has held chairmanships of numerous committees of the Air Pollution Control Association, the American Society of Mechanical Engineers, the American Public Works Association and many other technical societies.

At the present time, he serves as an incineration consultant to the National Academy of Sciences and as a radiological consultant to the Department of Defense for whom he has directed various fallout projects at five of the Nexada atomic test series.

He has been asked by the U.S. Public Health Service to appear on the program of the 1966 National Air Pollution Conference in Washington in December. Mr. Rehm will present a statement representing the views of the Milwaukee County Board of Supervisors concerning bill H.R. 13199.

Thank you very much, Mr. Rehm.

Mr. REHM. Mr. Chairman and members of the committee, my name is Fred R. Rehm, and I am deputy director of Milwaukee County's Department of Air Pollution Control. I wish to thank the committee for the opportunity to appear here today and to present the views of the Milwaukee County Board of Supervisors with regard to H.R. 13199—the 1966 Amendments to the Clean Air Act.

Milwaukee County initiated one of the first countywide, or regional, air pollution control programs in this country in June 1948. Å fulltime, well-staffed, air pollution control program has been underway in this community since that time.

You will note that Milwaukee County, therefore, preceded the Federal Government into the air pollution control field by 7 years and that we preceded even much troubled Los Angeles County in this effort.

A city of Milwaukee smoke and air pollution control program had been in effect in this area since 1904, and was one of the first such programs in any major city of this country. I would be remiss if I did not point out that Milwaukee County has taken significant steps and has made considerable progress in its program to clean the air of this community. We have operated a well-equipped laboratory for 16 years and are one of the pioneer air pollution control agencies in the measurement of air pollution emissions at the source

-the effective and logical point for controls.

We have devoted full-time, effective attention to our multitude of stationary sources of air pollution and have also devoted due attention to our motive power sources (autos, trucks, buses, trains) and to the many marine sources that are frequent visitors to our excellent port facilities.

It is not my intention to take this committee's valuable time to detail for you the progress in Milwaukee County's active air pollution control program. To do so would be an affront on this committee; however, the above brief account of this background will be helpful to you to understand our present position with respect to H.R. 13199.

By the same token that we admit to considerable progress in our efforts to date, we are the first to admit that a great deal more must be done to cope with this rapidly evolving field as man is compelled to learn to live with, and to control, his ever-increasing aerial wastes.

To this end, the Milwaukee County Board of Supervisors at its meeting of September 15, 1966, unanimously approved a 10-point 5year plan and objectives for its air pollution control program which when implemented will continue Milwaukee County in the forefront of those major cities seeking and finding workable solutions to this growing problem.

With the support of Milwaukee County, the State of Wisconsin was one of the first States in the Nation to enact favorable income and property tax concessions for the installation of air pollution control facilities. Such legislation has been in effect since 1953 and was again modified to be effective August 1, 1966, to provide the most liberal tax considerations for air pollution control facilities in the Nation.

I will not burden this committee with details of our 5-year plan and objectives, nor of the newest Wisconsin tax benefits. Instead, I have appended a copy of both of the documents detailing these two items to my prepared statement for inclusion in the record, if the committee so chooses.

Mr. JARMAN. They will be received.
(The information referred to follows:)

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In November, 1965 an application was filed for a Federal grant under the Clean Air Act (Public Law 88-206) to conduct an air quality monitoring program. In this project, a comprehensive study is planned to assess the extent and trends of the gas and suspended particulate matter phase of the air pollution problem of this community. Twenty-four-hour-per-day, seven-day-a-week studies will be made of the concentration of some of the more serious air pollutantsSO2, NO2, O3, HC, CO, and suspended particulates—at 5 or 6 different locations over a two- to three-year period. As a result of the initial study, this project may lead the Department to

(a) An extension of the continuous monitoring program for a number of years for any one, or more, of the above pollutants where concentrations of these pollutants are measured that approach a serious level.

(6) The initiation of a source emission inventory of any one, or more, of these pollutants found to exist in concentration levels considered to be approaching serious proportions.

(c) Establish the effect on pollutant concentrations of local meteorological and topographical conditions-for example, the effect of Lake Michigan's on-shore and off-shore breezes on pollution buildup, the effect of southerly winds bringing Chicago area pollution to add to our own emission sources, etc.

