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It is our hope that you and your committee will make sure that the HEW people, in their commendable zeal to achieve clean air, will not ignore this real threat to this large segment of our industrial economy. We hope that, either in language in the bill or in your report, first attention will be given to means to determine a desirable, safe level for sulfur oxides and to eliminate the sulfur contaminates from fuel. In this way, the public interests can be protected and coal can continue to be sold in its major markets.

Sincerely,

JOSEPH E. MOODY, President.

This will conclude the hearing this morning. We have several other witnesses that we have not been able to get to this morning. However, the House has gone into session and we must adjourn.

We have three gentlemen from out of the city as witnesses. We do not like to inconvenience you.

I note that Mr. Michaels is here representing the city of Philadelphia. Could you be here at some meeting in the future that we could arrange?

We did get to Mr. Tate, your mayor, last week. He was not able to be here at the time that he was called, and for that reason we had to reschedule him. We did have the testimony of one of your very able Congressmen.

Mr. MICHAELS. That will be all right.

The CHAIRMAN. We have from New Haven Mr. Millet, representing the Automobile Importers Association. Is he present? Perhaps he did not get here this morning.

We have Mr. Scott.

I am sorry that we did not get to you. We will arrange another date as soon as the schedule will permit and we will advise you. We will try to cordinate with your schedule so that we will not have any conflict.

Mr. SCOTT. Very well.

The CHAIRMAN. We thank you all very much.

The committee will stand adjourned subject to the call of the Chair. (Whereupon, at 12:15 p.m., the committee adjourned subject to the call of the Chair.)

51-707-65--23

CLEAN AIR ACT AMENDMENTS

TUESDAY, JUNE 29, 1965

HOUSE OF REPRESENTATIVES,

SUBCOMMITTEE ON PUBLIC HEALTH AND WELFARE OF THE
COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE,

Washington, D.C.

The subcommittee met, pursuant to recess, at 10 a.m., in room 2218, Rayburn House Office Building, Hon. Oren Harris (chairman of the full committee) presiding.

The CHAIRMAN. The committee will come to order.

When the committee adjourned the hearings a few days ago, on the various proposals having to do with so-called clean air and other related matters in this field, I was under the impression that there were several witnesses to be heard; particularly the mayor's representative from Philadelphia was to come down. For some reason, apparently he has not been able to come at this time. If he does not come to Washington, I will give him the privilege of filing a statement to be included in the record.

There were several other witnesses to be present, but apparently, they felt that their appearance would not be necessary. So they are not here.

The witness that we do have left is a very important witness, Mr. John Scott, who is the general counsel for the Socony Mobil Oil Co., of New York.

Mr. Scott, I know personally that you have gone to a lot of trouble and some inconvenience to be here today. But we do thank you for arranging you schedule to come, because I want to conclude these hearings this week and not let them go over until after the holidays when we already have other matters scheduled. It takes some time to get these records completed and printed. If we do not move on, we will get into a logjam.

So we are glad to have you this morning and to have your testimony. The field is yours.

STATEMENT OF JOHN SCOTT, GENERAL COUNSEL, SOCONY MOBIL OIL CO., NEW YORK, N.Y., REPRESENTING THE AMERICAN PETROLEUM INSTITUTE; ACCOMPANIED BY G. H. COLLINGS, JR., MEDICAL DIRECTOR OF THE STANDARD OIL CO. OF INDIANA; AND PAUL F. PETRUS, MANAGER OF FUELS, PRODUCTS DEPARTMENT, MOBIL OIL CO.

Mr. Scort. If I may have your permission, Mr. Chairman, I have a couple of experts with me. May they come up with me?

The CHAIRMAN. Yes, indeed, you may have your other experts to join you. And you may identify them for the record.

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Mr. SCOTT. They probably will deny the term that I have used, but at least they will try to contribute where my knowledge fails.

The CHAIRMAN. Just so we do not put the definition of an expert in the record at this point.

Mr. Scorr. I might add also, Mr. Chairman, that we are here to cooperate and help. And if you want us back again, we will come back any time. We are happy to do this.

The CHAIRMAN. Thank you very much.

You may proceed just as you desire with your statement.
Mr. Scorr. Thank you, sir.

