4. It has been stated that "the atmosphere's dilution capacity is enormous." (21) A conceivable strategy of optimization might be to load the air with the right pollutant at the right place at the right time without exceeding ambient air quality standards. This ignores the consequences of emissions into the world atmosphere. There is increasing evidence of an overall buildup of atmospheric pollution. (1) Turbidity is rising and a decrease in the electrical conductivity of the air is attributed to an increasing concentration of fine particles. (19) Dust particles are absorbing large quantities of pesticides and transporting them thousands of miles. (2) It is reported that sulfur dioxide washout is increasing the acid content of European lakes and rivers. (19) I predict that in 20 years, the problem of world pollution will be so pressing that we will treat regional airsheds as point-sources, the same way we look on industry sources today. By then, the adoption of maximum emission levels for each airshed will be mandatory.

5. A basic tenet of the Air Quality Act of 1967 is that the Government assist the development of regional air pollution programs. (12) This should include, I believe, technical assistance in setting up computerized cost-effectiveness models for evaluating alternative control regulations. Cost-effectiveness models based on maximum emission standards can reduce controversy over abatement regulations. (7) They are relatively simple to implement and have the advantage of being transferable from one airshed to another. (9)

Because of the emphasis on ambient air quality measurements, however, the National Center for Air Pollution Control is committed to the development of models "combining meteorological and emission data *** to test various emission reduction strategies." (12) Such models must be tailored to the specific source location, topographic, and dispersion characteristics of the individual airshed. They are sophisticated and require great expertise to program and interpret. Although they are useful for research, I am apprehensive about their practical application for the more than 50 air quality control regions. In summary, ambient air quality standards by themselves are unsatisfactory guidelines for air quality controls:

They do not adequately protect total air quality; they are affected by weather conditions and by atmospheric chemical reactions over which we have no control; maximum emission standards not only correct these deficiencies but provide superior safeguards for the world atmosphere and are amenable to relatively simple cost-effectiveness models.

REFERENCES

1. R.A. Bryson, A Reconciliation of Several Theories of Climatic Change,' Weatherwise, April, 1968, 56–61, 94.

2. J. Frost, 'Earth, Air, Water,' Environment, 11, July-August, 1969, 14-28. 3. R. E. Kohn, A Linear Programming Model: Air Pollution Control in the St. Louis Airshed, unpublished doctoral dissertation, Washington University, St. Louis, Mo., 1969.

1.

5.

6.

'A Mathematical Programming Model for Air Pollution Control,' School Science and Mathematics, June, 1969, 487-494.

'Abatement Strategy and Air Quality Standards.' Symposium on the Development of Air Quality Standards Sponsored by the Eight Tuberculosis and Respiratory Disease Associations of Southern California and the Institute of Urban Ecology, University of Southern California, Los Angeles, California, October 23-25, 1969.

'Achieving Air Quality Goals at Minimum Cost,' Washington University Law Quarterly, Spring, 1968, 325–360.

7.

8.

9.

"Application of Parametric Programming to a Controversy on Air Pollution Control,' Annual Meeting of the Regional Science Association, Santa Monica, California, November 7-9, 1969.

'Evaluating Air Quality Standards by Comparing Abatement and Damage Trade-Offs Between Pollutants,' Paper for the Winter Meetings of the Econometric Society, New York City, December 28, 1969.

'Linear Programming Model for Air Pollution Control: A Pilot Study of the St. Louis Airshed,' Paper 69-64, Annual Meeting of the Air Pollution Control Association, June 22-26, 1969, New York.

10. R. G. Lunche, et. al., Air pollution Engineering in Los Angeles County, Air Pollution Control District, County of Los Angeles, July 1, 1966.

11. M. McGraw, National Air Pollution Control Administration, Durham, N.C., personal letter with enclosure, dated November 4, 1968.

12. J. T. Middleton, "Public Policy and Air Pollution Control," Presented at the Perjerdel Regional Conference, Swarthmore College, Swarthmore, Pennsylvania, June 11, 1969, National Air Pollution Control Administration, Washington, D.C., 1969.

13. R. Venezia, G. Ozolins, Interstate Air Pollution Study, Section II, Air Pollutant Emission Inventory, Public Health Service, Cincinnati, Ohio, Revised Edition, December, 1966.

14. J. D. Williams et. al., Interstate Air Pollution Study, Section VIII, A Proposal for an Air Resource Management Program, National Center for Air Pollution Control, Cincinnati, Ohio, May, 1967.

