solid waste disposal practices. We also have been advised that your committee has under consideration H.R. 890 and several identical bills which deal with the solid waste problem in a comprehensive fashion. The purpose of this letter is to indicate our objection to the handling of solid wastes in S. 306 and our concern for early consideration of H.R. 890 or a similar bill. The solid waste problem and the inability of States generally to handle it with the resources currently at their disposal poses a serious problem for all health agencies. The meager attention which this matter has received from Congress, in spite of the President's message, (H. Doc. 70, has not been encouraging. Perhaps the problem is felt particularly keenly in this State where the natural beauty for which this State is recognized is being threatened by the inadequate disposal of solid wastes from our expanding population. The health problems resulting from the existing situation and those which the future will bring are not subtle, dramatic, unkown or poorly understood and thus lack the appeal of those associated with air pollution or radiation. Because of their familiarity they have inevitably come to be accepted by many as the price to be paid for the expansion of population and industry. A new attitude and a fresh start are needed if we are to be successful in altering the inevitable cycle in which we are presently entrapped. The assistance of the Federal Government in the exact ways outlined in H.R. 890 will, in our opinion, provide the incentive and the means. The proposal contained in S. 306 (the clean air bill) is not the answer and introduces an administrative concept which will not work in this State. Your consideration of this letter and your assistance are respectfully requested. Sincerely, BERNARD BUCOVE, M.D., State Director of Health. NATIONAL SOCIETY OF PROFESSIONAL ENGINEERS, Hon. OREN HARRIS, As set forth in the attached copy of our society's policy on this general subject, we believe that primary responsibility for the regulatory control of air pollution should rest with the local communities and States, but that the Federal Government should provide support and assistance where necessary through legislation and other appropriate action. We feel that S. 306 would help provide such necessary support and assistance to combat the rapidly growing hazard posed to the public health, safety, and welfare by air pollution. We respectfully request that this letter and the enclosed policy statement be made a part of the record of the hearing on this bill. Very truly yours, PAUL H. ROBBINS, P.E., Executive Director. POLICY NO. 73-AIR POLLUTION Pollution of the air poses a continuing and serious threat to the public health, safety, and welfare. The primary obligation of professional engineers is to protect the public health, safety, and welfare. It is, therefore, incumbent upon the engineering profession to provide all possible assistance in meeting this problem, based upon sound engineering principles, and in recognition that some of the primary sources of air pollutants are the very equipment, processes, and engineering works which have been developed by engineers. Primary responsibility for the regulatory control of air pollutants should rest with the local communities and States. To assist the State and local communities in meeting these problems, the Federal Government may provide significant support through legislation including the following principles: 1. Encourage and assist in the development of cooperative activities among the States. 2. Provide support for research and studies into the causes of air pollution and appropriate methods for solution. Such support should be administered through grants and intramural programs. 3. Make available to State and local communities financial support for State or local studies and action programs to control air pollution. 4. Sponsor conferences, seminars, and other methods to explore new developments in combating air pollution, and disseminate information resulting from such discussions. 5. Authorize a procedure for abatement of air pollution of an interstate character through conferences among various interests and States, recommend corrective action if the State or parties in interest are unable to agree on a proposed course of corrective action and, as a last resort, if cooperative measures fail, secure an abatement order from courts of appropriate jurisdiction after a reasonable period of time has been provided for the parties or States in interest to arrive at a satisfactory solution. 6. The Federal Government should accept responsibility for control of air pollution associated with Federal installations and other direct Federal activities. 7. We also strongly recommend that a National Advisory Board be established including professional engineering representation. 8. There are air pollutants not commonly considered by the public as part of the air pollution problem, such as dusts and sprays, which are an essential part of any consideration of the whole matter of air purity as it affects the health, safety, and welfare of the public. AMERICAN MEDICAL ASSOCIATION, Hon. OREN HARRIS, Chairman, Subcommittee on Public Health and Welfare, Committee on Interstate and Foreign Commerce, House of Representatives, Washington, D.C. DEAR MR. HARRIS: On behalf of the American Medical Association, I would like to respectfully submit for your consideration our views on S. 306, 89th Congress, which we understand is now under consideration by the Subcommittee on Public Health and Welfare. We agree with the basic objectives of S. 306 as they relate to the need to regulate pollution from automobiles. The relationship between air pollution and certain health conditions has been established. In view of the expanding seriousness of the problem, we believe that there exists a need to control automotive air pollutants. Although the technological and economic implications of automobile exhaust control are complex, data from both government and industry indicate that control technology is available. The State of California has approved a variety of automobile exhaust control devices and measures, and an increasing number of devices are being offered for official testing. The industry has announced that, beginning with the 1966 model cars, it will manufacture, for the California market alone, automobiles which meet the standards of that State. As a result of the research, development, and testing programs conducted in California over the past 10 years, a growing control technology has emerged from which further refinements can be expected. There is good reason to believe, therefore, that the preventive action indicated and