I want to make it clear that we are not merely discussing some theoretical proposition. The large majority of the country-virtually all of the areas outside large cities and inner suburbs-has air quality which is better than the national secondary standards for one or more of the six pollutants. If EPA's policy of allowing and indeed encouraging significant deterioration had been permitted to stand, the air quality of this entire area could have deteriorated to the secondary standards. This would mean, for example, that the level of sulfur oxides and particulates in the Rocky Mountains and the Blue Ridge could be allowed to increase to the level of Boston, Akron, Detroit, and Pittsburgh. What we are discussing and what is at stake here is the "graying" of America.

This process of massive deterioration of air quality was already well underway in some of the areas of the country with the cleanest air. In the Southwest, where visibility has ranged up to 100 miles, huge coal-burning powerplants, including the infamous Four Corners plant, were spreading a pall over the entire region. This haze often exists over Mesa Verde National Park in Colorado and threatened to enter the Grand Canyon. The pollution from the plants in New Mexico alone will emit 50 percent more nitrogen oxides than all the present nitrogen-oxide emissions in the State.

Even the plans for a large number of additional coal-burning powerplants in the Southwest, however, are dwarfed by the plans for the Northern Great Plains. The Federal Government and electric utility companies plan to locate in northeastern Wyoming and southeastern Montana 25 coal-burning powerplants, including 13 10,000-megawatt plants, with a combined capacity of 166,000 megawatts.

In comparison, the Four Corners plant in New Mexico is only onefifth the size of a single one of the 10,000 megawatt plants. The plants in Wyoming will produce far more than 100 times as much nitrogen oxides as are now produced in the air pollution region which includes approximately two-thirds of the entire State of Wyoming and 8 to 14 times as much pollution as New York City.

While the coal-burning electric powerplants in the Southwest and Northern Great Plains are the most dramatic examples of the deterioration of air quality which would have resulted from EPA's policy, similar deterioration would have resulted in other parts of the country. The natural result of these policies would have been to produce a relatively even level of pollution across the country. As we improved the air in our cities, the pollution level over other larger areas would have been increased by as much as 2, 5, or even 100 times.

There are those who say that this massive deterioration of air quality is not of any major importance. They argue that the deterioration could not exceed the national secondary standards and that, by definition under the Clean Air Act, any pollution below the seondary standards can have no harmful effect on health, crops, wildlife, or anything else. Unfortunately, however, the scientific premise to this argument is simply untrue-serious harm does result from pollution which is less than the national standards.

The basic assumption for any contention that no harm occurs at pollution levels below the secondary standard is that a precise threshold level for the six pollutants has been established. In fact, no threshold level for health or other effects has been found and probably

none exists. Numerous scientists have told congressional committees that threshold levels are merely a convenience so that "one can sleep nights" and the purported thresholds merely reflect the limits of scientific knowledge at a particular time.

HEW itself has stated that "[a]ll exposures of man and other living things to air pollution almost certainly involve some degree of biological risk" and this is particularly true for the very young, for the old, and for persons with lung, heart, and other chronic disease.

Our experience in other fields suggests that there is either no threshold level for air pollutants or at least that the threshold levels will have to be substantially reduced in future years as more scientific information is obtained.

Stricter standards have been adopted for such toxic elements as radiation, asbestos, mercury, and beryllium. EPA's own air quality criteria for sulfur oxides state:

If all of man's previous experience in conducting environmental hazards provides us with a guide, it is likely that improved knowledge will show that there are identifiable health and welfare hazards associated with air pollution levels that were previously thought to be innocuous.

In fact, new studies are now showing that serious health hazards are associated with air pollution levels below the secondary standards. A study of heart disease, arteriosclerosis, and certain forms of cancer and congenital defects in 38 metropolitan areas showed a correlation with all levels of pollution, including levels below secondary standards, and concluded that the statistics supported the conclusion that the air pollutants cause changes in basic body cells and serious dangers of congenital defects and cancer.

A study of deaths from respiratory and heart disease in New York City concluded that no threshold level exists and that the relationship existed for lower, as well as higher, levels of pollution. EPA scientists involved in studies on the effects of air pollution have recently said that asthma attacks increase when sulfur oxides reach 50 percent of the level of the secondary standards and that particulate levels which were one-third of the secondary standards aggravated chronic heart and lung disease and increased asthma attacks. And a recent EPA study concluded that the danger from suspended sulfates is so great that "it would be prudent to control ambient sulfur dioxide much more stringently than is now planned."

