page 2 I read that Utah Power and Light and the Intermountain Power Project are testifying before your committee. Undoubtedly they favor class III designation for much of southeast Utah so that the Intermountain and Emery powerplants can be easily constructed. These two powerplants are in the heart of what many consider to be the most scenic and geologically unique part of the United States. Construction of these plants would dramatically reduce visibility in the area for thousands of square miles. It is suggested that class I designation of the numerous national parks in the area would prevent their construction especially when coupled with an elimination of class III as a category. If so, I say so much the better because the development associated with these two projects will destroy millions of areas of land that should be in a national park and/or wilderness areas. I feel that the powerplants should be built nearer to the load areas. Turning to another subject, I think that the committee should consider directing the EPA to set ambient air standards for types of particulates rather than just for TSP. Some particulates are obviously more dangerous than others, e.g., windblown sand versus sulfates. Some parts of the West have naturally high particulate concentrations on windy days, but the particulates are large and not especially harmful to health. In farm areas where the natural ambient TSP is near 60 μ/m3, industries in towns nearby will obviously never attain the secondary TSP standard. They shouldn't have to. Finally, I would like to endorse that part of S. 659 introduced by Senator McClure which would allow the sale of automobiles in certain high altitude counties without the high altitude pollution control package. In Idaho many highly fuel-efficient small cars cannot be bought at the present except at an enormous loss in mileage in meeting high altitude standards for emissions. Ironically the only towns in Idaho where pollution from autos is serious are lower than 4000 feet in elevation. Therefore, in Idaho, cities with auto pollution problems can sell the relatively more polluting cars legally but those areas with little or no auto pollution have to sell fuel inefficient relatively non-polluting cars. In sum, the high altitude package is necessary only in places like Denver and Salt Lake City, not Elk City, Salmon, or Ashton, Idaho. Sincerely, Ralph Maughan Dr. Ralph Maughan Pocatello, Idaho 83209 copy: James McClure I would appreciate your making the enclosed state- STATEMENT BY MOBIL OIL CORPORATION BEFORE THE SUBCOMMITTEE ON ENVIRONMENTAL POLLUTION OF THE PUBLIC WORKS COMMITTEE OF THE U.S. SENATE FEBRUARY 14, 1977 Mobil Oil Corporation welcomes this opportunity to submit this statement of its views on S. 251, S. 252, and S. 253, Amendments to the Cleen Air Act of 1970. As a company, we have always been concerned about the need to improve environmental quality. Nevertheless, we are seriously worried that, if the proposed Amendments were to become law, one result would be an almost total prohibition on oil refinery expansion in the United States. Refinery expansion will, in fact, be seriously impeded if the present Clean Air Act is not considerably liberalized, instead of being made more stringent. Inability to expand refinery capacity would have serious repercussions on the economy of the United States, and on the security of our oil supplies threatened by our heavy dependence on foreign crude imports. already This curtailment of refinery expansion would occur as a result of passage of the "non-ettainment" provisions in the Amendments, with which this statement is concerned, since nearly all refineries erc located in "non-attainment" areas. The "non-deterioration" provisions could also limit increases in refinery capacity, as well as severely restricting the development of oil shale, coel, and synthetic gas and oil production from coal. The situation is already serious. The U.S. refinery system has very little spare capacity, and shortages could be apparent by 1979. Companies are unwilling to invest large sums in refinery expansion because of the uncertain political climate in this country, and because of the doubtful future for marketing of products under continued price controls end FEA allocation reguletions, If the proposed Amendments are possed, they will add - 2 a new impediment to refinery construction so that shortages of refinery capacity which may appear by 1979 would persist and worsen throughout the 1980s. It is therefore necessary es en interim measure, to permit refinery construction in non-attainment arces to contime. provided that best available technology is used, and provided that emissions will not substantially effect attainment of airquality standards. Also, & commission should be appointed to study this interin measure and other measures to amend the Clean Air Act so as to allow for continued construction of new plants, and expansion of existing plants, while providing e high level of environmental protection. The Fresent Position The status of the U.S. refining industry is as follows: In 1975, the industry produced virtually ell the gasoline and distillates consumed in this country. This high degree of selfsufficiency has been of greet value to the economy as a whole. It has also provided additional security of supply, since the United States while now highly dependent on foreign crude 011 - is not dependent on foreign sources for direct imports of gasolines and distillates. Nevertheless, the U.3. refining industry is fecing severe streins: We expect that refiners will have to increase capacity by about 1.1 million barrels a dry between 1978 and 1982 to meet demand for petroleum products which will increase by |