Clean Air Plans

“Smog Plan Would Harm Economy” (Sept. 30) seriously misrepresents the Wilson Administration’s recognized leadership on air quality improvement.

The key to this complicated issue is that the proposed Federal Implementation Plan (FIP)--drafted by the federal EPA--is under legal authority from the 1977 Clean Air Act amendments, a law subsequently superseded by the 1990 Clean Air Act amendments. In 1991, over the combined objections of the U.S. EPA and California, the Los Angeles Coalition for Clean Air convinced a federal court to compel the U.S. EPA (not California) to apply the old law here--and only here--in California. California has continued to work in Congress to clarify that the 1990 act superseded the provisions of the 1977 act. Regrettably, the federal EPA chose not to take a leadership role in the fighting for its previous position.

It is important to emphasize that the U.S. EPA’s 1977 FIP exercise will not enhance air quality. U.S. EPA has repeatedly stated its legal obligations under the 1977 FIP will be satisfied by California through a satisfactory state implementation plan (SIP) drafted under the 1990 Clean Air Act. The Air Resources Board has, therefore been hard at work developing a SIP to meet federal requirements. Given that U.S. EPA is far behind in completing numerous air regulations under the 1990 act that directly relate to California--including interstate transportation--they would also be well-advised to move their resources to meet real environmental needs.

While the 1977 FIP is a federal obligation relating to issues of an earlier decade, we have worked directly and intensively, filing timely formal comments and maintaining a continuing technical dialogue with U.S. EPA. Some critics’ real objection is the fact that we continue to simultaneously work to eliminate the legal confusion that led to the U.S. EPA’s obligation to draft the 1977 FIP now at issue.

California is making tangible progress in cleaning its air. By far the largest share of the credit must go to the millions of citizens who make it possible, even though the challenge can be difficult. This 1977 FIP process--based on controversies long past, on authority of a superseded law--manages to threaten our economy while not adding value to our environmental protection efforts.

JAMES M. STROCK

Secretary for Environmental Protection

Sacramento