Air Resources Management

Program Guidance

Basic Air Resource Management Questions

Several basic questions provide a useful investigative method for analyzing and understanding air pollution problems and their potential consequences for park resources. These basic questions relate to the types of air pollutants of greatest concern, the sources of these pollutants, and the potential effects on park resources. If park or regional staff begin to gather the data necessary to answer these questions, the process of defining the problem and determining appropriate action can be facilitated.

1. Which resources, if any, are known to be, or potentially may be, affected by the pollutant? What are those effects?

2. What are the current and/or projected levels of the pollutant in the ambient air?

3. Are the measured or projected pollutant levels high enough to cause effects?

4. How will the pollutant affect the protected resources, the ecosystem, or visitor enjoyment?

5. What is the source(s) of the pollutant?

6. What can be done to control or mitigate the pollutant's emissions and effects (including legal and regulatory options)?

NPS Air Quality Activities

The following general discussion of major NPS air quality related activities help provide answers to these basic questions. The activities include internal programs, such as monitoring (criteria pollutants, visibility, and ecological effects), modeling, park operations and planning, and interpretation; and external (interagency) programs, such as resource management planning, review of industrial development plans and air pollution permit applications, legislative and regulatory development, participation in the State Implementation Plan process, park redesignation, and participation in regional air quality forums. The roles and responsibilities of various offices and individuals are briefly discussed and described under Roles and Responsibilities, below.

Internal NPS Activities

Internal air resource management activities are those in which NPS personnel are the primary participants and the activities are primarily confined to parks. Field staff have initial responsibility for identifying a need for such activities, although servicewide initiatives and Congressional mandates are also likely to affect the nature, extent, and duration of activities undertaken in some parks. Regional offices establish priorities on a regionwide basis, and the Air Resources Division has responsibility for maintaining an effective and efficient servicewide air quality program and otherwise ensuring compliance with statutory and regulatory requirements. NPS employees at all levels of the organization are responsible for ensuring incorporation of NPS environmental leadership and sustainability principles into their daily work efforts, including planning, park operations, and concessions management.

Inventory and monitoring of air quality related values

Air quality and related values are monitored in NPS units for several reasons. The primary objectives of monitoring are to:1. establish existing or baseline concentrations of air pollutants in NPS units,2. assess trends in air quality in NPS units,3. judge compliance with the NAAQS,4. assist in the development and revision of national and regional air pollution control policies that might affect parks,5. provide data for atmospheric model development and evaluation,6. correlate existing effects on park resources with existing air quality levels, and7. provide meaningful input when commenting on proposed new sources of air pollution.Some of these objectives are satisfied by long-term monitoring at selected NPS sites nationwide; others may require that park-specific data be collected for a shorter time. In addition to monitoring specific pollutants in the air, meteorological monitoring is often conducted, because it can help explain monitored concentrations and is useful for modeling evaluations. The following meteorological parameters are typically measured at these stations: wind speed and direction, temperature, dew point, solar radiation, and precipitation. The following section of the reference manual provides a general summary of monitoring objectives, requirements, and data uses.

