Air Pollution: Implementation of the Clean Air Act Amendments of 1990
(Testimony, 05/17/2000, GAO/T-RCED-00-183).

GAO discussed the Environmental Protection Agency's (EPA)
implementation of the Clean Air Act Amendments and on sources regulated
by multiple provisions of the act, focusing on: (1) the status of EPA's
implementation of requirements established by the 1990 amendments; (2)
the views from the stakeholders--state governments, local programs,
industries that are regulated under the act, and environmental advocacy
groups--on the issues that either helped or hindered the implementation
of the 1990 amendments; (3) examples of emission sources subject to
regulation under more than one Clean Air Act program; and (4) the status
of EPA's efforts to facilitate compliance for such sources.

GAO noted that: (1) as of February 2000, EPA had completed the majority
of the 538 required actions it identified under the 1990 amendments'
first six titles, but not all the requirements were met within the
statutory deadlines; (2) EPA missed the statutory deadlines for 198 of
the 247 requirements with deadlines by February 2000, and will likely
miss 62 of the 108 future statutory requirements with deadlines; (3) EPA
officials attributed the agency's inability to meet its statutory
deadlines to: (a) its increased emphasis on obtaining stakeholders'
review and involvement during the development of regulations, which
added to the time needed to issue regulations; and (b) technical,
policy, or legal issues that were not fully anticipated in 1990; (4)
number of stakeholders expressed the view that flexibility in the
amendments has helped their implementation; (5) stakeholders cici cited
the specificity of goals and requirements as helpful; (6) stakeholders
cited inadequate resources at the state and local levels to effectively
implement and enforce the amendements as a factor that has hindered
implementation; (7) the large industrial complexes operated by the
petrochemical and refinery, chemical manufacturing, and electric power
industries are prime examples of sources regulated under multiple Clean
Air Act programs; (8) EPA has embarked on a number of initiatives to
reduce the regulatory workload and facilitate compliance for such
facilities, these including both industry-specific efforts and other
generic approaches, to introduce more flexibility in the overall
regulatory rule making and permitting processes; (9) the Consolidated
Air Regulation and the Clean Air Power Initiative; (10) the consolidated
Air Regulation is intended to incorporate all federal air regulations
that affect the synthetic organic chemical manufacturing industry into a
single set of regulations; (10) this proposed regulation, currently
pending approval by the Office of Management and Budget, would reduce
the regulatory burden and enhance enforceability by having one set of
emissions controls and monitoring, record keeping and reporting
requirements; (11) the Clean Air Power Initiative is an effort to
develop new regulatory approaches for controlling nitrogen oxide and
sulfur dioxide from electric power plants; and (12) according to EPA and
industry officials, efforts on this initiative have been suspended
because of disagreement within the industry as well as within EPA over
the appropriate level for proposed sulfur dioxide and nitrogen oxide
reductions.

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

 REPORTNUM:  T-RCED-00-183
     TITLE:  Air Pollution: Implementation of the Clean Air Act
             Amendments of 1990
      DATE:  05/17/2000
   SUBJECT:  Intergovernmental relations
             Environmental law
             Industrial pollution
             Air pollution control
             Environmental policies
             Reporting requirements
             Regulatory agencies
             Pollution monitoring
             Noncompliance
             Federal regulations
IDENTIFIER:  EPA Common Sense Initiative
             EPA Clean Air Power Initiative
             EPA Consolidated Air Regulation

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GAO/T-RCED-00-183

Testimony

Before the Subcommittee on Clean Air, Wetlands, Private Property, and
Nuclear Safety, Committee on Environment and Public Works, United State
Senate

For Release on Delivery

Expected at 9:30 am, EDT,
Wednesday, May 17, 2000

AIR POLLUTION

Implementation of the Clean Air Act Amendments of 1990

Statement of David G. Wood, Associate Director

Environmental Protection Issues

Resources, Community, and Economic Development Division

GAO/T-RCED-00-183

Mr. Chairman and Members of the Subcommittee:

I am pleased to be here today to discuss issues concerning the
implementation of the Clean Air Act, a comprehensive federal law that
regulates air emissions from stationary and mobile sources. The act was last
reauthorized and amended by the Congress in 1990. Those
amendments-particularly the first six titles of the law-require the
Environmental Protection Agency (EPA) to take a number of actions such as
issuing new regulations and guidance documents, undertaking research
studies, and preparing reports for the Congress. The amendments established
statutory deadlines for many of these actions.

