There is a deadline coming up at the end of this month for American cities to meet some important air pollution standards, and it's obvious that a number of them won't make it. Their failure to meet these standards set by federal law for carbon monoxide and ozone is clear evidence that urban smog continues to threaten the health of our citizens.

My response has been to take action now rather than to wait for Congress to amend the Clean Air Act to establish a new scheme for reducing smog. I recently proposed a comprehensive strategy under the act that places additional pressure on state and local governments to adopt enough pollution control measures to produce real progress toward attaining the two standards over the next several years. At the same time, it provides for the Environmental Protection Agency to play an active role in setting federal pollution control requirements where appropriate (for example, in controlling tailpipe and evaporative emissions from cars) and in applying sanctions on metropolitan areas that do not take the necessary actions.

This strategy has already met a firestorm of criticism. In some cases this is a result of basic philosophical differences over how we should attain the air quality goals to which we all aspire. But in others, the criticism results, I believe, from an inadequate understanding of EPA's proposed strategy and the history of the country's efforts since the Clean Air Act was enacted in 1970.

The strategy I have outlined has several basic elements. First, EPA is investigating whether the states have adequately implemented their existing pollution control programs. I fully intend to impose sanctions -- such as a ban on the construction of large new factories that would contribute to unhealthful pollution -- in areas that have failed to do what they committed themselves to do.

Second, I intend to decide soon whether the air quality plans that some states submitted in the past few years are tough enough to produce the pollution reductions required by the existing law. Where a state has not done the air quality planning required by the current law, I will have no choice but to impose a construction ban.

Third, for states whose prior pollution control plans seemed to meet the Clean Air Act's requirements, I will review whether those plans were in fact as successful as predicted. I will call on certain states to revise those plans that have not produced the necessary reductions in ozone and carbon monoxide.

My strategy will require most areas with unhealthful air to produce certain minimum pollution reductions over the next few years. Areas that fail to do so will be subject to a construction ban and, in some cases, additional sanctions, such as a cutoff of federal funding for highway construction.

Some have already suggested that EPA has no authority under the existing law to create a policy that extends beyond Dec. 31. They suggest that my only recourse on that date is to impose a construction ban in every city whose air violates the smog standards, regardless of whether the city submitted a pollution control plan that EPA once approved under the Clean Air Act's planning requirements.

This suggestion ignores the recent history under the act. In 1983 one of my predecessors, Anne Burford, proposed to do just that -- impose the ban in all areas that had failed to meet the air quality standards by the last date included in the law (Dec. 31, 1982). The public and Congress responded to that proposal with universal opposition. Indeed, they convinced my immediate predecessor, William Ruckelshaus, that the sanctions do not apply just because a city's air does not meet the standards by the statutory date. Rather, they apply only where the state failed to submit and implement an acceptable plan to meet those standards. It is startling to hear the people who opposed the Burford interpretation in 1983 arguing today that I have no choice but to embrace that interpretation.

Some are claiming that even if EPA does not have to impose sanctions in every single area with unhealthful smog, it still cannot call on the states to do new pollution control planning after 1987 until Congress amends the law. This argument, too, ignores recent history. When the 1982 date for meeting pollution standards passed, EPA did not close up shop and wait for Congress to act. Rather, it used its authority to call for revisions to the pollution control plans for the affected states and set new dates for meeting the standards -- dates that were consistent with the general principles of the Clean Air Act. My strategy would be the same -- with new, tougher requirements to ensure that we are more successful in the next planning round. It would be simply irresponsible for me to ask my staff (and the states) to sit on their hands awaiting congressional action to amend the law. If EPA had done that after the last deadline passed, we would not have made the progress that we have achieved in the past few years.

Others are suggesting that EPA should either insist that all areas submit new plans or step in itself with a federal plan that will bring smog to healthful levels immediately. This approach would, however, be counterproductive to our goals. Our experience with trying to impose transportation controls on cities in the 1970s shows that the public will not accept drastic solutions such as severe gas rationing and driving prohibitions that either are imposed on it by "bureaucrats" in Washington or are not preceded by sound planning and consultation at the local level.

Finally, EPA has been accused of delegating responsibility for pollution control to the states. This is an erroneous claim. First, the Clean Air Act places primary responsibility for meeting the standards on the states. It gives the federal government the role of overseeing state efforts, applying pressure through sanctions where state planning gets off track and creating some types of federal controls. The strategy I have outlined maintains this balance. EPA will apply sanctions where necessary and will continue to control those sources of pollution for which national action is appropriate. Beyond that, it is the job of the states and local governments to use the available information on pollution control techniques to make their own paths toward clean air.

The writer is administrator of the Environmental Protection Agency.