And Our Most  Endangered People"
         A Report  to the Administrator
         of the  Environmental  Protection
         Agency  by The  Task Force  on
         Environmental  Problems  of the
         Inner City.
                         September  1971
         This  document has not been  formally
         released by  the Environmental
         Protection Agency.   It  is being
         circulated to facilitate the review
         of  its  technical accuracy and policy


   And Our Most Endangered People"
         This document has not been
         formally released by the
         Environmental Protection
         Agency.   It is being circulated
         to facilitate the review of its
         technical accuracy and policy

        Director, Office of Equal Opportunity                    c  ^  ,    ,-  .......
                             M     KK                       D*TE September 30, 1971
        Task Force on the Environmental Problems
        of the Inner City Final  Report
        The Administrator
        The Task Force on Environmental Problems of the Inner City herewith
        submits its final report in accordance with your directive of July
        9, 1971.
                                            Norris W. Sydnor, Jr.
EPA Form 1320-6 (11-71)

                             TABLE OF CONTENTS


Preface                                                               i

Membership of the Task Force                                        iii

Synopsis of Task Force Recommendations                                1

Part I  -  Overview                                                   5

Part II  -  The Urban Poor (One Environment Unequally Shared)         7

Part III  -  The Problems, The Programs, The Recommendations         23

Part IV  -  Summary of Interrelated Program Recommendations         128

Appendix                                                            146

    PESTICIDES - Legal Authority in Functional Terms                147

        A.  Regulatory Provisions                                   147

        B.  Research and Monitoring Provisions                      150

        C.  Grant and Contract Provisions                           153

    FOOTNOTES/BIBLIOGRAPHY                                          155

    EPA-CEQ Issue Paper on Water Supply Legislation (July 9, 1971)  156

        I.   Background                                             157
        II.  Rationale for the Proposed Federal Water Supply
               Program                                              159
        III. Elements of the EPA-CEQ Water Supply Legislative
               Proposal                                             162
        IV.  State Program Status and the Need for Federal
               Support                                              166
        V.   Program Costs and Benefits                             170

On July 9, 1971, Administrator William D.  Ruckelshaus charged the
Director  of Equal  Opportunity with the convening of the Task Force on
the Environmental  Problems of the Inner City.  The Administrator set
the following goals for the Task Force:

     1.  Assess the environmental burdens  on the urban poor resulting
from air, water, solid waste, pesticides and noise problems.

     2.  Review current EPA activities to  determine how they were
alleviating the environmental burdens of the urban poor.

     3.  Formulate recommendations for achievements in environmental
improvements by June 1972.

In an attempt to ensure that the report would adequately reflect a
broad range of EPA concern, the Task Force solicited input from the
Office of the Administrator, the EPA Program Offices and the Regional

The report of the Task Force is organized  into four parts:

     Part One is the overview delineating  the problems as interpreted
     by the Task Force.  Also included are the Task Force Recommen-
     dations for action to be taken.

     Part Two contains a subjective narrative and factual profile
     describing conditions in the inner city.

     Part Three covers the program areas of solid waste, air, noise,
     pesticides and water.  Each Program Area describes:

          (a) The Problem

               - causes of urban pollution, pollution effects and
               their special impacts on the inner city.

          (b) The Program

               - discussions in what is currently being done by EPA
               to alleviate environmental  burdens of the inner city.

          (c) The Recommendations

               - describes, as a result of the analysis, actions the
               Administrator may wish to take in the near future.

     Part Four consists of recommended inter-related programs  for
     the Agency as program responsibility.

While the Task Force recommends the establishment of a few new positions,
it wishes to stress that the creation of major divisions is unnecessary.
The recommendations can be carried out by EPA as presently organized if
a central point of urban program coordination is delegated reasonable

I would like to thank the members of the Task Force for their  tireless
efforts to put together a professional, comprehensive report in the ex-
tremely short time required.
                                      Morris W. Sydnor, Jr.
                                      Equal  Opportunity Division

                           Membership of the
       Task Force on the Environmental  Problems of the Inner City

Louis V. Lombardo

                              EPA MEMBERS

Joseph Amaral, Water
Timothy Fields, Solid Waste
Joseph Foran, Planning and Management
Ellen Hall, Noise
Louis V. Lombardo, Air, Chairman
Dr. Maxie Jo Nelson, Pesticides
Katharine Stahl, Office of Equal Opportunity

                             SUMMER INTERNS
Linda Bryant, Office of Equal Opportunity
Bernard Cade, Office of Equal Opportunity
Tony Collins, Office  of Public Affairs
Susan Ferst, Office of Public Affairs
Davis Kelly, SPARE
Christine Labowsky, Pesticides
Wendy Page, Office of Public Affairs
Bob Schneider, Air
Robert Smith, Water
Glenn Troutman, Water
Larry Young, Council on Environmental Quality
                            SPECIAL ADVISORS
Conrad Varner, Office of Equal Opportunity
Geraldine Werdig, Water
Diane Pirkey, SPARE
                                       Louis V. Lombardo

             A.  Inter-related Program Recommendations

1.  Conduct a "National Operation Clean Sweep" in 20 major cities to
    supplement local sanitation department efforts in clearing away
    the backlog of trash accumulated in our inner cities; follow-up
    clearance effort with a maintenance program.   Special funding of
    $50,000,000 required from Congress.

2.  Concentrate and coordinate EPA resources in a "Demonstration City
    Project" to show the achievability of an improved inner city en-
    vironment within nine months.  Washington, D. C., is recommended
    for this "model" program.

3.  Appoint an EPA Urban Affairs Office to coordinate, direct, and
    initiate inner city environmental  improvement programs within the
    Agency and serve as EPA's interface with the  President's Council
    on Environmental Quality, the Office of Management and Budget, and
    organizations in target urban areas.

4.  Create an Administrator's (or President's) Urban Advisory Council
    to develop a budget and program package directed at inner city
    needs for incorporation into EPA's FY 1974 budget and to monitor
    EPA's progress in carrying out those recommendations of the Task
    Force adopted by the Administrator.

5.  Create a Voluntary Compliance Office to pursue a vigorous voluntary
    compliance approach for pollution  abatement since such an effort can
    result in significant achievements at relatively low cost to industry,
    the government, and the consumer.
6.  Recommend or support passage of legislation giving EPA lead agency
    authority and funding in areas of  noise, solid waste, toxic substances

7.  Continue SPARE youth program as a  means of implementing environmental
    improvement in the inner cities through an information-education-paid
    employment effort.

8.  Recruit inner-city residents in a  stepped-up  manpower training and
    career development program.

9.  Give a progress report on achievements of the urban improvement
    program and the job still to be done at the June 1972 United Nations
    Conference on the Human Environment in Stockholm.


                            B.   Solid Waste
1.  Purchase plastic bags  for distribution  to  the  inner  city  to  facili-
    tate trash collection.

2.  Establish a pilot recycling plant in  Demonstration City,  Washington,
    D.  C.

3.  Establish liaison officer in the Solid  Waste Program for  dealing
    with solid waste problems of the inner  city.

4.  Increase the number of environmental  public  education programs  in
    the inner city.

5.  Demonstrate and  evaluate different methods for improving  solid  waste
    storage and collection.
                                C.   Air
1.  Promulgate by January 1972 a regulation requiring all  gasoline  to
    be lead-free by 1977.

2.  Pursue voluntary compliance from automobile and  oil  industries  to
    accelerate use of lead-free gasoline as an interim measure.

3.  Adopt by January 1972 an ambient air quality standard  for lead.

4.  Promulgate by December 31, 1971, a regulation requiring automobile
    manufacturers to label vehicles with consumer information, such  as
    octane and lead content of gasoline to be used.

5.  Conduct public education programs to encourage lead-free gasoline
    usage, car tune-ups, low-pollution driving habits.

6.  Take leadership role in encouraging "clean street" and "green city"
    projects by local municipalities.

7.  Staff the Urban Advisory Council with two air pollution experts  to
    assure State and local air quality implementation policies are re-
    sponsive to the needs of the urban poor.

                               D.   Noise
1.  Adopt as Agency priority the passage of pending noise legislation.

2.  Develop a strong public information program to emphasize to the
    general populus the need for noise legislation; major speeches  and
    magazine articles should be issued immediately.

3.  Develop a model noise control  ordinance for city governments by
    January 1, 1972.

4.  Conduct a product noise measurement program via grants to Consumers
    Union and Consumers'  Research.

5.  Develop voluntary compliance agreements with private industry and
    Government to ensure noise level  control  on products, like trucks
    and motorcycles.

6.  Require the participation of the  Administrator's Urban Advisory
    Council in voluntary compliance negotiations.

7.  Require that environmental impact statements include noise impact
    on inner city, from such sources  as highways and airports.

8.  Provide adequate staffing in the  Office of Noise Abatement Control
    to implement the above recommendations.
                             E.   Pesticides

1.  Initiate and coordinate urban community pesticide education programs

2.  Conduct a survey on the kinds of pesticides used in inner cities,
    including information about the labels.

3.  Develop international insignia for toxic materials.

4.  Require improved pesticide packaging.

5.  Develop cooperative efforts between Federal agencies to alleviate
    reasons for extensive use of pesticides in inner cities, to be con-
    ducted by an EPA Clearinghouse on Pesticides.

                               F.   Water
1.  Establish an Inner City Ecology Corps utilizing EPA environmental
    interns or SPARE participants.

2.  Initiate inner city clean-up programs to prevent litter from
    entering sewers.

3.  Initiate agreements with HUD, FHA, VA, OEO and other Federal
    agencies to correct deteriorating plumbing and inadequate in-
    stallation of sanitary facilities.

4.  Initiate workshops with inner city residents to identify water
    supply problems.

5.  Expand current Water Programs'  training courses to a number of
    demonstration cities.

6.  Initiate Kingman Lake Project,  Anacostia River in the District
    of Columbia.

                               PART I

The Environmental Protection Agency was established in December 1970,
when it had become evident that the need to act on environmental
problems requires special attention by the Federal Government.   The
Agency brought together environmental  programs of several  Executive
departments.  Though the programs are diverse in their focus, they are
related in their aim of improving the environment.

Today, there are few who are unaware of the ecological devastation of
pollution, but our awareness must go further to an understanding of
the effect that this has on the human community.  The programs  of the
Environmental Protection Agency are designed to meet the needs  of
communities throughout the nation.  Among the most pressing needs are
those found in our urban communities.   Many cities are served by
projects already in existence, but solutions to the problems of the
cities require comprehensive long-range policy aimed at the roots of
the most urgent social problems.

The problems of today's urban poor represent a complexity of conditions,
none of which can be considered in isolation.  We have too often been
project-oriented in designing solutions to problems such as poverty,
racial inequality, crime, disease and drugs, and rarely ever considered
them as an integral part of a total environmental breakdown.  The En-
vironmental Protection Agency's most valuable contribution to the
solutions of these problems lies in its ability to envision the inter-
relationship of these problems and deal with them in that light.

Cities share many of the problems faced by smaller communities  and rural
areas, but.'in the crowded urban environment they are compounded by those
conditions which are unique to the city.  City residents must breathe
the emissions of suburban automobiles which travel in to work every
morning, and travel out in the evening to escape the noise and dirt of
the city.  City children play in the streets over which the automobiles
travel, inhaling the gases and dirt left behind.  The alleys behind homes
are havens for rats which feast on garbage set out for collection.  The
dirt found on streets and in the air has much greater concentrations of
harmful particulate matter in the city than in the less dense suburban
and rural areas.

Added together, these ecological conditions contribute to the unattrac-
tiveness of residence in the cities.  Those who are able to move to
cleaner suburban environments do so, taking with them valuable revenue
sources and contributing vicariously to the decay of the cities.   The
residents left behind in the migration include a high percentage of
those whose poverty inhibits their mobility.  Discriminatory practices
and the economics of poverty confine poor residents to certain high
density areas within the city.

In general, high density poverty pockets suffer most from the dirt and
inadequate sanitary services of the city.   Slums are plagued by rats
because garbage is allowed to stand uncollected in unsanitary alleys
for longer periods of time than in the more affluent neighborhoods.
Homes in the poorer areas frequently have  dilapidated pipes and
sanitary facilities which attract insects  and rodents into the very
rooms in which people eat and sleep.  Insecticides are sprayed to combat
the pests but also may have a harmful  effect on the human residents who
breathe and otherwise come in contact with these chemicals.  Lead-based
paint chipping off walls is a potential source of danger to children  or
anyone else who might repeatedly ingest this harmful matter, which can
cause lead-poisoning.

The fulfillment of civil rights responsibilities is one approach to
alleviating the burdensome environmental problems of the poor.  By
strict enforcement of the provisions of Title VI of the Civil Rights
Act of 1964, the Environmental Protection  Agency will ensure that all
sectors of a community which receive the benefits of our grants are
serviced by our projects.  Executive Order 11246 requires that recipients
of our financial assistance and contractors with whom we do business
affirmatively demonstrate that they do not discriminate on the grounds
of race or color in the hiring of employees who work on EPA projects.
Within the Agency, there is a vigorous affirmative action plan to provide
equal employment opportunity for all citizens seeking employment with
EPA as well as for all those working in the Agency.

Even greater efforts are required for the future if social problems are
to be alleviated.  The Environmental Protection Agency must take a close
look at its role in urban life, the nature and extent of the problems and
the impact of remedies.  Information gathering and analysis and research
efforts must be considered on a broad scale of inter-related problems
and solutions in a framework of complex, far-reaching social issues.

To date, most efforts have been compensatory, palliative measures to
correct problems created by the environmental mismanagement of the past.
We must explore preventative measures for the future.  Even more im-
portantly, we must devise programs to enhance the quality of life for
the urban  poor and to involve them in those programs.  Bold, creative
ideas must be generated and we must not be reluctant to experiment.

We must listen not only to the advice of technical experts but also to
those who  are most affected by the plight of the urban environment.  No
one person or agency can single-handedly solve the vast urban problems
but each can play a part in assuring that, in the future, our cities
will be pleasant and healthy for all who chose to live in an urban en-

                          PART  II
              THE    URBAN    POOR

                       PART II

                    THE URBAN POOR




                  By Summer Interns:  Linda Bryant
                                      Tony Collins

MS (Mr.  Suburbanite] is concerned about pollution.   He remembers  his
childhood days spent swimming in the stream near his home.   Today,  his
kids cannot play in the river which runs through their suburban community
because  20 miles up stream a large factory pollutes the water.   Instead,
his children must swim in the pool at the club nearby.  Luckily,  the
kids can enjoy fresh lake water at camp and can go  to the seashore  during
family vacations.  Thus, they are still able to experience the  thrill
of jumping off rocks and diving for shells that cannot be simulated in
a chlorinated pool.

Every morning, Mr. Suburbanite wakes up in the fresh air-conditioned
atmosphere of his bedroom.  The air outside his home is fresh,  too,
and full of the smells of trees, flowers, and grass, a sharp contrast
to the air outside of his downtown office.  Driving down the expressway
on his way to work, MS notices the difference in spite of the air-
coriditioning in his car.  He is annoyed by the foul smell and sickening
sight of polluted air.  Once downtown, he finds it  unpleasant even  to
walk the streets at lunchtime.  Waiting on the corner is noisy, and the
annoyance is aggravated by the fumes created by passing buses and cars.
After the shortest exposure to the sights, sounds,  and smells of the
city street, his air-conditioned office becomes an  oasis by comparison.
Rush hour traffic is a trying experience, but MS justifies subjecting
himself to it since it means he doesn't have to live with the unpleasant-
ness of the city 24-hours a day, and more importantly, neither do his

Arriving home in the evening is like stepping into  another world.  Set-
tling down with the evening paper on the patio overlooking the mowed
lawn and well-tended garden dispels all the annoyances of the day in
the hot, dirty city.

Just a few blocks off the expressway MS travels over twice a day is the
home of MI (Mr. Inner City).  He awakens every morning without noticing
the habitual fumes and sounds from the automobiles  of commuters.   Mi's
children, too, awaken to the sounds and smells of traffic coming in the
windows left open to cool their bedrooms at night.   During the day, they
play in the streets over which the cars travel and  on which are left the
dangerous residue of automotive emissions.  Mi's children cannot swim in
the river that flows through the city park, nor do  they go away to summer
camp or to an ocean cottage in the hottest months.   The community swim-
ming pool is many blocks away, and on hot days, there is standing room
only.  Jumping off of rocks and diving for shells will never be part of
their childhood memories.

MI worries about the dirty and unsafe surroundings  his children are
forced to play in, but not as much as he worries about how to keep them

fed and in good health.  Little does he know how harmful  many things in
their surroundings are.  He is unaware of the deleterious effects  which
pesticides may have on them in the long run.  He is concerned with pro-
tecting the children from harmful  rodent and insect bites.  He is  un-
aware of the need for new pipes and new paint to decrease the possi-
bility of lead poisoning.  He is concerned with buying food and clothing
to satisfy immediate needs.

MI tries to earn enough money to provide the basics for his family.   He
lacks training because he had to go to work at a young age to help support
his brothers and sisters.  As a result, he has never been given a  job
which provides training or opportunity for advancement and he cannot afford
to go back to school.  Nor can he afford to participate in a low paying
job training program when higher wages are needed in the  here and  now,
rather than at the end of a long training period.  He is  always among
the first to be laid off.  He sometimes is forced into having to buy the
family's groceries with food stamps.  At such times, he suffers not only
limited income, but a feeling of helplessness as well.  It's hard  to
maintain self-confidence or to gain a sense of self-importance under such

Coming home at night is not a relief for MI.  The city must be tolerated
24-hours a day.  Some of his neighbors try to escape by deadening  their
awareness of the environment.  MI feels such escape is not possible for
him; he must try to stay well.  He does not realize his life expectancy
is seven years less than that of his suburban counterpart.  The rest of
his family has not been as fortunate.  The children have  been bitten by
rats and cut on broken glass while playing in the back alley, but  the
street is worse because of the traffic.  The parks have broken playground
equipment which no one ever repairs and the ground is covered with old
cans, broken bottles and other debris which is rarely, if ever, removed
by municipal maintenance crews.  This contrasts sharply with the well
manicured parks in the downtown and other more affluent areas of the
city.  The world his kids grow up in is dirty, unhealthy and often un-
pleasant, but MI cannot afford to move elsewhere.  His children are aware
of how the world treats their father.  Their own experience in unpleasant
surroundings, compounded by the poor quality of their schools, and general
discrimination dim their outlook on the world, and any prospects for a
happy future.


Whatever the hope, be  it opportunity or stimulation,  that brings  people
to urban complexes - whatever the success or failure that keeps  them
there - 130 million Americans share a deteriorating urban environment.

Each of them, whether rich or poor, white or black, suburbanite  or
city dweller, bears increasingly heavy burdens physical  from environ-
mental depreciation.  These physical burdens are imposed by air  and
water pollution, noise, pesticides, and other toxic substances.   While
borne by all, they fall most crushingly on the poor of our inner cities.

The conditions of poverty create breaking point tensions.  When  en-
vironmental stresses are added, the problems of the inner city poor are
greatly compounded.

Who Are Our Most Endangered People?

One hundred and thirty million Americans now live in urban areas.   Of
these, nearly 8 million are central city residents existing in poverty  -
4.5 million white and 3.1 million black.  (Poverty is officially defined
for the non-farm family of four as having an income of less than $3,968
per year.)  Many people have an income much lower than the poverty level.
Approximately another 8 million "near poor" have incomes slightly above
the official poverty level.  While not counted in the "statistical" 8
million poor, they suffer a similar fate.

Contrary to common belief, the urban poor are not mostly black;  in fact,
they are predominately white.  The mistaken belief probably stems from
the fact that 25 percent of the black population lives in poverty.
See Tables  II-A and II-B (pages 15 and 16).

The age distribution of the 8 million urban poor is also significant.
Three million are under the age of 15 and nearly 2 million are over
60 years of age.  Thus, 60 percent of the urban poor are at age levels
recognized  by the medical profession as most vulnerable to the injurious
assaults of pollution.  For evaluating the effects of environmental burdens,
the control group is usually healthy adult males.  That selection has
lead to an  underestimate of the consequences of pollution.  The residents
of the inner city cannot afford such underestimates as the following
analysis demonstrates.

The mental  and physical consequences of pollution are intensified by
certain factors intrinsic to poverty level subsistence, such as:

    1.  Unemployment - lack of money, lack of self-respect and dignity.

    2.  Poor Housing - inadequate, decaying and infested buildings.

    3.  Overcrowding - more than one person per room.

Without the money to obtain adequate food,  clothing,  housing,  medical
care, and education, the urban poor suffer  from undernourishment,  mal-
nutrition, higher disease prevalence,  shorter life  spans  and  the  in-
ability to break out of the cycle of poverty.


Illness is more prevalent among poor people than in those with higher
incomes.  The Task Force, in reviewing the  data, was  struck by the
question:  "Are they poor because they're sick, or  are  they sick  be-
cause they're poor?"  This same ambiguity of relationship was  raised
by another member struck by high rate of mental disorders among those
unemployed.  Table II-C (page 18) graphically depicts the high incidence
of disabling physical conditions among the  poor. Heart disease,  high
blood pressure, and mental or nervous conditions are  prevalent.   Under
these conditions, noise, toxic substances in the air  they breathe  and
the water they drink have greater adverse effect on the poor  than  on
the more affluent, healthier segments of our society.

Heart Disease - Heart disease is the major  chronic  condition  which the
adult poor suffer - along with the rest of  our adult  population.   How-
ever, if one is poor and black, the chance  of suffering from  hyperten-
sive heart disease is three times greater than for  a  white with family
income over $10,000.  See Table II-D (page  19).

Other Chronic Conditions - Other chronic illnesses  which  afflict  the
poor include emphysema and other respiratory disease, hearing and sight
impairment.  Further, persons who have family income  of less  than $3,000
per year are subject to a substantially higher incidence of one or more
chronic conditions.  Limitation of activity due to  a  chronic  condition
occurs four times more often in the lowest  income group than  in family
groups with incomes over $7,000.  See Table II-E (page  20).


The health picture of the adult segment of  the urban poor population  is
depressing.  As one of the EPA participants in Washington, D.  C.'s
"Operation Clean Sweep" said while clearing a rubble-filled alley,
"While we cannot write off the adult population, our best hope for prog-
ress lies with the youth."  However, a Task Force review of the health
of the youth, unfortunately, does not support that  hope.

Undernourishment and Mai nourishment - The preschool nutrition survey,  as
reported in the 1970 White House Conference on Children, found shocking
nutritional deficiencies among poor children.  In the low income quar-
tile for children between 1 and 2 years of  age, 11  percent had low hemo-
globin levels, 48 percent were suffering from (blood) iron deficiency,
and 40 percent from vitamin C deficiency.  Median vitamin A and B levels
for low income children were 25 percent lower than  the  medians for
higher income children and for vitamin 62 nearly 50 percent  lower.


Malnourished and undernourished children are more susceptible to the
common childhood illnesses:   When these illnesses are contracted, their
effects are longer lasting and more damaging.

As President Nixon said to the White House Conference on Food, Nutrition,
and Health:

    "A child ill-fed is dulled in curiosity, lower in stamina,
    distracted from learning.  The cost of medical care for diet-
    related illness; remedial education required to overcome diet-
    related slowness in school; institutionalization and loss of
    full  productive potential - all  of these place a heavy economic
    burden on society, as a  whole."

Inadequate Child Care - The  children of the poor need medical care most,
but they receive very little.  Estimates indicate that only 50 percent
of children from families with incomes of less than $3,000 are regularly
treated by physicians.  This compares with 75% for middle class children.
Children of the poor also suffer from inadequate home care.  One-third
of our urban black children  live in a broken home.  Lest one jump to
the erroneous conclusion that this is due solely to absent fathers, one
must examine the maternal death rate among black women.  Figure
shows that the death rate of non-white mothers during childbirth is
nearly four times higher than for white.  This robs the newborn, as well
as the other children in the family, of their mother.

Hereditary Traits - Any overview of a population of several million has
to recognize that children have an incalculable number of different
genetic characteristics.  Some of these characteristics are common to
substantial numbers of the population such as those who have brown eyes.
But some of these genetic characteristics are not as innocuous as eye
color.  Many children carry  traits like the sickle cell trait which may
make them particularly vulnerable in some respects and strong in others.
The sickle  cell trait makes  people especially vulnerable to toxic
substances like lead and carbon monoxide, but resistant to malaria.

Another identified hereditary trait which is common to many urban chil-
dren (rich and poor), and pertinent to the urban environment is the G6PD
deficiency which is believed to make them more vulnerable to the toxic
effects of lead and other air pollutants.  These genetic characteristics
must be taken into account when government sets public policy.


We cannot measure suffering, but monetarily the cost to the nation for
all health care (doctors' services, hospital payments, and medicines)
is now over $63 billion per  year and steadily rising.  The costs due to
lost productivity would be even more staggering.

Heart disease (attributable in part to the assaults inflicted by our
urban environment noise, air, and water pollution)  is the leading cause
of Social Security compensated disability.  Payments now cost the nation
$44 million each month.

Emphysema, caused in part by air pollution, presents another staggering
monthly bill.  Social Security disability payments  to 93,000 victims of
emphysema and their families total $16-1/2 million  a month.

While pollution attacks on the body have been generally recognized, less
recognized have been the assaults of pollution on the mind.   The mentally
ill, many of them victims of an assortment of environmental  stress, occupy
more than half of the nation's hospital beds.  Income level, housing
quality, and the proportion of non-white are all  inversely proportional
to the rate of schizophrenia in an area.  Social  Security is making
payments of $18,600,000 per month to 103,700 schizophrenic disabled and
their dependents across this nation.

Health costs are not the only costs to the nation which result from our
deteriorating inner cities.

The people living in our blighted urban areas carry a heavy  burden, but
they also are a heavy economic burden for other taxpayers.  A study of
Sacramento, California, showed that 20% of the population (the urban poor)
paid only 12% of the taxes but took 50% of the city's budget for police
protection and 50% of the health services budget.


A profile has been presented to delineate the conditions of  that popu-
lation group most exposed to and most in need of protection  from en-
vironmental pollution.

These then are our most endangered people - the ones most vulnerable
to the assaults of pollution:

    1.  Millions of children, vulnerable because of their tender age.

    2.  Millions of elderly, vulnerable because of  their fragile age.

    3.  Millions, vulnerable because of genetic characteristics.

    4.  Millions of children, suffering from malnutrition, illness,
        and inadequate medical care.

    5.  Millions of people, suffering from one or more disabling
        chronic conditions such as heart disease, emphysema  and

    6.  All, suffering the oppressive burdens  of poverty:   inadequate
        food, clothing and shelter;  enduring  racial,  cultural,  and
        economic discrimination;  and engulfed  in problems  of  ignorance,
        alienation, drugs, and crime.

These are the people who need EPA the most.   The urban  poor,  more than
any other population group, need  protection  from solid  waste  pollution,
air pollution, noise pollution, water pollution, and  pesticides.

These forms of environmental deterioration constitute a severe  extra
burden on that portion of the population already most heavily laden
by chance and circumstances.  EPA, remaining  completely within  its
mandate, can take a giant step toward eliminating that  extra  burden -
environmental deterioration.




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                         TABLE II-B - DATA SUMMARY

A.  Population United States                                199,849,000

    a.  Race
          White                                             175,231,000
            % Pop. U.S.                         85.1%
          Black                                              22,349,000
      %     % Pop. U.S.                         11.2%
          Non-white other than black                          2,269,000
            % Pop. U.S.                          3.7%
          Spanish origin (included in whites)                 9,230,000
            % Pop. U.S.                          4.7%

    b.  Poverty
          Total poor U.S.                                    24,289,000
            % Pop. U.S.                         12.2%

B.  Location Population
    a.  SMSA
          Total SMSA U.S.                                   130,017,000
            % Pop. U.S.                         65.0%

    b.  Central Cities
          Total Central Cities U.S.                          57,781,000
            % Pop. U.S.                         29.0%
            % Pop. SMSA                         44.4%
          White central city                                 44,392,000
            % central city pop.                 76.8%
          Black central city                                 12,439,000
            % central city pop.                 21.5%
          Non-white other than black                            950,000
            % central city pop.                  1.7%

C.  Central Cities Below Poverty
    a"!  Total central city poor                               7,760,000
            % Pop. U.S.                          3.9%
            % total central city pop.           13.4%

    b.  Race
          White central city poor                             4,527,000
            % total central city white          10.2%
            % total central city poor           58.7%
          Black central city poor                             3,068,000
            % total central city black          24.7%
            % total central city poor           39.5%
          Non-white other than black,
          central city poor                                     165,000
            % total central city poor            1.8%

    c.  Sex
          Of poor urban families, 66% black families are headed
          by females, as compared with the white figure of 37%.

                   TABLE II-B -  DATA SUMMARY  (CONT'D)
Sources:  U.  S.  Bureau of the Census,  Current Population  Reports,
          Series P-23, No.  37, "Social  and Economic  Characteristics
          of the Population in Metropolitan and Nonmetropolitan  Areas:
          1970 and 1960," U.  S.  Government Printing  Office,  Washington,
          D.  C., 1971.

          U.  S.  Bureau of the Census,  Current Population  Reports,
          Series P-60, No.  76, "24 MILLION AMERICANS -  Poverty in  the
          United States:   1969," U.  S.  Government Printing Office,
          Washington, D.  C.,  1970.

          U.  S.  Bureau of the Census,  Minority Media Conference  Report,
          New York,  May 18, 1971.

                             TABLE II-C
               Activiiy-liniitirig ccnditions, &y incoma  1884

          e    ]
          y    t

              '  26.6
                       12.6   11.9
                                 us,  uy  income IIM

                                  MENTAL AND NERVOUS
                                     '  ,13.-3,


              ARTHRITIS AND
                                       HIGH BLOOD PRESSURE
            AND ABSENCE)
                                        VISUAL IMPAIRMENTS
          UNDER $2.000- $4.000-          UNDER $2.000-  $4.000-
          $2.000  3.999   6.999 $7<00°    $2.000  3.999  6.999
                            FAMILY INCOME
     Tovards A Comprehensive Health Policy For The 1970's - A White Paper*
      U. S. Department of Health, Education, and Welfare, May 1971, p. 6

                              TABLE II-D

Definite Hypertension


Under $2,000
$10,000 and over
Under $2,000
$10,000 and over
Definite Hypertensive
Heart Disease	


Under $2,000
$10,000 and over

Under $2,000
$10,000 and over
  Source:   National  Center for Health Statistics, Hypertension
           and Hypertensive Heart Disease in Adults:   United
           States 1960-1962, Series 11, Number 13.

                                  TABLE  II-E

           INCOME:  UNITED STATES, JULY 1965-JUNE 1967.

1+ chronic conditions
3+ chronic conditions
Limitation of activity

Under $3.000

1+ chronic conditions
3+ chronic conditions
Limitation of activity


1+ chronic conditions
3+ chronic conditions
Limitation of activity

$7.000 and over

1+ chronic conditions
3+ chronic conditions
Limitation of activity
Average # of persons in
21 ,984

   Source:  National Center for Health Statistics, Health Characteristics
            by Color; United States - July 1965-June 1967, Series 10,
            Number 56.


Health Statistics Bibliography

     Bodian, C. et al,  "Socioeconomic Indicators  From Census  Tract  Data
Related to Rates of Mental  Illness," U.  S.  Bureau of the  Census.  Paper  pre-
sented at the Census Tract  Conference,  Washington,  D.  C.,  September 1963.

     Bureau of Labor Statistics, Changes in Urban America, Bureau of Labor
Statistics Publication  Number 353, 1971.

     Cassel, John, The  Relation o£ the  Urban Environment  t£ Health, School
of Public Health, University of North Carolina.

     Farber, Robert E.  (Ed), 1970 Vital  Statistics  Summary, U.  S. Conference
of City Health Officers, Washington, D.  C., March 1971.
     Health Services and Mental Health  Administration,  "Medical Aspects  of
Childhood Lead Poisoning,"  HSMHA Health  Reports;  Technical  Reports, February
1971, Volume 86, Number 2.

     Health, Education, and Welfare, Department of, Reported  Tuberculosis
Data 1969, Public Health Service Publication Number 2180,  1971.

     Kisner, Ronald E., "Report Progress in Treatment of  Sickle Cell  Anemia
Victims," Jet, June 17, 1971.

     Klee, Gerald D. , "An Ecological Analysis of  Diagnosed Mental Illness in
Baltimore," Psychiatric Research Report  22. American Psychiatric Association,
April  1967.

     Lin-Fu, Jane S., Lead  Poisoning in  Children, U.  S. Public  Health Service
Publication Number 2108, 1970.

     Lin-Fu, Jane S., "Childhood Lead Poisoning...  an eradicable disease,"
Children, Health Services and Mental Health Administration, HEW, Volume  17,
Number 1, January-February  1970.

     National Center for Health Statistics, Vital and Health  Statistics,
Series 10, Numbers 19,  21,  32, 34, 36,  38,  48, 56,  62;  Series 11, Numbers
4, 55, 6, 10, 13, 24, 37; Series 20, Number 4.

     National Heart and Lung Institute,  First Draft of National Heart and
Lung Institute Data and Research Grants  Data, October 1,  1970.

     Person, Philip Hilmar, Jr., Hospitalized Mental  Patients and the Outcome
of Hospitalization, The American University, Washington,  D. C., June  1964.

     Pollack, Earl  S., et al,  "The Application of Census  Socioeconomic and
Familial Data to the Study of  Morbidity from Mental  Disorders,"  American
Journal of Public Health, Volume 58, Number 1, January 1968.

     Pollack, Earl  S., et al,  "Socioeconomic and Family Characteristics of
Patients Admitted to Psychiatric Services," American Journal  of  Public
Health, Volume 54,  Number 3,  March 1964.

     Redick, Richard W., "Admissions Rates by Family Income - Outpatient
Psychiatric Services, 1969,"  Statistical  Note 47,  May 1971, National
Institute of Mental Health.

     Taube, Carl A., "Admission Rates to  State and County Mental  Hospitals
by Age, Sex and Color, United  States, 1969," National  Institute  of Mental
Health, Statistical Note 41,  February 1971.

     Taube, Carl A., "Differential Utilization of Outpatient Psychiatric
Services by Whites  and Non-Whites, 1969," National Institute of  Mental
Health, Statistical Note 36,  December 1970.

     Winkelstein, Warren, Jr., and Fern E. French, The Role of Ecology in
the Design of a Health Car0 Systern, School of Public Health, University of
California, 1970.

                    PART III


                  SOLID WASTE






                        SOLID    WASTE

      Solid  Waste  in Urban Areas

      Sources, Causes,  and Effects

          The Open Cycle of Waste
          The Closed  Cycle of  Conservation
          Abandoned Automobiles

      Solid  Waste  Burdens of the  Inner  City

          Rats and Garbage
          Economic Loss Due to Rats
          Litter  and  Abandoned Automobiles
          Industrial  Pollution


      "Model  Cities" Demonstration  Grant  Programs

          Portland, Maine,  Project
          Savannah, Georgia,  Project

      Joint  Effort with HUD

      Technical Assistance

      New  Program  Focus

      Research Overlap

      Need of Programs Relevant to  Inner  City

      Manpower Training

      Budget for  Inner City  Expenditures

                       SOLID    WASTE

Bounty, product obsolesence, and the disposability of the products  used
by many people generate solid waste.  The U.S.  succeeds in producing 3.5
billion tons or more of solid waste each year.   We are indeed as  Vance
Packard described us, "The Wastemakers."

