I have a letter here from Mr. Minasian which I will include in the record. (The letter is as follows:)


New York, N.Y., January 27, 1964. Hon. EDMUND S. MUSKIE, Chairman, Special Subcommittee on Air and Water Pollution, Senate Office Building, Washington, D.C.

DEAR SENATOR MUSKIE: Thank you for your invitation to appear before your subcommittee at the bearings scheduled for New York City on February 18, 1964. I am most happy to accept.

I note that your committee is particularly interested in industry's responsibility in the control of air pollution and how the Clean Air Act will assist in this regard.

In following the progress of this legislation, I have been particularly glad to note the assurances of your committee and also of the Surgeon General's staff that you recognize that the prime responsibility for regulatory control rests with the local governments and States.

The session at Pace Institute on October 28 received good publicity. I was very glad to have had the opportunity of talking with you at that session, not only about matters of mutual interest in the air pollution control field but also concerning the State of Maine. Having spent so many happy years in Maine, Mrs. Minasian and I are looking forward to returning this summer.

I note that you have scheduled a pretty strenuous tour of the country on behalf of this legislation and hope that you will find it possible to enjoy a vacation this summer. Sincerely,


Assistant to Vice President. Senator MUSKIE. Mr. Minasian, you may proceed with your statement.



Mr. MINASIAN. My name is George Minasian. I am with Consolidated Edison Co. I am a licensed professional engineer, and a great deal of my time for a great many years has been connected with air pollution and air pollution problems, and I have served on various committees locally and in the State and nationally.

It is, of course, for that reason that I have been very much interested in following the legislation proposals in both the House and the Senate which ended up in the Clean Air Act of December 17. I certainly do appreciate your inviting me to be with you this afternoon.

I, also, was pleased with your letter and invitation in that you particularly referred to the matter of industry's responsibility in the control of air pollution because, in my experience, particularly in this area in New York City and New York State, I feel very strongly that industry most decidedly has accepted that responsibility-very decidedly.

My own company, which I have served now for over 40 years, is engaged in, of course, the manufacture and distribution of electricity, gas, and steam in New York City and adjacent Westchester County, which, as you remarked earlier this morning, is one of the areas of heaviest population centers and is also the great center of business and industry, probably as great as any in the world, and, coincident with that, naturally, is that it is one of the greatest consumers of energy. So, it is, of course, very natural that air pollution is of prime importance in this community and this area.

In serving this market, Con Edison consumes approximately half of all the fuel burned in New York City, exclusive, of course, of automotive fuels, which is quite unique, I believe, anywhere.

New York does differ considerably from the other large cities, of course, that you have visited, because we do have such a diverse númber of small industries scattered around, and in the total they represent a very large amount of industry.

But, we do not have any of these large single industries such as you have in Pittsburgh with steel and in Detroit with automobiles. So, although New York does occupy a leading position as a center of industry, it is Consolidated Edison that supplies practically all of its power requirements.

We had lunch today in one of the newest and largest skyscrapers for which New York is famous, and almost all of these large skyscrapers that have been going up through the years do not have any plant in them at all even for heating. They are supplied, for their heating requirements, by Consolidated Edison steam, and, also, to an increasing amount, for air conditioning.

Therefore, you might say that in speaking this way about Consolidated Edison's position in the city, our boilers are substantially the boilers which are the energy suppliers of the city, as we also supply the subways of the city and the trains, the electricity for the trains that come into the city.

So, it is against this background, naturally, that I want to particularly talk about Consolidated Edison and why we consider most seriously our responsibility to be sure that we don't have any more than is actually possible of the abominable discharge from our stacks.

It is interesting to me, since I have been with the company for such a long period of time, to go back to the days when we were installing, from a long way back, the very best equipment available for the control of air pollution, and it seemed to us at the time that nobody else took any interest.

People would come from some distance to see our latest cinder catchers, wet and dry cinder catchers, and would look upon us as being rather ahead in this game; and yet, there was no control agency as such, really, in existence here in the city that was pushing us to do that.

So, that I am really very sure in my own mind that it is because we were somewhat pioneers in this field that we welcomed the increasing interest of other groups, in other words, so that we would not be the only ones.

That does not by any means exclude the official bodies that have taken this up. The city has only had its own full-scale department with its commissioner for a relatively short time. So, even though these were control agencies, we welcomed their interest along with the interest of others in the area.

