It is for this reason that in New York City we are ordering the installation of smoke alarms, cutoffs, and recorders. Education as a technique for getting causes of air pollution corrected is a twofold tool. It can be employed for preventive as well as corrective measures. By education, I mean far more than the direct instruction of one individual on one problem. The preparation and distribution of little educational leaflets or pamphlets on the various aspects of proper maintenance and proper operation provide an important tool. Incidentally, where availability of funds may be a problem, it is sometimes possible to get the cost of printing taken over by some other public-spirited agency, organization, association, or manufacturer. Press releases to all agencies of public communication such as newspapers, radio, and magazines are an important technique. A more formal type of educational approach, which does require a little more effort, may be indicated in some cases. For example, the New York City Housing Authority, which operates many residential properties in the city of New York, has conducted regular classes for its custodial employees. Our health department has also conducted formal classes for janitors and superintendents. The better informed operator of boilers is less likely to cause air pollution from his equipment.

Last, but certainly not least, is the enforcement technique. The enforcement technique employed may range from warnings through violation notices, departmental hearings, summonses, or even the sealing of equipment. Earlier I mentioned that the methods for control of air pollution from boilers or for the correction of the causes of air pollution from boilers are pretty well known. This is not equally true of incinerators, although there has been, in recent years, a tremendous amount of research on this subject. Not only has there been much progress in the design of incinerators for special functions, but there has been a great deal of improvement in the design of incinerators intended for residential property use. Despite this, however, there still remains a need for a great deal of additional research in the field of proper incineration. Particularly on the subject of methods, the munic

ipality that does not have facilities for actively pursuing a research project certainly should take advantage of the work done by others, by keeping informed of all the latest developments, and by using the information thereby gained to the fullest extent in solving such problems as they may have. The control official must, when confronted with a problem originating from a municipally owned residential property, be just as diligent, if not more so, in seeking correction as when privately owned property is involved. It is far easier to convince the owner of private property that he should be cooperative, when he knows that lack of cooperation on his part may lead to a summons and a fine. This spur to cooperate is not present with the municipal offender. I would like to remind you that the word "cooperate" implies a mutual operation for a mutual objective. Cooperation is not a oneway street. If a municipal offender is expected to cooperate with the control agency, then it is the obligation of the control agency to cooperate with the offender. This means most often that you must be prepared to assist him in any way you possibly can, in his approach to the city fathers, to enable him to convince the "holder of the purse strings" that funds or manpower must be allocated to effectuate correction of the air pollution problem. It is not always possible for the municipal air pollution control agency and the municipal air pollution offender to get together on a plan or program to correct an offensive condition.

In such cases, it is the responsibility of the top municipal administrative head to evaluate the problem and then to take prompt, decisive, and effective action. It must be freely admitted, as I have inferred previously, that disagreements between municipal agencies occur everywhere, and that a strong hand is necessary to resolve the difficulties. These instances are equally applicable to Federal, State, regional, or "Authority" jurisdictions, which are not responsible to each other at the same or at different levels. It is not always simple to adjudicate these disputes and the methods of doing so could well be the subject of a paper longer than this one.

RICHARD E. HATCHARD

Chief, Air Quality Control Oregon State Sanitary Authority Portland, Oreg.

A 1961 survey of local air pollution programs underway in the United States showed that 119 urban places with more than 50,000 population were engaged in programs to control and prevent community air pollution. The primary emphasis in most of these activities is concerned with controlling discharges into the atmosphere that are creating nuisance conditions. These complaint situations originate from the effects of relatively large sources, such as heavy industrial plants, like a steel mill, foundry, oil refinery, or an open burning refuse dump or industrial metal salvage operations.

A relatively few community air pollution programs are now organized and staffed to effectively control areawide effects resulting from multiple source discharges into the community atmosphere. It is not too surprising that this is so, if we recall the sequence of past events which led to the initiation of the community air pollution program. In most cases, these actions have stemmed from an accumulation of public complaints about continuing nuisance effects from industrial sources of air pollution or at least the effects caused by a relatively few large suspected sources in the community. Usually the initial effort of the community program is to control the smoke and dust discharged from the large individual industrial sources. Until recently, little attention had been directed towards determining what kind of areawide atmospheric purity was desired by the community.

Frequently, air pollution from the municipality and the home has been lightly treated since there were other much larger sources, where, for a given amount of control agency staff time, a more sig

nificant source reduction could be produced. Generally aggressive citizens' complaint actions have demanded abatement actions of the large known or suspected sources. I am sure that most participants in this Conference would agree that the air pollution sources within the municipality's operations and the home should receive high priority for required control actions so that the municipality would then provide real leadership towards effective air sanitation in the community. However, this very logical approach has seldom been used; in fact, the ordinances adopted in many communities exclude the air pollution from single or from two- to four-family units from the regulatory requirements. Also, many cities with fairly active industrial air pollution control programs still permit the open burning of community refuse and allow the installation and operation of inadequately designed incineration equipment. Later, the community discovers that the desired air sanitation conditions were not achieved solely through the control of its large industrial sources and other large individual emissions. Many comprehensive community surveys have established that the total air pollution from the space heating and refuse disposal sources are a relatively large percentage of the total burden placed upon the atmosphere in the community.

In a few localities, public educational programs have been effective in gaining understanding that communitywide control actions are essential to produce the desired level of air sanitation. It would be delightful if the experiences of these communities were easily transferable to other urban loca

tions, and if this lesson did not have to be learned in each locality. Unfortunately, this is not generally true, but a far greater emphasis on public information and education probably could achieve a higher degree of public acceptance. Then one might expect that a well planned and supported educational program would automatically be one of the first activities in establishing a community air sanitation program. Although this is logical, it does not happen routinely. Usually the public educational effort follows along some time later, particularly to generate public support for extending the air pollution control activities after it has been demonstrated that control of the individual sources has not produced the desired results.

