the states to the AIRS Facility Subsystem.  Each state is to
use these data to help prepare a plan detailing what it will do to
improve the air quality in areas that do not meet national
standards.\10

While all the states must input emission and other data into the
Facility Subsystem, most heavy emission states do not use the
subsystem internally to monitor and analyze emissions and compliance
data.  In many cases, these states already had their own systems to
perform these functions.  Each state's system is customized to that
particular state's program data and reporting needs. 

Of the 10 states\11 that account for almost half of the combined
emissions of the criteria pollutants,\12 only one (Indiana) is a
direct user\13 of the emissions portion of the subsystem.  Further,
of these same 10 states, only 4 (California, Georgia, Indiana, and
Pennsylvania) are direct users of the compliance portion of the
subsystem.  By contrast, a greater proportion of the smaller emission
source states use the Facility Subsystem to manage and analyze air
pollution data.\14 These states do not have their own air pollution
information systems. 


--------------------
\9 The permit portion of the Facility Subsystem is still being
developed. 

\10 The act refers to this plan as the "State Implementation Plan."

\11 The 10 states are California, Florida, Georgia, Illinois,
Indiana, Michigan, New York, Ohio, Pennsylvania, and Texas. 

\12 Comparable data on a state-by-state basis are not available for
lead as they are for the other pollutants because, according to EPA,
the methodology for making such estimates would have been too
resource-intensive to perform.  Since lead emissions constitute a
very small part of total criteria pollutant emissions, their absence
would not affect the analysis. 

\13 Direct users employ AIRS to monitor, track, and manage air
pollution data. 

\14 Of the 43 states (the District of Columbia, Puerto Rico, and the
Virgin Islands are included in this analysis) accounting for the
other half of the emissions, 16 are direct users of the emission
portion and 33 are direct users of the compliance portion of the
subsystem. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :6

In his comments, the Acting Director for the Office of Air Quality
Planning and Standards expressed concern that the primary evidence
supporting our assertion that the proposed reporting requirements
exceeded EPA minimum program needs is based primarily on the written
comments provided by one state.  This is incorrect.  Our finding is
based primarily on our analysis of EPA's December 1994 study, which
also concluded that minimum program needs could be met with a
fraction of the data that would have been required by the suspended
regulation. 

The Acting Director also commented that the report did not adequately
reflect EPA's efforts to respond to the states' concerns.  We believe
that the report makes clear that EPA took action and suspended the
draft regulation based on state concerns. 

Finally, the Acting Director stated that the draft report did not
reflect the success of EPA's regulatory review process and only
focused on an interim finding that EPA addressed by suspending the
regulation.  We believe the report adequately reflects EPA's process
and states' concern with the additional burden that would have been
imposed on them if the draft regulation had been promulgated.  For
example, we note in the report that EPA has recently begun studying
alternative reporting options. 


---------------------------------------------------------- Letter :6.1

We are sending copies of this report to the Administrator, EPA;
interested congressional committees; and the Director, Office of
Management and Budget.  Copies will also be made available to others
upon request. 

Please call me at (202) 512-6253 if you or your staff have any
questions concerning this report.  Major contributors are listed in
appendix IV. 

Sincerely yours,

Joel C.  Willemssen
Director, Information Resources
 Management/Resources, Community,
 and Economic Development


SELECTED ADDITIONAL DATA
COLLECTION MANDATED BY THE CLEAN
AIR ACT AMENDMENTS OF 1990
=========================================================== Appendix I


         1990 AMENDMENT TITLE
----------------------------------------------------- Appendix I:0.0.1

New data requirements


         TITLE I (NONATTAINMENT)
----------------------------------------------------- Appendix I:0.0.2

Expands several existing information collection, storage, and
reporting requirements currently being met by the Aerometric
Information Retrieval System (AIRS).  Thousands of additional
facilities in ozone nonattainment areas will be defined as "major
sources" and will thus be subject to enhanced monitoring,
recordkeeping, reporting, and emissions control requirements. 


         TITLE II (MOBILE SOURCES)
----------------------------------------------------- Appendix I:0.0.3

Expands and revises emission limitations for mobile sources
(automobiles and trucks) of air pollutants.  New standards are
established for motor vehicle engines, fuel content, alternative
fueled vehicles, and other mobile sources.  AIRS was not affected by
these requirements. 


         TITLE III (HAZARDOUS AIR
         POLLUTANTS)
----------------------------------------------------- Appendix I:0.0.4

Creates a program to monitor and control the 189 hazardous air
pollutants.  AIRS is being enhanced to provide a tool for EPA to
develop technology-based standards and, when standards have not been
developed, for state pollution control agencies to make case-by-case
decisions on the best demonstrated control technologies for hazardous
air pollutants within an industry. 


