used in the Washington area to attempt to rely upon individual exemptions; because the problems that I pointed out in the receiving and the storing and the making available of the lowest sulphur oil, I think would-nullify the relief afforded by the individual exemption. In other words if they can't get the oil where is the low sulphur oil, how is it going to be brought in, where is it going to be stored and how is it going to be made available to anyone is the question in my mind. In other words, if the law went into effect based on one percent, before industry could supply it I don't see how each individual consumer applying for relief would be the right answer.

Mr. GUDE. If this exemption applies to all users, of say grade six or grade five fuel, what would be the difficulty?

Mr. COUNTS. Perhaps I didn't entirely understand. I thought the exemption was to be applied for on an individual basis by each individual consumer.

Mr. GUDE. Well it could be the industry could apply for it, or the suppliers could apply for it.

Mr. COUNTS. If it were brought in to include this type of provision perhaps it could be workable.

Mr. GUDE. You mentioned in your testimony the contract the Government signed for two percent oil. Were there any bids for oil of a lower sulphur content?

Mr. COUNTS. They sent out written invitations and to their invitations specified two percent.

Mr. GUDE. Do you know of any offer made of fuel oil of a lower sulphur content?

Mr. COUNTS. I know of none.

Mr. GUDE. We were going to try to inquire of the GSA whether there were other suppliers.

Mr. COUNTS. They may have had their conversations or they may have had activities of which I am not familiar, but when they issued their invitation to bid, after their studies and after their investigation, they did then specify two percent.

Mr. GUDE. I think the Federal Government has a responsibility to use as low sulphur oil as possible.

Mr. COUNTS. I think they were convinced they could not get it.

Mr. GUDE. We are going to try to find out from these people. Thank you very much.

Mr. MULTER. Page nineteen. On the last page of your statement, page nineteen, have you made any changes or corrections to that since you submitted it, or is this statement submitted the same way you read it?

Mr. COUNTS. No. I would like it to remain as stated in the page. Mr. MULTER. What do you mean on "June 30, 1968 two percent and the next day one and a half percent."?

Mr. COUNTS. Up to June 30, 1968. In other words, whenever the law becomes effective until June 30, 1968 it would be two percent.

Mr. MULTER. What you are suggesting is that on July 1, 1968, it be reduced to one and a half percent, and July 1, 1969, it be reduced to one percent?

Mr. COUNTS. Yes, sir.

Mr. MULTER. Thank you.

(Subsequently, the following supplemental statements were filed for the record:)

SUPPLEMENTAL STATEMENT TO HOUSE COMMITTEE FOR THE DISTRICT OF COLUMBIA REGARDING H.R. 6981 (GUDE BILL) AND H.R. 10017 (HORTON BILL)

During the testimony submitted to the Committee on Wednesday, August 16, 1967 by Mr. R. L. Counts and Mr. L. T. Via, of Steuart Petroleum Company, additional information was requested by Congressman Multer and Congressman Winn appertaining to that testimony.

These requests for additional information concerned:

1. The percentage of coal to residual oil usage by the Federal Government in the Washington, D.C. area.

2. The sulphur content of available coal.

3. The project number and full name and address of Mr. J. O. Copeland concerning the survey of heating equipment made by the Department of Health, Education and Welfare.

The current G. S. A. contract calls for a usage of approximately 420,000 tons of coal. The Federal Government currently uses 48% coal-52% oil, calculated on a B. T. U. basis.

The total sulphur content of coal mined in the bituminous fields of Virginia. Kentucky and West Virginia varies from .4% to 5.5% by weight on a dry coal basis. However, the availability of the low sulphur coal is limited.

The HEW survey referred to by Mr. L. T. Via in his testimony was conducted by Mr. John O. Copeland, Department of Health, Education and Welfare, U.S. Public Health Center, 1055 Laidlaw Road, Cincinnati, Ohio 45237, and was referred to as Project No. 103-Central Development Program.

L. T. VIA, Sales Manager, Industrial Oil Burner Division, Steuart Petroleum Company.

ADDENDUM BY L. T. VIA, SALES MANAGER, INDUSTRIAL OIL BURNER DIVISION, STEUART PETROLEUM COMPANY

(Submitted by: Richard L. Counts, President Steuart Petroleum Company)

AUGUST 16, 1967.

Residual oil-properly burned-does not smoke! Smoke is the result of incomplete combustion and is principally caused by an insufficient amount of air mixing with the fuel being burned. Smoke can occur with the burning of all fuels.

