STATEMENT OF LABOYTA GARNAND, COLORADO AIR POLLUTION

CONTROL COMMISSION

Ms. GARNAND. Thank you, Senator Hart.

I wish to state for the record that my remarks have not been reviewed by the commission or any of the other groups which I am currently a member of. Therefore, I am speaking as an individual.

Colorado, and specifically the Denver metropolitan area, is required to reduce carbon monoxide and hydrocarbons, it has been estimated, by about 64 percent and 60 percent respectively from the 1971 emission levels, a 31-percent reduction of vehicular miles traveled, according to our State Implementation Plan.

As a citizen representative on the commission and various advisory groups over the past 5 years, I have been wrestling with the problems of trying to make a dent in this problem. I am sorry to state that we have made very little progress with respect to reducing pollutants from the automobile-related sources. I do think, though, that there are three areas which concern me about the future of these programs and about which I think the Federal Government can considerably help the States and local governments to make some progress.

First of all, a State inspection and maintenance program, after sale, of automobiles appears to be the most effective strategy that we know of at the present time in the Denver area to reduce carbon monoxide and to get some reductions in hydrocarbons. We feel that it will be especially helpful in getting us the benefits of the new Federal motor vehicle program.

In order to do this and in order to sell it, I think we need some help from the Federal Government. We need valid base line emission. data from the 1977 automobiles, and newer. We need test information which will provide us with the kind of data we need to get an understanding of the correlation between the Federal motor vehicle test cycle and the idle test which we are proposing to use at the State level. We have asked the Environmental Protection Agency for this kind of data. They are considering our request.

It seems to me that it would be extremely helpful to us and to all other States that are using or proposing the inspection and maintenance program to have it done at one central point where it could be shared by all the States. The second thing that I am concerned about is transportation control measures. It is undoubtedly true we are going to have to use some other methods besides directly controlling the emissions from the automobiles in order to reduce transportationrelated pollutants.

I think that the problems that we have been running into at the State and local level recently in looking at the various kinds of transportation control strategies are related to the fact that we do not have any kind of broad-based comprehensive information about the reductions that are possible and the socioeconomic costs of the implementation of various kinds of strategies. These are difficult decisions to make. They require changes of government and citizens. I think if the Federal level could provide this kind of broad-based comprehensive study that could be either used as the basis for local and State agencies to build their own particular studies on or it

could direct us to the kind of things that need to be considered in our studies at the local level, I think it would be tremendously helpful.

I think the third thing that concerns me is the coordination of the various federally required planning programs that are currently in progress. We have a planning required for housing, for water quality and sewage treatment, for air quality, and for highways— all federally required through various programs.

It seems to me that these programs have tended to go off in separate directions. They have their own funding sources. They have their own sets of criteria. And rightly so. But often we find that perhaps the development patterns that might be required by extension of a sewage treatment line might not be the desired development pattern that you would want for a highway source or for the air quality problems.

In summary, I think that I would like to say that the time is right for shifting the Federal role from the adversary position which we have sometimes experienced in the past to a partnership role, in which I think you, the Federal level, provide the kind of information and flexibility we all need to solve air pollution problems.

Above all, I think the studies and guidelines that are provided by the Federal level have to be very clear and very easy for citizens and nontechnical policymakers to understand, because in the final analysis I believe these are the groups who have to solve the problems and make the decisions.

Thank you.

[Ms. Garnand's prepared statement appears at p. 19.]

Senator HART. Just to interpose one question before we go forward, in your judgment, is the adversary relationship between the Federal and State Governments a product of legislation or the way it is administered?

Ms. GARNAND. It is perhaps more a product of the way it has been administered. I think it is important not to impose or require or mandate strategies without the kind of supporting data I have been talking about.

I think that is really a problem. It does not allow us the flexibility that we need. What is right for Washington or New York may not be right for Denver.