I don't mean to insinuate that I do not fully recognize the fact that a really effective and fairminded control agency, whether it is local or otherwise, cannot be a very healthy stimulus to even better action, and that a good control legislation is quite a necessary part of the picture.


I have personally served on such committees that have drafted actual legislation, including enforcement legislation, in New York State.

I often find it surprising that as many people don't realize that we all ought to be on the same side in this picture of getting cleaner air, and that includes individuals and all sorts of organizations.

Very frequently they will sort of refer to larger companies and larger industries as if they were somehow against cleaner air or against the efforts of the authorities to do a good job. That is not

I am sure that from the way that things have been going, particularly in recent times, more of the people realize that we are all in the same boat and that we are most happy to have people, including the press and others, come around and visit us and see what we are doing or what we are trying to do.

It is not always as effective as we would like it to be. But we think that it is an open book and we are glad to have people come around who are really interested and see what is being done.

We, as a company, have spent, since 1937, just before the Second World War, over $100 million in air pollution control equipment and its installation. I am sure in your going around the country it will be very difficult for you to find any other similar company that has spent even half this amount.

We recognize, at the same time, that this is a big city, and that our plants are in the center of a very large and important city.

These latest equipments that are going in the new plants, combining mechanical and electrical precipitators, are better than 99 percent efficient in removing any particular matter of solids that would otherwise escape into the atmosphere.

Our problem, of course, is not smoke, unburned carbon. We do burn our fuels efficiently; that is the only sensible thing to do. But we must control the ash which is in the fuels. I would hope possibly that you or your committee members might have an opportunity to actually see one of these large, new, modern installations.

I also have included in my presentation the fact that my interest extends not only to my own hometown, but to a good deal further. I have been in all the 50 States and the Canadian Provinces and, because of my interest in this field, I have taken the occasion to visit many, many plants, not only utility plants, but the various steel and other industries, to see what is being done_even to riding around with the inspectors of the various enforcement agencies.

I feel, on the basis of that, that it is only fair to say that I see, in my mind, a great increase in the sense of responsibility on the part of industry for controlling its own pollutants.

I also mentioned in this report that it is quite enlightening to compare the figures of 1935 with the present to see the great increase in interest and acceptance of responsibility that has occurred in that time.

I do notice, at the same time, that air pollution, back, perhaps, in 1935, was not considered the menace that it has since come to be recog. nized as being. But the term “air pollution,” even to the members of the Air Pollution Control Association, is a rather new term. We have not heard too much of it in the past. Water pollution, yes; but air pollution, with all the reasons that you have given and other members have given for its increasing interest, has really taken hold.

Your committee, also, in your letter spoke about the ways in which the Clean Air Act could help in increasing or implementing the sense of responsibility on the part of industry in having cleaner air.

I did want to call your attention to the fact that in my visits to the Taft Center in Cincinnati, and other visits, I have felt that a pretty good job is already being done in this field, and I particulately note this in the dissemination of the information that is gathered on the causes and sources and harmful effects of air pollution and the development of methods for combating it.

I think that that has been quite helpful, and I would be glad to see that continued and augmented. I, also, feel that it is constructive for the Federal Government and its agency to pursue the matter of criteria or standards of ambient air quality, the basic amounts of pollutants that are considered acceptable in ambient air.

This information, again, can be most helpful to industry and to local authorities in the guides that they may use for emission standards, recognizing the vast variety of terrain and meteorology and land use that occurs in this area of the country.

In my previous statements, both the House Subcommittee on Health and Safety and to your committee, you will, perhaps, recall that I have expressed concern-which has been mentioned by some others here-lest the Federal enforcement provisions of the act result in interference with the activities of the local authorities where these authorities are doing a good job on their own.

And, I have also mentioned in here that I have found it encouraging, both in my conversations with you and with the Surgeon General, Dr. Terry, and others, that you do not feel that the Federal Government should interfere or overlap the activities of local groups, except where such a step would be clearly urgent.

In closing, I would just like to assure you and your committee and others that our interest will continue and we hope to continue to cooperate with the local authorities or any others who may be given jurisdiction in this field, because, as I said before, we should all be on the same side and be part of this battle for cleaner air.

Thank you, again, for inviting me here today, gentlemen.