"Perfect" combustion is that in which all of the combustible is burned while supplying only the exact amount of air to complete the reaction. In actual practice this condition is never attained and additional air-beyond the theoretical requirement is supplied to insure that combusion is complete. If this additional air is not supplied in sufficient volume-incomplete combusion and smoke results. This is not the fault of the fuel-but the fault of the equipment burning the fuel.

In practice, good combustion requires; a) proper proportioning of fuel and air, b) thorough mixing of fuel and air-and c) initial and sustained ignition of the mixture.

Residual oil can-and is being burned completely, efficiently and with practically zero smoke. This is accomplished when quality equipment is used, properly installed, and properly adjusted to supply sufficient combustion air to burn all the fuel.

The time of greatest potential for smoke emission occurs on a cold startup. That is, when the burner first fires into a cold combustion chamber and stack,

But even here, if the combustion cycle is so designed so that the startup occurs on "low fire" and remains on "low fire" until the combustion chamber refractory is heated to a point where it assists in supporting combustion-and then the burner switches to a "high fire" condition-incomplete combustion and smoke can virtually be eliminated.

Once the combustion chamber is hot-repeated cycles of the burner occur with a crisp, clean ignition-and produces no smoke. The combustion equipment, of course, must be serviced and maintained at a high efficiency just as an automobile must be checked and serviced to keep it running well.

Last winter and spring, under the close supervision of a committee of the Department of Health, Education and Welfare-headed by Mr. Jack Copeland— a survey was taken by Steuart Petroleum Company on some 20 installations of residual oil burning equipment here in Washington. The results of that survey point out and prove that residual fuel oil can and does burn cleanly.

The amount of sulfur in a fuel has no bearing whatsoever on smoke emission. For example, a fuel with a high sulfur content-say 5%-can be made to burn without any smoke; while a fuel with no sulfur will smoke if burned without sufficient combustion air.

For a fuel with 2% sulfur, only about .15% of sulfur dioxide will be found in the stack gases and only .002% by volume of sulfur trioxide might be produced. This gas is normally invisible and only under rare cases can it be seen in the form of a white water vapor. Normally, however, the white vapor seen on a cold day coming from the top of a stack is the result of hydrogen burning which has no pollutant or detrimental effects. It is immediately reabsorbed by the atmosphere. Quality equipment is available today from a variety of manufacturers which has been designed and field proven to be capable of burning residual oil completely, efficiently and cleanly. It must merely be installed and adjusted properly.

I repeat-residual oil properly burned-does not smoke!

Mr. MULTER. Our next witness is Mr. Frederick Babson.

STATEMENT OF FREDERICK A. BABSON, PRESIDENT, METROPOLITAN WASHINGTON COUNCIL OF GOVERNMENTS

Mr. MULTER. Introduce yourself for the record.

Mr. BABSON. Mr. Chairman and Members of the Committee, my name is Frederick A. Babson. I am president of the Metropolitan Washington Council of Governments and a member and past Chairman of the Board of Supervisors of Fairfax County, Virginia. I have with me Dr. Hohn J. Lentz, Director of Environmental Health for the Metropolitan Washington Council of Governments.

I am grateful for the opportunity to appear before you this morning. The Council of Governments is deeply concerned with the air pollution problem in this region and with the urgent need for a broad and intensive battle against this threat to our health and our economy.

The Council of Governments is the cooperative organization of the District of Columbia and the 14 other major local governments of Maryland and Virginia within the National Capitol Region. It is composed of the District Commissioners, members of the governing bodies of six counties and eight cities, and members of the U.S. Congress and the General Assemblies of Maryland and Virginia who represent portions of the National Capital Region. Through its members, the Council is reponsible to more than 212 million people.

In its ten years of operation, COG has contributed materially to the solution of areawide problems in such fields as Environmental Health, Public Safety, Transportation and Regional Planning. It has helped to pioneer the vigorous campaign against air pollution by embarking two years ago on a thorough three-year analysis, which is now almost two-thirds complete, to identify the kinds of pollution of our air and the most effective means of combating this enemy of life and property.

In cooperation with the local governments and the U.S. Public Health Service, our Council developed a scientific laboratory containing the latest technical equipment and a network of monitoring stations which enables us to sample air on a continuing basis in everypart of the metropolitan area. This data in turn are providing the basis

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for our recommendations on what our local governments can do in eliminating the problem.

In July of 1966 our Board of Directors unanimously endorsed a model air pollution control ordinance and voted to submit it to the local governments of the National Capital Region for their consideration and adoption. It was the Council of Governments' Model Air Pollution Control Ordinance that Congressman Gude used as a in developing the ordinance which is before the Committee today. guide The COG Model Ordinance was developed by one of our standing technical committees, the Regional Air Pollution Advisory Board. The Advisory Board has among its members the most competent local environmental health officials in the Washington Metropolitan area. In addition, the Advisory Board has representatives from the Maryland State Health Department, the U.S. Public Health Service, and the Virginia State Air Pollution Control Board.