Of our annual solid waste total, 200 million tons are household waste,  or
4.3 pounds per person per day.  This waste is picked up by some collection
agency and hauled away for disposal at a cost of approximately $4.5
billion per year.  By 1980, it is expected that each of us will be  dis-
carding 8 pounds of solid waste a day.

Solid Waste in Urban Areas

Presently, the solid waste problems of our urban areas fall  into  two
categories:  collection and disposal.

In our suburban areas, the collection of litter is becoming difficult
as we service an ever-widening land area used for residential  purposes.
In our cities, the more affluent sections generally have adequate collec-
tion service, while the poor inner city areas have sorely inadequate
collection service.

The urban areas as a whole have a disposal problem of what to do  with
collected waste - burn it or bury it.  Incineration and landfill  are the
disposal  "solutions" presently used in urban areas.  Both present problems.
Incineration creates air pollution, and a sanitary landfill  calls for
sufficient land to bury the waste.  Land sites  for either are increasingly
difficult to find.  People want neither incinerators nor dumps nearby.

Sources,  Causes, and Effects

The Open  Cycle of Waste - In our economy, there is an unclosed loop which
can be called the open cycle of waste.  This unclosed loop begins with  the
products  of our economy - their production, distribution and marketing.
The second step in the unclosed loop is the usage and discarding  of these
products  and their packaging.  The third step in the unclosed loop  is the
collection of these discarded products.  The fourth and final  step  of our
unclosed  loop is the disposal of these discarded products.  These steps
result in our present household solid waste total of more than 200  million
tons.  The present annual total includes 50 billion cans, 30 billion
bottles and jars, 4 million tons of plastic, 7.6 million television sets
and 7 million cars and trucks.  These "throwaways" are wasteful of
valuable  resources.

The Closed Cycle of Conservation - Closing the loop would change our
present open cycle of waste into a closed cycle of conservation.  To
achieve a closed cycle of conservation would require two additional  steps.
The fifth step would have to be reclamation of materials for further use.
The sixth step closing the loop and completing the cycle of conservation
would be production of new products from reclaimed materials.   In a  world
where the United States comprises only 6 percent of the population,  but
consumes nearly 50 percent of the world's resources, the open  cycle  of
waste cannot long continue.  The open cycle of waste is a situation  wherein
the affluent of the world take resources which belong to all - and waste
them.  EPA's job is to begin creating a system whereby the waste stops.
EPA must develop the means for converting waste into resources.  Eventually,
products must be designed such that their ultimate use is reuse.
Litter - Two causes of the litter problem are:

         (a) the propensity of people to discard these products
             wantonly after use; and

         (b) the creation of a vast quantity of limited-use products.

The quantity of these "throwaway" products is growing rapidly.  Some of
these products like aluminum beer cans and plastic cups will disfigure
the environment for a few centuries, while others like tissues and  paper
cups will degrade by biological action and disfigure the environment for
"only" a few years.

The average citizen puts his discards down somewhere and wants them to be
picked up and hauled away.  He doesn't care where; out-of-sight is out-of-
mind.  But preferably he does not want the disposed waste to accumulate

The average citizen is also cavalier about the public domain.  Note the
rubble in street gutters, in empty lots, near construction sites, in public
rest rooms and even in office bi'ildings and apartment house utility or in-
cinerator rooms.  What makes us such a nation of litterers when it comes to
the public domain?  What keeps us from realizing that everything we so care-
lessly discard on the street has to be picked up by someone else so that
we will  not be walking in our own dirt tomorrow?  What makes us continue
to create products which people want to throw away?  What makes us design
products which end in waste rather than use?

Abandoned Automobiles - The abandoned automobile is a growing national
eyesore, especially in urban areas.  Approximately 7 million motor vehicles

go out of use every year as  wrecked,  worn-out or obsolete.   Each  year
about 1  million of these are abandoned and not absorbed by  the current
system of scrap recovery.   In New York City,  it is  estimated that 1,000
automobiles are abandoned  each week.   These abandoned vehicles are more
than unsightly and depressing.  They  clog  traffic and thus  contribute to
noise and air pollution.  They are hazardous  to both neighborhood children
and motorists.  They represent the waste of valuable resources:  raw
materials and the time and energy required to cart  them to  dumps.   They
also serve as places of harborage and refuge  for rodents and vermin.

Solid Haste Burdens of the Inner City

The inner city is in great need of assistance in solid waste management.
Oftentimes, projects that  aid the typical  city resident only scratch  the
surface of the inner city  resident's  problems.  The solid waste problems
of the inner city cannot be treated in the same fashion as  those  of the
rest of the city or the suburbs.

Inner city residents must  contend with overflowing  garbage  cans that
line their sidewalks or alleys, rodents and insects which thrive  in this
refuse, and housing that offers little protection from the  rats which find
sustenance in the solid waste.

The inner city solid waste problem can be  categorized as follows:

     1.  Rodents and insects
     2.  Litter (paper, bottles and cans,  car parts and furniture)
     3.  Abandoned automobiles
     4.   Garbage

The Rodent Problem - Rats  and household insects are a constant threat to
the inner city.  The following discussion  is  from a section of the Council
on Environmental Quality's (CEQ)  1971 annual  report:

     "Strewn garbage, besides being unattractive and odorous, also
     invites rodents.  Rats feed on easily accessible garbage and
     present a health problem to inner city residents.  Greater than
     the danger of the diseases they  carry is the insecurity and
     fear they inspire, especially in parents with  small children.

     "An estimated 60 to 90 percent of rat bites occurs in  inner  city
     neighborhoods.  Eighty percent occurs after midnight when most
     victims are asleep.  The problem is intensified by large-scale
     building demolition in old, inner city areas,  where rats are
     dislodged and then flee to other parts of the city.  The presence
     of rats in an apartment often has nothing to do with the partic-
     ular building's cleanliness.  Substandard housing often is replete
     with holes in basement walls or  around windows and pipes, giving
     rats entry points from which they fan out through a building."

Diseases - Such diseases  as  rat  bite  fever,  leptospirosis,  salmonellosis,
and murine typhus fever are  spread by rats  and  insects  which  breed  in
solid wastes.   The young, the  sick and the  old  are  vulnerable,  and
especially so  after midnight when  rats are  most active  and  dangerous.

Play time, as  well as  sleep  time,  holds dangers for children  of the
inner city.  Bacteria  in  garbage and  litter can infect  those  playing  in
the mounds of  solid wastes.  The very handling  of this  rubble can spread
disease.  (And the children  must play on the streets for lack of recre-
ational  areas.   Here again,  garbage litter  and  abandoned automobiles
contend  with the children for  space.)

Economic Loss  Due to Rats -  The  direct economic loss to the nation  due
to rats  is estimated between one half billion and one billion dollars
annually.  The estimate of loss  is based on a rat population  in the
United States  of one rat  for every person.   Even if recent  improvements
in environmental  sanitation  and  rodent control  have cut the rat popu-
lation in half, the United States  still has some one hundred  million  rats,
each of which  damages  between  $1 and  $10 worth  of food  and  other materials
per year by gnawing and feeding, and  contaminates 5 to  10 times more.

Litter and Abandoned Automobiles - The problems of  litter and strewn
garbage, plus  abandoned automobiles,  are distressing both to  the residents
of the inner city and  to  visitors.
The CEQ 1971  annual  report has  also stated:
     "Junk and litter accumulated in streets,  on sidewalks,  and in
     vacant lots and doorways are a familiar sight in poverty areas
     and cannot help having a psychological  effect on those  who
     live there.  The resident often despairs  of keeping his small
     living space clean when all  around him are litter and garbage.
     He may conclude that since refuse collection is a public service,
     the abundance of uncoilected litter indicates that his  neighbor-
     hood is being discriminated against.   Residents in 9 of 20 cities
     surveyed by the National Advisory Commission on Civil  Disorders
     listed inadequate sanitation and garbage  removal as significant
     grievances.  Many cities able to set their own priorities with
     Federal funds have placed emphasis on sanitation services such
     as collecting garbage, buying trash and garbage containers for
     the city poor, removing abandoned automobiles, cleaning up
     littered vacant lots, and increasing the  number of sanitation

     "Solving the problem involves more than merely upgrading mu-
     nicipal services.  Some New York City poverty areas have
     garbage pickups six times a week, compared to three times a
     week elsewhere in the city.   In Chicago,  inner city poor are

     served by three collections a week, compared to one collection
     in the rest of the city.   Yet inner city littering and un-
     sanitary conditions continue, and there is widespread dis-
     enchantment at the failure of cleanup campaigns to have any
     lasting effect.

     "The reasons for this failure to maintain sanitary conditions
     in the inner city are complex and interrelated.   Frustration
     over limited opportunities for housing, employment, and educa-
     tion can lead residents of the inner city to withdraw from
     active efforts to improve conditions around them.   This psycho-
     logical impact is worsened by physical  conditions  which work
     against sanitation.  Buildings designed in earlier days have
     been subdivided into numerous crowded living units, with
     little provision for storage areas, common spaces, or refuse
     collection systems.  Receptacles are often nonexistent, make-
     shift, or in poor condition - all leading to a situation in
     which wind, animals, and  vandals spread litter throughout
     houses and neighborhoods.  The abundance of vacant lots and
     abandoned structures, already strewn with refuse,  encourages
     further junk, garbage, and other debris.  Together these forces
     work to frustrate even the most willing city sanitation depart-
     ment in working with residents toward a cleaner neighborhood.
     Also, sanitation collection services have been criticized as
     perfunctory in some poverty areas.   Often such services are
     confined to curbside collection of packaged refuse, ignoring
     litter in lots, sidewalks, and gutters."

Industrial Pollution - In addition to poor quality housing, neighborhoods
in the inner city may be further degraded by their location to marginal
industries.  G. L. Morris, Acting Director of Categorical  Programs  in
the Dallas Regional Office, reports, "Many of these industrial installa-
tions are negligent in the handling and disposal  of solid wastes.   Fre-
quent violations of good practice include substandard storage at the
plant, hauling in open vehicles, open dumping on company property  near
residential areas and improper operation of poorly designed incinerators
which discharge noxious smoke, mist and fumes."

Bitterness - Solid wastes cause disease and economic loss, but there is
an additional factor.  They cause bitterness among the  inner city  resi-
dents.  Feelings of depression, discouragement and despair result  from
lack of progress in environmental improvement.

The solid waste problem particularly angers  the young adults of  inner
city communities.  They feel that they receive inadequate collection
service compared with the more affluent neighborhoods,  and thus  they
feel discriminated against by  society.  This feeling is intensified  by
their other ills, such as the  high unemployment rate.

A group of 32 black legislators from 12 states wrote to President Nixon:
"Of course you are mindful  of the fact that the unemployment rate for
black veterans between the  ages of 20 and 24 years is 21  percent	
At the depths of the depression in 1933, the unemployment rate was 23.7
percent."  (UPI, July 12, 1971.)


The Solid Waste Program (and EPA in general) has defined  the environment
in such broad terms that the inner city is often overlooked in efforts
to improve the "environment."  However, we must come to realize that  the
environmental needs of the  inner city deserve more consideration by an
agency dedicated to fighting the environmental burdens of this nation's

"Model Cities" Demonstration Grant Program

In analyzing the Solid Waste Program's effort thus far, we must look
at the projects completed or in progress under our Demonstration Grant
programs.  The main effort  of our program in relation to  the inner city
has been through our "Model Cities" Demonstration Grants.

One of the problems experienced with pre-application proposals was that
the applicants were not aware of the terms and conditions of Grant
Programs under the Solid Waste Disposal Act.  One crucial condition for
funding of proposed projects is that "State, interstate,  and local
agencies of government and  public and private nonprofit organizations
may receive grant support for demonstrations relating to  the application
of new or improved methods  of solid waste collection, storage, processing,
and ultimate disposal."(emphasis added)

All solid waste demonstration grant applications, including those con-
cerning Model Cities, have to meet this requirement.  In  some cases,
it was felt that the proposals didn't give enough information to allow
an intelligent decision by granting officials as to whether they showed
promise of constituting a fruitful and useful endeavor.

Thus, several of these projects may have improved the communities in  which
they would have been administered, but they were rejected because they
weren't new and unique enough to meet the criteria set by the Solid Waste
Program, which was required by law.  So, if EPA is to relate to the inner
city in its fullest capacity, the grant program should be investigated and
its administration altered to involve the people concerned.

Portland, Maine, Project

One on-going project in the Model Cities category is being conducted in
Portland, Maine.  It is entitled, "Utilizing the Potential of Model

Neighborhood Residents to Prevent Litter Through  Exchanges  with  Chil-
dren and Youth."  The objective of the project, started in  the summer
of 1970, is to demonstrate that motivational  rather than enforcement
techniques can effectively reduce litter in local  neighborhoods.

Area youths were hired as "coaches" to lead teams  of children in
cleaning litter from neighborhood streets and vacant lots.   In return,
these youths were provided opportunities for recreational and cultural
activities.  Actual  clean-up campaigns were tackled during  the summer
months, and winter activities were mainly social  and instructional
aimed at creating anti-litter habits in young people.

Litter counts were undertaken each summer, and these results  are  now
being used to evaluate the project.  After one year there was a  33  per-
cent decrease in litter.   This project is proving  that working with
people to change litter habits can aid in solid waste management.

Savannah, Georgia, Project

Another project under our Demonstration Grant Program, classified as
Model Cities, is in  Savannah, Georgia.  Its purpose is to determine
the operating efficiency and adaptability of the  "Kuka Shark" combo-type
of refuse collection vehicle in comparison with existing methods.
(Savannah presently  provides a two-phase residential collection  service.
Compactor trucks are used for twice-a-week, behind the home or in the
alley collection of  normal household refuse stored in standard refuse
containers.  Dry trash or bulky wastes, such as yard wastes,  furniture,
and the like are collected on the curb or in the  alley once every two
to three weeks using open trucks.  The Kuka Shark  vehicle used in the
Model Cities area does both operations in one.)

The above are two examples of the several Demonstration Grant projects
concerned with the urban environment.  The one in  Portland, Maine,
incorporates the residents' efforts into the solid waste management task.
This is good because we need more effective resident involvement  to solve
the problems of the  urban environment.  Most EPA  projects fail to attack
this phase of the problem.  However, in most of the projects  undertaken,
this phase wasn't as important as it is when considering the  solid  waste
burdens of the urban poor.  In general, it can be  said that very  little
effort by the Solid  Waste Program has been directed at the  needs  of the
inner city.

Joint Efforts with HUD

Besides these two projects, the Solid Waste Program is working jointly
with HUD in another effort.  This is Operation Breakthrough,  sponsored
by the Department of Housing and Urban Development.  Its purpose  is to
inspire new and imaginative methods of housing construction that  will
help solve the problem of solid waste storage in  the home.

The Solid Waste Program will  provide technical  assistance to HUD to
assure that proper solid waste management techniques will be pro-
vided for the Operation Breakthrough projects.   It is also intended
that some innovative solid waste management systems be demonstrated
at selected sites.  The Solid Waste Program is  recommending these
sites and the systems that should be demonstrated.  EPA is providing
HUD with reliable data and design information for the selection and
installation of appropriate total solid waste management systems.

Technical Assistance
During the past year Solid Waste's Division of Technical  Operations
received over 1,200 requests for technical  assistance.   Some of these
are for assistance in urban related projects.   Recently,  the Division
fulfilled a request for technical assistance concerning solid waste
management from the Boston Housing Authority.

In the FY 72 Solid Waste Program Plan a technical  assistance project
is planned that should aid inner cities in  the storage  area.  A
demonstration of a storage system for the inner city will  begin in
1972 and continue in 1973.

New Program Focus

The argument can be used that the Solid Waste Program is  trying to serve
the solid waste management problems of all  citizens.  This is true, of
course; however, many times our assistance  may greatly  aid city residents
who have good housing, air conditioners, etc., but only scratch the
surface of the problem for the urban poor.   Thus,  we must realize that
greater emphasis on the urban poor's particular problems  is needed.

Existing legislation does not appear to present a  barrier in formulating
a new EPA focus upon the inner city.  There is a great  opportunity to
do many beneficial things within our existing legislative framework.
Thus, the scale of priorities must be evaluated within  the Solid Waste
Program (and EPA).  EPA must evaluate Agency programs to assure that
adequate attention, effort and funds are being allocated for the amel-
ioration or elimination of the solid waste problems of the urban poor.

Research Overlap

The Bureau of Mines' activities, also under the Solid Waste Disposal
Act, must be evaluated.  Its Division of Solid Wastes is involved in
a substantial amount of solid waste research.  Some of this research
is concerned with such projects as the development of junked car incin-
erators and automobile shredders, separation and recovery of metals from
urban refuse, and establishment of recycling plants.  In all these
areas there appears to be considerable overlap with EPA projects.  Each
is doing similar research in certain areas.  There should be more co-
ordination between the two agencies so as to make duplication of effort

less likely.  Currently, the Bureau of Mines and the Office of Solid
Waste Management Programs (OSWMP) are engaged in a technical  exchange
of information in order to remedy this problem.   Part of the EPA FY 72
legislative initiative is defining new legislative recommendations that
would eliminate this type of duplication.  Money spent on duplicative
research could possibly be used to aid the urban poor.

The Bureau of Mines conducts extensive research  on the disposal  and uti-
lization of junk cars.  Several years ago the Bureau made a nationwide
survey of the auto-wrecking industry, the ferrous scrap-processing
industry, and other elements pertinent to the junk car problem.   The
primary objective of the study was to identify the factors that influence
the accumulation and movement of automobile scrap.  The information ob-
tained in that study was used to prepare a report entitled, Automobile
Disposal:  A National Problem.  It is a basic source for industry informa-

However, the Bureau of Mines program is basically geared to the  technical
aspects of the problem rather than the legislative or aesthetic  aspects.
The Solid Waste Program is interested in another aspect of the problem;
namely, getting and keeping these cars off the street (or elsewhere) in
the first place.  This is the problem which impacts directly on  the
urban poor.  Many inner city young people are forced to use the  streets
as a playground because of lack of space elsewhere.  The abandoned auto-
mobile only serves to intensify the problem of congestion that already
exists.  Also, there is the aesthetic problem of the presence of di-
lapidated and rusting vehicles which have been brought to inner  city
neighborhoods for the purpose of abandonment.  The Solid Waste Program
is currently researching this problem.  There is contract effort being
exerted on several aspects of the abandoned car  problem.  The contract
specifies field data collection of the actual number of abandoned cars
(urban vs. rural) through sampling techniques, and the development of
state and local legislation pertaining to the abandoned car problem.

Need of Programs Relevant to Inner City

In examining other agencies which address problems relevant to the urban
poor, we must consider the Bureau of Community Environmental  Management
(BCEM).  This agency has the responsibility for  the Urban Rat Control
Program.  These three programs are focused upon  the inner city resident.
To properly relate to the urban poor, the Solid  Waste Program of EPA might
investigate establishing a program activity directed specifically at the
inner city.  This does two things:  delegates to a specific element of
the Solid Waste Program the responsibility for inner city solid  waste
issues, and gives those outside the program a focal point they can con-
tact for assistance.  However, this function could be effectively ad-
ministered through the pending reorganization of the OSWMP.  This re-
organization (EPA Order 1110.21) will result in  more emphasis being placed


on the problems of the urban poor.   The Storage,  Collection,  and Trans-
port Division (SCT)  will  concentrate on those aspects  of solid waste
management which most directly affect the inner city.

Because EPA does not presently have a rat control  program,  it could be
stated that the BCEM has  been fulfilling a gap in  the  area  of educating
inner city residents to the importance of sanitation for their health
and well-being.  Most EPA demonstration projects  have  not been directed
at this very important aspect of the solid waste  problem.  To be suc-
cessful, neighborhood cleanup campaigns must be accompanied by a compre-
hensive community education program.

HUD also has programs directed at the inner city  resident.   Among these
are the Model Cities Program and the Urban Beautification and Improve-
ment Program, of which the former is discussed above in this  chapter.
All of these programs aid the inner city residents in  combating solid

In the case of HUD,  as well as other Federal agencies  making  contribu-
tions to solid waste management, it would be desirable if the EPA Solid
Waste Program could  lend more technical expertise to their  efforts in
trying to help the urban poor.  Such is the case  with  HUD's Operation
Breakthrough, for which OSWMP is handling the technical solid waste
aspects of the project.

Manpower Training

Another problem of the urban poor is unemployment.  One way in which the
Solid Waste Program can help is in the area of manpower training.  This
aid should not be in the form of jobs that offer little chance of ad-
vancement, but a career-oriented solid waste management program.  A
major advantage of involving the urban poor in such a program is that
they are acutely aware of solid waste problems, and would be more
sensitized to the needs of inner city residents than outsiders.

At present EPA has an ongoing contract for the assessment of manpower
needs in the entire solid waste management field.   As a result of this
study, EPA may be able to detail a program of advancement for the urban
poor in solid waste management.

The individual job categories under evaluation include professional
personnel, technical and clerical, supervisory, skilled labor, and
unskilled labor.  Among the critical information required is the current
turnover rates within various occupational categories and functional
areas, educational and experience requirements, training opportunities,
salaries and wage levels, fringe benefits, analysis of the  civil service
and merit systems, and union membership.  As in any proposed manpower
training program we must be aware of the availability of employment
after training.

Currently, EPA is beginning an operator training program.  The two
major components are:

     1.  safety in collection; and
     2.  sanitary landfill  operations.

Budget for Inner City Expenditures

To assess the Solid Waste Program effort in the urban poor category,
the Demonstration Grant Program must be used as a yardstick.   This is
the area in which EPA "Model  Cities" grants are administered, as dis-
cussed above.  Since the EPA budget is  listed for 1971, EPA funding
for these Demonstration Grants will also be listed for FY 1971.

Our total FY 1971 budget was $20,591,000.   Of this total, $9,143,101
was allocated to the four types of grant programs.  $4,649,380 was
given to the Demonstration Grant program.   We utilized $557,800 or
roughly 12% of this amount for the "Model  Cities" area, on the following
grants listed in the Appendix:

     No. 227	$ 16,000
     No. 237	523,800
     No. 293	   18,000

      TOTAL                      $557,800


The Task Force finds that inner city residents consider solid waste and
the associated rat problem their Number One environmental problem.  The
Task Force finds that improved collection  of solid waste, rather than
transfer or disposal, is the most prominent aspect of the problem.  More-
over, the Task Force finds that the job of achieving a level  of cleanli-
ness in the inner city comparable to middle class areas is enormous.
Such an undertaking in all  our major cities would undoubtedly be a multi-
billion dollar program.  Nevertheless,  there is much that can and should
be done now.  The enormity of the task  should not deter us from making a
beginning effort to cope with the problems.  Even the most formidable
journeys begin with a humble step.

1.  Supplemental Trash Containers - Plastic Bags

The Task Force finds that the use of plastic bags can be a highly cost-
effective method of immediately improving  the inner city solid waste
problem.  Plastic bags have several important advantages, they:

     a.  accelerate the trash collection process (the sanitation
         worker does not have to return an empty trash can to the curb).


     b.  provide an odor barrier and thus are not an open invitation
         to rats and insects as are conventional  trash cans.

     c.  are available in unlimited supply while inner city people
         have limited and usually inadequate number of metal  con-
         tainers.   Thus, all trash can be packaged, and overflows
         can be drastically reduced.

     d.  are quieter than metal containers.

The Task Force recommends grants to inner city areas for the purchase
and distribution of plastic trash bags"!  (See National Clean Sweep
Recommendation for Budget.)These bags might have suitable civic pride
inscriptions on them; for example, "Help Keep Your Street Clean," or
"Help Protect Your Environment."  (See National Clean Sweep Recommenda-
tions elsewhere in this report.)

The Task Force recognizes that plastic bags have at least two environ-
mental disadvantages:

     a.  They are not biodegradable in sanitary landfills.

     b.  They create noxious fumes when incinerated.

The Task Force feels, however, that the pressing solid waste problems of
inner cities dictate, in the short run, the use of plastic bags.  For
the long run, however, the Task Force feels EPA should accelerate re-
search to develop plastic bags which are both biodegradable and free of
toxic fumes when incinerated.
The Task Force suggests that the Administrator set forth a challenge
to the membership of the American Chemical Society to develop s^ch a
plastic by June 1973, with a progress report to be made to the Adminis-
trator by June 1972.  An enormous market could be mandated for such a
product, and this market would be sufficient incentive for other chemists
to join the quest.

2.  Demonstration City Pilot Recycling Plant

The Task Force recommends the establishment of a pilot recycling plant
in Demonstration City (Washington, D. C.).This recycling center could
be run by a black-owned and operated corporation or community action
group.  Possibly, this center could be built at the site of D.C's in-
cinerator #5.

In general, recycling would pose an alternative to other forms of solid
waste disposal, such as incineration, which adds to the air pollution
problem.  EPA would thus be putting into action its desire to recycle
some of this nation's natural resources, as well as providing employment
and capitalization to minority groups.


Initially, this recycling center would serve only a segment of the city.
A long range goal  would be to expand this operation to the entire city.

In such a system,  the city government's sanitation department could
handle the collection services for this recycling center.   All garbage
from the service community would be brought to the center.  The garbage
would be sorted by recycling center personnel.  Solid waste which can't
be recycled would  be shipped to a disposal  facility, preferably a sani-
tary landfill.

This demonstration would be in keeping with one of the goals of the Solid
Waste Program,  i.e., to recycle solid waste.  Also, this would be a unique
demonstration project since we are dealing with inner city residents, as
opposed to the  middle class residents who benefit from the recycling
effort in Berkeley, California, which is a Solid Waste Program Demonstra-
tion Grant project.

The facility will  require bins for the sorted solid waste, a glass
crusher, a distribution mechanism (trucks, rail, etc.), and work stations
for the recycling  center personnel.  However, the most important need is
the technical expertise of Solid Waste Program personnel.

This recycling  center would not alleviate the solid waste probem by it-
self.  It must  be  accompanied by an imaginative solid waste collection
scheme.  However,  this recycling center would provide financial help for
the inner city  community and be a beginning step in completing the cycle
of conservation.  Jobs will be created by the center's operation, and
some of the money  would be funneled back into the inner city community.

To make demonstrable achievements by 1972, the solid waste recycling
would have to be done by outside companies initially.  This would entail
using  various  companies to recycle particular wastes, e.g., the Reynolds
Metal Company could recycle aluminum cans.   This would require the ship-
ment of recyclable solid waste to various centers.  Agreements would have
to be worked out with these companies to ensure the workability of such
a plan.

Leadership by EPA  could help actualize the desire of companies to partici-
pate in sound,  progressive projects.  Many companies are currently the
subject of much criticism which alleges that while they advertise that
they are trying to help improve environmental quality, they really do very
little.  In cooperation with these companies, substantive projects could
be begun which  would offset such criticism.

3.  Inner City  Coordinator

The Task Force  recommends the establishment of a liaison position within
the Solid Waste Program which is the focal  point for solid waste problems
of the inner city.  One of the reasons the Task Force on the Environmental
Problems of the Inner City was established was that there is no one in EPA

currently assessing the effort of our Agency relative to the urban  poor.
This points up a need in the Office of Solid Waste Management Programs
(and other EPA program areas) to have an "urban specialist"  who is
familiar with the problems in the urban environment,  who coordinates
program resources in researching solutions, and who is receptive to
requests for assistance to the urban poor.

4.  Public Education

    a.  The Task Force recommends the production of urban solid waste
        films thatenabfes the viewer to see corrective actions applied
        to problems.  Most of the present films makes one aware of  how
        severely solid waste can damage the environment, both physically
        and aesthetically.  This is good in that the  problem is being
        emphasized, and this helps create a concerned work force and
        public.  However, we should also emphasize solutions to these
        solid waste problems.

        The proposed films could be used by community action groups to
        emphasize to residents that there are solutions to their solid
        waste problems.  Also, it may serve as an inspiration to the
        community to clean up its neighborhoods.

    b.  The Task Force recommends the establishment of curriculum in  the
        public school systems, colleges, and universities relating  urban
        solid waste problems and possible solutions to students.  We  do
        not propose solely the creation of "urban specialists" by this
        recommendation, but the encouragement of students to take courses
        dealing with urban environmental issues.  These courses will  help
        sustain an environmentally-aware nation.  Also, these young people
        will bring fresh thinking to our inner city problems, and help
        provide workable solutions.

5.  Demonstration Grants

The Task Force recommends the demonstration and evaluation of equipment and
methods for improving solid waste storage in densely populated, low income,
inner city residential areas for the benefit of the users, and the  collection
agency.  This is in line with a currently proposed Solid Waste Demonstration
Grant entitled "Inner City Storage Demonstration and Evaluation."

It will provide alternative solutions for the many problems  of solid waste
storage for inner city areas.  Various solid waste storage techniques
should be utilized, such as refuse bags, metal, plastic, or rubber con-
tainers, special compactors, bulk containers.  New and improved storage
techniques which show promise for the inner city is especially encouraged.

One possible solution might be the placing of bins at strategic locations
within the inner city community.  One problem frequently encountered is
that there are not enough storage containers in the inner city for garbage


disposal.  Thus, garbage becomes piled on the ground next to those in-
sufficient numbers of trash containers residents can afford.  Sometimes
collection crews are very careless about the removal of this "additional"
trash.  This syndrome possibly can be avoided if there are adequate numbers
of containers in the first place.   Additional data would have to be gathered,
however, and a cost analysis performed before such a plan could be

6.  Monitoring

The Task Force recommends the establishment of a monitoring program for
the inner city solid waste problem^This could either be run by the Solid
Waste Program, or the city government with technical assistance from the
Solid Waste Program.  This monitoring program will be needed in order that
any concerted solid waste project in the inner city might have continuing

An inspection of the garbage and litter levels before and after the
projects are implemented to ascertain some measure of effectiveness
should be made to ensure that the level of clearance is maintained.  An
analysis should also be made of the types and frequencies of complaints
by the residents.  This would be accompanied by a survey of community
reaction to the project or campaign.

In this manner, the Solid Waste Program can ensure that its efforts to
aid the urban poor are viable and continuous.  Through the monitoring
programs, EPA will be assured that (a) any problems which arise are effec-
tively addressed and remedied, and (b) efforts in this area will have the
desired effect.

The above recommendation could be implemented within the existing National
Solid Waste Data Network, which currently monitors  residential solid waste
in three Standard Metropolitan Statistical Areas (SMSA's).  Some portion
of this monitoring effort should be allocated to the inner city.

7.  Manpower Training

The Task Force recommends the establishment of a manpower training program
for the urban poor by the Solid Waste Program.The manpower assessment
s'tudy currently being conducted is addressing this problem in part.  A
complete evaluation is needed to ensure that persons are not trained (a) in
skills for which there is no demands, or (b) for jobs which afford little
or no advancement.  The need exists for a program that will provide for
career development in the field of solid waste management for the urban
poor.  Such a program will help change the attitudes of inner city resi-
dents about their community's appearance, and give them the desire to
effect change in their own homes.

8.  Interagency Cooperation

The Task Force recommends that EPA investigate how it can cooperate more
effectively with other agencies on joint ventures, especially in cleanTFg
up the inner city.  As previously mentioned, HUD, HEW's Bureau of Communi-
ty Environmental Management, and other agencies have programs specifically
aimed at the inner city.   Mutual and reciprocal exchange of information
and expertise on urban environmental problems between these agencies and
EPA would be extremely beneficial to the development of programmatic
approaches to the problems.  HDD's Operation Breakthrough program, for
which we are supplying our technical expertise in solid waste management,
is a step in this direction.  This cooperation is necessary because the
solid waste problems of the urban poor will not be solved by the Solid
Waste Program alone.  Other factors, exterior to the solid waste problems,
must be examined simultaneously.  It is through such joint efforts that
the most meaningful and enduring results can be accomplished.

Also, duplication of effort could be avoided by this cooperation among

              A I R


                      AIR    POLLUTION

Air Pollution In Urban Areas

Air Pollution Levels, Low in the County. High in the City - Over every
urban area, on a typical day, one finds a dome of polluted air.   The 1971
Annual Report of the Council on Environmental Quality contains data de-
scribing the air pollution gradient as it increases from remote  to urban
areas.  The data show central city residents breathing air containing
five times (500 percent) more suspended particulate matter than  air being
breathed by people in remote areas.  The difference in the lead  content
of polluted city air and clean rural air is even more striking - 50 times,
(5,000 percent) more lead in the city air.

The Polluted Urban Air - The pollution content of the air varies not
only from time to time and place to place within a given city but also
from city to city.  Thus, the air pollution problem of Washington, D. C.,
which is primarily caused by motor vehicles, differs considerably from
the problem of an industrial city, such as Gary, Indiana.  Generally,
the same pollutants are found in the air of every city, only the relative
concentrations of each pollutant vary from city to city.  For example,
there is more particulate matter in the air over Gary, Indiana,  than
over Washington, D. C., but in Washington the photochemical oxidants
resulting from automobile emissions are likely to be more of a problem
than in Gary, Indiana.

Air Pollutants and Their Effects, Especially on the Poor - Air pollu-
tion dosage can be appreciated best with a knowledge of the various
pollutants and their effects on people.

Air pollutants at the dosage levels found in inner cities are injurious
to man, animals, vegetation, metals, and building materials and fabrics
and property in general.  Such levels cause man discomfort, eye irri-
tation, and difficulty in breathing.  Pollution levels restrict his
enjoyment of the environment by reducing visibility and violating his
aesthetic values.  Of all these effects, the most pressing is the de-
struction of man's health.  Each pollutant adds its burden to urban
man's health problems.

Particulars - Particulates is a general term for particles of solid
matter which are found suspended in the air of all industrialized cities
and towns.  Particulate matter may be composed of one substance or a
combination of substances.  The following is an analysis of particulate
matter composition.

    Suspended particulates - 102 micrograms  per cubic  meter
    (/"g/m3) average
    Analyzed fractions
        Benzene soluble organics                  6.9
        Benzo(a)pyrene                             .002
        Ammonium                                  0.6
        Nitrate salts                             2.9
        Sulfate salts                            10.7
        16 metals - at highest measured
                        levels in U.S.            18.33
    Total known                                  39.432/"g/m3

Ambient air quality standards to protect the public's  health  have  been
set for particulate matter at 75X:|/nr for an annual  average, and  at
260>'g/nr maximum, for 24 hours not to be exceeded more than  once  a

Most major cities have parti cul ate concentrations which exceed the
national standards.  In many cities the standards are  exceeded by  a
factor of two.   For example, in the "Critical Areas"  report the follow-
ing annual average suspended particulate concentrations were  given:

                            Chattanooga           ISl/'g/m3
                            Gary                  IBI/'g/m3
                            Indianapolis          ISS/'g/m3
                            Los Angeles           HS/'g/m3
                            New York              189'g/m3
                            Washington            104/"g/m3

Particulates (soot is a common particulate)  have subtle but significant
effects on health.  Particulates are of concern for several reasons:

    1.  Some particles are so small they elude the human respiratory
        system's ability to remove them and  they therefore remain  in
        the lung.