Other recent scientific studies show damage to vegetation and to materials such as concrete, steel, and textiles from levels of pollution below the secondary standards.

EPA's policy of allowing significant deterioration of air quality would produce serious harm to the environment by making rainwater more acidic. Acid rain is caused by the conversion of sulfur oxides and nitrogen oxides to sulfuric and nitric acid in the air. Under EPA's policy, while air pollution decreased in our cities, it would have been allowed to increase in clean air areas.

Since far more of the country has air quality below one or more of the secondary standards than above them, EPA's policy would have allowed a total increase in the amount of pollutants in the air. This would have increased the amount of acid rain since the quantity of acid rain depends upon the total amount of pollution in the air rather than the ambient air quality in a particular place.

Recent studies have demonstrated that acid rain, even at today's levels, poses serious dangers to soil, vegetation, lakes, and rivers, and the fish and other life which live in them. In Hubbard Brook, N.H., which is 200 miles from any major industrial area, rainfall is 100 to 200 times more acid than normal rainfall. This rain seems to affect the growth of plants by leaching out elements needed for growth. While serious study of acid rain is just beginning, it is extremely likely that acid rain will be seen as a major environmental problem in the future. The effect of increased air pollution, even below the secondary standards, on visibility is beyond dispute. EPA's criteria documents for particulates, sulfur oxides, and nitrogen oxides show a direct relationship between air pollution and visibility. For example, an increase in particulates from 30 micrograms per cubic meter, which is the typical level in rural areas, to the secondary standards would cut visibility in half from 25 to 12.5 miles. In areas of the West, where present visibility is often 50 to 100 miles, a reduction of visibility to 12.5 miles would be even more serious.

I might add that at the level of the secondary standards it would not be possible to see the North Rim of the Grand Canyon from the viewpoints on the South Rim near Grand Canyon Village.

When the level of sulfur oxides reaches the secondary standards and humidity is 98 percent, visibility is only 3 or 4 miles. And the effect on visibility is even greater when these pollutants are combined.

It is easy to dismiss visibility as unimportant, as merely a luxury which can be readily sacrificed. However, the difference between cystalclear air and the haze of our cities makes a dramatic impact on the quality of life. Already the haze over the Rocky Mountains and the Southwest can be readily seen. Soon, when we want to escape the perpetual haze of our cities, there will be no place to go.

I have only described a few of the studies which show the serious harm which will occur if we allow the deterioration of air quality to spread across our country. It is indisputable that significant increases in air pollution below the secondary standards are a danger to public health, to the environment, and to the quality of life. That, however, as I would readily agree, is only one-half of the equation. The other half involves the economic and social cost of prohibiting significant deterioration.

We have heard much about the serious consequences which will result from a prohibition against significant deterioration. All kinds of extreme statements were made by EPA and industry in their briefs about how our cities would be unable to solve their pollution problems unless the major sources of pollution were moved to the countryside, about how no growth would be possible in rural areas, and about how electric powerplants could not be built. All these statements are untrue.

I think there is some irony in the fact that industry often accuses conservationists of being emotional about these problems. I think some of the statements we have heard from industry on this subject, and even some from EPA border on hysteria.

The claim that pollution in our cities cannot be reduced without moving the pollution to rural areas is simply wrong. The industrial pollution in our cities can be controlled with few, if any, exceptions, by strict emission controls. The most difficult urban pollution comes from the automobile, not industry, and the prohibition against significant deterioration will have little effect on automobile emissions. If there

is any doubt about whether the prohibition against significant deterioration will add to the air pollution problems of our cities, it is surely answered by the fact that New York City, Boston, and virtually every major industrial State-New York, California, Illinois, Ohio, Pennsylvania, Michigan, Texas, Massachusetts-all supported the prohibition in the Supreme Court.

It is likewise untrue that the prohibition against significant deterioration will halt all growth in rural areas. Despite the statements of many critics, Fri v. Sierra Club was not a nondegradation case. As the district court explicitly ordered, only significant deterioration of air quality is prohibited. This obviously means that some nonsignificant deterioration is allowed.