15. C. E. Zimmer, R. I. Larsen, 'Calculating Air Quality and Its Control,' J.A.P.C.A., December 1965, 15, 565–572.

16. 'Air Quality Criteria: Staff Report Prepared for the Use of the Subcommittee on Air and Water Pollution, Committee on Public Works, United States Senate,' U.S. Government Printing Office, Washington, D.C., 1968.

17. Air Quality Data from the National Air Sampling Networks and Contributing State and Local Networks 1964-1965 Edition, U.S. Public Health Service, Cincinnati, Ohio, 1966.

18. Air Quality Data from the National Air Sampling Networks and Contributing State and Local Networks, 1966 Edition, National Air Pollution Control Administration, Durham, N.C., 1968.

19. Cleaning our Environment: The Chemical Basis for Action, American Chemical Society, Washington, D.C., 1969.

20. Environmental Science and Technology, 'New York Spokesman Warns of SO Removal,' October, 1969, p. 882.

21. 'Progress in the Prevention and Control of Air Pollution: Second Report of the Secretary of Health, Education, and Welfare to the Congress of the United States in Compliance with Public Law 90-148, The Air Quality Act of 1967,' U.S. Government Printing Office, Washington, D.C., 1969.

22. Report for Consultation on the Metropolitan St. Louis Interstate Air Quality Control Region, National Air Pollution Control Administration, Durham, N.C., 1968."

Mr. BILLINGS. Thank you, Dr. Kohn. Senator Eagleton had to leave for a few minutes and I would like to ask you a couple of questions. First, would you define for the record what you mean by maximum emission standards?

Dr. KOнN. By maximum emission standards, I mean the total allowable emissions for each pollutant in an airshed. The reductions in total emissions which would be necessary to achieve these levels could be allocated among individual sources according to a cost-effectiveness model. Mr. BILLINGS. Would the maximum emission standards include the capability of pollution sources to meet its allocation?

Dr. KоHN. The maximum emission level would be for the entire airshed.

Mr. BILLINGS. I understand that.

Dr. KOHN. In the linear programing model for air pollution control which I have developed, I am able to include technical capability for abatement as a factor in determining optimal maximum emission standards.

Mr. BILLINGS. May I ask this then? Let's assume you have two sources of sulfur dioxide one of which has the technology available to achieve a high degree of control, say 99.9, the other, which emits the same volume of waste, has inadequate or in fact no technology to control. Would you allocate the reduction to the source that can be controlled and leave the other uncontrolled?

Dr. KOHN. You are quite right in saying I would allocate reduction to the sources that can abate at the least cost. Such a conclusion is based upon economic efficiency. However as a practical matter, other considerations than pure efficiency would enter into the regulatory process. Mr. BILLINGS. Would this have the potential of creating economic discrimination between industries in a given region.

Dr. KOHN. This particular approach says nothing about equity. To avoid the kind of discrimination which you forsee, we might prefer some form of inter-firm compensation or even a system of emission fees whereby all pollution sources are taxed in proportion to their net emissions after abatement. However, I don't believe that the least-cost solution to my model contains any clear examples of blatant discrimination between firms.

Mr. BILLINGS. Thank you very much, gentlemen. We will take a brief recess until Senator Eagleton returns.

(Thereupon, a brief recess was had.)

Senator EAGLETON. Our next witness is a representative of the Citizen's Clean Air Committee, Mrs. Colleen Kerstetter, chairman. Mrs. Kerstetter.

Mrs. KERSTETTER. Thank you, Senator Eagleton and members of the subcommittee.

STATEMENT OF MRS. J. H. KERSTETTER, CHAIRMAN, CITIZENS' CLEAN AIR COMMITTEE, ST. LOUIS, MO.

My name is Colleen Kerstetter. I am chairman of the Citizens' Clean Air Committee for the Bi-State area. The Citizens' Clean Air Committee is sponsored by the Tuberculosis and Health Society in St. Louis. (See appendix.)

As chairman, I wish to thank you for this opportunity to express the ordinary citizen's point of view. What I have to say reflects the thoughts and feelings of our 120-member committee and hopefully the thousands of worried citizens who have relayed their concern to us. We care-we are concerned and we want to be effective in speeding the cleansing of the air we breathe.

We are worried when we hear that in 30 years we will not be alive to worry about anything, unless we get at the job of cleaning up our environment immediately. We will have to move faster than we have in the past 21 years. Twenty-one years-think of that-21 years since the President of the United States proclaimed the first Cleaner Air Week. In 21 years, the air that we breathe has progressively deteriorated. We know that in this great country of ours we have the technology and know-how to do what we think is important and worthwhile. This is important and worthwhile. It is a matter of priorities. We have been to the moon and back with scientific perfection. We, the citizens, are calling for the use of this kind of "first-class know-how" to clean up our air now.

