Springfield, Virginia
April 8-9,1980
Prepared by:
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
August 1980

Speaker	Page
First Day
Dr. Stephen J. Gage	1
Mr. Douglas M. Costle	3
Dr. James N. Galloway	9
Dr. El 1 is B. Cowl ing	27
Mr. Ray Robinson	81
Mr. Lowell Smith	90
Dr. Wal ter A. Lyons	100
Dr. Kenneth Demerjian 	 112
Dr. Steven R. Reznek	130
Question and Answer Period 	 149
Second Day
Mr. David R. Hawkins	183
Mr. Walter C. Barber	197
Commissioner Jerry English 	 198
Mr. James K. Hambright	211
Mr. Harry H. Hovey	241
Dr. T. Craig Weidensaul	264
Open Remarks	270
Mr. David G. Hawkins	326

Dr. Gage: Ladies and Gentlemen, I would like to call this session to
order. I am Steve Gage the Assistant Administrator for Research and
Development. I am very pleased to welcome you here to this historic
meeting on acid rain. During the next two days, we hope that all of us
will gain a much better insight into the acid rain problem and learn
more about what can be done to lessen its impacts.
As many of you are aware, this meeting follows, by less than a
month, an important scientific meeting which was held in Norway. From
that meeting we know that our state-of-the-knowledge remains incomplete,
but that our state-of-the-knowledge is indeed changing very rapidly.
There are now hundreds of scientists in Sweden, Norway, Canada, England,
Germany, the United States, and other countries working on this problem.
I am convinced that during the next few years we will see a dramatic
advance in our understanding of the acid rain problem. I am also convinced
from what we have learned, that the problem we will be discussing for
the next twenty-four hours is not just a passing fad--it will occupy our
attention well beyond this day and probably for most of the decade of
the 1980s.
The impacts of acid precipitation affect wide geographical areas in
virtually the entire aquatic and terrestrial ecosystem. Acid rain has
the potential to cause severe economic damages which can only become
more costly should we delay in recognizing its full scope. Most importantly,
it is not clear, at this time, whether the impacts of acid rain are, for
all practical purposes, reversible. So it is very important that we
begin today to establish a dialogue about this problem, and I invite you
to join with us in seeking the best approaches for its solution.

Before we begin, I would like to introduce the other members of
the EPA team who are here. My cochairman for this two day session is
Dave Hawkins, and I would like to introduce Walt Barber; David is the
Assistant Administrator for Air, Noise, and Radiation, and Walt is the
Deputy Assistant Administrator for Air Quality Planning and Standards.
Also I should recognize Bruce Jordan from Walt's office who has worked
very hard to arrange this meeting. Also on the program this afternoon
are other members of the EPA staff, one is my Deputy Assistant Administrator
for Environmental Engineering and Technology, Steve Reznek, and others
are Lowell Smith, Ken Demerjian, and Dennis Tirpak who has been coordinating
the acid rain research within the Office of Research and Development. I
also want to recognize the person to my left, Ray Robinson, the Assistant
Deputy Minister of the Environmental Protection Service of Environment
Canada. I will hold the introduction of my boss until he begins his
opening remarks but let me just make a couple of other procedural comments.
Because many of you are interested in the status of the President's
Acid Rain Research Plan, I would like to point out that it has been
distributed for review within the Federal agencies and will be available
shortly for general distribution to the public. We will be having
public meetings on the plan and will have a much greater opportunity at
that time to go into detailed comments on research activities.
Last, I would like to call to your attention the procedures for
conducting this meeting. In the interest of time and in the interest of
a good exchange among all of us, we have asked that only official
representatives of the States participate in the discussions. We will
certainly welcome written comments and questions from other individuals

who would like to submit them. Time permitting, we will ask the panel
members and State representatives to address these comments and questions
during the course of the conference. With that, I would like to turn
the program over to the Administrator of the Environmental Protection
Agency, Douglas M. Costle, who will make the opening remarks for the
Mr. Costle: At the risk of being talked back to by the microphones,
I will try to speak up. First, I would like to add my welcome to that
which Steve Gage just extended both to participants and observers who
have come here to discuss strategy for resolving an increasingly serious
environmental problem, acid deposition. The widespread interest in this
conference and the fact that so many of us are packed into this room
says something about the depth of concern about the problem.
I want to take this opportunity to extend a special welcome to the
delegation from Canada led by Ray Robinson. Their attendance today
continues the spirit of cooperation which has increasingly characterized
our relations on air pollution issues.
This conference will be divided into two sessions. Our focus today
is to establish a mutual understanding of the causes and the effects of
acid rain. We are fortunate to have with us Dr. James Galloway and Dr.
Ellis Cowling, two of the most respected experts in this field. Tomorrow
we plan to lay on the table some approaches to dealing with the problem.
In addition, representatives from five States will address issues from
their perspective.

I want to emphasize that the purpose of this meeting is to open a
dialogue between the States as well as between the States and EPA. We
have left open a lot of time for discission and I urge that it be lively;
that it be unrestrained; and that it be positive and productive. I have
two main objectives for this meeting. The first is to establish a
mutual understanding of the causes and the effects of acid deposition,
the second is to lay out on the table for debate a number of options we
are considering to deal with the problem.
Our knowledge of acid deposition is not perfect. As one scientist
recently put it to me, the problem has gradually "snuck up" on us in the
last few years. Extensive research is now underway by government, by
industry, and by independent scientists both in the United States and
abroad. For example, last August the President intensified federal
research activities by establishing the Acid Rain Coordination Committee
to oversee a ten year, one hundred-million dollar budget. Many States
have set up monitoring programs to assess the impact of acid deposition
within their borders. In several other countries, particularly the
Scandanavians, already have compiled some complete and dramatic information
about acid deposition affects.
0 While there is much we do not know, we do know acid deposition
can and has destroyed lake and stream ecosystems killing fish
and other water life.
0 Lakes in Northern Minnesota, about 200 lakes in New York, and
many hundreds of lakes in Canada already are acidified and
their fish populations are shrinking or are extinct.

° Headwater streams in the Appalachian Chain from Georgia to
Maine are becoming acidified.
0 We know some soils are being damaged over time due to leaching
of minerals and nutrients.
° We know stone buildings and monuments are eroded more rapidly
by acid rain.
° We know that sulfur mist from power plants is contributing
significantly to poor visibility in the Northeast which averages
now less than eight miles.
0 We suspect some important crops can be damaged by acid deposition
and that others may be injured by acidified soil.
° We suspect growth of forests may be reduced.
° We suspect that in the long term some drinking water supplies
may be contaminated by toxic metals leached from the soil by
acid deposition.
What we know and what we suspect about acid deposition tells us
that we are faced with a genuine and serious environmental problem. It
is a problem which will, if allowed to grow unchecked, carry substantial
economic costs. Further research and development of new control technolo-
gies obviously must continue, but, in my judgment, we should not let the
problem get worse while we learn how to make it better. I have discussed
my concern about acid rain with the President and he shares my belief
that it is a serious problem and one that must be addressed. He has
asked me to propose solutions which I intend to do. In formulating
those solutions, I want and I intend to consult widely with various
interested groups.

As a practical matter, the only way to reduce acid deposition is to
reduce the emissions of sulfur and nitrogen oxides, the pollutants that
cause the problem. Among the major sources of these pollutants are
utilites and power plants. Last year we set emission standards for new
power plants which will prevent them from contributing significantly to
the problem of acid deposition* however, there are hundreds of older
plants that are either uncontrolled or poorly controlled. Any effective
plan to reduce acid deposition will of necessity require reducing emissions
from these older plants.
As the Nation backs away from oil and returns to coal for its
energy needs, reducing total regional emissions will not be easy but it
can be done. I wholeheartedly support coal conversion, it is essential
that this Nation reduce its dependence on imported oil. I strongly
believe, and have consistently stated publicly, that we can switch to coal
and at the same time protect against environmental degradation. As we
do so, we must realize that the distribution of coal reserves in this
country precludes us from relying simply on low sulfur coal. The welfare
of our miners and the economies of our Eastern and Midwestern coal-
producing States require that we find ways to use all our coal. The
new source performance standards for coal fired power plants allows for
just that.
I know many of you are also concerned with the economic effects of
being down wind of interstate transport of air pollutants. In reality
all States import and export air pollution. When one State is forced to
clamp down on sources within its borders to compensate for pollution
coming from a neighboring State, its industry unfairly may bear an

inequitable share of the cost for dealing with what is in reality a
larger regional problem. Moreover, the States margin of economic growth
may be unfairly reduced.
In the future, EPA intends to involve itself more directly in these
issues. Where States are unable to resolve these inequities among
themselves, we will use our authority in favor of the State imposing
more stringent controls when it is being adversely affected by another
State with relatively lax controls.
Our goals are clear, the best means to achieve them is not. As we
chart a course of action, we must face the fact that the Clean Air Act
has been used primarily to protect air quality near major pollution
sources on a State-by-State basis. The Act has not been fully tested in
dealing with regional pollution problems such as acid deposition.
However, if we are to do anything in the very near term, we must work
within its current structure.
We intend to put the provisions of the law that will allow us to
address regional problems to the test. The effectiveness of these
provisions remains to be seen. They simply may offer more opportunity
for debate and long litigation without providing any real benefits.
Although it is still too early to draw definite conclusions we may need,
eventually, legislative help.
I am convinced that there will be no obvious, easy, or cheap solutions.
There will inevitably be debate over both the significance of acid
deposition and the mechanism for its control. Tomorrow Dave Hawkins will
moderate a series of discussions with you to explore alternative control

In closing, I am persuaded that the time has come to make the
transition from research to action. My bottom line is to accomplish in
the near term a clear reduction in emissions from current levels. As a
first step, we must act now to avoid wherever possible, significant
increases in emissions of sulfur and nitrogen compounds which are
causing acid deposition to increase both in severity and geographical
extent. We can then turn to the question of reducing atmospheric loadings
from current levels. I look at this conference as a first step toward
building substantial agreement between the States on the seriousness of
the problem and on the kinds of near term and long term remedial actions
that are both appropriate and necessary. Again, I welcome you here and
I appreciate the inconvenience to you to travel to Washington for this
conference. I consider it perhaps the most important conference that
EPA has held since the inauguration of our administration. Steve.
Dr. Gage: Thank you, Doug. The first speaker this afternoon who will
discuss the acid rain phenomenon is Professor James Galloway of the
Department of Environemntal Sciences of the University of Virginia.
Professor Galloway did his graduate work at the University of California at
San Diego, and studied with Professor Likens on a postdoctoral fellowship
at Cornell University. He is one of the authors of the Council on
Environmental Quality Report which led to the President's initiative in
the environmental message this past year. He is presently participating
in major studies sponsored by both the Electric Power Research Institute
in the Adirondacks, the Environmental Protection Agency, and the
National Park Service. He is also secretary of the National Atmospheric

Deposition Program. I would like to ask Professor Galloway to take the
Professor Galloway: Thank you, Steve. After moving from New York to
Virginia I am very careful with my "you alls," and "how you dos," and
all that kind of stuff, and so if I do not have the appropriate southern
twang to my accent I ask my Virginia colleagues to excuse me.
I consider it a great honor to be here. I am going to speak about
what I consider the nuts and bolts of acid precipitation. To some of
you, it is going to be redundant, but I am really trying to get us all
started out on the same foot about what we know about acid precipitation.
What are the facts about the phenomenon of increased acidity of precipi-
tation, the causes, where does it come from, and what do we think the
trends will be? I have two acknowledgements to make. Really just one,
it is to my colleague, Ellis Cowling, I thank him for climbing a step
ladder and taping the screen to the mirror so we could show our slides.
I would like to make two definitions before I get started into what
we know about acid precipitaiton. The first is: What is atmospheric
deposition? Atmospheric deposition is the main transfer mechanism of
removing materials from the atmosphere and putting them back on the
ground. It is the end result of the adage of what goes up must come
down. All the materials that were in the atmosphere that are deposited
on the ground, originated on the ground. Because of its primary importance
in transferring materials to the ground, it is a major source of not
only acids but also nutrients, toxic metals, and toxic organics to
systems on the ground. Indeed, the process of atmospheric deposition
can supply most of the nutrients or toxic substances to streams, lakes,
fields, and forests.

Today we are primarily concerned with wet deposition, rain and
snow. That is really just because we are very ignorant about the other
processes of atmospheric deposition. We know the most about wet deposition,
we know very little about dry deposition, except that it can transport
from the atmosphere to the ground as many acids, nutrients, metals, and
organics as can wet deposition. So do not be fooled by the focus on wet
deposition. We need to know more about dry depostion.
Being a Professor of Environmental Chemistry, I need to talk to
you about some chemistry definitions, to make sure we all know what we
are talking about when we talk about pH and acidity. The function pH is
the negative logarithm of the hydrogen ion concentration. While I do
not want you to remember that, what I do want you to remember is that as
the pH goes down the hydrogen ion concentration or the concentrations of
acids increase. The lower the pH, the higher the acidity. Every time
you change the pH from 5 to 4 or from 4 to 3, you increase the hydrogen
ion concentration, by a factor of 10. And so, a solution with a pH of 4
has ten times the acidity as a solution with a pH of 5. Note, that down
at the lower end of the pH scale, very small changes in the pH of the
solution, say from 3.5 to 3.3 would cause very large changes in the
hydrogen ion concentration.
Now, by way of definition, we define acid precipitation as rain and
snow with a pH of less than 5.6. Why 5.6? Well if you take carbon
dioxide in the atmosphere and equilobrate it with atmospheric water
vapor, we form a weak solution of carbonic acid, which has a pH of 5.6.
We take that to be the lower limit of the natural pH of precipition.
Precipitation with a pH which is less than 5.6 is termed acid precipitation.

I would like to talk about acid precipitation on three scales.
First of all on the global scale, and then narrowed down into what we
know about Northern Europe and then narrowed down to what we know about
the Northeastern North America. On a global scale, the annual average
map shows two areas of acid precipitation (Figure 1). There are areas
in the world where the acidity of precipitation--the hydrogen ion concen-
tration of precipitation--is ten times greater than you would expect it
to be in a natural environment. In other words, the pHs are less than
4.6, 4.6 being ten times as acidic as a pH of 5.6.
Now there are some areas of the world where we do not have data, for
example Eastern Europe and China. We suspect however, that you would
see these same kinds of colors in those areas if we had the data. Well,
why here? Why not somewhere else? It turns out, as we will see later,
that these areas of the world either have high emission densities of
fossil fuel combustion products or are down wind of areas that have high
emission densities of fossil fuel combustion products.
Next, I would like to go to Scandanavia and look at temporal trends.
The question is: On a temporal scale, how is the pH of precipitation in
Northern Europe changed? Using data from the SNSF project, from Norway,
and from other countries in Northern Europe and other countries, we are
able to make this map of the pH depression in ten years (Figure 2). The
area that is bright red is where the pH of precipitation has decreased
by 1.5 units, that is greater than ten times the increase in the actual
acidity of precipitation, and then the pink, yellow, etc. are just still
decreases in the pH but are less dramatic.

In conclusion, the acidity of precipitation has been increasing in
Northern Europe. Northern Europe is very fortunate in having a very
extensive and intensive data base on the composition of atmospheric
deposition over several decades. We in North America are less fortunate.
However, from the data that exist, we are able to say, and again this is
data from Likens, Cogbill, and others, that in the Eastern U.S. the pH
of precipitation has been decreasing over the last approximately 18
years there.
Therefore, the acidity of precipitaiton in the Eastern United
States is increasing as a function of time. This applies also to the
geographical area receiving acid precipitation. Now, these are measurements.
We are reporting on conclusions based on these measurements, and it is
what I call the phenomenon of acid precipitation. We are observing this
trend and the acidification of precipitation in two large regions of the
The next question that is appropriately asked is: What is the cause
of these increases in the acidity of precipitaiton? These are the
available acids (Figure 3) or as we say proton doners--acid donating
materials—that could be found in the atmosphere. Some of the work
that was done at Cornell with Gene Likens was to investigate the contri-
bution of these materials to the acidity of precipitation in the Northeastern
U.S. A primary conclusion from that study was that precipitation acidity
in the Northeastern U.S. (in the Eastern U.S.) is caused by increases in
sulfuric and nitric acid with a smaller and irregular contribution from
hydrochloric acid. That was a valuable piece of knowledge. We now knew
what acids were causing the acid precipitation.

As long as I am talking about acids, I would like to also talk
about materials in precipitation. If you were to take a sample of
precipitation in the Northeastern U.S. and analyze it for its major anions
and cations you would find a lot of hydrogen ions for the cations
balanced out by high concentrations of sulfate and nitrate. Those are
the component parts of sulfuric and nitric acid. You would also find
chloride, phosphate, calcium, sodium, magnesium, potassium, and ammonia.
An important point that I want to make here is that I have been talking
about hydrogen ions as being harmful in precipitation. There are also
beneficial components that are found in acid precipitation. Sulfuric
acid and nitric acid in addition to having protons which we view as
harmful, also have sulfates and nitrates, which are nutrients. Some
forests of the Southeastern United States are sulfur deficient. The
increased sulfate concentration of precipitation may be beneficial.
Nitrate is often a limiting nutrient in lakes and near shore areas. The
increased nitrate concentration of precipitation could be beneficial.
However, the hydrogen ions associated with this increased concentration
of nutrients are not beneficial. So when you weigh the affects of acid
precipitation, it is very important to weigh the harmful effects of the
hydrogen ions and the toxic metals and organics to the benefical affects
of the nutrients that come along with the compounds.
We have identified the acids, now where do they come from? The
possible sources of sulfuric and nitric acid in the atmosphere are
fossil fuel combustion, the ocean, natural biogenic processes, increased
rate of decay of organic matter, etc. I will not go into the details
except to say that the sulfuric acid and nitric acid concentrations of

the atmosphere and precipitation are due almost entirely to fossil fuel
When you burn a fossil fuel you put into the atmosphere sulfur
oxide and/or nitrogen oxides. Once in the atmosphere, these are oxidized
to sulfuric and nitric acid. You do not directly inject the acids into
the atmosphere. You would inject or emit a precursor, the SO and NO ,
after that they are oxidized into sulfuric and nitric acid in the atmosphere,
then they are scavenged out by precipitation. The atmosphere is cleansed of
the acidity, making it less acid, but the precipitation acidity increases.
Estimating from the sulfate and nitrate concentrations of precipitation
what their relevant contribution is to acidity precipitation, on an
annual basis you would come up with a factor of about 2.5 to 1 sulfuric
acid to nitric acid.
The question is: Why is precipitation acidic in the Eastern U.S.?
Why not in the Western U.S.? This is a map prepared by Brookhaven
National Laboratory (Figure 4) showing the points and intensity of SO2
emission in 1975. The highest intensity of emissions of sulfur and
nitrogen are East of the Mississippi River. This does not imply that
the Western United States does not have acid rain problems, but in the
Western United States the problems are primarily of a local nature. For
example, in the area of Southern California where you have a high intensity
of automobile use and Seattle where you have some smelters, the aspect
of regional acidification of the atmosphere and precipitation is right
now, we think, primarily limited to the Eastern U.S., at least to this
degree of magnitude. Now, please note, this meeting has been structured

around the individual States, and I suspect every State representative
here could find a series of dots in their State. We all contribute to
the problem, the atmosphere does not know State or indeed national
boundaries. Every State, every nation contributes to the problem. It
is up to every one of us to assess the affects and look for solutions.
There is another factor beside the patterns of emissions of sulfur
and nitrogen oxides in the atmosphere that influence acidity of precipi-
tation. On the annual average, air mass trajectory over the whole of
the Eastern U.S., moves from West to East. That is why the emissions
are blown to the East and not to the West or why we have acid rain in
the East and not in the West. However, there are times and seasons
where the air masses do not blow West to East and that is why we see
acid rain stretching out into areas of the Midwestern U.S. The transport
of acid precipitation and acids is very complex. We can calculate how
much goes into the atmosphere, and we think we can calculate how many
acids are formed from that. But it is very difficult to calculate where
it is going to go. It is very hard to determine where the emissions
from one plant or in one State will end up one day, two days, or even a
week later.
I would like now to talk about some more temporal trends in the
acidity of precipitation on two scales. First, on a seasonal basis, and
then on an annual basis. I would like to put some more focus on the
relative contribution of sulfuric acid and nitric acid (Figure 5),
because, indeed, until we define that, we really do not know what to
control. It turns out that in the summer period in the Eastern United

States, we have a maximum in the acidity of precipitation shown by the
hydrogen line. It turns out that the maximum of precipitation acidity
in the summer in the Eastern U.S. is caused by sulfuric acid, not by
nitric acid. Indeed, we could say in the summer, acid precipitation is
a sulfuric acid phenomenon.
It is very unfortunate that the increase in acidity is coincident
with the peak of biological activity from our growing plants and animals.
Note that the nitrate concentrations do not change as a function of
time, but rather the acidity is really controlled by the sulfur. Well,
let us stretch the time scale from seasons to years (Figure 6). In the
1940s and 1950s the emissions of NO relative to SO were much lower
than they are now. Since that time, our emissions of N0X relative to
S0X have increased dramatically. Saying that another way, nitric acid
from this data is becoming more important relative to sulfuric acid. We
see this also in the nitrate concentration of precipitation (Figure 7).
The nitrate concentration of precipitation is increasing. We believe
nitrite acid is becoming more important relative to sulfuric acid as
time goes by. This trend will continue unless we are clever in putting
controls on the emissions of NO in the environment. There has been a
good deal of discussion about acidity trends in the atmosphere of the
Eastern U.S. Because of the very poor data base that we have, and I
hope this will not continue, we really have very few data points where we
can say absolutely that the acidity of precipitation is increasing in all
areas of the U.S. But, you know, we can get lost in these arguments about
how the acidity increased by 10%, 20% in the Northeastern U.S.; or
that it increased by 100% in the Southeastern U.S. over the past ten or

twenty years. Those are what I consider secondary questions. The main
question is: Has the acidity of precipitation increased in the Eastern
U.S. through the combustion of fossil fuels? Or to say it another way:
If we turned off the combustion of fossil fuels, would we have acid
Doug Whelpdale of the Atmospheric Environment Service of Canada and
I prepared a sulfur budget for the atmosphere of Eastern North America
to address these questions. We looked at all the sources—natural and
anthropogenic—and all the removal mechanisms of sulfur to try to answer
three questions. What is the anthropogenic relative to natural source
of sulfur in the atmosphere? If the answer is that the natural source
is very small relative to the anthropogenic, acid rain is clearly an
anthropogenic problem caused by combustion of fossil fuels. A secondary
question is: What were the removal mechanisms, and our third question
was: What kind of transport do we see of sulfur between the two countries?
" Figure 8 shows the following: (1) in the United States and Canada,
greater than 95% of the sulfur in the atmosphere is anthropogenic. If
you turned off the fossil fuel combustion, the sulfur concentrations
would drop by about a factor of 10; (2) there are three main removal
mechanisms for the sulfur that we put in the atmosphere—dry deposition,
wet deposition, and transport out to the ocean; (3) based on this model,
every year there are two terregrams of sulfur exported into Canada from
the U.S., while we receive 0.7 terregrams. We are a net exporter of
sulfur to Canada. Note, that we put about the same amount of sulfur
into the Canadian atmosphere as they put into their own atmosphere. So
we are not really talking about an interstate problem. It is an interna-
tional phenomenon that we have to address and be concerned with.