Senator HART. I would like to pursue that in a few minutes, because I think it is extremely important whether it is the law itself, the way it is written, that causes that confrontation or whether it is the way that law is carried out. I think that is very important to us.

I would like to ask the indulgence of the panel in interrupting at this point so that we may hear from Congresswoman Schroeder. Then we can pick up exactly where we left off, if that is agreeable to everyone.

I am pleased to have Congresswoman Schroeder with us. She has been extremely concerned about the quality of the air and air pollution problems in the Denver area which she has represented for the last 4 years. I am glad she could take the time to be with us this morning.

STATEMENT OF HON. PATRICIA SCHROEDER, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF COLORADO

Ms. SCHROEDER. Thank you very much, Gary. I would like to apologize for having to bump the people on the panel. We get started early every morning, but somehow we always get behind schedule.

I am going to discuss something you know an awfully lot about already, Gary, but I want to take a few minutes to go over it again, because I think it is so very important. One of the very fine people in Denver, R. L. Rickenbaugh of Rickenbaugh Cadillac, came upon a tremendous problem with the original Clean Air Act. The problem was that vehicles were being set for sea level operation, and when you brought them up to a high altitude, the emission control devices produced a fuel mixture that was excessively rich, causing a vehicle to emit up to twice the amount of pollutants as a well-tuned vehicle at sea level. However, automobile dealers could not adjust the emission control devices to perform more efficiently at high altitudes without being in jeopardy of violating the antitampering provision of the Clean Air Act, which carries a $10,000 fine. As a result, we have attempted to amend the Clean Air Act for several years to remedy this situation.

You are well aware of the nature of the amendment, Gary, since you helped us with it last time. I think it is very, very important that we push for it again. In essence, all it does is permit auto dealers to adjust emission control devices on all 1968 to 1976 model year vehicles and on 1977 and later model year vehicles not specifically manufactured for high altitude operation to improve the high altitude emissions performance of those vehicles. Auto dealers would be given printed instructions provided by the automobile manufacturers and approved by EPA on how to best adjust the emission control devices to improve their performance at high altitudes.

The argument has been made that the amendment should only affect model year 1968 to 1976 vehicles, since EPA has issued regulations which, beginning with model year 1977, would allow manufacturers to ship only cars that will meet the air quality standards at their designated place of sale. However, with our population being as mobile as it is, the problem of vehicles geared for sea level operation ending up in a high altitude area must be dealt with. That is a great problem here in Colorado, because so many people move here every year from lower altitudes. Even if these people are driving vehicles manufactured after EPA's regulations went into effect, these vehicles, if purchased in a low altitude area, would be geared for sea level operation and would require adjustments to perform properly at high altitudes.

In sum, the amendment is very simple. There have been all sorts of rumors as to what it does. In essence, that is all that it does. I would like to mention that Representative Tim Wirth and I will be offering the amendment this year as part of the original Clean Air Act Amendments of 1977 which Representative Paul Rogers, chairman of the House Subcommittee on Health and the Environment, will be introducing in the next few weeks. I hope that this time we will

finally get it passed. The irony of the high altitude situation has been that something can be done to alleviate the problem, but a combination of bureaucratic redtape and legal haggling has prevented anything from being done. As a result, I think mandating a solution through legislation is the most sensible way to proceed. That way we will solve the problem once and for all.

Before leaving, I would like to take a moment to commend Dick Deane. His advice and suggestions have helped make our amendment the most workable legislation possible, and his efforts are much appreciated.

Senator HART. Thank you very much. I think it is important, because there has been some misunderstanding of the high altitude. emission control provision which you mentioned, both the one you introduced in the House and a similar version which was introduced in the Senate, about whether the intent is to permit automobiles operating at high altitudes in areas such as Denver to perform well or worse in terms of their emissions than automobiles operating at lower altitudes. I think it would be helpful for the record to clarify what the purpose and intent of this amendment would be.

