same time for a suitable type of periodic maintenance and inspection. As suggested, the States, acting through the established channels of the vehicle equipment safety commission, could effectively deal with this problem; action on it should be recommended to them concurrently with any action taken on this bill. By appropriate means Congress should indicate its intent to insure that there is periodic maintenance and inspection.

S. 306, however, proposes vehicles inspection and enforcement at the factory or warehouse level in sections 207 and 208. And in section 208 provision is established for manufacturers to maintain records, make reports, et cetera, presumably so the Federal agency can determine whether the manufacturer is complying with the legal requirements.

The provisions of sections 207 and 208 are unnecessary. They are not likely to achieve desired results because the mere physical inspection of a new vehicle or an engine will not indicate whether it will emit pollutants, or not.

Moreover, such a procedure could not be employed in the factories or premises of foreign manufacturers of vehicles, who will be exporting their products to the United States and selling the products, presumably in conformance with the same U.S. legal requirements.

It appears likely that this wording and type of provision may be based on those employed in the inspection of foodstuffs or drugs at their source of manufacture or warehousing, where processing or spoilage sometimes presents health problems. However, the problem in these fields of commerce is entirely different from that in the motor vehicle industry, and on the highway where milage accumulations may have effects on vehicle emissions.

In practice the Automobile Manufacturers Association member companies provide published specifications with each new model vehicle. These specifications pertain to equipment and performance characteristics. Even prior to the introduction of new models, the companies develop and publish texts on maintenance procedures, tolerances for mechanical and electrical parts and other components. They also train many thousands of mechanics to perform necessary adjustments so there is a wealth of widespread disseminated technical information about the products.

The industry regularly complies with laws of the States for equipment, including crankcase blowby devices, and will shortly be complying with California laws and regulations on exhaust control systems, without imposition of such requirements as those in section 208 and 207.

The point to be emphasized is not the question of new vehicle compliance which is the manufacturers' responsibility-but rather continued compliance as these new vehicles become older. This is important to the total emissions control question, especially as the vehicle population in future years grows in numbers. The performance of current vehicles in 1970 or 1975 is really the pertinent question, and it can only be assured by proper maintenance and inspection procedures which we have already suggested.

For these reasons the provisions proposed in sections 207 and 208 are neither necessary nor practical. Such a system of inspection in factories and warehouses would not serve a useful function.

For the reasons indicated, and consistent with normal procedures in the regulation of motor vehicle equipment, we believe that the penalty provisions of section 206 are unnecessary and unwarranted. Our industry has consistently cooperated with public officials and complied always with legal requirements imposed by both State and Federal agencies. We request deletion of section 206.

In conclusion, we repeat our desire to work cooperatively with Congress and its committees to achieve good legislation in the public interest, and pledge also that the automobile industry will continue to cooperate with any agencies that may be involved in establishing standards for air pollution control.

We want to thank your committee for affording us this opportunity for a comprehensive statement on behalf of the Automobile Manufacturers Association member companies, each of which takes a deep and serious interest in air pollution control, and is giving it maximum attention.

Mr. ROGERS of Florida (now presiding). Thank you very much, Mr. Barr, for your testimony on behalf of the Automobile Manufacturers Association. It is very helpful and perhaps there will be some questions.

Mr. Satterfield.

Mr. SATTERFIELD. As I understand it, one of the main points you make is that mere installation of this equipment will never be enough, that there has got to be inspection to show that it continues to function properly.

Mr. BARR. This is correct, sir; and I would like to open the question and answer period to other members of the AMA Engineering Advisory Committee, if any of the gentlemen here would like to reply to a question. As stated toward the last of our statement, I believe you are concerned with the air pollution and air quality in 1970 and 1975.

This is one concern that the Department of Health, Education, and Welfare has indicated that it is more the future air quality that they are concerned about, it is the reason they are even considering these applications now. And we are stating that a 7- or 8-year-old car will not be doing the job that a new car is designed for unless some followon inspection is provided in the model.