As you requested, my testimony today will focus on EPA's implementation of
the Clean Air Act Amendments and on sources regulated by multiple provisions
of the act. Specifically, I will discuss (1) the status of EPA's
implementation of requirements established by the 1990 amendments; (2) the
views from stakeholders--state governments, local programs, industries that
are regulated under the act, and environmental advocacy groups--on the
issues that have either helped or hindered the implementation of the 1990
amendments; (3) examples of emission sources subject to regulation under
more than one Clean Air Act program; and (4) the status of EPA's efforts to
facilitate compliance for such sources. This testimony is based on our April
report and ongoing work for this Subcommittee that relates to emission
sources affected by multiple provisions of the act. We will issue a report
on the latter work this month.

In summary, we found the following:

   * As of February 2000, EPA had completed the majority of the 538 required
     actions it identified under the 1990 amendments' first six titles.
     However, not all the requirements were met within the statutory
     deadlines: EPA missed the statutory deadlines for 198 of the 247
     requirements with deadlines by February 2000, and will likely miss 62
     of the 108 future statutory requirements with deadlines (primarily
     requirements to establish new standards for certain hazardous air
     pollutants). EPA officials attributed the agency's inability to meet
     its statutory deadlines to (1) its increased emphasis on obtaining
     stakeholders' review and involvement during the development of
     regulations, which added to the time needed to issue regulations, and
     (2) technical, policy, or legal issues that were not fully anticipated
     in 1990.

   * Stakeholders provided a variety of views on the issues that have helped
     or hindered the implementation of the six titles. A number of
     stakeholders expressed the view that flexibility in the amendments has
     helped their implementation; for example, the trading system for sulfur
     dioxide emissions, under which utilities that reduce their emissions
     below required levels may sell their allowances to other utilities to
     help them meet their requirements. This allows electric utilities to
     achieve required sulfur dioxide emissions reductions at a lower cost.
     Also, stakeholders cited the specificity of goals and requirements as
     helpful; for example, the title dealing with stratospheric ozone
     depletion listed the affected chemicals and the dates for their
     eventual phase-out. Stakeholders cited inadequate resources at the
     state and local levels to effectively implement and enforce the
     amendments as a factor that has hindered implementation.

   * The large industrial complexes operated by the petrochemical and
     refinery, chemical manufacturing, and electric power industries are
     prime examples of sources regulated under multiple Clean Air Act
     programs. For example, the emissions of nitrogen oxides from electric
     power plants are controlled under six programs, including those for
     controlling acid rain, ground-level ozone, and fine particles and
     programs for improving visibility. In addition, petrochemical
     refineries are regulated under five different titles of the 1990
     amendments, and individual chemical plants may be regulated by as many
     as seven different statutorily authorized programs. Additional state
     and local requirements may also apply to the same industrial emissions
     sources.

   * EPA has embarked on a number of initiatives to reduce the regulatory
     workload and facilitate compliance for such facilities. These include
     two industry-specific efforts and other generic approaches, such as
     establishing total plant-wide emissions limits, to introduce more
     flexibility in the overall regulatory rule making and permitting
     processes. EPA's two industry-specific efforts are the Consolidated Air
     Regulation and the Clean Air Power Initiative. The Consolidated Air
     Regulation is intended to incorporate all federal air regulations that
     affect the synthetic organic chemical manufacturing industry into a
     single set of regulations. This proposed regulation, currently pending
     approval by the Office of Management and Budget, would reduce the
     regulatory burden and enhance enforceability by having one set of
     emissions controls and monitoring, record keeping, and reporting
     requirements. The Clean Air Power Initiative is an effort to develop
     new regulatory approaches for controlling nitrogen oxide and sulfur
     dioxide from electric power plants. According to EPA and industry
     officials, efforts on this initiative have been suspended because of
     disagreement within the industry as well as within EPA over the
     appropriate level for proposed sulfur dioxide and nitrogen oxide
     reductions.

Background

The Clean Air Act, enacted in 1963 and substantially overhauled in 1970, is
a comprehensive federal law that regulates air emissions from stationary and
mobile sources. This law authorizes EPA to, among other things, establish
National Ambient Air Quality Standards to protect public health and welfare.
In large part, the 1990 amendments to the Clean Air Act were intended to
meet unaddressed or insufficiently addressed problems. The major provisions
of the amendments are contained in the first six titles.