Acid rain is a unique pollution problem. Local and regional impacts
will be addressed by Dr. Cowling, but the main point I want to make—the
main conclusion I would like to leave with you--is that pollutants
originating in one country or State may adversely impact the resoures of
another. It is a wet and dry deposition problem, and so we see that the
acidification of precipitation is an anthopogenic process caused by the
combustion of fossil fuel. The primary acids are sulfuric acid and
nitric acid with an acuta! contribution to acidity, sulfuric acid being
more important than nitric acid but as more time goes by the nitric acid
is becoming increasingly important.
Well, scientifically it is very interesting to study these problems
of the phenomenon of acid rain. It intrigues me as an atmospheric and
aquatic chemist. But relative to the audience we have here, and the
severe problems we are forced to address, we have to ask the question:
So what? This slide is an introduction into Dr. Cowling's talk about
the effects of acid precipitation. You see here that some of the regions
in North America that could receive acid precipitation contain large
areas that are sensitive to acidification by acid rain. Thank you very

10 x

Figure 2 is missing.

Hydrocntoric, sulfuric, and nitric acids
are strongest of several potentially
Important proton donors in rain and snow
IMaMv* MrangMi (pK«)
H48O4	—3
HHO$	-1
HsSOs	1.9
NSOli**	2.0
ftHfeOfe*	2.2 to ^-3
NF	3.2
< 6.3
H90.-	7JZ
NH«	9.3


- 70
* 60
Monthly Bulk Precipitation Values
for Hubbard Brook Experimental Forest
during 1963-1974
\ » A
V s /
Q V f				 no;
^ 'V'
		I	I	I—I—I—I—I
Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May

Nitrate, mg per liter1
1915 20 25 30

—	i»		

1.2 DD 3.0 WD
3.3 DD 12.5 WD
Inland marine
Saturated soils
Transport between
air masses
Wet deposition (WD)
8 dry deposition (DD)
Shallow marine

Dr. Gage: Thank you, Professor Galloway. The next speaker is Dr. Ellis
Cowling who is the Associate Dean for Research in the School of Forest
Resources at North Carolina State University and also Assistant Director
of the North Carolina Agricultural Research Service. Dr. Cowling received
a doctoral degree from Uppsala University in Sweden in plant physiology.
It was there that he first became acquainted with the acid rain problem.
Since then he has played a very dominant role here in the United States
in attempting to bring this problem to our attention. He has contributed
many professional publications in this area and is currently serving as
the Chairman of the National Atmospheric Deposition Program. Ellis,
take it away.
Dr. Cowling: Thank you, Steve. It is obvious from the participation in
this meeting that acid precipitation is approaching a new level of
public consciousness in many parts of the United States and Canada.
This is an exciting development for many of us who have been concerned
about the ecological effects of acid precipitation. It has been particu-
larly satisfying to Dr. Svante Oden, the soil scientist at the University
of Uppsala who first called the world's attention to the long range
transport of air pollutants and has given you an introduction to the
chemistry and meteorology of acid precipitation. It is my duty to
introudce you to the ecological effects of acid precipitation. Let me
begin my presentation with the same slide that Jim used to begin his
(slide 1).
It is important that we understand that acid precipitaiton is only
one special feature of the general phenomenon of atmospheric deposition--
the transfer of matter from the atmosphere into ecosystems--into lakes,

streams, forests, and fields. As Jim emphasized, both wet and dry
deposition are exceedingly important. You will remember in his slide
showing the total atmospheric deposition in the United States that
sulfur deposition dry, exceeded sulfur deposition wet. So let me emphasize
again that we are concerned not only with wet but also with dry deposition.
Next let us look at acid precipitation in the context of how plants
grow (slide 2). This slide shows the essential chemical elements that
it takes to grow a plant. Chlorine has been added recently so that
there are now 16 essential elements that are required by plants to grow.
All 16 are distributed abundantly in the atmosphere. All 16 can be
taken up by the foliage as well as by the root system of plants.
We must all understand that atmospheric deposition is a mechanism
by which plants obtain both beneficial nutrients and injurious substances
of which acids are only one example. Jim also showed this third slide
which illustrates the extent to which nitrate ions in precipitation have
become progressively more abundant in recent years (slide 3). At Ithaca,
New York, from the early part to the latter part of this century, a
four-fold increase took place in the content of rain and snow. Nitrate
ion is an essential nutrient for the growth of plants. This slide shows
that nitrate ion is being provided in four times the abundance it was
during the early part of this century. Nitrate ion is a fertilizer
element. It helps plants grow. But the nitric acid that gives rise to
nitrate ion also provides hydrogen ions. Thus, to understand acid rain,
we must understand the balance between beneficial and deliterious effects.
A few years ago I remember making the remark in a meeting in Washington,
that plants had two root systems, one stuck in the air, and the other

stuck in the ground. Eville Gorham heard my talk and later reminded me
that this was not an original statement--in fact, the same idea was
enuncisted by Rober Hooke in the year 1671 (slide 4).
Where do all these substances in the atmosphere come from? This
next series of slides shows the great variety of places from which they
come. They come from various natural sources. They come from decomposing
organic matter in wet lands and bogs (slide 5). They come as air-blown
dust from desert regions of the world (slide 6). They come from volcanos
such as Mount St. Helens in the State of Washington. They also come
from various man-made sources such as power plants (slide 7). Power
plants are the predominant source of acid-yielding substances in the
United States. They also come from metal-smelting operations (slide 8).
This slide shows the famous Sudbury Smelter which injects more sulfur
into the air than any other point source in the world. Floyd Elder took
this picture some years ago. As you can see here, the emissions from
this stack can be seen as a very visible plume for very long distances,
up to 200 miles, under the right meteorological conditions. Slide 9
shows the City of Chicago on January 24, 1972. Hopefully, EPA's efforts
to clean up Chicago have made it so that this kind of brown smudge
occurs less frequently in 1980 than it did in 1972.
Atmospheric deposition also originates in agricultural operations.
Slide 10 shows a livestock feeding operation in Colorado which provides
an abundant and rich array of ammonia and amine compounds that are
dispersed over the landscape. Slide 11 shows a farm in Georgia, a
turkey operation. It is no surprise that the grass is green here. The
grass is being fertilized by an abundance of volatile ammonia and amines--

valuable nutrients which are used by the grass to grow green. But these
same substances also are used by algae that grow in farm ponds and
therein make a nuisance of themselves.
Atmospheric deposition also comes from agricultural and forest
burning operations. Agricultural burning is an important plant-disease
management tactic in the Willamette Valley of Oregon (slide 12).
Atmospheric deposition also comes from controlled burning operations and
wild fires in North Carolina (slide 13).
All these substances from all these different sources are mixed and
chemically transformed in the atmosphere. They are also transported
over great distances to many different regions of North America (slide
14) in every season of the year. When they eventually return to the
earth, they are deposited in two general places—onto the vegetation and
soils of the landscape or onto surface waters. If the rain or snow does
not fall directly into a surface-water system, it will fall first onto
the landscape and then drain into the steams or lakes of the area.
Slide 15 is one of Svante Oden's slides. It illustrates the importance
that must be attached to the mobilization of metal ions by acid precipitation-
some of these ions are nutrients such as calcium or magnesium while
others are toxic metal ions such as aluminum or mercury. These metal
ions are transferred from the soil into water systems where fish or
aquatic life in a stream or lake are the recipients. In essence, the
lake tends to integrate the chemistry of the entire watershed. As we
will show later, the ground water systems of the earth also integrate not
only the watershed but the entire morain, or clay, or sandy-soil system
that covers the earth and the vegetation that is supported by it. When

we think about the effects of acid precipitation on aquatic ecosystems,
it is very important that we understand these integrating relationships
between the chemistry of precipitation and the chemistry of the atmosphere,
the vegetation, the soils, and the bedrock of the area in which the
precipitation falls. Slide 16 shows these integrated chemical relationships
very clearly over a long span of years. These data are for the	iy
complete data bases we have in America showing the changes in aquatic
chemistry in a whole drainage basin. The lower curve is for the alkalinity
of the water system. In a crude sense alkalinity is the opposite of
acidity. These measurements were made every week from 1924 through the
present day. What a valuable data base this is, because it show us what
the changes have been in the chemistry of deposition into this particular
reservoir. Notice that in this particular series of years there was a
very rapid decrease in alkalinity whereas there was practically no
change for almost a decade. But in this period of years a very rapid
increase in alkalinity took place and finally in this series of years a
very rapid decrease in alkalinity took place. Thus, over the long term
of this fifty year span of time, a very substantial decrease in alkalinity
took place in this municipal reservoir. We have every reason to believe
that these changes in alkalinity were caused by the deposition of acid
substances in rain and snow about which Jim Galloway spoke about earlier.
Now what are the consequences of acid deposition into a lake? It
must be understood that not all precipitation comes down as rain, some
of it comes down as snow. In Northern New England you might be able to
take a picture such as this (slide 17) but you certainly could not in my
U S En virnnmpntal infection Aqency
Corv.ili-	,	¦ ,rc!; L*b.
200 S V\
Reservoir near the City of Utica, New York. /It is one of the most

State of North Carolina except perhaps on the top of Mount Mitchell. It
is important to understand that unmelted snow accumulates air pollutants.
If the snow pack does not melt durino the entire winter season, the
soluble pollutants that are in that snow will be held all winter long
and then come out into the local stream waters in one immense pulse--a
gush of polluted melt water. The fish kill shown in slide 18 is a
consequence of that kind of pulse--a shock to the aquatic life that
lives in the stream or in the lake.
In addition to these shock effects, there are also other more
insidious effects that take place slowly and without the catastrophic
visible impacts that a fish kill shows. Slide 19 shows the roe of brown
trout. When these little eggs hatch, they turn into little fingerlings
that look like this (slide 20)--fish fry. This slide shows what a
normal brown trout fry looks like when it hatches in lake water with a
pH of 5.5. Slide 21 shows what they look like when the hatch at pH 5.0.
Notice they have difficulty assimilating the yolk sac in this case.
Slide 22 shows what the fish fry looks like when they hatch at pH 4.5.
None of these will survive. The phenomenon of progressive acidification
shown in this series of slide leads to a progressive failure of recruitment.
When this process continues year after year, the population of fish goes
to extinction.
To show what recruitment failure means in summary form, let me show
slide 23. The bottom scale on this slide is pH. The vertical scale is
the proportion of lakes that have no fish, sparse populations, or good
populations of fish. Notice that the more acid the lake, that is, the
lower the Ph, the more frequently the lake will have no fish or only

sparse populations. The more nearly neutral the lake water is, the
greater will be the likelihood that the lake will have good populations
of fish.
Many of you in this room are concerned with the protection of
environmental quality in your respective States. But what can you or we
do about acid precipitation? Doug Costle has indicated his determination
that we should not increase and, if possible, diminish our emissions of
the air pollutants that cause acid rain—SC^ and N0X- This next slide
was originally designed for another purpose but we can use it to show
something of what we can gain by decreasing the rate of loading of
sulfate into a lake. Notice that the bottom scale shows sulfate loading
to lake water and the resulting pH is shown on the vertical axis. The
two curves show that the more heavily you load a lake with sulfate, the
more rapidly you will change the pH. But if you decrease the rate of
loading of sulfate you will increase the time it will take to achieve a
chemical "titration" of the lake. So one of the things we would gain by
diminishing emissions is to gain time with which to more completely
understand the chemistry, to understand the effects on the aquatic life,
and to understand the kinds of ameliorative pollution-control stategies
that may be desirable for us to take in the interest of protecting
aquatic life.
These next two slides show some ideas that Dr. Carl Olof Tamm of
Sweden and I presented for the first time at the Ohio Conference on Acid
Precipitation in May of 1975. At that conference we talked about possible
effects of acid rain on vegetation. This word possible is a "weasle
word" which we scientists put in when we think something might happen but

we have not yet proved it. Slides 25 and 26 each show four possible
effects. The first item is leaching of mineral elements from foliar
organs. In 1975 we thought this might occur; it has now been established
to occur. The second item is leaching of organic compounds from the
foliar organs; we now know that this also occurs because it has been
demonstrated both in field and in laboratory experiments. The third
item is erosion of protective wax over the surface of leaves. This
effect has been demonstrated not only in this country but also in Britain.
The fourth item, interference with normal guard cell functions, has been
detected in laboratory experiments.
Slide 26 shows four other possible effects. The first is direct
injury to meristematic or unsuberized succulent tissues—the tender
shoots that develop in young plants. The second item is alteration of
plant exudation processes with attendant changes in the kinds of organisms
that live near roots and on leaf surfaces. The third item is alteration
of the integrity of cell membranes due to the deposition of acid substances.
The last item is alteration of resistance or susceptibility to foliar,
soil-borne, and other plant pathogens. All of these effects were postulated
in 1975 and by 1980 they all had been proven to occur in at least one
experimental plant.
Let me show you some of these effects. If you apply an acid solution
to plants as Mark Decot did in our laboratory some years ago, it is
possible to induce little spots which show injury to the leaves (slide
27); but you have to apply a pretty strong acid solution to do that {pH
2.7). At much more mildly acid conditions you can also induce the
premature senescence of older needles on pines (slide 28). These older

needles are supposed to remain functional in photosynthesis but they
cannot do this very well when they turn brown. These older needles
turned brown after only a single year of function rather than after the
two or three seasons of function that is customary with this type of
pine. Slide 29 shows a condition in Yellow Delicious apples which, in
so far as we know, is not due to acid rain; this "russetting" is induced
by other substances, as yet uncharacterized in terms of their chemistry,
in both dry and wet deposition. If you were to shelter apple trees in a
plastic enclosure or use a simple furnace filter to remove the particulate
matter you could decrease this kind of injury. You can also further
protect them from precipitation (slide 30); but it is pretty hard to
grow apples in an economic way without them ever being rained on.
Slide 31 is one that my former student, David Shriner, used to
demonstrate the erosion of epicuticular waxes. Let me show you the
detail of this. Plate B shows the platelets of wax that accumulate on
the oak leaf. These platelets of wax are very easy to see when they are
not eroded. This plant has never been watered over its foliage. In
plate C you will see that the platelets of wax are more rounded, it is
much more difficult to see texture in the wax. This plant received
simulated precipitation of 6.0. In plate D you see wax platelets that
are extensively eroded. Much of the wax was removed by simulated acid
precipitation of pH 3.2. David Shriner did not know that this erosion
would cause an increase in drought susceptibility but he thought so. At
a meeting in Norway about two weeks ago a scientist from Scotland reported
that he had observed a decrease in resistance to water loss in leaves
subjected to simulated acid precipitation. I consider the erosion of

surface waxes one of the most likely general effects on crop and forest
production. If the protective wax surfaces are removed, it is likely
that this will cause an increase in susceptibility to drought, not
actual damage by the acidity, but increased susceptibility to drought.
Acids in precipitation also have been shown to leach valuable
nutrients from the root zone of plants so that they end up so deep in
the soil that they are inaccessible to plant roots (slide 32). Acid
precipitation also has been shown to inhibit the formation of nitrogen
fixing bacterial nodules on legumes (slide 33). This research also was
done by David Shriner in our laboratory in Raleigh. He found the same
inhibiting effect on both soybeans and kidney beans.
Here is another effect of air pollution--substances in the air that
interfere with normal visibility. All of you who have traveled the Blue
Ridge Parkway have seen the logo shown in slide 34. The Peaks of Otter
are the symbol of that marvelous parkway which we all have enjoyed in
the Blue Ridge Mountains of Virginia. Slides 34 through 37 were provided
by Dr. John Skelly of the Virginia Polytechnic Institute. They show
what the Peaks of Otter look like in reality at three different concen-
trations of oxidant in the atmosphere. We do not know that the oxidants
were the cause of the haze but we do know there is a correlation between
oxidants and poor visibility. Slide 35 shows what the Peaks of Otter
looked like at two parts per hundred million in the atmosphere. Slide
36 shows what they looked like at 12, and slide 37 shows what they
looked like at 16 part per hundred million in the atmosphere. Obviously
it is far more enjoyable to visit the Peaks of Otter when there are 2
rather than 16 pphm of oxidant in the atmosphere. The frequency with

which we have days when there are only 2 pphm in the atmosphere are
decreasing year by year. The question for us is: How much do we wish
to allow our children to enjoy these kinds of scenic vistas in the
national parks?
Doug Costle referred to the erosion of monuments by acid precipitation.
Slide 38 shows a very famous madonna that adorns a castle in Germany.
The madonna was created in 1702. The picture on the left was taken in
1908 after 200 years. The statue is clearly a madonna and adorns that
building with grace. The second picture was taken by Winkler in 1969.
The statue may still be discernable as a human form but it is no longer
a madonna. The cultural heritage of German society is slowly being
eroded away. The statue suffers, no doubt, because of both sulfur in
the air and sulfur in precipitation.
One of the most intriguing and perhaps one of the most worrisome of
all effects that we now know due to acid precipitation is illustrated in
slide 39. It shows the pH of a number of wells in Western Sweden.
Notice that the pH of the ground water ranges from 4.0 to 8.0. Notice
also that 13 percent of the nearly 1600 wells which were sampled were
owned by persons who complained about corrosion problems. When the
acidity of ground water changes, the acidity of well water changes and
that means that human beings and livestock are drinking water which is
substantially more acid and in many cases substantially richer in metal
ions than usual. Plese understand that ground water has percolated over
foliage, it has percolated through the humus layer, it has penetrated
deep into the soil, and sometimes deep into the morain or other sedimentary
materials that make up the aquasphere--and still the water may be only pH

4.5. There appears to be no buffering capacity left in the soil system.
This is a very serious and perhaps one the most insidious of all the
effects we have seen. At least in certain local areas, acid precipitation
apparently can affect the quality of drinking water. Slide 40 is an
attempt on EPA1s part to sum up what we know and what we think we know
about the effects of acid precipitation. The first effect is the acidifi-
cation of lakes, rivers, and ground waters resulting in damage to fish
and other components of aquatic ecosystems. That is established, but
acidification also leads to item 2--release of metal ions from soil.
Notice that the word "possible" is used three times—in item 3, item 4,
and item 6. The word "possible" means that we think it occurs, but we
have not been able to prove it conclusively. We think acid precipitation
may reduce forest productivity and we think it may also cause damage to
agricultural crops. There is certainly deterioration to man-made materials.
Notice that the last item say "possible contamination of drinking water
supplies by metals being released from soils and from pipelines". After
the international conference on acid precipitation in Norway two weeks
ago, we can cross out the word "possible" in item 6. It is now established
that acid precipitation can cause contamination of drinking water.
Steve Gage mentioned the President's environmental message and the
initiation of the President's Acid Rain Coordinating Plan. Steve is one
of the two cochairmen of this committee. Rupert Cutler of the Department
of Agriculture is the other cochairman. I think it is a very encouraging
thing that Jimmy Carter has provided a measure of leadership for us in
seeking to deal in a constructive way with the problem of acid precipita-
tion over the next ten years. In conclusion, I should like to leave you

with two general thoughts (slide 41). These thoughts are the objectives
to which the group of scientists associated with the National Atmospheric
Deposition Program committed themselves in the Fall of 1975. We think
it is essential that this country develop a permanent, high quality
monitoring network to determine spacial and temporal trends in the
chemistry of wet and dry deposition in the various regions of this
country. We also think it is important that we should encourage and
coordinate research on the effects of atmospheric deposition on all the
things that you have seen in these slides. I hope you will reflect in a
serious way on these various kinds of effects—that is the major reason
why we are here today.
It is important for all of us here today to reflect on how the
systems by which we use energy in this country should be adjusted so
that the quality of the air, the quality of soils, the productivity of
our agricultural and forest ecosystems, and the stability of fish popula-
tions can be maintained for our children and our children's children. I
thank you very much.

10 x

Elements	Distribution	Avai1abi1i ty
Carbon All organic compounds Rarely limiting
Hydrogen esp. cellulose, hemi-
Oxygen	celluloses and lignin
M.	Proteins, nucleic acids
Nitrogen peptides, amino acids Usually
nu , Nucleic acids, phospho-
Phosphorous lipidSj ATP	0ften
Potassiun (?) Growing portions	"	"
Sulfur Proteins	Sometimes "
Pectic substances,
^a» M9	chlorophyll	Rarely
F r 7 Co-factors or constitu-
m' m* d ents of enzymes or
Mn, Mo, Bo cytochrome/


OF THE PLANT." Robert Hooke, 1671.