    2.  Particulates are often composed of toxic substances.   Some
        are carcinogenic substances.

    3.  Some parti cul ates increase the harmful effects of other
        pollutants which are present in inhaled air.

    4.  Particulate matter can react in the  atmosphere to increase
        the amount of harmful pollution, e.g., sulfur  dioxide is
        converted to more toxic sulfur tri oxide in the presence of
        some mineral particles.

Participates are often  a  severe  pollution  problem in  the  inner  city
because factories,  power  plants, and incinerators built many  years ago
are not equipped with modern  emission control  equipment.   The urban  poor
are often housed near such  heavy sources of pollution.

Sulfur Oxides -  Sulfur  oxides  is another  generic term for a  class of
pollutants which include  sulfur  dioxide, sulfur  trioxide  and  their acids
and acid salts.   These  pollutants result from  the combustion  of fuels
containing sulfur.
The ambient air  standard  for  sulfur oxides is  SO/'g/m or 0.03  parts per
million (ppm) annual arithmetic  average.   Sulfur oxide concentrations
vary considerably from  city to  city because the  fuels used in different
cities have different sulfur  contents.  Thus,  while Los Angeles has
ambient concentrations  of 65^g/m3, approaching  the standard, Chicago
has sulfur oxides levels  of 372Ag/m3,  or  more than four  and  a  half  times
the level considered protective  of the  public's  health.   The  sulfur  oxides
attack the sensitive tissues  of the lungs  and  are believed to be a con-
tributing factor in the development of emphysema and  other respiratory

Oxidants (See Table III-A on  page 61] -  Oxidants  are a major class of
chemical compounds  found  in photochemical  smog.   An ambient air quality
standard to protect the public's health has been set  by EPA at  125Xg/m3
or 0.06 ppm for  one (1) hour  not be exceeded more than once a year.   Oxidants,
ozone being the  most common oxidant, result primarily from the  interaction
of automobile exhaust gases (hydrocarbons  and  oxides  of nitrogen) under
the influence of sunlight.  Ozone causes irritation of the respiratory
system and causes difficulty  in  breathing.

In Los Angeles,  to  protect their health, children are restricted from
active play on high smog  days.   The urban  poor of Los Angeles live in
Watts, which is  located in one  of the worst smog areas of the L.A. basin.
The adverse health  effects of smog are not the most pressing  problems of
the people of Watts, but  they are a real though  generally unacknowledged
environmental part  of the oppressive burden they carry.

Oxides of Nitrogen  -  Oxides of nitrogen is a term which refers  to the
family of compounds of  oxygen and nitrogen which are  formed when combustion
occurs.  The ambient air  quality standard  for  nitrogen dioxide  (the  most
toxic of the nitrogen oxides) has recently been  set by the Administrator
at lOO^g/m3 or  0.05  ppm  for  annual average.  In Washington,  D. C.,  the
Continuous Air Monitoring Program (CAMP) station recorded an  annual  average
of 0.05 ppm in 1968 (the  last year of data presented in the criteria docu-
ment for nitrogen oxides).   In most major  cities yearly average nitrogen
dioxide levels are approaching levels known to be harmful to  health. On
high pollution days concentrations of 0.05 ppm are often  exceeded by a
factor of 4.

Nitrogen dioxide is the compound of most concern since its toxicity is
even greater than the toxicity of an equal  amount of carbon monoxide.

Carbon Monoxide -  This gas is perhaps the  most well known air pollutant,
since deaths due to the carbon monoxide poisoning are frequently recorded
by the news media.

Ambient air quality standards to protect the public's health have been
set for carbon monoxide at lO-^g/m^ (9 ppm) for an 8-hour maximum, not
to be exceeded more than once a year.   This value was exceeded 70 per-
cent of the time at the Chicago CAMP station between 1962-1967.   On the
city streets where the urban poor live, traffic frequently creates carbon
monoxide levels on the order of 100 ppm.  Traffic jams create levels of
several hundred parts per million (ppm) carbon monoxide.

The toxicity of carbon monoxide results from its chemical characteristic
of attacking the blood's oxygen carrying capacity.  Carbon monoxide re-
acts with the red blood cells 200 times faster than oxygen.  The ambient
levels of carbon monoxide commonly found in city air (around 10 ppm)
result in individuals living day in and day out, deprived of 2 percent
of their blood's oxygen carrying capacity.   The urban poor who live and
play on city streets are deprived of even more of their blood's  oxygen
carrying capacity.  Ambient carbon monoxide levels may poison as much
as 5 percent of the blood.  Lest one erroneously conclude 2 to 5 percent
to be an insignificant deprivation of oxygen, one must remember certain

    1.  Thirty percent of the body's oxygen is used by just one
        physiological organ - the brain.

    2.  Dizziness and headache result with  over 5 percent deprivation.

    3.  Above 50 percent deprivation death  occurs.

    4.  The rule of thumb, often used by air pollution control
        officials to relate effects with ambient concentrations,

                               10 ppm - Dullness (of thought process)
                              100 ppm - Dizziness
                            1 ,000 ppm - Death

Inner city residents continually carry a heavy carbon monoxide poisoning
burden.  Their other environmental burdens:  noise, rats, malnutrition,
undernourishment, pesticides, and all  the other air pollutants magnify
the significance of the carbon monoxide burden.  This is  especially true
for those urban poor with hereditary traits, such as sickle cell anemia,
and the G6PD deficiency, which make them particularly vulnerable to the
effects of carbon monoxide.

For example, the National  Academy of Sciences Report on  "The Effects
of Chronic Exposure to Low Levels of Carbon Monoxide on  Human Health,
Behavior and Performance"  devotes a chapter to the effect of carbon
monoxide in the presence of abnormal  hemoglobin.   In this chapter
concern is expressed that  people with anemia or other abnormal  hema-
tological  conditions will  suffer magnified adverse effects when exposed
to carbon  monoxide.

    "Carboxylhemoglobin in theory can affect the physical-chemical
    equilibria and reaction velocities of abnormal hemoglobins
    to a different extent  from those of normal hemoglobin A.  How-
    ever,  the loss of oxygen-transport capacity and shift of the
    dissociation curve for oxygen to the left, as mentioned earlier*
    for normal Hb, are often exaggerated by anemia and complicate  it."


Lead air pollution occurs  in two forms:  inorganic solid lead particles
so tiny as to be invisible to the naked eye, and organic lead in vapor

Lead vapors last only briefly in the atmosphere; they quickly convert
from the vapor to the solid particle form.  But lead vapors are of
concern because they are estimated to be ten times more toxic than
lead particles.  Automobiles emit most of the lead found in urban  air,
(roughly 90 percent).  Lead emissions from tailpipes are a by-product
of the combustion of leaded gasoline.

Lead Air Standards - Recently. California adopted an ambient air quality
standard for lead of l.S^g/m^ over a 30-day averaging time.  The  data
in Table IH-B, page 62, indicate that this level is often exceeded  in  urban
areas and that urban lead levels have increased during the 1960's.

Lead Air Standards Exceeded - Every day millions of U.S. citizens  are
breathing air which is contaminated to levels beyond these standards.
Residents of urban areas breathe air with annual average concentrations
of lead ranging from lA9/m3 to 3/fg/m3.  In a current report, Colucci,
Begeman and Kulmer recorded an annual average of 7.9/^g/m^ at Herald
     *"A second, more subtle disadvantage is that the effective
     02Hb dissociation curve is shifted to the left and becomes
     relatively more hyperbolic.  Although the affinity for oxygen
     is increased, the tissue cells are in jeopardy, because the
     local pO£ must be reduced to remove a given amount of oxygen
     from the Hb."

Square, New York City.   Recent NASN data show 11  cities exceeding
California's 1.5 ug/m3  level  30-day standard all  year long as  follows:
                    11  Cities                 Annual  Average
                   	               Lead  ug/m3
                 Phoenix                          2.0
                 San Francisco                    2.0
                 Oakland                          2.07
                 Burlington Co., N.J.              2.08
                 Fairbanks, Alaska                2.12
                 Detroit                          2.42
                 Scranton                         2.50
                 Long Beach                       2.60
                 Glendale                         2.80
                 Omaha, Nebraska                  2.80
                 Los Angeles                      3.10

Data on localized in-traffic or near-freeway conditions  reveal  much
greater exposure to atmospheric lead.   In a review of this data,  Landau,
Smith, and Lynn reported "Lead concentrations measured in traffic have
been about an order of magnitude higher than those measured at  off the
road sampling cities...in a 1967 study designed to determine the  levels
of lead in cars in rush hour traffic,  1/2 hour averages  in the  5-25  ug/m3
range were found."

Dr. Goldsmith testified that monthly average values in excess of
5 ug/m3 have been recorded in Los Angeles and individual  samples  obtained
near heavily traveled roadways contained concentrations  in excess of
50 ug/m3.

Roughly, it appears that in far out suburban areas the concentration of
lead in air is approximately 0.1 ug/m3 while in urban areas the concen-
tration is approximately 1.0 ug/m3.  This gradient can also be  seen  in
blood lead levels of the exposed populations.  A composite figure for the
blood lead level of the rural American male is 16 ug/lOOg while the  com-
posite figure for the urban American male is 21 ug/lOOg,  more than 30 per-
cent higher.  For females the figures  are 10 ug/lOOg rural, and 16 ug/lOOg
urban, or a 60 percent increase with exposure.

Health Effects of Lead - Historically, lead has been known to be  toxic
to humans for over 2,000 years.  Its effects on the human organism seem
to be many and diverse.  Inorganic lead is implicated as  a causative agent
in decreased hemoglobin synthesis, liver and kidney damage, mental retarda-
tion in children and in abnormalities  of fertility and pregnancy.

Any discussion of the health effects of lead must be set in  proper
perspective.  The following quote from a classical  medical text on
lead toxicology does this:

    "One of the most dangerous features of lead poisoning is
    the insidiousness of its development.  Absorption,  excretion
    and storage of excessive quantities of lead may continue for
    many years without significant manifestation of intoxication."

The body's long term, delayed response to lead can be seen from this
excerpt from a report on a  lead experiment.

    "The daily absorbed dose for the first dosage level  was
    about 0.50 mg; this produced a noticeable decrease  in red
    blood cell count and hemoglobin count within two months, while
    urine coproporphyrin rose sharply within two week_sT"
    (Emphasis added)

Lead also is absorbed rapidly by bone and apparently is released at
a slow rate over extended periods of time.  Lead workers, removed several
years from exposure, still  have shown high levels of porphyrin in their
blood.  Presumably, sufficient lead was released slowly from accumulated
reserves to interfere with  porphyrin metabolism.

Children are much more susceptible to lead intoxication than adults.
Encephalopathy and mental deterioration in lead-poisoned children have
been well documented.  One  study disclosed that 200 normal children had
blood lead levels of 14 to  30 micrograms per 100 grams  of blood while
100 mentally defective children showed 40 to 80 ug per 100 grams of blood.
Aminolevulinic acid levels  in the blood of these latter children were
also high.  It has been stated that an upper limit for blood lead in
children should be 40 ug per 100 grams of blood.  This  figure already
borders on the lower value  found in affected children,  though general
population studies of children have not been done.

Air Pollution Burdens of the Urban Poor

Longer Exposure - High air pollution levels found in city areas have long
been a cause for concern.  These high levels have a greater  impact on the
urban poor than the average urban dweller.

Urban poor tend to live, work, and play in the inner city, thus they spend
twenty-four hours a day, nearly everyday, breathing higher air pollution
levels.  The middle class,  on the other hand, lives, works,  and/or plays
much of the time in the areas where the air is cleaner.  They have the
financial means to live in the suburbs, or cleaner parts of  town, take day

trips through the countryside nearby, spend summers at the lake, etc.  At
the end of a year's time the urban poor have spent considerably more time
breathing polluted air than their more affluent suburban counterparts.

Urban poor tend to live in row or tenement housing close to street traffic.
They breathe the high pollution levels produced by traffic coming into  the
city in the morning and leaving in the evening.  This type of living is in
sharp contrast to suburban residential living which is typified by houses,
surrounded by grass and shrubbery, and set back from tree-lined streets
over which pass occasional cars.

Typically higher traffic counts on inner city streets cause high peak
pollution levels.  These peak levels are often 10 to 30 times higher than
average ambient levels.  An example of higher traffic counts can be seen
from Table III-C below.

                               TABLE  III-C

                          GARY, INDIANA  -  1968

             TYPE         	     	COUNT, VEHICLES/DAY
Major streets
Residential -



e dwelling

1 ,000
People in the inner city experience high pollution levels caused by higher
traffic counts and more frequent traffic jams.   The road in front of an
average suburban home carries traffic typified  by a car cruising at 25
mph - the lowest pollution traffic mode.  The street in front of an average
city house carries high traffic counts typified by frequent stops with long
idle periods, accelerations and decelerations - all high pollution traffic

In the inner city, houses are not the only things found in a dilapidated
condition.  Factories built in the early 1900's are now surrounded by low
income housing.   These factories are often equipped with outdated, in-
adequate, dilapidated or poorly maintained air  pollution controls (some-
times no emission controls).

The Result of Higher Pollution Levels and Greater Exposure:   Air Pollution
Poisoning - The net effect of these conditions  is to expose  inner city
residents to more pollution than suburbanites and far more than  rural
residents.  The results of such greater exposure can be seen in  the  follow-
ing summary of a study of the blood lead content of residents of the Phila-
delphia area:

        Blood specimens of three groups of persons in the Philadelphia
        area were taken to determine the amount of lead in their
        systems.  The groups were divided into  those who had lived
        and worked in the downtown area, and those who lived in  the
        same neighborhood as the suburban commuter, but also worked
        in the suburbs.  For both men and women, lead was significantly
        highest in the city dwellers.  The suburbanites who  worked in
        the city showed higher lead concentrations than those who
        lived and worked in the suburbs.

These results demonstrate the greater dosage of pollution received by
inner city residents.  The dosage received by any given individual is  de-
termined by the level of pollution to which the individual is exposed and
the length of time such exposure continues.

A study by the California Department of Public  Health shows  the  effects of
higher lead dosage received by inner city residents - the higher the dosage
of lead breathed, the higher the levels of lead found in the blood.   Thus,
the dosage received in the inner city environment is far greater than re-
ceived in the less hostile environment of the suburbs.  The  hostility of
the inner city environment has often been credited with contributing to
the "flee to the suburbs" both because it enabled people to  move out of the
city away from mass transit systems and because it helped convert the city
into a hostile environment.  In fact, it has been conjectured by  cynics  that
the automobile industry has a positive incentive to design cars  that continue
to pollute city air.

It is maintained that the automobile industry's historic opposition to
stringent emission control standards and mass transit is rooted  in their
interest in furthering the "flee to the suburb" syndrome, because subur-
banites are totally dependent upon the automobile for their  transportation

Lead Poisoning of the Urban Poor

Lead in gasoline contributes to the dangerously high blood lead  levels found
in inner city children.  Some 400,000 inner city children are believed to
be suffering from high blood lead levels.  The street dirt found in the
inner city, containing high levels of lead from the tailpipes of automobiles
burning leaded gasoline, adds to the lead burden of inner city children.

While airborne lead is of concern to the 130 million  inhabitants  of urban
America, it is of critical  concern to the inner city  poor,  especially
the children because they:

    a.  are very sensitive to lead.

    b.  are exposed to the highest concentrations  of  lead.

    c.  are ingesting lead from both the street air and street dirt
        in which they play.

    d.  are ingesting lead from lead-based paints  found in  dilapidated

    e.  are carrying dangerously high blood lead levels (an estimated
        400,000 of them).

    f.  are undernourished and malnourished, with  diminished ability
        to ward off the effects of environmental lead assault
        which include mental  retardation and death.

    g.  have a high prevalence of anemia.  The National Pre-School
        Nutrition Survey found 48% of the children tested from low
        income families suffering from iron deficiency.  Hemoglobin
        deficiency was found  in 34% of Blacks tested  in the National
        Nutrition Survey.

    h.  carry hereditary traits of sickle cell and G6PD deficiency
        which are believed to make them even more  vulnerable to the
        adverse effects of lead.

    i.  breathe other air pollutants, especially carbon monoxide
        and nitrogen oxides which attack the circulatory system
        (blood) as does lead  and, thus, add to the harmful  effects
        of lead.

The Clean Air Act - The Purpose and the Poor - EPA's  legal  authority and
responsibility for the control of air pollution stem  from the Clean Air
Act as amended in 1970.  Title I of the Act, "Air Pollution Prevention
and Control," has as its first purpose:

    "to protect and enhance the quality of the nation's air re-
    sources so as to promote the health and welfare and the
    productive capacity of its population."

The wording of this section is particularly pertinent to the urban poor,
since they,more than most, can least afford to have their health,  welfare,
and productive capacity reduced by air pollution.

Responsibility for Results - Section 101 (a) of the Clean Air Act  states

    "the prevention and control of air pollution at its source is
    the primary responsibility of States  and local governments;"
    and "that Federal financial assistance and leadership is essential
    for the development of cooperative Federal, State, regional,
    and local programs to prevent and control air pollution."

This language tends to place the Administrator of the Environmental  Pro-
tection Agency in a difficult position.   He finds himself with substantial
legal responsibility for producing results in controlling air pollution,
but only indirect authority.  He must still rely on the State and local
governments to protect the urban poor from air pollution, yet Congress
will hold him accountable for the progress, or lack of progress,  in
achieving clean air.

From the point of view of the urban poor, this legislation places primary
responsibility for results at the levels  of government least responsive
to their needs.  (Witness the example of the District of Columbia's recent
action to proceed with construction of Incinerator #5 which will  emit
thousands of tons of poisonous gases each year, for the next 20 years,  in
the center of a low income area and simultaneously to purchase the
Hopfenmaier rendering plant to stop relatively harmless odors from offend-
ing a well-to-do neighborhood.)  Experience has taught the urban  poor to
look to the Federal level for effective action.

Regulatory Authority Over Stationary Sources of Pollution

The Clean Air Act, as amended, has two major sections:  one concerned with
the control of stationary sources through State and local governments;  the
other concerned with the control of moving sources - automobiles  and air-

The Administrator must set national ambient air quality standards to pro-
tect the public health and welfare.  The primary responsibility for
achieving these ambient air quality standards, however, rests with State
governments.  The States must achieve the EPA-set ambient air quality
standards within three years (or five years if a two-year extension is
granted by EPA) in accordance with an implementation plan.  The implemen-
tation plan is to be developed by the State and approved by the Administrator.
The States were to have submitted their implementation plans for approval
by the Administrator by January 31, 1972.  The Administrator had four  (4)
months, or until June 1, 1972, to approve or disapprove of the States'
implementation plans.

The Administrator by regulations can set requirements for State implemen-
tation plans to assure that State programs will  be both adequate and
effective.  Through the EPA review process, the  Air Programs Office can
guide local governments to consider the needs of the urban poor in
carrying out their implementation plans.

Historically, the Federal air pollution program  has always focused on
controlling the high pollution levels found in urban areas.   This con-
cern has been typified by the actions of the Federal Facilities Office
which places priorities for the control of emissions from Federal fa-
cilities on the basis of those urban areas with  the highest air pollution

Regulatory Authority Over Mobile Sources of Pollution

While Title I of the Clean Air Act generally deals with the control of
stationary sources of pollution, Title II deals  with emission standards
for moving sources.  This Section of the law places the most direct regu-
latory responsibilities on the Administrator.  The Act requires the
Administrator to set emission standards for 1975 and 1976 model year
vehicles 90 percent lower than present emission  standards.  The Act au-
thorizes the Administrator to set interim standards for 1973 and 1974
model year vehicles and provides for a certification program to assure
conformance with the standards.  Authority is also provided for the
suspension and revocation of certificates of conformity.

The Administrator's authority to control motor vehicle emissions is the
most direct air pollution control authority he possesses.  If EPA is to
constitute a viable force in alleviating the air pollution burden of the
inner city residents, the Agency must utilize its legal authority to the
fullest extent.

The Federal Air Pollution Control Program has already set standards for
automobiles manufactured after 1968, and trucks  and buses manufactured
after 1970, which will improve inner city air quality.  Standards have
also been set for 1973 and 1974 models as well as 1975 and 1976 models.
If all these standards are met we should achieve urban air quality levels
protective of public health by 1984.  However, if past is prologue, the
on-the-road performance of Detroit's 1968, 1969, and 1970 models has not
met Federal emission standards and it cannot yet be determined when air
quality levels which protect public health will  be achieved.


Atmospheric Surveillance Networks - Most but not all of the stations in the
National Aerometric Surveillance Network (NASN)  are located in central city

neighborhoods and thus monitor the home environment of our urban  poor.
The Task Force did not have sufficient time to separate out this  com-
ponent from NASN stations which primarily reflect commercial  and  in-
dustrial district exposures.   The Community Health and Environmental
Surveillance System (CHESS) maintains six of its twenty-six monitoring
stations in poor urban neighborhoods located in three southeastern cities.
This CHESS monitoring effort  in poor urban areas involves  approximately
$120,000 in FY 72 funds.   In  addition, studies of simultaneous measurement
of indoor and outdoor air quality are being supported.  These have showed
that defective heating and poorly vented cooling adversely effect indoor
air quality.  This factor, coupled with a general lack of  central  air
conditioning, inadequate  housing and central city location mean that  the
urban poor are heavily exposed to air pollutants.  Trace metals,  including
lead,are monitored by NASN and CHESS.  A special study of  roadside dust
and dirt by our Division  of Effects Research provided one  key data link
between automotive emissions  and the urban lead problem which is  severest
among the urban poor.

Other Environmental Monitoring - House dust and tap water  are being
monitored for toxic substances in disadvantaged neighborhoods by  the
CHESS program.

CHESS Health Effects^Studies  - The health effects of environmental pollu-
tion, particularly air pollution, upon urban children from disadvantaged
neighborhoods is being investigated in the CHESS program.   Roughly, $500,OOu
of the total $2,950,000 allotted CHESS during FY 72 is devoted towards  such
research in disadvantaged neighborhoods in three southeastern cities.  Tissue
levels of metals (including lead), ventilatory function, acute respiratory
disease history in children and frequency of asthma and heart disease are
being monitored among the poor.  Panel studies which involve telephone
queries of volunteer families involve fewer poor as they cannot often afford
telephones.  However, $265,000 of FY 72 funds is being devoted to the study
of the effects of ambient air pollution on elderly volunteers living  in
public housing in New York City.  One panel involves healthy but  elderly
adults while two others involve those afflicted with chronic heart or
lung disorders.

Health Research Projects  Linked to Special Health Problems of the Urban Poor
- Studies are underway on pollution effects upon unborn and newborn infants,
relationship of pollution to toxemia of pregnancy, carboxyhemoglobin  levels
in urban residents and the effects of carbon monoxide upon angina symptoms
and coronary artery disease deaths.  The relationship between chronic respira-
tory disease symptom frequency, hereditary deficiency of alpha-!-antitrypsin,
cigarette smoking, and urban air pollution is of special interest in  that
chronic respiratory disease seems to be more of a problem  in poor urban whites
than poor urban blacks.  Roughly, $250,000 of FY 72 funding to the Bio-Medical
Research Branch Program Element is involved in these studies.

Air Monitoring for Short-Term Standards and Short-Term Health  Effects  -
The urban poor who reside in the most polluted sectors in the  city are
probably exposed to the highest short-term peak levels and thus  might  be
expected to suffer a disproportionate loss of good health.  Dose-rate, a
function of pollutant concentration and time, is certainly an  important
factor in the production of acute health impairments and may be  an
important component in the genesis of chronic disorders.

Expanded Monitoring for Toxic Substances in Tissues -  The lead  problem
among the urban poor is well-defined.One might also expect that cadmium,
manganese, selenium, vanadium, nickel, plasticizer and chlorinated hydro-
carbon pesticide residues would be higher among the urban poor.   Such
monitoring now carried out by CHESS and the Division of Community Pesti-
cides should be expanded in any case because of its importance for an
overall environmental index.

Lead-Free Gasoline - The Task Force finds that lead emissions from motor
vehicles contribute to the high blood lead levels of inner city children.
It has been estimated that several  hundred thousand inner city children
have blood lead levels which are dangerously high.  These high blood lead
levels stem from several sources, a prime one of which is leaded gasoline.
Other sources of lead such as lead-based paints and water supply are not
likely to be eliminated in the near future because the economics of elimi-
nation are prohibitive.  Lead intake from gasoline, however,  can be

The Bonner & Moore report just completed for EPA shows that adoption of
the most rapid lead removal  schedule would result in all  gasoline being
lead-free by 1977.  The report further reveals that total lead removal  is
both technically feasible and economically reasonable.  The Task Force
concludes that the lead burdens of the urban poor dictate adoption of this
most rapid lead-removal schedule.  The Task Force, therefore, recommends
that the Administrator promulgate by January 1, 1972, a regulation re-
quiring all gasoline to be lead-free by 1977.

The lead burdens of the urban poor are so severe that even this accelerated
lead-removal schedule represents an insufficient response to  their needs.
Thus, further actions to reduce lead emissions between now and 1977 must
be taken.

Ambient Air Standard for Lead - The Task Force finds that highways are
often built through, or alongside of, urban poor neighborhoods.  Highways
are notorious for creating heavy concentrations of lead -  automobiles
emit most of their lead when travelling at highway speeds.  Thus, high-
ways are a major contributor to the lead burdens of the urban poor.

The Task Force, therefore, recommends that EPA adopt by January 1,  1972,
an  ambient air quality standard for lead.  Promulgation of an ambient
air quality standard for lead would permit local  pollution control
agencies to fight for the delay of highway construction through or  near
urban poor neighborhoods.  EPA has been severely  criticized for not
promulgating such a standard and further delay would be unconscionable.
Delay on this action only deprives the poor of an important legal weapon
with which to defend themselves from this environmental assault.

Voluntary Compliance - To accelerate the use of lead-free gasoline  the
Air Programs Office has attempted to obtain by voluntary compliance with
both the automobile industry and the oil industry an agreement to  use
special nozzles for the dispensing and use of lead-free gasoline.   Lead-
free gasoline would be dispensed through pump nozzles which perfectly
fit special gasoline tank-fill pipes of new automobiles.  New automobiles
would be able to use only lead-free gasoline as a result of this special
nozzle-fill pipe arrangement.  This attempt at voluntary compliance by
the air programs was unsuccessful but meritorious.  The Task Force
believes that the needs of the urban poor require a renewed effort  to
achieve such an agreement.  The Task Force, therefore, recommends  that
the Administrator direct further pursuit of this  voluntary agreement by
the Air Programs Office and the Office of Voluntary Compliance.  Since new
model automobiles consume 15% of the total gasoline sold in a given year,
such an agreement can have an immediate and dramatic impact on reducing the
lead levels of the inner city.

Labeling Regulations - The Air Program Office has for some time now had
under consideration a proposal to require automobile manufacturers  to label
automobiles with two items of information:  (1) the lead content of the
fuel they recommend be used in the vehicle, and (2) the minimum octane of
the fuel they recommend.  These two items of information ought to  be
available to every consumer so that he can begin  to choose a fuel  which
does not excessively pollute the air with lead and other pollutants (and is
not wasteful of natural resources and money).  The Administrator has the
authority to require automobiles be labeled with  this information.   The cost
of such labeling to the industry and government would be insignificant, and
the consumer would actually save money.  The Task Force, therefore, recom-
mends that the Administrator promulgate by December 31,  iy/1, a regulation
requiring  1973 and  later model year automobiles to carry a label designating
We manufacturer's recommended fuel specification for lead content and

The Administrator has authority to require labels on motor vehicles in
the engine compartment to contain tune-up specifications.  Such labels are
now required by EPA, but a crash review of the information now required to
be included on the label is likely to result in a more comprehensive and
useful  label.  For example, new engines now require new special heat range
spark plugs.  Present labels do not specify the type of spark plug needed.

Installation of the wrong spark plug can result in high emissions  and/or
engine damage.  Spark plug specification could be required at insignificant
cost to the government, the industry, and the consumer, and result in
significant (albeit not readily quantifiable) benefits to the public in
terms of air quality, and lower fuel and maintenance costs.  Spark plug
specification is only one useful added information bit that could  be in-
cluded on the label.  A quick 60-day review of label specifications could
result in a much more useful  and effective labeling regulation within 120
days, effective for 1973 model  year vehicles (for sale in the Fall of 1972).

The Task Force, therefore, recommends the Administrator direct a review
of label information content to arrive at a more effective labeling regu-
lation by January 31, 1972.

Public Education Campaign - The Task Force finds that the inner city poor
tend to do the least driving, yet as a group they are exposed to the most
air pollution from motor vehicles.  The more affluent suburbanites drive
through and around inner city neighborhoods on the way to and from jobs
in the city.  Commercial traffic primarily serving the affluent is often
routed through poor neighborhoods.  Consequently, an effort must be under-
taken to minimize the emissions of these vehicles, and where possible, to
provide alternate routes for this traffic.

Much can be done by the individual motorist to minimize emissions.  Many
individuals would voluntarily take actions to minimize their emissions
if they only knew how and what they could do to help.  The Task Force
feels that the people have not been adequately informed of the actions
they might take to minimize emissions.  For example: individuals can use
lead-free gasoline of the proper octane to minimize emissions; individuals
can drive with moderation to minimize emissions (erratic and fast  driving
maximize emissions); individuals can keep their cars well-tuned (cars out
of tune create excessive emissions).  Thus, the Task Force recommends that
EPA commence a three-pronged public education campaign to obtain citizen
participation in helping to alleviate urban air pollution now"!

The three-part public education effort would consist of the following

    1.  Get the Lead Out Campaign - encourage the motoring public
        to switch to lead-free gasoline.

    2.  Drive with a Light Foot Campaign - encourage the motoring
        public to drive moderately, avoiding what is known as
        "jack rabbit" driving (fast starts and fast stops).

    3.  Tune Your Car in Harmony with the Environment Campaign -
        encourage the motoring public to have their cars tuned
        in accordance with the manufacturer's specifications at
        the recommended time or mileage intervals.

The Task Force finds, the seriousness of the air pollution  burdens  of
the poor places an enormous responsibility on the shoulders  of the
Administrator.  Practically speaking, he is the only government official
in a position to help alleviate their burdens.   In addition  to the promul-
gation of the above regulations and seeking voluntary agreements,  the
Administrator is in a position to provide leadership to the  nation.   He
can begin a nationwide publicity campaign to encourage voluntary actions.
Many people would be pleased to do something personally to help improve
the environment.  We should encourage and enable such voluntary actions
by citizens, government, and industry.

Action by the Administrator - Leadership of Concern - State  and local
governments, under the Clean Air Act, have three years to  achieve  the
ambient air quality standards adopted by EPA.  They need more than dead-
lines from EPA, they need more manpower and better ideas on  how to get
the job done.  Mr. Alexander, the new head of D. C.'s Department of
Environmental Services, indicated that "more than money, State and local
governments need expertise, energy, and enthusiasm."  The  Administrator
has demonstrated he can provide leadership; the Task Force recommends he
exercise a "leadership of concern" for the urban poor.  Such leadership
should be provided by example as well as by exhortation.

Examples of Leadership - EPA can and should provide assistance and advice
to city governments in cooperation with other Federal agencies such as
HUD, Interior, Agriculture, Labor, and HEW, to build "Clean  Air Areas"
within our inner cities.  Much can be done when government decides to
provide leadership.  Resources of agencies such as the Department  of
Agriculture's Forest Service and the Department of Interior's Park Service
can be joined with resources of EPA to begin projects improving the inner
city.  For example, trees could be obtained from one agency, sod from
another, expertise from both.  The Department of Labor already provides
funds through SPARE to engage inner city youth in worthwhile environmental
projects.  With leadership EPA could do much to begin creating little pockets
of clean air in our inner cities to make them more livable.

The Task Force recommends that the Urban Affairs Office be given a staff
of at least five (5) professionals to carry out a program  of Leadership
of Concern to encourage, initiate, and develop projects to improve both the
quality of life and the air quality in the inner city.Such a staff should
include an urban planner, someone trained in the social sciences,  and some-
one who can obtain the cooperation of industry and other government agencies.
The Task Force recommends the following projects be pursued by the Urban
Affairs Office:

    1.  Clean Streets Projects

        a.  Frequent washing down of inner city streets by sanitation
            trucks ought to be vigorously encouraged to reduce lead
            intake of urban poor children.

        b.   Designation of play-streets  in  the  inner  city.   Traffic
            pattern changes should be  encouraged  to reduce  the  ex-
            posure of children  to  high pollution  levels.  Play-streets
            would sKarply reduce traffic to only  those  vehicles having
            business on that particular  block.

        c.   Designation of bicycle routes should  be encouraged  to
            reduce vehicle traffic in  the inner city.

    2.  Green City Projects

        a.   EPA could encourage the adoption and  enforcement of ordi-
            nances requiring inner city  landlords to  have rubble-filled
            lots cleared, sodded,  and  maintained  as mini-parks.

        b.   Tree-planting programs, possibly, as  an extension of the
            President's "legacy of parks,"  could  be started in  the
            inner city, especially on  play-streets.   Such programs
            could make a beginning on  converting  the  presently  hostile
            inner city environment into  a more  hospitable environment.

        c.   By leadership develop  projects  in cooperation with  local
            governments, industry, and other Federal  agencies to
            increase the quantity  and  quality of  green  space in our
            inner cities.

Some benefits which would result from  Clean Streets Projects and Green  City
Projects are:

    1.  Mini-lawns and tree programs would  contribute to cleaner air
    since vegetation (grass) and active  bacteria  in the soil have a
    cleansing effect on polluted air - trapping and converting  pollu-
    tants into non-toxic substances and  creating  life-giving oxygen.
    Vegetation is both a sink for  air  pollution and a source of clean

    2.  Mini-lawns and trees would give  people  in the community a
    psychological life instead  of  a psychological letdown.   They soften
    the harshness of the inner  city.

    3.  Vegetation cools a city by transpiration, as  well as by shade.
    There is no doubt that programs are  desperately needed  to cool the
    inner city both physically  and psychologically.

    4.  Rodent control would be improved, since havens  formed by
    rubble would be eliminated.

    5.  Children would have safer, cleaner, quieter places  to play.

    6.   Maintenance of mini-lawns  and  city trees  would  provide  employ-
    ment for young  inner city teenagers.   Landowners  would have to
    hire them to  pick up litter and  cut the grass each  week.   Companies
    on  contract or  government agricultural  experts could train  urban
    poor in park  maintenance.

    7.   Even water  pollution  problems  would be alleviated since
    vegetation would trap water which  now runs into storm sewers
    overloading sewage treatment plants.