   * Title I of the 1990 amendments establishes a more comprehensive
     approach for states to implement, maintain, and enforce the National
     Ambient Air Quality Standards.

   * Title II contains provisions for controlling air pollution from motor
     vehicles, engines, and their fuel.

   * Title III establishes new requirements to reduce the emissions of
     hazardous air pollutants (often called "air toxics") that are known or
     suspected of causing cancer or other serious health effects.

   * Title IV establishes the acid deposition control program to reduce the
     adverse effects

of acid rain by reducing annual emissions of pollutants, which are
precursors of acid rain.

   * Title V establishes a national permit program to ensure compliance with
     all applicable requirements of the act and to enhance EPA's and the
     states' ability to enforce the act. Title V requires the states to
     establish permit programs.

   * Title VI establishes provisions to protect the stratospheric ozone
     layer.

Each of these titles requires EPA to, among other things, promulgate
regulations, publish final guidance for state air pollution control
programs, and issue various research reports to the Congress. Most of the
requirements involve promulgating regulations to implement the act. Once the
regulations are promulgated, it is generally up to state and local air
pollution control agencies to enforce their provisions, with oversight from
EPA.

 Status of EPA's Implementation of the

 Clean Air Act Amendments of 1990

While EPA has completed the majority of the actions required by the 1990
amendments, it has not done so in accordance with all statutory deadlines.
EPA missed the statutory deadlines for 198 of the 247 requirements with
deadlines by February 2000. Furthermore, according to EPA officials, it is
unlikely that the agency will meet the deadline for 62 of the 108 remaining
statutory requirements (primarily requirements to establish new standards
for certain hazardous air pollutants). Specifically, the officials do not
believe they will meet the November 15, 2000, deadline for establishing
standards for hazardous air pollutants.

EPA officials cited several factors explaining why the agency has missed
deadlines including: (1) its increased emphasis on obtaining stakeholders'
review and involvement during regulatory development, which added to the
time needed to issue regulations; (2) the setting of priorities to manage
the work load resulting from the 1990 amendments, which created a tremendous
number of new responsibilities for EPA; (3) complications associated with
the startup and effective implementation of new programs (e.g., operating
permits and air toxics), which posed technical, policy, or legal issues that
were not fully anticipated in 1990; (4) competing demands caused by the work
load associated with EPA's response to lawsuits challenging some of its
rules; and (5) the emergence of new scientific information and other factors
that led to major Clean Air Act activities that did not arise from the 1990
amendments, such as the effort to reduce the regional transport of ozone
pollution throughout the East.

It is important to recognize that in terms of their ultimate impact on the
environment, all requirements are not equal. For example, a requirement that
EPA issue a rule on monitoring a limited number of stationary sources in a
single industry has neither the complexity nor the impact of a provision
that requires dozens of states to submit implementation plans to attain a
major national ambient air quality standard. The latter is inherently more
difficult to accomplish and often requires states and local agencies to pass
legislation and issue, adopt, and implement rules. Certain programs are
implemented largely by states and require extensive, continuing interaction
between EPA and the nation's governors, state legislators, county officials,
state and local regulators, and others on numerous complex requirements
while others are implemented solely by EPA.

Views of Key Stakeholders on Major Issues Affecting

Implementation of the Clean Air Act Amendments of 1990

The stakeholders we interviewed from environmental groups, industrial
groups, and state and local governments stated that the Clean Air Act
Amendments of 1990 have had positive effects on the environment by reducing
pollutant emissions. However, the stakeholders had differing views on the
issues that either helped or hindered the effective implementation of
specific provisions.

Extent of Flexibility in Meeting Requirements

One of the overarching issues affecting implementation cited by stakeholders
is the tension between allowing states and sources of pollution the
flexibility to develop their own approaches for achieving air quality
improvements and using a more prescriptive "command and control" approach.
For example, the title IV acid rain program, as designed by the Congress and
implemented by EPA, attempted to strike a balance between traditional
command and control principles-which specify where and how emissions
reductions must be achieved-and the flexibility of market-based measures for
reducing air pollution. Specifically, this program uses a market-based
approach to allow electric utilities to trade sulfur dioxide allowances with
other utilities. Utilities that reduce their emissions below the required
level can sell their extra allowances to other utilities to help them meet
their requirements. Stakeholders from environmental and industrial groups
and state and local governments told us that the flexibility provided by the
acid rain program's sulfur dioxide emissions allowance-trading system
enabled the required emissions reductions to be achieved at a lower cost
than that estimated at the time the amendments were passed. Other
stakeholders pointed out that because the legislation specified the
reduction goals and identified the power plants that were required to
achieve these reductions, the program was administratively more efficient to
implement.