I am John J. Scott, chairman of the American Petroleum Institute's Coordinating Committee on Air and Water Conservation and general counsel for the Socony Mobil Oil Co. With me are Dr. G. H. Collings, Jr., medical director of the Standard Oil Co. of Indiana. and Paul F. Petrus, manager of fuels in the products department of

my company.

I appreciate the opportunity to be here today and to present the thoughts of the petroleum industry on the legislation you are currently considering in the field of air conservation.

The petroleum industry has long been aware of the fact that the Nation's rapidly growing population and subsequent fuel demand has carried with it an increased responsibility for avoidance of atmospheric pollution. For many years, the petroleum industry has squarely faced this problem and, through the efforts of individual companies as well as its various trade associations, has endeavored to earn good marks in corporate citizenship.

The organization we represent here today-the American Petroleum Institute-has been the main channel through which oil companies have carried on an organized effort against pollution in its various forms for almost four decades. API's abatement research programs to date have covered an extremely wide range, including projects dealing with aquatic life, oil-and-water separators, ships and barges, smog compounds, and automobile exhausts. This research program--at a cost of millions of dollars-has also included projects directly concerned with health that have been conducted at Harvard University, the Chicago Medical School, the University of Texas, and many other institutions and laboratories.

The API Committee on Disposal of Refinery Wastes dates back to 1929 and has been active in the fields of both air and water pollution abatement. One of this committee's major contributions has been the preparation of a manual on "Disposal of Refinery Wastes" which currently runs to six volumes. Some of these volumes are in their seventh edition. This manual has been a standard reference source not only for the petroleum industry, but also for other industries.

In the late 1940's, west coast oil companies, individually and through the Western Oil & Gas Association, began a sizable research program to determine what was causing smog in Los Angeles' air, and what might be done to correct the situation. In 1953 when it became apparent that air pollution was not confined to Los Angeles, the API through the air and water conservation committee assumed sponsorship of a nationwide research program. The program, to date, has cost in ex

cess of $2 million. This figure does not include expenditures by individual companies in this field.

In the light of this broad background of experience, we come here in the hope of making a constructive contribution to the discussion. We believe it is imperative to maintain forward motion toward the objective of cleaning the air, and to avoid false starts, backward steps, and wrong turns. Such mistakes are easy to make when the subject with which we are concerned involves so many unanswered questions, so many unsettled differences of opinion among recognized experts, so many doubts and uncertainties.

Let me illustrate with a case history of such a mistake. At one point in Los Angeles' search for a solution to its smog problem, the city fathers concluded that the oil refineries in the area might be to blame. Refineries were summarily required to install very stringent controls. But after special refinery emission control devices were installed, the city's smog problem remained as bad as ever. Only through later adequate research work was it found that the cause lay elsewhere. A considerable part of this research was sponsored by API. The API work, at the Franklin Institute, established the validity of Prof. A. J. Haagen-Smit's theory that sunlight acting upon a mixture of hydrocarbons and nitrogen oxides produces smog-forming ozone.

The cost of the false start in Los Angeles was high. To the petroleum industry-and ultimately, of course, its customers-the cost was $50 million. The cost to the community was intolerable delay. Time was wasted while the community waited to see if the devices would work-time that could have been better spent trying to find the real cause of the pollution problem.

An air pollution problem is always complex. It cannot be solved by the simple writing of a rule that will act like a magic formula. The recently promulgated HEW regulations on heating installations in new Federal facilities offer an excellent case in point.

As you know, the Department has issued a set of proposed instructions that would, if adopted, force Government agencies to use in these buildings fuels with a sulfur content of less than 1 percent. The regulations state that the "emission should not exceed 1 pound of total sulfur oxides per million B.t.u. heat input for installations below 10 million B.t.u. per hour heat input in any community, and for all installations in standard metropolitan statistical areas or standard consolidated areas whose central city has a population greater than 2 million and a population density greater than 15,000 per square mile."

It is the petroleum industry's feeling that the application of these rules to new buildings is merely the opening phase. Soon the older Government-owned buildings will have to comply with similar regulations. The cost to the taxpayer, who will have to pay for the necessary conversion, is anybody's guess.

This would be a problem even if it stopped with Federal buildings, but we know that is not to be the case. These regulations will set a pattern for all local, State, and regional pollution agencies. Indeed, rules of the Department are meant to be examples, as was made clear in the statement of James M. Quigley, Assistant Secretary

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