Looking toward the future, it is probable that increased emphasis will be placed upon air pollution sources from municipal operations and the home. The steady addition of new industrial and commercial facilities which include effective control systems will in time make the air pollution discharged from the municipal operations and the home appear relatively larger as an important community source. Also, the rapid development of ambient air quality regulations will serve to define and identify more clearly the need for increased communitywide activity. However, there will be continuing difficulties in obtaining adequate budget increases to provide needed expansion of the community air pollution program. At present the growth in local programs is not at all adequate to meet the needs; in fact a 1962 report by Jean J. Schueneman showed that little or no headway has been made in the last 10 years, except in California jurisdictions, to bring the resources of local air pollution control agencies to the level that is needed to cope with the problem. During this 10-year period, about one-third more personnel were employed but the 30-percent increase in urban population offset any real gain in resources. Competition from other governmental needs is great.

A new approach toward the financing of local air sanitation programs is critically needed. If a grantin-aid program is authorized by the Congress, some stimulation of program development would follow; however, the rate of growth from this stimulus alone probably would not be enough to satisfy the increasing public demand for reasonable air quality conditions. Then what is the answer towards organizing adequately financed community programs? During the 1958 conference on air pollution, Dr. R. A. Nisbet presented a report on the impact

of air pollution control programs on our economics and society. A main point of his analysis emphasized that a grassroots type of campaign for air pollution control was needed to establish the stake of the community and the neighborhoods in the community in the struggle for clean air. He suggested that women in the upper middle economic groups, preferably in the 20-50-year age category, would be the most effective persons to energize the need. He stressed the need for two-way communications between the community action groups and the local operating agency concerned with air problems, needs, and activities. If air pollution from the municipal operations and the home is to be adequately controlled, then new emphasis and drive from the community itself is overdue. The administrator of the community air sanitation program should devote part of his time to the formation and servicing of local action groups; however, I know that the day-to-day demands upon the official's time does not stimulate his initiative to deliberately pursue activities of this kind, since it creates a need for followup and, in time, some criticism of the agency's program activities. However, the local official's overall responsibility to inform the public regarding air pollution conditions and needs really should make such activities mandatory.

Now let's assume that the community has a wellinformed community action group in support of the local air pollution agency. This accomplishment will not itself assure that adequate budgets will be forthcoming. The severe limitations of the local tax base to finance a multitude of other community needs like schools, fire and police protection, urban renewal, water supply, sewage treatment, and welfare programs, will severely limit the realistic financing of the air pollution community activities. Obviously, continued pressure from the action group will increase the funds each year, but without some kind of a local crisis, the annual increase probably will not be sufficient to support an effective overall air sanitation program.

It appears then that a new approach to obtain adequate budgets for community air quality programs is needed. An analysis of the possibilities of new financing could be the subject of a separate paper, by a specialist in such matters, but some of the desirable elements of the financing seem clear. It should have a relationship to the community activities that create at least part of the basic air pollution problem. It should have a built-in fea

CRITIQUE

VICTOR H. SUSSMAN

Director, Division of Air Pollution Control

Pennsylvania Department of Health
Harrisburg, Pa.

The planning committee for this session scheduled this paper to serve as an introduction to the discussion period. In a sense, all of the discussions at this conference are critiques. A definition of critique is "a critical discussion of the execution of a problem." The problem presented to this conference is how to stimulate action to clear the air.

As a governmental air pollution control officer and an advocate of clean air (which is a somewhat redundant statement), it is my job to continually and critically evaluate air pollution problems and abatement programs. Therefore, basing my comments on experience (and not intending to be sacrilegious), I would like to discuss the first two papers-Bishop's comments on Faith.

Dr. Faith stated that "most industrial pollution problems are susceptible to economic methods of control." Dr. Bishop presented a graphical representation of the economic factors to be considered in determining if and when controls are to be instituted. I believe that it should be noted that the "Cost of Air Pollution Damage" also includes the loss to the community of new industries and tourist trade.

It is obvious from Dr. Bishop's graphical presentation and Mr. Frankenberg's paper that the cost of damage decreases exponentially, and that the cost of control increases exponentially, with increasing degree of control, for example, collector efficiency. The various factors affecting the choice of a level of control are not equally weighted. The relative weights given to these factors also vary among various industrial plants, as pointed out by Dr. Faith in his discussion of the economic problem. There is another exponential factor which I believe should be noted.

Recognizing the limitations of this type of subjective discussion, I should like to submit an empirical equation which I believe may describe the view taken by some industries:

K P= Mm

P is the probability that air cleaning equipment will be installed on a certain process. It can also represent the efficiency of the air pollution control equipment installed (since it is reasonable to expect that if the chances are good that control will be effected, it is probable that a good job will be done). The value of K depends upon a number of factors:

1. The severity of the air pollution problem caused by emissions from the process.

2. The value of the material (dust, fume, etc.) recovered from the gas stream to be cleaned.

3. The existence of governmental air pollution control regulations and, as pointed out by Commissioner Benline, the degree to which cooperation, persuasion, education, and enforcement are employed.

4. Whether or not there are similar successfully operating installations.

5. A nebulous item known as "company policy." This item is related to Dr. Faith's discussion of "enlightened public relations . . . absentee management . . . deep-seated distrust of governmental controls."

M is money (the cost to the industry) and is a function of the gas volume to be handled, the difficulty in separating the contaminants from the gas stream, and other factors such as maintenance, power requirements, and corrosion. m depends