Inner City Air Quality Assurance Plan  - Under the provisions  of the Clean
Air Act, State and  local governments file implementation plans  to achieve
ambient air quality standards by 1975.  The Task  Force  fears  that in this
area, as in so many other areas, the interests of the urban poor will  be
least attended to unless EPA  forcefully advocates their interests in the
review, approval, or withholding approval, of air quality implementation
plans.   One way to  assure such advocacy is to staff the Urban Advisory
Council with several air pollution specialists to influence EPA's review
process on behalf of the inner city residents.

Thus, the Task Force recommends that EPA staff the Urban Advisory Council
with two air pollution experts, one on stationary sources and one on
mobile  sources, to  assure that procedures, actions, and safeguards to
protect the health  of the urban poor are incorporated into State and local
implementation plans.  Furthermore,  these advocates should be given the
responsibility to assure that these procedures are actually carried out
over the next three years.

                      TABLE III-A





St. Louis

Washington, D. C.

Number of days with at
least 1 hourly average
equal to or exceeding
0.05 ppm
0.10 ppm
0.15 ppm




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      Noise in Urban Areas

      Major Sources of Noise and the Effects of Noise

          Public Transportation
          Housing Factors

              Noise Inside the Factory
              Noise Outside the Factory

      Physiological and Psychological  Effects of Noise

      Noise Burdens of the Urban Poor



      Noise Legislation
      National Noise Monitoring Program
      ONAC Staff Increase
      Public Education Program
      Voluntary Compliance Program
      Noise Abatement Program Under Existing Authority


                                 0 I  S E

Noise in Urban Areas

One-hundred and thirty million urban Americans are exposed to  an ac-
celerating level  of noise.   The noise sources include transportation
vehicles (including aircraft and recreational equipment),  construction
equipment, heavy industrial  machinery, and an array of devices used  in
homes and offices.   (See Table III-D, page 80.)   Merely being  on the street
at times can be stressful  to the ear and psyche.

Though little research has  been done on the effect of generalized communi-
ty noise on physical and mental health, two significant and disturbing
facts are evident:

    1.  Some 20 percent of the United States population, in addition
        to those exposed to excessive occupational noise,  have
        significant hearing impairment by their fifties.  While part
        of this loss in hearing is due to natural  causes,  the  role of
        noise is of increasing concern.

    2.  In urban areas, the noise level is increasing at an alarming
        rate, up one decibel (dB-A) a year.  In another fifteen years,
        it is believed that the overall noise level will have  doubled.

Major Sources of Noise and the Effects of Noise

Traffic - Motor vehicles create the primary source of city noise. While
communities bordering major airports experience the highest levels of
outdoor noise exposure, more people are exposed to road traffic noise.
This, though lower level than aircraft sounds, can be more continuous
in nature.  Urban expressway noise of over 90 dB-A can go  on for hours
at a time.  (For purposes of comparison, 90 dB-A is the Federal standard
for maximum in-plant factory noise.  Concern that even this level will
damage workers' hearing over a period of time has led to the introduction
in Congress of a Bill to reduce the standard to 80 dB-A, H.R.  6991.)

Already noise levels measure 90 dB-A on the street corners of  many of
our cities.  Stopping, starting, and accelerating automobiles, typical  of
city driving, creates more noise than the 25-mph average cruising speed,
for example, in suburban areas.

The inner city is particularly burdened by traffic noise because of
poor city planning practices and opportunism.  Consequently, highways  are

generally constructed through inner city neighborhoods.   In the inner
city, over 60 percent of the traffic noise is generated  by people who
live elsewhere.  Trucks, too, are more apt to be routed  through the inner
city areas.  Trucks are a major source of ambient noise.   Older trucks
and diesel-powered trucks are especially loud, and their impact on the
human organism is one of the most detrimental.

Motorcycles also have become an increasing nuisance.   (There were only
417,578 in 1952, and there are now 2.4 million.)  Some are producing
up to 122 dB-A's measured 18 inches from the tail pipe.   This is, quite
literally, deafening.  Even at 50 feet their noise can be damaging.

Public Transportation - Buses, subways and elevator trains ("els") inflict
their noise elements into the urban scene.  For example  - not as an
indictment of mass transportation, but rather a plea  for quieter equip-
ment - the Jackson Park el, Chicago public transit, generates noise up
to 105 dB-A.  This particular train runs at all hours, and passes so
close to apartments in the inner city that a passenger could lean out of
a train window and touch the buildings.

One irony in the area of public transportation noise  control which was
discovered by the Task Force can be found in the New  York City 1970 Task
Force Report on Noise Control.  This report pointed with envy to Montreal's
subway system, which is 80 percent quieter because the trains run on
rubber wheels rather than on the steel wheels used in New York.  At the
same time in D. C., engineers are designing a "modern" Metro subway system
to roll on standard steel wheels.

Aircraft - Aircraft noise has received a great deal of attention, mainly
from those who live near flight patterns.  For those  city people who do
live near airports, normal activities and communications  are often
impossible, even watching television or talking on the telephone are
difficult.  Aircraft noise when heard closely arouses fear and apprehen-
sion.  (See section on psychological effects of noise.)

By 1985, 95 percent of all aircraft will be jet-powered.   Jets are much
louder than piston aircraft, and have already been responsible for the
mass exodus from areas bordering airports.  The exodus is understandable
as the noise level exceeds that found in riveting operations or around
textile looms.  And, unlike industrial noise, aircraft noise is usually
a 24-hour-a-day occurrence.

Current models of four-engine jets produce up to 105  dB-A at an altitude
of 100 feet overhead during takeoff, and up to 108 dB-A  at 400 feet over-
head during landing.


Construction - Construction noise in the city,  though  often  considered
temporary, affects all  in the surrounding area.   Diesel-driven engines,
bulldozers, and rock drillers are among the worst offenders.   Air com-
pressors and suction pumps, riveting hammers and pneumatic drills are
loud and unpleasant.  The men who spend their lives  working  these machines
usually sacrifice most of their hearing.

Housing Factors - Residences in high density sections  of the city are
often located on or near heavily travelled streets,  and  are  generally
without trees and shrubs to absorb noise.  The  houses  and apartment
buildings in the inner city, in addition, are often  poorly built or have
a variety of inadequacies, including thin walls.  Acoustical  considera-
tions are frequently overlooked in the construction  of relatively expensive
single family units.  This oversight is usually even more pronounced in
public housing projects.

One of the problems of public housing, and modern architecture in general,
is its exterior flatness.  The noise from streets reverberates back and
forth off of the flat surfaces and thus noise canyons  are created.  In
suburban areas, trees, open spaces and architecture  (both internally and
externally) help to dissipate and absorb sound.   In  the  city, where
buildings are attached or close together, noise is often transmitted from
one building to another, further increasing noise levels. Though we tend
to think of homes as being "private" places, where one may have shelter
from the stress of everyday life, most modern,  public  housing is simply
not this way.

Few people know that if a barrier (such as a wall) does  not  have enough
mass and enough dead space to be sound-absorbent, it will act as a
transmitter of sound.  As Theodore Berland, author of  The Fight For
Quiet has noted:
    "This is what happens in so many of the buildings that were
    erected in the 1950's and 1960's.  Solid, thick, load-bearing
    masonry walls became too expensive to build and were replaced
    by lighter and more flexible steel frames.  Inner walls are now
    made of 2x4 studs spaced (usually) on 16-inch centers.  To each
    edge of these vertical studs are nailed sheets of lath, over
    which plaster is applied, or to which plasterboard is nailed.
    As a result, the wall is, in effect, a drum (emphasis by author)
    Noise that imposes on one side of the wall makes it vibrate
    sympathetically and transmit the noise directly through steel
    nails and wooden studs to the other side, where the plaster
    vibrates almost like a loudspeaker.

    "To make matters worse, in a further move to save money through
    lowered labor time, the electrical outlets are installed
    back-to-back, connected by a conduit for wires which acts like
    a small sound tunnel.  Plumbing is also installed back-to-back;
    so are ventilating ducts."


Noise in the home can  be  generally  classified  into  three  sources:   those
generated by family members;  building  noises such as  fans,  blowers  and
plumbing; and those originating  outside  but penetrating into  the home.
In inner city dwellings much  noise  is  associated with plumbing, the
neighbor's music  and occasionally TV,  and/or mechanical appliances.   Few
people relish the thought of  having an auditory involvement with the
next door neighbors.  And even within  families  the  need for auditory
privacy is basic.  Space  and  privacy as  any city dweller  can  tell you
costs money.  And money,  the  typical inner city resident  does not have.

Industrial - It has not been  "proven"  that noise degrades job performance,
but most individuals would agree that  inappropriate or loud noises  are
an undesirable addition to any work environment.  In  most jobs some form
of verbal communication is necessary.  The strain of  constantly raising
one's voice is unpleasant.  In jobs where concentration or  risk is  in-
volved, noise makes the job difficult.

Noise Inside the  Factory  - The  "blue collar" worker is one  of the chief
victims of noise  pollution.  Aram Glorid states that:  "The noise source
most common to man is  industrial, and  large population studies indicate
that this is by far the most important single  cause of hearing loss."
It has been estimated  that between  6 million to 17  million  production
line workers experience noise conditions that  are hazardous to their

The study, Noise  as a  Public  Health Hazard, has shown that:  "If two
populations are considered, the  one -  the general population, and the
other - an industrially-exposed  population, the difference  in amount
of hearing loss is between 10 percent  and 30 percent  for  all  ages.  At
age 55, 22 percent of the individuals  in a non-noise  exposed  population
show significant  hearing  impairment; in  an industrial group the percentage
is 46 percent."

Studies have shown that workers  in  noisy plants (steel and  ball bearing)
have abnormally high incidences  of  cardiovascular problems  and that
there are complaints of impotence,  fatigue and insomnia.

Noise is damaging not only if it is exceptionally loud, but if it is
continuous.  The worker who is exposed to moderately  loud noises  (85  dB-A)
for eight hours a day, for years at a  time, is running considerable risk.

Noise rarely occurs in a  continuous flow; it hits peaks and lows, occurs
at a variety of frequencies,  comes  from  a variety of sources.

Tasks requiring concentration,  and  verbal communication are often
impossible, or intensely  frustrating in  a noise environment.

Noise Outside the Factory - Men using heavy equipment at construction
sites are cause for considerable concern.   Unless effective remedial
measures are undertaken, the vast majority of heavy equipment operators
of the future will  be victims of significant noise-induced hearing loss.

Industrial  noise also affects those outside  of the plant or company.
Most noise "leaks"  come through the intake and discharges for fans and
compressors, ducts  and piping running outside the building, from open
windows, from blowers and fans and from machinery noises such as punch
presses, machine tools, forging equipment, and printing presses.  Often
such noise is accompanied by air and water pollution, further increasing
the burden of the "blue collar" worker.

Physiological and Psychological Effects of Noise

Loud, unwanted sound produces deafness.  The first hearing loss  occurs
in the higher frequencies.  An individual  suffering from this sort of
deafness will notice that he cannot hear high frequency consonants such
as f, th, sh, ch, s, t, or the ringing of a telephone, or the high voices
of children.  The first effect usually is a shift in the hearing thresh-
old.  Temporary deafness and ringing in the ears function as warnings.
If the noise level  continues, hearing sensitivity will be decreased.

In addition to hearing loss, noise is linked with cardiovascular
diseases, nervous diseases and gastrointestinal problems.

Experiments have shown that levels of noise which are not loud enough
or continuous enough to produce hearing loss can still cause an  in-
voluntary constriction of the peripheral blood vessels.  Loud, un-
expected sounds can cause a variety of physiological reactions.   For
example, sudden loud noises can cause the heart to beat rapidly, the
blood vessels to constrict, the pupils to dilate, and a spasm to occur
in the esophagus and intestines.  These symptoms probably lessen con-
siderably as adaptation to the noise occurs.

Animal experiments  also show that noise tends to cause elevated  levels
of cholesterol in the blood, furthering the tendency toward constricting
the blood vessels.   Thus, the functioning of the circulatory system, as
well as the ear, is endangered.

The hardest to quantify, and yet perhaps the most important aspect of
noise, is its effect on the quality of life.  The interruption of sleep
and conversation, the strain at having to shout and listen over  the roar
of air compressors  and the pounding of jackhammers are just isolated
examples of the indignities caused by noise.

Unnecessary noise seems to be particularly provoking and has been blamed
for triggering murder, suicide and insanity.  Less dramatic and  probably
too common to document are the cases of sudden loss of temper, child
abuse, headache, sleeplessness, depression and irritability caused by the
intrusion of noise into our private lives.


The idea that people become adapted to noise is a myth.  The circulatory
system does not adapt.  Also, studies have been shown that people who
work in high noise levels during the day are more, rather than less,
susceptible to aggravation from noise after work.  The factory worker is
more apt to explode at his noisy children than the man who works in a
quiet office.

It is not generally realized that sound affects the human organism in a
variety of ways.  Not only does noise affect the ear, it also affects
the brain.  The reticular formation is located at the base of the brain.
It acts as an information alert and relay system.  We are generally not
conscious of the workings of this area of our brain; it is nevertheless,
very important to our survival.  According to Etienne Grandjean:

    "The reticular formation is somehow a central alerting or
    activating system which enables the whole organism to react
    in an adequate way to the given outworld situation.  The stim-
    ulation of the reticular formation by noise...will arouse the
    animal or human being in order to enable it to focus its atten-
    tion to the external acoustical information...Therefore, the
    ability of paying attention depends on the reticular formation.

    "Noise provokes physiological reactions over which we have no
    control:  the eyes become dilated; sweat, gastric acid and
    adrenal glands are activated; the blood vessels contract; the
    stroke beat of the heart is reduced.

    "Thus noise means 'danger1  to the most primitive pith of our
    beings.  Without any thinking being necessary, the human being
    prepares itself for danger; it gears up for imminent attack.  It
    seems like an evolutionary vestige of what would be lifesaving
    readiness from the roar of a saber-toothed tiger, a mastadon, or
    a volcano.  And the 'roar1  does not need to be so loud to arouse
    this animal reaction within us.  Most researchers agree that
    levels of only 70 dB-A can do this, while 85 dB-A certainly can.
    The trouble comes in today's modern world, where bodily re-
    sponses to noise are too many and too often.  Thus, what developed
    over millions of years as protective physiological responses now
    only serve to deteriorate the body."

A leading audiologist has indicated that when exposed to 90 dB-A of white
noise (in his volunteers), there was a change of distolic pressure, a
decrease in the stroke volume of the heart, a decrease in the blood supply
and other negative cardiovascular effects.

Sontag has done research on the effect of noise upon the reproductive
system of female rats.  His studies indicated that noise may cause:  in-
fertility, increased numbers of stillborn babies, death in infant rate,

inherited defects, malfunctioning in infants  (cleft  palate,  etc.),  earlier
sexual maturity, bleeding disorders  and congenital malformation.

Recent testimony before a state  legislative committee  on  jet noise  in
New York cited paranoid delusions, hallucinations, suicidal  and homicidal
impulses as some of the possible consequences  of continued  sleep  depri-
vation.  Even if one is not awakened by the noise, there  is  likely  to  be
a shifting of the stage of sleep. Each of the stages  is  important  to
human health, and such shifts  can be stressful.   Sleep disturbance  is
very distressing for:   the young, the old, the ill and women.   (Drs.
William Wilson and William Zung  have found that women  are three times  more
likely to be aroused from sleep  by noise than  men.)

England's Wilson Report states:   Of  all noise's effects,  repeated inter-
ference with sleep is  least to be tolerated.

Though there has been  little information on the subject of  noise  dis-
orientation, it is a worthy field of investigation.  Too  much noise
removes the audital cues which are so necessary to distinguish parts of
the environment.  Too  much noise has a jamming effect, is over stimu-
lating, and stressful.

Verno Knudsen feels that noise,  like smog, is  a slow agent  of death.   If
it continues to increase for the next 30 years, as it  has for the past 30,
it could be lethal.

Noise Burdens of the Urban Poor

When environmental burdens such  as noise are  added to  the burdens of
poverty and racial discrimination, can they cause collapse?


    Innis' son, 13, Killed in  Bronx

    "Negro accused of Shooting Boy in Dispute  over Noise
    The 13-year-old son of Roy Innis, the militant associate
    national director of the Congress of Racial Equality,
    was shot and killed last night outside a  Bronx apartment
    house a short distance from  his  mother's  home.
    The police quickly took a 49-year-old Negro man  into

    "According to the police,  the boy, Roy Innis, Jr., was
    playing with his brother,  Alexander, 12,  and two other
    boys outside 1142 Union Avenue about 7:45  p.m.   As the
    youngsters shouted, wrestled and raced in  and out  of  the
    three-story building, the police said, a  man leaned from
    his second-floor apartment and called:

    "STOP THE NOISE,  (emphasis added)
    When the boys failed to heed the warning, the police
    said, the man came downstairs with a pistol  and, as
    the boys started to run, fired a shot that struck
    young Innis in the back."

This incident tragically shows what noise can do to people already at the
breaking point.

In our cities there are many, and not just the poor, who are often driven
to distress and distraction by noise and many other urban factors.

In New York City's report, Toward A Quieter City, the medical  subcommittee
advocated noise control to alleviate psychological  distress.  They cited
calculations of a definitive study, "Mental Health  in the Metropolis,"
showing 81 percent of the population experienced mild to incapacitating
symptoms and 42 percent showing moderate to severe  symptoms.  The medical
committee concluded:  ..."a good proportion of our  population  does in-
deed experience distressing psychological conflicts, and the added upset
of preventable noise is an area, which in terms  of  prophylaxis should
be directly confronted."

The long and loud noises of the city cause hearing  loss and tension, but
the inner city is filled with another kind of noise which contributes to
incidents like the Innis tragedy.  This other kind  of noise is noise
which annoys, alarms, irritates, or upsets.  Theodore Berland  points out
that the most annoying sounds are those that are loud, high pitched, in-
appropriate to your own activities, and unexpected.

City noises often have these characteristics.  For  example:

Loud - police sirens, fire sirens, ambulance sirens.
High pitched - screeching tires.
Intermittent and irregular - the rumble and roar of passing trucks.
Produced from a hidden or moving source - movement  in the halls or rats in
                                            the  walls.
Inappropriate to your own activities - kids carousing on the street.
Unexpected - garbage cans clanking or cars backfiring at dawn.

Can such noises contribute to the high rate of hypertension among the
urban black population?

The urban poor are particularly burdened by traffic noise:

    1.  Highways are more often built through or near poor neighborhoods,
        because land values are cheaper and the  poor do not have the
        money or power to successfully oppose highway construction.

    2.  When highways are built through or near  middle class neighborhoods,
        the adjacent housing becomes less desirable and economically more
        available to the poor because of the noise  and poisonous fumes
        which are created.

The fact that traffic noise creates a particular burden for the urban
poor contains a perverse irony.   Ninety percent of the non-poor own cars
while only 30 percent of the poor do.

The inner city residents, as has been pointed out, live in the noisiest
and most crowded sections of the urban environment and do not have the
money to pay for insulated housing or privacy.   This noisy environment
may very well be interacting with other environmental  and socio-economic
factors in their lives to reinforce the cycle of poverty and dependence.
A 1967 Public Health Service study indicated that the  prevalence of
binaural hearing impairment decreased as the amount of family income
and education increased.  In fact, 55 percent of those persons with
binaural hearing loss had family incomes less than $4,000.

It has also been suggested that because of the lack of verbal stimulation
given inner city children, the noisy environment consists of essentially
random and meaningless noise.  The children learn, in  self-defense, to
screen these noises out of their attention patterns.  This means, if
true, that in the formative preschool years, many inner city children
are learning inattention on an organized basis.


On the Federal level, very little progress has been made toward alleviating
the noise problems of the inner city.  Industrial noise and aircraft
noise have been subjected to Federal scrutiny, but these are not the
primary woes of the inner city resident.  Several pieces of legislation
now before Congress offer some hope for alleviating the problem.  Among
some of the provisions being considered are labeling requirements for
noisy consumer products, the development of maximum permissible noise
levels for transportation vehicles,  Federal grants to State enforcement
agencies and provisions for citizens' suits against noise polluters.

The Environmental Protection Agency's noise control activities were authorized
by the  "Noise Pollution and Abatement Act of 1970 (Title IV of the Clean Air
Act)."  The EPA Office of Noise Abatement and Control  was established in
April  1971.

The broad mission of the new EPA unit is to identify and classify causes
and sources of noise and determine their effects on public health and welfare.
The enabling legislation calls for the preparation of a special report to the
Congress which will include information on present Federal programs; State
and local laws, regulations, and enforcement capabilities; the state-of-the-
art on  control technology, and recommendations on a long-range noise
abatement and control program.

The law also requires that, for the first time, all Federal agencies include
noise as a consideration in preparing statements describing the environmental
impacts of their various projects.  The Office of Noise Abatement and
Control has been given the responsibility for reviewing these statements
before  they are submitted to the President's Council on Environmental Quality.

Until some noise abatement legislation is passed, however, the primary
activity, or inactivity, with regard to urban noise remains the
responsibility of State and local governments.

It is currently within the purview of the States to set ambient noise
level standards, although few States have moved in this direction;
California being a notable exception.  Providing State authorities
with the necessary means of enforcement is an important but often
overlooked concern in this area.

On the local level, efforts to mitigate urban noise problems are
also few.  A notable exception is Memphis, a city in which an ordinance
against horn-honking and an anti-noise public attitude campaign have
earned it the reputation of being the quietest city in the country.

In New York, an ordinance prohibits the use of sirens by city-operated
ambulances.  Other localities restrict the operation of heavy trucks
in their cities during certain hours of the night.

Passage of any of the noise abatement bills now pending before the
Congress would give the Office of Noise Abatement and Control or
EPA's Administrator broad powers in dealing with this problem.

On the local level, adoption and enforcement of noise abatement ordinances
and regulations could make life within urban centers quieter and more
livable.  More effective land use planning, zoning ordinances, building
codes and transportation controls could ease the noise burdens of the
inner city.

1.   Berland, Theodore
    The Fight for Quiet
    Prentice Hall,  Inc.
    Englewood, Cliffs, N.  J.

2.   Glorid, Aram
    "Industrial  Noise and  the Worker"
    National Conference on Noise as a Public Health Hazard
    Washington,  D.  C.
    June, 1968

3.   IBID

4.   Shetolov, N.N., E. Grandjean, T. Berland, Samuel Rosen, et.  al.
    see "Symposium on the  Physiological  Effect of Audible Sound"
    136th Meeting of the American Association for the Advancement of
    Boston, Mass.
    Dec., 1969

5.   Berland, T.
    P. 47-56

6.   Grandjean, Etienne
    "Biological  Effects of Noise"
    Proceedings  of the 4th International Congress on Acoustics

7.   Sontag, Lester
    "Effects of Noise During  Pregnancy Upon Fetal and Subsequent
    Adult Behavior"
    Symposium on the Physiological Effects of Audible Sound
    136th Meeting of the American Association for the Advancement of Science
    Boston, Mass.

8.   Wilson, Sir Alan, et.  al
    Noise a Final Report
    (MND. 2056)
    London, England

9.   Knudsen, in Berland, See #1, P. 140


1.     Noise Legislation

The first and most pressing need of the noise program is legislative
authority in the fields of standard setting and enforcement.

The Task Force recommends as a priority action that the Administrator adopt
as a personal challenge the passage of the pending noise legislation.
EPA should continue to seek enactment of the pending noise legislation.
EPA's effectiveness in the noise abatement field depends upon the passage
of this enabling legislation.

2.   Public Education Program

For legislation to be effective, people need to know about it and support
its aims.  Without knowledge and support, legislation is likely to be
ineffectual.  This is particularly true in the noise control  field.  The
Task Force passes along a recommendation made by the New York City Task
Force on Noise which advises:

      "Educate before you legislate."  This advice was also the recom-
      mendation of a predecessor task force in New York.  In its report,
      "City Noise," dated 1930, was the statement:  "Prohibition has
      demonstrated only too well the disaster that inevitably engulfs
      those who legislate before they educate."

EPA's Office of Noise Abatement and Control is currently conducting
hearings on noise pollution in major cities to gain information on and
possible solutions to noise problems.  A bonus from these hearings has
been public education.  Additional public education efforts should be
undertaken immediately to assure the success of the legislation.

The Task Force recommends that the Administrator and key senior staff
personally deliver at least one major speech, or release a major article
to a national magazine, on a once-a-month basis for the next nine months
under the theme:  "Let's Lower The Noise in our Cities."

To further increase national awareness of the growing noise problem,
the Task Force recommends that $100,000 be^allocated to ONAC and the
Office of Public Affairs for public education efforts to disseminate" in-
formation on noise, its sources, effects, and control techniques as well
as what city residents can personally do to abate noise.

To assist city governments in their noise abatement programs, the
Task Force recommends that the Administrator convene an internal
action group of attorneys detailecTto ONAC. with a $50,000 budget for
consultants, to accelerate present efforts of ONAC to develop a model
noise control ordinance for city^governments by January 1, 1972.   TTTis
model ordinance should then be given wide distribution.  ONAC should
be given the manpower for advocating its adoption and for updating the
status report of city ordinances.

ONAC should maintain a listing of these city ordinances so that by
June 1972 a progress report can be made on the number of cities which
have adopted adequate noise control authority.  Such a progress report
could be presented at the June 1972 Stockholm Conference on the Human

3.   Voluntary Compliance Program

Voluntary compliance, the "achievement of the possible," is the
exercise of leadership, the power to persuade.  Through the public
education program, speeches, and technical trade journal articles,
EPA can carry on a campaign to encourage the manufacture of products
with "quietness" built in at the drawing board stage of production.
The design stage is the point in time when industry can most cheaply
incorporate quietness features.  In fact, at the design stage, thought
given to noise control features can result in cost savings and/or other
quality improvements.

Consumer Information - The Task Force recommends that contracts be made
to Consumers Union of U.S., Inc.  and Consumers' Research Inc. to conduct
a product noise measurement program.  The publication of their measurements
in magazines widely read by consumers would create a gentle but persistent
encouragement for product designers to incorporate quietness as a feature
of their products.

The Task Force specifically recommends these two organizations because
no other organizations would create as effective encouragement.  The
amount of the grants has been estimated at $100,000 to each group to
enable each to adequately equip for the task.  Emphasis should be
placed on measurement of auto, truck, motorcycle and tire noise.   This
recommendation ought not to be delayed for lack of agreement on protocols
for measurement.  Allowing the grant recipient freedom to choose his own
protocol will engender a healthy competition on ways for both measuring
and designing quieter products.  Also such grants will provide valuable
information to ONAC on products and act as a pilot program in noise

ONAC ought to be given the resources to monitor the progress of
the voluntary compliance program.  As quieter products are voluntarily
developed, ONAC should be in a position to document the veracity of the
improvements and to publish an annual list of these new products.  Such
actions could avoid repeats of the fate of the "quiet garbage can."
A quiet container was developed and marketed at a premium cost of $1.50
per can.  Lack of individual interest and lack of a mandated market
caused it to be withdrawn from the market.

Historically, voluntary compliance through agreements with industry
has been a highly cost effective and relatively painless mechanism of
progress.  In the pollution control field, outstanding precedents are:
(1) The voluntary agreement with the automobile industry to install
crankcase emission control on 1962 and later model automobiles.  This
was achieved by HEW Secretary Abraham Ribicoff when Federal emission
standard setting authority was non-existent.  (2) More recently a voluntary
agreement was reached with the airline industry to install smokeless
combustors on all medium-long range aircraft by the end of 1972.  These
smokeless combustors are estimated to reduce particulate emission by
70 percent, carbon monoxide emissions by 20 percent and hydrocarbon
emissions by 50 percent.  This agreement was achieved by HEW Secretary
Robert Finch.  (3) Recently, EPA effected a voluntary agreement with
detergent manufacturers to discontinue the use of NTA in their products.
The Task Force recommends that the voluntary compliance approach be
utilized vigorously in noise abatement since it can result in significant
achievements at relatively low cost to the industry, the government, and
the consumer.

The Task Force finds that the number of motorcycles in use is growing
at an alarming rate.  Their associated noise levels are terrifying.
ONAC already has substantial information on motorcycle  noise and
possible noise control levels on which to base an agreement with
motorcycle manufacturers.  The Task Force therefore recommends that
efforts be made to obtain a Government-industry voluntary agreement
by June 1972 on noise levels of new motorcycles.

The Task Force finds that trucks are major sources of noise in the
inner city areas.  The Task Force recommends that efforts be made by
ONAC and the Office of Voluntary Compliance to obtain a voluntary
agreement by October 1972 with truck manufacturers to begin building
quieter trucks.

To assure that both the schedules for voluntary compliance and the
degrees of noise reduction are as progressive as  possible, and to
avoid criticism that they are not; the Task Force recommends that the
Administrator's Urban Advisory Council be involved in negotiating
voluntary agreements.


One other tool that the Administrator should use to encourage voluntary
compliance is to staff ONAC with a coordinator to work with GSA and DOD to
insure that all future procurement of vehicles and noise-producing equip-
ment conform with the lowest possible noise production characteristics.
The Task Force recommends that the Administrator provide ONAC with resources
to immediately hire two professionals to carry out this function.

4.  Noise Abatement Program Under Existing Authority

Under the Noise Pollution and Abatement Act of 1970, the Administrator is
given the authority to review the present activities of Federal agencies
which he believes amount to a public nuisance or are otherwise objection-
able.  Furthermore, the National Environmental Policy Act, and Section
309(a) of the Clean Air Amendments oblige the Administrator to review
and comment on the proposed actions of Federal agencies which may cause
noise pollution.  This authority carries with the responsibility and
obligation to achieve results.

One of the most important sources of noise pollution for the inner city
is freeway traffic.  The DOT is funding highway construction projects
in most, if not all, of our major cities.  Through conscientious review
of environmental impact statements, EPA ought to be able to reduce the
noise impact of these projects on urban areas.  EPA, by strongly recommending
the incorporation of noise control features into the design of urban high-
way projects, can and should become an effective advocate for the protection
of the inner city environment.

Aggressive review and comment may be time-consuming and difficult, but
it is absolutely imperative if we are to carry out our obligation to the
urban poor.  (Such a review is also imperative from an air pollution
point of view.)  The Task Force recommends that the Administrator organize
and staff an urban highway impact review unit within either ONAC or the
Federal Activities Office to carry out this obligation.  At least five
people should be immediately assigned to carry out this function.

Aircraft noise is a particularly severe problem for millions of urban
Americans living in the vicinity of airport takeoff and landing routes.
Areas where the problem is particularly severe are likely to house low
income or urban poor residents.  EPA can do something to help.  The FAA
periodically authorizes changes in approved takeoff and landing routes,
patterns and procedures.  STARs, as they are called for Standard Takeoff
and Arrival Routes, should be preceded by draft environmental  impact state-
ments and reviewed and commented upon in such a manner as to advance the
public interest of the urban poor.  The Task Force recommends  that EPA
press for a decision from CEQ to requTre environmental impact  statements
from  FAA and STARs.  At least one attorney, with assistance, should
be given full-time responsibility for review and comment Q" aTl
actions of the FAA having environmental impact, including STARs".  His


function would be to advocate procedures, routes, anc         <-,
can be taken by the FAA to protect the urban populatic.

One last source of noise that EPA can attack through Ntl'A is radio and
TV noise.  EPA can request the FCC to encourage producers of radios and
TVs to limit the maximum volume of sets to, let's say, 75 dB-A (equivalent
to the noise of a freight train at 50 feet).  This would be similar to
and simpler than the requirement that all TVs be equipped for both UHF
and VHF reception.

Similarly, the FCC could be encouraged to require that stations fre-
quently urge viewers and listeners to lower the volume of their sets
after 10:00 p.m.  The FCC also could require commercials to be broadcast
at the same volume as the regular programs.  At present, many commer-
cials are much louder than t" "» interrupted program.

In short, EPA should take on an advocate role in protecting the environ-
ment through voluntary actions, the vigorous exercise of its authority,
and leadership.

Vigorous implementation of NEPA can be a mechanism for alleviating the
environmental noise burdens of the urban poor.  EPA has not yet won any
major battles for the poor with this weapon.  If the Administrator charges
EPA with both its mandate and the need of the people, many victories
probably could be won between now and June 1972.

5.  ONAC Staff Increase

The Task Force finds that the Office of Noise Abatement and Control is in-
adequately staffed.  "Inadequate" is an understatement since a total of
25 people, part and full-time, cannot carry out a national noise control
program responsive to the nation's needs.  As an interim, but immediate
measure, the Task Force recommends that the Administrator exercise his
managerial prerogatives to permit ONAC to hire at least 35 additional
people by December 1, 1971, to carry out present requirements and the
additional requirements envisioned in this report.

6.  National Noise Monitoring Program

The Office of Noise Abatement and Control should be allocated sufficient
funds and manpower to conduct a noise monitoring program in our major
cities.  This monitoring activity is necessary in order that the efficiency
and effectiveness of EPA's noise control efforts can be maximized.

An estimate has been received by the Task Force that a staff of 10 to 15
subprofessionals and one professional audio!ogist would be required for a
noise monitoring program in ten cities.  Funds for equipment and personnel
should amount to about $175,000 per city.  Such a program should be imple-
mented immediately in Demonstration City and the rest implemented upon
passage of the legislation.

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          Pesticides in an Urban Context

               The Misuse of Pesticides
               Many Application Methods
               Lack of Usage Data
          Pesticides and Their Effects on People

               Ethnic Differences
               Routes of Entry
               Sex Differences
               Age Differences
          Pesticides and the Urban Poor

               Poverty, Pests, and Pesticides
               Poor Housing and Pesticides
               Poor Education and Pesticides
               Poor Work and Pesticides
               Poor Children and Pesticides
               Poor Diet and Pesticides
               Public Education Program - Short Range
               Public Education Program - Long Range
               Improved Labeling Program - Short Range
               Improved Labeling Program - Long Range
               Pesticides Research Recommendations - Long Range



Pesticides in an Urban Context

The term "pesticide" refers to a wide variety of chemical  substances  or
mixtures of substances intended for preventing,  destroying,  repelling,
or mitigating any insects, rodents, nematodes, fungi,  weeds, and  other
forms of plant or animal  life which are considered by  man  to be  "pests,"
i.e., inimical to human interests.

It has been reported that there are currently some 900 active pesticide
chemicals formulated into over 60,000 preparations in  the  United  States.
In 1969, production and sales of synthetic organic pesticides was on
the order of 1.1 billion pounds, of which about 20% was exported.  Slight-
ly more than half of all  pesticides produced are used  in farming.  (About
45% is actually used on crops.)  Government agencies use about 5%; resi-
dential and industrial users account for the rest.  In light of these
figures, it is little wonder that the use of pesticides for  domestic
purposes has become commonplace.  And as Dr. Norman E. Dyer, toxicologist
in EPA's Dallas office, reported to the Task Force, "Pesticides  are sold
under many trade names which may tend to confuse the average consumer.

The very existence of these slightly active compounds  poses  potential
and often real problems.