Senator MUSKIE. Thank you, Mr. Minasian. Since you departed from the text of your prepared statement, I will place it in the record at this point.

(The prepared statement is as follows:)


CONSOLIDATED EDISON CO. OF NEW YORK, INC. Mr. Chairman and members of the committee, my name is George T. Minasian. I am assistant to vice president of the Consolidated Edison Co. of New York, Inc. I am a licensed professional engineer of New York State. I have been actively associated with air pollution control matters for many years, serving on various National, State, and local committees.

Naturally, I have followed with interest the progress of legislation in both Houses of Congress, culminating in the approval of the Clean Air Act on December 17, 1963. I deeply appreciate the invitation of your chairman to appear before you today.

The suggestion in Senator Muskie's letter that I cover particularly industry's responsibility in the control of air pollution also appeals to me, for in New York City and New York State, industry most assuredly does accept its responsibility. My company, Consolidated Edison, which I have served for more than 40 years, is engaged in manufacturing and distributing electricity, gas, and steam in New York City and adjacent Westchester County, an area with one of the heaviest concentrations of people, business, and industry in the world, and thus one of the largest consumers of energy.

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Proper control of air pollution in such an area is, of course, a matter of prime importance. Con Edison, in serving this market, consumes approximately half of all fuel burned in New York City (exclusive of automotive fuels). New York differs considerably from most of the large cities of the Nation in mans ways. For one thing, it has a great number and variety of relatively small manufacturing plants. It does not have large single industries in the sense that Pittsburgh has steel and Detroit has automobiles.

New York occupies a leading position as a center of industry, and it is Con Edison that supplies practically all of its power requirements. Also. very few of the skyscrapers for which New York is famous have their own plants, even for heating. Con Edison supplies steam for their heating in winter and, to an increasing extent, for their air conditioning in the summer. Therefore, in effect, Con Edison boilers are the prime source of energy for the city, since we also supply the electric power for the city's subways and for the trains entering the city.

It is against this background that I wish to emphasize that Con Edison always has considered most seriously its responsibility to control any objectionable discharge from its stacks. For a great many years, Con Edison has been installing the best available equipment for control of air pollution. This policy started well before there were any effective control agencies. In fact, at times, it seemed that we were the only ones in the area interested in the problem. I firmly believe that it is because we were somewhat the pioneers in this field, that we welcomed the growing interest of others, including the official bodies being set up or augmented to regulate air pollution and enforce regulations.

We also fully realize that an effective and fair-minded control agency can act as a healthy stimulus to even better control. We have cooperated closely with agencies having jurisdiction in our area. I personally have served as a consultant in setting up control legislation and regulatory rules in New York State.

I believe it is most important that it be realized that we should all be on the same side in this battle for cleaner air. For a company such as Con Edison, the installation of the best available control equipment is a costly matter. Since 1937 Con Edison has spent more than $100 million on air pollution control. I am sure that you will not find another comparable company that has spent even half that amount. Our latest combined mechanical and electrostatic precipitators maintain efficiencies in the collection of particulate matter of better than 99 percent. It is my hope that your committee may find time in your busy schedule to visit one of these installations.

While I have been talking about Con Edison, my observations and interest extend a great deal further. I have visited all of our 50 States and the Canadian Provinces, and have been in nearly all of the large cities. Because of my interest in air pollution, I have visited a great many plants of many large industries. I feel that it is quite fair to say that with few exceptions, industry has become well aware of its responsibility to control its pollutants. In fairness I must admit this has not always in the past been universally true. From my own observations, I believe that a comparison between attitudes in 1935 and today would be most revealing. However, one must not lose track of the fact that at the early date there was little awareness of the growing menace of air pollution. In fact, the term "air pollution” is relatively new to most people.

Your committee is also, through means of these hearings, seeking to learn ways in which the Clean Air Act can assist in creating increased responsibility on the part of industry. I believe the Public Health Service has already been doing a pretty good job in this area, particularly through the dissemination of knowl. edge on the subject, as its various research projects dig deeper into the causes, sources, harmful effects, and methods of abatement. Having visited the Taft Center in Cincinnati many times, I have been most favorably impressed with the work being done.

Also, it seems constructive to me for the Federal Government to pursue the setting of reasonable standards of ambient air quality. This could assist industry and local authorities in arriving at guides for emission standards,

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