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country where that unemployment results indirectly
from delaying the imposition of further regulation
on Detroit.

As to remedies for these situations, I would recommend:

1. Write the trade-off scheme (recently offered by EPA as a proposed regulation) into the Clean Air Act. Expand it beyond EPA's design to permit clean-up actions in non-owned as well as owned plants in the area to achieve the necessary reduction in pollutant levels.

2. Require a study to project ten years into the future the percentage of hydrocarbons which will be cleaned up by Detroit during that period, the percentage of the balance which should be assigned to local government to clean up by transportation controls and the percentage to be left for clean-up by future technological break-throughs. As a related subject, there should be a study of the question of natural background hydrocarbons to determine whether the present .08 standard is realistic.

3. Require a study to determine the percentage of hydrocarbon emissions from paint and solvent manufacture and use which can be cleaned up in the next eight to ten years with present technology and whether it would be preferable to have regulation by local government or uniform federal regulation. (These substances contribute 20 percent of the hydrocarbon emissions.)

4. Require a study of the percentage of hydrocarbon emissions from oil and gasoline production and marketing which can be cleaned up in the next eight to ten years with present technology and whether it would be preferable to have regulation by local government or uniform federal regulation. (These substances contribute 15 percent of the hydrocarbon emissions.)

4

5. A similar study should be required for industrial
processes (which account for about 10 percent of
hydrocarbon emissions.)

In summary, the loss of the Dow Chemical Company plant to the San Francisco Bay area highlights the present distortions to a local economy which can result from putting pressure on new stationary sources while delaying pressure on Detroit. The present policy, which exerts this extra pressure on local new source rules, should be replaced with a consistent national policy developed to treat all parts of the country the same through uniform national rules and goals for all sectors of the economy that emit hydrocarbons. Such a policy would apply uniformly to both Detroit and San Francisco Bay and uniformly to refineries, to users of paints and solvents, and to producers of the internal combustion engine.

Thank you.

The American Hotel & Motel Association is a federation of hotel and motel associations located in the fifty states, the District of Columbia, Puerto Rico and the Virgin Islands, having a membership in excess of 6,500 hotels and motels containing in excess of 850,000 rentable rooms. The American Hotel & Motel Association maintains offices at 888 Seventh Avenue, New York City, and at 777 - 14th Street, N.W., Washington, D.C.

We wish to use this opportunity to briefly express our support for the provisions dealing with indirect sources and transportation controls included in S. 253 and in last year's Conference Report.

The hotel-motel industry along with other real-estate oriented businesses have consistantly supported the goals of the Clean Air Act.

Our industry's main concern with the Act stems from Environmental Protection Agency's indirect source and parking management programs. Those programs are ostensibly designed to regulate facilities which standing alone do not pollute but because they attract automobiles are found to pollute.

Beginning in July of 1974, the Environmental Protection Agency (EPA) attempted through regulation in all 50 states to begin an indirect source review program. That program was prevented by both court and Congressional action. In both instances, we like to believe that the argument of equity prevailed. Simply, if the real culprit is automobile emissions, then effective attempts should be made to deal first with that situation before, secondary or indirect sources are asked to bear burdens.

Honorable Edmund S. Muskie

Page two

February 15, 1977

Efforts by the Congress to enact a reasonable clean air bill in the 94th Congress failed but our primary concerns were recognized. Especially convincing was language found in the Report on the Clean Air Act Amendments of 1976 by the House Committee on Interstate & Foreign Commerce which read:

"Section 201 (limitation on indirect source review
authority) of the Committee bill recognizes the va-
lidity of many of the arguments of those opposed to
the current indirect source regulations. For in-
stance, there can be no doubt that the primary em-
phasis of any air pollution control program must be
on the reduction of air pollution--including that
generated by automobiles--at the source. Consider-
ations of equity and common sense demand that pri-
mary emphasis be placed on the prevention of pollu-
tion by reducing the emissions from each and every
new automobile tail pipe. Efforts based on indirect
control of the use of automobiles through restric-
tions on parking lots, shopping centers and other
indirect sources, rather than full and prompt con-
trols for new autos, trucks, buses, and motorcycles
are inherently inequitable. It transfers from the
motor vehicle manufacturers to the public and to in-
direct source owners and operators the burden of
protecting public health from dangerous vehicle
emissions.

"But the Committee is also aware that even after new
car emissions meet the full standards first required
by the 1970 Clean Air Act, many communities will re-
quire additional measures if national ambient air
standards are to be attained and maintained.

"With increasing awareness of the environmental causes
of many serious diseases, including heart and pulmon-
ary disease, and various forms of cancer, there can be
no doubt of the urgent need to protect those who are
'at risk' from air pollution, including the elderly,
the infirm and the very young.

"There can be no doubt, therefore, of the need for
additional control measures in areas where ambient
standards will be exceeded after the statutory attain-
ment date for meeting health standards. These measures
may include all additional feasible control measures on
stationary sources of mobile source air pollutants,
tighter emission controls on new trucks, buses, and
multi-purpose vehicles, measures to improve traffic flow,

Honorable Edmund S. Muskie

Page three

February 15, 1977

expansion and improvement of public transportation,
vapor recovery, and even perhaps, in some cases, re-
view of new facilities which attract heavy automobile
traffic.

"But the Committee is especially cognizant of the
potential sweeping consequences and potentially so-
cially and economically disruptive impacts which may
result from efforts to reduce automobile pollution
through mandated reductions in parking supplies and
restrictions on new parking facilities."

As noted at the outset, we support S. 253, and believe it is the best bill pending before your Committee regarding Amendments to the Clean Air Act of 1970. We do believe that the bill would be even better if it contained Section 305 of last year's House passed Clean Air bill, H.R. 10498. That Section dealt with the administrative procedures EPA must follow when promulgating regulations and the standard by which courts review action taken by EPA.

We appreciate your making this statement part of the Record.

Sincerely,

Albert Mermett

Albert L. McDermott
Washington Representative

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