1. Ambient air quality monitoring: Gaseous pollutantsTwo gaseous criteria pollutants, ozone and sulfur dioxide, are particularly toxic to native plant species found in NPS units. These pollutants are known to be harmful to vegetation even at levels below the NAAQS established by the EPA. Ozone, which forms when volatile organic compounds and nitrogen oxides interact in the presence of sunlight, can be transported long distances in the atmosphere and thus is often an areawide problem. In general, ozone concentrations are higher during the summer months. Because of high ozone levels in most urban areas throughout the nation, ozone levels in many NPS units are also high enough to adversely affect human health. Sulfur dioxide is more likely to be a localized problem affecting individual parks close to a source. The EPA has established reference and equivalent methods for the measurement of air pollutants for which NAAQS have been established. (See 40 CFR 53 and 58.) The EPA requires the use of this methodology by federal, state, and local agencies that wish to use the measurement data for regulatory purposes, such as determining the attainment status of an area with respect to these standards. Because the NPS is involved in numerous regulatory arenas at the state and national level requiring the use of measurement data comparable to those collected by state and federal agencies, the NPS relies on the sampling methodology specified by the EPA. Any criteria pollutant monitoring conducted in NPS units must conform to EPA requirements.In order to ensure compliance with EPA requirements, including quality assurance and quality control requirements, the Washington Office Air Resources Division has responsibility for coordination and supervision of the NPS gaseous pollutant monitoring network. Site field operations are carried out in one of four ways. Generally, NPS park personnel are trained to operate and maintain the monitoring equipment, perform routine quality control checks, and calibrate the instruments. The NPS can also enter into cooperative agreements with state or local agencies to obtain some level of support ranging from total operation to assistance for NPS site operators. Where it is not possible to obtain site operations support from the park, state, or local agencies, NPS monitoring support contractors will assume this responsibility by hiring and training a local person to function in this capacity. Finally, some monitoring sites located in NPS units are funded and operated by the respective state or local agencies. The collection of scientific data requires that procedures be developed to ensure that the data are sound and defensible. The Air Resources Division adheres to this philosophy and takes the necessary steps to ensure that the data are valid and comparable to those collected by other federal, state, and local air pollution control agencies. The Air Resources Division has implemented a quality assurance program that meets EPA requirements, including written standard operating procedures for equipment and site operations, a servicewide training program, and a schedule of external quality assurance performance and system audits. A minimum of one performance and system audit is conducted at each site to supplement any audits currently being performed by state and local agencies.2. Visibility monitoringScenic resources are extremely sensitive to air pollution. Even a very small amount of fine particulate matter (less than 2.5 microns in diameter, or one tenth the diameter of a human hair) in the air can affect the ability to perceive colors, contrast, texture, and form of features, landmarks, and panoramas. Visual air quality is very important to park visitors. Specific vistas are often mentioned in legislation or Congressional reports concerning the establishment of an NPS unit. Visibility in mandatory Class I areas is also specifically protected by the Clean Air Act, and the NPS is required to be involved in decisions made by other agencies if visibility in a Class I area might be affected. Therefore, the NPS conducts visibility monitoring and research to provide managers with the tools, methods, and data needed to manage and protect visibility in the parks.

Visibility monitoring provides information about current visibility conditions at the parks, and, over time, can be used to assess trends. When optical monitoring (using instruments such as nephelometers or transmissometers) is combined with aerosol monitoring (using fine particle samplers), information about the composition of the particles in the air associated with visibility impairment can be obtained. This information can be used to help determine how much of the observed visibility impairment is human-caused and how much is natural. Analysis of the monitoring data and research on the transport and transformation of pollutants in the air helps to identify the urban and industrial areas that cause or contribute to visibility impairment. Visibility monitoring is conducted primarily in Class I areas, but should also be considered in response to a particular visibility problem, or if visual air quality is an especially important value at a park, or if the park is situated along an important pollution transport pathway. The Air Resources Division has servicewide responsibility for the NPS visibility monitoring and research program, including data analyses and reporting on a routine basis. The Air Resources Division should be consulted to determine whether and how visibility should be monitored in a specific park. Regional offices help set priorities for visibility monitoring and special project requests submitted by parks. Park staff provide substantial assistance in operating and maintaining visibility monitoring equipment.The EPA has not yet established reference methods for visibility monitoring, but the NPS is currently cooperating with the EPA, states, and other federal agencies to develop and test such methods through the Interagency Monitoring of Protected Visual Environments (IMPROVE) program. Many NPS-managed Class I areas are part of the IMPROVE network, which was established to meet regulatory needs and is managed by a committee composed of the EPA, states, NPS, U.S. Fish and Wildlife Service, U.S.D.A. Forest Service, and Bureau of Land Management. 3. Ecological effects monitoringAir pollution also affects ecological and biological resources. The Air Resources Division works closely with parks, regions, the EPA, and the U.S. Geological Survey on ecological effects research. The Air Resources Division assists with identification of research needs, provides advice on research projects, and helps ensure that products will enhance our air quality protection efforts. The Air Resources Division's ecological effects program monitors (1) the effects of gaseous pollutants on terrestrial vegetation and (2) the effects of acidic compounds (e.g., nitrate and sulfate) on aquatic chemistry and associated biota.

