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What he says there, ties the auto emission standard very closely, of course, to the stationary sources. I wonder if you would want to comment on that?

Dr. GREENFIELD. I think what Dr. Pitts is saying is probably very true in the south coast basin area where the automotive pollution plays such a large role. It is not at all clear that this is not also true in places like New York, Chicago, and other areas where the auto doesn't play that large a role.

Senator Muskie. I raise this testimony because of Mr. Ruckelshaus suggestion earlier this morning that these policy recommendations be included in the Federal Register for comment. Unless Dr. Pitts is persuaded by the kind of presentation you have made to us, we are going to get adverse comments upon your recommendations.

Dr. GREENFIELD. Dr. Pitts remarks were also made before we noted the problem with the measurement and reclassified those areas.

Senator Muskie. I understand. But I say unless he was persuaded by the Presentation you made this morning and your position doesn't change, then we are going to hear a lot about this. So I am simply putting this before you this morning so we can begin to get the dialog started and the issue drawn for the purpose of enabling you to make your case in the face of possibly contrary opinion.

Mr. GREENFIELD. That is exactly why, Senator, that at the administrators insistence we are going to put this analysis in the Federal Register and invite public comment to give us and the others a chance to examine the validity of the analysis that we have made and the implications of it.

Senator MuskIE. What is the nature of NOx control in today's technology and in the technology that will be applied for the purpose of dealing with other pollutions? Is it just an incidental control, incidental to the catalyst that would be installed on the automobile to control HC and carbon monoxide? What is the nature of NO, control in the present technology?

Mr. RUCKELSHAUS. The primary control in the automotive emission is an exhaust recirculation valve which in effect recirculates exhaust gases for further reduction in nitrogen oxide. So that there is a specific control mechanism being used on the present automobiles for control of NOx

Senator MUSKIE. It will be continued

Mr. RUCKELSILAUS. Yes. Again, it doesn't seem to me to make sense to go back and start all over again, particularly in light of the HC and (O increased reductions that would push the NO, up if there were no controls.

Senator Muskie. Will the hardware you have just described eliminate that possibility?

Mr. RUCKELSHAUS. Either that hardware or some other. If we leave the standard where it is, we have to continue to control it at that level. If they can find a better way to do it, we would encourage that.

Senator MUSKIE. Do you have any indication of the extent to which the No, problem will be aggravated as the control on hydrocarbons and carbon monoxide are tightened? To what extent is that a technological problem?

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Mr. RUCKELSHAUS. It is a problem clearly of controlling two, HC and CO at the same time. As you tightened the controls on both of them, it becomes more difficult to do that.

Senator Muskie. The hydrocarbons standard for 1973–74 I gather is 3.1 parts, grams per mile and the 1976 law will require reducing that to 0.41

. Carbon monoxide is at 39 grams per mile and it will have to be reduced to 3.4. That suggests that the pressure, upward pressure on NO,, will be considerable. Did the companies present testimony to you that they are going to effectively continue that upward pressure to hold NO, emissions at 3.1 if your policy recommendations on NOx is adopted?

Mr. RUCKELSHAUS. I don't have any testimony from the companies to that effect, Mr. Chairman. Senator Muskie. You have not made that proposal ? Mr. RUCKELSHAUS. No. I never proposed to them that we do this. I have made the proposal several times in the hopes that if Dr. Pitts or whoever thought this proposal was ridiculous would say so. What I am suggesting today is that we get this out in the public now and let the dialog start.

Senator Muskie. The reason I raised this question is I was sure that would be your answer because the issue was not raised in the hearing, that we now pose a different technological problem or issue for them and we need a response. It is conceivable, for example, that in order to meet a NO, problem of that dimension that they would still have to consider the other catalysts?

Mr. RUCKELSHAUS. Our technology assessment that is in the decision itself and in the appendix assumes that they would meet a 3.1 NO, standard for 1975 without the catalyst, without any production catalyst

. In fact, our technical people think that they can go down to 1.5 without the use of the additional catalyst. Senator Muskie. If they can do that, shouldn't they be required to in light of the other implications of the NOx pollutants or studies and so on?

Mr. RUCKELSHAUS. I think that is certainly a legitimate question for the committee to consider. With the increased exhaust gas recirculation need

, there is presently a substantial fuel penalty in the neighborhood of 15 percent to get down to 1.5.

