maintained in the interim. Mass conversion to high sulfur coal for urban energy production without stringent control procedures will unquestionably result in increased illness, disability, and death among urban dwellers, particularly those with heart and lung disease.

I urge the Senate to maintain the language of the Senate Emergency Energy legislation passed on Tuesday. It is much preferable to the House version.

I should like now to turn to another area of concern, namely the nature of pollution control procedures. There appears to be a trend toward adopting high stacks and directed plumes-intermediate control strategies-as a major pollution control strategy.

It has been suggested that the use of this method of dispersion during noninversion periods represents a reasonable method for disposing of SO, and particulate air pollutants, particularly the former. There is mounting evidence to suggest that this would be a very poor strategy, certainly from a health standpoint.

Acid sulfates and sulfuric acid are more toxic than sulfur dioxide itself. They are formed in large quantities in the air from emitted SO2. Recent evidence suggests that high stacks lead to the formulation of stable clouds of these toxic substances.

Thus, rather than diffusing and dissipating these materials, strategy may actually increase the stable concentrations of these more harmful pollutants and, indeed, may affect much larger populations than those in the urban areas where the pollutants are developed.

There appears to be good evidence that large cloud masses of these agents are present over the northastern United States, so that even those in rural areas are now being exposed to what may be significant levels of toxic SO2 derivatives.

This effect may prevail even though SO2 levels near the ground are decreasing. This phenomenon may be true with other toxic materials, also.

A substance like lead, for example, which is immutable and does not disappear, is also emitted from the stacks, and while it may be diffused, it ultimately reaches the ground and remains there.

In addition, where a significant number of these stacks are present in a relatively small area, the result is one of blowing dirty air from one place to another, rather than dissipating.

Considerations of technical feasibility and reliability aside, the high stack, directed strategy is best labeled as an epidemiological gamble. At stake, of course, is human disease and death.

I therefore suggest that Federal dollars might be better allocated. toward elimination of these pollutants by other devices, the use of cleaner fuels, more complete combustion methods, and the exploration of new methods for producing clean energy.

Since these things directly operate together, reduction of useless forms of energy becomes another critical way of approaching this problems.

Another area of concern from the medical viewpoint is the adequacy of the health care delivery system to deal with increased patient demand during periods of high pollution.

Studies by our group in Chicago, over the past 8 years, have suggested significant increases in cardiac and respiratory disease and death on days when sulfur dioxide is elevated. During a 1969 high pollution episode, hospitalization of bronchitics was markedly increased, when compared to either before or after the episode.

The need for planning for such occurrences is clear. Communities must promulgate plans for emergency care during pollution crises. This planning should include, perhaps, medical surveillance, of certain groups at high risk such as cardíacs, bronchitics, and asthmatics, newborns and very young infants.

I feel that Congress and the Environmental Protection Agency may be well directed to investigate this area in detail from the national perspective. We recently had a very serious hydrochloride spill in Chicago which presented a serious hazard to many hundreds of thousands of our citizens.

There was, as far as I know, no organized plan to deal with this kind of question. It was only because the wind was blowing over the lake and we did not have an inversion and we did not have a rain that we averted what might have been an extremely serious episode. As it is, many hundreds of people were seen in emergency rooms and a considerable number of people were hospitalized. Such plans can be used for these types of environmental emergencies also.

I have dealt at great lengths with the importance of defining those populations at high risk. Qualitative definition of those at risk will permit physicians to caution those patients regarding levels of activity during high pollution periods and counsel them on advisability of living in highly polluted areas.

For other reasons also, it is critical to make an assessment of those at high risk, since the only way that decisions can be made regarding safe levels will be to develop dose response relationships and establish the numbers at risk at each level of pollution.

Models which have been developed by our group will shortly appear as a Ford Foundation American Public Health Association Energy Report, soon to be released. I am concerned that studies attempting to find those at high risk and quantitating the level of risk have not been assigned high priority by the Federal Environmental Protection Agency.

If this is true, it would be most unfortunate, and I would urge that it receive the emphasis that most of us in the field believe it should have.

Finally, I urge the subcommittee to advocate full funding for the Clean Air Act and especially for the implementation of the State plans sometime hence.

I must also emphasize that this funding should provide for ample multidisciplinary training in both air pollution epidemiology and control technology.

My written statement is now concluded. Thank you for permitting me to appear before you. I shall be happy to answer any questions you may have.

[Appendix 1 follows:]

[Appendix 1 from "Health and Safety effects of Energy Systems" a draft report of the American Public Health Association.]

Cor pulmonale (secondary to chronic obstructive pulmonary disease).
Hypertension with left ventricular disease.

Coronary insufficiency (with or without angina).

Rheumatic heart disease.

Congestive heart failure1 (secondary to atheroscleratic heart disease).
Chronic bronchitis.

1 No data but might be expected to be at high risk.

Senator MUSKIE. Thank you very much for your excellent statement, Dr. Carnow. We appreciate it.