Vegetation effects monitoring activities are designed to:

• determine the sensitivity of native plants to different air pollutants,
• identify air pollution impacts on sensitive plants, and
• establish baseline conditions of plants and monitor trends in NPS ecosystems.

Vegetation effects surveys and dose-response research to determine symptoms are recommended in parks that either have existing high pollution levels or have a high likelihood of pollution levels increasing to harmful levels in the future. Parks should contact the Air Resources Division regarding the advisability of conducting vegetation injury surveys or dose-response studies. Air Resources Division can also advise park staff on the species that should be examined and how the monitoring should be conducted.

Similarly, deposition and effects monitoring is designed to:

• monitor deposition of pollutants of concern,
• determine the sensitivity of lakes or streams to deposition,
• establish baseline conditions of surface waters and monitor trends in surface water chemistry, and
• determine existing and potential effects of changes in water chemistry on aquatic biota.

Surface waters that are sensitive to acidification often have particular physical characteristics. The lakes or streams occur at moderate to high elevation, in areas of high relief. The bedrock and associated soils of the watersheds do not weather easily, so the soils don't release many base cations to buffer acidic input. Sensitive streams are low order, i.e., small headwater streams. Sensitive lakes are either small drainage systems or small seepage systems that derive much of their hydrologic input as direct precipitation to the lake surface. If such conditions exist in a park, and acid deposition is of concern, surface water chemistry monitoring should be considered.

Air quality modeling

An air quality model is the mathematical representation of the physical and chemical processes by which air pollutants are emitted into, dispersed, transported, and transformed in the atmosphere and deposited onto a surface. Air quality modeling is used in situations in which estimates of total air pollution exposure are desired and air pollution monitoring data are not available (such as for new source permit applications). Other applications include cases where information is needed on the individual contributions of existing or proposed sources of air pollutants. The EPA has published guidelines on air quality models to foster consistency in model applications and to improve modeling procedures. Certain models are used to assess impacts from air pollution sources within parks or close to parks (within 50 km [31 miles]). Other more sophisticated and complex models are needed to assess the long range transport of pollutants from sources located more than 50 km (31 miles) from a park. The NPS, through the Air Resources Division, is actively engaged in extensive research activities to improve modeling techniques that are used to assess impacts on NPS resources.