According to some stakeholders, adopting more market-based approaches like
the acid rain program is a particularly effective way of achieving greater
flexibility. In their view, this program has shown that an aggregate "cap"
on emissions, which permits individual sources to trade allowances, can lead
to lower-cost emissions reductions than those under the traditional command
and control approach used in other programs. EPA officials agreed that the
"cap and trade" approach can reduce emissions at a lower cost (and, in some
cases, reduced pollution levels as well) than those under a traditional
command and control approach. However, they pointed out that to work
effectively, cap and trade programs traditionally require a well-known
population of sources with extremely well-characterized emissions and
control costs. According to EPA, in some circumstances, other forms of
economic incentive programs and approaches (e.g., open market trading and
emission fee programs) can be added to the existing regulatory structure and
can provide incentives for reductions from other source categories when
accountability is adequate. For this reason, EPA has issued rules and
guidance that allow states and other stakeholders to consider a variety of
economic incentive approaches to both reduce costs and gain improved
environmental quality.

Specificity of Requirements

Several stakeholders identified the specificity in the amendments or in
implementing regulations as an important factor affecting implementation.
For example, according to a state and local government organization,
specifying the amount of sulfur dioxide emissions reductions to be achieved
and the specific power plants where the reductions were to come from made it
easier to achieve the required reductions in sulfur dioxide emissions. The
stratospheric ozone provisions of title VI-which specify the affected
chemicals and the time frames for their eventual phase out-were also cited
by stakeholders as an example of successful implementation.

Adequacy of Funding

The states, state organizations, and environmental groups that we
interviewed all commented that state and local governments need additional
funding to more effectively implement the requirements of the amendments.
According to a director of an organization that represents all state and
local governments, there is currently a $140 million annual shortfall in
funds for implementation of the Clean Air Act at the state and local
government levels.

EPA awards grants to the states and local government agencies to help them
implement the amendments. However, the agency has reduced this funding over
the last several years by 25 percent, to $120 million annually. According to
a state and local government organization, EPA justified the decrease by
considering the funding available to states and local air pollution control
agencies through permit fees (which are assessed on regulated sources for
permits required by the Clean Air Act). However, according to a stakeholder
representing an environmental group, there is a scarcity of funds from
permits because states have been under pressure to keep the fees low. EPA
officials stated that they work jointly with states and local agencies to
establish priorities on the basis of available funding and, through work
plan negotiations for grants, have been successful in directing grant funds
toward agreed-upon priorities.

Examples of Sources Subject to Multiple
Clean Air Act Regulatory Programs

Because the act is structured to address different aspects of the nation's
air pollution problems, some sources are regulated by more than one
statutory program. For example, industrial emissions sources such as
petroleum refineries, chemical manufacturing facilities, and electric power
plants are sometimes regulated under multiple provisions of the act and
numerous associated federal air regulations.

Petrochemical and Refinery Industry

Petrochemical and refinery facilities are regulated under all of the first
five titles of the 1990 amendments and a multitude of EPA regulations
designed to implement the legislative provisions. In addition to the large
number of existing air regulations, the industry is faced with planning and
implementing measures to comply with a host of new requirements beginning in
2000.

According to industry officials, efforts to comply with one program by
controlling emissions of a pollutant from a single facility may have the
unintended effect of increasing emissions of other pollutants from elsewhere
in the same facility. For example, title II requires the petroleum industry
to reduce sulfur levels in gasoline to help produce cleaner fuels for motor
vehicles. Producing these cleaner fuels, however, requires changes in the
refining process that may increase the emissions of other pollutants
including such hazardous air pollutants as benzene, formaldehyde, and
mercury from emission points within the refineries.

EPA officials told us that while they do not expect this to occur at all
refineries, it could occur at some. According to the officials, this case
illustrates how separate requirements can serve different, but equally
important purposes. The low-sulfur gasoline requirements will work
nationwide to help ensure that air quality improves significantly in areas
where mobile sources are a primary source of pollution. On the other hand,
permitting requirements for statutory sources ensure that an individual
facility's emission increases do not contribute to a local air quality
problem.

