Many in industry supported the Clean Air Act Amendments of 1990 and believe in general it has worked out well. Some parts of the Act have been implemented by EPA and reinterpreted by some courts in ways that contradict what we believe was intended resulting in wasting resources by society and imposing unnecessary costs to industry. This reduces the competitiveness of the US in the world without commensurate benefits. Several areas of the CAA could be modified which would benefit everyone.

Good: General structure and details supported by DuPont and the Chemical Industry

Bad: Implementation and interpretation by EPA and Courts on some issues (e.g. NSR)

Room for improvement:

* Short time intervals for NAAQS standards reviews (5 yrs.)

* Short times for implementation from a new standard to attainment (i.e., 5 years): the classification and SIP process takes almost that long, stationary planning and construction takes almost that long, and mobile sources standards and fleet turnover can take longer

* Precautionary basis of NAAQS standards setting using statistical epidemiology studies needs "cause and effect confirmation"

* Air permit fees need limits: escalating fees with a now mature program need justification