desired under S. 306 is feasible within the time limits of this proposal. We feel that the exhaust control devices scheduled for California may be equally applicable to other parts of the country even though photochemical smog, to which California standards relate, does not appear to occur to the same degree outside California. The reduction of total exhaust emissions of carbon monoxide and hydrocarbons and other combustible contaminants is desirable in itself, since automobiles probably contribute up to 50 percent of the total pollution emissions to the atmosphere of our major population centers. It is felt, morever, that the standards applied in California represent a desirable means of attaining the goal of air pollution reduction. While it might be preferable to regulate automotive exhausts only in the States most affected and willing to assume the costs involved, we believe that in this situation such selective control does not appear to provide an effective solution. Automobiles are designed, manufactured, and distributed on a national basis, and they move continually across State lines. Varying requirements of different States and jurisdictions would add to the cost and confusion of control procedures. Federal legislation of this type should be helpful in the solution of automobile emission problems. If clear goals and procedures are outlined, a high degree of uniform compliance should be obtained. Under S. 306, the Secretary of the Department of Health, Education, and Welfare would be given the discretionary powers to set standards and implement enforcement action. The usual program phasing and assurances of scientific objectivity which can be found, for example, in the enforcement provisions of the 1963 Clean Air Act with respect to stationary sources, and in the operation of the California Motor Vehicle Pollution Control Board, are not included in this bill. We suggest, therefore, that S. 306 provide for a commission or control board which would conduct open hearings with regard to the setting of standards and the certification of control measures. The commission or board, through technical advisory committees, would evaluate the progress of California and other States in controlling automotive exhausts and the technological, economic, and administrative aspects of the automotive exhaust problem. Hearings should provide for adequate notice, and mechanisms should be established which would provide for conferences held before any enforcement action is taken. These procedures would, while maintaining the intent of the law, provide a clear opportunity for public and private cooperation and understanding, and for compliance at each stage in the implementation of this program. While we support the objectives and principles of this legislation, we believe that it could be improved in accordance with our above suggestions. In addition to automotive emissions, the American Medical Association also recognizes that the problems associated with solid waste disposal in the United States are significant and deserving of much greater attention than they have yet received. The production of solid wastes is increasing with the increase in population of this country. and the disposal of solid waste is particularly difficult in the large metropolitan areas where the population is concentrated. Problems potentially associated with the disposal of solid wastes from a public health standpoint include: the prevention of pollution of the atmosphere, prevention of pollution of ground water supplies, and the control of disease vectors. The development and demonstrations of new methods of disposal, as provided for in S. 306, could resolve these problems. Section 206(d) provides for grants to State and interstate air pollution control agencies for surveys and planning with respect to solid waste disposal. We believe that this section should be amended so that the funds would be made available to the agency designated by the Governor of each State as being responsible for problems associated with solid waste disposal, rather than to State and interstate air pollution control agencies. Other agencies, such as the State health department, could in some States be the appropriate group to receive such funds. With the adoption of the above suggestions, the American Medical Association welcomes the opportunity to support and endorse the provisions and intents of S. 306. Thank you for this opportunity of presenting these views. I respectfully request that this statement be made a part of the record of the hearings on S. 306. Sincerely, F. J. L. BLASINGAME, M.D., Executive Vice President. Hon. OREN HARRIS, CITY OF OAKLAND, CALIF., June 7, 1965. Chairman, House Subcommittee on Public Health and Welfare, DEAR CONGRESSMAN HARRIS: The city of Oakland supports passage of H.R. 890 (Solid Waste Disposal Act) and identical bills. Oakland is one of several cities bordering the San Francisco Bay where the outlook for future solid waste disposal presents serious problems. A chief problem lies in the present practice of utilizing a fill or dump type operation on the shores of the bay. Obviously, such methods cannot continue indefinitely without detrimental consequences to the best use of these lands. Another major concern is the ever-increasing amount and kinds of solid waste material. With such increases coupled with anticipated population increases, it becomes essential that modern technological advances be made in this field. It is requested that your subcommittee on the Solid Waste Disposal Act accept this statement of support as part of the scheduled hearings and that the statement be placed in the record. Sincerely, WAYNE E. THOMPSON, City Manager. Hon. OREN HARRIS, MANUFACTURING CHEMISTS' ASSOCIATION, INC., Chairman, Committee on Interstate and Foreign Commerce, House of Representatives, Washington, D.C. DEAR MR. CHAIRMAN: This letter is being sent to you on behalf of the Manufacturing Chemists' Association (MCA), a nonprofit trade association including 196 U.S. member companies, large and small, which together account for more than 90 percent of the country's productive capacity for chemicals. Our purpose is to oppose the amendment to the Clean Air Act recommended in item 3 on page 5 of the June 10, 1965, report of the Department of Health, Education, and Welfare to you regarding S. 306 and the seven related House bills under consideration. This amendment would empower the Secretary to call a public conference concerning "potential air pollution" that in his judgment might arise from "new or additional discharges into the atmosphere." This proposal has serious shortcomings. It would permit the Secretary—with duty implied-to intervene in local situations, without