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Y f 33.94-.28x(r*».648)
*»5 30 as 40 45 SO 55 *0 45 70
Average Annual total alkalinity and hardness in
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based on dally measurements from 1924-28 and
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Fish population declines as the
acidity of lake water increases
% of lakes
No fish

Sparse population
Good population

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Sulfate Loading to Lake Water (Kg/ha/yr)



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Dr. Gage: Thank you, Ellis. The third speaker this afternoon is our
distinguished colleague from Canada, Mr. Ray Robinson. He is the Assistant
Deputy Minister of the Environmental Protection Service in Environment
Canada. On the U.S. side, it takes both Dave Hawkins and myself to fill
Ray's shoes. He is in charge of both the research and the regulations
for this problem in Canada. We have also enjoyed working with Ray as
the delegate from Canada for the bilateral discussions on the acid rain
problem that we both share. I would like to turn the podium over next
to Ray.
Mr. Robinson: Thank you very much Mr. Chairman. It certainly is a
great pleasure to be here. I would like to begin by expressing appreciation
on behalf of my government for your courtesy in inviting a Canadian to
make a presentation here today. Such courtesy says something about our
relations and that something is good. Much of what I am going to say
will necessarily sound similar to what has been said by previous speakers.
That's a simple consequence of geography which dictates that we share
the problem of acid precipitation.
History has demonstrated that we have successfully cooperated to
resolve similar problems in the past. The Canada-U.S. agreement on
Great Lakes water quality is one example of the success story that is
unfolding. In the early 1970s we found ourselves in a situation similar
to that presented by acid rain. We did not have all the scientific
knowledge which we would have liked, but we did have enough to know that
we had a worsening situation and that both countries needed to initiate

or extend control action. As a result of those actions, we are now
seeing the environmental systems on their way to recovery.
It has been said that there are many uncertainties concerning the
phenomenon of acid precipitation and we have had some discussion of that
already today. There is no question that these uncertainties do continue
to exist. We are joining our colleagues in the United States and in
other countries in working to fill some of the gaps in knowledge that
have been identified. It is also true that a great deal of research has
already been done. Again, without repeating what has already been said,
we see quite clearly that there are a number of conclusions that have
been brought out and which we can use as a base for guiding us in terms
of the decisions we should make.
Rather than go through my address in detail, which is, as I say, so
repetitious of what you have already heard, I will pick out points here
and there that add a Canadian flavor, if you will, to some of the points
made. My text will, in fact, be made available to everybody so you can
look at the detail later if you wish.
Our own monitoring, for example, has certainly reinforced that
which you saw presented earlier—the trend in acidity of rain over the
past two decades. There has been a marked increase in acidity. There
has been no question of that whatever. Similarly, in terms of documenting
the deterioration of watersheds, we again have quite good data going
back a number of years which demonstrate progressive deterioration. For
example, in the case of the Cloche Mountain Lakes in Ontario, we have
done some very detailed work demonstrating the impact of lake acidification
on fish populations. It does affect different types of fish at different

levels. From this and other studies we can certainly conclude that
lakes in sensitive areas, some hundreds of miles from the source, show a
marked drop in the number of fish species when the acidity of water
moves above a certain point.
Similarly, our own examination of impact on our streams show
results very much in tune with those established earlier in Norway,
especially the impact of the so called pH shock in the Spring, both on
the actual living fish and particularly on their capacity to spawn.
I would say further in the matter of property damage, that we do
not have a good data base at this time. We did in fact undertake a study
by our National Research Council. The study was completed about 7 years
ago but the data was about 10 years old. At that time they came up
with some conclusions and came out with some figures. The figures
seemed extraordinarily small by today's standards, about a couple of
hundred million dollars a year. I rather think that if we add both
inflation and the increase in acidity over the 10 years in between,
' " 		
that figure would skyrocket. We are in the process of updating those
/figures to get a clearer understanding of the economic impact of acid
I	c*//
rain on property and on buildings.	Q-r-^ ^
Similarly, and it hasn't been mentioned today or very little, we do
not have conclusive evidence in the area of human health. Here we are
referring not so much to the indirect effects from the release of heavy
metals, which have been referred to, but the other problem of the inhalation
of fine particulates. We are aware of the conclusions that were drawn
by the OECD in this area, we are aware of the work of your Brookhaven
National Laboratory, and of Drs. Mendel son and 01 me. We are increasing

our efforts to look into this area but we are very conscious of the fact
that there is still much controversy and much doubt about it. I think I
could say this, that one of the things that is particularly troubling
about the concerns relating to health and to property is that they can
impact a very much wider segment of society simply because they are not
dependent upon the recipient being particularly susceptible, except in
the case of health. I am referring to areas which are geologically
susceptible, which is one of the phenomena that mark the acid rain
problem, particularly in Canada, as I will mention in a moment.
Some of the unanswered questions: well, we don't know why some of
our lakes have acidified more quickly than others. We are not sure why
some fish species are more sensitive than others. We don't know why
toxic heavy metals seem to be released with increasing acidity at different
rates. We also do not yet know how large an impact accumulative acidifi-
cation will have on our generally thin soil cover, or on forest produc-
tivity, which was mentioned earlier and which, in our Northern latitudes
is often marginal, I will say more about that in a moment. Research to
answer these and other questions is going on and we have set up a mechanism
between Canada and the U.S. to ensure that research is well coordinated
between the two countries. We are, nonetheless, convinced of one thing.
The inescapable relationship between the release of certain pollutants
which are increasing the acidity of precipitation, and those effects
that have so far been thoroughly documented obliges us to look for
effective ways of taking early action to control those pollutants.
There are general reasons why this particular problem is of particular
concern to Canadians and especially those who live in the Eastern half

of our country. Large parts of Eastern Canada are underlain by rock
types that are deficient in the minerals needed to effectively neutralize
more than limited quantities of acid. Many of those same regions of
Canada and particularly Northern Ontario and Quebec had most of their
soil cover pushed south during the last ice age. For the most part, the
thin post-glacial soils we find there now also have a very limited
capability for absorbing and neutralizing acids. The Canadian climate
compounds the problem, in that much acidity is stored in the snow over
the winter and then released in a sudden burst in the spring. As mentioned
earlier, this brief but often intense increase in acidity can be disastrous
for the fish spawning and, indeed, for the living fish.
North American weather patterns dictate that the plumes from the
stacks of major industries in the industrial heartland of both our
countries very often move across parts of Eastern Canada. The generally
warmer and more humid condition of air masses coming from the south and
west accelerate the transformation of some of the pollutants to acid.
We, thus, find ourselves in a situation where some of the most sensitive
areas of Eastern Canada are frequently downwind from some of the major
North American pollution sources. As more than half our population is
to be found there, this demographic arithmetic adds a major social and
economic dimension to Eastern Canada's vulnerability to acid rain.
The natural environment of Eastern Canada not only sustains a
resource base for important components of the nation's economy but also
constitutes an invaluable and irreplacable contribution to the nation's
quality of life and its environmental heritage. Without measures to
deal with acid rain and other elements of the class of problems associated

with the long-range transport of air pollution, Canada's tourist, sport,
and commercial fishing industries face substantial adverse economic
impact in the years ahead.
The attention of the media has been drawn understandably and indeed
properly to the impact of acid rain on our lakes and streams, particularly
because such impact is extremely time sensitive, and in many respects
irreversible, but also perhaps because tens, if not hundreds of thousands
of lakes could ultimately be affected. However, those of us who are
responsible for addressing the problem are becoming increasingly concerned
about the less spectacular but no less real impact on soil chemistry,
and, therefore, on vegetation growth. Our scientific work very much
reinforces the conclusions that you have had put before you so far.
What really is in doubt about the changes that we see occurring in soil
chemistry, is the speed with which they are occurring. As noted above,
we are uncertain about the precise effects these changes have on forest
productivity which, to underline the point again, in our northern
latitudes is often marginal.
The forest industry is our largest industry in Canada, and it
competes on a world-wide market. We cannot afford anything which would
reduce that competitiveness. I realize that must create something of a
conflict of interest with some of the Southern States represented here,
particularly since I just heard a few moments ago that sulfate and
nitrate may be helping out our competitors to the South. I assure you,
I am not accusing you of a great plot.
In undertaking the essential task of examining what we can do in
Canada to address this problem, we are proceeding from three premises.

First, we are convinced that acid rain is a serious and worsening environ-
mental problem. Second, policy decisions on resolving the problem will
have to be made without the luxury of having all the scientific evidence
we might like to have. Third, the solutions may well be expensive, and
therefore, have a substantial social and economic impact. We are,
therefore, accelerating the process of developing—in concert with the
Provinces concerned and in consultation with major industry—control
stategies that are appropriate to the Canandian situation.
Our control strategy program, now well underway, comprises four
major components. The first is the assessment of the major sources of
concern, and of the reduction of emissions which would accrue from the
application of specific abatement technologies. The second is the
examination and assessment of the economic and social consequences of
achieving various levels of reductions in emission. In other words,
what impact would such additional costs have? The third is a macroscale
assessment of the physical and economic benefits which would be expected
from reduced environmental damage, and the fourth, the development and
analysis of abatement options which is really pulling together the first
Before an American audience, it is important that I explain that
the distribution of sources in Canada of acid causing pollutants is very
different than in the United States. Nearly 60% of our contribution to
SO2 emissions, in excess of two million tons per year in Eastern Canada
comes from nonferrous smelters. Less than 15% comes from coal-fired
thermal plants. (That's a very different situation than in the U.S.)
The remainder is from a wide variety of industrial sources, mostly
emitting at a low level.

I notice we have not said very much today about high stacks but, in
fact, they are a factor in the problem as well as most of you here would
understand. Thus, our focus must be on the smelting industry, although
we are also examining the power industry and certain of the other
As for N0X emissions--oxides of nitrogen—these currently total
only 1.2 million tons per year in Eastern Canada and about 65% of these
emissions are from motor vehicles. Automobile emissions constitute
a low level source of as yet undetermined significance for acid rain.
Fortunately, unlike the situation in the United States we are not
projecting significant emission increases of either pollutant. Indeed,
our largest source, the Inco Plant in Sudbury has cut its SC^ emissions
by more than half in the past decade. Most of our smaller smelters are
well controlled, with up to 90% SC^ removal. A new one, planned by
Texas Gulf in Ontario, will have 97% S02 removal. As for power plants,
probably only one completely new coal-fired facility, and at the outside
two, is planned this whole decade throughout Eastern Canada. Moreover *
this one facility, is only 400 megawatts and will burn very low sulfur
coal, 0.6%. Its total emissions are expected to be less than 20,000
tons of SO2 per year. You can, therefore, see that new coal fired power
plants are not the area of focus for our attention. I might make a
point, that if you want to know which one this plant is, you only have
to ask the State delegation from Minnesota. In addition, there are some
plans to convert some plants to coal along the Atlantic Seaboard, but at
the very outside, these might total 1,000 megawatts.

I have described our physical circumstances, our contribution to
the problem, and the procedures we are employing to develop the appropriate
responses. Obviously, to be effective, such a response must go beyond
our own borders, and it is accordingly being proposed that our two
countries enter into an air quality agreement designed to address
transboundary air pollution. You have, therefore, the right to know
something of the will and determination of your future partner in this
major endeavor. I can say to you flatly on the basis of my knowledge of
the views of Federal and Provincial governments in Canada, that we are
committed to bringing about major reductions in SC^ emissions as rapidly
as the systems we have put in place will allow us so to do. I have no
doubt that if our principal Provincial colleagues were here with me,
they would make the same point. The reason is very simple. The effects
of acid rain are now sufficiently widely known in Canada and concerns on
the part of the public have reached such a point, that actions to control
the sources have become a political imperative at both levels of government.
In short, your future partner is both willing and ready. Thank you.
Mr. Gage: Thank you very much, Ray. We now have moved somewhat ahead
of schedule and I think it would be very appropriate at this time to
take about 15 minutes for questions and comments from State representa-
tives. I would just ask you to identify yourself and your State, not
so much for those of us up here who can see you but for the hundred
people or so who are in the back. Are there any comments at this point
for any of the three speakers who have made presentations during this
session? We will have a chance to have quite an extensive discussion at

roughly 4:45, but I thought that since we are running a little ahead of
schedule it might be well to take several questions. Well, if not, why
don't we take a 30 minute break and be back at 3:15.
Mr. Gage: Our next speaker is Mr. Lowell Smith who has spent many years
on the Ohio River Basin Energy Study and the problem of long-range
transport and modeling. During this time, he has become widely acquainted
with the many aspects of the acid rain problem. We have asked Lowell to
talk about the emissions of sulfur and nitrogen oxides to open this
session. Lowell.
Mr. Lowell Smith: Thanks, Steve. It is certainly encouraging to see
this many people on an afternoon like today who are as interested in the
acid rain problem as what we see here today. I would wager that if we
held this meeting a bare 12 months ago, we would barely be able to fill
the seats around the table. I think we have come a long way in a very
short period of time. What Doug Costle started to talk about this
morning was that we have only started to control air pollution in the
Agency with the States and with the Federal government under the Clean
Air Act to meet concentrations locally around power plants and other
large sources of air pollution. I should not say just around power
plants, we have only controlled sources to meet local ambient air quality
This slide is what a power plant looks like and if you are standing
downwind of that power plant, we see something like this. This is really
what EPA is trying to control from those power plant stacks, it is what
this ambient concentration of that plume downwind is. We see that
plumes can travel fairly long distances—this is a shot over Lake Michigan

I believe—with a plume starting to spread out over the lake. These
plumes can travel great distances.
Here in the Ohio River Basin, we see that these plumes are traveling
off to your right and we see that these plumes can travel very long
distances and start to merge into hazy blobs. The important point is
that here we have plumes that come up from several sources and start to
merge into a hazy plume and then go on for some time until on a continental
scale we now see the United States here, Lake Michigan, the Atlantic
Coast, and here we see the plume which has spread out over much of this
part of the United States, in fact, even has been transported up in this
direction. This is one large hazy air mass made up of hundreds of
plumes like the one I pointed out over the Ohio River Basin.
How does long-range transport actually occur? I want to talk to
you a little bit about are three points. First, how transport occurs.
Second, what the atmospheric effects are. Third, how are the sources
First, talking about how transport occurs, notice this black line.
It is an indication of where the inversion layer—a sort of cap in the
atmosphere--is over the time of day. Here is midnight, here is noon,
and midnight again. Here we see that the inversion layer during a
typical summer night is very low, then as the sun comes up and stirs up
the atmosphere it heats it up and mixes it, and then it rises up to
maybe 1200 meters or so, and then when evening comes it drops back down
and starts the process over again. The important point is that we have
a stack that is a couple hundred meters high. This will shoot the
emissions up into the atmosphere, rise up 300 or 400 meters and then it

will be above the inversion layer. It will not come into contact with the
ground till 6, 8, or more hours later when the sun starts to mix the
atmosphere. That means that some chemical reactions can take place in
this plume during that time. It also means that this plume can transport
several hundred kilometers during that time, because frequently we see,
especially in the Midwestern part of the United States, a thing called a
nocturnal jet. That nocturnal jet means that at about this height there
is a preferential wind velocity that increases the speed with which the
pollutants are transported and keeps the pollutants in a narrow band and
transported cohesively several hundred miles overnight. Much of the
chemical activity, we think, takes place during the daylight hours when
this plume is well mixed with all urban sources, the other source of air
pollution. There is a lot of chemical activity that goes into changing
those sulfur oxide and nitrogen oxide emissions into the acids that we
have been talking about earlier this afternoon. Let us go on and see
what this might look like for sulfur.
We see that if we have a unit amount of SOg coming out here, that
during the first day, a large part of this deposits on the ground dry,
gets caught in the trees, on the grass, on buildings and anything else
that it comes into contact with. Another small fraction of it gets
chemically transformed into a sulfate. This is the anions of that
sulfuric acid that we talked about earlier. That is now an aerosol, a
very fine particle. Part of that can get rained out (wet deposited) and
a lot of it is dry deposited as well (which we are not showing on this
slide). The important thought is that this SC^ can go on for several
days getting less and less SO2 but more and more sulfate, and by the

end of three or four days we see a lot more sulfate than we do S02.
This mass of gas has now turned into a mass of particulate, which is
also very acidic.
Put another way, as days go on we see that S02 tends to go away,
sulfate tends to build up and slowly dry deposit out, and of course the
bulk of it dry deposits as S02 or wet deposits as S02 as it rains or
gets caught up in cloud water. The same sort of thing happens for
nitrogen although the chemistry is a little more complex. Most nitrogen
comes out as NO, a gas, which very quickly transforms chemically into
N02 and then a lot of the N02 does deposit out rapidly but then some of
it converts to NOg (nitrate) which is the anion of nitric acid, and that
nitric acid is a very sticky molecule which will quickly deposit out on
anything it comes in contact with that is dry or will get caught up in
the rain water. This nitric acid stays as a molecule (really a gaseous
acid if you will) instead of going into a particulate like the sulfate
does. Then some of this slowly transforms into PAN (the oxidant aerosol
chemistry) and that can stay in the atmosphere for long periods of time,
and finally gets deposited out as well.
What is the effect of all this? The effect is that we see these
hazy air masses; here is one blowing out over the Atlantic. Just to
show you that this can become disassociated with the sources of the
pollution which are back in this region, all this hazy air is moving out
here in the satellite photograph. The effect then is that we are going
to have a lot of particulates building up but those particulates are
also scattering light. This is a schematic of that same satellite photo-
graph. The gray area shows where the hazy area on the satellite photograph

was. The yellow areas are where ground level visibility is less than 5
miles. That is because the sulfate scatters light and that means you
cannot see through the air horizontally very far and decreases your
visibility. The red area is where visibility is less than 3 miles.
This means that you are unable to fly an airplane under those conditions
unless you are under instrument control.
Here we see the sulfate level during the same period of time build
up from 20 micrograms per cubic meter to over 50 micrograms per cubic
meter in 5 years. The rest of this area is white because we simply did
not have sulfate monitoring data. Our sulfate monitors, as you are
probably aware, come out of our hi-vol filters which are only turned on
either every 6 days or every 12 days. This area is on a 12-day cycle
and this area is on a 6-day cycle. The monitors happened to be on at
the right time so that we see part of where the high concentrations of
sulfate were.
Well, what are the atmospheric consequences of this? First, we see
that we have a lot of particulate matter around and, in fact, as we just
pointed out in the last slide, 50 micrograms is one-third of the secondary
PSD standards. So on that one day, one-third of what you are allowed to
have over a 24-hour period was in sulfates. Very little of that was
emitted near that hotspot area. Most of it slowly blew in from other
areas. That means that in those areas which are measuring or experiencing
high sulfates, they do not have the ability to control their TSP levels
as do areas that are less affected.

A second effect is this: remember that sulfates scatter light,
thereby decreasing your visibility. I am going to run very rapidly
through a little time sequence of visibility trends in the U.S. The
areas in white have a summertime visibility. The average summertime day
visibility is greater than 10 miles. The yellow areas are areas where
the summertime visibility is between 8 and 10 miles. We see a little
area over Washington, D.C. where the summertime visilbility is between 6
and 8 miles. In something like 15 years, these areas have spread out
quite a bit. We see that over a 20 year period we have a whole new area
where the summertime visibility on the average day is less than 6 miles.
That means that over a period of 20 years we have gone from over 10
miles visibility on the average summertime day almost everywhere in the
Eastern U.S., to a fairly large area where visibility is less than 8
miles and in many areas less than 6 miles on the average summertime day.
A lot of that is due to sulfates, not all of it, but over half.
This slide shows what the impact on visibility would be if you were
a vacationer up in the Adirondacks on some of the white mountains. This
would be the view on a fairly good-seeing day when the visual range is
30 or 40 miles. Forty-eight hours later, the visual range has dropped
down to less than 3 miles and yet this is not fog. Nothing obvious is
happening except that a hazy polluted air mass blew in. Remember this
is an area which the State of New York decreed in their constitution
should remain forever wild. I do not think that is a very wild picture
that we are seeing.

The third point I want to make in terms of the atmospheric effects,
besides the particulates and the visibility, is simply what we get
after depositing out. We have already talked about that so I am not
going to spend more time on it. I want to tell you more about the
source of these emissions. This is the latest data that we have showing
the source of nitrogen oxides emissions. Notice that a large portion
(just over 40 percent) are from transportation sources, mostly automobiles.
These are only for the U.S. not Canada, Ray. We see that another major
portion (a little over 30 percent) comes from the electric utilities
sector and still another good size portion (more than 20 percent) comes
from industrial combustion, then we have all of these little nickel and
dime portions thrown in as well.
If we were to look at the S02 emissions, we would see that the
electric utilities sector is by far the major contributor. About two-
thirds of the SO2 emissions in 1978 came from that one sector. Ninety
percent of these emissions came from coal-fired power plants. The next
largest sector is the industrial combustion sector, and I do not remember
the number, but the majority of these emissions are coal-fired emissions
for rising industrial steam. Other industrial processes, primarily the
nonferrous smelting industry, are responsible for less than 10 percent
and most of these are not in the area we are concerned about. These, of
course, are in the Southwestern U.S. Also, residential oil burning and
other sources contribute as well as various miscellaneous sources such
as oil refineries, etc.