Incorporating air quality management into park planning

1. Air quality compliance requirementsWhen the sources of air pollutants are within the parks themselves, these sources should be controlled to the maximum extent practicable, and should never be operated at the expense of the air resource. All air pollution sources within parks (even those with exclusive jurisdiction) must comply with all federal, state, and local laws and regulations. Facilities and activities that might be affected by this compliance requirement include prescribed fires, heating plants, industrial boilers, incinerators, asphalt batch plants, earth moving or disturbance activities (e.g., construction or demolition of roads or structures), and wood/coal-burning stoves. In addition to ensuring regulatory compliance, parks should take appropriate steps to minimize the impacts of in-park sources on neighboring communities.Parks are encouraged to work directly with their state (or local) air pollution control agencies to ensure park activities are in compliance. Alternatively, parks should consult with their regional air quality coordinator or the Air Resources Division prior to engaging in any activity or commencing construction of any facility that might emit air pollutants, including smoke, to determine compliance requirements. These requirements may vary depending on the location and nature of the activity, and the size and type of facility. The Air Resources Division can assist in the design of facilities and the selection of fuels that will ensure the maintenance of good air quality in parks. Civil penalties (up to $25,000 per day or infraction) may be levied by federal, state, or local air pollution control authorities for violations of air quality control regulations. The 1990 Clean Air Act amendments added a number of provisions that affect in-park emissions. For example, the amendments added Section 169B to the visibility protection provisions of the Act. This section requires the EPA to assess progress and improvement of visibility in Class I areas. As a result of this provision, the EPA developed regional haze regulations that require states to establish visibility improvement goals. Park activities cannot interfere with achievement of these goals. The regional haze regulations provide an excellent opportunity for parks to work cooperatively with states to improve air quality in NPS areas. The focus on air quality protection in NPS areas also provides an impetus for parks to voluntarily reduce emissions beyond the reductions necessary to simply achieve the prescribed visibility goals. The 1990 amendments also expanded upon the "conformity" concept introduced in the 1977 Clean Air Act amendments. The Conformity Rule says that the federal government cannot support, license, permit, or approve any activity that does not conform to a State Implementation Plan. In other words, parks must ensure that their activities do not interfere with a state's efforts to attain and maintain the NAAQS. Parks located in, or adjacent to, nonattainment areas need to quantify all reasonably foreseeable emissions that would result from an activity. Examples of activities that could require a conformity determination include prescribed fire, construction of new roads, or re-surfacing of existing roads. If an evaluation shows emissions would exceed a de minimis level (which differs by pollutant and severity of nonattainment), the park will need to go through a conformity determination that shows the activities will not interfere with the State Implementation Plan. The most efficient way for parks to ensure conformity is to work with the state to incorporate existing and projected park emissions into the State Implementation Plan. Otherwise, if a conformity determination is required, the park will need to offset new emissions, perform modeling to show the emissions will conform with the State Implementation Plan, or ask the state to revise the State Implementation Plan to accommodate the action. Parks should contact the Air Resources Division or the state or local air permitting authority regarding whether or not conformity applies in their area. See 40 CFR 93 for more information on conformity requirements. Finally, the 1990 amendments required each state to develop an "operating permits" program for existing sources. The operating permit for each source lists enforceable emission limits, a compliance schedule, and any necessary proof of compliance. A source is required to pay for its operating permit on a ton of pollutant emitted per year basis. States were given discretion in how they implemented the program. Therefore, some states only require operating permits for major stationary sources, while other states require an operating permit for any source that emits more than one ton per year of an individual pollutant. Parks should contact the state (or local) permitting authority regarding the specifics of the applicable operating permits program. Again, failure to obtain or comply with the terms of an operating permit makes the source's operator liable for civil penalties.2. NPS internal planningThe park planning process provides excellent opportunities for NPS personnel to identify and carry out air resource management responsibilities. It is important to include air resource management objectives and projects in NPS planning documents to ensure that projects to protect the park resources and enhance visitor enjoyment are funded and implemented. Documenting air quality objectives and issues in park management plans also provides a useful record of management concerns for use in external decision arenas. Park staff, in consultation with regional air quality coordinators, are normally responsible for ensuring that air resource management is adequately addressed in NPS planning documents. Park staff also have an important role in implementing the air resource management projects. The statement for management in the general management plan should identify issues, problems, and management objectives related to air quality and AQRVs. Air resource management objectives could be addressed in several sections, including inventory and analysis of influences, land uses and trends, major issues, and management objectives. Air quality discussions should also be incorporated into the resources management section of the general management plan, which establishes actions to monitor, inventory, study, restore, interpret, and perpetuate a park's natural and cultural resources.