Industry may complain that the cost of pollution control is too high-not feasible. We know that in the long run, pollution costs far more than pollution control. Will the dollar sign jeopardize our health and perhaps our very lives?

We urge:

1. Strict implementation and enforcement of the existing laws.

2. Strict prosecution of violators not additional variances.

3. Stricter standards be established-According to the reports that we have they are minimum-shouldn't we have standards that are higher than minimum?

4. The development of better air pollution control equipment.

5. The development of a new type of transportation vehicle-not just more antipollution devices.

6. The development of a modern rapid transit system for our cities. We don't need research by an expert to tell us our air is bad. We can see it, feel it, smell it, and even taste it. We don't need a specialist to tell of the reduction in visibility. This fact is particularly noticed by members of our committee who are airplane pilots.

Air pollution affects our wallets, our buildings, our clothing, our crops, and, more important, our health. But (and I quote from the National Tuberculosis and Respiratory Disease Association "Air Pollution Primer") "Air pollution erodes man's soul. Every mountain blacked out by pollution, every flower withered by smog, every sweetsmelling countryside poisoned by foul odors, destroys a bit of man's union with nature and leaves his spirit diminished by the loss." The Citizens' Clean Air Committee thinks it is of utmost urgency to have clean air to breathe it is our right. It is a matter of life and breath. Senator EAGLETON. Thank you, Mrs. Kerstetter, for your very short, but very excellent statement.

I mentioned earlier that there are costs involved in this. Some of them will have to be paid, as I said, on April 15. But, as your statement points out, there are other costs that industry is going to have to pay. The cost of clean air must become a cost of doing legitimate business. Just as industries pay transportation costs in shipping their products, just as they pay labor costs in terms of the people they employ, heat and electric cost-all of the costs doing business-the cost of clean air must be a cost of doing business. And they will, as they do in the free enterprise system, ultimately pass that cost on to the consumer depending on what the product involved may be. But this is a cost that all of us have to pay. You must pay and I must pay it. All of us must pay it because we want and expect and are entitled to have clean air. We may be the richest Nation on earth, the most militarily powerful on earth, we may have a great abundance of national resources, but it is the quality of our life in terms of air and water and those things that make life really worth living. If the quality of that depreciates to intolerable levels, then all the armaments and all the bank accounts really avail very little. Thank you very much.

Our next witness is Mr. Robert Hardy, the news director of KMOX Radio, St. Louis, Mo.

STATEMENT OF ROBERT HARDY, NEWS DIRECTOR, KMOX RADIO, ST. LOUIS, MO.

Mr. HARDY. Senator, I thank you for the opportunity to appear before your subcommittee.

Our presentation would be brief this morning in that we are not technically in the business of air pollution control but wish to testify before this committee only to spotlight the increasing public concern for air pollution and its eventual solution.

KMOX Radio's involvement in the air pollution problems of St. Louis has been long standing. As a radio station in constant two-way communication with the community we serve, it has been obvious to us that more and more people were concerned with the pollution problems and were asking what might be done. They, the listeners, felt there was too much lipservice, too many variances granted, and too little real action being taken. They cited pollution, usually industrial, in their own neighborhoods.

With the occurance of the 5-day air inversion in late August and the subsequent air pollution alert, our listeners posed such questions as *** "Why, with the establishment of pollution control offices, must this contamination continue?" *** "Why is the effort made to enforce the leaf-burning ban with seemingly no effort to curtail industrial and automotive air pollution?" *** "What can we, as citizens who must live and work in this kind of environmental contamination, really do?"

We posed these questions to local, State, and Federal officials who suggested that our listeners organize into a letterwriting campaign demanding that their representatives become actively involved in seeking the solution to the air pollution problems. In the days since August 25, KMOX Radio has done just that *** with what we feel to be some small measure of success. (Please see the ACIC petition which I have attached to my statement.)

We would like the committee to understand that our testimony is in collective behalf of the citizen who was written or phoned us offering assistance and/or active support in the campaign.

I now submit for the record some letter comments which we have received.

KEN WOODS-KIRKWOOD, MO.

LETTER COMMENTS

"I am a high school student, and I realize I will have to live, hopefully or not hopefully, many more years in our endangered environment. Air pollution stands as a disgusting mark against man and his technology."

MRS. RALPH R. BEAL-HAMBURG, IOWA

"I hate to think of our infant grandson breathing the air that stung my eyes so badly on a recent visit that I had to remove my contact lenses."

MR. & MRS. V. STUART-ST. LOUIS, Mo.

"We are volunteers willing to work to stop air and water pollution."