The Misuse of Pesticides - Accompanying the increased  application of
household pesticides is an increased danger of misuse, accidental poisoning
and increased contamination of the home environment.  Homeowners  are
seldom acquainted with the scientific rationale of safe application and
frequently fail to read and heed the instructions contained  on the label.
Thus, problems of overuse and misapplication of pesticides have reached
the point where contamination by household pesticides  may constitute a
significant proportion of the total population exposure.  One report also
advises that while household sprays may be convenient to use, and may
satisfy certain hostile impulses, that their use rarely reduces insect
infestation.  Baits and repellents are recommended as  being far more
effective, and safer.

Many Application Methods - Of special concern is the development of a
large number of pesticide-dispensing devices intended to simplify the
reduction of pests in the household.  Shelf paper impregnated with pesti-
cides and evaporators (e.g., "no pest" strips, pellet vaporizers, etc.)
intended  to produce an insecticide aerosol for insect control are examples
of potentially hazardous installations in poorly ventilated areas.

Lack of Usage Data -  There is  a paucity of information  available con-
cerning the type and  quantity  of pesticides used for domestic purposes
in the United States.  Odd as  it may seem, no nationwide figures are
collected routinely on the use of pesticide chemicals;  this is true
regardless of whether the use  be agricultural, institutional, or domestic.
United States domestic pesticide sales were reported by the USDA to total
$1.7 billion for 1969 (latest  sales figure available).   Of this figure,
approximately $1.2 billion was expended for agricultural  use; $255 million
for industrial,  institutional, and government use;  and  $255 million for
household, lawn, and  garden use.

Usage Patterns Vary - Where information on the domestic uses of pesti-
cides is available, usage patterns are found to vary widely.  A case in
point would be reports from the Community Studies Pesticides Projects in
Utah and Arizona for  1968.  These reports indicated that domestic usage
of pesticides in Salt Lake County, Utah, accounted  for  approximately 50%
of the pesticide usage in that County, whereas in the State of Arizona
study domestic usage  accounted for only about 0.6%  of the total.

Pesticides and Their  Effects on People

Disease - In one study by W. B. Deichman and J. L.  Radomski autopsied
tissues from persons  succumbing to chronic disease  suggested a relation-
ship between elevated pesticide concentrations in adipose tissue in cases
of liver cirrhosis, carcinoma, and hypertension.  However, there is some
question regarding these findings, since there was  a great variability
in pesticide concentrations found, and the results  were complicated by
the diverse backgrounds of the deceased and by the  ravages of disease
and death.

Another study by B. P. Weiner and R. M. Worth, conducted in Hawaii,
suggests a causal relationship between frequent use of household insecti-
cide aerosol sprays and increased prevalence of respiratory impairments,
such as asthma,  chronic bronchitis, and sinusitis.   However, the report
cautions that testing for causal effects of specific components of the
sprays (e.g., active ingredients, petroleum distillates, etc.) by inhalant
challenge to volunteers is necessary before a precise association, if any,
can be delineated.

Ethnic Differences -  There have been numerous studies of pesticide
residues in human tissue and blood.  The general consensus from such
reports is reflected by data from epidemiological studies in Florida
which indicate that there are race-associated differences (Negro more
than Caucasian)  with  respect to storage of DDT and  its  derivatives
(W. F. Edmundson, "Dieldrin Storage Levels in Necropsy Adipose Tissue,"
Pesticide Monthly Journal. Vol. 2, 1968) (J. F.. Davies, "An Epidemiological
Application of the Study of the DDT Levels in the Whole Blood," Amer.
Journal of Public Health, Vol. 59, 1969), but no such race-associated
differences for another persistent pesticide.


The explanation for this  association  of greater fat and  blood  levels  of
DDT-derived materials  with  the Negro  race  in  the United  States  is  not
readily apparent.   However, the most  plausible  explanation  would attri-
bute this to socioeconomic  factors  and  would  incriminate such  aspects
as poor housing, inadequate garbage collection, deficient window screen-
ing, etc., all  tending to further the problems  of pest control  and the
need for greater domestic use of insecticides.

Routes of Entry -  Pesticides may gain entrance  to the  body  through the
intestine subsequent to ingestion;  through the  lungs as  a result of in-
halation of air-borne  pesticide-laden dusts,  vapors and  aerosols;  by
penetration through the intact skin;  and by absorption directly into
the bloodstream through the broken  skin.

The relative importance of  these pathways  varies to a  large extent,
according to the population group under consideration.  In  the general
population, ingestion  of residues remaining on  foods is  probably the
major route by which pesticides enter the  body.  Inhalation may be a
factor, particularly in lower income  households, where "bug-bombs" are
used in the effort to  control cockroaches  and other pests.   Percutaneous
absorption also may be a significant  route of entry among members  of the
urban poor population.

Sex Differences -  Insofar as tissue residues  of pesticides  are con-
cerned, some investigators  have reported a significant association of
residues with sex, others have failed to find any differences, and still
others find sex differences but only  in the Negro race.   The apparent
discrepancies in the reported data  are  attributed to a small sample size;
in the largest survey available, which  was conducted by  the Human
Monitoring Program, no differences  due  to  sex were observed.

Age Differences -  Data from the Human Monitoring Program Report, and
elsewhere, indicate a positive age  association  for DDT and  its residues,
including DDE.   The body burden of DDT  increases as age  increases.

Pesticides and the Urban Poor

The urban poor live in a hostile environment where, daily,  they are
subjected to conditions of  substandard  housing, improper sanitation,
inadequate garbage collection, pests  and their associated diseases.
Pesticides are used by many of these  residents  to combat rodents,  roaches,
and other vermin which invade their homes  and bring discomfort and illness.

Poverty^Pests, and Pesticides - Pesticide-usage patterns vary considerably.
A pesticide use survey by J. E. Keil  (Agricultural Chemistry,  August,
1969) of urban households in Charleston, South  Carolina, contrasted the
use of household pesticides by middle-class white families  with that of
non-white families (mainly  Negro) of the lower socioeconomic level.  This

survey indicated that whereas 83% of the white families  sampled used
pesticides in their home, 97% of the non-white families  employed house-
hold chemicals for pest control.  The prime concern of non-white families
appeared to be common household insects (roaches, mosquitoes,  flies),
whereas whites were more frequently concerned with gnats,  termites,
fleas, weeds and mold.  Both ethnic groups seemed equally  plagued by
ants and rodents.  Accordingly, non-white families applied pesticides
inside their homes more intensely than did whites, and yard and garden
applications were found principally among whites.

At the same time, it was also indicated that private pest  control
operators were utilized by 51% of white families as compared to only
28% of non-white families.

Grocery stores were the usual source of household pesticides for both
races.  Places of pesticide purchase differed little between the races,
except that whites patronized feed and seed stores more  frequently,
probably a reflection of a greater interest in ornamental  plants and

Both white and non-white families commonly ignored common-sense safety
precautions in the use of household chemicals.  Locked storage was not
employed by 88% of all families; 66% stored the pesticides within easy
reach of small children; 54% stored the chemicals near food or medicine;
and 66% never wore protective gloves during use or washed  their hands
after the application.

Poor Housing and Pesticides - Dr. Norman Dyer portrays the pesticide
plight of the poor.Substandard housing denotes dilapidated residential
homes in deteriorated neighborhoods, located in the inner  city.  Most
of these homes and/or apartments are owned by suburban landlords.  They
are in deplorable conditions, with holes in the screens  of windows and
doors or no screens at all, and cracks in floors and walls.  The appalling
situation results in an invasion of the premises by all  kinds  of pests,
including flies, ants, mosquitoes, roaches, rats and scorpions; sub-
jecting the residents to a greater exposure to disease-carrying organisms
or to continuous exposure to pesticides as they attempt  to eradicate
their unwanted house guests.  But the battle is futile,  because of the
housing condition, and the prevailing unsanitary local environment which
is due to infrequent and improper garbage disposal, resulting  in breeding
grounds for rats and flies, and inadequate drainage which  produces
stagnant ditches of water, creating hatcheries for mosquitoes.

Many times in an effort to counteract these unsanitary environmental
conditions, the cities may resort to frequent fogging operations which
cause more pesticidal exposure to the residents.


Poor Education and Pesticides - In general,  the urban poor are less  able
to choose the proper pesticide for the type  of pest involved because of
the lower educational levels.  Consequently, chemicals are applied which
are ineffective in eradicating the pest, resulting in an  increase  of
the pesticidal insult to their health without an accompanying decrease
in the vermin problem to which the pesticide is directed.

Additionally, there is extensive disregard  for safety in  the application
of these chemicals in and around the homes,  which is exemplified in  the
spraying and/or storage near food and sleeping infants.   The defying of
instructions is typified by the old adage,  "if a little is good, a lot
is better."  (The Task Force heard another  terrifying description  of
this typical reaction of the poorly educated:  While profusely spraying
a room, a mother began feeling dizzy.  She  stopped.  Her  reaction  then
was that the stuff must be good and, with enthusiastic determination,
began spraying again.)

Poor Children and Pesticides - The proper disposal of various types  of
"empty" pesticide containers presents yet another health  problem to  the
urban poor.  These discarded containers constitute a potential health
hazard, mainly to childen.  These so-called  "empty" containers are never
completely empty.  Several fatal poisoning  cases have been reported  in
the literature as a result.

Poisoning by pesticides occurs predominantly in children.   The facts are
that death of an estimated 200 people in the United States last year
along was attributed to pesticides and more  than 5,000 people in the
United States have been involved in nonlethal poisoning due to pesticides
since records have been kept.  Information  on chronic effects on humans
is not generally available.  It has been found that 15.2% of the total
cases in persons 10 years of age or older were in non-whites, and an
additional 13.6% were in persons with distinctly Spanish  names.  These
percentages are higher than the corresponding percentages of these
ethnic groups in the general population.

Poor Diet and Pesticides - The urban poor are not as cognizant of the
importance of sanitary measures to remove residual pesticides from fruits
and vegetables, which contributes to their  greater pesticide exposure.

Concomitantly, as a result of the economic  status of this large segment
of our population, the purchase of lower grade food products is the  rule
rather than the exception,  resulting in consumption of more fatty foods,
which contain the greater concentration of  pesticides, again compounding
their pesticide exposure.

In addition, the purchase of non-graded meats, eggs and other food products,
direct from small farmers or through small  businesses whose batches  have
not been subjected to FDA pesticide tolerances and regulations, results in
more exposure.

In alliance with these observations,  malnourished children are  more
apt to "chew" on window sills which may be heavily laden  with pesticides.

The tolerances set from animal studies and extrapolated for humans is
based on healthy, well-fed individuals; as health conditions decrease,
the toxic effect is enhanced.  Another avenue of increased toxicity  occurs
when stored pesticides are released from the adipose tissue as  a  result of

It is the expressed opinion of the author and others that the preceding
propositions represent some of the contributory causes  for the  greater
incidence of prenatal  and infant deaths, chronic illnesses, shortened
life expectancies and, in general, the degraded quality of life existing
in the communities of the urban poor.  Yet, they are the  least  able  to
pay for medical care;  consequently, they are the last to  seek it, which
results in the existence of chronic morbidity.

Furthermore, the efficacy of many drugs is reduced when treating  persons
heavily exposed to pesticides due to  a decrease in drug half-life
resulting from an increase in drug-metabolizing enzyme  activity.


                           (Jo  Problem Section)
 1.   Report of the Secretary's  Commission  on  Pesticides and Their
     Relationship  to  Environmental  Health  (1969),  ("Mrak"  Report).

 2.   The  Pesticide Review,  1970.

 3.   Environmental  Quality,  First Annual Report  (1970).

 4.   USDA Bulletin, "Pesticide  Uses  in  Wisconsin"  (1971).

 5.   Utah Community Studies  Pesticide  Project:   Annual Report.
     Division of Community  Studies,  Food and  Drug  Administration, 1968.

 6.   Arizona Community Studies  Pesticide Project:   Unpublished Data.
     Division of Community  Studies,  Food and  Drug  Administration, 1969.

 7.   Deichmann, W.  B., and  Radomski, J. L.,  "Retention of  Pesticides
     in Human Adipose Tissue—Preliminary  Report," Indus.  Ned. Surg.
     Vol. 37, (1968).

 8.   Weiner, B. P., and Worth,  R. M.,  "Insecticides:  Household  Use
     and  Respiratory  Impairment," Hawaii Med.  J.,  28:283  (1969).

 9.   Davies, J. E., et al.,  "An Epidemiologic Application  of  the Study
     of DDT Levels in Whole  Blood,"  Am. J.  Pub.  Hlth. 59_:435  (1969).

10.   Edmundson, W.  F., et  al.,  "Dieldrin Storage Levels in Necropsy
     Adipose Tissue From a  South  Florida Population," Pest. Hon. J.
     2;86 (1968).

11.   Campbell, J.  E., et al.,  "Insecticide Residues in the Human Diet,"
     Arch.  Environ. Hlth.  10:831  (1965).

12.   Yobs, A., Human  Monitoring Program, 1969.   Unpublished Report.

13.   Keil, J. E.,  et al.,  "A Pesticide Use Survey  of Urban Households,"
     Ag.  Chem., (Aug.  1969); Finklea,  J. F.,  et  al.,  "Pesticide  and
     Pesticide Hazards in  Urban Households,"  J.  So. Car.  Med. Assn.
     65:31 (1969).



         1.   Research  and  Monitoring  Activities

         The  pesticides  research program  comprises studies on the causes,
         sources,  transport,  fate,  and  effects of pesticides on man,
         plants,  animals,  and the  general  environment.   The results of
         these studies provide  the  scientific basis  for  setting safe
         tolerance levels  and for  determining pesticide  use policy.  The
         program  also  includes  specific studies to verify the toxicity
         of new pesticide  products  and  provide the bases for reviewing
         and  approving or  disapproving  applications  for  pesticide label

         In FY 1971, the program of research  included  investigations on
         the  physiological  effects  and  metabolism of pesticides, the
         measurement of  pesticide  residues  in humans and various animals
         and  plants, and special analyses  and studies  to support court
         actions.   For FY  1972, studies on  the toxicity  and other effects
         of pesticides will be  expanded.   A large portion of the in-
         creased  resources  will support activities to  be carried out at
         the  National  Center  for Toxicological Research  currently being
         jointly  established  by the Food  and  Drug Administration and EPA
         at the Pine Bluff  Arsenal  facilities in Pine  Bluff, Arkansas.
         The  work  to be  carried out at  the  Center will encompass the
         development of  tests to be performed by the pesticide industry
         in evaluating its  products,  basic  toxicological research, eco-
         logical  research  on  the fate and  effects of pesticides, and
         comparative epidemiological  research to relate  the effects of
         pesticides on test animals to  the  effects on  man.  Additionally,
         in order  to support  and strengthen the pesticide label-registration
         program,  studies will be  carried  out on improved methods of
         testing  the effects  of pesticides  and residues  on food, feed,
         crops, soil,  water,  and air.

         Activities in the  pesticides monitoring program include:

             the  development  of monitoring  technology.

             the  collection of environmental  quality data and
             information on sources of  pesticide pollution.

             network monitoring (e.g.,  soil,  estuarine,  human)
             and  special studies to assess  amounts and types of
             pesticide residues in  the  environment.


2.  Regulatory Activities.

    Pesticide regulatory activities  include:

        the review of pesticide formulations  for efficacy
        and hazard.

        the establishment of tolerance levels or exemptions
        for pesticides residues which  occur in or on  food,
        feedstuff, or raw agricultural produce to be  marketed
        via interstate commerce.

        the registration of pesticides for use.

        the regulation of sale or use  patterns when necessary.

        checking for compliance with label provisions.

        surveillance by field inspectors,  and market  sur-
        veillance of both domestic and imported products.

    Enforcement activities include:

        the issuance of citations.

        compliance procedures, either through the voluntary
        or mandatory recall and removal of the product  by
        the manufacturer, or through seizure  of the product
        by EPA.

        initiation of cancellation or suspension proceedings.

3.  Grant and Contract Activities

Grant activities are confined to research  on  pesticides, or  a  re-
lated research area such as alternatives to the use of  chemical
pesticides.  The areas of research encompassed by the FY 72  pesti-
cides research grants program include:  ecological,  chemical,
microbial, physiological, biochemical, and toxicological.

Contract activities are exemplified by the community  studies program.
This program produces epidemiological  information on  the effects of
pesticides on human health.  Both long- and short-term  clinical  and
sub-clinical studies are conducted.   Currently, the  community  studies
program is being conducted primarily through contracts  with  14 uni-
versities and state health departments; additionally, intramural
research is conducted to supplement the contract work.

    A more detailed description  of the community studies  program may
    be found in the Appendix,  Section  IV.

    4.  Other Activities

    Technical Assistance

    EPA provides technical  assistance  to other Federal,  State,  and
    local  agencies  for the  control  of  pesticide pollution.   Such
    assistance includes field  investigations and special  studies,
    many of which are joint endeavors, and technical  advice and
    consultation to develop solutions  for complex pollution problems.
    It also encompasses provisions  of  laboratory services.   In
    addition, in-house training  programs are conducted in field
    facilities for personnel of  Federal, State, and local govern-
    ments, and industry and educational  institutions.


    1.  Research and Monitoring

        (a)  Title:  Human  Exposure            Code No.:   510101

        The ultimate objective of this research is to provide data
        necessary for the intelligent  assessment of the  hazard  to
        human health of exposure to single pesticides, combinations
        of pesticides and pesticides in  combination with  other  en-
        vironmental factors.   The studies  will  be concerned with
        the identification  of  pesticide  metabolites and  the effects
        of the parent pesticides and their metabolites on normal
        biological  functions,  including  the function of  the primate
        nervous system.

        And, to study the teratological  effects of environmental
        pollutants  with special  emphasis on pesticides.   This
        project will methodically test environmental  pollutants,
        first singularly  and then in combination, and establish
        dose response data  to  allow an appropriate extrapolation
        of human risk.

        To develop, evaluate and improve techniques and  chemical
        methods for direct  and indirect  measurement of exposure
        of persons  to pesticides under field use conditions and
        correlate with toxic effects;  to be carried out  in  specific
        exposure situations such as in the home or garden,  at or
        near pesticide applications in the field, in specific work
        areas of pesticide-formulating plants,  and in various other
        areas where pesticides may contaminate man and his  environ-
        ment.  Determine  how such exposure of man and contamination
        of his environment  can be reduced.


(b)  Title:  Animal Well-Being            Code No.:  510102

The objectives of this project are to determine the effect
of pesticides and related chemicals on aquatic organisms
and to study the effect on organisms of the interactions
of more than one pesticide or a pesticide and a heavy metal
under several environmental conditions; to determine tolerance
levels for pesticides and effects of sublethal concentrations
in aquatic ecosystems.

(c)  Title:  Residue Toxicology           Code No.:  510201

This is an activity to evaluate the acute and subacute
toxicity of pesticides by different routes and various
dosage levels and combinations to determine safe levels
of exposure in laboratory animals and thus obtain data that
will be useful in ultimately establishing possible safe
levels of exposure for man.

The toxicity of at least six pesticides will be studied
per year in laboratory animals (principally rats).  This
will include the determination of 1-dose 1059 values for
pesticides by the oral and dermal routes, 90-dose oral
LDcQ values, and determination of the effect of these di-
ets, or when given to female rats by injection during

Determine what chemical changes are taking place and
factors responsible for such changes of pesticides or
combination of pesticides producing increased toxic hazard
or allergic reactions in workers who come in direct contact
with pesticides or with residues on foliage or other
surfaces in the environment.  Determine hazard of pesticide
spillage during transportation and storage and evaluate
techniques and methods for determining hazard and for
decontaminating surfaces.

(d)  Title:  Residue Profiles            Code No.:  510302

To determine levels, trends and other characteristics of
pesticides, heavy metal and other related materials (1) in
soils of major land use areas and major urban areas in the
United States, in crops grown on these soils and other re-
lated environmental components; (2) in the ambient atmos-
phere, and (3) in the major estuaries in the United States.
 (e)  Title:  Product Identification     Code No.:  510402

 To develop multiresidue methods for determining the extent
 of human and animal exposure to persistent and biodegradable


    pesticides and to develop,  evaluate,  and apply various
    instrumental  techniques  to  a program  of basic  and  applied
    pesticide chemical  research.

         (1)   Elucidation of the mechanism of action
         of pesticides  and their metabolic products;

         (2)   Development of a  methodology and capability
         for the  isolation,  detection,  identification,
         confirmation,  and quantitation of pesticide
         residues, metabolites, and other chemical  con-

2.  Regulatory

    (a)  Title:   Products Registration       Code No.:   521A01

    Conduct timely and  sound handling of  matters requiring
    scientific review.   The  registration  or re-registration
    of the pesticides product,  the clearance of the suggested
    labeling, and the establishment of  a  tolerance or  an
    exemption when residues  on  food may be involved.

    (b)  Title:   Tolerance Petition Review  Code No.:   521A02

    Since the processing of a tolerance petition requires a
    thorough scientific review  of the supporting data  provided
    by the petitioner within the specified time limit, the
    basic objectives of this project are  to complete a com-
    prehensive and scientific review and  to meet those deadlines.

    The immediate objective  is  to reduce  the processing time
    of new petitions and amendments and supplements to 90
    days and to eliminate the backlog of  petitions in  review
    status beyond the statutory time limit.

    (c)  Title:   Market Surveillance       Code No.:   521501

    The market surveillance  program involves:

         (1)  surveillance of domestic market and sample collection.
         (2)  examination of imports.
         (3)  monitoring of recalls.
         (4)  monitoring of temporary permits.
         (5)  monitoring of pesticide use  patterns.
         (6)  inspection of factories, books, and records.


    (d).  Title:   Sample Analysis              Code No.:   521502

    General  objectives are to:   test and report  surveillance
    product  samples  on a current  basis;  to  develop new  or
    improved test methods; and  to re-examine methodology
    related  to renewal registrations.

    (e)  Title:   Monitoring of  Accidents     Code No.:   510501
                 and Other Incidents

    Insure there is  a reporting system which will give  90
    percent  assurance of incidents and accidents involving
    pesticides and other related  chemicals  being reported;
    and provide for an investigational program incorporating
    Federal, State,  and local governmental  agencies that will
    insure prompt and Affective remedial action.

    (f)  Title:   Case Preparation            Code No.:   521503

    FY 1972  - Evaluate an estimated 8,000 pesticide samples.
    Prepare  about 2,000 initial enforcement actions.
    Redesign the system and procedures for handling review actions.
    Initiate criminal actions against an estimated 20 companies.
    Complete recruitment and training schedule for implementation
      of FEPCA of 1971.

3.  Grants and Contracts

    (a)  Title:   Pesticide Exposure,         Code No.:   510301
                 Health Effects

    General  objectives are to determine  in  14 study areas the
    levels of selected pesticides in human tissues, and in
    environmental media such as food, water, air and soil; to
    study the effects of pesticides upon the health status of
    a group of subjects selected for their known frequent
    contact  with these chemicals; to determine the types
    of pesticides to which the  human population  within  the 14
    study areas are exposed, the ecologic factors which may
    effect their health status  and to undertake  such special
    studies  as may be necessary to provide specific information
    on individual chemicals or  attendant problems.

4.  Other

    (a)  Technical Assistance

         (1)  Title:  Intrastate Pollution   Code No.:   530202

         Assist States in insuring uniform application  of
         registered uses of pesticides and provide routine
         surveillance of control  programs.

     Conduct regional  workshops  on regulatory  problems
     and future manpower development for regional,  state,
     and local  officials.

     (2)  Title:  Intrastate Pollution     Code No.:   530202

     Technical  assistance is given at State  and local
     levels  to  improve legislation and  regulations;  develop
     control programs; promote accident reporting;  advise
     on disposal of pesticide wastes and containers; assist
     with plant safety practices;  advise on  scientific  and
     technical  skills  development  and provide  a focal point
     for latest Federal  regulations and scientific  informa-

     (3)  Title:  Special  Skills          Code No.:   530602

     To develop technical  competence at regional, State,
     and local  operating levels  and in  regional and  state
     product analysis  laboratories; to  have  standardized
     pesticide  residue methodology.

     Provide consultative services to State  pesticide
     control agencies; assist State officials  in planning
     for and providing training; and provide formal
     resident courses.

     (4)  Title:  Training Pesticide     Code  No.:   521B03

     General objective is  to have  uniform training  programs
     for pesticide applicators functioning in  all fifty
     States  by  1977.

(b)   Technical  Information

     (1)  Title:  Intergovernmental     Code No.:   530301

     To collect, store,  and disseminate information  on
     all aspects of pesticides available within Pesticides
     Programs,  other EPA programs, and  from  other agencies
     and scientific users, as well as to the general public.


The Table below indicates the allocation of funds, in functional
terms, for pesticides in FY 71  and FY 72.
   	Activity                 FY 1971                FY 1972

   Abatement and Control         $  11,167,000         $  13,629,000
   Research, Development,
       and Demonstration*           5,031,000             7,846,000
   Manpower Development         	-0-             	-0-

            TOTAL               $  16,198,000         $  21,475,000

    includes the Grants  Program (FY 71  = $783,000; FY 72 = same)


    1.  Department of the Interior (Bureau of Sports Fisheries
                                      and Wildlife)

        (a)  Research and Monitoring

        Conducts substantial  research and monitoring activities
        pertaining to pesticides on both fish and wildlife.

            (1)  Fisheries Services

            Conducts research studies concerned with, and antici-
            patory to, the requirements  for information necessary
            to the management of this natural resource; does not
            conduct studies relating to  pollution abatement.  The
            Fisheries Service budget for pesticides-related research:

            FY 71 = $730,000 and FY 72 = $730,000.

            Also maintains a nationwide  monitoring system, some of
            it on a contract basis, for sampling representative
            fish species  for a continuous assessment of pesticide
            residues in marine species.   The total budget for this
            type activity:

            FY 71 = $216,000 and FY 72 - $266,000.


        (2)  Wildlife Services

        Basic objective of pesticides wildlife research
        studies is to assess the hazard of pesticides upon
        natural populations.  The Wildlife Services budget
        for pesticide-related research:

        FY 71 = $1,747,000 and FY 72 = $1,817,000.

        Monitoring activities are diverse:  protect wild-
        life by forecasting hazard; monitor for tissue
        residues; render technical  assistance, as  needed.
        The total budget for the monitoring program:

        FY 71 = $132,000 and FY 72  = $182,000.

    (b) Regulatory

    None;  function transferred to EPA.

    (c) Grants and Contracts

    A small percentage of the monitoring budget for both the
    Fisheries and Wildlife Services is allocated for contract

    Fisheries Services, FY 71 = $26,000 and FY 72  = $50,000.
    Wildlife Services, FY 71 = $10,000 and FY 72 =  $10,000.

2.   Department of Agriculture (Agricultural  Research Service;
                                 Forestry Service)

    The USDA has extensive programs on pesticides  and related
    activities (e.g., pest control, biological alternatives,
    etc.); these programs include research and monitoring,
    regulatory, and grant and contract activities.   The objec-
    tives  of these USDA programs are:

        to gain knowledge of the taxonomy, biology, ecology,
        physiology, pathology, metabolism, and nutrition of
        pests and host plants and animals.

        to improve and develop means of controlling pests
        by nonpesticidal  methods.

        to develop safer and more effective pesticide use
        patterns, formulations, and methods  of application;
        and improved methods for detecting,  measuring,  and
        eliminating or minimizing pesticide residues  in plants,
        animals, and their products, and in other  parts of
        the environment.

        to  study  the  toxicity, pathology, and metabolism of
        pesticides  and  investigate levels, effect, and fate
        of  their  residues  in plants, animals, and their
        products, and in other parts of the environment.

        to  study  economic  aspects of pest control and its
        impact  on the environment; determine the supply, re-
        quirements  and  use of pesticides; and give assistance
        to  control  agencies and  industries in emergencies.

        to  control  pests and protect the environment during
        and after control  operations.

        to  monitor  the  presence  and distribution of pesticides
        in  plants,  animals, and  their  products, and in other
        parts of  the  environment.

        to  provide  guidelines for the  safe and effective use
        of  properly labeled pesticides.

        to  educate  and  inform the public about the importance
        of  pesticides and  pest control, and the need for safe
        and proper  use  of  pesticides;  coordinate and review
        pesticide and pesticide-related activities of the
        U.  S. Department of Agriculture and coordinate them
        with other  Federal, State, and private organizations.

    The USDA budget expenditure  for research and regulatory
    activities  related  to  their  pesticides and pest control program
    is  as follows:

                                  (Thousands of dollars)

                                FY 1971         FY 1972  (Est.)

        In-house  Research     $68,938         $71,611
        Extramural  Research       1,500 (est.)      1,500
        Monitoring                 800            1,300
        Regulatory  (Pest
                     Control)    42,665           41,890
        Managing  Use  of
          Pesticides               213            1.000	

             TOTAL          $114,116         $117,301

3.  Department  of Commerce (National Marine  Fisheries Service;
             National Oceanic and  Atmospheric Administration)

    (a)  Research and Monitoring

    Conducts research relating to marine organisms; monitors
    shellfish for pesticide residues and assesses biological
    effects, if any.   Special interest in research on techniques
    to reduce pesticide content in marine organisms.  The budget
    for pesticide-related activities:

    Research, FY 71  = $115,000 and FY 72 = $167,000
    Monitoring, FY 71 = $82,000 and FY 72 = $0.

    (b)  Regulatory


    (c)  Grants and  Contracts


4.  Food and Drug Administration

    (a)  Research and Monitoring

    None;  transferred to EPA.

    (b)  Regulatory

    Field  and market surveillance for presence of pesticides
    in food.  The expenditures for this program:

    Headquarters, FY 71 = $150,000 and FY 72 = $315,000
    Field  operations, FY 71 = $2,635,000 and FY 72 = $2,867,000.

    (c)  Grants and  Contracts


5.  National Institute of Environmental Health Sciences, PHS, HEW

    (a)  Research and Monitoring

    Research on health aspects of pesticide use.  The budget
    for this activity:

    FY 71  = $2,700,000 and FY 72 = $3,100,000.

    (b)  Regulatory


    (c)  Grants and Contracts
    Awards grants to public and private non-profit institutions
    for research on biological  effects, in general, and human
    health aspects, in particular.   The grants program for
    pesticide-related research:
    FY 71  = $9,500,000 and FY 72 =  $12,300,000.
6.  Department of Defense
    (a)  Research and Monitoring
    Conduct a wide range of operational activities dealing with
    the evaluation of various aspects of pesticide use (e.g.,
    effectiveness, human health hazards, etc.).   The budget for
    these activities:
    FY 71  = $5,700,000 and FY 72 =  $6,800,000.
    (b)  Regulatory
    (c)  Grants and Contracts
    Not specified; if any, budget figures are included in the
    research and monitoring budget  figures given above.
7.  Department of Transportation
    (a)  Research and Monitoring
    None, except through grants.
    (b)  Regulatory
    Regulates the interstate shipment of certain pesticides
    as hazardous materials; controls non-Federal use of
    pesticides via licensing of aerial applicators.
    (c)  Grants and Contracts
    Awards grants and contracts for research and development
    designed to support the regulatory function.  Expenditure
    of funds for pesticide-related  regulation for:
    FY 71  = $252,000 and FY 72 = $800,000.


 8.   National  Science Foundation

     (a)   Research and Monitoring

     None, except through  grants.

     (b)   Regulatory


     (c)   Grants and Contracts

     Awards grants-in-aid  to public and private non-profit
     institutions, and to  individuals  for applied basic
     research, includes research  relating to pesticides,
     ecology,  etc.  The grants  program for pesticide-related

     FY 71 = $250,000 and  FY 72 = $300,000.

 9.   Office of Education,  HEW

     (a)   Research and Monitoring

     None, except through  grants.

     (b)   Regulatory


     (c)   Grants and Contracts

     Awards grants to public and  private non-profit institutions,
     and  to individuals, for research  relating  to environmental
     education and environmental  quality.  In the current FY  72
     grants programs pesticide-related project  expenditures are
     estimated at $10,000.

10.   Department of State

     Role limited to providing  technical assistance and advice to
     foreign governments relative to policy matters concerning
     economic poisons (e.g., meeting U. S. importation standards;
     recommending substitutes for "banned" pesticides; etc.).
     There are no separate budget figures available for this  type
     program activity.

11.   Federal  Trade Commission

     Regulates the advertising of economic poisons.   The FY  72
     budget for this purpose is approximately $25,000.

12.   Department of Labor

     This Agency has a $1  billion budget for FY 1972 to be
     used as  grants-in-aid for socioeconomic improvement through
     employment, training, etc.  Of these funds, all or nothing
     at all may be environmentally oriented depending upon
     priority judgments.

                          [Pesticides  Program]
1.  "Agriculture - Environmental  and  Consumer  Protection Appropriations
    for 1972," House Appropriations Subcommittee  Hearings,  Part  5,
    (1971), p. 5 ff.

2.  "Pesticides Programs  FY 1972  -  FY 1977  Program  Plan," dated  May  15,
    1971, as prepared by  E.  L.  J. Grandpierre,  Director, Program
    Development, Office of Pesticides Programs, Environmental  Protection


The pesticides programs of the Environmental  Protection Agency are quite
diverse in nature, and are in keeping with the mandate of this Agency to
protect and enhance the quality of the environment,  both for man  and
other life forms.   The Agency's pesticides programs  are not directed
toward any particular segment of society,  but rather toward a protection
from environmental hazards for all  persons.   But because the poor, both
urban and rural, carry heavy burdens which probably  make them more sus-
ceptible to pesticide hazards, EPA has a special  responsibility to this
group of endangered citizens.

The urban poor are a disadvantaged segment of society.  It should be
recognized tiiat the total  burden on the urbi.  • poor arises from a  complex
interplay of social, cultural, economic, environmental, and educational
factors, and the necessity for use of pesticides is  a part of the problem.
To try to separate out the pesticides factor  and study its effect, per
se, on the urban poor is a formidable task which approaches impossibility.

But as the Mrak Commission's Report on Pesticides expressed it:

     "No human activity is entirely without risk and this maxim
     holds for pesticide usage in the human environment just as
     it does for all other exposure to chemicals. There are formida-
     ble inherent difficulties in fully evaluating the risks to
     human health consequent upon the use of  pesticides.  In part,
     these difficulties stem from the complex nature of the problems
     involved, the fact that many facets of these problems have been
     recognized only recently, and the general backwardness in this
     area of research in man, as distinct from work  in laboratory
     animals.  Above all,  one must not lose sight of the large number
     of human variables -  such as age, sex, race, socio-economic status,
     diet, state of health - all of which can conceivably, or actually
     do, profoundly affect human response to  pesticides.  As yet,
     little is known about the effects of these variables in practice.
     Finally, one must realize that the components of the total environ-
     ment of man interact in various subtle ways, so that the long-term
     effects of low-level  exposure to one pesticide  are greatly in-
     fluenced by universal concomitant exposure to other pesticides as
     well as to chemicals  such as those in air, water, food and drugs.
     While all scientists  engaged in this field desire simple, clear-
     cut answers to the questions posed by human exposure to pesticide,
     the complexity of the human environmental situation seldom allows
     such answers to be obtained."