This s1ide— I will apologize to you—did not come out as I had
expected. 1 wanted to show you these things stacked on top of each
other--the trend of these emissions over time for the total amount of
emissions. Here we see that these unimportant factors really have not
been having any major trends from 1940 to 1978. But we do see that
three sectors are industrial combustion post-1960; electric utilities,
post-1940; and transportation post-1940. Notice that there is a cut
here; there are 2 million tons per year of emissions cut out; that is why
we have the break. The important thing is that when you start adding
all these up on top of each other, the nitrogen oxide emissions are
rising very rapidly in time. Unfortunately, we see little to suggest
that they will not continue to rise. However, in the future there are
some promising technologies which you will hear about from Steve Reznek
that will suggest that we can at least start to turn the corner in the
future. That is at least several years off.
In terms of the S0£ historical emissions, again we see that the
less important ones have not been doing much over time, except that the
commercial-residential sector has declined from 1940 to 1978 simply
because most of the people do not want to burn coal in their store furnaces
or in their home furnaces. There is still, in some few States, a significant
amount of residential coal combustion which accounts for most of this
residual. The very striking thing is that industrial combustion
has declined dramatically during this time period. More than offsetting
it is the electric utility sector which has been growing very rapidly
from less than 3 million tons of S02 in 1940 to over 19 million tons of
SOg emitted per year in 1978. Again, I will caution you that there are

about 6 million tons per year cut out of this graph so that we could get
it all on one slide. The overall total trend, which is not shown here,
is that SO,? emissions rise slowly between 1940 and 1970 and then remain
roughly the same from 1970 to 1978 due to the great decrease in emissions
from these two sectors offset by the strong rise in the electric utility
sector. We are a bit more optimistic for S0£ emissions in the future.
We think that we are close to turning the corner, depending on the
electric utility sector. There are many uncertainties in predicting
that behavior but we see that we will be able to cap those emissions and
hopefully see them reduce before the end of the century, under current
operating conditions.
Let us see where the emissions come from. NO emissions are strongly
dependent on autmobiles so that every place there is an automobile, like
in Chicago or New York, we see strong amounts of N0X- For those of you
who cannot see it, the yellow squares are less than 10 grams per second.
This goes up expodentially, so that the green is 10 to 100; light blue
is 100 to 1,000; dark blue is 1,000 to 10,000; and the purple is more than
10,000 grams per second in this 80 by 80 kilometer grid cell. The other
point that you should notice from this slide is the area where electric
utilities are concentrated such as along the Ohio River Basin, especially
in the upper part of the Basin where we see a large continuous block of
NO2 emissions which are unbroken by spaces such as you have down in the
Southeast. Areas like this give little chance for the area to cleanse
itself as it goes from one high emission square to the next.

If we look at the SC^ geographic distribution, again we have this
expodential scale where yellow is less than 10 running through purple
which is greater than 10,000 grams per second. The single largest SO2
emission point in the North American Continent is this square up here.
That is one smelter. However, the two highest emitting grid squares on
here are this grid square and this grid square. That is because these
have enough power plants in them that they more than account for the
amount of emissions from this one isolated emitting point up here. In
fact just before I came here, just for the fun of it, I did a simple
little calculation any of you can do--assume that the depth of the air
that these emissions have to mix into is one kilometer thick. That is
roughly 2,000 feet which is a little high for a mixing layer, and this is
about 20,000 grams per second going into each of these grid squares.
Very quickly you come to the conclusion that if there is no transport of
air into or out of these grid squares and if there is no deposition of
sulfur going on in the atmosphere, that within a day, or a day and a half,
the U.S. primary SO2 standard would be exceeded in these grid squares
simply from that rate of emissions alone. So, we can be very thankful that
deposition does take place; we can be very thankful the winds do blow;
but, we have to consider what are the effects on other grid squares.
That is the point of this conference. Thank you for your attention.
(Slides were not made available for publication)

Dr. Gage: The next presentation will be a movie or rather an edited
version of a movie prepared by Dr. Walter A. Lyons. Dr. Lyons is the
President and founder of MESOMET, Incorporated, which is an environmental
and meteorological consulting firm in Chicago. Dr. Lyons received his
PhD from the University of Chicago and taught at the University of
Wisconsin for some years. He is the former chairman of the American
Meteorological Society Committee on Air Pollution Meteorology and has
published more than 50 papers in the area of pollution transport. I
will let Walter introduce this short movie which has been receiving rave
reviews around the world. Walter.
Dr. Walter A. Lyons: There are a number of comments I could make. This
is a "dirty movie" that is rated R for Research. The first such movie
was produced last year, basically as part of a technical planning conference
at EPA in Raleigh. It went over very well—so a book was produced by
EPA, and since widely distributed. The "Anatomy of an Air Quality
Episode" was so popular, like "Jaws", that we now have the "Blob" movie
as it has been nicknamed.
I would have to say that if repetition is the mother of learning,
I am going to come out with several motherhood statements here because
many of the things that have been said, I am going to repeat.
This film was produced both as a generic description of the entire
topic of long-range transport and it also highlights the use of several
new technologies, or I should say, old technologies being used in new
ways. It, furthermore, produces an inkling of what will be transpiring
this summer in a major field program called PEPE 1980. If we can dim
the lights first and start the projector.
This is the Eastern United States--and you have seen this picture
before—what is visible are not water clouds but clouds of pollution.

We are going to discuss satellite observations of what are now being
called "persistent elevated pollution episodes" or, the acronym PIPE.
A preface. The Clean Air Act directed concern toward many sundry
effects of air pollution on health and welfare. Part of this effect is
to examine the transboundary transport, and how to model it effectively
so that we can develop effective control strategies. With this goal in
mind, EPA will conduct an experiment this summer, called PEPE-1980 to
better quantify long-range pollution transport and transformation.
We turn to White Face Mountain in the Adirondacks on August 26,
1977. As Lowell Smith pointed out, it took a shift in the wind
and only 48 hours for visibility in excess of 30 miles to deteriorate to
less than 5 miles. Unfortunately, this is not an infrequent occurrence
but a common one throughout much of the Eastern United States. CompuUrized
trajectory modeling shows that on the first of these days the "clean"
air was coming in from polar regions—from Canada. In the subsequent 48
hours the trajectory analysis shows the air started avecting from the
southwest.--from the large industrialized regions of the Eastern United
States. The trajectories, I think, speak for themselves.
Ten years ago after the passage of the Clean Air Act and its Amendments,
much attention was given to the control of localized point sources;
power plants being, of course, one of the favorite targets. We were
scrutinizing the first 10, 15, or 20 kilometers downwind, and the sulfur
dioxide impact on those receptors. Various field programs began to
extend the view a little bit further. For instance, the MISTT program
in St. Louis. A plume from a large power plant, the Labadie plant,
located north of St. Louis, Missouri, was tracked by aircraft. Under
certain preferential meteorological conditions, that plume was observed

to move cohesively for over 300 miles into Southern Minnesota. Long-
range transport and then some. Of course, it does not exist in isolation
all by itself. There were many other sources of sulfur dioxide as well
as other pollutants in the vicinity. When you aggregate these together,
you do not normally just have a single plume but a conglomerate of plumes,
an urban plume if you will, which can blow in this direction, or any
direction that the prevailing low level winds are carrying it. Of
course, even though we are emitting a given pollutant--by various chemical
transformation processes—results are a myriad of secondary pollutants.
That is really what we are concerning ourselves with today.
The oxides of sulfur and nitrogen, especially in warm, humid air
masses, in the presence of sunlight, are transformed into a veritable
"chemical soup." Some of the constitutents we know well, others we are
just now beginning to monitor. With the right filtration, a time-lapse
camera system allows one to literally see the clouds of pollutants-
particles, liquid sulfuric acid mist, and other particulates—continually
drifting by with the prevailing winds.
An urban environment does not exist in isolation, it is surrounded
by other urban environments. During a typical summertime episode, when
North America experiences a stalled high pressure system, these begin to
coagulate and to accumulate. These combined urban plumes are what has been
called a "blob," a "smog blob," a "hazy blob," or a PEPE. If you examine
day to day the satellite pictures, they can be seen in one area as it
avects with the low level winds into another. The episode may also
continue to build southwards, move northwards into Canada, and usually
only ends after a cleansing cold front sweeps through from the west or
to the north.

Now Lowell Smith already has gone into great detail about sulfur
dioxide, but perhaps if you just look at a very simplified map of these
sources it brings the point home that anywhere in the Eastern United
States, nobody is really all that far from the very major source regions,
particularly a high stack source of pollution. There are many major
sources and many, many smaller sources. Now it may be just a few tens
of kilometers or it may be a thousand kilometers or more, but the atmosphere
clearly has the capability of dispersing pollutants that far. The
leading four States in terms of total tonnage, Illinois, Indiana, Ohio,
and Pennsylvania, are not alone because they are surrounded by other
States with lesser but still very significant contributions. Essentially,
we are all breathing each other's emissions, in fact, we are suffering
"the sins of emissions" of others (pun intended).
This is Chicago on a typical day in August 1976, and unfortunately
we could not blame this pollution on Gary, Indiana. This is a widespread air
pollution episode with visibility less than several miles extending over
many States. It is very interesting to watch the pattern of airport
visibility reports from the 17th to the 28th. These areas in orange are
visibilities less than 5 miles. These make a very good surrogate for
sulfate aerosol concentrations and other related pollutants. For the
first several days, little happens. You have a few random patches of low
visibility but after several days of "cooking," a massive area of 5, and
now less than 3, miles visibility begins to appear. An area of pollution
stretching from Louisiana up through Lake Superior out through the
Middle Atlantic States and well into the ocean persists for several

days at a time, waiting until on the 28th a very strong Pacific cold
front moved through and blew the entire mass into the Atlantic, and, of
course, we are not sure how far it kept going.
Keep in mind that a PEPE, a persistent elevated pollution episode,
is many things. It is a region of high sulfate aerosol concentrations,
producing low visibilities, almost always associated with elevated ozone
levels and is the stuff of which acid rain is made, or at least a signifi-
cant contributor. It is not an urban problem, it is widespread. In
fact, we turn to the satellite to show us how widespread.
What do satellites really see? First of all there are many types
of satellites. The one we are referring to is a geosynchronous satellite-
one that stands over the equator and allows us to see the entire earth
at a time. These pictures are taken in the visible and infrared portion
of the spectrum every 30 minutes allowing us to produce animations if
desired. It is in the visible spectrum, closely matching what we would
see with our own eyes, that we get the most interesting information.
Two satellites are monitoring the United States, GOES East and GOES
West. There is a similar one called METEORSAT which is monitoring
conditions over Europe. It is part of a satellite global network.
You will perhaps get a better idea of what the satellites can show
us by looking at this animation. Here is a static image at one o'clock
on a summer afternoon showing clouds over Oklahoma, Arkansas, and Missouri,
but with the tremendous increase of information we can obtain by animating
these images, we can see the morphology, and the dynamics of the atmosphere.
We begin to realize how incredibly complex things are, how air moves at
different levels, the different directions at different levels, how

thunderstorms can boil up and ingest air from the lower 2,000 or 3,000
feet and spread it over the 20 or 30 or 40 or 50,000 feet of the atmosphere,
involving low level air masses in the precipitation mechanism in a most
complex four-dimensional manner (the fourth dimension being time). So we
begin to realize we have new ways to view things, that animation is
important as an analysis tool. Just being able to see the geographical
extent of aerosols is most helpful.
Here is a forest fire in Los Angeles (it is either floods or fire
that appears out in this area). In November several years ago, severe
fires occurred in the mountains surrounding the Los Angeles area and by
animating the plume you can clearly see advection of several hundred
kilometers into the Pacific Ocean. There is no doubt about the reality
of long-range transport of particulates in high concentrations. Perhaps
ten years ago, we would have doubted that the smoke in this case could
have traveled that far in such high concentrations but that argument has
long since ceased.
Now, it is really no surprise if you fly above the Ohio Valley on a
typical summer day and you look down and do not see the ground, because
of the tremendous amount of reflected light from the sulfur aerosol haze
and whatever other constituents are there. It is no surprise that if we
can see it with our naked eye from an aircraft that we should be able to
see it from a satellite image which is designed essentially to see
reflected light. But first we would like to dispel a myth. In the textbooks
it says weather moves from west to east. This has already been alluded
to. If we go up to the jet stream we find that ribbon of air which
separates the polar air masses from the tropical air masses happens to

be at 30,000 feet, and, yes, air trajectories do move in a general west
to east direction although they can become highly convoluted. They do
have a tendency to steer the high and low pressure systems across our
television weather maps, but keep one thing in mind. If you check
further in your basic meteorology textbook, the air around a high pressure
system rotates clockwise. Air can move in any direction around a high
pressure system depending on where you are. If one checks the literature,
one finds various long-range transport episodes reported in Florida, in
the maritimes of Canada, even intrusions as far west as Oklahoma and
Kansas. Episodes can, and do, and will continue to impact any given
area from virtually any direction, depending upon the prevailing meteoro-
logical conditions. So, therefore, virtually every receptor can be
impacted from any source in an airshed which stretches from eastward
100 degrees west longitude.
An anatomy of a typical "smog blob" or a PEPE. A high pressure
system may drift out of Canada, initially very clean, but the circulation
around it begins accumulating myriads of pollution plumes over a wide
area. They undergo several days of transport—photochemical conversion--
and by the time it has extended to its maximum aerial coverage, the
episode may blanket the better part of 20 or even 30 States. We are all
"in the soup" together.
A major episode occurred from the 21st of June to the 6th of July
1975. Over a three-week period, much of the Eastern half of the United
States was engulfed. Computer predictions of sulfate concentrations
suggested that by the 29th of June a huge area would have experienced
exceedingly high sulfate levels, therefore, low visibilities, and probably

(by inference) elevated ozone values. By the next day, the 30th, the
enhanced satellite imagery did reveal a vast area of haze stretching
through this region. It had now shifted, not to the east, but to the
west. Why? Because the high pressure system was centered over the
Great Lakes. Visibility contours of less than 5, 3, and even 2 miles,
are predominate from Arkansas, up into western Missouri, Iowa, and
into Minnesota. Ozone levels in excess of 160 parts per billion (peak
hourly afternoon values) were recorded in the hazy air mass. The limited
sulfate data we have for this day indeed show elevated sulfates throughout
this entire region. This was in fact, a very typical episode.
This movie print has suffered somewhat from reprinting and has
lost a little contrast but I would like to show you a satellite animation
of that episode on the 30th of June. The whiteness visible throughout
the central U.S. is sulfate haze, with corresponding elevated ozone and
reduced visibility. Notice the general flow of the pollution from Pennsylvania
through Ohio, Tennessee, Kentucky, down to Alabama. Then it makes a
sharp turn and begins moving northward through portions of Arkansas,
Eastern Oklahoma, Missouri, Kansas, up through Iowa and into Minnesota.
Most interesting, between St. Louis and Kansas City, there seems to be a
"dark spot" in this overall bright, hazy air mass. This apparently is
air with reduced aerosol concentrations due to the involvement of that
air in thunderstorms perhaps 12 hours ago. These white spots are thunder-
storms ingesting massive amounts of low level air and, therefore, sulfate
aerosols which make excellent cloud nuclei. They are becoming involved
in the cloud and, presumably the precipitation mechanisms, with resultant
wet deposition—acid rain. It is a complex, four dimensional phenomenon,

but we can see clearly in the satellite image the "footprint" of what is
probably an acid rain event.
We move north on that day into Minnesota. Notice the tremendous
flow of polluted air from the south. Ozone values on this day were the
highest ever measured in the State (in and around central Minnesota).
Thunderstorms with precipitation in excess of 18 inches fell in Northern
Minnesota as that polluted air mass fed into those thunderstorms. What
rain did not become involved in the precipitation mechanism undoubtedly
moved through the Boundary Waters Canoe Area into Canada.
This different view provides the realization that Eastern North
America is one large, complex airshed.
What are the effects? Well, many of these effects have already
been alluded to. Certainly, there are known effects on aquatic ecosystems,
forest growth, and we are worried about possible effects upon important
agricultural crops. Even if the sulfur being deposited during a particular
episode is helpful to certain crops, it may coincidentally be associated
with high levels of injurious ozone. The different pollutants do not
"attack" as isolated incidents—they occur simultaneously, with possible
unknown, synergistic impacts. We take note of several epidemiological
studies. Urban dwellers spend much of their time inside. Yet certain
sectors of the population spend considerable time outside such as farmers
and children at camp. Also aerosols have been shown sometimes to be
significantly more acidic in rural areas than in urban atmospheres.
There are many differences which we have to contend with.

And what about weather modification? Note this thin band of haze
across Florida. The computer can enhance the image to better define it.
A very definite band of dense haze which came in from the Northeast,
across the ocean (and probably originated in the Middle Atlantic States)
was bright enough to absorb and reflect significant amounts of the sun's
radiation so that in the afternoon, thunderstorms formed both north and
south of it but not under it. This is a clear impact on local weather
as a result of man-made haze. During July 1978, a widespread episode
caused the oceans and coastlines of the Eastern U.S. to be virtually
invisible in the satellite images for several days. This line of thunder-
storms "chews" polluted low level humid air masses—the result is acid
rain. But do not forget as it has been pointed out many times, even
where you do not have these aerosols involved in the precipitation
mechanism, there are significant quantities of dry deposition.
Time-lapsed films of the thunderstorm reinforce the opinion that we
not only have to look at the horizontal motion of air but also its
tremendous vertical displacement. These aerosols become involved in the
cloud and precipitation mechanisms.
Acid rain has been shown to be highly episodic. As we begin to
look at acid rain systems with radar in the same way we monitor haze
systems with satellites, we may be able to find distinct differences in
acid rain episodes. We now discuss some of the technology that is being
brought to bear, such as the McIDAS system. This computer is attached
to an antenna at the University of Wisconsin which is directly receiving
digital data from the GOES satellite. McIDAS stands for the Manned
Computer Interactive Data Access System. It is a very complex system

which has been developed over the last 10 years in response to many
research needs. The hardware, and particularly the software, allows
research meteorologists to take real time satellite data, to analyze and
manipulate it, and to display it in video form while overlaying real time
meteorological data. McIDAS is going to form an integral part of this
summer's upcoming PEPE-1980 program where we wish to measure, track, and
detect the growth of these PEPE's or hazy blobs, and to make actual
specific quantitative radiometric measurements of the brightness of the
air mass which can be used as a surrogate for sulfate measurements.
This view is directly off the television display screen of the
system at 2030 Greenwich Mean Time on August 26, 1976. If you are having
trouble locating yourself, we will ask the computer to tell you where you
are. We will start drawing in the boundary. There is the East Coast of
the United States up into the Washington area and Long Island. This is
not a water cloud but a cloud of turbidity associated with a major,
large scale episode which stretched, as I mentioned, from Minnesota to
east of Bermuda. It may be hard to see on this print, but by using the
cursor, we were actually asking the computer to pick out the digital
values of brightness. How bright is this image? How much of the sun's
light is being reflected back into space? Seventy digital counts—
that is on a scale of 1 to 256. We find that over the dark water,
we get a very strong signature of these polluted air masses—in this
second measurement 80 digital counts. As a check, let us move the cursor
down over the "black" water, the unpolluted area south of this very
sharply delineated "smog front." The results—only 40 digital brightness
counts. A very definite and measurable impact on atmospheric brightness

is, therefore, recorded. This tells us something about the concentrations
of the aerosol and gives us quantitative ways to map it. As we mentioned,
as acid rain is occurring, we can now take a real-time satellite picture
of an episode, in this case in Wisconsin, Minnesota, and portions of
Ontario. We can overplot temperatures, visibilities, or surface wind
stream lines. We could use McIDAS to direct aircraft research so they
sample events more efficiently. McIDAS operators could also look for
developing thunderstorms which may be ingesting large amounts of polluted
atmosphere, and consequently, a highly episodic acid rain event.
In retrospect it is interesting to go back to an image that was
taken in 1974. We have long had the ability to use satellites to map
these large scale PEPE episodes. Again along the East Coast of the
U.S., from Boston to Washington, we could see this temendous polluted
air mass drifting off shore for over 1,000 miles. We do not know how
much further it goes because satellite coverage ends there. Yet I
suspect that if we were able to pick up the current European satellite
imagery, we would indeed detect, on occasion, the transport of significant
amounts of aerosols across the Atlantic Ocean (if it did not become
involved in any sort of washout mechanism).
We have presented here simply a synoptic review, trying to give
you, with a couple thousand pictures, perhaps saving a couple million
words, a "feel" for the temporal and spacial scales of the events and to
emphasize the fact that our atmosphere is a giant "chemical soup," in
which, there are many interrelated processes occurring simultaneously.
You cannot look at acid rain as independent of ozone or of sulfate
problems. They are many facets of a single problem. Thank you.