Senator Muskie. I think my time is up. Senator Buckley has been very patient.

Senator BUCKLEY. Thank you, Mr. Chairman. Mr. Ruckelshaus, the testimony this morning indicates, I gather, that even if there is a reduction in the NOx emission standards, we would still have at least two areas in the country where the ambient. NO, would be above the levels mandated.

Mr. ROCKELSHAUS. There are two areas of the country where they violate the 100 micrograms.

Senator Buckley. The requirement as to ambient standards in accordance with the present law? Mr. RUCKELSHAUS. Yes. Senator BUCKLEY. You, of course, had the miserable duty of having to propose a Draconian approach to meeting the standard in the Los Angeles basin. This brings to mind two statements you made yesterday

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which greatly interested me. One was your statement that you felt there was a need for greater flexibility in handling the LA type of situations. You also stated that as research continues to find that smaller and smaller quantities of pollutants in the air will have adverse health effects. Does this suggest or would you suggest that among the options this committee needs to consider is that of moving away from a policy of zero health risk standards for the entire population?

In other words, ought we to consider as an option the setting of standards which will eliminate the health risk to, say, 99 percent of the population while requiring that areas like Los Angeles be surrounded by signs saying, "Beyond this point breathing may be injurious to your health”?

Mr. RUCKELSHAUs. I think, let me say as far as Los Angeles is concerned, Senator Buckley, that what we want to do in Los Angeles is run out the string on attempting to come up with a most reasonable plan that we can devise that will achieve the standard in Los Angeles by 1975 or 1977. What is it we can do? We are in the process of attempting to do that now. To assess the possibility of setting milestones, assuming that the plan itself appears to be unworkable, setting milestones along the way as to what they might do to achieve the standard ultimately. That is the kind of presentation we would like to make to the committee before we would make any recommendations as to what that flexibility ought to be if in fact we need additional flexibility.

The other question that you raise which is certainly fundamental is supposing in a case like Los Angeles, if you couple the zero health risk standard with the very tight time frame in which the standards must be achieved, and the achievement of the standard itself within that time frame, while there is no question but what it benefits the air, might put such a disruptive force on the community that you have all kinds of effects that when weighed against the improvement in the air seem to be more important to the community.

For instance, if it were necessary, as we now assess, to remove up to 80 percent of the vehicles or reduce by 80 percent the vehicle miles traveled at certain periods in the summer in Los Angeles, what would Te the health effects of that?

Thiere clearly are some health effects. If it affected a person's ability to get to the job, make enough money to buy food, feed his family, it is going to have a health effect on that individual.

We can't weigh that at the present, under the present law, against what we are attempting to do. So you can get at it in one of two ways. You can permit something to be weighed against a zero health risk standard or against the necessity of protecting the public health with one standard or you can give additional flexibility in moving the timeout in which a health related standard can be achieved.

As Dr. Greenfield and Dr. Finklea will undoubtedly tell you, as we get more data on the various pollutants, it is clear that it tends to drive the standard down because we find health effects at ever lower level of these pollutants and it does ampear that for some pollutants there simply is no threshold above which there is no health effect. So it gets to the point of eliminating all of that pollutant from the discharge in order to satisfy a zero health risk standard.

How do you deal with this problem? It is an extremely difficult problem to deal with from the point of view of how you set a standard

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short of a zero health risk in what things are permitted to be weighed
against it. I think historically, as I view the committee's decision to
set a zero health risk standard, it was based on the fact that against
health in the past was weighed the phrase economic feasibility. The
concept of economic feasibility has been often greatly abused in the
past in that it was an excuse for doing nothing.

Having been in the State agency back in the early 1960's, I was faced
constantly in attempting to get compliance with the pollution stand-
ard with that phrase in the statutes. "It is too expensive, can't do it, it
is not worth it. Therefore, we are not going to." In general the courts
would agree with that position.
The question is because the concept of economic feasibility was
abused, does that mean to discard it or is there some way to avoid
the abuses that occurred in the past? I think that is something the com-
mittee ought to consider. It is a very difficult problem to wrestle with.

If I had any suggestions as to how you might resolve it, I would
be glad to give them to you.