We do not know what harmful effects result when pesticides burdens are
added to all the other physiological burdens  of poor health and poor en-
vironment borne by the urban poor.  Definitive answers on the effects of

these added body burdens will take many years of research.   In the interim
our duty is clear:  to take every practical  action to minimize human
dosage and accidental poisonings.  As the regulations implementing FIFRA
(the Federal Insecticide, Fungicide and Rodenticide Act) state:   the
purpose of the Act is "to protect the public health before  injury occurs
rather than subject the public to dangers of experimentation and take
action after injury."

Public Education Program - Short Range

A public education program is needed nationwide, but especially in our
inner cities to provide instruction on the following:

     1.  Proper purchase - the right pesticide for the right pests,
         and the right applicator.

     2.  Proper usage - the right quantity and type of application
         (for example, don't paint the floor boards with persistent
         pesticides when there are children  at the crawling stage
         in the house).

     3.  Proper storage of pesticides - locked away from children.

     4.  Proper disposal of empty pesticide  containers (which are
         never really empty).

     5.  The use of alternatives to pesticides such as repellents and

The Task Force recommends that^the Urban Affairs Office be  directed to
initiate and coordinate community pesticide  education programs in urban

The Urban Affairs Office can utilize the Regional  Public Affairs Officers
and the Public Services Division of the Office of Public Affairs in a
coordinated effort to obtain the broadest possible dissemination of in-
formation in nine months' time.   In cooperation with the Pesticides Pro-
gram, the effort would involve preparation of pamphlets and fact sheets
capable of being easily understood by the poorly educated.   Similar
materials should be prepared for those whose only language  is Spanish.

Dissemination of the information materials would be achieved through
community improvement groups and the mass media.  Magazines, newspapers,
TV and radio stations with predominantly minority audiences should be

The Task Force recommends that $100,000 be allocated for use on this
pesticide education program over the next nine months.

Public Education/Community Action  Programs  -  Long  Range

1.   Pesticide protection teams  should  be  developed within  each  urban  area.

    Such pesticide protection teams  could be  composed  of existing  local
    personnel supplemented by neighborhood  volunteers, or  such  teams
    could consist entirely of local  citizenry (both  volunteers  and
    salaried) who have been thoroughly trained by  professional  personnel.
    This represents one means of providing  a  job opportunity  for the
    urban-poor resident while,  at  the  same  time, involving him  in  a
    neighborhood self-help program.

    Such pesticide protection teams  would be  responsible for  informing
    and training persons in their  immediate neighborhood of the safe
    uses of pesticides, proper storage, techniques for disposal, dangers
    from improper use, procedures  to follow in pesticide-related emer-
    gencies, etc.

    Such teams should also be able to  work  with city officials  in  their
    rodent control, anti-litter, etc., campaigns by  explaining  to
    neighborhood citizens how such programs are beneficial to them and
    what they, as individuals,  can do  to  help.

    Such teams could also serve as a focal  point for citizens to lodge
    local grievances relating to inadequate pest control,  etc.

    The effectiveness of such teams  would be  related to  the extent of
    personal contact and rapport which they are able to  establish  with
    the local residents, especially  in the poorer  urban  areas where the
    intrusion of "outsiders" is often  resented.

    EPA's role in this activity would  be advisory, with  conceivably an
    active role in the training and up-dating of such  teams.   A collabora-
    tive effort with the Department of Labor  would be  required  to  secure
    the money and jobs necessary for its  implementation.

    The concept of pesticide protection teams is similar to that of the
    "health educator aide" program which  has  been  implemented by the
    Department of Health, Education, and Welfare.   Perhaps a  collaborative
    effort with DHEW would be in order so that these two programs  could
    be intermeshed.

2.   A counselling service for pest control  problems should be made available
    as a public service to the urban dweller.

    The most important element in the wise use of  household pesticides  is
    the individual person who selects  the chemical to  be used and  decides
    upon the method of application.   Too often individual  selection  is

    based upon cost and availability rather than  upon safety and effi-
    cacy.  Detailed information and recommendations  (e.g.,  what pesti-
    cides to use for what pests, best method of application, brand
    names locally available, special precautions  to  take,  emphasis on
    reading and following label directions, advice regarding pro-
    fessional  exterminating services, etc.) should be available at
    the neighborhood level  to residents who have  specific  pest problems.
    Such advice should be easily obtainable - either by telephone or
    through some non-profit public service community center specifically
    set up for that purpose.

    Implementation of this  recommendation could be achieved via the
    pesticide  protection team concept discussed previously.  As stated
    above, EPA could work in concert with the Department of Labor and
    the Department of Health, Education, and Welfare to implement this
    program; EPA would provide the professional expertise  to train such
    teams and  would oversee their activities and  keep them supplied
    with up-dated information.

Improved Labeling Program - Short Range

The Task Force recommends that the Administrator  order:

    1.   for completion by November 30, 1971, a survey to determine
        which  pesticides are used most frequently in our inner cities.
        (See details on survey) ]_/

    2.   for completion by December 30, 1971, an evaluation  of the
        most commonly-used  labels for compliance  with the  following

        a.  Readability - easily understood by a  poorly-educated

        b.  Legibility - reasonable size print, contrast with back-
            ground color.

        c.  Content - toxicity warning
                      target organism
                      recommended application procedure
                      methods and quantity
                      recommended antidote and first aid procedures.
]_/ The nationwide survey in selected urban areas  should gather information
on types, amounts, and formulations of pesticides used; purpose and fre-
quency of use; methods of storage and disposal; marketing information;
et cetera, including scientific data pertaining to health and physical en-
vironmental  factors (climate,  ventilation, areas  of usage in square footage,
etc.).  Such a survey should canvass the individual user, the commercial
pest control operator, and city operations (e.g., tree-spraying, rodent
control, etc.) involving the dissemination of pesticides in urban areas.

        d.   Spanish - the instructions  and warnings  should be
            in several  languages,  but must include Spanish.
    3.  for completion by January 30,  1972,  a  report recommending  actions
        to be taken by the Administrator to  achieve compliance with  the
above criteria.
The actions to be recommended should be aimed at achieving effective
labeling on the major products found with inadequate  labels by May 1,
1972.  It is envisioned that through a voluntary compliance effort on  the
part of EPA, manufacturers could be persuaded to begin attaching decals
to their products by May 1, 1972.   Decals could be an interim measure.
The companies could alter their basic labels  at a later date convenient
to their production schedules.

Improved Labeling Program - Long Range

The Task Force finds there is a longstanding  need (the Mrak Report on
pesticides referred to it) to develop a system of non-language, inter-
nationally recognizable insignia or marketings on pesticides to convey:

    1.   the toxicity.

    2.   the target organisms.

    3.   the application method and quantity.

    4.   antidote and first aid.

The Task Force recommends that the Administrator order a study to develop
an international  insignia system for toxic materials  which can then be  a
proposal by the Administrator at the United Nations Conference on the"
Human Environment in Stockholm, Sweden, June  1972.

Appropriate consultation with our counterparts in other governments should
be undertaken to assure acceptability of the  proposal.

Improved Packaging Program - Short Range

The Task Force feels, as does the CEQ, that the growing trend to less  per-
sistent, but more to*ic, pesticides will probably result in a higher
incidence of accidental poisonings.  Thus, the Task Force recommends
the Administrator order a review of the packaging of pesticides used in
urban areas (both inner city and suburbs).  Although  accidental poisonings
have tended to occur more frequently among the poor,  the Task Force believes
that the danger to suburban children also is  growing and demands a broad
review of pesticide packaging.


The Task Force recommends that reviewers be required to prepare a  report
by January 30, 1972, for the Administrator on actions which  should be  taken
to require improved pesticide packaging to prevent accidental  poisonings.

Improved packaging concepts which should be considered include:

    1.  Child-proof containers (such as those used for baby  aspirin)
        with safety closures.

    2.  Deposit of 25 cents to insure return of the dangerous  empty
        containers (which are never empty) to the manufacturer for
        proper disposal  or preferably recycling.

    3.  A review of aerosol nozzles to insure that more toxic  ground
        sprays are applied with a highly-focused  spray, while  nozzles
        which produce a  fine mist are limited to  cans containing
        substances of low toxicity.

Pesticide Research Recommendations - Long Range

1.  The causative factors necessitating the household use  of pesticides
    should be removed.

    This would require  a sustained effort on the  part of Federal,  State,
    and local governments, industry, and private  individuals to  improve
    the urban environment by elimination of sub-standard housing,  solving
    the solid waste and  litter problem, and, in general, the alleviation
    of the socio-economic and related factors which are the  basis  for  a
    slum environment.

    The Department of Housing and Urban Development, through its "Model
    Cities" program, is  attempting to improve life in the  inner  city.
    Other Federal agencies (e.g., Department of Labor, DHEW, etc.)  are
    participating in this effort, also.  EPA should contribute its
    expertise in any way possible.

2.  A study should be commissioned to delineate the most effective means
    of heightening and sustaining public awareness of the  proper handling
    (use, storage, and disposal)  of pesticides and other toxic chemicals.

    It is within EPA's statutory  authority to commission such  a  study.
    An effort should be  make to involve consultants from the advertising
    industry who have expertise in "the selling of the public" (i.e.,
    consumer habits).

    Based upon the findings of such a study, EPA  should actively partici-
    pate in the development and implementation of a toxic  chemicals
    awareness program.


3.   Continued research  efforts  are needed  to  develop  safe  methods  of
    disposal  of pesticide wastes.

    The best  means for  the large-scale  disposal  of  stockpiles  of  unused
    pesticides, used containers,  and  other pesticide-contaminated  materials
    must be found.  EPA has on-going  research efforts in this  area via
    grants-in-aid to various universities. The  Offices of Solid  Waste
    and Pesticides Programs are working together to try to find a  solution
    to this problem.

4.   A study of dangers  from aerosol application  of  pesticides  should  be

    There is  preliminary indication that household  use of  pesticides  in
    aerosol containers  may result in  an increased prevalence  of respiratory
    impairments.  This  study should be  followed  up  to determine the
    causative factor and to delineate the  preventive  or corrective
    measures  which should be initiated.

    Such a research effort is within  EPA's purview; the preliminary
    study was conducted within  the Office  of  Pesticides Program's
    epidemiologically-oriented  Community Studies Program  (Hawaii).

5.   A national clearinghouse for  pesticide information should be  estab-
    lished within EPA.

    With respect to pesticides, a serious  information gap  exists  in the
    absence of reliable sources of data on local activities,  progress,
    and problems throughout the nation. This was pointed  out in  the
    Mrak Commission's Report on Pesticides in 1969, and it remains there

     A national clearinghouse is needed  to  collect,  organize,  and  dis-
    seminate information on pesticides  and their relationships to human
    health and the quality of the environment in a  modern  system  for
    information storage and retrieval.   The Environmental  Protection
    Agency is a logical place to  house  such a clearinghouse.

    Cooperation from other Federal, State, and local  agencies, universities,
    private research centers, industrial laboratories, et  cetera, will  be
    needed if such a clearinghouse is to effectively  serve the purpose
    for which it is intended.



          Water Pollution and the Effects on Urban People

          Quality Aspects of Water Pollution

              Water Quality Detractors
              Health Effects

          Water Pollution and the Inner City Populace


          Training and Manpower Development

          Research and Development

          Water Quality Planning

          Water Hygiene

          Water Quality Standards



          Recommendations - Immediate Action

              Ecology Corps
              Clean Sweeps
              Residential Construction
              Public Involvement
              Short-Term "Colleges"
              Kingman Lake

          Recommendations - Long Range

              Storm and Combined Sewers
              Waterfront and Shorelines
              Project Cure
              Training and Employment
              Incorporation of Human Aspects into Environmental  Assessment
              Legislative Recommendations



In our cities, water, a vital  resource, is becoming increasingly in-
adequate to meet the requirements of concentrated population and industry.

The quality of many city waters is degraded by municipal  and industrial
wastes.  These pollution problems become intensified in congested central
city areas where deterioration of water and sewer facilities are common-

The following analysis looks at the magnitude and effects of water pollu-
tants on urban residents, and proposes recommendations to prevent and
control the problem.

Mater Pollution and the Effects on Urban People

Municipal Wastes - Municipal wastes rank first in terms of waste sources
affecting the people of this country, including the inner city populace.
Fortunately, this waste source also ranks first in terms  of our ability
to solve the existing or potential pollution problems it  creates.

Municipal wastes consist of two components:  (1) domestic waste discharges,
and (2) discharges to municipal systems from industrial sources.  In  most
municipal systems, the industrial waste component is a significant part
of the total waste load.

Wastes from municipalities are significant because:  (1)  they are a
large source of organic material which lowers the dissolved oxygen con-
tent of water; (2) they contain large numbers of bacteria and virus creating
a potential health hazard where receiving waters are used for recreation
and as a public water supply, and (3) they contain nutrients that accelerate
eutrophication of rivers, lakes, and estuaries.

Industrial Wastes - Industry adds to the pollution problem in inner city
areas by discharging huge volumes of untreated wastes into the municipal
sewer systems.  As of 1968, an estimated 50 percent of the Biochemical
Oxygen Demand (BOD) in municipal sewage was produced by industry.  The
toxic wastes that industry adds to our waters include oils, metals, pesti-
cides, poisons, dyes and chemical catalysts that can strain a sewage treat-
ment plant to the breaking point.

In addition, industries also discharge untreated wastes directly into our
waters, causing a greater BOD load than that of municipal sewage.  Since
1920, industrial pollution has exceeded domestic pollution.  In 1968, in-
dustrial wastes were responsible for four to five times more pollution
(in terms of BOD load) than domestic wastes.

Other Urban Wastes - In addition to sewered municipal and industrial  wastes,
other urban wastes - including combined sewer discharges and other urban

runoff, such as land erosion - are a serious  source of water pollution
in urban areas, which must be attacked in  the next five years in  order
to achieve water quality standards, even in part,  by 1976.   In large
metropolitan regions where water-based recreational demand  is especially
high and combined sewer systems are the rule  instead of the exception,
control of "other urban wastes" will be the keystone in meeting water
quality standards and preventing closure of beaches during  wet weather

Quality Aspects of Water Pollution

The main impacts of water pollution on the inner city populace are  mani-
fested by changes in the physical  qualities of the water,  its taste and
odor, its appearance, its oxygen levels and the aquatic life within the

Hater Quality Detractors - Domestic wastes, including industrial  wastes,
if inadequately treated, can have the following effects:  (1) closing
recreation areas to swimming, fishing and  boating; (2) closing shellfish
beds; (3) eliminating desirable fish species; (4)  denying  the use of
water as a public water supply or creating taste and odor  problems  if a
polluted water source is used for drinking water purposes;  and (5)  cre-
ating a nuisance and thereby reducing the  aesthetic enjoyment of  water-
adjacent land areas.

The number of sewered communities in the United States is  just under
13,000 and 68 percent of the nation's population lives in  such communi-
ties.  During the next five-year period, it is estimated that about 8,000
communities across the nation will construct  new,  improved  or expanded
sewage treatment facilities.

Urban runoff wastes have many of the same  adverse  effects  on water
quality and water use as municipal sewage:  they contain high concen-
trations of bacteria, solids, organics, and inorganics and  result in
attendant degradations of water quality.

Pollutants from storm sewer run-off, raw or inadequately treated  sewage,
and industrial wastes, along with excessive blue-green algae growth, are
mainly responsible for producing the foul  taste, odor and  coloring  of
some urban water supplies.

Such pollution contributes to non-potable  water and can cause physical
discomforts such as vomiting and gastric upsets.  A nationwide survey,
reported in a 1970 study, indicated that algae was considered by  241
water works officials to be the most frequent cause of foul taste and
odor in water supplies.   (Kenneth Mackenthun and Lowell Keup, American
Water Works Association Journal, August 1970.)


Although algae may not be directly injurious to human health, excessive
algae growth in addition to other organisms can interfere with a water
supply by clogging filtration systems and pipes.  Organisms such as  thin
red blood worms in piping (Midge larvae) which generally indicate polluted
water have occurred in municipal drinking water in at least 17 scattered
municipal systems, including New York City and Washington, D. C.  The
combined presence of worms and bad taste make some urban water unfit for
domestic use.

Health Effects of Water Pollution - The physical effects of polluted
water on the individual range from minor discomforts and bad taste to
major diseases causing death.  Bacteria in polluted streams may cause
typhoid fever and kidney disease.  Mercury, arsenic, and other chemicals
in water may be fatal to those drinking the waters.

Methemoglobinema, a disease affecting infants less than three months old,
is caused by the bacterial conversion of the relatively innocuous nitrite
ion to nitrate.  The physiologic effect is oxygen deprivation, or suffo-

Acute cases of "blue babies" may only be the tip of the iceberg.  Nitrates
have been found to interact in the stomach with secondary amines from
drugs, food flavoring or decaying meat to produce nitrosamines.  Some
nitrosamines are carcinogenic, and teratogenic.

The authority of EPA's water hygiene program extends to preventing the
spread of communicable diseases.  To do this EPA has set up national
standards on the acceptable bacterial levels of drinking water.  At this
time EPA has no enforcement authority beyond notification to the Food and
Drug Administration that a certain area's water supply falls below safe
bacteria levels.  The FDA then prohibits interstate carriers such as
trains and planes from using such substandard water.  Currently, about
670 water supplies serve interstate carriers.

Related to health effects is the fact that waters surrounding our major
cities are littered with dead fish, garbage, wood, metals, detergents,
suds, oils, plastic and rubber goods, cans, and dead plant life.  Domestic
sewage and industrial wastes emptied into rivers account for most fish
kills.  The newspapers and the technical literature are replete with
records of small to massive kills in urban areas.  Statistics for 1969
show that an estimated 41 million fish were killed in that year.

Water Pollution and the Inner City Populace

The lack of hard data on the wide range of physical effects on  inner
city people caused by contact with polluted water, however, permits
only speculation.  A reason few  data exist is due to desensitization

of the people who come in daily contact with polluted water.  Effects
are often not reported, or, if they are, are reported days after con-
tact with the water and not recognized as stemming from water contact.

The biggest psychological effect of water pollution on the inner city
people is the loss of recreational resources and facilities.  A recent
report shows there will be an average increase of 65% of the number of
people who swim in the United States between 1965 and 1980.  At present
there are 100 million swimmers, 57 million fishermen, and 52 million
boaters.  By 1980, they expect there will be 200 million swimmers.   Of
these only 50% live within commuting distance of a beach.

Many inner city residents take their existing environment for granted.
Colored, odd-tasting drinking water is to some a customary presence.
Often, the bad taste, however, can be traced to piping in the urban
homes, not the municipal water systems.  The presence of a nearby
polluted or littered body of water, unfit for recreational purposes, may
also be a customary sight.  Effective implementation and enforcement of
the water quality standards program can change the situation and result
in water of sufficient quality to be used for many beneficial uses.

Why Big City Haste Water Systems Have^Deteriorated - Degradation of the
urban waste water treatment system exists for two reasons.

First is  neglect.  This has created a great backlog of unmet facility
needs and the need for improved operation of existing facilities.  This
is severe in the Northeast which includes a large percentage of the urban
population of the country.  New England, New York, and Pennsylvania, with
about 20 percent of the national population, have 52 percent of the
sewered population with waste handling facilities that are often in-
adequately or improperly operated through lack of trained plant operators
or other reasons.  It has been estimated that 40% of existing treatment
plants are not operating at designed efficiency levels.  The effect is
that the public, including the inner city populace, are not getting their
money's worth out of many waste treatment facilities which they have or
are paying for at the present time.  The question of neglect also relates
to the inner city people.  Litter and garbage on city streets contribute
to the pollution load entering the sewers and hence the treatment systems.

Second is the expense, currently estimated at $12 billion for conventional
waste treatment alone to meet water quality standards, which has dis-
couraged, until recently, a real attack on municipal waste problems.  The
money, however, is now hopefully becoming available for upgrading con-
ventional  treatment through intensified and expanded Federal grants pro-
grams.  The immense cost of sewer separation, estimated at $15 to $50
billion and lack of effective technology, are tremendous constraints to
any serious addressal of the combined sewer problem.  The age of the
wastewater collection and treatment systems in use in many of the older
cities of the Northeast and Midwest, with its corollary of combined sewer
systems, is yet another factor.

It is recognized that the cost of replacing wastewater collection and
treatment facilities  in our older urban areas  is costly.   In many of
our cities the existing fee or rate schedules  for wastewater treatment
are often inadequate  to allow replacement and  renovation  of existing

The technological problems are more or less solved with respect to con-
ventional municipal waste treatment systems, although more efficient
and cheaper techniques are highly desirable as the move is made to 100%
purification of water in the cities with the highest population con-
centrations.  However, considerable additional research is needed in
the combined sewer and run-off areas.   These areas have significant
public impact in terms of the living conditions of the inner city people.
It is the problems of combined sewers, urban run-off and deteriorating
facilities in our central cities that have a continuing hazardous
impact upon the inner city populace from the standpoint of public health.


Mackenthun, Kenneth and Keup, Lowell,  "Biological  Problems
Encountered in Water Supplies," American Water Works  Association,
Vol. G2, No. 8, August 1970.

Mackenthun, Kenneth and Keup, Lowell,  "Biological  Problems
Encountered in Water Supplies," paper  presented at the  90th  Annual
AWWA Conference, June 23, 1970.

Epstein, Samuel S., "lexicological  and Environmental  Implications
on the Use of Nitrilotriacetric Acid as a Detergent Builder,"
Staff Report for U. S. Senate Committee on Public  Works,  Dec.
1970, citing Gelperin, A. Medical  World News,  July 17,  1970.

"1969 Fish Kills," II.  S.  Department of the Interior,  Federal Water
Quality Administration, U.  S. Government Printing  Office, 1970.

"River of Life - Water:  The  Environment Crises,"  U.  S. Department
of the Interior Environmental Report,  Vol. 6,  GPO.



The Water Quality Program, authorized by the Water Pollution Control  Act,
as amended, and conducted by the Office of Water Programs,  EPA,  contains
many facets, all of which relate in some part to the inner  city  environ-
ment as well as to all other urban and rural environments,  because it is
a national program.  To avoid lengthy discussions of the total  program,
only those facets of the program which relate more directly to  the inner
city environment are described in the following paragraphs.

Training and Manpower Development

Development of Wastewater Treatment Plant Operator Training - This pro-
gram includes:(a) a pilot State-training grants program for water
pollution control operator training; (b) an intensive technical  training
program for supervisory treatment plant and public works department
personnel; and (c) an instructor training program to support the training
of operators and supervisors.

EPA at present manages a contract, under the Manpower Development and
Training Act, which annually trains about 300 entry level waste treat-
ment plant operators drawn from the unemployment and disadvantaged, and
about 700 operators drawn from the under-employed blue collar workers
currently employed in waste treatment plants.  Twenty of the State water
pollution control agencies, plus those of Puerto Rico, the Virgin Islands,
and the District of Columbia, manage similar contracts to provide training
for an additional 2,500 each year.  Three new programs supplement this
work.  First, pilot grants for State training programs will be  awarded
in 20 states to design and initiate State-directed training activities
and to commence development of the self-supportive State training capa-
bilities.  These will result in the training of 700 persons.

Second, a new program will be conducted under contract at one or two
advanced waste treatment plants.  Supervisory treatment plant and public
works department personnel, mostly professional engineers from middle and
large-sized plants across the country, will be given intensive  technical
training  in the operation of advanced waste treatment processes.  The
program will train approximately 100 individuals.

Third, an instructor  training program will  be carried out to support the
pilot State program and the intensive technical training efforts.  The
courses will be conducted at two or three locations to train approximately
50 personnel, mostly  former treatment plant operators who can provide
the  insight of  practical experience.

Professional Training - Professional training grants are awarded to
educational institutions for graduate training programs.   Office of Water

Programs (EPA) encourages institutions to develop specialized water
pollution control  sources within multidisciplinary curricula and to
consider total environment needs which may cross and combine a number
of traditional disciplines.  During 1972, 88 training grants to academic
institutions will  be supported and these will  provide traineeships
for about 930 students.

Research and Development

Research and demonstration grants and contracts are awarded to assist
in supporting basic and applied research projects and to develop and
demonstrate the feasibility of new methods related to the causes, control
and prevention of water pollution.  They support projects in the field
of water pollution control which are directed toward the discovery  and
application of new information and technology in the chemical, physical,
biological  and social  sciences, in engineering, and in administrative
aspects related to water pollution in urban and rural areas, including
the inner city environment.  These grants and contracts may be awarded
to states'  municipalities, intermunicipal agencies, public and private
agencies, institutions, and individuals.

Construction Grants and Wastewater Treatment Works

Grants are provided to assist and serve as an incentive in the con-
struction of waste treatment works and major interceptor sewers to
prevent the discharge of untreated or inadequately-treated sewage or
other wastes into any waters.  Basic grants cover 30 percent of the
cost of a project; may be increased to 50 percent if the State pays at
least 25 percent of the cost.

Municipalities (including the inner city areas), States, and interstate
agencies having jurisdiction over the disposal  of wastes are eligible.

The proposed $12 billion program is designed to meet municipal needs as
identified in water quality standards.  Approval of grants is based on
conformance with basin/metro plans, approved cost effective guidelines,
EPA (OWP) design,  operation, and maintenance guidelines, and State

Water Quality Planning

EPA's planning programs include three general  kinds of activities:

    1.  Financial  assistance to regional, State and local planning

    2.  The administration of the grants used to provide this
        financial  assistance.

    3.  Direct performance of broad scope planning in cooperation
        with states and other Federal agencies.


Basin Planning Grants serve as incentives to State and local  governments
to cooperate in the development of plans for the systematic cleanup of
an entire river basin, or portions of it, such as metropolitan areas,
including the necessary fiscal and organizational machinery to make the
plan work.

EPA-OEP requirements necessitate the development of metropolitan basin
or regional  plans, including urban areas, and that these plans incorporate
adequate sewage treatment facilities in compliance with water quality

Federal Planning and Technical Assistance - This includes an interagency
water resources planning program; joint Federal-State river basin
planning program (development of mathematical models of the 100 most
critical and complex basins); and direct assistance and review programs,
to increase aid to State, regional, and metropolitan water quality
planning agencies to ensure effective plans and conformance of con-
struction grant applications with those plans.

Interagency Relationships - Water Quality Planning is conducted at all
governmental levels, and such planning, together with construction of
wastewater collection and treatment systems, is supported by grants from
EPA Wastewater Treatment Works Construction Grant Program and River
Basin Grants.  HUD provides grants from Water and Sewer Facilities Grant
Programs and 701 Planning Assistant Programs.  However, fundamental re-
sponsibility for water pollution control is at the State and local level.

Comprehensive planning by the States, with the assistance of Federal
agencies, develops fundamental water quality goals and objectives, guides
development, and provides a framework for regional, metropolitan, and
local water quality management planning.  Planning will be done by area-
wide planning organizations recognized by EPA, HUD, and the Governor of
each State.  On or after October 1, 1971, area and organizational,
comprehensive planning, and water/sewer planning and programming certifi-
cations are required by both EPA and HUD prior to grant awards.

EPA regional staff are available for establishing coordination with State,
local and regional agency officials.  Permits for allowable wasteloads
issued to industry are determined by the basin plans.  Basin planning
organizations are to be designated by the States, and are to be assisted
iVtheir work by EPA and HUD.

The Federal Government, and some States, require impact statements on all
major Federal or State actions that may impact on the environment to be
made public.  These statements, with attached comments by any governmental
agency with  legal jurisdiction or special expertise, must cover impact
adverse effects, alternatives, short and long-term uses, and irreversible
resource  commitments.

Water Hygiene

Water Hygiene Office initiates major revisions of the Drinking Water
Standards, publishes a Program Guide to Interstate Carrier Water Supply
Program, conducts research on treatment technology on virus removal
and toxicity of trace metals, and presents 14 training courses on
Water Hygiene, all of which relate to urban and rural areas.

In addition, the office has realized the need for an expanded program
and has developed a proposed program described in detail  in the paper
included in the attachments.

Water Quality Standards

The Water Quality Standards Program provides effective tools to help
clean up America's polluted rivers, streams, and lak.es, both in urban
and rural areas.

The Standards Program provides for the protection of public drinking
water supplies, recreational water uses, and for the general protection
of our health and welfare and enhancement of opportunities for future
benefits to mankind.

As a result, cities and industries with significant waste discharges
know what is required of them in order to upgrade or maintain the
quality of the interstate waters in their respective States.  In effect,
the program puts cities and industries in a given river basin or along
an interstate lake on a relatively equal footing.  Although not required,
many States took advantage of the opportunity and extended standards
coverage to include intrastate waters.  In an action clearly indicating
their desire for high quality water the States have classified about
90% of their streams for recreational use and/or the propagation of
fish and wildlife.

The standards package from a State contains three main elements:

    1.  The uses to be made of a particular stretch of a  river,
        lake or coastal waters, such as for swimming.

    2.  A scientific determination of the specific characteristics
        or criteria which would permit the appropriate uses agreed
        on by the State and the Federal Government.  Limits on such
        pollutants as bacteria, toxic materials, and taste and
        odor-producing substances in the water are set by the standards.

    3.  A step-by-step plan for construction by cities and industries
        of waste treatment facilities and use of other measures to
        meet the water quality requirements.

The major immediate objective will  be the control  of pollution from
cities with inadequate waste treatment facilities  or none at all  and
major industrial  plants which either have unsatisfactory treatment or
no treatment at all.

Once standards submitted by a State have been approved fay the Administrator
of EPA, they become Federal Standards as well and  are, therefore, subject
to Federal enforcement action.  However, the initial responsibility for
enforcement of standards rests with the States.   If a State fails to
exercise this responsibility, the Administrator  may act.   If the  Adminis-
trator is advised that monitoring or other information indicates  that
the standards are being violated, he is empowered, after notice and a
wait of 180 days to refer the matter directly to the Department of
Justice for filing of a court suit.

Residents of the inner city along with all other people can play  an
important role in both the establishment and enforcement of standards.
In establishing or revising standards, participation in public hearings
to influence the determination of water uses is  paramount.  After adoption
of standards, enforcement assures that action will be taken to meet
these standards.  Specifically, the inner city residents may participate
in enforcement by joining local environmental groups, working with edu-
cational, scientific, and technical groups, find out what local govern-
ment agency is responsible for enforcing standards, use political pressure
to get clean water action, and accumulate the required data to bring
direct court action if responsible agencies are  slow to act.

Once the standards have been approved, they are  not set in concrete for
all time.  They can be changed from time to time as new information be-
comes available.  Either at the request of a Governor or on his own
initiative, the Administrator is empowered to take steps for revision
of standards.


EPA is concerned with securing compliance with water quality standards
for interstate waters, abating pollution in shellfish areas where the
marketing of shellfish in interstate commerce is adversely affected.
EPA, in conjunction with the Coast Guard, carries  out also various activities
to enforce regulations covering the control, cleanup, and prevention  of
oil spills.  EPA also brings enforcement actions under the Refuse Act of
1899.  In all cases, close cooperation and coordination with State and
local efforts are maintained.  During 1971, work in over 50 active
enforcement actions is under way.



Recommendations:   Immediate Action

Establishment of an Inner City Ecology Corps - It is recommended that
such a corps be established to prompt people to be involved in edu-
cational projects and action projects to cleanup inner city areas.   We
cannot assume that the inner city people are knowledgeable about the
causes and effects of water pollution.  A description of the various
types of projects which could be conducted under the aegis of a Ecology
Corps are described in the attachment.  The Corps, among other things,
would provide a means to expand EPA's public educational system with
informational materials such as "A Curriculum Guide to Water Pollution
and Environmental Studies."  Initially, a corps could be developed  in
one to 20 major cities on a "pilot basis."  The cost would be about
$5,000/person/year for residents in the program, about 100 people would
be needed per city.  Thus, the cost would probably run from about $5 to
$20 million depending on the size of the Corps.  The Corps could in-
corporate another recommendation by the Task Force, that a government
Environmental Intern Program be initiated for inner city residents.
(See general recommendations on SPARE which incorporates this concept.)

Inner City Clean Sweeps - It is recommended that inner city cleanup pro-
grams be initiated to remove the litter, garbage, etc., that contribute
to the pollution load entering the sewers and thence the treatment  plants.
Because this is primarily a solid waste problem, the details are in-
cluded in that section.  (See general recommendations on National Operation
Clean Sweep which incorporates this concept.)

Residential Construction - Deteriorating plumbing and inadequate installa-
tion of sanitary facilities in many of our old urban neighborhoods  can
be corrected to provide safe drinking water and adequate sanitary facilities,
It is recommended that administrative agreements be initiated with  HUD
(expanded agreements), FHA, VA, OEO, and other Federal agencies involved
in urban renewal, housing codes and home mortgage insurance.  Short range
costs would be administrative.

Water Supplies - Public Involvement - It is recommended that workshops
be covered with inner city residents to identify water supply and other
problems particular to their immediate environment - to feel the pulse of
the local people.  Conversely, Water Programs representatives could inform
residents of actions they can take to help remedy local immediate problems.
The cost would probably be about $1,000 per workshop.  Again, perhaps this
could be initiated on a pilot basis in one to 20 cities.

Inner City Short-Term "Colleges" - It is recommended that the Water Pro-
grams1 established 22-week and 44-week training courses in various  aspects

of water quality be expanded and that the expansion be directed to a
number of demonstration inner cities.  This would involve expansion of
the Public Service Careers Program directed to the disadvantaged.   Approxi-
mate training cost is $1,000/person.

Initiation of Kingman Lake Project -  EPA should strongly support the
proposed Kingman Lake Project, located on the Anacostia River in D. C.}
which would use new techniques to control and treat combined sewer over-
flows, with the renovated water being used for recreation.  The project
is presently awaiting OMB clearance,  and we strongly recommend that the
Administrator encourage OMB clearance.  The Bicentennial Commission has
shown an interest in the  project.  Estimated cost of the water pollution
aspects of the project is $29.5 million over a four-year period.  The
financial burden is on the District of Columbia.   It is, also, recommended
that additional funds be  allocated to the D. C. budget, approximately $1
to $2 million to initiate the planning and design; this should be  coupled
with a strong, effective  public information program.  Details on the
project are included in the attachment.

Recommendations - Long Range

Storm and Combined Sewers - A major source of urban pollution is storm
and combined sewers.TnTs problem requires:

    1.  Immediate planning and programming for handling and treating
    storm water and waste water in major cities.   This requires con-
    siderable capital outlays over the next ten years, estimated at
    $15 to $50 billion.  Immediate actions could consist of promoting
    installation of fine  straining treatment systems in cities,
    coupled with an active public information program.  Costs would
    depend on the number of cities involved; a 25 million gallon/day
    (mgd) screening facility would cost (construction) about $500,000
    per unit.

    2.  Expand present control anu monitoring authority.  Example:
    promote strengthened local controls to prevent indiscriminate
    dumping of oil and other toxic wastes (from garages and car washes),
    trash and fleatables  in storm drains.  A means of preventing entry
    of such wastes in storm drain systems should be explored.  A public
    information program is needed (see recommendation regarding Ecology

Waterfront and Shoreline - Many of our major cities are blessed with miles
of waterfront, coastline and streams  that no longer can provide recreational
opportunities or even aesthetic beauty to the urban scene because of
pollution.  Remedial measures could include establishing appropriate
water quality standards, followed by regulation and control and supported
fay more intensive and expanded monitoring systems and surveillance programs.


