-2 economy performance than 1974 models and that these 1975 levels are comparable to pre 1968 uncontrolled levels. In these days of energy consciousness, such evidence can not be ignored. Congress must heed the sucess of Volvo in meeting automotive emission standards and in fuel economy and demand equal performance from U.S. automobile manufacturers. Part B-Ozone Protection Although the full impact of halocarbons on the earth's ozone layer is not completely understood, the Ozone Protection section of S.252 is a conservative approach to this potential health hazard. The evidence accumulated to date about the harmful health effects of halocarbon use and the feasibility of replacing products with non-aerosol sprays suggests that this issue should be resolved in favor of public health. S.252 should be amended to ban all non-essential uses of aerosol products which utilize fluorocarbons, such as most aerosol spray containers, as of a certain date. National Commission on Air Quality Section 315 establishes a National Commission on Air Quality. The Commission, in addition to certain members of Congress, will consist of twelve members of the public. APHA feels the composition of the Commission should be further defined to insure majority representation of the consuming public and persons with expertise in public health. Training S.252 should be amended to include the training amendments of S.253. The language of this section would make the provision of training to personnel of air pollution control agencies and others with suitable qualifications mandatory. In order to fully implement the provision of the Clean Air Act, a supply of trained manpower must be insured through federally supported training programs. Health Effects Research Greater national attention must be paid to research dealing with the health effects of air pollution. Research should not be confined to "in-house" EPA efforts, but should be carried out nationally through geographically represented centers of research excellence. The American Retail Federation would like to take this opportunity to again express our desire for the passage of amendments to the Clean Air Act. The Federation is an umbrella organization which represents before Congress and the Executive Branch of government all 50 state retail associations and 31 national retail associations (lists attached), as well as many corporate members. This total membership encompasses nearly onethird of the GNP and acts as an employer for over 12 million Americans. This group is affected by the Clean Air Act, not only as citizens in whose behalf Congress legislated this law for their health and welfare, but also as businessmen. The Environmental Protection Agency issued regulations in response to a court decision on July 1, 1974, which were to go into effect on January 1, 1975. These regulations called for pre-construction review of parking areas of a certain size and, in this manner, would regulate indirect sources throughout the United States. These indirect sources are the areas which are deemed to attract direct sources of air pollution. They include parking lots of almost all major buildings. At the direction of Congress, these regulations were suspended several times in order for Congress to consider their application and effect while deliberating on the amendments to the Clean Air Act. The present suspension will terminate on September 30, 1977, unless Congress takes action on this legislation before then. Honorable Edmund Muskie The Federation has long been involved with the issues of the Clean Air Act, as most members of Congress know well. A representative of our membership testified in 1974 and again in 1975 before Senate and House Committees. We have closely followed all levels of your deliberations. After the long conference of the House and Senate at the end of the last Congress, retailers actively worked to obtain passage of the bill and report. All Congressmen and Senators were contacted, advising of retailing's support and urging acceptance of the bill. In these current 1977 hearings, the issues affecting retailing remain the same. ARF presents this letter and the attached statement (our 1975 testimony to your Committee) to reemphasize that indirect source issues must be addressed in any amendments to the Clean Air Act. Sincerely, Loyd Hackler Loyd Hackler STATE AND NATIONAL MEMBERSHIP OF THE AMERICAN RETAIL FEDERATION NATIONAL CONFERENCE OF STATE RETAIL ASSOCIATIONS Alabama Retail Association Alaska Retail Association Arizona Retailers Association Arkansas Retail Merchants Association California Retailers Association Colorado Retail Council Connecticut Retail Merchants Assn., Inc. Delaware Retail Association D.C. Metropolitan Washington Board of Trade Florida Retail Federation Retail Merchants of Hawaii Kansas Retail Council Massachusetts Merchants, Inc. Montana Retail Association Retail Merchants Association of Nebraska Nevada Retail Association Retail Merchants Assn. of New Hampshire New Jersey Retail Merchants Association New Mexico Retail Association New York State Council of Retail Merchants North Carolina Merchants Association North Dakota Retail Association Ohio State Council of Retail Merchants Oklahoma Retail Merchants Association Oregon Retail Council Pennsylvania Retailers Association, Inc. Rhode Island Retail Federation South Carolina Merchants Association South Dakota Retailers Association Tennessee Retail Merchants Association Texas Retail Federation Utah Retail Merchants Association Vermont Retail Association Virginia Retail Merchants Association Assn. of Washington Business Retail Council West Virginia Retailers Association, Inc. Wisconsin Merchants Federation Wyoming Retail Merchants Association CENTRAL COUNCIL OF NATIONAL RETAIL ASSOCIATIONS American Association of Nurserymen, Inc. Associated Retail Bakers of America Direct Selling Association National Appliance & Radio-TV Dealers Assn., Inc National Association of Food Chains National Assn. of Installment Companies, Inc. National Association of Music Merchants, Inc. Natl. Assn. of Retail Grocers of the U.S., Inc. National Decorating Products Association National Home Furnishings Association National Sporting Goods Association Retail Floorcovering Institute Soc. of American Florists & Ornamental Horticulturists STATEMENT OF THE AMERICAN RETAIL FEDERATION on THE CLEAN AIR ACT Before The Subcommittee on Environmental Pollution United States Senate by Eugene F. Rowan Divisional Vice President and Director of Urban Affairs J. C. Penney Company Chairman Environment & Energy Committee American Retail Federation APRIL 24, 1975 AMERICAN RETAIL FEDERATION 1616 H ST., N.W., WASHINGTON, D.C. 20006 |