16 continuous basis is simply prohibitive for GPA. At Cabras, therefore, in view of the foregoing, the most sensible approach is to permit the continued use of the present control strategy. This can be accoru- plished by simply exempting GPA from sections 111 (NSPS) and 123(a) (2) (intermittent control prohibition) of the Act, By exempting GPA from NSPS Cabras need not meet an absolute emission limitation requiring the continuous burning of low sulfur fuel or the use of a scrubber. By removing the prohibition on intermittent controls, the present control strategy can be continued in- definitely at beth Tanguisson and Cabras. . NSPS were intended to provide for future industrial growth while muintaining clean air by imposing strict emission limitations on all new sources, This rationale does not apply on Guam wherethe airts already clean and industrial growth 1s limited. Indeed, since the establishment of NSPS, there do not appear to be any major new sources of sulfur dioxide on the island except Cabras 1 and 2. More- over, the only likely new sources in the future are new GPA generating facilities. All will be built on the coast, principally near Cabras for the efficiency and cost benefits of sharing suport facilities. These new generators will be built solely to replace older existing facilities. Because of modernefficiencies these newfacilities will produce the same amount of electricity while burning less fuel than the facilities they replace. Accordingly, overall emissions will actually decrease without any emission controls as GPA builds newfacilities. Similarly, the rationale for prohibiting intermittent control strat- ecies does not exist on Guam. The principal argumentfor this prohibi- tion as applied to wind-based strategies is that pollution wil! be “exported” to other populated areas (e.g., across State lines). As explained above, GPA’s pollution is not exported to any populated areas. Another problem with intermittent control strategies is difli- culty of administration. This problem does not. exist on Guamfor several reasons. First, there are few sources to oversee and the Guam Environmental Protection Agency needs to commit few resources to enforcing implementation of the strategy. Second, since the Navy constantly monitors wind conditions, wind data is always available without any further resource commitment, Third, the low sulfur switch-over is easily and quickly effected, as necessary. Fourth, the prevailing winds are so regular and so dominantthat little administration is necessary; low sulfur fuel is required only 114 percent of the time. It is to be emphasized that under the proposed legislation Guam would continue to be required to have a STP and that STP would continte to be required to satisfy NAAQS. The SUP would also remain subject to EPA approval as to its adequacy and to HPA jurisdiction h 4 : ee shee ake appears eminently more sensible for Guam. i ae wht the ws, Ses-chalininan-nie'%.”, lime-limestone scrubbers create a semi-solid sulfate by-product which must be pondedor landfilled. On Guam, land for ponding is scarce and there is the risk of contaminating the limited freshwater drinking supplies. Given the good air quality, the present wind control strategy iM ah eds tee A deme, am der on SPSTDele Se aad ree GPA would be forced to install a scrubber. But the scrubbers have a waste product which must be treated somehow. The seawaterscrubber, for example, creates-a contaminatedeffluent which must somehowbe returned to the sensitive marine ecosystem at Guam. Conventional