Senator Buckley. I was going to suggest, as you are in the difficult
position of having to try to plan strategies, we think about the
alternatives perhaps it could be helpful if you would define for us,
if you can, the areas of flexibility which you feel would enable us to
achieve public policy.

Mr. RUCKELSHAUS. Yes. I would be happy to do that, Senator.
Senator Buckley. Thank you.
There is one other question I would like to ask. It refers to the
question I asked yesterday and again this morning. There seems to be a
conflict between conclusions drawn by the EPA study and by the
National Academy of Sciences as to fuel economy. I refer to this
because I happen to be very much engaged in doing something about
the fuel crisis. But I believe you stated yesterday that it was the EPA
conclusion that the 1975 model year requirements did not have signifi-
cant adverse fuel impact.
Mr. RưCKELSHAUS. Over 1973.
Senator BUCKLEY. The National Academy of Sciences states on page
1 of its study, and referring to the 1973 model year light-duty motor
rehicles, it concludes that model year 1975 vehicles using Wankel
engines or catalyst equipped spark ignition piston engines will use
significantly more fuel than their 1973 counterparts.

Mr. RUCKELSHaus. The Wankel may be based on the fuel penalty
associated with the Mazda rotary engine. Where they arrived at the
comclusion that the catalyst equipped 1975 automobile would have a
significant fuel penalty, I don't know. The basis for my answering your
question vesterday was testimony at the hearings by the major auto-
motive companies, where in fact General Motors said they thought they
would get about the same fuel economy from their 1975 system as they
do from their 1973 vehicles.

The catalyst itself does not cause any significant fuel penalty that
we have been able to discern. There was testimony by Ford and
Chrysler of some minimal fuel penalty problems. But again, in re-
sponse to questioning, a lot of that was answerable on the basis of the
advanced engine modification they might be using or in the case of
Ford, I believe it was the lower NO, standard which they were think-
ing about.

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So on balance, it was our best assessment that it would not be any significant fuel penalty associated with meeting the 1975 standards with the catalyst equipped automobile.

Senator BUCKLEY. I am not questioning your conclusion. I am again disturbed that the public record would seem to have this conflict in the conclusion. I was wondering perhaps if somebody in your agency could consult with the appropriate person that participated in the study?

Mr. RUCKELSHAUS. I certainly will. I don't understand how they conclude that. We will be glad to see any analysis they have and submit it for the record of this hearing.

Senator BUCKLEY. Thank you very much.
I have no further question, Mr. Chairman.

Senator MUSKIE. I am sure all of us would like to pursue this health question and the NOx question further. But at this point this morning we had agreed informally to give you an opportunity to make another presentation that we think is important to an understanding of this whole subject; that is, the impact of the emission controls and the cost effectiveness of alternatives.

I know you have developed such a presentation. I think it would be very useful to the committee and a very important part of the record, and I suspect of interest to the public. If you are ready to present that at this time. I think maybe we should receive it and maybe tomorrow we could get into any other questions on health and NO, matters as the committee may desire.

Mr. RuCKELSHAUS. Mr. Chairman, that is fine. We did have available today both Dr. Finklea and Dr. Greenfield in the event the committee felt there was any necessity to go into the CO and HC health related standard.

Senator MUSKIE. I would like to do that. Would they be available again tomorrow ?

Mr. RICKELSHAUS. Yes.

Senator MUSKIE. I would like to get this other basie presentation today so that tomorrow we can get into whatever questions remain in any area of this subject including this one.

Mr. RưCKELSIIAUS. Mr. Sansom? STATEMENTS OF ROBERT SANSOM, ASSISTANT ADMINISTRATOR

FOR AIR AND WATER PROGRAMS, AND GEORGE V. ALLEN, JR., DEPUTY ASSISTANT ADMINISTRATOR FOR ENFORCEMENT, ENVIRONMENTAL PROTECTION AGENCY

Mr. Saxsom. Mr. Chairman, I don't have formal charts. I think there are about 100 copies in the room. Assuming everyone has a copy cf the handout, what I want to review here very briefly is an analysis of the relationship betreen the emissions standard for the automobile and the number of air quality control regions that would meet the primary standards for the autoinotive related pollutants without transportation controls.

The first chart which you have is a chart that summarizes the present air quality in terms of the number of air quality control regions for carbon monoxide and oxidants that are in violation of the primary standard.

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