Air resource management issues should be addressed in detail in the resource management plan (RMP). The RMP contains strategies designed to resolve issues and problems related to a park's resources as well as research programs needed to more accurately define crucial aspects of those problems. Air quality related issues may be integrated into one project statement, or various aspects of monitoring and research may be discussed in several project statements. The project statement(s) should include references to legislative authorities and mandates, air quality designation (whether the area is Class I or II and the attainment status for each criteria pollutant), detailed descriptions of air quality conditions and issues and how they may affect park resources and visitors, alternative actions, and recommended actions.Class I areas and other parks with critical or sensitive AQRVs should consider developing comprehensive air resource management action plans. In addition to describing past, ongoing, and proposed air quality monitoring and research projects, this plan would also explain how information about park air resources will be used, internally and externally, and what actions will be taken to remedy existing problems and prevent future ones. Management objectives could also be more specific and explicitly stated if sufficient data are available, including, possibly, establishing park-specific ambient air quality standards or visibility protection standards. When developing comprehensive action plans, parks should work closely with the appropriate regional air quality coordinator and technical experts in the Air Resources Division.Administration of a wildland fire program can be challenging for park managers because the use of fire to benefit ecosystem health can conflict with efforts to protect air quality. A smoke management plan is a necessary component of any prescribed fire or wildland fire program. This plan should encourage burning only under fuel and weather conditions that minimize smoke production and/or maximize smoke dispersion. In addition, the plan should describe how the park will advise employees, visitors, neighboring communities, and air pollution control agencies of smoke conditions and should outline the steps park staff will take if there are complaints about smoke generated from fire management programs. (See Fire Management in this Reference Manual and DO/RM 18 Wildland Fire Management.)3. Air quality project fundingFunding for air quality projects may be obtained from a variety of sources, primarily within the NPS. These funding sources include the park base, the regional base, fee revenues, the Natural Resources Preservation Program, the Servicewide Air Quality account, the Fire Program, and the Cultural Resources Preservation Program. The Air Resources Division manages the Servicewide Air Quality account, a large portion of which is dedicated to funding the gaseous pollutant and visibility monitoring networks. A small amount of money is available for project funding. Parks should submit requests to their region for prioritization.

Interpretive activities

It is important for the public to understand how air pollution affects park resources, since the public plays a key role in bringing about those actions needed to remedy existing air pollution problems and prevent future ones. Interpretive activities provide excellent vehicles for explaining air quality conditions and concerns, NPS responsibilities to protect park air resources, and air resource management activities, including research and monitoring programs, as well as participation in regulatory matters. Park staff are responsible for preparing those elements of interpretive programs that address the air resource. The Air Resources Division can provide park-specific or servicewide information for use in developing interpretive media. All air quality-related interpretive materials, programs, or exhibits developed by parks must be reviewed by the regional air quality coordinator, in conjunction with the Air Resources Division, prior to publication or presentation in order to ensure technical accuracy and policy consistency.In parks that conduct visibility monitoring, wayside exhibits at scenic overlooks are particularly effective in explaining visibility conditions and concerns. In addition, exhibits on native vegetation or surface waters can incorporate information about air pollution effects on these resources. Site bulletins can be developed to provide more detailed information on specific issues. Interpretive talks, including slide presentations or field trips to monitoring stations, are another way of imparting air quality information.Park visitors are frequently under the impression that the air quality in parks is pristine. On the contrary, air in many parks is often unhealthy. For example, ozone concentrations reach unhealthy levels in several units of the National Park System many years between April and October. In addition to parks with monitored violations of the ozone health standard, it is likely that violations are also occurring in areas where no data are available. Park managers need to take actions to protect park employees and visitors when air pollutants reach unhealthy levels. The NPS is, therefore, developing national guidance to ensure consistency for health advisory programs servicewide. See Exhibit 3 for guidance on ozone public health advisories.

Environmental Leadership Initiative

As an important component of the servicewide effort to ensure that the NPS is proactive in demonstrating its commitment to strong environmental stewardship, internal air resource management activities need to incorporate the principles and priorities of the NPS environmental leadership and sustainability program. DO 13 Environmental Leadership outlines NPS policy for "greening" the NPS. Air resource management goals, objectives, and strategies are part of a servicewide environmental leadership strategic plan designed to achieve NPS environmental leadership objectives.

