Hon. Edmund S. Muskie
Page Three

February 17, 1977

Particularly troublesome also is Section 121(a) which would amend Section 110(a)(2)(E) of the Clean Air Act by, in effect, permitting the governor of one state to prohibit any stationary source located within another neighboring state from operating if he determines that exhaust emissions from that source would prevent attainment of air quality standards in his state. A compressor station located in one state could be operating well within that state's ambient air quality standards but would run afoul of the standards in a neighboring state. Since one interstate pipeline may transverse or serve several states, it is not difficult to imagine the adverse economic and social impact of interrupting the flow of natural gas should one state secure a restriction on a compressor station emission located in the neighboring state. The identical concern extends to Section 124(d) and specifically, the possibility of having to replace old compressor stations with newer models, even though no significant improvement in exhaust emissions could be attained.

We would strongly urge, therefore, that S. 253 be amended so as to exclude from its provisions compressor stations located on natural gas transmission lines. At the very least compressor stations should be excepted from the above-noted provisions of S. 253.

We would be pleased to provide any information we can should you desire further assistance in this matter.

Yours truly,

Matte

Walter E. Rogers
President

JJM:eoc

THIS MESSAGE IS SUBMITTED FOR THE RECORD OF THE PUBLIC HEARINGS ON
S-251, S-252, AND S-253 CONDUCTED ON 9, 10, AND 11 FEBRUARY 1977 WITH
THE UNDERSTANDING THE DOCKET IS OPEN THROUGH 15 FEBRUARY 1977.

I WAS PLEASED TO NOTE THE REMARKS OF SENATORS HART AND
MUSKIE ON 11 FEBRUARY DURING THEIR INTERROGATION OF THE
REPRESENTATIVE OF THE NATIONAL ASSOCIATION OF REALTORS.
THESE REMARKS REFLECTED A RECOGNITION ON A BROAD BASIS OF THE

SF-1201 (RS-69)

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IMPORTANCE OF BALANCING COSTS AND BENEFITS IN THE LEGISLATIVE AND
RULE MAKING PROCESSES. CONCERN WAS

ALSO EXPRESSED FOR INTERACTING

EFFECTS OF CONTROLS FOR FARIOUS QUALITIES, SUCH AS CLEAN AIR VERSUS ENERGY CONSERVATION.

WITH REGARD TO THE CONTROL OF EMISSIONS FROM HEAVY DUTY VEHICLES
AND ENGINES, THIS PHILOSOPHY WOULD

SUPPORT THE PROVISIONS IN S-253
REGARDING REGULATION OF THESE PRODUCTS. THE INTERNATIONAL HARVESTER
COMPANY ENDORSES THESE

PROVISIONS AND URGES THEIR ADOPTION.

IN OCTOBER 1975 THE INTERNATIONAL HARVESTER COMPANY

PREPARED A DOCUMENT WHICH SUMMARIZED KNOWN FACTS REGARDING THE RAPID

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I V TVCREASEING LOSS IN FUIFI ECONOMY OF HEAVY DUTY DIESEL AND GASO

wu

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LIVE ENGINES, AND THE INDICATED ACCOMPANYING DEGRADATION OF ENGINE
DURABILITY, AE EMISSION CONTROLS ARE MADE MORE

STRINGENT. THIS DOCUMENT WAS PROVIDED TO AND REVIEWED WITH SEVERAL
MEMBERS OF THE SUBCOMMITTEES AND/OR THEIR STAFF PERSONNEL IN LATE
1975 AND INTO 1976. WE FEEL THAT THE HEAVY DUTY ENG IVE EMISSION
CONTROL PROVISIONS OF S-253 WERE, IN PART AT LEAST, DRAWN IN CON-
SIDERATION OF THESE FACTE. MUCH OF THE MATERIAL IN OUR SUMMARY DOCU-
MENT WAS IN THE FORM OF A COLLATION OF DATA PRESENTED INDIVIDUALLY
EBY SEVERAL HEAVY DUTY ENGINE MANUFACTURERS TO THE CALIFORNIA AIR
RESOURCES BOARD IN APRIL 1975. MORE

RECENT TESTIMONY TO THAT BOARD CONFIRMED THE QUANTITATIVE EFFECTS PRESENTED IN APRIL 1975.

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IN CONFIDERATION OF THESE FACTS. WE HAVE ARRANGED FOR SEPARATE

84-239 - 77 - 42

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DELIVERY TO YOU OF A COPY OF THE STILL PERTINENT INTERNATIONAL HARVESTER DOCUMENT PREPARED IN OCTOBER 1975. WE REQUEST THAT

ALONG

WITH THIS MESSAGE, BE INCLUDED AS A PART OF THE OFFICIAL DOCUMENTATION DOCKET OF THE FEBRUARY 1977 HEARING S

RODGER F RING HAM

CORPORATE VICE PESIDENT

INTERNATIONAL HARVESTER COMPANY

NN N N

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