Moreover, most clean air areas in the country, even though the level of pollution is below secondary standards, have some, and often considerable, manmade pollution. If the level of this existing pollution is reduced, for example, by better control on emissions from present sources, new sources can emit an equal amount of pollution without any increase in the total level of pollution at all.

This point was illustrated, I think, by the material handed out by EPA in their press conference about 10 days ago announcing what they planned to do in going ahead with the policy of no significant deterioration. They presented an analysis in their statement showing that the concentrations of particulates in the rural areas of New England would decrease by 25 percent the cost of the cleanup of sources in the industrial areas 100, 200, or 300 miles away.

There is, therefore, a margin for further industrial development in New England that will come about as the sources in the cities are controlled and the pollutants coming into the rural areas is reduced, thereby giving new industry an opportunity to put new plants which will have some emissions without exceeding the baseline levels which were present at the time the Clean Air Act passed.

Better technology exists than is being used to control many pollution sources. Furthermore, the prohibition against significant deterioration is likely to induce the spending of more money on research and new devices. Consequently, if as the Senate report said, site selection, the most advanced technology, and other methods are used, substantial development can occur in rural areas.

Finally, it is untrue that the prohibition against significant deterioration will stop the construction of new powerplants. Large oil- or coal-burning powerplants can be built in locations with existing powerplants by applying the most advanced technology to both the existing and new plants. More modest-sized plants can be constructed in other areas without causing significant deterioration if the best technology is applied. There is a lot of loose terminology concerning best technology, best available technology, and so on. When I refer to best technology, I am not necessarily referring to what EPA had adopted on the national basis as the best available technology. We don't think that that really is the best technology that can be used to control emissions of, for example, sulfur oxides.

There are examples of emissions being controlled to much higher levels than even EPA has said they plan to implement. Electric power can be produced from coal with relatively little air pollution by first converting the coal to gas or liquid. Most of these processes are in the development stage; they have suffered a lack of attention, a lack of

priority being given to them by both industry and the government. I think they have a good deal of promise. If developed to appropriate specifications the emissions should be very, very low from those

processes.

There are some processes that can be built right away. For example, one process is called gasification technology which is commercially available.

And, of course, nuclear power, and, in the near future, solar power, geothermal power, and other new techniques can produce electricity without any deterioration of air quality.

I do not want to suggest that the prohibition against significant deterioration of existing air quality can be carried out without any cost. Industrial and other development will have to be carefully planned. Money will have to be spent in applying the best present technology and, even more important, developing new technology as quickly as possible. The cost of energy and other commodities will undoubtedly be increased. And this country will finally have to start on a major effort, supported by carefully drawn regulatory and tax policies, to

conserve energy.

These actions are urgently needed regardless of the prohibition against significant deterioration. If we are to save the environment, if we are to have a reasonable supply of gasoline and fuel oil, if we are to meet a host of other problems, we must both achieve major breakthroughs in the technology of energy production and end the incredible waste of energy. But neither industry nor Government is likely to spend the money or make the difficult decisions which are needed as long as they have an easy way out. As long as control of air pollution does not have to be achieved, as long as the pollution can be simply moved to another place, as long as coal-burning powerplants can be located far away in New Mexico or Montana, the difficult decisions which must be made will be avoided.

The decision of the courts to prohibit the significant deterioration of existing air quality forces all of us to face the problems which must be faced.

I then go on in my statement to quote some statements that were made by you, Mr. Chairman, and also Senator Cooper which I think express the fact that Congress knew when it passed the Clean Air Act that it would cost large amounts of money and require a major sacrifice. We owe a great deal to the leadership that has been provided by this committee in making that as clear as possible, not only at the time the legislation was discussed, but also in the years that have passed since then.

The obvious question now is where do we go from here?

The first step in carrying out the intent of Congress and the decision of the courts is for EPA to promulgate regulations which will effectively protect existing air quality. EPA was placed under court order on May 30, 1972, to review all the State plans and to determine which effectively prohibited significant deterioration by September 30, 1972. After failing to obtain a stay, EPA flagrantly violated the court order by taking no action concerning the State plans until November 7, 1972. On that date EPA disapproved all the State plans in that they did not effectively prevent significant deterioration.

The District Court's order further required EPA to promulgate regulations effectively prohibiting significant deterioration for each