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Heavy-Duty Truck Engine

Emission Controls

INTERNATIONAL HARVESTER

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Thank you very much for your letter of 2 February, and for the copies of the bills on the Clean Air Act amendments.

We appreciate your invitation to submit our written statement for the record. A copy of it is enclosed, and a copy is also being sent directly to the attention of the Committee's printing clerk.

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AMERICAN WHEELVIEN

LEAGUE OF AMERICAT VEDELNEN

The national organization for bicyclists

Committee on legislation and

governmental relations

112 South 16th Street

Philadelphia, PA 19102 Phone: 215/564-0055
Ralph B. Hirsch, chaimian

TESTIMONY ON THE CLEAN AIR ACT AMENDMENTS OF 1977

BEFORE THE SUBCOMMITTEE ON ENVIRONMENTAL POLLUTION,
COMMITTEE ON PUBLIC WORKS, UNITED STATES SENATE

11 February 1977

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The nation's bicyclists, now estimated to number more than 100 million, have a vital intorest in the quality of the air over the streets and roads. The overwhelming proportion of bicycling in this country is now being done and will continue to be done on roadways shared with motor vehicles, rather than on physically separate trails. Cyclists thus are exposed directly to auto emissions. Because of the effort required to propel themselves at traffic speeds they tend to breathe more deeply and rapidly than a person at rest, and therefore they are likely to take in a somewhat higher volume of pollutants than, say, auto commuters. Although the precise effect on cyclists of this uptake of pollutants is currently being studied, we know from recent research in oston and Philadelphia that on many streets frequented by cyclists the carbon monoxide levels at non-rush periods average in oxcess of 12 parts per million and that on some the level is around 20 ppm, with peaks of 60 or 90 pen not uncommon. The problem is not limited to CO, of course, since several other pollutants are usually associated with high CC emissions.

From the cyclist's standpoint the mix of vehicles sharing the road is an important consideration. If all the motor vehicles were new conз properly tuned, the cyclist could breathe with much more confidenco. But the presence of many older cars manufactured before emission standards, of new cars improperly adjusted, and of buses and trucks not yet subject to standards, makes breathing a hazardous business for the urban cyclist.

Standards for emissions from new cars should be reasonably strict and on timetable that will encourage the earliest feasible co.apience without forcing the factories to close dow. The slendirds proposed by Seaktor tackle eppoer to us to mast those requironts. The timɔtstie sho da not be su:ject to Jurbar extension, in view of the abilit o sevonci Forelga cer makers to meet strict standards now, and the record of delay of mose of the U.. ruto makers.

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Standards for pa3a3 and trucks are very important to the cyclist, since many such vehicles engage in stop-and-go driving and in prolonged standing while the engines idle. Prompt implementation of a reasonably strict standard, preferably on a speedier timetable than the one in last year's Clean Air Act conference report, is highly desirable.

Inspection and maintenance programs for older motor vehicles, which tend to be the grossest violators, are of special concorr Co the cyclist. At the very least, national legislation should require implementation of I&M programs in urban areas which now exceed air quality standards.

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We are encouraged by the recent use of recall of autos that emission standards for new cars. An alternativa enforcement tool available to the SPA ininistrator should be a Congressionally mandated penalty on new cars that violate the standards. of the fine should be set high enough to form a significant deterrent. If passed on to the consumer the fine should be clearly labeled at the point of sale. As an altomative to passing the cost on to the consumer, the amount of the fine could be withheld from the dividends, thus creating additional pressure on management to comply with the standards as quickly as possible.

The revenue from such fines should be made available to urban areas in the form of grants for implementing their transportation control plans, with priority to be given to plans providing for modes that do not pollute, namely walking and cycling.

A number of areas have requested extensions in the timetables for their transportation control plans. Extensions should be available only on a measure-by-measure basis, rather than for all measures at once. In addition, extensions of more than five years should be granted only to cities that have a present transit capacity of less than 50 of the daily commuter trip needs, and that have committed themselves to major capital improvements for transit and to significant improvements, whether capital or programmatic, for the human-powered modes.

Areas that receive extensions on transportation control measures should be required to submit their applications for federal transportation grants through 3PA prior to approval by DOI. EPA should be authorized to specify conditions on 's approval or to specify alterative means for meeting transportation needs in ways that will meet air quality goals.

February 9, 1977

Honorable Edward Muskie

Chairman, Subcommittee on Environmental Pollution

Committee on Public Works

United States Senate

Senate Office Building

Washington D. C.

Dear Senator Muskie:

I would like the following remarks entered into the record on the proposed amendments to the Clean Air Act. I hope they are useful to your committee.

I am a professor of political science at Idaho State University and a member of the board of directors of the Idaho Environmental Council. I am writing on behalf of myself, however.

First, I would like to endorse the inclusion of a strong provision protecting the quality of air which is at the present cleaner than the national secondary ambient air quality standards. For those of us living in the Intermountain West, I feel that this is the most important of all the aspects of the Clean Air Act.

I feel that the EPA's class III deterioration standard should be eliminated and that all national parks, national monuments, and congressionally established wilderness areas larger than 15,000 acres should be mandatory class I zones. In addition, consideration should be given to mandatory class I designation of certain national recreation areas, national wildlife refuges, and national forests.

It is often remarked that there is no need for air to be kept cleaner than the national secondary standards because these, by law, are designed to protect both the public health and welfare. I disagree. The aesthetic benefits of air that is cleaner than the secondary standards are highly relevant in the West where visibility of distant mountain ranges is natural and highly regarded by the bulk of the population. For example, if the air quality in Grand Teton National Park was allowed to be degraded to the secondary standards, public health would still be protected, crops would not be damaged, but the reduction of these peaks' beauty would be nearly total.

I live in Pocatello, a town of 45,000, where two of the major employers process phosphate rock, contributing to air pollution. Five year averages for S02 and TSP are now, thankfully, approaching the primary standards. Nevertheless, one can hardly see across the Portneuf Valley during the Winter months. Such a reduction of visibility throughout the more scenic parts of the West, would be highly objectionable. In recent weeks, a large number of letters criticizing air pollution control efforts have appeared in the Pocatello newspaper this despite the fact that the air is getting cleaner and Pocatello is no garden spot. This leads me to believe that visibility per se is important to people and part of the public welfare.

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