(d) Make recommendations for legislation to establish source emission

limitations for any, or all, pollutants reaching serious concentration levels. Status

1. We have been notified that we will shortly receive an approval Certificate from the U.S. Public Health Service that we have qualified for the U.S. grant and that we can proceed as per our project application by advancing local funds until U.S. funding is received ($12,978 for each of three years). Preliminary work on this project has been initiated. Needed to implement

1. It is becoming increasingly evident that the Department will need the services of a skilled equipment and laboratory technician to service, maintain and operate the growing amount of scientific equipment acquired by the Department to operate effectively and efficiently in this field. To ignore this need will mean the dilution and diversion of our limited professional, technical resources from the important stack testing program. Such a need will probably be more definitely established after the first year of study under this grant. It is believed that the U.S. funds can be diverted to cover three-fourths the cost of this new position under our grant. This man will be used in data analysis and evaluation of the monitoring study and in the upkeep and servicing of the

$22,000 of electronic laboratory and field test equipment the Department presently has on hand and the approximately $8,000 of new equipment that will be acquired under this project. Estimated cost-$9,500/year.


The Department has been delegated the responsibility by law to

Publish and disseminate information on air pollution reduction and control and to enlist the cooperation of civic, technical, scientific and educational

societies. With the growing public awareness and the rapid technological developments in the air pollution field, there is a rapidly developing need for the Department to establish an organized training and public information program. The need exists at present for the Department to

(a) Organize, develop, and conduct technical training courses for the following categories of people :

(1) Industrial Plant Engineers.
(2) Architects and Consultants.
(3) Heating, Sheet Metal and Ventilation Contractors.
(4) Operating Engineers and Firemen.
(5) Incinerator Contractors.

(6) Inservice Training for Department Inspectors. (6) Publish periodically a news or information piece aimed at the general public to acquaint them with the Department's efforts, programs and developments in this field.

(c) Augment and expand the publication of its technical reports on specific air pollution problems and solutions.

(d) Assist in fulfilling the increasing number of requests for public, civic

and technical society speaking engagements. Needed to implement

1. The need for a technically oriented training and public information man has been established to carry out all four of these functions. A position having these duties and responsibilities should be sought immediately. Estimated Cost-$9,000/year.



The Advisory Board, aided by the Department's staff, has undertaken the development of comprehensive Rules and Regulations governing all New Installations capable of adding air pollutants to the community's atmosphere. Upon development of proposed Rules and Regulations, the Advisory Board has assisted the Department in seeking favorable action by the County Board on its recommendations. To date, comprehensive Rules and Regulations and Permitting programs to have been adopted for New Combustion Process and Incinerator Installations. The following general areas require similar treatment, it is felt, and in this approximate order of importance relative to the contribution of these processes to the community's air pollution :

(a) Metallurgical Processes.
(0) Construction Industry Processes.
(c) Driers, Kilns, Oven Processes.
(d) Organic Solvent Processes.

(e) Grain Processes. Status

1. Rules and Regulations and Permitting programs have been established and adopted for New Combustion and Incinerator Installations within the past 142 years and 6 months, respectively. No new staff was added to implement these programs.

2. The research, industry contact, development, writing and legislative guidance in the realization of the earlier programs have largely been as the almost exclusive effort of the Department's Deputy Director. It is expected that this same employee will carry the basic work load in all future efforts to establish a sound and reasonable technical legislative program in the remaining fields. It is expected that the time table involved here to completely establish a Permitting program covering all of these new process installations will extend beyond a

69-400 0—66


5-year period under the current method of approach because of the extensive time demands involved in developing such a comprehensive Legislative program which then in each case must be implemented by the establishment of a working Permitting and Inspection Program. The implementation of this program will require a second source test team consisting of a Test Engineer and Test Engineering Aide. Even as of now, the present single source test team is falling badly behind as they are being diverted to other assignments (general air quality monitoring, specific area studies, augmenting the incineration permitting program, etc.). Needed to implement

1. There is a definite need established by the present permitting system (Combustion Process, Incinerators) for a Supervisory Inspector position to be established from a promotional examination from our Inspector specialist ranks. As soon as Rules and Regulations and a Permitting system are established in the Non-Combustion process field, the need for this position will be urgent. Estimated Cost_$9,500/year.

2. A need is rapidly becoming evident for a second source test team as the Permitting program is expanded to the Non-Combustion process field. This will entail the addition of two men for this function (Test Engineer, Test Engineering Aide). Estimated Cost-$15,000/year.