Project Cure Hater Programs - A proposal has been developed,
"Project Cure" (Clean Urban River Environment), that  offers an imagina-
tive approach to reintroduce water courses  in the immediate urban
environment.  By means of strategic location of sewage treatment plants,
control and treatment of surface water runoff,  a high quality effluent
can be used to increase the flow of existing streams or to create canals
which lace the urban centers with water courses providing recreational
opportunities and aesthetic beauty.

Estimates on a per city basis could range from a small amount to the
$50 million-plus range.  Such efforts involve intense interagency co-
ordination and assistance.

Training and Employment - Many opportunities exist to provide the inner
city populace with job opportunities or training in  pollution control
programs.  A substantial number of disadvantaged persons from the inner
city are reached in current sewage treatment plant operator training
programs.  Disadvantaged persons are now referred to EPA through "local
employment services" and "concentrated employment sources."  Full utili-
zation of the Emergency Employment Act of 1971  would increase Federal
authority to provide training and employment in cooperation with the
Department of Labor.  Such efforts have been initiated but need to be
expanded.  Now, the EE Act is entirely under the jurisdiction of the
DOL; we recommend that EPA be given an active role in the use of salary
support funds for urban areas.  Maximum salary support to match previously
identified training programs would be approximately  $50 million/year.
The training portion would be $9 million.  The  mechanism would consist of
grants to cities to train people, train the teachers, and provide salaries
for needed jobs - thus initiating a modicum of self-sufficiency.

Incorporation of Human Aspects into Environmental Assessments - The
Environmental Policy Act should be examined along with the functions and
responsibilities of the Council  on Environmental Quality to incorporate
criteria for assessing environmental pollution  on the human and social
environment, particularly that of the inner city populace.

Legislation Recommendations - EPA should strive to expand its water quality
standards program to include all intrastate, navigable, land ground waters
plus an increased contiguous zone to provide the basis for protecting the
public health and welfare and enhancing the quality  of water.

That EPA, through its Water Hygiene Office, should establish an expanded
water supply program as described in the attachment.  The program would
probably cost in the range approaching $20  million/year addressed pri-
marily to community level (urban areas).

Also, it is recommended that EPA should:

    1.  provide financial and technical assistance to State and
    local governments for the development of improved methods of

making water safe for drinking and recreational  purposes.   The
development of water quality management plans for handling
municipal, combined sewer and industrial  wastes  in all  urban
areas of the United States will  cost about $250  million.   EPA
planning grants program will be providing about  $2 million in
direct financial  assistance to this effort in FY 72, and

2.  provide training grants to State and local  governments for
training persons  for occupations involving the public health
aspect of raw water sources, water treatment and purification
works, and distribution systems.  Annual  expenditure would be
about $9 million.


                             KINGMAN LAKE
About one-third of the area of the District of Columbia is served by a
combined sewer system which causes large quantities of raw sewage to
be discharged into Rock Creek and the Anacostia River during wet weather.
These overflows contribute significantly to the organic and nutrient
loads in the estuary and also cause serious bacteriological problems.
The combined sewer problem must be dealt with if the total effort, in-
cluding the massive Blue Plains Project to cleanup the Potomac estuary,
is to pay off.  The staff of the Office of Water Programs conceived
the idea of the Kingman Lake Project to abate pollution from the com-
bined sewers discharging to the Anacostia River.

The proposed Kingman Lake Project, located on the Anacostia River near
RFK Stadium, would utilize the newest techniques of controlling and
treating combined sewer overflows, with the renovated water being used
for recreation such as boating, fishing, and swimming.  The project
would be located on land in the heart of the nation's capitol that is
at the present time not being utilized fully.  With this project the
Federal and D. C. Governments could demonstrate how both waste water
and waste land can be reclaimed for the use of society.

The present estimated cost of this project is $45.2 million, of which
$29.5 million is for water pollution control, $6.3 million is for
recreational facilities, and $9.4 million is for associated highway and
parking costs.  Cost would be spread over a four-year period and would
have no immediate cash outlay effect.  It is felt that most of the costs
for water pollution control will be eligible for Federal construction
grant assistance from EPA.  It is also felt that certain planning and
operation costs will be eligible for grant assistance from research,
development, and demonstration funds.

The effective implementation of this project will require coordination
of efforts with agencies of the D. C. Government and with the National
Park Service.  Recommended actions to be taken by EPA are fully outlined
in a document prepared by the Office of Water Programs.  This document
identifies the benefits which would be derived from this project and
suggests a method of implementation so that the facility would be under
full construction in 1972.

                    PART  IV



The Task Force recommends that the Administrator request from Congress
a supplemental appropriation to fund an "Operation Clean Sweep" in 20~
major cities.[See Table IV-B for list of cities.)

Operation Clean Sweep would finance the formation of Environ Men Teams
within City Sanitation Departments to clear away the backlog of trash
accumulating in our inner cities.  These teams would augment the trash
collection service presently being provided to inner city areas by the
local sanitation departments.  The Environ Men Teams would be supple-
mented by SPARE "Follow Through" Teams, also financed by EPA.  These
"Follow Through" Teams would be teenagers working on a part-time basis
to maintain an area's level of cleanliness achieved by the "Environ

Environ Men Teams - Three-man teams would be formed and provided with
trucks and cleanup equipment to remove rubble from alleys, vacant lots,
and the yards of abandoned buildings.  The rubble behind abandoned
buildings is probably the most challenging task.  At times this rubble
is piled to the second story window level.

Bulky wastes such as refrigerators (dangerous to children), abandoned
automobiles, and discarded furniture would also be removed by these
teams.  The teams would begin to fill the gap between the service pres-
ently provided by trash collectors, who simply empty trash cans at the
curb, and the street cleaners who clear up litter in the streets.

The Environ Men Teams would have important and well-paid jobs.  Un-
employed inner city veterans would be given preferential consideration
for these jobs.

To appreciate the number of Environ Men Teams needed for the abandoned
building problem alone, one need only review the following statistics
from the CEQ 1971 Annual Report:

    "It is estimated that there are 100,000 abandoned dwelling
    units in New York City, between 20,000 and 30,000 in Philadelphia,
    more than 10,000 in St. Louis, 4,000 or more in Baltimore, and
    5,000 or more in Chicago."

Employment of Inner City Residents - The staffs of the 20-city Environ
Men Teams should consist of residents of the inner city, because the
workers would be sensitive to the needs of their communities.

The Task Force proposes a flexible program for the teams that will allow
each city to meet its own solid waste collection needs.  In some cities,
the abandoned house problem would need emphasis; whereas in others, the
bulky waste problem would be paramount.

Salaries - The salaries of the Environ Men Team members would be worked
out according to the applicable wage guidelines set up in a particular
city for its sanitation department staff.   The Task Force recommends
that the "Environ Men" be paid at least $10,000 annually.

SPARE "Follow Through" Teams - Environ Men Teams would be supplemented
by SPARE "Follow Through" Teams made up of teenagers who would help keep
the areas clean after the "Environ Men" have worked through a neighbor-
hood.  They would also be involved in projects to clear, sod, and
maintain vacant lots as mini-parks.

Cost of National Operation Clean Sweep - Assuming each Environ Men
Team consists of three men and a truck with appropriate equipment, the
Task Force arrived at the following rough budget for the National Clean
Sweep Program:  $50,000,000.

             Environ Men Teams                          Cost
    1.  3,000 men @ $10,000/year                     $30,000,000
        1,000 trucks @ $10,000/truck                  10,000,000

        SPARE "Follow Through" Teams

    2.  7,000 teenagers @ $2.00/hour
            (10 hours/week) (50 weeks)                 7,000,000

    3.  Trash receptacles (40,000 @ $50.00 each)       2,000,000

    4.  Plastic bags                                   1,000.000


Lest budget people think that $50,000,000 is an extraordinarily large
program cost, it is not when compared with the need.  $50 million is
not an excessive cost for a program of this nature because of the
immediate and compelling need for its implementation.

If each team could clear the yard of just one building each day
(probably an unrealistic goal), and even if each team worked 300 days
each year, the 200 teams would clear only 60,000 of the estimated
100,000 abandoned-house areas in New York City.  Still left unattended
would be the abandoned lots, alleys, and general bulky waste collection



TKe Task Force feels that,  since fragmented efforts have been made in
the past, there is a necessity for EPA to become involved in a meaningful
attempt at the rehabilitation of the inner city environment.  Therefore,
the Task Force is recommending a "Demonstration City Project" as a viable
and efficient means of urban improvement.   Washington,  D. C. is the
recommended Demonstration City.

By concentrating EPA resources in one city in a coordinated effort, the
Agency should be able to develop a model  environmental  improvement pro-
gram for the nation to follow.  Such coordination would be the responsi-
bility of the Urban Affairs Officer.  (Functions of this Officer are
described elsewhere in this Recommendations section.)

The Task Force recommends that the Administrator select Washington, D.  C.
as the demonstration city since it is most visible to municipal and
State government officials  and to the nation as a whole.  The capital
should be the nation's model.  The proximity to EPA headquarters, plus
the efforts of the District's Environmental Services office, would help
assure achievements by June 1972.

Five projects in EPA program areas and two projects of  a general nature
are suggested:

     1.   SPARE Environmental Protection Ombudsman

     Hire one professional  to direct a SPARE operation  with five
     inner city assistants  to supervise some 200 SPARE  teenagers
     and job trainees.  Teenagers would work 10 hours a week,
     trainees full time.

     The SPARE office director would act as an environmental ombudsman
     for the inner city.  Under his guidance, his assistants and their
     teams of trainees would identify and seek remedial action for en-
     vironmental problems such as noise, air, and solid waste.  They
     would also educate inner city residents on pesticide usage and
     solid waste practices.

     2.   Solid Waste

         a.  Finance "Environ Men" teams to:  (1) cleanup inner city
         lots, alleys, and  the yards of abandoned houses, (2) collect
         bulky waste materials, (3) haul  abandoned automobiles off the

         b.  Finance the purchase of plastic bags for distribution to
         inner city areas for improved trash collection.  Plastic bags

    are:   (1)  effective  odor barriers,  and thus would not be
    "open  invitations" to  rats  and  insects,  (2} quiet,  from a
    collection consideration,  (.3) more  easily stored; thus,
    when the trash supply  necessitates, there are  containers
    on hand to handle the  overflow.

    c. Purchase  2,000 additional trash cans at a  cost  of
    $10,000 for inner city use.   District trash cans are
    currently  unevenly distributed; many more in the business
    district than in the inner  city where need is  greatest.

    d. Hire SPARE "Follow Through" Cleanup  Teams.

        (1) Teenagers under the supervision  of an  EPA SPARE
       program director would  be paid  to work 10  hours weekly
       cleaning  up light  trash and debris after Environment

        (2) These teenagers would also  clear, sod,  and  maintain
       vacant lots converted  to mini-parks.

        (3) They  would educate  the  communities in  city  programs
       and requirements for solid  waste removal,  and provide
       follow-through on  city  service  to the SPARE Director.

    e. Explore through  the Office  of Solid  Waste  Management and
    the Urban  Advisory Council  the  possibility of  organizing a
    black  firm to collect, for  recycling, the waste paper  generated
    by all  the government  agencies  in the District of Columbia.

3.   Air

Provide planning  assistance funds to  develop a constructive alternative
to  the incineration of the District's solid  waste.  (The city  is  in
the process of building  a  large incinerator  - Incinerator  #5 -  in
the area  of highest air  pollution.  This incinerator will  emit  over
1,000 tons of  pollutants each year.)  The District would like  to  con-
vert Incinerator  #5 into a combination  trash transfer station  and
pilot recycling plant.

Technical  assistance is  needed  by the District's Department of
Governmental  Services.   Two experts,  one from Solid Waste  and  one
from Air  Pollution Control, should  be assigned to  the District
Government for a  one-month period to  draw up an  implementation
plan to convert Incinerator #5 into a baling and transfer  station
and pilot  recycling plant  by June 1972.

By acting on this proposal, the Administrator could by June 1972:

    a.  Prevent a major source of air pollution in the District.

    b.  Make the District the first city in the nation to handle
    its solid waste without incineration within the city.

    c.  Start a model recycling plant to provide employment to
    people of the inner city.

    d.  Provide an example of "waste being converted to use."

4.  Hater

Train 100 teenagers and young adults from the SPARE program for
sewage treatment and water supply technician jobs (training to
be completed by June 1972).

5.  Noise

The Office of Noise Abatement and Control will conduct a one-year
noise monitoring program.  Specific sources of noise would be
identified and measured as well as general ambient noise levels in
various parts of the city.  A budget of $200,000 should be provided
for this project.

A noise abatement team would be created consisting of five SPARE
personnel.  This team, under the supervision of the EPA SPARE
program, would investigate noise complaints and spot check inner
city areas to identify "noise polluters."  Complaints would be
rectified by voluntary compliance and legal mechanisms.

6.  Pesticides

Carry on community education campaigns through SPARE on the dangers
of pesticides, correct use and storage of pesticides, need for
proper disposal of containers.

7.  EPA Planning Grant to District of Columbia

The Task Force recommends a planning grant be made to the District's
Department of Environmental Services to help make it the most modern,
local environmental protection agency, one responsible to the needs
of the people.  Such a grant would help make the D. C.'s Department
of Environmental Services an exemplary counterpart to EPA on the  local
level, emulating the progressive image of EPA at the national level.

The grant would do much to show the nation by June 1972, through
the national media, that Federal and local levels of government
can bring about achievements through progressive teamwork.

The budget for the District of Columbia Demonstration City  Project
has been estimated as follows:

        Environmental Teams: *

                            198 men                 $1,980,000*
                             66 trucks                 660,000*
                            462 SPARE workers
                              (teenagers part
                               and full time)          462,000*
                            Plastic bags and
                              trash receptables        198,000*

        *(From National Operation Clean Sweep
        budget elsewhere in this Recommendation

                            Noise Monitoring
                              Project                  200,000
                            Planning Grant
                              (1 year)                 200,000
                                      '  Total      $3,700,000

In summary, the D. C. Demonstration City project consists of the
following elements:

    a.  Financial  assistance (grant and contact money).

    b.  Public education assistance (SPARE program).

    c.  Technical  assistance (for air, solid waste, pesticides
        and noise).

    d.  Enforcement (legal) assistance (through the Ombudsman).

    e.  Manpower training (SPARE).

The financial and technical assistance would be provided to the
District's Department of Environmental Services.

The project would be comprehensive to achieve demonstrable results
in solid waste, air, water, pesticides and noise.

      The responsibility for the implementation and operation of the
      various aspects of the program could rest in the hands of appointed
      officials in the responsible program offices  coordinated by the
      Urban Affairs Officer.


The Task Force recommends that a coordination point be established within
EPA that can give focus Con an agency, interagency, inter-governmental"and
EPA-community basis) to our programs on behalf of the inner city.

This coordination point, or Urban Affairs Officer, could be in EPA's Office
of Civil Rights and Urban Affairs, or Office of Planning and Management,  or
preferably in the Office of the Administrator, or under the Deputy Adminis-

This Urban Affairs Officer would have three major functions, and serve
as an interface for three groups:


          1.  The UAO would coordinate the various EPA and EPA-funding
          efforts in the urban core, and insure that the Administrator's
          mandate was fulfilled.

          2.  The UAO would direct non-Program Office projects, as well
          as intermedia efforts in the urban core.

          3.  The UAO in consultation with various EPA and non-EPA
          groups would initiate new thrusts directed at the problems
          of the environment of urban America.


          1.  The UAO would interface with intra-agency groups (regional
          offices, program offices, support offices, Administrator's
          Urban Advisory Council, and staff offices) to provide the
          aforementioned coordination and information on specific areas
          in the urban setting.

          2.  The UAO would interface with the following:   (a) other
          Federal governmental agencies, perhaps through CEQ, and
          certainly OMB, and on a regional level through the FEE,  to
          provide information on EPA activities, and to promote inter-
          agency cooperation in dealing with the urban environmental cri-
          sis;  (b)  State and local agencies concerned with target urban

          areas for essentially the same reasons mentioned above (under
          other Federal  agencies) and to make States and localities
          aware of the expertise, funding, and training available
          through EPA.  In this "interface" the UAO would serve as a
          resource to EPA regional  offices.

          3.  The third interface would be with selected non-governmental
          organizations in the target urban areas":  block councils,
          citizen improvement groups, etc.  Perhaps the major means
          here could be the Environmental Intern Program,* being studied
          by the Committee on EPA Youth Programs.  An Environmental
          Intern would be an inner city youth, who, after having been
          trained, would return to his community with the technical
          and legal expertise to attract contracts and grants money,
          and otherwise mobilize the available governmental resources
          in the pursuit of a better urban environment.

The Task Force feels the UAO essential to any long-term, broad-gauged
commitment on EPA's part to help solve the environmental problems of
the urban poor.


The Task Force recommends that the Administrator create an Administrator's
Urban Advisory Council and/or ask for a President's Urban Advisory Council.
The purpose of the Council would be to:

      1.  Develop a private report for the Administrator or President
      by June 1972, recommending a budget and program package directed
      at inner city needs for incorporation intoiEPA's FY 1974 budget.

      2.  Monitor EPA's progress in carrying out those recommendations
      of the Task Force adopted by the Administrator.

The Council would consist of 12 members from such national urban-oriented
organizations as:  the NAACP, the Urban Coalition, and the Urban League,
and from such environmental-activist organizations as:  the Center for the
Study of Responsive Law, Environmental Action, the Environmental Defense
Fund, and possibly representatives from EPA's Senior Staff Wives Corps.
Necessary staff would be provided from within EPA.

Provision should be made for the Council to meet frequently, and with the
Administrator of EPA, or his designee, on a bi-monthly basis.
*See Recommendation VIII in this section.

Council subpanels would be required to prepare private, but written, reports
for the Administrator on a regular basis.  The reports would contain the
subpanels1 views on EPA progress, or lack of progress, in carrying out those
recommendations of the Task Force on Environmental Problems of the inner
city which have been adopted by the Administrator as action goals.

While such a Council would require a one-year budget of $150,000, the
Task Force believes this Council would be the most effective method
for assuring substantive achievements by June 1972.  The money would be
well spent since the Council would create an avenue for constructive
dialogue and assure progress and motivation.

The Task Force recommends a public advisory group rather than an internal
group for several reasons:

      1.  This public group, containing many experts on urban problems,
      will bring to EPA much needed expertise responsive to the needs
      of the inner city.

      2.  This public group will be most helpful in justifying the
      budget and program, once designed, after June 1972.

      3.  This public group will serve as a constructive and stimu-
      lating sounding board to program personnel.

The Task Force believes that frequent meetings are necessary until June,

The Task Force believes the Administrator's/or President's Urban Advisory
Council should be under the guidance of the Administrator's Liaison Officer.
A small staff must be provided the Council, and the Task Force feels that
in view of the dual function of the Council, two staff members are needed.
One should be from the Office of the Assistant Administrator for Planning
and Management to assure a realistic budget proposal, and one should be
from the Urban Affairs Office for technical coordination.


The Task Force finds that voluntary compliance in EPA is an under-utilized
mechanism for environmental improvement.  The Task Force recommends that
the^Administrator create a Voluntary Compliance Office under the Assistant
Administrator for Standards and Enforcement?Placement of an Office within
this branch of EPA is suggested because of the following factors:

      1.  Voluntary compliance can best be achieved by an office with
      technical and legal background in enforcement.

      2.  The Assistant Administrator for Standards  and Enforcement is
      the individual  most responsible, under the Administrator,  for
      achieving concrete environmental improvements.   What better way
      than through voluntary compliance can a substantive list of
      accomplishments be achieved by June 1972?

      3.  Voluntary compliance is likely to be most  effective if
      housed in a branch of EPA which can wield the  stick if the
      proffered carrot is not accepted.

This office should initiate, explore and coordinate  EPA efforts  toward
voluntary compliance  agreements not only in matters  of air, water, noise,
solid waste and pesticides but in more general matters of environmental
protection as well (for example, preservation of urban park land).  The
office ought to be given the challenge to sign at least two major agree-
ments in each of these areas by June of 1972.  The Task Force further
recommends that prior to, and during, the development of voluntary agree-
ments the office advise and, in turn, receive advice from the Administrator1
Urban Advisory Council to (1) assure that voluntary  agreements are as
progressive as possible, and (2) to avoid criticism  that the terms of the
voluntary agreements  are weak.

The Task Force would  urge that voluntary compliance  be interpreted and
applied in its broadest context.  Voluntary compliance should include
appeals not only to industry but to Federal government agencies  as well.
In fact, appeals can  stimulate effective response from government agencies
at all levels (regional, State, and local), from labor organizations,
from civic and educational groups, and even from individual citizens.

The Task Force has recommended various voluntary compliance actions in
areas of air, noise,  and solid waste in Chapter II.


The Task Force finds  that additional EPA legislative authority is needed
in the areas of:  solid waste, noise, and toxic substances in order to
tackle effectively the environmental problems of the inner city.

The Task Force recommends that EPA accelerate efforts to obtain legislative
authority to fill the following needs:

Solid Waste

      1.  Authority and funds are needed to provide  program support
      to local sanitation departments for improved collection services
      in inner city areas.

      2.  Authority and funds are needed to set up small companies in
      the business of recycling.  (The inner city is naturally suited

      to such businesses  because raw material  is  in abundant supply,  the
      manpower is readily available, and the collection  and distribution
      systems converge in the inner city.   The only elements missing  must
      be provided by government:   mandated markets  for recycled material,
      technical  know-how, encouragement, and seed capital.)
      1.  Authority and funds  are needed to support local  noise control

      2.  Authority and funds  are needed to set and enforce national
      control  standards.

Toxic Substances

      1.  Authority is needed  to prevent problems such  as  those created
      by the use of lead-based paint.


The Task Force recommends the  continuation of EPA's Summer Program for
Action to Renew the Environment (SPARE)  as a_means of implementing
environmental  improvement information-education-and-employment programs
in the inner city!!

To effect change in the inner  city,  residents must be involved.

      1.  Inner city residents need  to be made aware of the hazards
      in their environment and the benefits to be derived  from en-
      vironmental  improvement  programs.   However, this  information
      and teaching  should be carried on  by local  organizations
      and/or neighbors to be effective.

      2.  Inner city residents need  to be made a  part of a working
      team to improve their neighborhoods.  With  this community
      involvement,  programs have effect, meaning, and continuation.

      3.  Inner city residents need  gainful employment.   EPA has the
      making of such a three-pronged program of education-involvement-
      and paid employment in the SPARE program.   The Task  Force has
      found that inner city residents  do not want super-imposed govern-
      ment programs.  They want to be  able to develop their own programs
      suited to their own particular needs and utilizing their own ways,
      ideas, and people.  SPARE projects can be designed to enable com-
      munities to  develop their own  flexible, self-help projects.


                       Background on  SPARE  Program

SPARE, the Summer Program for Action  to Renew the Environment,  was  an
EPA summer work program designed to employ  high-school  age enrollees  in
the Department of Labor's Neighborhood Youth  Corps (NYC)  in work
improving the urban environment.  SPARE gave  teenagers  a  chance to  make
concrete improvements  in their environment.   It also taught them about
environmental issues,  surveys of local environmental problems,  and  work
efforts in environmental improvements.

In its first summer (1971), SPARE employed  approximately  10,000 inner
city, low-income youths, ages 14-18,  in approximately 50  communities.   In
compliance with the NYC program, SPARE enrollees were paid $1.60 per  hour,
usually for a 26-hour  work week.  EPA provided some planning for work  and
educational activities, as well  as technical  assistance.   The Department
of Labor, through its  local NYC sponsor, selected and funded the SPARE
participants.  Most administrative costs and  daily administration came
from the local  sponsor, usually the city government or  Board of Education.

Enrollees worked at a  variety of environmental improvement projects in
their own neighborhoods.  In some cities, like St. Louis, SPARE workers
canvassed homeowners to warn of the danger  of lead poisoning from deterio-
rating lead paint in inner-city homes.  In  Goose Bay, Oregon, students traced
local sewage problems  throughout the  town.   In Indianapolis, SPARE  won
enthusiastic responses in one area when enrollees cleaned up a  rat-infested
four-block area which  had been used as an unofficial dump for nearly  30
years.  And in Cleveland, SPARE participants  joined in  a  major cleanup of
the city's parks and beaches.

In addition to work projects, environmental  education was an important
part of the program.  In Cleveland's  program, for example, many enrollees
spent 40 percent of their time taking a course in ecology for which they
received high school credit; and 45 enrollees in the Cleveland  program re-
ceived prospective college credit for their classroom environmental work
at the local community college.   And, as supplements, participants  took
field trips to environmental protection facilities.  By providing work
supervisors with some  expertise in environmental and community problems,
SPARE projects provided environmental education through on-the-job  training.
For example, Cleveland enrollees were led by  high school  science teachers
and Baltimore students assisted city  health inspectors.

As these projects have indicated, SPARE is  part of EPA's  effort to  help  the
urban poor recognize and solve environmental  problems that concern  them.
Specifically, SPARE recognized that rats, lead paint poisoning, extensive
trash accumulation, and crowding are  as much  a part of the inner city
environment as are air pollution and  water quality control.  As it  developed


out of the Clean Waters Program of 1970 (under the  Office  of Water  Quality),
SPARE expanded the traditional  understanding of environment  to  include
the total environment of a community.

Proposed SPARE Programs for 1972

      1.  In the area of Solid  Waste:   Provide manpower for  a Clean
      Sweep program and increase the effectiveness  of such a program
      by canvassing, informing, and educating the community; and  re-
      lating community concerns about city services to municipal

      2.  In the area of Air Pollution Control:   Monitor air pollution
      content (following a training period), make reports  on specific
      "pockets" containing high quantities of pollutants,  investigate
      pollutant sources, make reports  to city officials.

      3.  In the area of Water  Quality:   Investigate quality of drinking
      water in inner cities, locate contaminant sources, investigate
      run-off in gutters, study health effects on local  residents,
      make reports to city officials.

      4.  In the area of Pesticides:  Survey rodent control  programs
      in inner city and the effectiveness of these  control measures,
      survey use of pesticides  by residents, encourage proper use-
      storage-container disposal measures, suggest  alternative  measures,
      suggest alternative measures of insect control.

      5.  In the area of Noise:  Operate equipment  to monitor noise
      levels (following a training period), report  sources of noise
      and effects on inner city residents, suggest  alternate routes
      for trucking.

The Task Force recommends a two-component SPARE program for  carrying out
an inner city information-education-and-paid employment program.

      1.  Continue the joint EPA-Department of Labor (DOL) SPARE
      program enabling teenagers to work on environmental  projects part-
      time.  This would utilize (DOL)  Neighborhood  Youth Corps  funds to
      pay nearly 10,000 teenagers roughly $10 million over the  next
      year.  EPA funds would be limited to $500,000 for supervision
      and equipment in 50 cities during the school  year, and $2,000,000
      during the summer of 1972 for supervision and equipment in  100 cities.

      2.  The Task Force recommends, as a part of the National  Clean
      Sweep Program, that EPA create a SPARE "Follow Through" Program
      to hire 7,000 teenagers at a cost of $7,000,000 to supplement  the
      cleanup efforts of the "Environ Men."  These  teenagers would  be

      paid for 10 hours of work each week helping to clean,  improve,
      and maintain their neighborhood environment.   These "Follow
      Through" teams would be working in 20 cities  across the nation.
      (See Recommendation I in this section for details  of National
      Operation Clean Sweep.)

The Task Force recommends that EPA recruit in the inner city to provide
minorities with both employment and career growth.

This would involve additional training in entry level positions that
will be primarily filled by minorities.  The recruitment should be in
accordance with EPA's personnel system.  The Office of Civil Rights and
Urban Affairs' Equal Employment Office can serve as liaison between the
Personnel Division and job aspirants.

One promising manpower training development, under consideration by EPA's
Youth Program, is the "Environmental  Intern Program."

Environmental interns would be inner city youths of college age (though
probably without college education) who would spend a year in four
three-month assignments, each assignment would be in a different office
of EPA.  They would learn the complexities of government involvement
in the inner city environment.  Typical assignments would include:

      1.  Contracts Compliance and Section 8(a) Program - learning
      how to attract contract money to the inner city and how to
      assure fair treatment of minority contractors.

      2.  Enforcement and General Counsel - learning in a broad way
      the laws designed to counteract environmental deterioration
      in the inner city.

      3.  Public Affairs - learning how to call attention to, and
      stimulate public concern for, various critical issues in
      the inner city.

At the end of the year, these  interns would generally return to the inner
city where they would work for municipal governments and community organi-
zations  to draw Federal monies and technical expertise to their local

EPA's Equal Employment Office  (within the Office of Civil Rights and Urban
Affairs), under authority of the Manpower Development Training Act of
1962, is already geared toward helping the disadvantaged, semi-skilled
and skilled workers under the  following programs:

The Couple-OJT Program (Institutional plus on-the-job training)

This program is designed to improve the skills of employees on-the-job
and to recruit new employees for entry level  positions.   The program also
combines classroom work with related in-plant training.

Institutional Training Program

This program is conducted in community colleges or vocational  training
schools.  For example, in the Water Programs  a cooperative arrangement
was made with training institutions and publicly-owned local waste treat-
ment facilities which provide the opportunity for "hands on training."
Upon completion of the courses, trainees have a marketable skill  to make
them employable at entry level in the waste treatment control  plants.

Public Service Careers

The objectives of this program are:  secure,  within merit principles,
permanent employment for disadvantaged persons in government agencies
and stimulate the upgrading of current employees, thereby meeting public
sector manpower needs.

Neighborhood Youth Corps

This program is comprised of three main components:  an  in-school program
designed to provide paid jobs for youth inclined to drop out of  school;
a program to encourage youth to remain in school, and a  summer program
with similar objectives.  The program provides an "equivalent certificate"
(comparable to a high school diploma) to those who have  already  left school
and needed work experience and remedial education to be  able to  compete  in
the job market.

It would cost approximately $300,000 to implement a comprehensive manpower
training program.  This would provide salaries for trained personnel,
institutional training for youth involved in  the program, and other re-
lated costs.

The Task Force recommends that the Administrator (or his designee)  include
in his presentation at the June 1972 United Nations Conference on the
Human Environment, Stockholm, a progress report on U.  S. A.  urban environ-
ment achievements.

Since the theme of the conference is the human environment,  the findings of
the Task Force on conditions in our inner cities and the achievements of
EPA should be of value and inspiration to developing countries.  We must
demonstrate to the world that our concern is with the environment of people,
everyone's environment, rich and poor, but especially the environment of
those upon whom pollution falls most heavily.

                     Table  IV-A                               144
      of  Total  Poverty  Population  of 20  Cities

New York, New York
Chicago, Illinois
Detroit, Michigan
Philadelphia, Pennsylvania
Washington, D. C.
Los Angeles, California
Baltimore, Maryland
Houston, Texas
Cleveland, Ohio
New Orleans, Louisiana
Atlanta, Georgia
St. Louis, Missouri
Memphis, Tennessee
Dallas, Texas
Newark, New Jersey
Indianapolis, Indiana
Birmingham, Alabama
Boston, Massachusetts
Denver, Colorado
Seattle, Washington

Black Population
8,151 ,569
% of Pop.
*Not strictly ranked - geographical factor added.





















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    1.   Environmental  Protection Agency  Authority^

        a.  Federal  Insecticide, Fungicide,  and Rodenticide Act,
            as amended,  7  U.S.C. 135-135k.2

            An Act  regulating interstate marketing of  economic
            poisons  and  devices  by  means of  a  registration and
            labeling procedure;  enforcement  provisions explicit.

        b.  Federal  Food,  Drug,  and Cosmetic Act, as amended,
            21 U.S.C.  346,  346a, 348.2

            Relating to  the establishment,  regulation, and/or
            exemption  of pesticide  tolerances  in food  and feed-
            stuffs,  and  in  or on raw agricultural commodities
            shipped  in interstate commerce.

        c.  Section  112  of  the Clean Air Act of 1970,  as amended,
            42 U.S.C.  1857  et seq.2

            Provides authority for  the issuance of national ambient
            air quality  standards for individual air pollutants
           which adversely affect  public health and welfare;
            implicit authority to set air emission standards for
            economic poisons.

        d.  Pending  legislation- Federal Environmental Pesticide
            Control  Act  of  19713, HR 4152, a Bill pending before
            the 92nd Congress.

            An Act to  supersede  and strengthen the Federal Insecticide,
            Fungicide, and  Rodenticide Act.

    2.   Related Authority of  Other  Federal Agencies

        a.  Department of Transportation

            Department of Transportation Act,  Public Law 89-670,
           49 F.C.R.  170

            Provides authority for  regulation  of transport of hazardous
           materials, including pesticides, in interstate commerce.


    b.   Federal Trade  Commission

        Section 5 of the  Federal Trade Commission Act,
        15  U.S.C. 45.

        An  Act regulating the  advertising of economic poisons.

    c.   Food  and Drug  Administration

        Federal Food,  Drug,  and  Cosmetic Act,  as amended,
        21  U.S.C. 321-392.

        (Excepting  Sections  346, 346a, 348).   Authorizes
        monitoring  and surveillance of food for economic poisons.

    d.   Department  of  Agriculture

        Regulatory  authority derived  from a series of Acts;
        USDA  statutory authority is listed in  the  "Research
        and Monitoring Provisions" Section [(B)(2)(c)].

        USDA  regulatory authority no  longer relates  to  pesticides,
        per se (authority transferred to EPA); however, USDA
        retains authority to prevent  the introduction of pests
        into  the United States,  and other activities relating
        to  the control and spread of  pests.

3.   Related Authority  of  State/Local  Agencies

    a.   State Laws4

        (1)  Registration Laws

             These  include those laws which:   (a)  regulate  the
             production and  marketing of pesticides  by  requiring
             compliance with registration and  labeling  criteria
             prior  to  interstate or intrastate commerce; and,
             (b) set  up pesticide  tolerances  for  agricultural
             commodities  sold  within  the particular  jurisdiction.

             These  State  laws  are  generally modeled  after  the
             Federal  Insecticide,  Fungicide,  and  Rodenticide
             Act,  as  amended,  and  are relatively  uniform in
             content.   All except  two States  (Indiana and
             Delaware) now have  pesticide  registration  laws,
             although  not all  States  have  fully  implemented
             the authority granted.


    (2)  Use and Application Laws

         These include those laws which:   (a)  require
         examination and licensing of persons  engaging
         in the business of applying pesticides  (e.g.,
         custom applicators, etc.); (b)  regulate pro-
         fessions concerned with the use  and application
         of pesticides, including consultation services
         and recommendations for treatment (e.g.,
         horticulturists, tree surgeons,  etc.);  and
         (c) 1) prohibit or restrict the  use of certain
         pesticides; 2) require (i) the  purchaser to
         obtain a permit before using highly toxic
         pesticides giving the kind of pesticide to use,
         the concentration permitted, the crop to be
         treated, method of application,  and precautions
         to be observed, and (ii) dealers in "prescription"
         pesticides to be licensed.