Mr. SATTERFIELD. I take it you are not advocating that the Federal statute require that there be specific inspections, are you?

Mr. BARR. Well, it would be good in our opinion to pass recommendations to the States who have this regulatory ability in being, to consider that, in application of the law to their area.

Mr. SATTERFIELD. It seems to me this is nevertheless a matter that ought to be regulated by the State and it seems to me, too, that we have a special problem here insofar as automobiles are concerned. Since they can move throughout the country indiscriminately the problem is whether your industry is going to be subjected to the requirements of 50 individual States or whether it would be better for the Federal Government to act.

Mr. BARR. Maybe one of my colleagues would like to comment on that. Will you, Herb?

Mr. MISCH. We, of course, prefer one standard that will be acceptable in all areas wherever possible. In support of the point Mr. Barr

made with regard to inspection and also partly in answer to your question, we would not necessarily like to see specific inspection standards established but we do favor the provision for appropriate inspection which will undoubtedly change as the systems and the requirements change over the years. By taking such action now inspection can be and will be provided throughout the lifetime of the equipped vehicles to assure continued emission control to the degree that it was intended when these systems were installed on new models.

Mr. SATTERFIELD. What you are really saying is that there ought to be some source to which the States can look for guidance. Mr. BARR. Right.

Mr. SATTERFIELD. Is this what you are saying?

Mr. MISCH. Yes, sir.

Mr. SATTERFIELD. I was interested, too, in your suggestion that— first of all, as I read it, there are four separate types of units that can be installed, is that correct? Three catalyst type mufflers and one afterburner?

Mr. BARR. This is going back to the four devices that were approved by California over a year ago to trigger their law for compliance. Their law stated that when two or more devices were approved, this would trigger the law and exhaust controls would have to be installed. Mr. SATTERFIELD. This doesn't mean you have to have all four on one vehicle, does it?

Mr. BARR. No, sir; and none of these four is actually the one our industry is applying to our vehicles.

Mr. SATTERFIELD. I was interested in your figure that each unit would cost approximately $50 installed and that you estimated the cost of maintenance annually to be $49.

Mr. BARR. This, sir, is not our estimate. This is the reported figures to the California Air Pollution Control Board about a year ago. Mr. SATTERFIELD. In other words, you would practically replace this unit every year.

Mr. BARR. In effect that is what that would say.

Mr. SATTERFIELD. Well, is it the nature of these units to actually take the hydrocarbons and pollutants out of the exhaust fumes or merely to provide a greater ratio of air to the exhaust?

Mr. BARR. Well, if we can get our minds off of those four systems that we mentioned there which were approved by California to trigger the law, the systems our industry is using consist of major engine design modifications in carburetion and distributor spark timing.

Mr. SATTERFIELD. This would change the ratio of air to combustible fuel, and the burning quality within the cylinder?

Mr. BARR. This would be true to some extent and then some of our company members use air injection to inject air into the exhaust stream to further promote oxidation.

Mr. SATTERFIELD. In essence, then, you would be reducing the content of pollutants per cubic area of exhaust rather than eliminating those pollutants?

Mr. BARR. This is correct. And the California standard of 275 parts per million maximum value on a prescribed test cycle is a reduction of something like 60 to 70 percent. Most engines on automobiles will be putting out in the area of 600 parts per million and up

without equipment as they are now running on the street today, to as high as 900 or a thousand.

Mr. SATTERFIELD. Is it possible that some of this can be achieved and perhaps will be in time with engineering in terms of the engine itself rather than some gadget that would be placed on the engine? Mr. BARR. We don't like to call the air injection pump a gadget. Mr. SATTERFIELD. Let's say device.

Mr. BARR. It is part of the job. But I think perhaps Mr. Bogan of Chrysler might like to comment on that question.