Ms. SCHROEDER. The intent of the amendment is to allow vehicles to perform more efficiently at high altitudes, thereby decreasing the emission of pollutants and improving air quality.

Senator HART. I think that is extremely important because there have been those who felt the exceptions for the provisions proposed in both versions of the bill were for the purpose of somehow permitting automobiles to operate less efficiently or in a more polluting capacity than other parts of the country. That obviously is not your intent, nor was it mine. I think that is very important to have in the record.

Ms. SCHROEDER. Thank you.

Senator HART. Anything else you wanted to add?

Ms. SCHROEDER. No. Basically, that is it. I really do think that it is important for all of us to work together to solve the high altitude. emissions problem, since there are so few of us, proportionately, living in the high altitude areas. I think the proportionately small number of people living in high altitude areas was the reason the high altitude emissions problem was overlooked in the original bill. In any event, I certainly hope we can finally get the situation turned around. I thank you very much for the time. I again extend my apologies to the panel.

Senator HART. Thank you very much for coming by.

We will resume if our panel members will come back. This prob lem that Congresswoman Schroeder mentions is a problem we share with a city such as Albuquerque or Salt Lake City.

Pat has met with representatives of the automobile industry in this area, and I have also. It is a matter of great concern. I think, for those in the automobile industry to try to accommodate the provisions of the law and do so as responsible citizens.

We had heard a summary statement from Ms. Garnand. I think we will go to Professor Corrin who is a member of the Colorado Air Pollution Control Commission as well as a professor of the department of atmospheric sciences. Colorado State University. Fort Col lins, Colo.

STATEMENT OF MYRON L. CORRIN, DEPARTMENT OF ATMOSPHERIC SCIENCES, COLORADO STATE UNIVERSITY

Mr. CORRIN. First let me state, as did Ms. Garnand, that I speak for myself and not as a representative of other commissions or the Colorado State University. I would like to briefly comment on three issues. The first deals with the major air pollution problem along the Front Range extending from at least as far south as Colorado Springs to at least as far north as Fort Collins, which is pollution caused by the automobile. I would consider that one measure that must be taken to alleviate this pollution is the control of automotive emissions at the Federal level. I would again feel that there can be little delay in imposing such regulations. I am furthermore, however, concerned with the fact that we know so little about the complex atmospheric interactions between hydrocarbons and nitrogen oxides which lead to the formation of ozone that the controls imposed purely on the basis of a 90-percent reduction from some standard year may not be the optimum controls at all and would suggest that continued study be made of this complex phenomenon so the optimization of controls for hydrocarbons and nitrogen oxides can be imposed.

Let me further state that in my opinion pollution controls are not going to solve the problem along the Front Range, that we must go to some method to reduce the use of the automobile. I think the Federal Government has very wisely assigned the decisions to be made in this regard to local governments. But I don't think the local governments have been supplied with the resources and capability to make rational decisions. It is a very complex problem. It involves technological factors, social factors, economic factors, and political factors.

It is a complex system and subject to a discipline which is used to study complex systems, namely, systems analysis. I very strongly suggest that the Federal Government make available to local communities the services and trained analysts in this field or provide a training program to the local government so that it in effect can operate most efficiently.

I think it is further essential that given the resources of local governments, Federal support be given to obtain the necessary data by which to evaluate the possible strategies, and then in terms of the value judgment of the local communities they will reach some planning decision.

Let me speak to the second issue which is that of ambient air quality standards that were adopted some years ago on the basis of information available at that time. Since then we have considerably more information which suggests that some of the standards might be inadequate or quite overprotective.

Colorado, as you know, is a dry State; it is a windy State. I am not too sure that in many parts of the State we could ever hope to achieve the Federal standard for total suspended particulates. This is a concentration standard. It is based upon micrograms per cubic meter. It pays no attention to the health effect of the particulates which is size-dependent. It pays no attention to visibility reducing particles and producing phenomena like the Denver brown cloud.