         TITLE IV (ACID DEPOSITION
         CONTROL)
----------------------------------------------------- Appendix I:0.0.5

Establishes a new federal program to control acid deposition.  AIRS
was not affected by these requirements.  The separate Acid Rain Data
System/Emissions Tracking System provides for recording and
validating emissions data from sources emitting sulfur dioxide and
nitrogen oxides, ingredients of acid rain. 


         TITLE V (PERMITS)
----------------------------------------------------- Appendix I:0.0.6

Establishes a new permit program that, in large part, is to be
implemented by the states.  AIRS is being enhanced to accommodate
additional permit program data elements and to merge emissions and
enforcement data. 


         TITLE VI (STRATOSPHERIC
         OZONE PROTECTION)
----------------------------------------------------- Appendix I:0.0.7

Creates a new federal program for the protection of stratospheric
ozone.  Each person producing, importing, or exporting certain
substances that cause or contribute significantly to harmful effects
on the ozone layer must report to EPA quarterly the amount of each
substance produced.  AIRS was not affected by this requirement. 


         TITLE VII (FEDERAL
         ENFORCEMENT)
----------------------------------------------------- Appendix I:0.0.8

Enhances federal enforcement authority, including authority for EPA
to issue field citations for minor violations.  AIRS was enhanced to
collect and report new data concerning administrative, field
citation, and other actions. 


         TITLE VIII
         (MISCELLANEOUS)
----------------------------------------------------- Appendix I:0.0.9

Includes various miscellaneous provisions, including provisions
addressing emissions from sources on the outer continental shelf and
visibility issues.  AIRS was not affected by these provisions. 


         TITLE IX (RESEARCH)
---------------------------------------------------- Appendix I:0.0.10

Requires several national or regional research programs.  Most of the
research programs require air data that can be integrated with data
from other media or from other systems.  This may require system
modification. 


AIRS ESTIMATED COMBINED
DEVELOPMENT AND OPERATIONAL COSTS
========================================================== Appendix II

                    (Dollars in millions)


                                        Area
                         Air     Air     and
                      qualit  facili  mobile  Other\
Fiscal year                y      ty  source       b   Total
--------------------  ------  ------  ------  ------  ------
1984                   $ 0.8     n/a     n/a   $ 1.4   $ 2.2
1985                     0.8   $ 0.3     n/a     1.4     2.5
1986                     0.8     0.3     n/a     1.4     2.5
1987                     0.8     0.5     n/a     1.4     2.7
1988                     0.8     1.0     n/a     1.4     3.2
1989                     0.8     1.3   $ 0.9     1.4     4.4
1990                     0.8     3.4     0.9     1.4     6.5
1991                     0.8     1.6     1.3     1.7     5.4
1992                     0.9     2.3     1.3     1.9     6.3
1993                     0.9     2.1     1.2     1.8     6.0
1994                     0.8     2.4     0.8     2.0     5.9
1995                     0.6     2.4     0.1     2.0     5.1
============================================================
Total                  $ 9.4   $17.5    $6.5   $19.3   $52.6
------------------------------------------------------------
Legend: n/a = not applicable.

Notes:  We did not verify the accuracy of these figures.

Columns and rows may not total precisely due to rounding. 

\a Costs include software development and maintenance, EPA computer
time, and EPA personnel costs. 

\b For fiscal years 1991 through 1995, other costs include the
Geo-Common Subsystem, a graphics program; new technology; and
miscellaneous items, such as a bulletin board and conferences.  These
costs, where applicable, were allocated to the subsystems for fiscal
years 1984 through 1990.  For all fiscal years, other costs also
include charges for telecommunications, state computer time, and
on-line disk storage. 


COMPARISON OF ESTIMATED DATA ITEMS
TO BE REPORTED
========================================================= Appendix III


                                                       Draft
                                      Minimu   regulation as
                               Draft       m   percentage of
                              regula  requir         minimum
State                           tion      ed         program
----------------------------  ------  ------  --------------
California                    1,323,  241,57           547.9
                                 540       4
Delaware                      100,79  22,541           447.2
                                   6
Missouri                      442,89  97,982           452.0
                                   2
============================================================
Total                         1,867,  362,09           515.7
                                 228       7
------------------------------------------------------------
Source:  GAO analysis of EPA's Emission Data Reporting Options,
December 1994. 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix IV

ACCOUNTING AND INFORMATION
MANAGEMENT DIVISION, WASHINGTON,
D.C. 

Ronald W.  Beers, Assistant Director
George Vindigni, Evaluator-in-Charge

LOS ANGELES FIELD OFFICE

Allan Roberts, Assistant Director
Barbara Y.  House, Senior Evaluator


*** End of document. ***