Mr. BOGAN. You ask is it possible to improve the engines eventually and we are inclined to think it is. We haven't got the answer. If we did, we would be using it. But we are working on it.

Mr. SATTERFIELD. That will be a longtime proposition in any event. Mr. BOGAN. That is right. If you are on the same track we are thinking about, there is no question about that.

Mr. SATTERFIELD. Thanks. I have no other question, Mr. Chairman. The CHAIRMAN. (now presiding). Dr. Carter?

Mr. CARTER. No questions.

The CHAIRMAN. Mr. Mackay.

Mr. MACKAY. Mr. Chairman, Mr. Barr, I want to thank you for this very fine presentation. I am sure that a lot of technical questions should be answered.

I am interested in page 4. I want to see if I read this correctly. The burden of what you have to say is that you feel that any national standard is premature, that this legislation is premature until you get the answer to that first question, does a nationwide photochemical smog problem exist? You are not sure that we have reached a point where we ought to establish a national standard?

Mr. BARR. Well, we are saying that the situation probably needs more definition. We don't know. We feel there is not an appropriate answer to that question at the present time.

Mr. MACKAY. Well, I will state my question this way. Does your group feel that the 1963 Clean Air Act should be amended in this Congress?

Mr. BARR. Should

Mr. MACKAY. Should the 1963 Clean Air Act be amended in this Congress? Do you see any deficiencies in the act or do you feel that we should wait until we have more information before we legislate further?

Mr. BARR. What we tried to indicate in our prepared statement a bit is the overriding requirement that the public be fully informed and that they realized the need for the proposed increased costs that they will be assuming, and this is the only area where we have question about doing a very efficient job so far as our industry is concerned.

Now, as to the need, we showed the tables and there is diversity there in the situation in various cities, but what that will be in 1970 or 1975 is perhaps impossible to guess or project but this is something than should be attempted, some projections should be made as to what ambient air quality is going to be, based on any available information.

or any growth potential that the Department of Health, Education, and Welfare could obtain.

Mr. MACKAY. Certainly public understanding of any law is necessary but you have the technical information. I really would like to know whether you feel that this year it is premature for the Congress to attempt to define standards.

Mr. BARR. I think my answer on that is to the extent that the public is not fully aware of the possible costs and inconvenience of such equipment on their automobiles, until they see that they are getting a good buy for their money in the national interest we question it.

Mr. ISBRANDT. I believe until the questions on page 4 are pretty well defined, that it could well be premature. If we apply these devices to all our vehicles, and then do not see any improvement in the air quality in areas other than California where we do expect to see some improvement, I think that we could well have repercussions from the public that might make it inadvisable at this time to have such a law on the books. I certainly agree with the intent of the law, to obtain better air quality, and especially looking forward to the future, to maintain the air quality or see that the air quality level doesn't drop further.

Mr. MACKAY. Do you have any projections on the number of motor vehicles expected in the country? We were given a figure of 84 million vehicles currently on the highways. Do you have any information as to the rate of the increase of vehicular traffic?

Mr. BARR. I think Mr. Sherman-did you hear the question? He is asking what the car population might be in 1970.

Mr. SHERMAN. I do not have such information available here but we can supply various figures that have been projected, yes, sir. Mr. MACKAY. Thank you.

(The information requested follows:)

SOME RECENT ESTIMATES OF FUTURE VEHICLE OUTPUT, STOCKS, AND MILEAGE NOTE.-Analysts are referred to original sources for description of methods and assumptions used in developing the various estimates.

2 Yearend number of cars registered about 10 percent greater than cars "in use." Difference attributable to cars removed from use (junked or wrecked) during course of a year; duplicate registration (licensed in more than 1 State due to migration of residents); cars held for resale on used-car lots; etc.

3 With existing road systems.

4 With Interstate System complete.

5 With all freeway needs complete.

Source: Wilbur Smith & Associates. "Future Highways and Urban Growth." New Haven, 1961.