22 million people. The metropolitan community of which we are a part includes two States, six counties, and 169 municipalities. There is probably not one of these many governmental entities which does not have sources of air pollution, and it is obvious that any effective program for the purification of the air must involve air pollution control within the total air shed.

According to the best available estimates, the sources of air pollution emanating from St. Louis County break down as follows: 5 percent from open burnings; 25 percent from industrial sources; and 65 percent from motor vehicles. Six years ago, prior to the inception of our air pollution control program, 30 percent of estimated pollution came from open burning, 30 percent from industrial sources, and 40 percent from motor vehicles. Just as any effective air pollution control program within the total air shed will involve compliance by all governmental entities within the area, so must any effective program be directed at all sources and types of air pollution, if we are to clean our air.

2. THE HISTORY OF AIR POLLUTION CONTROL WITHIN ST. LOUIS COUNTY

Although air pollution control efforts within St. Louis County date back to 1963, our control program did not become fully operative until 1967 when, based on the provisions of the Air Quality Act of 1967 and the Missouri Air Conservation law, the St. Louis County council enacted a strong air pollution control ordinance. Since then, the following major steps have been taken by county air pollution control authorities to deal with air pollution in our country:

(a) The interstate study identified 400 major sources of air pollution within the air shed, of which 15 were located in St. Louis County. As of today, 10 of the 15 sources have been brought into total compliance with the county's air pollution control code, and five have embarked upon corrective programs which should bring them into compliance within the shortest period of time necessary to design, acquire, and install air pollution control equipment. Our administration has enunciated a policy of insisting upon total compliance by those remaining five as soon as possible.

(b) 1,500 industrial and commercial open burning sights have been closed.

(c) 225 commercial incinerators have been inspected and are now in compliance with the code.

(d) 228 incinerators incapable of conforming to the code have

been closed.

(e) 89 violators of the open burning provision of the code have been cited, and four have been prosecuted for repeated offenses. (f) 128 notices have been issued to owners and operators of trucks or buses for violations of the code.

(g) 258 operating permits have been issued to industrial plants since the adoption of the code.

(h) Industrial and institutional plants which previously had burned more than 100,000 tons of high sulphur content coal per year have been converted to natural gas, thus eliminating the emission of about 6,000 tons of sulphur dioxide per year.

(i) All leaf burning has been prohibited in the more densely populated areas in St. Louis County, effective October 1, 1969. All

other open burning, such as trash, tree limbs, and automobile bodies became illegal as of July 4, 1967.

I respectfully submit. Mr. Chairman, that St. Louis County is doing its share within the limitations of our authority to eliminate air pollution.

3. AN AIR POLLUTION ALERT PLAN

Under certain adverse meteorological conditions, coupled with current pollutant emission levels, excessive and hazardous levels of air pollution may occur. Such a condition was experienced in the St. Louis metropolitan area on August 25, 26, 27, 1969.

Under the provisions of the 1967 Clean Air Act, we are called upon, in conjunction with our neighbors, in this air shed to formulate an emergency alert system to be in effect by July 7, 1970. It is my opinion that we cannot wait until the summer of 1970 to create such an alert system, as it is entirely possible that hazardous conditions such as occurred last August might recur prior to the deadline prescribed in the 1967 Clean Air Act.

In order to meet such a contingency, the St. Louis County Air Pollution Control director has organized a technical committee consisting of enforcement officials involved with air pollution control within the St. Louis air shed, and this group has prepared an interim air pollution alert plan to be placed into effect in the period prior to the time when a more sophisticated plan utilizing a comprehensive telemetry system is implemented. I have attached a copy of this temporary plan for your information.

I am concerned by the apparent absence of any model emergency alert plan at the Federal level which might be used as a guide for local situations such as ours in formulating our own emergency procedures. In discussing this matter with officials of the National Air Pollution Control Administration, I was advised that although that agency is familiar with one or two plans which have been developed elsewhere in the Nation. no model plan has as yet been formulated which could serve as a guide to all concerned regions in meeting this serious problem. I would respectfully suggest that action be undertaken at the Federal level to develop such a model plan which might serve as a guide to us in the various affected air sheds throughout the Nation.

4. RECOMMENDATIONS FOR FUTURE ACTION

As I have previously pointed out, the government which I represent cannot alone eliminate polluted air from this region. Other air pollution control agencies throughout this air shed must adopt and enforce stringent measures based on the standards prescribed in the interstate study completed in 1966. I would urge that the National Air Pollution Control Administration act within the confines of the Federal Clean Air Act of 1967 to assure compliance throughout this metropolitan area with approved stringent standards of air pollution control.