Dr. Gage: Thank you, Walter. Our next speaker is Dr. Kenneth Demerjian,
who is in charge of much of our modeling work, particularly that related
to the long-range transport of air pollutants, at the Environmental
Sciences Research Laboratory, EPA, Research Triangle Park, North Carolina.
Ken will give us an overview of mathematical models that predict the
transport and deposition of acid rain with particular emphasis on some
work which pioneered in Europe well ahead of the efforts here in the
United States. Ken.
Dr. Kenneth Demerjian: What I would like to do today, is discuss with
you some of the research and development activities in regional air
quality simulation modeling underway at EPA in the Office of Research
and Development. In particular, I will discuss some results from the
ENAMAP-1 Model (Eastern North American Model for Air Pollution) under
contract with SRI, International. ENAMAP-1 is a modified version of the
original European Model EURMAP developed for the Federal Republic of
Germany by SRI, International. The Environmental Sciences Research
Laboratory research program in long-range pollutant transport modeling
is multifaceted in nature. The major objectives of the program are to
expand upon our basic understanding of the various chemical and physical
processes occurring in the atmosphere and develop models which capture
the essence of these processes to provide realistic descriptions of the
relationship between pollutant emission sources and receptors. As you
have seen from Dr. Lyons' presentation, the complexities of the dynamic
atmosphere as it relates to transport and dispersion phenomena presents a
formidable task to the air quality modeler. Our mission is to develop a
sufficient level of understanding to construct theoretical approaches to

treat these critical phenomena within modeling. The goal is to develop
creditable scientific relationships capable of providing decisionmakers
with the information necessary to assess air quality impacts for given
emission control strategies. The program is designed to expand our
regional models to meet the evolving needs of the Agency.
Currently, regional studies have been focusing on the long distance
transport of ozone, in which case, we are concerned about the transport
and transformation of precursor emissions (hydrocarbon and N0V) and
ozone over various sections of the country and, in particular, the
Northeast Corridor (Baltimore-Washington, D.C. to Boston). The transport
of precursor emissions and ozone across State boundaries is of special
interest. The model development program meets basic needs not only for
regional oxidants but provides the framework for treating all other
long-range transport problems, such as acid precipitation. The chemical
formation processes associated with sulfur transformation into sulfate
are not significantly different than the processes that are involved in
photo-oxidation cycles of hydrocarbons and NO and actually are a necessary
prerequisite to the treatment of SO chemistry.
In addition to the continuing research of these processes, we also
have been looking at existing technologies and how they may be utilized
in near-term applications to address the problems of today. The ENAMAP-
1 Model is an example of such an application. The model covers a section
of the country from 30 degrees north to 50 degrees north latitude, and
105 degrees west to 65 degrees west longitude. The schematic on the
first slide identifies the important factors which have to be understood
in order to model the impact of emissions on air quality as well as its

impact on receptors in the area. It is quite easy to draw one of these
figures, the difficult part is developing theoretical formulacions which
provide a scientifically creditable explanation of the process.
Much of the work underway is designed to study individual phenomena
that contribute significantly to the regional modeling problem both in
terms of transport and dispersion, as well as the processes of deposition
and chemical transformation. The model, developed by SRI, that I am
going to discuss is a long-range trajectory type model. The basic
assumptions of the model and a schematic of its operation is presented
in the following two slides. In the U.S. version, emissions inventories
have been gridded on an 80 kilometer by 80 kilometer basis. The emissions
inventory is based on the National Emissions Data System (NEDS) information,
and has been augmented with refined utility data compiled for the Electric
Power Research Institute. The combined inventory has been incorporated
into this model. The model assumes that 12-hour averaged increments of
emissions are released into circular puffs of the order of the 80 kilometer
grid. They are then transported in 3-hour intervals with certain assumptions
regarding the dynamics of the atmosphere. First, the atmosphere is
assumed well mixed in the vertical and is bounded by the average mixed
layer height on any given day. Dispersion in the horizontal is based on
a Fickian theory, and assumes a t 1/2 functional form for puff expansion.
The chemistry is first order in SO2 transformation to sulfate. The
first order rate constant is based on best estimates, considering both
the photolytic and heterogeneous transformation processes. Dry deposition
for SO2 and sulfate are also first order processes. The wet deposition
of SO2 and sulfate are linear, but are related to the precipitation rate

that is empirically based on observational data. The puffs are transported
based on the 850 milibar upper air wind observations processed through
an objective analysis routine, and averaged over 3-hour increments.
The next slide highlights the major element values for processes
used in the model. The loss rate for S02 by dry deposition is assumed
to be 3.7 percent per hour. The wet deposition rate is a function of
the precipitation rate which is inputed into the model. The factor 0.28
times the precipitation rate gives the actual wet deposition rate within
the model. The transformation of SC^ to sulfate is 1 percent per hour,
based on a 24-hour average. All values chosen are best estimates based
on current information in the scientific literature. The model does not
consider NO or nitrate chemistry, but we are currently considering a
developmental effort to include these processes.
The gridded region of the model shown in the next slide is the 70
by 70 kilometer receptor grid. It covers portions of Eastern North
America and the United States. Calculations on individual grid cells
are available, but for computational and interpretational convenience,
the region has been blocked off into sectors. The next slide shows the
various sectors in the model. The model application considers each
individual region to assess not only its localized impact on itself but
the interregional exchanges that it has with other sector regions in the
modeling domain.
The following results are analyses of two sets of case studies
based on results reported in SRI, International's final report to EPA
available within the next month. Before discussing those results, the
following slide shows a sample output from the model, in this case S02

isopleths over the modeling region. In the handout presented today, you
will find comparisons given between SO^ concentrations from the model
and observations from the Storage and Retrieval of Aerometric Data
(SAROAD) and Sulfate Regional Experiment Program (SURE) networks. The
results presented are monthly averages for August 1977. The model gives
both ambient concentrations of S02 and sulfate as well as deposition
fields for SO2 and sulfate both in terms of dry and wet deposition. The
model also computes and compiles tables of interregional exchange for
each one of the parameters above. An example of such a table is presented
in the handout.
The first example shows annual average depositions for the three
major receptor regions in the year 1977. This is total sulfur deposited.
The three regions of highest total deposition are Region V south, Region
II and Region IV north. The interesting conclusion drawn from these
results is that at least 50 percent or more of the total sulfur deposition
contribution, within these regions, comes from the region's own emissions.
This result makes physical sense in that SO2 is dry deposited at a
fairly high rate, therefore, its lifetime in the atmosphere is rather
short compared to that of sulfate. Therefore, major amounts of SC>2
emissions are taken out of the system rather quickly, so the region gets
back the SC>2 emitted fairly quickly through dry deposition processes.
Remember that the rate of dry deposition is 3.7 percent per hour, the
transformation rate is 1 percent, and the sulfate deposition rate is
less than 1 percent per hour. Total sulfur deposition is dominated by
dry deposition of S02> shown in the hestogram. Contributions by other
regions to these sectors do exist, but they are not the dominant factor.

In the next slide, analyzed results for dry and wet sulfate deposition
are presented. In this case, we are considering the sulfate components
only. Presented on this slide are the three highest receptor regions
for wet and dry sulfate deposition for August 1977. The results have
been unit area normalized to mitigate the varying size of regions. The
highest three regions for sulfate deposition are Regions II, III, and I
in order of decreased magnitude. The interesting observation in this
particular case is that the self contributing component is not of signi-
ficance, except possibly for Region III. Major contributions in Region
I and II are from other regional sectors.
Upon reflection, these results seem quite reasonable. Since sulfate
is a long lived species in the atmosphere, due to its slow chemical
formation and deposition and its chemical stability, it is available for
transport for longer time periods. One of the interesting problems that
will have to be addressed in the near term is our ability to better
understand this phenomena, and other phenomenological processes that
contribute to long-range transport in the atmosphere.
One other important point that must be made is that these results
do not indicate anything about the acidity of the sulfate. They only
address sulfate deposition. The model is not capable of dealing with
the chemical processes related to the composition of the sulfate. Such
detail can only be considered in complex theoretical models currently
under development in our program. We are currently performing research
studies aimed at resolving major contributions associated with the
regional transport problem. These include cloud invection processes in
terms of their ability to pump pollutants from the lower atmosphere into

upper layers of the atmosphere, heterogeneous processes within clouds
affecting chemical transformation, better estimates in dry deposition
rates, and the compositional aspects of sulfates and nitrates in the
ambient atmosphere. With that, I would like to conclude my talk.

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Mr. Gage: Well so far, we have been concentrating on what goes up into
the atmosphere; what happens to that material in the atmosphere; how it
comes down; and what is the effect of that material. Now we would like
to take a somewhat different tact for the closing formal presentation
today and that is: what we might be able to do about keeping those
materials out of the atmosphere. Before I introduce the next speaker, I
would like to indicate that following this next talk, we will have
discussion among all the panel members who have given presentations this
afternoon and the State representatives. I also would like to indicate
that we will take written comments and questions from other members of
the audience and we are serious about responding to those in the time
that we have. I see that Dave Hawkins is right out here in the front
row and if you would like to get a question up here, we will take them
in order of the written questions received there by Dave, or Dennis
Tirpak or Ken Demerjian could take them. As I collect them, I will try
to work them into the series of questions which I am sure will be coming
from our State respresentatives. Without any more introduction, let me
introduce Dr. Steven Reznek who is the Deputy Assistant Administrator in
the Office of Research and Development. Steve heads the Office of
Environmental Engineering and Technology and as such has the responsibility
for the pollution control development activities within the Environmental
Protection Agency. Steve will be talking about the technology and cost
of controls associated with controlling the acid precipitation precursors,
the nitrogen oxides, and the sulfur oxides. Steve.

Dr. Steven Reznek: Thanks, Steve. (Slide 1) Many of the other papers
were about subjects that nobody in the audience knows much about, like
satellites. I am going to start out by violating one of the rules of
public speaking, I am going to talk about what I am not going to talk
about first. It is possible to control the national emission inventory
or the regional emission inventory of sulfur and nitrogen oxides through
nonstructural approaches. (Slide 2) These options can be extremely
attractive because they do not require any new capitol investment or
capitol construction. They would require changing the electricity
capacity dispatch among the utilities that operate in the Eastern United
States. Such approaches raise a series of very complicated and confusing
economic and institutional questions. We are going to be looking at
such solutions, what can be achieved, and what some of the problems
would be, but we have not yet moved very far in that analysis. Therefore,
as I started out by saying, that is one of the things I am not going to
talk about.
What I am going to talk about is some of the technology solutions
that exist today for solving the problem. Slide 3 summarizes some of
the things I am going to cover. We differentiate the technologies as
those applicable to NO reduction and sulfur oxide reduction. We have
also listed them in terms of precombustion modification (what you can do
to coal to make it a cleaner fuel); changes in the combustion process
itself (things you can do today to make that process cleaner); and
finally, the treatment of flue gas after combustion to remove sulfur

I want to take one minute to talk about the combustion processes
used today. Approximately 60% of the N0X emitted by utility boilers
comes from so-called wall fired units. These are units where the actual
coal-fired burners are in the long faces of the boiler. Forty percent
of the NO from existing facilities today come from so-called tangential
fired boilers, the coal burner is in the corner. One of the things you
can do is to use so-called modern burning designs. This means replacing
the burners. That is only applicable on the wall fired facilities. The
modern burners could not be used in the tangential fired capacity.
There are things that you can do to control the combustion process in
the tangential fired burner. We will return to this point.
First thing I want to talk about is physical coal cleaning. Slide 4
is a schematic of a coal cleaning process. The coal comes into a crusher
it is ground up and goes into a grate, and then it is introduced into a
liquid bath, and the schematic shows what happens. The ash material is
heavier than the coal. The coal floats on the surface of the liquid and
is removed. The ash material and, in particular, the sulfur containing
pyrite sinks to the bottom and is removed.
We have a number of handouts in the material, including an article
which was prepared by the Electric Power Research Institute, discussing
the advantages of coal cleaning. Over half of the coal mined in the
United States today is cleaned in a process similar to this. Those
processes are not optimized for sulfur removal, however. There is
another article by Jim Kilgroe summarizing our position on the clean-
ability of various coals in the United States.

You cannot completely separate the coal floating on top and the ash
material that sinks to the bottom. All coal cleaning processes require
or imply a loss of coal in that bottom residue. For highly cleanable
coals that residue can be kept to about 5 to 15% of the carbon content.
Slide 5 is a schematic of the technology for which I guess EPA is
most famous, that is, flue gas desulfurization scrubbers. In flue gas
desulfurization, a slurry of an alkaline material either lime or limestone
usually is introduced into the chambers you saw, and the flue gas post-
combustion is also blown up through that chamber. The sulfur oxides in
the flue gas reacts with the alkali lime or limestone and is absorbed—
the gas goes out and is discharged.
We show two versions of flue gas desulfurization, the so-called
spray dryer version is applicable to lower sulfur coals. In that version
the heat of the flue gas is used to completely evaporate the slurry.
What comes out is a dry powder. The spray dryers that are being built,
and have been built at pilot scale, are using lime as the reactor rather
than limestone.
In the more traditional kind of scrubbing--the wet scrubbing—the
heat of the flue gas is not nearly sufficient to evaporate the water.
The water with the reacted limestone is discharged. The solid matter is
separated—that is the stuff called sludge. There is a very large
handout in some of our materials discussing the subject of sludge.
The capitol investment in the dry or spray drying technology is
considerably less than the capitol investment in the wet process, however,
the operating expenses are considerably higher. First, you have to use
lime rather than limestone as a reactant. Second, the reactant's

alkali is not fully utilized, so you will have to use more of it than
theoretically the minimal amount for the sulfur. What all that means is
that for low sulfur coal the technology of choice will be the spray
dryer. For high sulfur coal the wet or conventional flue gas desulfuriza-
tion will be the most economical. It appears that the break-even point
is between 2 and 3% sulfur coal.
Slide 6 is a schematic of a modern dual register burner. The
pulverized coal enters down the center tube and air is introduced to the
flame chamber from two separate registers, an inner air supply and an
outer air supply. There is not enough air in the first tube to complete
the combustion so the flame forms in two zones. The first part is the
reducing or fuel rich zone where much of the coal is partially oxidized.
The outer air supply has enough air to complete the combustion. That
staging process prevents the oxidation of the fuel bound nitrogen. Fuel
bound nitrogen becomes Ng rather than being oxidized to NO, the nitrogen
Slide 7, this techno!ogy--over-fired air--is applicable to the
corner fired or tangential fired boilers that are in place now. Here
you want to stage the addition of air to complete combustion, however,
in this case you add the secondary air well away from the burners at the
top of the boiler. It is possible to achieve close to the same results
in terms of reducing the formation of NO.
Slide 8 is a summary chart of the cost of sulfur reduction technology.
The two middle bars are low sulfur coal and the bars on the extreme left
and right are high sulfur coal. The first technology, PCC is physical
coal cleaning.

We are able to remove between 20 and 40% of the sulfur. Assuming
you are trying to recover something like 90 to 95% of the energy value,
your ability to remove sulfur is very dependent on the individual coal
Northern Appalachian coal is the most easily cleaned coal. As you
move into the central province coals—Ohio, Indiana, and Illinois
coals—the sulfur becomes more difficult to remove. For the two low
sulfur coal cases, we have costed out the spray drying technology and
the conventional flue gas desulfurization technology for 70% removal for
low sulfur coals. We have also developed the costs for treatment of
high sulfur coals, taking conventional technology at 90% removal. At
the bottom of the slide, we show the cost per ton of sulfur removed.
You will notice that the physical coal cleaning and the flue gas desul-
furization on the high sulfur coal are coming out about the same cost.
Another document in the handout has looked at 11 different utility
boilers that actually exist, and at the cost savings that can be achieved
by combining front-end coal cleaning with back-end flue gas desulfurization.
Those designs are for 1.2 pounds per million Btu emission requirements.
Slide 9 is the same kind of information for NO removal using the
present currently available control technology. In both the modern
burner design on the wall-fired units and the stage combustion or over-
fired air on the tangential fired units you can reduce their present
emissions by about 30%. The cost to achieve that reduction is quite low
compared to the sulfur costs.

Slide 10 is a summary table of costs. The first column and the
last column are the numbers you have seen on the previous two graphs.
Let me concentrate on the middle two columns, they are the cost per unit
of electricity generated. Look at the high sulfur coal case. Physical
coal cleaning, the capitol cost, is in the range of $35. per kilowatt of
electric generating capacity that you would design that coal cleaning
plant to supply. In other words, if you were designing for a 1,000
megawatt plant, you would multiply that 34 by one million and get 34
million dollars. The conventional flue gas desulfurization cost is
$175. per kilowatt of capacity. These cost are based on amortization
over a 15 year lifetime, assuming a retrofit, and the load factor is
50%. We are assuming those plants will continue to operate at 50% of
the time over the next 15 years. That 50% number goes into the annualized
cost in terms of dollars per kilowatt hour of power produced. Those
numbers are reflected in the 2.7 mills per kilowatt hour for the physical
coal cleaning and the 9.1 mills per kilowatt hour for the flue gas
I have included in the handout five summary data tables, but I am
only going to look at one of them. I put in a summary of the performance,
the applicability, the advantages, and the disadvantages for each of the
five technologies that I have talked about. Let me just run through the
one for physical coal cleaning. (Slide 11) The performance has a range
of 20 to 40% reduction, it is applicable on the Eastern Appalachian coal
and some of the Midwestern coals, but as you go to central province
coals, the applicability goes way down. Advantages are lower cost,
often lower transportation cost, the EPRI paper discusses the fact that

the Btu content of the clean coal can be significantly higher than the
Btu content of the raw coal. Much of the solid waste--sulfur, pyrite,
and ash--that would be generated at the coal cleaning plant are at the
mine where disposal problems are easier to resolve. This is one of the
few ways of getting a cleaner fuel to small boilers, boilers that could
not afford flue gas desulfurization technology.
Disadvantages—it is not applicable to all coals, only a 20 to 50
percent reduction can be achieved and there is an energy penalty. There
is a coal loss penalty of 5 to 15%. I have such a summary sheet in the
handout for each of the other four. I want to turn lastly to some of
the things that are on the horizon.
We do support an R&D program in control technology. (Slide 12) We
are going to demonstrate a three-stage combustion burner. The first
one, the low N0X burner would be applicable to the wall-fired unit and
the so-called rich fire ball would be applicable to the corner-fired
boilers. One of the problems that you have to demonstrate that you can
avoid is corrosion on the wall faces of the boilers. Therefore, these
demonstrations have to be fairly long-term, at least 18 months. We hope
to have those completed by 1983.
The summary paper in your handout talks about what we are hoping to
achieve--i.e., a 70 to 80% reduction in NO emissions. These technologies
hopefully will be usable on the existing boilers. Another project that
we hope to have completed this year is the creation of coal limestone
pellets. This fuel would burn with considerably reduced S02 emissions.
This fuel is not applicable to utility boilers. It is applicable to
small, stoker-fired boilers. We are hoping that demonstration will be
completed this year.

Another demonstration that we are hoping to complete this year is
our buffered limestone scrubbing, so called adipic acid additive.
That is a buffering agent to the limestone slurry. It allows very enhanced
control of the chemistry of the desulfurization reaction. One way to
look at the effectiveness of this technology is that for the same design,
it would increase removal efficiencies from 90 to 95%. The other way to
look at it is if you design for 90% removal, you would lower your overall
cost by about 1% using adipic acid buffering.
Finally, let me talk about the last technology. We are extremely
excited about this. We are going to try to combine our low N0V burners
with a powdered limestone addition to the coal. This is a very cheap
technology. We know from pilot data that it will force the sulfur in the
coal into the form of a calcium sulfate in the particulate. Some
Western coals burn this way right now. Instead of coming off as S02, the
coal's sulfur decreases calcium sulfide in particulate. With the new
technology, you will be able to catch the sulfur without a scrubber,
using only conventional particulate control. This is now a gleam in our
eye, based on some pilot data, but we are hoping to get to a demonstation
by 1985. Thanks, Steve.
Dr. Gage: Thank you, Steve. Amazing we are within five minutes, allowing
for two academics, one member from the private sector, and four bureaucrats.
I don't think that is too bad. Now, we would like to open the floor for
discussion, and I would like to ask Dr. Galloway and Dr. Cowling to come
up and join us during the question period. Please identify yourself and
your State.