The Regional Air Pollution Advisory Board, in developing the COG Model Ordinance, worked closely with the Taft Air Pollution Laboratory in Cincinatti, Ohio and with the Public Health Service's regional offices in Charlottesville, Virginia.

In addition, this ordnance is consistent with positions taken by the Maryland State Health Department, the D.C. Medical Society, the District of Columbia Tuberculosis Society, Greater Washington Citizens for Clean Air.

In January of this year, the Council of Governments formed an Air Pollution Technical Evaluation Committee. This Committee is composed of some of the leading experts in the country in the fields of industrial engineering, metallurgical engineering, agricultural research, pulmonary diseases and allergies. This committee of non-governmental specialists has strongly endorsed the COG Model Ordinance for the Washington Metropolitan area.

Two of our member jurisdictions, Montgomery County, Maryland, with a population of about 460,000 and Rockville, Maryland, with a population of about 40,000, have already adopted air pollution control ordinances conforming to the provisions of the COG Model.

The City of Falls Church, Virginia, has held a public hearing on a similar ordinance and should adopt the measure in the very near future. The legal staffs of Alexandria, Virginia; Arlington, Virginia and City of Fairfax, Virginia, and Prince George's County, Maryland, are in advance stages of preparing air pollution measures for council or commission consideration.

My own Fairfax County, Virginia, has recently transmitted a strong air pollution ordinance, also based on the COG Model to Virginia State Air Pollution Control Board in Richmond for review and approval. Our Board will schedule public readings and hearings on the bill as soon as the draft is returned. I expect this to be within the next few weeks.

The Council of Governments has expressed keen interest in the air pollution control activities of the federal Department of Health, Education and Welfare. It is the judgment of the elected officials and staff of our Council that local and state governments may see their pollution functions assumed by the Federal government unless they act quickly and wisely. Our Board has so advised our local jurisdictions.

The present and proposed federal legislative efforts in this field, we believe, generally constitute constructive attempts to help clean up the air over America's cities, but they also lay down a direct challenge to state and local governments everywhere. In effect, the Federal government is saying to our local jurisdictions, "put your houses in order, or we'll do it for you."

The local governments of Metropolitan Washington are aware of this possibility and of the seriousness of the air pollution problem in this region. As a member of the Board of a large jurisdiction, I can appreciate the need for the larger cities and counties to adopt effective air pollution ordinances. As an elected official in a suburban jurisdiction, it is clear to me that the central city, in this case the District of Columbia, must have effective air pollution measures to supplement ordinances of suburban governments. And as the President of a metropolitan organization, I realize fully the need for all jurisdictions to take action on this regional problem.

I have been pleased to learn of the amendments to this legislation proposed by Congressman Gude. Since control of air pollution should remain a local function, it is essential that legislation provide local control. Because of this, we strongly favor those amendments which would enable the District of Columbia Government to revise its standards to suit local conditions, just as all other local governments are and must be free to do.

This ability to adapt to local conditions has been a key element in the fact that the ordinance is nearing adoption in our local jurisdictions. We feel that, with this provision, we can endorse this proposed legislation to the degree that it achieves local control while still providing an effective ordinance.

The need for legislation in this field is dramatic. The District of Columbia Medical Society has called air pollution in metropolitan Washington "a matter of urgent public health importance." The U.S. Public Health Service estimates that air pollution causes $11 billion in damage to property every year in this Nation.

In the Washington area, this figure is approximately $110 million. This is $40 every year for every man, woman and child in Metropolitan Washington, a staggering sum to the general public, to the business community and to our cities and counties.

The Council of Governments over the years has called for action to fight this deadly enemy of life and property. We do so again today, Mr. Chairman, in the face of this increasing public urgency. Thank

you.

Mr. MULTER. Thank you very much Mr. Babson. Can you make available to us, for our records, the studies you made or a report on the study you've made thus far?

Mr. BABSON. Yes. Dr. Lentz, I think, could make that available. Could you the results of the studies you made?

Dr. LENTZ. I have been with the Council of Governments for approximately three months now. In the time that I have been there we have discussed some studies of damage to vegetation as a result of pollution in the air. What studies were made prior to my joining the Council of Governments were undoubtedly made as a result of activities concerned with developing the Model Ordinance. I'm talking now of formal studies. In the past three years we have been working closely