Secondly, I would urge that action be taken at the Federal level to mandate the control of air pollution from motor vehicle exhausts. As has been pointed out, emissions from automobiles and buses are presently the major source of air pollution within St. Louis County. It is estimated that 1,040 million gallons of gasoline are being burned

in the St. Louis metropolitan area each year with an estimated emission of 260,000 tons of hydrocarbons. Unless and until the Federal Government takes stronger action to insist that automobile manufacturers include effective air pollution control equipment on motor vehicles, we cannot expect success in our efforts to combat air pollution. Emissions from jet aircraft are another source of pollution which cannot be dealt with by local agencies, but which are of major concern, particularly for those citizens who reside within the flight paths of major airports. In 1963, at Lambert Municipal Airport in St. Louis County, there were 258,000 aircraft flights annually. For the 12 months just completed, total air flights at that airport amounted to 345,000, an increase of 87,000 flights over the past 6 years. According to reliable, sources, a retrofit unit is available which would reduce visible emissions from jet aircraft to a point that they are practically invisible. Unfortunately, these are being installed only on new planes or replacement motors. It is my recommendation that airline companies be required to install such devices immediately on all operative aircraft.

I would call on the Federal Government to step up its support of research for the development of new technology for the control of emissions from industrial processes. Research should be also expanded in effects of pollutants on community health. In this respect, I would recommend that Congress reconsider tax rebates; as incentives for those firms that involve themselves in research in capital improvements for the purpose of air pollution control..

These are a few of our experiences and suggestions concerning air pollution control. I reiterate that the key to clean air lies with no single layer of government, nor any one individual or industry. Rather, it will involve a cooperative effort by Government, by industry, and by all of our citizens if we are to achieve the quality of atmosphere necessary for our survival.

Senator EAGLETON. Thank you, Mr. Roos. The exhibits to which you referred and submitted by you will be placed in the record at this point.

(The exhibits are as follows:)

INTERIM AIR POLLUTION ALERT PLAN FOR THE ST. LOUIS AREA ADOPTED BY THE AIR POLLUTION TECHNICAL COORDINATING COMMITTEE

This Air Pollution Alert Plan comprises an intensified surveillance plan which had been previously under consideration by the Technical Coordinating Committee and amends that plan to include the general procedures as to criteria and control action previously adopted by the State of Illinois Air Pollution Control Board; the latter are documented in "Rules for Controlling Air Pollution Episodes" adopted in Illinois June 18, 1968,

It is intended that this interim plan is subject to modification prior to incorporation into an Implementation Plan for the St. Louis Air Quality Control Region. As provided in the Clean Air Act of 1967, such Implementation Plan is to include an alert plan and is to be approved by the Department of Health, Education, and Welfare subsequent to adoption by state and local governments. This submission is scheduled by July 6, 1970.

Members of the Air Pollution Technical Coordinating Committee:

Illinois: Robert R. French, Chief, Bureau of Air Pollution Control, Illinois Department of Public Health.

Missouri: Charles M. Copley, Jr., Commissioner of Air Pollution Control, City of St. Louis; Donald A. Pecsok, Director, Air Pollution Control Division, St. Louis County; Harvey Shell, Acting Executive Secretary, Missouri Air Conservation Commission.

1. OBJECTIVES

This alert plan has been developed to prevent high levels of air pollution which may cause acute harmful health effects. Adverse meteorological conditions, coupled with current pollutant emission levels, may create excessive levels of pollution. Following satisfactory reduction of these emissions, these excessive levels should not occur. Therefore, any alert plan is intended primarily as an interim measure until long-term pollution reduction programs demonstrate that emergency plans are no longer required.

The plan described below is focused on two pollutants, namely sulfur dioxide and particulates. In accordance with DHEW criteria, these pollutants have a synergistic effect and, accordingly, the product value of their concentration and their duration in air serves as an index of resultant health effect.

It is contemplated that other parameters may be incorporated in the alert plan as further study indicates and as the monitoring capability for other pollutants becomes available.

Initiation

II. MONITORING PROCEDURES

An intensified air pollution monitoring program (hereafter called “program”) will be initiated when either of the following conditions occur:

1. A high air pollution potential forecast is issued for a minimum of thirty-six (36) hours by ESSA Weather Bureau, Lambert Field.

2. A high air pollution potential forecast for less than thirty-six (36) hours is forecast and pollutant concentrations indicate the program should be initiated. This initiation shall be at the discretion of the Air Pollution Technical Coordinating Committee upon the recommendation of one or more of its members. Establishment.

A. Once conditions have dictated the initiation of the program, the Chairman of the Air Pollution Technical Coordinating Committee formally notifies the members of the Committee that the intensified air sampling program will begin.