         There is considerable divergence among State
         laws of this type, and some 10  States have no
         laws of this nature at all.

b.  Local Ordinances
    A few local governmental  bodies and municipalities
    have adopted ordinances and regulations which,  in
    part, control the use of pesticides.   Perhaps  the most
    common are those which prohibit or restrict the use of
    highly toxic rodenticides or other pesticides  by pest
    control operators in homes, warehouses, and structures.5

    The considerable amount of State and Federal  legislation
    regulating pesticides has reduced the need for local
    ordinances; however, in the 10 or so States without use
    and application laws and in the two States without
    registration laws, local  ordinances are necessary if
    control of pesticides is to be accomplished.


    1.   Environmental  Protection Agency Authority

        a.   Pesticide  Research  Act,  as amended,  16 U.S.C.  742(d)(l).2

            An Act authorizing  studies on the effects  of pesticides
            upon the fish and wildlife resources of the U.S.

        b.   Federal  Insecticide, Fungicide,  and  Rodenticide Act,
            as amended, 7 U.S.C. 135-135k.2

        c.   Section  204(5) of the National  Environmental  Policy Act,
            Public Law 91-190,  83 Stat. 855.

            Authorizes the conduct of general research pertaining to
            ecological systems.

        d.   Sections 104(b)(1)(3), (k), and  204(k) of  The Agricultural
            Trade Development and Assistance Act, as amended,  Public
            Law 480, 7 U.S.C. 1701 et seq.2

            Authorizes Federal  agencies to conduct selective  Federal
            research programs,  explicitly including investigations
            relating to the effects  of economic  poisons,  in foreign
            countries  through agreements with foreign  research in-
            stitutions and universities.  Such programs utilize
            foreign  currencies  generated by  the  sale of surplus U. S.
            agricultural  commodities.

        e.   International Health Research Act of 1960, 22 U.S.C.
            2101-2104; 42 U.S.C. 242f/

            Authorizes the conduct of health-oriented  research and
            research training in foreign countries.

        f.   Section  5(e)(l)(2)  of the Federal Water Pollution Control
            Act, as  amended, 33 U.S.C. 466 et seq.2

            Authorizes research to determine the kind  and extent  of
            effects  on health and welfare which  may be expected from
            the presence of pesticides in the water in varying quanti-
            ties; authorizes the conduct of studies and investigations
            of methods to control the release of pesticides into  the
            environment, including examination of the  persistency of
            pesticides in the aquatic environment and  alternatives

    g.   Section 212 of the Solid  Waste  Disposal Act,  as
        amended, 42 U.S.C.  3254(f).2

        Orders a study on  means  and methods  for storage  and
        disposal of hazardous  wastes,  including toxic chemical

2.  Related Authority of Other Federal  Agencies

        a.   Department of the  Interior  (Bureau of  Sport  Fisheries
            and Wildlife)

            Fish and Wildlife  Act of  1956, as amended, 70  Stat.
            119; Fish and  Wildlife Coordination Act  of 1964,  as
            amended, 48 Stat.  401.

            Authorizes research  and monitoring investigations
            relating to the fish  and  wildlife resources  of the U.  S.

        b.   Department of Commerce (National Marine  Fisheries Services;
            National Oceanic and  Atmospheric Administration)

            Fish and Wildlife  Act of  1956, as amended, 70  Stat.
            119; Fish and  Wildlife Coordination Act  of 1964,  as
            amended, 48 Stat.  401.

            Authorizes research  and monitoring activities  relating
            to aquatic environment and  fisheries.

        c.   Department of^Agriculture  (Agricultural  Research  Service;
            Forestry Service)

            The USDA statutory authority  for research and  regulatory
            activities involving  pest  control is as  follows:

                Organic Act of U.S.D.A.,  1862;
                Hatch Act  of 1887,  as  amended, PL  84-353;
                Mclntyre-Stennis  Act  of 1962, PL 87-788;
                Research and Marketing  Act,  1946,  PL 79-732;
                McSweeney-McNary  Act  of 1928, as amended,  PL  70-466;
                Agricultural Trade Development and Assistance Act
                  of 1954, PL  83-690;
                Control of Incipient  or Emergency  Diseases of Insect
                  Pests or Plant  Diseases, 1937, PL  75-20;
                Cooperation with  Mexico in Screwworm Eradication,
                  1966, PL 89-251;
                Cooperation with  States,  1962, PL  87-718;
                Federal Plant  Pest Act, 1957, PL 85-36;
                Golden Nematode  Act,  1948, PL 80-645;
                Halogeton  Glomeratus  Control Act,  1952,  PL 82-529;

                Mexican  Border  Act  of  1942, PL 77-426;
                Plant Quarantine  Act of  1912, PL 62-275;
                Terminal  Inspection Act  of 1915, PL 63-293;
                USDA  Organic Act  of 1944, PL 78-425;
                Research  Grants - Basic, 1958, PL 85-934; and
                Research  Grants - Special, 1965, PL 89-106.

            Under  these  authorities the  USDA conducts functional
            activities relating to  pest  control and pesticides,
            including the conduct of research in foreign countries.

        d.   Department of Defense

            A.R. 40-5 (preventive medicine) and 420-76  (entomo-
            logical service).

            Army regulations providing guidance for DOD operational
            activities dealing  with the  evaluation of various
            aspects of economic poison use.

        e.   National  Institute  of Environmental Health  Sciences,
            PHS, HEW

            Public Health Service Act, as amended, 42 U.S.C. 201.

            For research on physical and mental diseases and
            impairments  of man; human  health-oriented research

3.   Related Authority of State/Local Agencies

        Research and  monitoring authorities are implicit in the
        State registration laws which  are modeled after the Federal
        Insecticide,  Fungicide, and Rodenticide Act.


1.   Environmental  Protection Agency Authority

    a.  Sections 301, 311,  314,  and 361  of the  Public  Health
        Service Act, as amended, 42 U.S.C.  241  et  seq.2

        Authorizes the awarding  of grants-in-aid to  universities,
        hospitals, and other public or private  institutions,  and
        to individuals for  the conduct of research,  investigations,
        experiments, demonstrations, and studies,  including those
        relevant to human and environmental  effects  of economic
        poisons; provides grants to assist health-oriented State

    b.  Federal Insecticide, Fungicide,  and Rodenticide  Act,  as
        amended, 7 U.S.C. 135-135k.2

        Implicit authority  to let contracts relating to  research
        and monitoring of hazards associated with  economic poison

2.   Related Authority of Other Federal  Agencies

    a.  National Institute  of Environmental  Health Sciences,  PHS,  HEW

        Section 301(d) of the Public Health Service  Act, 42 U.S.C.

        Authorizes grants-in-aid to public and  private non-profit
        institutions, and to individuals, for research on diseases,
        including health significance of economic  poisons to  man.

    b.  National Science Foundation

        The National Science Foundation  Act of  1950, as  amended
        July 18, 1968, PL 507, 42 U.S.C.  1861 et seq.

        Authorizes grants-in-aid to public and  private non-profit
        institutions, and to individuals, for applied  basic re-
        search, including research on economic  poisons.

    c.  Office of Education, HEW

        Environmental Education  Act, PL  91-516, 84 Stat. 1312.

        Authorizes grants and contracts  to public  and  private non-
        profit institutions and  organizations for  research, demon-
        strations, and pilot projects on environmental quality and
        ecological balance, including effects of economic poisons.


    d.   Department  of the  Interior

        Fish  and  Wildlife  Act of  1956, as amended, 70 Stat. 119;
        Fish  and  Wildlife  Coordination Act of 1964, as amended,
        48 Stat.  401.

        Implicit  authority for  contracts relating to monitoring
        of fish and wildlife resources for hazardous substances
        such  as economic poisons.

    e.   Department  of Agriculture

        The statutory authorities of the USDA are listed under
        "Research and Monitoring  Provisions," (B)(2)(c).

        Under various of these  authorities the  USDA is authorized
        to award  grants-in-aid  and  let contracts for research
        relating  to pest control, and for other purposes relevant

    f.   Department  of Labor

        Manpower  Development Training Act of 1962, 42 U.S.C.
        2571  et seq.; Emergency Employment Act  of 1971,
        PL 92-54.

        Authorizes  grants-in-aid  and other assistance at the
        Federal,  State, and local levels for training and
        programs, including those environmentally oriented.

    g.   Department  of Transportation

        Department  of Transportation Act, Public Law 89-670,
        49 F.C.R. 170.

        Provides  implicit  authority to award grants and contracts
        for the purpose of conducting research  into improvements
        of the regulatory  control of the transport of hazardous
        materials such  as  economic  poisons.

3.   Related Authority of State/Local Agencies

      Implicit in the State registration laws is the authority  to
      let contracts,  as needed, for the  research and monitoring
      activities  needed to support  the implementation of the  Act.

                               (for Appendix)
1.  The Environmental  Protection Agency was  established  by Reorganization
    Plan No.  3 of 1970 (July 9,  1970);  copy  in  Appendix  III.

2.  Copy of legislation in Appendix III.

3.  Copy of Bill  and transmittal letter outlining its  salient  points
    in Appendix III.

4.  Listing of Pesticide Laws,  by States,  in Appendix  III.

5.  Frear, D.  E.  H.  (ed.), Pesticide Handbook-Entoma,  p.  36,  (1971).

6.  Rohrman,  D.  F.,  "Pesticide  Laws and Legal  Implications  of  Pesticide
    Use," National  Communicable  Disease Center, (1968),  p.  18.

  EPA-CEQ Issue Paper



      July 9, 1971

                         EPA-CEQ Issue Paper


                       WATER SUPPLY LEGISLATION
     This paper was developed to accompany the EPA-CEQ legislative
proposal on water supply during review and discussion within the
Executive Branch.  The rationale for the proposed Federal  program and
the elements of the legislative proposal are presented.  In addition,
the paper presents the rationale and implications of the proposed
State program grant authority and considers anticipated costs and
benefits associated with the proposed Federal program.
                            I.  Background
     The Federal government has a long standing history of involvement
with community water supply systems through administration of the inter-
state quarantine regulations under the Public Health Service Act.  We
are now proposing to improve that involvement through a more effective
Federal program - a program designed to enhance State and local  program
effectiveness in assuring adequate supplies of safe drinking water.
The need for program improvements was documented by the Community Water
Supply Study which was originally undertaken in response to an OMB
(then BOB) initiative.

     Following publication of the Community Water Supply Study in
August of 1970, a joint EPA-CEQ study of water supply problems was
undertaken during the early part of 1971.  The result of that effort
was an issue paper, dated May 11, 1971, which summarized a number of
facts concerning the problem and outlined alternative solutions and
legislative options.

     Briefly, the major problems were found to be as follows:

     A.  A number of communities - particularly communities of less than
5,000 population - are delivering potentially dangerous water.  Based
on extrapolation of the findings of the Community Water Supply Study,
the phenomenon affects approximately 5.4% of the national population
served by public water supply.  Problems are generally related to bac-
terial contamination and/or harmful quantities of toxic or hazardous

     B.  Nearly 25% of the 160 million persons served by community
water supply systems are using water which exceeds recommended drinking
water limits for one or more parameters.   Although consumption of such
water is not considered to represent an immediate threat to health,
aesthetic (related to taste and odor), economic and convenience (related
to excessive mineralization) problems exist, and such water supply
systems may not provide adequate protection over the longer term.

     C.  Most community water supply systems, including some large
systems but most prevalent with smaller community systems, evidence
deficiencies relating to construction, operation, maintenance and
surveillance which may inhibit the ability of the suppliers to deliver
water of an acceptable quality on a continuing basis.

     When the magnitude of current national water supply problems was
considered in light of anticipated future conditions, it became apparent
that new and expanded Federal leadership and assistance should be given
serious consideration.  A number of options, ranging from no additional
Federal action to strong Federal regulatory authority were considered
and presented in the previous issue paper.

     Publication of the Community Water Supply Study led to national
concern about the quality of drinking water.  As a result, five Con-
gressionally sponsored bills - each of which proposed various extensions
of Federal authority in the area of drinking water supply - were in-
troduced in the current session of Congress.  The Administrator of EPA
testified on the subject of drinking water before the House Committee
on Interstate and Foreign Commerce, Subcommittee on Public Health and
the Environment, on May 26, 1971, indicating that EPA was currently
studying the problem and would consider the need for both legislative
and administrative actions.  Since that time, the House Committee has
prepared draft water supply legislation.


    II.  Rationale for the Proposed Federal  Water Supply Program

     Development of the proposed Federal  program was premised on the
fact that basic and primary responsibility for maintaining,  operating
and regulating public water supply systems rests with State  and local
government.  Past Federal  involvement has dealt with establishment and
limited enforcement of standards to prevent interstate spread of
communicable disease, research, and technical  assistance and training
to enhance State and local capabilities.   The  proposed program envisions
a continuance of these basic Federal-State relationships but is designed
to more effectively deal with major institutional deficiencies related
to the current water supply situation.

     A substantial majority of existing water  supply problems may be
attributed to the general  ineffectiveness of State and local water
supply programs, which are largely understaffed and inadequately funded.
This situation, on the other hand, may be attributed to a general lack
of public awareness of the sometimes tenuous state of public water
supply systems.  Most people - because of inadequate surveillance of
water supply systems and lack of procedures  for informing the public -
are simply not aware of the quality of their drinking water  or of the
dependability of their water supply systems.  As a result, there is
little incentive for public support of expanded regulatory programs.

     The problems of inadequate regulatory programs and lack of public
involvement are thus interrelated, and there is every reason to believe
that neither State and local governments  nor the private sector will be
able to resolve these problems without additional Federal leadership
and assistance.  In view of this, it seems unreasonable to wait until
existing water supply problems become more serious or new ones emerge
before taking corrective action.

     The proposed program would provide the public and local and State
government with new incentives for action and  more effective means of
control.  The program would involve and rely upon the public and each
level of government in the following ways:

     A.  Improved public awareness of drinking water problems would be
achieved through a provision whereby each community or private water
supply system found out of compliance with established standards would
have to so notify its customers.  This would allow and enchance public
choice between accepting known problems or petitioning local government
for improvement of drinking water quality.

     B.  Better local support and new forms  of Federal assistance would
lead to improved programs for regulation  of water supply systems.  As
a result, the states would be in a better position to deal with the
public's demands for adequate quantities  of safe drinking water.

     C.  The Federal  role would be largely stimulatory in  nature,
involving financial and technical  support of State regulatory programs.
Enforcement authority would be available to deal  with problems of  an
imminent and substantial nature in cases where the States  are unable
to implement remedial actions.  In most cases, however, remedial actions
would result from public demands and would be dealt with at the State
and local levels of government.

     A strengthened Federal role in the water supply area  is in line
with current trends in safeguarding the general health and safety  of
the population.  As a part of these trends, Federal  agencies have  set
and enforced standards for drugs,  foods, air quality, mine safety, etc.
The water supply issue, presenting some of the same health dangers,
would also seem to justify continued Federal involvement.   Safe water
supply will be an area of increasing public concern in the overall
environmental field.   The question appears to be one of how extensive
that Federal involvement should be.

     After considering several alternative levels of future Federal
involvement, we find extension and improvement of Federal  drinking
water standards and more effective Federal enforcement authority,
coupled with financial and technical support to State water supply
programs, to be the appropriate course of Federal action.   The rationale
for this broader Federal role is as follows:

     A.  Health threats in water are not limited to the transmission
of communicable diseases, currently covered under interstate quarantine
provisions; they include the harmful effects of toxic chemicals and
other hazardous materials as well.  Therefore, Federal authority should
be extended to cover these constituents.

     B.  Insuring adequate supplies of safe public drinking water  is
largely a State and local problem.  However, because of the mobility  of
our population, interstate affects as result of consumption of nearly
any public water supply are probable.  Direct Federal enforcement  in-
volvement under the EPA-CEQ proposal would focus on "imminent and
substantial" dangers, which can affect residents other than those  of  the
state or community concerned.

     C.  Extension of present Federal enforcement authority, which is
currently limited to prohibiting interstate carriers from using unsafe
supplies rather than initiating action against the water supply system
itself, is proposed because interstate carriers represent only one means
by which interstate health threats can occur.  In addition, current
authority is not directed to assist the 82 million residents served
directly by  interstate carrier water supply systems.

     D.  For chronic health effects,  which require long-term exposure,
the proposal would continue to rely on direct State regulatory action.
We would provide the Federal  financial support and increased technical
assistance to State water supply programs to enhance the capability of
states to deal with their problems.  Promulgation of more comprehensive
and more stringent drinking water standards will  place increased
demands on these now relatively ineffective programs.   Thus, any new
Federal initiative to improve drinking water quality must include a
commitment for Federal  assistance in  the development and operation of
effective State programs in order to  insure effective implementation
of drinking water standards.

     E.  The research,  technical assistance and training provisions are
a continuation of the existing authority.  The basic purpose for in-
cluding these provisions in the proposed legislation is to secure a
comprehensive bill.

   III.  Elements of the EPA-CEQ Water Supply Legislative Proposal
     Major elements of the EPA-CEQ legislative proposal  and explanatory
notes are as follows:

     A.  Federal Standards

         1.  The standards would include drinking water quality con-
stituent limits as well as standards for water supply treatment and
distribution facilities and their operation, maintenance and surveillance
to assure that the water quality constituent limits are met consistently.

         2.  The standards would be applicable to all public water supply
systems, not just those serving interstate carriers.

         3.  The standards would distinguish between those violations
which represent an imminent and substantial danger to health and those
which represent less than adequate protection over the long-run, but
appear to present no immediate threat to health.  This distinction
concerning the nature or degree of threat would serve as a basis for
triggering Federal regulatory action in the absence of appropriate
State action.

         4.  The Federal standards would not deal with the aesthetic,
economic and convenience problems - such as taste and odors, and other
similar non-health related problems - other than advising as to the
preferability of such limits, as is done under current standards.   We
see no direct Federal regulatory role or exertion of pressure on states
or communities to achieve such standards.

     B.  Federal Enforcement

         1.  The primary responsibility for enforcing compliance with
the standards would rest with the states.  In all cases, the states and
communities would be relied upon to enforce against all violations which
did not represent a substantial danger to health.  State regulatory
capability would be strengthened through Federal program grant support
described in Section IV of this paper.

         2.  Despite the primary State and local enforcement responsi-
bility, a strong Federal backup role is necessary.  We already have a
history of Federal enforcement with respect to supplies serving inter-
state carriers.  An extension of this currently limited authority is
proposed, but only in cases of imminent and substantial dangers to

         3.  Federal enforcement authority would be invoked only in
cases where a violation of standards representing an imminent and
substantial danger to a health occurred, and after determination that
State remedial  action was not adequate.

     C-  Nature of Enforcement and Regulatory Action

         1.  As a part of an approved State program plan (see item D.3.
below), the Federal government would require inclusion of a provision
whereby each community or private water supply system found out of
compliance with standards would have to so notify its customers, in
transmitting water bills or by other appropriate means.  Where the
State does not  have such a requirement - and therefore no approved
program plan -  the Federal government could post appropriate notice,
even in those cases where no imminent and substantial danger to health
exists.  This provision would be the full extent of Federal regulatory
action in situations of less than imminent and substantial  danger to
health.  It is  proposed only for the purpose of assuring that the
public is notified when a water supply system is found to be out of
compliance with standards so that citizen remedial  actions  may be
instituted in the affected community.

         2.  In all cases where an imminent and substantial danger to
health came to  the attention of EPA (through the State program plan or
other means), EPA would assure that the following actions would be taken:

             (a)  Appropriate notice would be posted in the affected

             (b)  Use of the substandard water on interstate carriers
would be prohibited;

             (c)  The Food and Drug Administration  and the  Department
of Agriculture  would be notified, with a recommendation to  prohibit use
of the water under their authorities (e.g., use of water in bottling
and food processing); and

             (d)  The adequacy of State action to secure remedial
measures would  be reviewed.

         3.  If State action were adequate, no further Federal  action
would be taken.

         4.  If State action were inadequate, direct Federal  enforce-
ment action would be taken.   The proposed authority would provide an
opportunity to  issue compliance orders or to bring  civil suit.   These
measures would  be designed to induce community remedial action  and
would include the following forms of injunctive relief:


             (a)   Limitations  or prohibition of certain  uses  of
unsafe water;

             (b)   Prohibition  of new connections to  the  substandard
water supply system;

             (c)   Holding of water supply user charge receipts  in
escrow until remedial  action is  taken;  and

             (d)   Other suitable remedies.

         5.   Other proposed regulatory  provisions would  include:

             (a)   Reservation  of authorities in the  Public Health
Service Act to control  interstate spread of communicable disease;

             (b)   Opportunity  for EPA entry and inspection of any
water supply facility,  after reasonable notice and at reasonable  times,
to determine compliance with Federal standards; and

             (c)   A provision  requiring Federal installations to
adhere to those standards relating to imminent and substantial  threats
to health.

     D.  State Program Grants

         1.   Since a major deficiency in the national water supply
situation relates to the weakness of State programs, one component of
the legislative proposal is State program grant support.  An  initial
program of three-years  duration  is proposed at the following  funding

                  FY 73 -  5 million dollars

                  FY 74 -  7 million dollars

                  FY 75 - 10 million dollars

         2.   The initial program would  provide formula grants (allocated
primarily on the basis  of population),  requiring non-Federal  matching
funds ranging from one-third to  two-thirds of total  program costs
(matching ratios determined primarily on the basis of per capita  income).
These provisions would be very similar  in nature to those of Section  7
of the Federal Water Pollution Control  Act.

         3.   In order to be eligible for program grant support, States
would be required to:

             (a)  Develop and submit for approval  a program plan
which provides for administration of the plan by the State agency;
sets forth plans, policies and procedures to be followed;  and provides
for appropriate accounting, budgeting and other fiscal  procedures for
proper administration of the plan.

             (b)  Adopt drinking water standards the same as or more
stringent than those promulgated by the EPA Administrator.  (States
could qualify for program grant support during the first year of the
program by agreeing to adopt appropriate standards in those instances
where State legislative sanction would be necessary.)

             (c)  Adopt appropriate regulations and procedures which
can reasonably be expected to ensure that public water supply systems
will comply with the standards.

             (d)  Report annually to EPA the status of standards com-
pliance in each community.  Reporting categories would be:  (i) in
compliance with standards; (ii) presently in marginal compliance, but
required to take remedial action in the foreseeable future; (iii) in
violation, but not creating a substantial danger to health; and (iv)
in violation and creating a substantial danger to health.   These annual
reports would serve to focus attention on areas where Federal regulatory
action might be needed [category (iv) above].

             (e)  Implement a standards violation notification system
whereby each community or private water supply system found to be out
of compliance with standards [categories (iii) and (iv) above] would
have to so notify its customers, in transmitting water bills or through
other appropriate means.

     E.  Research, Training, Technical Assistance, etc.

         1.  It is proposed to have a general authorization for these
activities, rather than specific authorized funding levels.  This will
provide more flexibility for EPA choice of priorities in administering
its budgetary resources.

         2.  EPA already has general authority, and is conducting these
activities under the Public Health Service Act.

      IV.  State Program Status and the Need for Federal  Support

     The Community Water Supply Study and subsequent  analyses  have  very
clearly shown that a large majority of our current water  supply problems
are operational in nature and could be significantly  lessened  by  im-
proving the capabilities of State and local  water supply  programs.
For this reason, a significant component of the proposed  Federal  program
relates to State financial and technical  assistance.

     A.  Current Status of State Programs

         Many State water supply programs are currently understaffed
and inadequately funded to meet their primary responsibilities for
insuring adequate supplies of safe drinking water. The impact of this
situation is felt severely at the local level of government in the  form
of ineffective technical assistance and laboratory support, inadequate
water treatment plant operator training, and poor surveillance of
operating water supply systems.

         In June of this year, the EPA Water Hygiene  Program conducted
a study of State water supply program expenditures and found that total
1970 expenditures for the fifty states and six territories amounted to
approximately $10 million.  These expenditures translate  to a  national
per capita expenditure of 6.3 cents per person served by  public water

         A state-by-state analysis of these data shows that State
expenditures (excluding the ocean islands, some of which  have  very  small
populations served) ranged from as little as 1.3 cents to 18.2 cents  per
capita served.  About 40 percent of the states (23) provide less  than
5 cents per capita served, one-third (19) provide between 5 cents and
10 cents per capita and the remaining states (14) provide in excess of
10 cents.

         Data concerning 1960 State program expenditures  were  also
collected as a part of this study.  After adjusting the value  of  the
1970 dollar to that of the 1960 dollar in terms of the services  it  could
purchase, it was found that the per capita expenditures (based on total
population as opposed to population served by public  water supply)  in-
creased by only 14% during the 10-year period.  However,  when  considering
that about 15% more people are now served and that the number  of
community water supply systems has approximately doubled  during  the
past decade (primarily due to the proliferation of small  systems),  this
rate of increase in expenditures appears insufficient.

         Although per capita expenditures can be somewhat misleading
when applied to any specific state because of the many local  variables,
previous studies by the EPA Water Hygiene Program, in which detailed
analyses of several State programs were performed, have indicated that
a fully effective State water supply program would require funding in
the vicinity of 20 cents per capita served.  (This estimate appears
reasonable when compared with the actual 1970 expenditures of approxi-
mately 18 cents per capita by State water pollution control programs -
after program needs and differences in the programs are taken into

         On this basis then, it can be stated that the states should be
spending approximately $32 million per year on water supply programs,
as compared to current expenditures of approximately $10 million per
year.  It would be unrealistic to assume that the states will fill  this
$22 million per year gap - particularly in view of current State fi-
nancial problems.  For this reason, we feel that Federal financial
support should be provided to supplement and, to the extent practicable,
increase the level of State program funding - contingent upon the
adoption of appropriate enabling and regulatory authority, regulations,
policies and procedures and the development, implementation and operation
of effective programs.

     B.  Rationale for Proposed State Program Grant Support

         The basic rationale for proposing a program of Federal fi-
nancial support to the State water supply agencies is that we feel  the
states could significantly lessen water supply problems by implementing
effective control programs at the State and local levels of government.
These programs are currently inadequate and ineffective, and they are
not now satisfying their primary responsibilities for insuring adequate
supplies of safe drinking water.  With a program of Federal leadership
and assistance in the development of effective State programs, the
states could better fulfill their responsibilities.

         The Environmental Protection Agency is currently providing
State and local program grant support in many of its environmental
programs - including air pollution control, water pollution control,
solid wastes management planning, etc.  As a result, we have gained
experience in the formulation and administration of such programs.
Each of these existing programs were studied during our consideration
of alternative approaches to be applied in the area of State water
supply programs.

         Consideration of several key issues, discussed below, largely
shaped our proposed program:

         1.   Duration of_ Program Authorization.   Because the proposed
program is new and because several  proposals  for combining various  forms
of program grant support are under  consideration both within and outside
EPA, we feel that the program authority should be of relatively short
duration.  Our proposed three-year  authorization would thus allow subse-
quent evaluation of the program in  light of our experience with the State
water supply agencies and would permit early  alteration of the program
should a new approach to administration of program grants be adopted.

         2.   Type of Grant.  Three  general types of grants were considered:
project grants (which provide the greatest leverage for Federal influence
and development of the grant recipient's program), straight formula grants
(which have their virtue in simplicity and ease of administration), and
formula grants modified by bonus provisions (similar to that currently
proposed in the area of water pollution control  program support).  We
feel that a straight formula grant  provision  with language similar to
that of Section 7 of the Federal Water Pollution Control Act would be
most appropriate during the initial  three-year phase of the program.  Upon
evaluation of our experience during this initial phase, we could modify
the program - possibly toward bonus provisions to provide incentives for
development of desirable control program elements.

         3.   Magnitude of the Program.  A state-by-state analysis of the
financial impact of alternative Federal funding levels was conducted on
the basis of the allocation equations and matching ratios specified in
Section 7 of the Federal Water Pollution Control Act.  Summary results of
that analysis are shown in Table  1.  The analysis indicated that a program
of more than $4 million or $5 million in the  first year would place a
significant number of the states in the position of requiring additional
non-Federal  funds to meet minimum matching requirements.  With an advance
indication of these needs for additional funds, however, it would appear
reasonable that most of the states  could obtain the necessary funds (which
would amount to about $2.7 million  or a 26% increase above current ex-
penditures)  over the three-year period.  As a result, a $5 million initial
program is proposed, with increases to $7 million and $10 million over the
subsequent two years.  This program would provide an incentive for increased
non-Federal  spending in more than half of the states and would result in  a
more than doubling of expenditures  to 14.2 cents per capita served.


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                     V.   Program Costs and Benefits

      A.  Program Costs

          The EPA budget now pending before the Congress contains  a re-
quest of $4.6 million for the Water Hygiene Program in fiscal  year 1972.
The extent to which various aspects of the program will  be increased over
the next five years has  not yet been determined, although preliminary
estimates of future resource requirements for the program are  currently
under internal review.  It can be assumed that there will be some  increase
in Water Hygiene budgets in future fiscal years, but the magnitude of these
increases will have to be determined in competition with other EPA programs
in relation to overall EPA ceilings and allowances.

          If the proposed legislation were enacted, certain additional
increases over and above those which might be required under existing
legislation would be called for.  These increases fall into two categories:
those that would be mandatory and those that would be desirable in view
of our increased commitment to the program as a result of the  new  legis-

          The mandatory  increases would be required to fund the new State
program grants (together with certain additional administrative costs)
and to increase Federal  enforcement efforts as a result of broader enforce-
ment authority.  The commitments necessary as a result of the  new  legis-
lation are summarized as follows:

                                    Additional Resources Required  ($l,000's)
                                     FY 73   FY 74   FY 75   FY 76   FY 77

      State Program Grants           5,000   7,000  10,000     *       *
      Grants Administration            250     300     400     *       *
      Enforcement                      800   1,000   1,500   1,500   1.300

          TOTALS                     6,050   8,300  11,900   1,500   1,300

          *No commitment of Federal funds would be involved
          inasmuch as authority for State program grants is
          not being requested beyond FY 75.  It would be reasonable
          to assume, however, that reevaluation of the program in
          FY 75 would indicate the need for continued State program
          support at a level of $10 million to $15 million annually
          in future years.

          The implied Federal commitment for an expanded water supply pro-
gram as a result of new legislation could also absorb additional costs in
other program elements such as research, technical assistance and  training.
These costs would not be mandatory, however, and would be determined in
light of other EPA program priorities on a discretionary basis.

      B.  Program Benefits

          The true measure of anticipated benefits attributable to the
proposed program would be expressed in terms of reduced incidence of
waterborne disease and health effects, and in terms of reduced societal
costs associated therewith.  However, our ability to precisely quantify
benefits of this type on an incremental basis is limited.  Epidemiological
surveys have yet to define a true demarcation between infection or disease
per se and economically critical physical disability.  The major cost to
society of waterborne disease and illness is probably not the cost of
medical treatment or even time lost from work, but the 365 days spent each
year in semi-productive work due to chronic disease and illness.

          The correlation between water supply and disease and toxicity
is a complex matrix of cause and effect, interrelated with innumerable
other factors.  However, the downward trend of enteric disease with
improved water supply technology is universal, irrespective of per capita
income and health expenditure.  These trends are supported by incontro-
vertible laboratory, clinical and epidemiological evidence that water is
a major carrier of disease-bearing organisms and toxic chemicals.

          Even though no quantitative assessment of program benefits is
available, several significant - although not mutually exclusive - antici-
pated benefits can be described.  Enactment and implementation of the
proposed legislation could be expected to result in the following:

          1.  Broader Preventative Program Coverage of_ the Population.
Current Federal enforcement authority under the Public Health Service Act
is limited to prohibiting interstate carriers from using unsafe water
supplies, but is not directed toward protection of the 82 million residents
served by interstate carrier water supply systems.  The proposed standards
and regulatory authority would not only provide better protection for these
82 million people, but would serve to protect all of the 160 million people
served by public water supply systems.

          In addition to broader population coverage, the new standards
would provide much broader coverage in terms of toxic materials and other
pathogenic microorganism constituent limits and would cover water supply
treatment and distribution facilities and their operation, maintenance and

          2.  Reduced Waterborne Disease Outbreaks and Health Damage.
Extrapolation of findings of the Community Water Supply Study indicated th.at
approximately 5.4% of the 160 million people served fry pubYIic water supply
systems are consuming water considered to be potentially dangerous,  and
some 274,000 persons  (or 3.3% of the 82 million  people served by interstate
carrier systems)  are  consuming water now prohibited under interstate quaran-
tine regulations.

          During the ten-year period 1961-1970, there were 128 known out-
breaks of disease or poisoning attributed to drinking water.   Of these,
35 outbreaks involving 39,810 cases of illness were attributed to drinking
water from public water supply systems.  Nearly half of these outbreaks
were caused by contamination of distribution systems, and the causes of
most of the remaining outbreaks were evenly distributed between inadequate
treatment facilities and improper control of treatment processes.  About
one waterborne outbreak that we know about occurs per month with something
over 100 persons becoming ill.  Some of the illness is quite  severe and
about two deaths per year are attributed to waterborne outbreaks.

          Although we do not have adequate data on which to base a prediction
of the anticipated reduction in waterborne disease outbreaks  and health
damage, we are convinced that some reduction will accrue as a result of  the
proposed program.  Many of our current water supply problems  are operational
in nature and could be rectified rather easily if they were first recognized
as problems and if pressure for remedial action were instituted through
strengthened regulatory programs and increased public awareness.

          3.  Enhanced Opportunity for Citizen Choice Through Public
Awareness.  The proposed program is designed to bring about improved drinking
water quality throughout the nation - but largely at the option of local
citizens who would be expected to bear the burden of most of the additional
costs of safer drinking water.  We believe that the proposed approach of
informed citizen decision, coupled with strengthened State and local regu-
lation of public water supply systems, has many advantages over both the
current situation as well as the less desirable alternative approach of
strict imposition of Federal regulation upon local jurisdictions.

          4.  Better Capital Investment Safeguards.  The Department of
Commerce in 1967 estimated the^ capital investment in public water supply
facilities to be about $50 billion.  When this investment is considered
in relation to the 160 million people served by community water supply
systems, we find an average investment of $312 per capita served.

          Most of the investment is in municipally-owned and operated
public water supply systems and is thus considered to be part of the social
overhead capital comprising basic public services, such as police, public
health, fire protection, etc., that are necessary so that other productive
activities may function in a specialized society.  The industry, though  large,
is largely non-profit and in many cases tax-supported, which has limited the
amount of funds available for overseeing the construction, operation,
maintenance and surveillance of water supply facilities.

          As a result of these minimal administrative overhead expenditures,
many water supply facilities are inadequately designed and constructed,
improperly operated, and poorly maintained (findings of the Community Water

Supply Study support  these  contentions).  The proposed program  -  through
improved standards, strengthened State regulatory programs,  and better
public awareness of water supply problems - would serve not  only  to correct
many of these current deficiencies, but to prevent them from occurring in
the future.  Over  a period  of time the public costs saved as a  result of
reducing and minimizing  the rate of depreciation of these facilities could
be substantial.