STATEMENT OF JOHN J. SHEEHAN, CHAIRMAN, NATIONAL AIR CONSERVATION COMMISSION OF THE AMERICAN LUNG ASSOCIATION, ACCOMPANIED BY ELAINE C. BERLINSKY

Mr. SHEEHAN. Mr. Chairman, members of the subcommittee, I am the legislative director of the United Steel Workers of America. However, I appear before you today officially as the chairman of the American Lung Association's National Air Conservation Commission. I am also accompanied by Elaine Berlinsky, a professional staff person assigned to this commission by the American Lung Association.

35-497-74 - pt. 1 - 34

Controversy and criticism are certainly nothing new to the Clean Air Act, but the intensity has reached new heights recently. This is due not only to the energy crisis but also the approaching deadline for the attainment of the primary ambient standards.

The Clean Air Act has proven itself to be a convenient, visible. target for our frustrations as a Nation being caught short with the energy supply. That, in conjunction with our anxiety over the 1975 deadline by an increasingly vocal segment of industry may make conditions right for granting major concessions from the goals of the

act.

If there is one point which the American Lung Association wishes to make, it is to urge you that in view of the public health needs, such concessions should not be made. The evolution of the Clean Air Act from the mid-1960's on has been at a very deliberate and, I might say, incremental pace. That growth process needs to continue.

We are not yet at a turnaround position. The single goal of the American Lung Association, its constituents and affiliates is the prevention and control of lung disease. As such, a major portion of our preventative program deals with the need for keeping the air around us as free from pollutants as possible since both short term exposure to high levels of lung pollution and long term exposure to low levels may produce adverse health effects.

The National Air Conservation Commission was established in 1966 to provide guidance to the American Lung Association in developing and implementing its own air pollution programs.

I would like to relate to you some of the positions adopted most recently by the commission with regard to the Clean Air Act. I might also interject here that during the early part of the Clean Air Act, the American Lung Association participated in the citizen education programs, especially the hearings at the air quality control regions, and I think we were very appreciative of the opportunity we had to participate in this people's movement for clean air.

With regard to some of the commission's positions:

1. General scope and strength of the act. For reasons of public health and safety, the Commission opposes any general relaxations of the compliance schedules, standards or standard making procedures now contained in or developed under the act.

Some industrial sources are now calling for a postponement of the compliance date for meeting the primary ambient standards. The reasons for calling for such delays may range from economic and technological hardship to outright negligence.

Whatever the reasons, we cannot accept a carte blanche postpone ment of returning our air shed to a healthful quality. The Act already contains some flexibility for compliance dates, postponing them, for those specific areas where there is an overburdening need.

To proceed on grounds other than such limited, case-by-case approach would be a major setback for the public health field and would be a clear signal that stalling on cleanup requirements does indeed pay off.

2. Public participation. We seek both administrative and statutory changes to provide for greater opportunity for the public participation in EPA's decision making process.

While virtually every industrial site is at least a potential antagonist to the intent of the act, there is very little in the way of professional protagonists. The constituency of the Clean Air Act is the general public.

For at least two reasons it would be incumbent upon EPA to involve the public as much as possible. First, it is a means of assuring the public that their interests will be represented in carrying out the intent of the act.

Second, in the self-interest of EPA and of the act, itself, it is a means of keeping the issues visible and alive in the public eye and, in a sense, of therefore cultivating a stronger constituency for the act and the Agency.

Two examples of measures which would help in this area are:

(1) Public hearings by EPA so located and publicized as to encourage public participation prior to the promulgation of major standards, rules, and regulations as it may issue under its general statutory autority; and

(2) Publication of summaries of substantive public comments made on such proposed standards, rules and regulations, together with EPA's response thereto.

3. Health effects advisory committee. We recommend that such a committee be established to advise the Administrator and the Congress not less frequently than once every year of current research needs, objectives, priorities and progress concerning the health and other effects of ambient air pollution.

4. Emission standards. The commission feels that the Administrator of EPA should be given more power, administrative power, in the establishment of emission standards.

Primarily, here we are speaking about automobiles. In the first place we feel that the emissions standards should rightfully be the product of an administrative regulation pursuant, of course, to statutory authority and guidance, rather than being placed in the act, itself, as in the case of section 202 (b) for automobile standards.

Second, EPA should be empowered to establish more stringent auto emission standards in those heavily polluted geographical areas which require special action.

5. High pollution impact areas. Areas, regions, and communities which have been designated by the Administrator as high vehicle pollution impact areas should recieve preference and priority in the award of Federal grants and other financial aid for the construction and operation of mass transit facilities and services.

6. Land use controls. The commission feels very strongly that a Federal policy on land use is crucial for long range control of both stationary and auto pollution.

Perhaps this should be more in the domain of the pending National Land Use Planning Act, but the 1970 Clean Air Act certainly opened the door with its reference to land use in section 110 of the act.

What is needed is a procedure whereby the location of new sources is fully examined with regard to all the ramifications, including environmental, before the fact, before the plant, for instance, is actually located at that site.