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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.

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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
February 15, 1977
Page Two

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
Georgia Retail Association

Retail Merchants of Hawaii
Idaho Retailers Association, Inc.
Illinois Retail Merchants Association
Indiana Retail Council, Inc.
lowa Retail Federation, Inc.

Kansas Retail Council
Kentucky Retail Federation, Inc.
Louisiana Retailers Association
Maine Merchants Association, Inc.
Maryland Retail Merchants Assn., Inc.

Massachusetts Merchants, Inc.
Michigan Retailers Association
Minnesota Retail Federation, Inc.
Mississippi Retail Merchants Association
Missouri Retailers Association

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
Association of Family Apparel Stores
Association of General Merchandise Chains

Direct Selling Association
International Franchise Association
Mail Order Association of America
Menswear Retailers of America

National Appliance & Radio-TV Dealers Assn., Inc
National Association of Chain Drug Stores
National Association of Convenience Stores

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 Licensed Beverage Association
Natl. Lumber & Building Material Dealers Assn.
National Mass Retailing Institute
National Retail Hardware Association
National Retail Merchants Association
National Shoe Retailers Association

National Sporting Goods Association
National Tire Dealers and Retreaders
Retail Confectioners International

Retail Floorcovering Institute
Retail Jewelers of America, Inc.

Soc. of American Florists & Ornamental Horticulturists
Volume Footwear Retailers of America
Women's Apparel Chains Association, Inc.

STATEMENT OF THE

AMERICAN RETAIL FEDERATION

on

THE CLEAN AIR ACT

Before The

Subcommittee on Environmental Pollution
Committee on Public Works

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

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