Emissions Control
Technology and Costs
Steve R. Reznek
April 8,1980
Slide 1

Nonstructural Approaches
Least Emissions Dispatching
• Institutional and
Economic Questions
Plant Retirement Schedules
Slide 2

Summary of Existing and Near Term
Control Technology
SO* Reduction
Classification Technology Applicability Technology Applicability
Post Combus-
Flue Gas
tion (FGD)
•Spray Drying
High Sulfur
High Sulfur
Low Sulfur
Burner De-
sign (MBD)
Staged .
Boilers Less
than 15 Years
Slide 3

Physical Coal Cleaning (PCC)
for Precombustion Sulfur

Raw Coal and
Media Feed -

' Coal
¦To Refuse
Overflow ^ jo Further
1	Processing
Enlargement of
Gravity Separation
/^ir .i—j Thermal
Heaterjn Pry'"9
Clean Coal
Slide 4

Flue Gas Desulfurization (FGD)
for Post Combustion SOx Reduction
Dry Scrubbing
Flue Gas
Dry Solid Waste Disposal
Conventional FGD
	Clean Gas






"Wet" Solid
Waste Disposal
Slide 5

Modern Burner Design (MBD)
For NOx Reduction
Pulverized J
Coal Inlet
Inner Air 0uterAir
SuPP'y Supply
Slide 6

Staged Combustion
(NOx Combustion Technology)
Burn Out

SOx Removal & Costs
Retrofitted on Existing Utility Boilers
% sox
Low Sulfur Coal
High Sulfur Coal
Removal Cost
$/Ton SOx
Slide 8

% NOx 20
NOx Removal & Costs
Retrofitted on Existing Utility Boilers
Removal Cost
$/Ton NOx

Control Technology Cost
Retrofitted on Existing Boilers
Annual $/Ton
Percent Capital, Cost, SOxorNOx
Removal $/KW mills/kwh Removed
SQy Control
Low Sulfur Coal
•	Conventional FGD
^ • Dry Scrubbing FGD
High Sulfur Coal
•	Conventional FGD
NO* Control
•	Modern Burner Design
•	Staged Combustion
Slide 10

S0X Control Technology
Physical Coal Cleaning (PCC)
•	20-40% Reduction
•	Appalachian and Mid-Western Coal
•	Low Cost
•	Lower Transportation Cost
•	Solid Waste at Mine
•	Small Boilers
•	Not Applicable to All Coals
•	Low to Moderate Reduction
•	5-15% Coal Loss
Slide 11

Will Brown from New Hampshire, Acting Chairman of our Water Pollution
Agency. I would like to commend our guest from Canada for a forthright
and down-to-earth statement. I would hope that it is not just because he
is a long way from home and feels freer to speak up. I would hope that
many of his American counterparts who go to Ottawa would do an equally
good job. I guess what I am saying indirectly is that I for one around
the table here am not technicial. I recognize the importance of the
research work in which you are engaged, but I get a little impatient to
come to grips with what we are going to do about it, especially in
political terms. I guess that is more of a comment than it is a question
for any one individual; unless it might be fair to ask Ray Robinson
since he alluded to the work that is being done toward an international
treaty, whether he would care to make any comments as to how that is
proceeding, whether there is anything that individual States can do that
might be helpful.
Mr. Robinson: Thank you very much for your comments. I do not think my
comments were a function of distance from my superiors. Quite the
contrary. In our system, it is extremely important that the really
exciting news be given out by the boss rather than by someone like me.
That is to say, I really feel that we are going to be able to say even
firmer things. We are very, very determined to bring SO2 emissions down
in Canada, and it is a little easier for us because we have some rather
larger targets in the sense that they are all concentrated in one or two
places. Our talks are already underway toward that end, so it was not
just rhetoric. We are, in fact, going to bring those S02 emissions
down. I think, to put it very squarely, we now realize that some

things are happening to our environment that are widespread and serious.
The only argument is how quickly it is happening and precisely what
effects and the range of those effects. There is no argument about
whether something adverse, or of a serious nature, or widespread is
occurring. From that standpoint it has not been too difficult for us to
develop the political consensus to move. I fully recogni2e that this is
more difficult for yourselves because you have a much more varied situation
in the United States in terms of the impact. Having said that, that
raises the question which you raised, which is the question of the
agreement between the two countries. We have before us now, a proposal
by the United States to set up a structure that is analogous to the one
that preceeded the Great Lakes Agreement. Some of you are familiar with
that, indeed some of the States here are very familiar with that agreement,
and will know that prior to negotiating the original agreement back in
1972, there was set up between the two countries a task force with ten
subcommittees to look at all the component elements that should go into
the agreement, to examine what the IJC had brought forward, and then
recommend to the two governments what ought to go into the agreement.
That was the procedure that was followed. It was very effective, and it
led to an effective agreeement and a subsequent renewed agreement as you
know in 1978. To those States here today that are located around the
Great Lakes, I think you will agree that we are certainly moving in the
right direction in the Great Lakes area because there has been a real
improvement. The proposal now is that we put in effect a similar structure
for the purpose of bringing into reality an air quality agreement.
Obviously, as a general concept, we welcome that proposal. We are now

examining the detailed description of the task of each committee to see
if we agree with that. If we do, no doubt, we will get it on the road.
Thank you.
Dr. Gage: We have not waited for a formal agreement to be signed either.
We have had joint research groups working for some months now and they
are preparing a report, to be dated, I believe, October 1, to advance
our understanding of the transboundary problems. Of course, all of
tomorrow's session will be devoted to the thrust of your initial question,
Mr. Brown, pointing towards steps we can take here in the United States
to begin to discuss what other problems we are going to run into in both
the political, technological, and economic areas. Other comments or
Carl Beard from West Virginia. Dr. Robinson, I heard you say there were
measurable changes in soil chemistry that your people have looked into
and researched. I thought I heard you say it is changing rapidly.
Could you enlighten us a little further on that? Who is doing the work
for instance?
Dr. Robinson: I am sorry, sir, if I misled you on that point. What I
was saying and, in fact, what I skipped over in my address because I
felt I was repeating some of the earlier statements, was basically that
while there is disagreement, or more precisely a lack of conclusive
evidence on the rate at which changes are occurring, what we are finding
is that in the aquatic ecosystems there are appearing a number of components
that were previously in the soil. Obviously, these are coming out of
the soils, and the rate at which they are coming out does seem to be
erratic. There is some confusion over the speed at which the phenomenon
is occurring. What we really get down to is not so much the argument

about whether there is a change in soil chemistry, there must be. The
substances are coming out of the soil in a manner different than would
occur in a normal sense. Therefore, there must be changes occurring in
the soil chemistry. The difficulty has been in determining what this
means. There is the argument about the positive effects in certain
particular types of soil. We come back then to the particular kind of
soil. If you look at the different kinds of soil, again you draw a
quite different conclusion as to the implications. From that perspective
we are no further ahead than anybody else. Our particular concern,
naturally, necessarily, is over the impact on our forest because of the
size of our forest industry, and also because located as we are in a
northern area, our growth cycle is slower than in southern areas.
Therefore, any marginal impact could have quite serious implications for
us. We have a marginal economic productivity in some areas. That being
the case we have been able to demonstrate in internal studies and in lab
work definite reactions in vegetation to changes in acidity in soil
chemistry. We have not been able, to borrow a term from the atmospheric
chemists, to ground test these truths in terms of the reality out in the
field. The reason for that is one that anyone would readily recognize,
there are so many different things which impact on the growth of trees
that to be able to demonstrate over a short timeframe that what you have
shown in the lab is occurring in a real life situation is certainly
difficult. Our forestry scientists tell me they would be no more successful
than the Swedes, who have been at it a lot longer, in trying to prove
that what they have shown in labs is also occurring out in the fields.
A lot of the disagreement about the impact on the forest industry comes

from the fact that we cannot conclusively prove, in the field, that
trees are, in fact, growing more slowly. We do not have the background;
we do not have the data; we do not yet have the time to do this. We
certainly can show that there are changes in soil chemistry, we can show
that that appears to have adverse effects in lab settings, and we--the
people who are expert in these things—can draw a number of conclusions
about what it does to plants if you make certain changes in nutrient
patterns—the possiblity of the uptake of nitrogen for example, this
sort of adverse impact. All this can be done and put forward on a
theoretical basis, but it is still questioned for the reasons I have
indicated. I do not have before me the list of people doing this type
of study, but I am sure that information could be obtained for you.
Dr. Gage: I might also ask Professor Cowling to respond in part to that
question. Professor Cowling along with a number of other U.S. scientists
was at the meeting in Norway less than a month ago. I believe the
Swedes reported at that meeting some very interesting and alarming
results on the effects of acid rain on certain soil horizons in southern
Professor Cowling: Let me comment in general about what we understand.
I think Dr. Robinson has characterized our general understanding very
adequately. The hydrogen ion tends to displace other cations--some of
which are nutrients, some of which are metals. Whether they are metals
or whether they are nutrients, they are going to end up downstream.
That may be groundwater, surfacewater, streams, lakes, or so on. I
think it is also important to understand that certain soils would benefit
from acidification. In Western Canada and the Western United States

there are soils that are more alkaline than optimum for a range plant
growth or for forest growth. In certain of those instances a bit of
acidification could be beneficial. In most soils, acidification tends
to decrease productivity, largely because of displacement of cations.
A diminished cation exchange capacity means the ability of the soil
chemistry simply to hold nutrients in a situation where the plants could
benefit from them. There are also rather complex influences on soil
microbial processes. It is very difficult to generalize about those
influences because they are so variable with the type of soil and with
the nature of the vegetation. I think it is also important to recognize
that in this linkage between dry deposition and acid precipitation, it
seems a simple solution to inject ammonia into the flue gas stream,
create neutral ammonium sulfate, and get rid of the acid rain problem
period. But the net effect of ammonium sulfate being deposited dry in
an ecosystem would be about 1 1/2 times as acidifying in its effect on
the ecosystem as would be the direct deposition of an equivalent amount
of sulfate as sulfuric acid. That is due to the microbial transformation:
that would be induced and the uptake of ammonia from the ammonium sulfate
ion. The soils are an extremely complex area for investigative work and
in the opinion of most of the scientist at the Norwegian conference we
believe that whereas we know about the effects in aquatic ecosystems, we
would say the next most likely frontier for affects that would be signi-
ficant and particularly in regions that are dependent heavily on non-
cultivated soils, forest and range soils, in those regions we can find
affects. That seems generally appreciated whether you are talking to an
English scientist, a German scientist, a Norwegian scientist, or a
Canadian or American scientist.

Dr. Gage: Thank you, Ellis. Another question.
Del Rector from Michigan: The question for Dr. Robinson is my perception
that both the citizens in Canada and the Canadian officials at the
Federal level have placed a very high priority on the acid rain problem,
and in fact, it appears to be setting an even higher priority than they
are in solving the problem of ozone which is also a long-range transport
problem. First of all I would like to know whether assertion is correct
and, if it is, whether you think the government is placing the proper
priorities on these pollutants and what are the problems with the public
health issues.
Dr. Robinson: That is quite a question. I think it is fair to say that
the concern of the public over acid rain is much larger, as a generality,
than the concern over ozone. That is correct, what you have just said.
In a democratic society, as in your country or ours, that is reflected
in the political process. Certainly, the governments of both the Provincial
and Federal levels are currently giving a lot of attention to acid rain.
There is no question about that at all. On Friday of this week, the new
Canadian Environment Minister, Mr. John Roberts, will be meeting with
his Ontario counterpart for some pretty pointed discussions about where
we are going and we hope to be moving pretty smartly toward real control
measures, not just theorizing about it but really moving. That is a
reflection of a political need as well as an environmental need which is
why I talked about a political imperative when I gave my address. There
is no question they are responding to that. In the matter of ozone, I
think there are two factors to consider here. It is certainly true that
ozone is a part of the long-range transport problem and it is certainly

true that in Southern Ontario we are getting levels that are beyond what
we call our objectives and you call your standards. There is no question
about that. It is also the case that a good portion of the ozone that
we are receiving in Southern Ontario does appear to be coming from
beyond our southern border and I guess there is a limit to what we can
actually do about that. You might say well why don't you build it into
the discussions. I guess it is a matter of developing sufficient detail
to do that. It also is a matter of looking realistically at what is
being done and what more could be done. Again, taking the field of car
emissions, for example, automotive emissions which are seen as major
precursors to ozone creation, there I think it is fair to say that the
U.S. has been world leaders in controlling auto emissions. I would
personally like to see my own country do rather more in this regard but
the question really arises: What more than you in the U.S. do? There
are certain other things that can also be done but I think realistically
we have to look at what you might call the controllability of the problem,
as well as the impact of the problem. In the area of acid rain the
potential for contolling the sources is enormous. Whether they get
controlled is another question but the potential for control is tremendous.
The potential for control over and above what is being done now for the
ozone problem is much less. You can get a handle on some of it through
the same sort of controls you would have for acid rain. That is another
question. If you had effective control on the acid-causing pollutants
or the precursors, you would also get a better handle, obviously, on
ozone since in some cases it is the same precursors. So from that
perspective, I see as a practical matter the thrust to deal with acid

rain as having some benefit in the ozone matter and as a practical
political matter in Canada, there is no question that acid rain is the
front page concern. So from both of those perspectives, I am not too
upset about that situation.
Dr. Gage: Yes, Bob please.
Bob Flacke, Commissioner of the Environmental Agency from the State of
New York: For Dr. Cowling and Ray Robinson. Is there enough evidence
available today in the basic academic and scientific community to indicate
that some sort of source control is a necessary prelude to the variation
of problems at hand?
Dr. Gage: Ellis, do you want to take a crack at that first?
Dr. Cowling: I think we need to distinguish the extent of the scientific
evidence of effects on the aquatic ecosystems from the extent of the
evidence on terrestrial. We know that there are effects in aquatic
ecosystems and I think we know enough to realize that if we work at
diminished emissions we can prolong the useful life of the lake if I may
say it that way. I think we could prolong the time period over which
this titration that I showed in that one draft would occur and there may
be other methods by which we could come to deal in a more effective way
with the deleterious effects in time. I believe we know enough to have
confidence that if we diminished emissions we would increase the longevity
of our fish populations in lakes and I would certainly think that that
should be under very serious discussion as a matter of regulatory
Dr. Robinson: Bob, if I could speak quite bluntly to that question. I
explained in my address, but I did not bring along with me slides that

would have shown it more graphically, that a very large portion of
eastern Canada is poorly buffered which simply means that the lakes and
streams in that very large portion—and we are talking about probably
something in the order of three quarters of a million square miles or
something of that sort, maybe more--are, over time, bound to take on the
same acidity as the rainfall, simply because the buffering capacity is
either nonexistent or is rapidly exhausted. The question at issue is
how long will it take for many of those lake systems to reach the level
of 5 pH which seems to be the magic level at which fish life starts to
show serious problems. In fact, in the long term, the fish will not
survive at pH below that level for the most part. Given the fact that
the rain falling on these lakes is below 5 pH, significantly below in
some cases, it is just a matter of time before that occurs. How much
time? Well, the answer to that depends on the size of the lake, the
quantity of water in it obviously, and the precise location of the lake
in terms of the amount of acidity in the rainfall. Therefore, if the
lake is further to the south, in Canada, there is a greater chance of it
going acid that much more quickly. Already we have lost about 150 lakes
which have reached acid levels of 5 or below and into which have also
been released from the surrounding soils sufficient heavy metals which
are toxic to fish. As a consequence, our efforts to lime some of these
lakes to restore the acidity levels and reestablish the fish populations
have failed. The fish were not able to cope with the change in water
chemistry. That is very worrisome because it suggests that notwithstanding
the obvious difficulty of reversing the pattern and getting the lakes to

pH levels that are acceptable through a natural process, you may not be
able to reverse the effect, which is extremely worrying. That is why I
use the phrase in my address "time sensitive." That suggests to us that
we really do have a clock ticking away and the more dramatic efforts in
Canada to popularize the issue have shown clocks with so many lakes per
minute disappearing. Nonetheless, statistically there is a certain
element of truth if you look at it over the long term and we are probably
talking twenty years for a good portion of these lakes. It may be
thirty years, it may be less than twenty, and it is that kind of precision
that we do not yet have. Here I will speak very bluntly, if I look at
the projections for N0X and SC^ emissions in Eastern North America over
the next twenty years, they all show substantial increases. That means
the acidity of the rain is going to get greater, there will be more acid
rain, rather than less. It means it will spread over a larger geographical
area and that the pH values will be lower in the sensitive areas—the
very pattern we have seen shown to us today. On the basis of present
levels of acid rain, we are projecting tens of thousands maybe even
hundreds of thousands of lakes being affected in the next twenty to
thirty years. What then are we to expect if in fact there are increases
in emissions? So when you ask the question is there a basis for moving
quickly for control, I have to answer with a resounding yes on the basis
of the aquatic ecosystems alone. We are simply not prepared to contemplate
leaving the generations of the next century with tens of thousands or
hundreds of thousands of sterile lakes which is what we are talking

about in terms of aquatic ecosystems. This is an area we know a lot
about. We know that it is happening. The area that is much more
doubtful, although I do not know how much more doubtful, is the area of
soil chemistry which we just finished discussing. Another area which is
not in doubt is property damage. We know we are causing damage to
building faces, to cars, and a lot of other things. A lot of things are
being documented to demonstrate that. If you write that into a macro-
economic setting and you calculate how much is involved, spreading it
over a large populated area such as we are talking about in both Eastern
Canada and Eastern United States, then you are talking about enormous
amounts of money. I am convinced of that.
Bob Flacke, New York: We are pleased to see that New York's problem in
the Adirondacks and the proven destruction of 107 lakes and several more
is also evident beyond our borders and not only has elevated itself to a
Regional problem but a National problem. We, too, have concluded that
it is now time for source control based upon what has been presented
today and on evidence that we have gathered over a number of years. You
will notice that many of the slides emanated from New York's data gathering
which has been part of both our academic community and natural resource
management for many decades. Thank you.
Dr. Gage: I can only underscore what Ray has said in terms of damage to
human structures. We have initiated a project under the Committee on
Challenges to Modern Society which is a civilian arm of NATO and we are
finding that it is not just the Scandinavians, Norwegians, and Swedes
who are interested in participating with us in that particular project.
It is all the countries of Western Europe who have a very real concern

for their cultural heritage and the project, in fact, is being lead by
the Greeks who are very concerned about the destruction of the Parthenon
and Acropolis. They can literally see effects there occurring on a
yearly basis, quite dramatic effects. Yes, Tony.
Tony Cortese, Environmental Commissioner of Massachusetts: I have a
difficult question to ask Steve. Conspicuous by its absence in your
presentation of what the President's program is on acid rain was the
planned program for control and I know we are going to be talking about
that tomorrow. The President has launched through EPA an ambitious $10
million a year-ten year program for research on the acid rain problem.
I assume that does not mean that EPA is going to suggest that we wait
ten years before we begin to apply controls. I guess my question to
the panel is, and I know it is somewhat unfair because you are the
research arm of the agency, my question to the panel is: How long
should we wait and if we are going to wait two to three years or more
before we begin to make a decision, make a final decision on controls,
and it takes three to five years to get the controls on, are we likely
to cause more irreversible damage than we have already caused by acid
Dr. Gage: That is a good tough question, Tony. I think that Doug
Costle signaled in his opening statement today that we are not going to
wait for all of the research results to be in to begin taking actions.
I think he said it very clearly, we need to translate from the research
results we have today, meaningful steps towards putting a cap on emissions
and moving to the tougher step of reducing the current levels of emissions
All through the process we are undoubtedly going to have to learn to

live with a much higher degree of uncertainty by not having the scientific
and technological information at hand to make the firmest of decisions.
The research plan, of course, is not a plan which is just now being laid
out. We, in fact, took a lead, followed very closely by the U.S. Department
of Agriculture, TVA, DOE, NOAA, and several other agencies as well
started dealing with this problem several years ago. If we did not have
those research activities underway right now, I think we would be in
much worse shape but there are going to be results coming out on a
monthly basis through the next 12 to 18 to 24 months. That will give us
a great deal more insight into the short-term impacts. It will, very
frankly, not give us any appreciable insight into the long-term impacts
on the soil ecosystems and on forest ecosystems. With the very long
time constants that are involved in those systems, we are, quite frankly,
going to have to hedge our bets in the level of control activities we
are willing to afford as a country to protect the long-term integrity of
the soil and forest ecosystems. But, I think that you heard very clearly
from Ellis and Ray that we have enough data on hand at this point to
fairly well indict acid precipitation as a major, if not the predominant
contributor to the deterioration of aquatic lake ecosystems. I think we
are going to be starting tomorrow with Dave Hawkins' opening statement,
a very serious discussion of what alternatives we can undertake so that
we can join together in discussing how we begin to take those first
Tony Cortese, Massachusetts: I have one follow-up question, Steve, and
that is: How likely a situation is it, if the longer we wait before we
begin to apply controls, the more we come into a situation where the

life of the existing coal-fired power plants become short enough that
the economics tip it away from applying the control technology that is
available right now. I know Steve didn't have any data on that in his
slide presentation but I am curious about that because I wonder if it
does take us five or ten years to make a decision, do we then find
ourselves with a problem in the long run because we cannot afford to
begin to apply technology to existing power plants because it just will
not be worth it because they will be too old and they will be phased
Dr Gage: Well, of course, with interest rates running at 19 1/2 to 20
percent we seemingly have a different economic order. There will probably
be some different economic rules applying to the affected lifetime of a
capital plant. Steve, can you add some comment to that with particular
respect to the Ohio Valley study.
Steve Reznek: I guess Lowell will give more detail on the Ohio Valley
Study. There was a major expansion in electricity generating capacity in
the late sixties and the seventies and then a small expansion just
before the embargo in 1975 or so. So a lot of the plants date from
those times. Before the embargo, it would have seemed like they would
be aging now. However, with new capital going sky high maybe those
plants will last considerably longer than the thirty year life they were
originally projected to have. Lowell wants to talk about how that
lifetime . . . split out in the Ohio Valley now. Lowell Smith: This is
one of the areas that I alluded to that makes it very hard to predict
what future emission rates will be. We really do not know what the
utility executives plan for the retirement for the existing capital

stock, but, we do not know what the shape of the capital stock or shape
of the age distribution of that capital stock is. If we were to plot up
a cumulative distribution of retirement date versus the total capacity
retiring, assuming a thirty-five year operating life for those plants,
in the six Ohio River Basin States, we would see that only a third of
those plants would be retired before 1995. The remaining two thirds
would run over a fairly linear curve between 1995 and 2010. However, we
are beginning to rethink that thirty-five year lifetime. We do know
that boilers are continually retubed since it is the tubes of the boiler
that tend to wear out and they can be replaced and there are a lot of
tax policies and policies that the State Regulatory Commissions for the
industry have which determine the probable retirement dates for those
plants more than anything else as well as what the cost of capital is
for replacing. We really cannot answer the question at all precisely.
All we can do is say this is what the age distribution is. Here is what
might happen under a different "what if" type scenario.
Craig Weidensaul, State of Ohio: I have a question for Dr. Cowling.
Ellis, about, four years ago we initially sat down to discuss the deposition
monitoring program which, at that time, was one that would hopefully
materialize. I think we all agreed that there was a great insufficiency
of data and a lack of reliable information in the U.S.--whether it be
different methodologies used in collecting and analyzing precipitation
or whether there were insufficient numbers of sites and improperly
located, and so forth. The justification for our national atmospheric
deposition program was based primarily on the fact that we did not have

information in the U.S. of a reliable nature. We have collected data
for 17 or 18 months now and I have, as you know, been very familiar with
those data. We have also come to the conclusion, I say we figuratively,
in this room and across the nation that the acidity of rain has increased
significantly. In our proposal for the establishment of the monitoring
system, we indicated that the only reliable data could be generated over
a period of many years. Yet we are already making a conclusion that we
have significantly increased levels of precipitation and acidity. Would
you be willing to go out on the limb and agree with that or do you think
maybe we should tread lightly and really find out what the answers are
before we run off in all directions proclaiming great increases in
Dr. Cowling: Let me answer in this way Craig. I think that if we look
at any of the monitoring network data that is avail able--maps or NADP or
the TVA data or, country and one has to doubt in some ways the reliability
of the WMO data, but nevertheless—there are certain trends and I think
that data is persuasive that over rather long periods of time there are
significant increases in the amount of acid being deposited over the
landscape. I think if we were to take any set of data over a period as
short as you mentioned, 18 months, which is as long as we have data in
the NADP network, I don't think that that is adequate, using that data
alone as an inference. I might just call attention to the slide from
the Hinkley Reservoir. Over any given period of ten years you could
tell any sort of a story you want with that data. You could say that
the alkalinity was increasing over a period of ten years, you could say