B. The Commissioner of Air Pollution Control, St. Louis City, will assign a person or persons to the St. Louis Division of Air Pollution Control headquarters to serve as a data monitoring coordinator.

C. The Air Pollution Meteorologist, ESSA Weather Bureau, will supervise continuous monitoring of meteorological air pollution potential at Lambert Field.

D. Each Committee member will be responsible for carrying out the following functions:

1. Each Committee member or his designee will go to the St. Louis Division of Air Pollution Control headquarters to coordinate and direct monitoring actions and abatement recommendations.

2. All available continuous monitoring instruments will be put into operation, including continuous instrumentation for SO2, CO, Oxidants, NOx, and soiling index meteorological instrumentation.

3. All existing and supplemental high volume air samplers will be started at the direction of the coordinator.

4. All continuous stations will be provided with adequate manpower to maintain operation and report data as called for.

A. Each agency will report data to the coordinator every two hours on the even hours and at other times when called for. Routine reporting will be the responsibility of the field personnel and should not be called for by the

coordinator.

B. Members of the coordinating group will review data as received and will direct those actions warranted by the intensity of the episode such as:

1. Reporting to news media

2. More frequent reporting of data where possible

3. Abatement recommendations to appropriate authorities

4. Termination of program

Post episode evaluation

The Data Evaluation Subcommittee will compile and analyze all data obtained during the episode and issue a report to the Technical Coordinating Committee indicating such factors as the cause of the episode, intensity, effect of abateme actions, and recommendations for surveillance during future episodes.

III. ABATEMENT PROCEDURES

Criteria for initiating Alert Level procedures are stated as the product of the hourly sulfur dioxide concentration in ppm and the hourly particulate concentration in COH per 1000 linear feet.

A. Yellow alert initiation

Air Pollution Yellow Alert procedures shall be initiated by the Technical Coordinating Committee.

The Yellow Alert procedures can be initiated if the following two requirements are met:

(1) A 36-hour forecast of high air pollution potential from the ESSA weather bureau advisory in effect for a particular geographical area; and (2) The Yellow Alert Product value of 4.0 equalled or exceeded for 4 consecutive hours in the same geographical area.

The Yellow Alert procedures can also be initiated if :

(1) A product value of 1.0 is equalled or exceeded for 48 consecutive hours and a forecast of stagnation for the following 12 hours is received; or

(2) The Yellow Alert value is equalled or exceeded for 12 consecutive hours and at forecast of stagnation for the following 12 hours is received.

B. Yellow alert procedures

Committee members shall inform appropriate authorities that Yellow Alert conditions prevail and recommend the following actions:

(1) The general public shall be informed through the news media that air pollution is high enough to require action to avoid a health hazard and that the appropriate authorities are taking action to reduce air pollution.

(2) Plants, as designated by the Technical Coordinating Committee, which burn large quantities of high pollution potential fuels shall be requested to convert to emergency fuels with lower pollution potential, or to take other measures to reduce their emissions.

(3) Operators of municipal and large industrial and commercial incinerators shall be requested to stop operation.

(4) Sources as designated by the Technical Coordinating Committee which emit large quantities of air contaminants shall be requested to reduce emission of contaminants.

(5) The public shall be requested to reduce non-essential uses of automobiles and to stop all incinceration.

C. Red alert initiation

The Red Alert procedures can be initiated by the Technical Coordinating Committee if the following two requirements are met:

(1) A 36-hour forecast of high air pollution potential from the ESSA Weather Bureau in effect for a particular geographical area; and

(2) Red Alert product value of 3.0 equalled or exceeded for 4 consecutive hours in the same geographical area.

The Red Alert procedures can also be initiated if;

(1) A product value of 1.0 is equalled or exceeded for 72 hours and a forecast of stagnation for the following 12 hours is received.

(2) Or the Yellow Alert value is equalled or exceeded for 48 hours and

a forecast of stagnation for the following 12 hours is received.

(3) Or the Red Alert value is equalled or exceeded for 12 hours and a forecast of stagnation for the following 12 hours is received.

D. Red alert procedures

(1) Committee members shall inform appropriate authorities that Red Alert conditions prevail.

(2) Committee members shall be responsible for investigating or contacting again all sources contacted during the Yellow Alert to notify them that Red Alert conditions exist and that they should continue operating at conditions of reduced emissions or with low pollution fuels.

(3) The Committee shall recommend that the pubic shall be informed that conditions have worsened and that all unnecessary activities that may lead to air pollution, particularly nonessential driving, should be curtailed. (4) The Committee shall recommend that certain commercial and industrial operations previously designated as critical sources of air contaminants during alert conditions be requested to cease emission of these air contaminants.