The first requirement of the NPS environmental leadership effort is to meet all compliance requirements and responsibilities mandated by local, state, regional, and federal governments and advisory organizations. The air resource requirements and responsibilities are discussed at length in this chapter. The next phase of the servicewide environmental leadership program is designed to improve the protection and enhance the condition of NPS air resources through sustainable practices and pollution prevention activities that go beyond the minimum compliance requirements. The program also provides the NPS with educational and interpretive opportunities to demonstrate and perpetuate NPS environmental leadership and sustainability efforts.

External (Interagency) CooperationOverview

In most cases, the air pollution affecting park resources and values comes from outside the parks. Information from the air quality and effects monitoring program is used to support NPS participation in external decision-making arenas. NPS concerns and recommendations regarding proposed or existing air pollution sources are directed to the governmental agency that has authority to regulate existing air pollution sources and to permit construction of new sources. Cooperation is also elicited from industry to ensure protection of NPS resources. The Clean Air Act requires that the NPS be involved in reviewing State Implementation Plans, particularly those plan elements related to prevention of significant deterioration of air quality in clean air areas and to protect visibility in Class I areas. The NPS is also required to evaluate the effects that a new air pollution source might have on nearby park resources. The Air Resources Division has servicewide responsibility for ensuring compliance with these Clean Air Act requirements, in coordination with NPS regional offices and parks. The NPS has also been actively involved in regional, multi-stakeholder air quality forums. These forums provide an opportunity to influence the state and federal regulatory process. NPS participation to date has included staff from parks, regions, and the Air Resources Division.

Reviewing impacts of new air pollution sources

1. Resource management planningOther federal agencies engage in resource management planning activities similar to the NPS process. For example, the U.S.D.A. Forest Service and the Bureau of Land Management each have planning programs for integrating resource development and resource protection activities within their jurisdictions. To the extent that NPS lands are near lands managed by other federal agencies, these resource management planning programs may have direct or indirect impacts on air quality or AQRVs. Park staff have responsibility initially for identifying opportunities to work cooperatively with other land managers to ensure that potential conflicts are anticipated, avoided, and resolved. This requires early involvement (e.g., at the scoping stage) in other agencies' planning processes, including the assessment of potential environmental impacts. Parks should consult with regional air quality coordinators to determine whether another agency's development plans might adversely affect air quality and AQRVs. If highly technical expertise is required to communicate concerns and recommendations to another agency (e.g., modeling of air quality or visibility impacts is needed), then the Air Resources Division should be consulted as well. The Air Resources Division may also review draft environmental impact statements at the request of the Washington Office Environmental Quality Division or on its own initiative if major energy or industrial development is planned that could affect park air resources. In such cases, the Air Resources Division review is coordinated with the regional air quality coordinator or regional environmental compliance officer.2. Review of permit applications for new air pollution sourcesIf an industrial or energy resource developer wishes to construct or modify a major stationary source of air pollution, the developer must first obtain a permit to emit air pollutants. Usually the permitting authority is a state or local agency, but permits may also be issued by the EPA. The permitting authority must notify the publicof permit applications for major stationary sources, and a public comment period must be provided. This process gives the NPS an opportunity to be involved in any decision to permit increased air pollution near any NPS unit, regardless of the area's classification.

If the permit applicant proposes to locate the air pollution source near a Class I area, the permitting authority must notify the NPS and provide a reasonable opportunity to comment on whether the proposed source would adversely impact AQRVs of the Class I area, as required by section 165 of the Clean Air Act. In most cases, states send permit applications directly to the Air Resources Division. If a park or regional office receives a permit application, they should immediately contact the Air Resources Division. The Air Resources Division reviews the permit application, assesses potential impacts, prepares technical comments, and recommends policy positions to the affected regional director and superintendent, through the regional air quality coordinator. The Air Resources Division generally prepares NPS comments for the regional director's or park superintendent's signature.