Chemical Manufacturing Industry

Within chemical manufacturing facilities, individual emission sources such
as storage tanks may be subject to four or five different regulatory
programs. At any given facility, all or part of the following-in addition to
obtaining title V operating permits-may apply: (1) meeting standards for new
source construction permitting, (2) reducing the emissions of hazardous air
pollutants, (3) meeting new source performance standards, and (4) complying
with visibility protection requirements.

According to industry officials, the act's regulatory process is an
especially complex system and it is not always clear which emission
reduction requirements are applicable to a specific source. For example, the
emissions of pollutants known as volatile organic compounds (VOC's) are
subject to regulation under title I of the 1990 amendments, but some are
also considered to be hazardous air pollutants, which are regulated under
title III. Thus, the same facility may be subject to meeting regulatory
requirements associated with each title. According to industry officials, in
some cases, EPA has recognized the title III requirement (under which the
source must meet emissions levels associated with maximum achievable control
technology standards) as the most stringent, and so the VOC emissions
control requirements are considered to be satisfied through demonstrated
compliance with the technology standards. According to an industry official,
however, EPA has, in some situations, required that facilities report or
demonstrate compliance with both emissions reduction requirements.

Electric Power Industry

Electric-power-generating facilities may be subject to more than a dozen
federal air regulations and initiatives that have different objectives, time
frames, and compliance requirements. For example, the emissions of nitrogen
oxides from power plants are subject to regulation under several title I
programs, including (1) the national ambient air quality standards program,
(2) the new source review program for minimizing air pollution from large
new stationary sources; and (3) the visibility improvement program. Nitrogen
oxides emissions are also controlled under the title IV acid deposition
program, which is targeted at specific electric utility plants. According to
industry officials, some of the regulations affecting the same air
pollutants and emissions sources can make it difficult for the industry to
accurately determine the applicability of each of the requirements and to
develop effective emissions control strategies.

EPA Efforts to Address Sources Affected

by Multiple Clean Air Act Requirements

Recognizing that individual facilities are regulated under multiple
programs, EPA has undertaken initiatives to reduce the regulatory workload
and facilitate compliance for such facilities. These include two
industry-specific efforts--the Consolidated Air Regulations and the Clean
Air Power Initiative--and several generic approaches to introduce more
flexibility and stakeholder involvement in the rulemaking and permitting
processes.

Consolidated Air Regulations

One of the administration's initiatives aimed at reinventing environmental
regulations was to consolidate federal air regulations, so that all federal
air requirements for an industry would be incorporated into a single set of
regulations. EPA used the regulations applicable to the synthetic organic
chemicals manufacturing industry for its pilot study of the feasibility of
consolidating and streamlining existing federal air quality regulations. The
synthetic organic chemical manufacturing industry was selected for the pilot
because of the large number of air regulations that apply to the industry's
facilities and the similarity in many of the requirements in the existing
regulations. The resulting single set of regulations, which incorporates all
of the applicable requirements for 16 different air regulations that affect
the industry, is referred to as the Consolidated Air Regulations.
Participation in the consolidated regulations by facilities will be
voluntary; facilities may choose to continue being regulated under the 16
separate regulations or the consolidated regulations. EPA's objectives are
to (1) reduce the regulatory burden, (2) facilitate implementation and
compliance, and (3) ensure the continued environmental protection and
enforceability of the regulations. Proposed by EPA in October 1998, the
consolidated regulations are currently being reviewed by the Office of
Management and Budget.

The Consolidated Air Regulations are intended to maintain the current levels
of health and environmental protection benefits currently afforded by the 16
existing regulations and also to ensure the same degree of emission controls
as the existing regulations do or a greater degree than they do. However,
the level of human health and environmental protection may be greater in
some instances because the regulations will require some facilities (that
choose the consolidated regulations) to meet more stringent emissions
reductions or requirements.

Because of the reduced burden afforded by the Consolidated Air Regulations,
some sources are expected to elect to comply with the consolidated
regulations despite the more stringent requirements. However, according to
EPA officials, it is unclear at this time how many of the synthetic organic
chemical manufacturing facilities will elect to participate because the
consolidated regulations requirements may require some to achieve larger
emissions reductions than they are currently required to meet under the
older air regulations. EPA officials acknowledge that progress has been
slower than expected because of difficulties in getting the chemical
industry to agree on specific environmental protection requirements in the
consolidated regulations and their reluctance to accept the more stringent
emission reductions.