At the request and initiation of the Heating, Ventilation and Sheet Metal Contractors, and their affiliated Labor organizations, legislation was enacted (which became effective in November, 1965) permitting Milwaukee County to license Heating and Air Conditioning Contractors. It is felt that such a program, if initiated, should logically be administered by this Department as it is currently in regular contact with this segment of our local industry in its present permitting program covering the combustion fields.

It is also felt that a County-wide licensing program covering Operating Engineers and Firemen is needed to strengthen the control of air pollution caused by operating personnel. At present, only a City of Milwaukee licensing program of these groups is in effect. Outside the City of Milwaukee, there are no uniform requirements for personnel operating heating and power equipment, all of which are potential sources of serious air pollution emissions. Needed to implement

1. The development of a suitable Milwaukee County Ordinance under Statute Section 59.07 (89) Heating and Air Conditioning Contractors, should be undertaken and enacted to implement this program. The industry and labor groups involved have met with the Department and have indicated in informal talks that thi Department (they feel) is the logical one to administer this program which is aimed at upgrading the industry, as well as the air pollution problem. Enactment of this legislation will require the addition of one man and secretarial help to administer this program. Estimated Cost-$11,000/year.

2. State legislation and a County Ordinance will be required to permit Milwaukee County to establish a County-wide licensing program covering Operating Engineers and Firemen. Such a program should be patterned after, and be an extension of, the present successful City of Milwaukee program-but should cover all of Milwaukee County. The Labor organizations involved have unsuccessfully tried to establish a State-wide licensing program of these skills. A County-wide program would be an acceptable intermediate step to these groups, as well as providing an effective tool in the control of air pollution caused by irresponsible operation of equipment capable of emitting air pollutants. It is expected that the same employees handling the Heating and Ventilation Contractors licensing program could be utilized in the conduct of this program. The training and public information division would augment these efforts.


At the present time, the Department's statutory authority in this field needs clarification and expansion to permit control actions in this important phase of the community's air pollution problem. Odor problems are becoming an increasing factor in the total air pollution control problem and require attention initially at the legislative level.


It is becoming increasingly evident that a regional approach to air pollution control may be needed covering the counties abutting Milwaukee County, along with Milwaukee County. Since air pollutants do not respect political boundaries, and the concentrations are instead governed by natural air basins, it would appear proper to give some consideration and planning to a Regional approach to its control. Precedence for such approach has been established in other areas

such as San Francisco Bay Area where 5 or 6 counties have set up a single unified control program governing all units. Because of the present great urbanization trends in the former rural areas of contiguous counties, it will be necessary that they establish some form of air pollution control programs less our local effective efforts are negated by inattention to this problem by counties "upwind” of Milwaukee County. Needed to implement A possible approach to be considered in studying this proposal is

Expansion of Milwaukee County's program to cover this air basin and urbanized areas. Such a study might best be made by the Southeastern Wisconsin Regional Planning Commission. This approach could be implemented by providing air pollution control services to municipalities in neighborng counties and communities by Milwaukee County on a contract

basis. To implement a program of this type, much study is needed, and Statutory authority will be required.



In their present state, most existing fue-fed incinerators are major contributors to air pollution (soot, char and odors) in the downtown, apartment house and commercial business districts of this and most large urban areas. Within the past year, the National Academy of Sciences (after a careful study of this problem) has recommended that this type of incinerator be prohibited in new construction unless it incorporates many air pollution control features—the principal feature being a wet scrubber unit. This same report suggests methods for upgrading existing units of this type-this also incorporates adding scrubbers prior to the discharge of these units to the atmosphere. The report also recommends discontinuance or abolishment of the operation of these units, if such improvements are not incorporated after a specified period of time depending on local considerations. These type installations, we know, are the principal sources of air pollution in the above-described districts. It is felt that the location and performance evaluation of all such units be initiated promptly by Department personnel and a "phasing out or upgrading" program be established in the hundreds, and possibly thousands, of such existing units being used in Milwaukee County. Needed to implement

1. The initiation of a location and evaluation survey by Department personnel.

2. The development and enactment of suitable local legislation to deal with this problem.

It is felt that the legislation establishing time limits under such a program should await initiation and implementation of a County-wide Refuse Disposal Program. Additional personnel needs cannot be estimated at this time until details of such a program are developed.



Once a County-wide Refuse Disposal Program is implemented, it is planned to initiate a strong enforcement program aimed at the open fire and back-yard burning of garbage as is being practiced at present in large areas in certain sections of Milwaukee County. This practice is a major contributor to the community's air pollution problem. Also, it is intended that a strong enforce

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