it was decreasing over a period of ten years, or at another time you
could say it was holding constant. I do not consider it relevant that
over this particular 18 months we have seen any change at all in terms
of the question that you raised, but I do think it relevant that we know
that emissions are increasing in various regions of the country and in
response to the question asked by the representative from West Virginia,
I think it is important to recognize the difference between national
trends in emissions and regional trends in emissions.
In the Southern United States region, the projections for increases
in emissions are much more substantial than they are, for example, in
the Northeastern part of the country. So, though New York has a good
reason for worrying now, North Carolina may have good reason for worrying
later. That suggests that we need a stable monitoring base that will
exist over decades of time. We need to find some way to ensure that it
is isolated from the political winds of change. I think there is substantial
evidence with which to piece together from a variety of sources which
emission inventories are major. The film which we were talking about
today demonstrate how large distances, we are talking about in terms of
dispersal, have good reason to be concerned about the interstate and
international dispersal now.
Dr. Galloway: I would like to add a comment to that if I may. I second
what Ellis has said, realizing that there are two main questions we are
concerned with. First of all: is the acidity of precipitation now
greater than it used to be before we were burning substantial quantities
of fossil fuel in the U.S., indeed in North America? Secondly: are

there effects of this increased acidity? I think the answer to both
those questions is yes.
Dr. Gage: There is one question from the audience, and just to make
good on my promise to work these in at appropriate points, the question
is: Wasn't coal combustion much greater in the 40s and 50s than it is
today? If so, why is the trend toward a more serious acid rain problem
today? This is by Tom Curtis, of the National Governor's Association.
Lowell, would you like to take a stab at that?
Mr. Smith: Sure. The initial premise of the question was that we are
burning at least as much coal today as we were back in the 1940s and
1950s. We are actually burning a little more coal today. Historically,
coal consumption, with some ups and downs which were a function of our
economic activity, has been around 500 to 600 million tons per year from
about 1920 through about 1970, in fact through about 1975. Since then,
coal consumption has jumped up to 700 million tons and as we all can
expect will be rising even higher. The real point here though, is what
are the SO2 emissions. From the graphs that I showed, SO2 emissions in
1940 were about 20 million tons a year, that was primarily because we
were not burning as much oil in 1940 as we are in 1980. Now we are
emitting about 30 million tons of SO2 per year, so emissions for S0£
have risen by about 50%. More importantly than that is height into the
atmosphere that we inject these emissions. We are not just burning coal
in everybody's home fireplace or home furnace, and we are burning it as
we saw in large electric generating stations that have stack heights of
200 to 250 meters. This is injected into the atmosphere at points were

they can travel much further distances, and have a much longer time to
react chemically. Also, we have a more oxidizing atmosphere today
because of our automobile emissions; we have many free radicals in the
atmosphere that tend to turn that S02 into acid much more rapidly.
Finally, we all have to recognize that we not only have somewhat increased
SC>2 emissions that are injected into a more reactive atmosphere, but we
have the nitrates the nitric acid components building very rapidly at
this time. We have a number of factors which, all added together, can
certainly account for substantially more acid being deposited today than
was being deposited back in 1940, even though we are burning about the
same amount of coal--to within 25%—as we were in 1940.
Dr. Gage: Questions here?
Mr. Paul Leroy, Technical Representative from the State of New Jersey.
Ken Demerjian, you presented a very eloquent slide presentation on your
modeling results on the actual S0£ emission inventories which we know of
today. Since our problem is regional — interstate boundary in its integrity.
You showed Regions I, II, and III being impacted slightly more severely
by various regions, extramural or extraregional to it. Have you done
any analyses which would indicate that by controlling emissions in
various locations--!".e., in various regulatory regions, more severely or
let's say with more judicious nature than may be apparent due to the
emission density at this particular time—have you seen reductions?
Have you done the options situation? The ones that are not real . . .
at this particular time. What would happen if you controlled SO2
emissions let's say more in Region V than you do now, or Region II than
you do now, or various combinations thereof.

Dr. Demerjian: The answer is yes to some extent. There is continued
work being done to apply the model to various emission scenarios.
Within the study that I have been commenting on today, there is a
scenario for 1985 projected emissions based on an inventory prepared by
the Department of Energy. I did not show any of the results from those
model runs, but the projected emissions did show reductions in several
areas of the modeling region both in terms of SO2 and sulfate ambient
levels. I am not prepared to comment on the methodology used by DOE in
developing these emission projections, maybe Lowell Smith has a better
knowledge of the technique used. It was considered the best available
projection for 1985 at the time. We run the model with the projected
emissions for comparison purposes using the same meteorological data set
for the 1977 test year. The model is capable of at least scoping out
the impacts of such control strategy scenarios and certainly is a useful
tool for that kind of preliminary application. Some of the future model
application work includes further emission projection studies with
emphasis on regional exchanges and impacts on highly sensitive ecosystem
receptor areas.
Mr. Smith: Just in passing the mike back to Steve, I will just comment
that we may not necessarily agree with the Department of Energy's 1985
projected emissions, there are a number of reasons for saying that.
Without going into them all, let me just say, all future emission estimates
are highly dependent on the degree of compliance with existing SIPs or
the emission limits for State implemetation plan controlled plants, and
other factors which as we know are somewhat variable over time.

Dr. Gage: Carl, West Virginia.
Mr. Carl Beard: Dr. Gage, has EPA received any concerns from the holders
of commercial timber, be it pulp and paper, hardwood, or what have you?
Has anybody voiced any concerns about acid rain damage?
Dr. Gage: I think we have received a number of inquiries from a variety
of the forest associations in EPA, but I think that probably Ellis, who
is much closer to the forest industry than we are, might comment on
Dr. Cowling: International Paper Company is the largest single owner of
forests or timberland in the United States, and the Vice President for
Research is very much concerned about the problem. Weyerhaeuser Corporation
shares that concern. We have established a new center in Raleigh for
southern forest land productivity. Russ Ballard, the chief soil scientist
involved in that project is very conscious, also Carol Wells at the
forestry sciences laboratory. Since this point is related to an earlier
question, I might also comment that Dennis Tirpak has reminded me of the
Soil Survey Data System that is used in Sweden and is run by Trepe
Trodeson. They have a very elaborate system for soil chemical analyses
by Horizions in Sweden. That system is not now used in this country,
but could be adapted and would give us some idea about the distribution
of nutrient elements among soil layers which would give us additional
information that would be germane to the question of forest growth and
Dr. Gage: I would say that the Forest Service in the U.S. Department of
Agriculture has been most aggressive among the many bureaus in that
department in working in the acid rain area, and we want to encourage

them even more. We also want to encourage our friends from the soil
conservation service and several of the other major bureaus or departments
to use any major resources that they have available in the extension
service or the land grant universities to focus on this problem.
Dr. Cowling: Don Boelter of the U.S. Forest Service is here; he might
just raise his hand. Don are you still here? Yes, in the back. Good
job. You might also remember that it was the Forest Service that sponsored
the Ohio Conference, which was the first international conference on
acid precipitation/forest ecosystems, so the Forest Service is keenly
Dr. Gage: Yes.
Mr. Daniel J. Goodwin: I am Dan Goodwin with the Illinois EPA. I will
address my question to either of the two Steves that can answer it, or
maybe the two of them together. Steve Reznek mentioned—but then said
nothing very substantive about—nonstructural approaches, the least
emissions dispatching concept, plant retirement schedules, the way you
have them listed here, there are other things that you can throw into
that category. My question is: Was that not discussed because nothing
is going on at the Federal level in that regard, or because it is a DOE
area of interest, or what? It seems to me that it is potentially a very
fruitful area for short-term gains that could be implemented within a
matter of a couple of years with no need for Federal legislation.
Mr. Reznek: It is a very interesting field. By the way, I am reminded
of a better answer made by Tony's question, in that old power plants
never die, their load factors just go down. We are developing a knowledge
base of what dispatch algorithyms of current utilities are and what

their supply capabilities are. We are also aware of the power interchange
arrangements that are already in place amongst regional collections of
utilities. There have been some very good cooperative cost-letting
adventures between individual utilities in different States; The rate
setting commissions have allowed those to occur when there is a cost
savings involved. We are going to put that information together, we are
also, frankly, going to be very sure that we do not walk into--if I can
mix my metaphor--into windmills where we have not thought thru whose
toes will get stepped on and who realizes what savings. That information
will be available, we have just started the process of looking at it,
and looking at what some of the potential savings may be. The only
reason I did not talk about it in detail is one, we are not very far
into the process, and two, we are afraid of charging ahead and not
realizing that we suddenly put a major utility out of business and
brought power into its area without knowing what we were doing. Lowell,
you want to comment a little bit?
Mr. Smith: O.k. Simply to comment that both Steve Gage and Dave Hawkins
are jointly sponsoring analysis in this area. It is a three-phased
analysis where we are looking at the acid rain emission region as a
whole, first of all in the first stage, those results will be available
next month, at least for internal review. Second phase will be available
next fall, where we will be looking more in detail at individual utility
systems, both where we will have greater detailed analysis of what this
so-called least emissions dispatch might mean, what early retirements
might mean, what other policy initiatives to address this question might
mean. Also, in the Ohio River Basin Energy Study, whose draft report

will be out next week for review arid comment, there will be further
analysis in this area as well.
Dr. Gage: Yes.
Mr. Brown: Will Brown, New Hampshire. As a forester I certainly share
the uncertainty as to the terrestrial impact of acid rain, but I wondered
whether that needs to give us any pause because there seems to be general
agreement from the panel and certainly from the questions that have been
asked, that the aquatic impacts are sufficient to justify action now. I
did hear some mention about benefit to the alkaline lands from acid
rain, but unless we can recycle the jet stream in the opposite direction,
I do not think we are going to be able to deliver much of it out that
direction. I have not hear anybody say that there were any potential
beneficial terrestrial impacts on nonbuffered soils with which we are
blessed in much of the Northeast.
Dr. Gage: Point well taken. Yes.
Mr. Collom: Bob Collom from Georgia. I was wondering if Dr. Cowling
could go further into the aquatic effects and that is: Is the adverse
effect on fish due to the absolute pH concentration of the water, or the
rate of change, like the immediate snow melt that occurs in the North?
Dr. Cowling: I am afraid I may be misleading in suggesting that acidity
per se kills fish. There may be circumstances where that is true, but
for the most part it is the associated metal ion toxicity that is far
more worrisome than the simple effects of pH. Particularly on mature
fish. There are certain circumstances under which extreme acid stress
may be experienced by fish, and I am not a fish biologist so I am having
to give you second hand information. Dr. Harvey, in Canada, has shown

fish that have a distorted backbone structure, the crippled appearance.
This is due to the continual necessity for resorption of calcium out of
its own bone structure in order to maintain an ionic equilibrium with
the surrounding water. Now that is an acidity effect, but it does not
kill fish, it simply deforms them. It depends upon what your concerns
are for the fish. I think we are able to recognize that acidity is not
good for fish under any circumstances. Aluminum toxicity which clogs
the gill membrane, and maintaining blood level calcium concentrations
that are suitable for the internal physiology of the fish are the two
primary effects of which the most important by far is the metal ion
Dr. Gage: It is the absolute concentration of these metals as opposed
to some rapid rate of change that seems to cause the problem, is that
Dr. Cowling: Yes. There are circumstances in which the fish are intolerant
to the rapid rate of change, as when you get a very rapid accumulation.
There were some illustrations shown in Norway of the accumulation of
aluminum precipitates on the gill structure, they are shown open looking
like a cone, and then they are shown essentially as closed. Apparently
that precipitation on the gill membrane can occur with great rapidity.
It is a shock and the fish actually die in many cases from lack of
Dr. Gage: One of the developments in our Duluth Laborabory has been the
fish meter in which the response of the fish to the clearing of particularly
toxic metals from the gills can be converted into a pressure pulse which
can be picked up with a very sensitive probe. The scientist can measure

well down below the parts per million level of concentrations of toxic
metals in the water, just by looking at these little fish coughs or gill
cleaning responses in the fish to very very low levels of toxic metals.
So, it is not at all unlikely that the higher levels smother the gill
action which really leads to a toxic effect in the fish.
Dr. Cowling: Jim Galloway has just reminded me that the acidity per se
is much more deleterious upon the fish fry than it is upon mature fish.
The adult fish are reasonably tolerant except for the calcium adsorption
busi ness.
Dr. Gage: Yes.
Mr. Martini: Bob Martini from the Wisconsin Department of Natural
Resources. Wisconsin has a very large number of susceptible lakes and
we also have acid deposition as we have already measured. I have been
reading recently in your five year plan for research that EPA has developed,
through a contract with the Mitre Corporation. I do not see very much
in the way of work outside of the Northeast for any other region in the
United States. I wondered if you could comment on the distribution of
those research funds to document problems that we feel are already
occurring in other parts of the country and the ability of the States to
carry out a program to demonstrate their own susceptibility and the
problems that they are having in areas outside the Northeast.
Dr. Gage: Since that plan was drafted some 9 to 10 months ago, we have
made a number of changes which give a much better balance to our efforts.
Even at that time, we had Dr. Garry Glass at our Duluth Laboratory
involved in a very extensive study of the Boundary Waters Canoe Area in
Northern Minnesota, where he found many of the lakes highly susceptible

to acidification and also found fairly good evidence of increased acidifi-
cation in those lakes. He has subsequently extended that work to the
Northern Wisconsin area and I believe there are contacts with a number
of academic people in that area. One of the results of the dialogue
that has already been established in setting up this particular conference
is the much greater feedback we are already getting from the States.
This is in partial response to one of the other written questions we
have here. We would like, following this meeting, in conjunction with
our regional offices, to have a survey performed of all the activities
that you are conducting in the States so that we can, in some cases,
possibly be an information broker in getting information from State to
State, but also know what you have underway so that we can incorporate
that in the various studies we have going on in either our laboratories,
the national laboratories, or university laboratories through our consortium
which is basically run by Ellis. We will take that feedback and probably
carry out even more of a balancing of the distribution of our research
funds than we have today.
Dr. Cowling: If I could further comment. I think it is important to
realize that EPA has money to spend but it does not have it all by any
means. The amount of investment being made by other agencies including
the Fish and Wildlife Service, the Forest Service, the various States
agencies that are concerned with the research, the U.S. Geological
Survey is making very substantial investments in this area, NOAA has
intentions to make a much more substantial investment. I think you are
going to see not just EPA making a decision about where the investments
ought to be made. The State Agricultural Experiment Stations are increasing

their investments. I do not think you are going to see a major concen-
tration of Federal funds by any means in the Northeastern quadrant
Dr. Gage: Yes, over here please.
Bob Schrieber: Bob Schrieber with the State of Missouri. EPA is currently
developing a fine particulate standard, or a respirable particulate
standard. Have they done any work to identify what percent sulfates may
play in that particular standard? If so, what respirable particulate
standard would be the controlling factor for sulfates?
Dr. Gage: We are in the process right now of reviewing the scientific
basis for the sulfur oxide particulate standard. In fact, for some
number of months, we have been developing the criteria document for SO
and particulate. That criteria document will be available within the
next few day and will be sent out for two to three months of very wide
public review as well as detailed review by our Science Advisory Board.
In that document, the role of the respirable particulates are addressed
as far as the total particulate problem but at this time there is not a
separate document prepared on the respirable particulates to support a
separate standard, but rather the total effects of the respirable parti-
culates. The relative contributions of the secondary pollutants such as
the sulfate are discussed as part of that combined sulfur oxide particu-
late problem. Unfortunately the timing of this meeting was somewhat out
of sync with the conclusion of the preparation of the criteria document
but please note that in the Federal Register within a few days we will
have the announcement of its availablity.

Bob Flacke: Will that automatically be sent to the State Air Agencies?
Dr. Gage: I think so, if not, I will take the responsibility to see
that each official State representative here gets a copy of the criteria
document. Yes.
Mr. Wilms: I am Paul Wilms. I am with the State of North Carolina. I
have heard a lot of talk today from various States and a number of the
speakers to the effect that additional controls on stationary sources-
especial ly sulfur oxides, etc.--may be necessary, maybe not as the
panacea, but simply as Dr. Cowling mentioned to gain some additional
time for this study. This may be a point of further discussion tomorrow,
if not, I would like it to be. I would like us to ponder this evening
and then discuss tomorrow, alternatives either in addition to or in lieu
of additional stationary source controls. If those controls are necessary
on stationary sources, I would like some response particularly from EPA
as to what form they might take. Whether they would be Federally promul-
gated emission controls for existing sources or whether they would be
simply Federally mandated controls for the States to formulate and adopt
after control technology guidance is promulgated or whatever.
Dr. Gage: Well I know Dave Hawkins will be discussing in his opening
remarks tomorrow the structure of the Clean Air Act and the use of the
various mechanisms under the Clean Air Act including the possible use of
the secondary standards; all of the time constants that are built into
the promulgation of revisions; the state implementation plans; and the
time required to make changes—all this in the context of the urgency of
beginning to deal with the acid rain problem. I think you will have
very ample opportunity tomorrow to address precisely the kind of questions

that you are talking about. Ray indicates that there are 200 hundred
copies of his speech across the hall in the press room, so if you would
like to have a copy of his speech, it will be available there. Yes,
Dr. Cortese, Massachusetts: I have two technical questions. First, can
we affect fish life by changes in pH which could affect the type and
number of micro-organisms which would exist in lakes or in rivers and
streams? Second, can we affect the kinds of micro-organisms which help
in nitrogen fixation and other kinds of processes which help plant
growth by changes in pH?
Dr. Gage: Ellis, would you take that?
Dr. Cowling: With response to your question about the fish life and
other organisms living in streams and surface waters, it is very clear
that the affects of acid deposition and the associated metal ion toxicity
have influences at all trophic levels. Algae will be affected, diatone
communities will be affected, bethnic invertebrates would be affected,
emergent vegetation would be affected, and so on. The data to support
this is primarily from Scandinavia although I think essentially similary
observations have been made in Canada. It is very clear that we can
expect major changes in the character of the vegetation existing in
lakes and streams. One of those changes will be to inhibit bacterial
decomposition which will also have the effect of increasing populations
that will be directly competitive for oxygen with the fish so that there
could be direct competitive effects from changes in acidity of the soil.
Then the second question, yes, David Shriner first demonstrated the
effects on the nodulation of soy bean and kidney bean as I showed in the

slide. He did experiments which excluded the acidified water from the
soil. He found the same extent of inhibition of nodulation, whether or
not the precipitation ever contacted the soil. I think it is very clear
that we could increase the nitrogen fertilization costs if those effects
became general. It is not just a question of soil alkalinity or acidity
or the pH of the soil, it is a question of what happens when the precipi-
tation first hits the vegetation. It is not widely understood that most
raindrops do not enter the soil directly. They do in an agricultural
field where there is no crop, but most of the time, especially in a
forest, it will trickle over three tiers of foliage before it will hit
the ground, and there is plenty of opportunity for physiological interaction
with the foliage.
Dr. Gage: I think one of the most dramatic examples of accumulation in
aquatic systems, that has been pointed out to me, is the growth of
sphagnam moss along the bottom of the lakes particularly in Southern
Scandinavia where the moss grows out from the shore and starts to blanket
the bottom of the lakes, basically smothering all the biological activity
that lives at the interface between the water and the sediments underneath.
Dr. Cowling: That same situation has now been detected in the United
States and in Canada, so we now have another phenomenon to look forward
to. In addition, with sphagnam, it has a very large and estranged
capacity in its foliar surfaces. It is normally a terrestrial plant,
but when you acidify a lake it invades the lake bottom. It has been
detected in Sweden as far down as 18 meters which is 51 feet. If you
lime a lake, you will tend to kill off the sphagnam. If in the meantime
heavy metal ions have accumulated on the foliar surfaces of the sphagnam,

you will release them into the water again, so you can blacklist the
lake by liming it for the purpose of increasing the likelihood of repro-
duction of fish in the very same body of water. We are really dealing
with a very complex web and if you wiggle the web there are pertubations
in that chain that will be felt over substantial periods of time.
Dr. Gage: Yes.
Tony Cortese: Ellis, I would like you to clarify a point. You said
something that did not make sense to me. You mentioned that bacteria
would be killed, but yet there would be a substantial growth of algae.
Without bacterial degradation of organic matter, two things will happen,
one there will be no nutrient cycling for the algae and they cannot
grow; and two, with the accumulation of organic matter you have tied up
a lot of the heavy metal, I do not think you meant to say that, did you?
Dr. Cowling: Well, it is a question of short-term versus long-term
effects. In the long-term you are right and in the short-term I think I
am right. I have some other illustrations of the slimy accumulation of
algae on rock surfaces for example. That does occur, the bacteria are
inhibited sufficiently so that the algae gets the upper hand in the
balance bewteen the two populations.
Dr. Gage: Yes, Bob.
Mr. Bob Collom: I would like to address Dr. Galloway. The Scientific
American article compared say a 20 to 25 year period. How comparable is
the data from the 50s to that now being gathered as far as methodology
of sampling and analysis?
Dr. Galloway: The methodology sampling and analysis were different
between the samples collected in the 50s, the mid-60s, and in 72. One

of the advantages of doing annual averages of pH is that you tend to
smooth out these changes in technique. I feel confident that there have
been increases in precipitation acidity, especially in the Southeastern
United States, as that data show. Also, getting back to the acidic
question, has the acidity of precipitation in the Eastern North America
increased since we started burning fossil fuels at the rate we are now,
and the answer to that has to be yes. No question about it.
Dr. Gage: Are there other questions? There is one question that I
received from the floor that I hesitate to toss to the panel now. It is
not identified by question, and I would not rule it out just on that
point, but I will read the question and maybe it could be clarified and
asked again tomorrow. The question is: The President's Commission on
the Increased Utilization of Coal concluded that at the present the
proposed mass conversion of electric utilities to coal would not increase
sulfur emission under existing EPA standards. How could they come to
this conclusion if EPA has acknowledged that this is not the case? I
guess we have a little problem with the premise in the first question,
maybe you can grab some of the people from EPA and get that question
sharpened up a little bit more for tomorrow.
Mr. Hawkins: By way of an interim answer, I know that some of you . . .
were invited . . . you might want to jump in, but a quick review of the
Commission report indicates there are a variety of measures proposed in
that report, some of which tend to increase . . . and others which tend
to provide offsetting reductions. The principal ones which would tend
to provide offsetting reductions are related to policies that would
accelerate ... I think the whole Commission study does show that