Clean Air Power Initiative

The concerns about the electric power generating industry's costs to control
multiple pollutants under several provisions of the Act added by the 1990
amendments prompted EPA to initiate the Clean Air Power Initiative (CAPI).
In consultation with electric power industry representatives, EPA developed
an integrated regulatory strategy for sulfur dioxide and nitrogen oxides
emitted from power plants. The purpose of this collaborative effort was to
seek new approaches to pollution control that would improve public health
and the environment but simultaneously cost less and reduce the number and
complexity of current and expected requirements. EPA began the CAPI in 1995
by meeting with interested stakeholders to discuss more cost-effective
alternatives to pollution control and developing a model that could analyze
the costs and emissions implications of different reduction scenarios for
sulfur dioxide and nitrogen oxides.

However, the lack of complete support within the electric power industry
ended the initial effort in late 1996 without agreement, according to EPA
officials. Some stakeholders believed that the controls suggested under the
CAPI were not desirable or cost-effective, according to an EPA official,
because they had not yet been required through rule making. According to
officials at Edison Electric Institute, the initiative ended because (1)
there was substantial disagreement over the science underlying EPA's
proposed new controls for sulfur dioxide and nitrogen oxides; (2) EPA could
not provide any regulatory certainty should a program be mutually agreed to;
and (3) certainty could result only from amending the act, which neither
stakeholder wanted to pursue.

In late 1998 and throughout 1999, EPA staff participated in the Edison
Electric Institute Air Quality Integration Dialogue at which EPA and
industry staff explored an integrated approach for controlling pollution
from the electric power industry. The dialogue had broad industry
participation as well as EPA staff participation. The White House Climate
Change Task Force also attended these meetings. The Dialogue was intended to
promote a free exchange of ideas and analysis at a staff level concerning
new or potentially upcoming regulatory actions to address air emissions of
sulfur dioxide, nitrogen oxides, carbon dioxide, and mercury.

EPA continues to believe that over the next several years, it will probably
be necessary for the power industry to achieve large reductions of sulfur
dioxide and nitrogen oxides. According to agency officials, there continues
to be considerable interest in developing an integrated approach to address
cost-effective strategies for implementing multiple air regulations. EPA has
had a number of follow-up discussions and expects to continue interactions
with industry representatives on this topic.

Other Initiatives to Address
Multiple Regulation Issues

In addition to the Consolidated Air Regulations and the Clean Air Power
Initiative, EPA has developed other regulatory approaches to provide
industry with more flexibility to achieve the necessary reductions in air
pollution, while still providing accountability for the results. For
example, EPA allows facilities to average the emissions from all emissions
points and to use trading programs in order to provide more flexibility in
how and where an industrial facility chooses to reduce its air emissions. In
some cases, EPA has set plant wide limits that control total emissions that
are allowed to be released from an individual plant. These efforts provide
latitude to industries in choosing how and where to reduce emissions.

EPA has also worked with individual industries to eliminate duplicating or
overlapping regulatory requirements. For example, EPA worked with industry
organizations, such as aerospace and shipbuilding and coating operations, to
set limits for VOCs and toxic air pollutants and with the pharmaceutical
industry to give it more flexibility in complying with new source
performance standards for storage tanks.

Furthermore, EPA and various stakeholders began, in 1993, to identify
opportunities for developing "cleaner, cheaper, smarter" environmental
protection strategies that were tailored toward environmental protection and
would consider the unique circumstances of different industries. EPA, along
with states, environmental and public interest groups, and the environmental
justice community worked with six industries--petroleum refining, printing,
iron and steel, computer and electronics, metal finishing, and auto
manufacturing--to find better ways to manage environmental responsibilities.
With the completion of the Common Sense Initiative-one of EPA's efforts to
"reinvent" environmental regulation-EPA is applying the lessons learned to
other sections of the act.

- - - -

Mr. Chairman, this concludes my prepared statement. I would be pleased to
respond to any questions you may have.

Contact and Acknowledgements

For further information regarding this testimony, please contact David G.
Wood at (202) 512-6111. Individuals making key contributions to this
testimony included William McGee, Harry Everett, Odell Pace, and Karen
Keegan.

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