In controversial cases or other cases where technical review suggests that Class I area AQRVs might be adversely affected, concurrence from the Department of the Interior's Assistant Secretary for Fish and Wildlife and Parks must be obtained before NPS comments are transmitted to the permitting authority. In addition, if Class I increments are expected to be exceeded and technical review shows that no adverse impact on AQRVs is likely to result, the permit applicant will need to obtain a certification to that effect from the Assistant Secretary before a permit can be issued by the permitting authority. Only the Assistant Secretary can issue such a certification. The procedures for doing so are set forth in 47 FR 30226 (July 12, 1982). When determining whether the changes caused by air pollutants constitute an adverse impact on AQRVs, the NPS primarily looks at whether the national significance of the area would be diminished, whether the structure and functioning of ecosystems would be impaired, or whether the quality of the visitor experience would be impaired. The frequency, magnitude, duration, location, and reversibility of the potential impact are also taken into account.

Legislative and regulatory development

In order to carry out its air resource management responsibilities, the NPS participates in the development of air quality related legislation and regulations, at both the federal and state level, to promote establishment and implementation of air pollution control programs that consider and address existing and potential air pollution impacts on park resources and values. Because of the servicewide effect of federal legislative and regulatory programs, the Air Resources Division has the primary responsibility for monitoring air quality-related legislative and regulatory proposals and preparing comments or testimony on behalf of the NPS. The Air Resources Division ensures that any necessary NPS or departmental clearances are obtained prior to external release or publication of NPS comments.States are required to develop State Implementation Plans detailing how they plan to protect air quality. These plans must include strategies needed to attain NAAQS, to prevent significant deterioration of air quality in clean air areas, and to make reasonable progress toward the national visibility goal. Using information and analytical tools developed through the NPS air quality and effects monitoring program, the Air Resources Division has primary responsibility for working cooperatively with states to develop plans consistent with federal requirements and park protection goals. The Air Resources Division encourages and supports regional and park staff involvement in this planning process. The Air Resources Division has responsibility ultimately, however, for preparing NPS comments on State Implementation Plan proposals for the appropriate regional director's signature, after obtaining any necessary concurrences from the Assistant Secretary for Fish and Wildlife and Parks.

Redesignation

States and Native American tribes are given authority under the Clean Air Act to redesignate clean air areas to provide greater or lesser protection from air pollution degradation. The NPS encourages and supports redesignation actions that will provide added air quality protection under the law wherever necessary and feasible, and, conversely, to intervene in proposed redesignation which would allow greater air quality degradation.Prior to a redesignation, a state must conduct an analysis that addresses the health, environmental, economic, social, and energy effects of the proposed redesignation. Public hearings must be held in the area prior to the redesignation. If units of the National Park System are being considered, the NPS must have an opportunity to comment.The Clean Air Act required the NPS to review all national monuments, primitive areas, and preserves and to recommend those areas for possible redesignation where AQRVs were important attributes. The NPS conducted its review and published a list of those areas in the Federal Register on June 25, 1980. There are various ways that the NPS can become involved in the redesignation process, including:1. working with states that are contemplating redesignation actions and assisting in preparation of relevant sections of the required analysis;2. working with appropriate state officials to help ensure that redesignation procedures provide for adequate consultation with NPS officials as to the effects of the proposal on park air quality and AQRVs; and

3. becoming actively involved in public review of redesignation issues at the national, state, and local levels, including presenting NPS views in writing, attending meetings, participating in public hearings, and assisting local/state government officials in their assessment of redesignation issues.

Official NPS recommendations related to redesignation actions require concurrence from the Assistant Secretary for Fish and Wildlife and Parks.