regard to whether interstate pollution is involved. This action could be taken without regard to State or local officials or their established air pollution control agencies, with no requirement even that they be parties to the proceeding. Such an amendment, in practical effect, would make it hghly advisable to obtain prior Federal approval of each new industrial facility and of each enlargement or modification of existing industrial establishments with regard to air pollution control. Failing to do so, manufacturers would risk the prospect of a publicized conference which could involve disclosing company plans and business secrets to the world at large, including competitors. The heavy burden on both the Federal Government and industry of a system leading to prior approval of the details of air pollution controls is immediately apparent, as is also its deterrent effect on State and local regulatory activity and responsbility. Accordingly, we believe the proposed amendment is not in line with the policy intent of the Clean Air Act, and would be detrimental to the accelerating program of the States on air pollution control under the act's provisions. Moreover, it seems clear to us that the Secretary already has ample authority to accomplish the purported objective of the President who, in his message on natural beauty, encouraged the investigation of “potential air pollution problems before pollution happens." Under section 3(a) of the act, the Secretary has the power and duty to "establish a national research and development program for the prevention of air pollution." As part of that program he is directed to "conduct research, investigations, experiments, * * * surveys, and studies relating to * ** prevention of air pollution." Also, under section 3 (c) of the act, the Secretary is directed to publish criteria reflecting knowledge useful in indicating the effects which may be expected" from air pollution agents. 66 We have noted the absence of any testimony during the hearings on the proposed amendment by the representatives of HEW or by anyone else, also rejection by the Senate Public Works Committee of an amendment having similar effect. The chemical industry has worked diligently toward control of air pollution through research and the application of appropriate control technology. Research for better tools to meet future needs is a continuing process. We have supported what we believe to have been constructive improvements in Federal legislation in the past, and expect to be similarly responsive in the future. We appreciate this opportunity to express our views for your consideration, and request their inclusion in the printed hearings record. Sincerely, G. H. DECKER, President. VOLVO, INC.. Re Senate bill 306. Hon. OREN H. HARRIS, Rockleigh, NJ., June 28, 1965. Chairman, Subcommittee on Public Health and Welfare, Committee on Interstate and Foreign Commerce, House of Representatives, Washington, D.C. DEAR CHAIRMAN HARRIS: The undersigned is president of Volvo, Inc., the wholly owned U.S. subsdiary of AB Volvo, manufacturer of the Volvo automobile. This statement is being submitted by me on behalf of Volvo, Inc., its distributors, and approximately 425 franchised dealers who have a vital interest in Senate bill 306. During 1964, there were about 17.400 Volvo automobiles sold at retail in the United States, which sales comprised 3.6 percent of all imported cars sold in the United States and 0.22 percent of total sales of automobiles in the United States. The committee may know of the pioneering developments made by Volvo in advancing certain phases of automobile safety. All Volvo automobiles are equipped with the three-point safety harness, generally recognized as the safest and most advanced safety harness. Our factory in Gothenburg, Sweden, however, is continually experimenting with ways and means of improving even this far-advanced design. Standard equipment on all Volvo automobiles also includes such safety items as padded dashboards and sun visors, energy-absorbing steering wheels, safety anchor seats, and oversized brakes, to mention but a few. In addition, Volvo makes substantial contributions to automobile safety throughout the world by contributing the results of its research and engineering developments to scientific organizations and engineering societies. With this reputation for safety in automobiles, our company naturally supports the philosophy and objectives underlying S. 306. We would, however, present three points with respect to the bill which we do not believe have been brought before the committee and which we feel it is incumbent upon the committee to consider. 1. The committee has heard testimony from a number of witnesses who have indicated that the automobile industry will be able to supply exhaust control systems on cars for distribution in California with the 1966 model year and that such systems could be supplied on all new cars if required by S. 306, by the 1968 model year. Dr. Vernon G. MacKenzie, Assistant Surgeon General, Chief, Division of Air Pollution, Public Health Service, in his testimony before the committee on June 10. 1965, indicated that "all new cars manufactured in the United States by the 1968 model year” could be equipped with emission control systems. By implication, it was noted that only U.S. manufacturers have indicated the 1968 model year cars could be supplied with exhaust control systems. It is recognized, that automobiles equipped with engines of smaller displacement than U.S.-manufactured automobiles have exhaust control problems unique from those presented by larger displacement engines. As yet, no suitable device has been perfected for controlling exhaust emissions from these smaller displacement engines. California has recognized this unique problem and has given those automobile manufacturers with engine displacements of less than 140 cubic inches until December 1, 1967, to comply with the California exhaust control regulations. As the committee has heard, automobiles manufactured in the United States control exhaust emissions by the injection of air into the exhaust manifold or by finer tuning of the engine. Approximately 10 percent of engine horsepower is lost by utilizing these methods. If either of these systems is installed in automobiles with engine displacements smaller than cars sold in the United States. the 10-percent decerase in horsepower would drastically reduce the efficiency of such smaller cars. Thus, in order to control exhaust emissions on smaller cars other methods must be applied. Volvo commenced investigating and testing vehicular exhaust control devices in 1962, before the first State legislative action to reduce pollution of air by |