conversion by itself would result in some emission increase, but the
total program also includes elements which would have offsetting reductions.
Dr. Gage: Thank you, Dave. Well we are at 5:57; it has been an absolutely
orderly meeting; I do not really take responsibility for it; we have
been right on schedule; and I think now is a good time to conclude
today's session. Tommorrow's session will open at 9:00 a.m. in this
room--Dave Hawkins will be the moderator. The emphasis will be primarily
on the discussion of various regulatory and other options that might be
used to deal with the acid rain problem. We have a number of presentations
from State representatives, who have been thinking very hard about the
problem. I think tomorrow offers to be another very good day. I want
to thank the panel members, who have given the presentations this afternoon.
They were first rate professional presentations, and did an awful lot to
set the basis for tomorrow's discussion. Thank all of you who have
attended today.
Mr. Hawkins: I want to welcome you all once again. The intent today is
to follow up where yesterday's discussion left off. Yesterday we focused
principally on the scientific and technical facts and issues associated
with the phenomena of acid rain and long-range transport of air pollutants.
Today we are going to be talking about institutional, legal, political,
economic, and social issues. From EPA's perspective we are going to be
talking about them in terms of questions and, hopefully, in terms of
answers that the States feel comfortable in articulating.
Our sense of the usefulness of today's session is to lay some
options on the table and to have the various States discuss their view

of those options as well as identifying others which we may not have
identified. Principally my initial remarks will focus on two sets of
options. First, what possible legal ^ools under our current authority
may exist and second, what legal tools other than our current authority
might hold some promise.
I would like to start off with an assessment of our current legal
authority. I would like to emphasize that in EPA's view this is not a
conclusive assessment, it is rather an identification of possible sections
of the law that might or might not hold some promise, and rather than
expressing a firm conclusion on that this morning, I want to lay out
some of the pros and cons of each, and have the participants in the
conference attempt to identify other pros and cons, or other options
under our current authority as well as other authorities. Let me try to
run through a list of possibilities. These are in no particular order
of priority.
First, the stack height regulations. As you know under Section 123
of the law we are required to adopt regulations that give credit for
stack heights. We have some discretion as to the amount of credit we
can give, and clearly to the extent that we exercise that discretion to
give the maximum amount that might be available under the law, that
could lead to greater allowable emission limits than if we exercise that
discretion to provide the minimum amount of credit that is available
under the law.
So, one option we have is to structure those regulations in a way
that does not give more credit than is mandated by the law and as a
result, does not give the sources an opportunity to justify higher

emission limitations than would be mandated by the law. The plus side
is that it is our feeling that a large number of current SIP relaxations
as well as current SIP regulations may be based on higher than minimum
stack height credit that might be justified. If this is the case, then
a very tight regulatory policy could in fact provide for some reduction
in emissions. On the negative side, the resource implications of reviewing
all existing sources is substantial and if that is to be done by EPA
itself, it would take a considerable amount of time. If the States are
also interested in reviewing sources within their States or sources
within other States, then obviously the resource base would be substantially
expanded. I think it is still a fact that in the air pollution area
about 90% of the resources in terms of personnel are at the State and
local level, and 10% at the Federal level. Some of the other negative
factors are that there may be legitimate stack height increases which,
under a tight policy, would have to undergo substantially greater burdens
in order to justify their increases, which could result in delays in
legitimate modifications to SIPs. In addition, it is our initial assessment
that the total magnitude of emission reductions that one might get by
operating within the boundaries of our discretion, is not an enormous
fraction of the current loadings.
Another area is Section 115 with respect to international pollution
abatement. That section does allow a foreign country to trigger a
Federal call for SIP changes in order to deal with source impacts on
that foreign country. The authority is fairly broad and it could relate
to impacts that are not associated with criteria pollutants, so it could
be used to address to the acid rain phenomena. The negative side of it

is that it does rely on the state implementation plan process. It would
probably deal principally with sources that are fairly close to our
international boundaries and where we are fairly able to identify the
impacts rather clearly on the acid rain phenomena and that may not be
too many sources. Finally, it may indeed require an additional inter-
national agreement in order to meet the requirements of Section 115.
Third item is the improved enforcement and enforcement monitoring.
We could pursue the enforcement monitoring activities much more agressively
so that we have a very accurate picture of whether current emission
limitations are being complied with, and take enforcement actions
against those sources which are not in compliance. We also have estimates
that that would allow us to find some emission reductions from today's
existing emission levels. That is one of the positive features, another
of the positive features is that it could lead to improved operation and
maintenance practices at large stationary sources. I think that histori-
cally the air pollution community has tended to focus on getting the
equipment installed and not place as much emphasis on seeing that it is
operated on a daily basis and to its maximum potential. In flue gas
desulfurization areas it is particularly important that we focus on the
actual operation because a little bit of down time can make a large
difference in the total reductions over the course of a year. It would
also force EPA and the States to clarify the averaging times involved in
their current emission limitations. As long as there is uncertainty in
that area, we will have some difficulty in establishing the actual
violations or compliance status of sources. It might lead to practices
that would reduce sulfur variability, that could reduce peaks but it

would not necessarily reduce total loadings, and as I mentioned, it
could substantially reduce emissions and finally have positive equity
implications. Now, of course, again an issue that is present here is
the resource implications, and it depends again on whether this would be
an initiative that EPA would undertake by itself or be an initiative
which would be shared by the States. Again, to the extent it is shared
by the States, those resources would be much more available. Another
negative factor is that it is quite possible that enforcement against
sources could disrupt some current coal market relationships, and that
is a fact of life that we are all going to have to deal with. I do not
mean deal with by backing away from dealing with an abatement problem,
but we have to recognize that where there is that kind of dislocation,
we are going to have to figure out a way to make people feel comfortable
with bringing sources into compliance.
Another option is to assess our modeling guidelines and require
best techniques to be employed and to go back and remodel sources and
SIP limits using those best techniques. I think that around the country,
depending on when the SIP limits were set, you have a wide variety of
techniques that have been employed in modeling sources for calculating
emission limitations. We could tighten up on a variety of those parameters,
and probably wind up establishing, even under our current ambient system,
a set of tighter emission limits. There are a variety of suboptions
here, we could do that for all sources, we could do it for the largest
emitting sources, and we could do it for sources that are seeking SIP
relaxations. The positive aspects are that this modeling could in fact
. . . many emission limits based on old, less rigorous techniques that

are too lenient. It could force reduced emissions and improve the
overall quality of the SIPs. If we took the suboption of limiting it to
SIP relaxations it could tend to deter those relaxations. The negative
side is that the modeling might show that some emission limitations are
more stringent than necessary, and I say negative from the point of view
of an objective of reducing total loading. Another familiar negative
point is resource implications, and again if this is an exercise which
EPA would be undertaking, it would take some time to do if we were doing
it for all of the Eastern States. Then there is the issue of equity.
If we take some subset which happens to fall on a particular group of
plants or particular group of States and only those are chose to be
modeled, obviously, again, if EPA is the only one engaging in this
initiative, we would obviously start first with somebody, and cries of
inequity might be heard.
Another area is Section 126 of the Act, the Interstate Pollution
Abatement Activity. Here we have the option of taking a more aggressive
role in dealing with the requirements in identifying and clarifying the
requirements that a State must meet in order to make these showings. I
think it is safe to say that that is an option which we have already
decided is positive, and we are going to try to take a more active role
in the interstate area. Specifically by taking the interpretation that
if a State can show that a source in another State is unreasonably
interfering with the air quality margin of growth in the impacted
States, that that is enough to make a prima facia showing (that is
lawyer's talk for getting in the door) to hold such a proceeding. The
remedies remain to be seen, but the intent would be to enter into an

arbitration process that would get the States to agree on some limit
which were thought to be acceptable to both States, and would tend to
reduce the impact in the affected State. Now, the pros in this are that
it would be repsonsive to some of the most insistent complaints we have
heard about the inequities of widely differing emission limitations
which are believed to have substantial impacts in States with more
stringent emission limitations. It would put the State most immediately
involved across the table from each other, so they could start talking
seriously about a resolution to this problem, recognizing that EPA has
this backup authority to impose an arbitrated solution, if necessary.
The negative side of it is that section 126 is related to criteria
pollutants so it would be necessary to show impacts on sulfur dioxide
concentrations, PSD concentrations, and nitrogen oxide concentrations,
rather than showing the impact on the ecosystem of a substantial acid
deposition. This means that it would be most likely limited to close-
range microscale impacts rather than the long-range transport-import
impacts that appear to be a substantial part of the acid rain problem.
It would probably have to be done largely, at least at present, on a
plant-by-plant basis and the tools that we have to tie impacts to a
variety of plants are not as rigorous as the tools we have on a plant-
by-plant basis. We are proceeding to try out this authority and the
first hearing will be held next week involving the petition between
Kentucky and Indiana. We will see what comes of that.
Another item is developing an ambient standard, and there are
several different options for ambient standards. One is to set an
ambient standard for a conversion product that is related to acid rain--

say sulfates--or to set a tight secondary sulfur dioxide standard, or to
set a respirable or inhalable particulate standard. The positive side
is that, if stringent standards were set, they would tend to increase
the degree of control required on the precursor pollutants, depending
which option were chosen, either for sulfur dioxide or nitrogen oxide or
both, and that in turn would lead to additional control opportunities.
The negative side is that we do not, today, have in hand doucments that
assemble a broad amount of information that would result in a substantially
more stringent emission limitation, most likely coming out of the process.
To some extent, that is a forecast of a process that we are still in the
middle of with respect to the sulfur oxide and TSP criteria document
review. The regulatory side of this Agency is not all that familiar
with the draft criteria document, and as Steve Gage indicated to you,
all the registrants here will all be getting copies of that draft and
you may be able to form some judgements, as we will, of the potential of
that option. Another negative factor is that because it involved the
SIP process, the timeframe is rather lengthy. We have a year or so
process before the ambient standards are locked into a promulgated form.
There are opportunities for litigation on that. The schedule for submission
of plans is either 9 to 27 months depending on whether we are talking
about health- or welfare-based standards or whether a State asks for an
extension. If we are talking about welfare based standards, the current
law sets an attainment date as a reasonable time. We can attempt to
establish some criteria for what constitutes a reasonable time, but we
do not have the tight deadlines for attainment demonstrations that we do
in the primary standards area.

Yet another option is the exploration of the use of Section Hid of
the Clean Air Act where we would need to require controls on some non-
criteria pollutants that are associated with the acid precipitation
problem, if we identified such noncriteria pollutant or pollutants that
would trigger an obligation on the part of the State to adopt regulations
for existing sources of those pollutant(s), again through the SIP process.
The positive aspect of that is that it triggers the SIP process perhaps
more quickly than setting an ambient standard would, especially if we
had to do additional research prior to setting an ambient standard. The
second positive aspect is that it avoids dispersion model gaming. That
is, it is a technology based requirement—even though it is adopted
through the SIP it is technology and hiring meteorologists do not necessarily
wind up giving you a relaxed emission limit because your emission limit
does not depend on the dispersion models. Sorry for that slight against
meteorologists, Walter. The final aspect of the positive side is that
it does allow tailoring. We could establish guidance for categories or
subcategories of plants that appear to be the most cost-effective. We
could require certain degrees of control for some categories of plants
that would be very cost-effective without requiring those same degrees
of control for every plant across the board. Now the negative sides of
that option are that there is possible litigation over the pollutants
selected; and arguments about whether it is truly a noncriteria or a
criteria; pollutant and the probable need to tighten up on our current
generic 111d regulations. Our llld regulations, as they are written
today, which were nonhealth-book based pollutants, allow the States
considerable ability in deviating from a.iy technology based norm that we
lay out under that section.

Moving to another possibility, and that is the definition of modifi-
cation or reconstruction. It may be possible to modify the definition
so that activities at a plant which tend to extend the useful life of
that plant or tend to increase the total emissions generated over the
total life of that plant could be legally defined as a reconstruction or
modification which would, if those activities were undertaken, then
cause the plant to be governed by the new source performance standards.
Now, the positive aspect of that is that some of our current existing
sources which are subject to relatively high emission limits, if they
were to extend their useful life substantially, might be brought into
the new source performance standards system. That regulatory requirement
might cause one of two effects, it might cause a retirement of that
facility rather than an extension of its life, or it might cause the
retrofit of a source in order to meet the new source performance standard
emission limit. The negative side is that there would likely be litigation
over any modification of our definition, enforcement might be difficult,
the activities that tend to extend useful life are largely a function of
what the utility or other source is saying about the effects of those-
modifications. It might be fairly easy to get into arguments with the
sources about these particular physical changes and whether they would
have the effect of extending the useful life. If we define the cutpoints,
the type of activity that shifts you from one gain to the other too
strictly, then you you could wind up imposing some very costly retrofits.
Well there are a number of other items which I would like to identify
that are things that the States may be able to do under their current
legal authority, at least some States certainly can do some of these

things and other States may be able to do more. There are also things
that EPA could explore in terms of additional legal authority that might
be sought from Congress. One would be some form of emissions cap--some
form of maximum emission limit on some category of existing sources,
which would be a maximum available in any State in the country and
separate from any emission limits that might be calculated by dispersion
modeling. The positive aspect of that is that it would address the
inequities concern. It could well reduce the emissions substantially
from the largest existing sources. It would be quite cost-effective and
there is at least an appearance of reasonableness to it. The negative
side is that it does raise the potential for disruption of existing coal
markets which is a problem which would have to be addressed and resolved
and its economic impact might fall on one, two, three, or four States
rather heavily and not at all on other States. This would obviously
make a political coalition to undertake that, either within the States
or nationally, more difficult than something that had a little bit of
sacrifice and a little bit of benefit for everybody.
Another possibility would be an emissions cap, a total loadings cap
or budget on a Statewide or regionwide basis. This is something that is
being discussed in Europe, for example, between the various nations
there, many of whom are geographically not all that much larger than
some of our States or collections of States. They are discussing total
national sulfur budgets, for example. This process would involve
giving each State or having a group of States negotiate between themselves
a set of total loading targets and each State then would determine the
best approach for achieving that target. Two that total loadings

target could be anywhere from preserving the status quo to some range of
percent reductions, either immediate or phased. The positive aspect of
this is that it does allow flexibility within each State to find the
most cost-effective way of achieving the target and it does allows some
fine tuning geographically in order to try to have the maximum impact on
improving the acid rain impacts that we are most immediately concerned
about. The negative side is how do you come up with this budget. We do
not have an 0MB for this process and we do not have someone who has been
clearly given the authority to resolve disputes so we do not have an
institution that is sitting here today with the legal authority to
impose a solution if you do not have agreement among the States. Given
what we all know about the adequacy of emission inventories, even in
metropolitan areas where they are fairly closely studied, there is some
difficulty in determining the compliance with an emission cap particularly
since the State that has the obligation to meet a cap is also the insti-
tution that has the most information about whether it is or is not
meeting that obligation. Finally, these caps may be broader than necessary
or optimum, it may be that an air quality control region would be a
better basis for a cap or some other geographic subregion that might
extend across State boundaries.
Another item which we have mentioned several times already, and
other States have mentioned and are considering is mandatory coal washing,
which would require all our coals above some sulfur content to undergo a
coal washing to a certain percent reduction. This would be economically
sound, it might even, in a number of instances, wind up paying the
utilities because of possible reductions in transportation costs as well

as some operating difficulties associated with burning a poorly washed
coal. It would reduce sulfur variability so it would deal additionally
with these peaks as well as reducing the total loadings and could get
anywhere from 20 to 40% reduction in terms of emission reductions on
certain high sulfur coal. The negative features that have to be explored
are the adverse secondary environmental effects that might be associated
with broad scale coal washing. Coal washing facilities are industrial
processes themselves. What are their affluence? What are their exter-
nalities, and if broadly done, do we know what they all are? The other
feature that we would have to address ourselves to is how do we design
the system to avoid fuel switchings that could wind up with more washed
coal but not necessarily lower emissions. That is, if plant A switches
from a five pound unwashed coal to an eight pound run of the mine coal
which is washed to five, we are right back where we started from in
terms of total loadings. We may have improved our flexibility in terms
of our resource base but we have not directly attacked the total loadings
I will just run through the others in the three minutes I intend to
take to finish up on this to keep it to a half an hour. Final opportunity
is our taxing schemes--a sulfur tax, an N0X tax. These are taxes that
could be established by Congress or taxes that could be established by
State legislatures. They could take on an infinite variety, they could
be negotiated through interstate compacts that have equitable taxing
schemes to deal with some of these issues, they might allow transfers of
burdens across utility systems or across grids in a way that would avoid
putting all the economic burden on one utility system or one group of

rate payers. They are argued to be quite efficient, flexible, and cost-
effective. The negative side is that getting tax schemes through our
legislatures, whether they be Congress or the State, go to committees
that are not environmental committees and have not been historically
favorable to using tax schemes to accomplish these kinds of objectives.
We might wind up with a tax scheme that had the appearance of a reform
but in fact did not accomplish the intended objective because of some
carefully written language which all of us are not expert in under-
Another institutional approach, if you will, is one that would
require least emissions dispatching rather than least cost dispatching.
This could reduce emissions without additional capital investments and
might encourage utilities to retire some older, less efficient, higher
emitting sources simply because the Utility Commission would be requiring
those to be used less and they would be less efficient to keep operating.
The negative side of that is that in utility systems that are burning
oil and gas you could and probably would lead to an increase in oil and
gas use which is something we are trying to avoid. It would most likely
increase cost to the rate payer because if least cost and least emissions
dispatching did not coincide then least emissions dispatching would be
more expensive than the least cost alternative. It would be difficult
to monitor because we are dealing with daily operational decisions and
it might encounter some of the enforcement difficulties that we felt
have always existed with schemes like intermittent controls.
There are other activities that we, in the abatement area, could
encourage. Things like the regulatory reform or the State Utility

Commissions that would allow automatic pass through similar to the fuel
adjustment clause for emission control costs. This could be used and is
something that all of us could try to educate the Public Utility Commission
on. Finally we could and we will be communicating with the IRS to
encourage favorable tax treatment for the facilities that reduce sulfur
but are not located at the fuel consuming facility itself. Right now,
if a utility puts a scrubber on, it does get favorable tax treatment.
If it uses washed coal it does not necessarily get that and especially
if the coal washing facility is not at the utility plant itself.
Well, these are a fairly extended but probably not all comprehensive
laundry list of some areas that I think during the rest of the day we
would like to have you explore and the format for the rest of the morning
will now be to turn to presentations by the States themselves and I
would like to have Doug come forward and Walt also wants to make a
Walter Barber: We have a couple of administrative things. We are
going to change the order of presentations a little bit. Commissioner
English from New Jersey will lead the series of State presentations
followed by Jim Hambright, then Bud Hovey, and then Dan Goodwin, to accommodate
some schedules. I would like to add one note to Dave's comments, it
sounded like an awfully long list. We have an effort going on in the
Agency to analyze a subset of alternatives over the next couple of
months both in terms of energy environmental impacts and economic impacts
to bring into better focus some of the choices. I have been looking at
this as what can we do in the near-term, what can we in the mid-term,
and what can we do in the long-term. We probably have to carve this

problem up into pieces, be they 10% reduction pieces, or 5% reduction
pieces. If we wait until we have the perfect solution, the right mix of
all of them, to get to the bottom of the problem, we will be into the
next decade because we will not have the problem fully identified and
analyzed until then. In our discussions today, we ought to start to
explore what is the best first step, and then what is the best second
step, and if you really need legislation it is probably out at the third
step range, assuming that we can do some things in the near-term. Bud,
you want to introduce the State speakers?
Dave Hawkins: Walt will now introduce each of the State speakers and
the first is going to be Commissioner Jerry English of New Jersey.
After I just said Walt will introduce her, I will introduce her. Commissioner
English has been able to come down and join us and we want to welcome
her from the State of New Jersey. She will make an initial presentation
which will then be followed by Jim Hambright. So Commissioner English,
Commissioner English: Good morning, I think that the first thing we
want to dispel is some suggestion that the Environmental Protection
Agency is not a group of able people capable of prompt change. By
changing the agenda this morning just like that it shows me that they
can also change directions and more importantly get lunch together.
Obviously, I am going to miss the best part.
My name is Jerry English, I am the Commissioner of Environmental
Protection of the great State of New Jersey, also known as the garden
state. I would like to thank the Administrator and Mr. Hawkins for
providing this forum in response to requests basically from the Northeastern

States who have expressed concern with the acid rain phenomenon and the
tremendous social and economic implications that will flow from any
solutions or nonsolutions to the problems that you have been talking
about. I am now going to apologize in advance. I realize that you have
been here already for one day, discussed everything I am going to talk
about, but I would like to try and put it, if you will, into some sort
of perspective for those of us who must administer the program every
The United States, as you have already said, annually discharges
more than 50 million tons of sulfur and nitrogen oxides into the air.
The pollutants are converted into acids and are causing severe ecological
impacts on widespread areas of the environment. This is obviously not
just a national phenomena but is also an international phenomena, but
again I am certain that you have talked about this already.
When my neighbors in the Adirondacks talk about 90 lakes that are
fishless because of the acidic conditions, that only indicates that
other areas of the United States such as Northern Minnesota and Wisconsin
will be vulnerable to similar impacts. More importantly, I think that
the Agency's own research has shown that sulfates and fine particulates
emitted by the same processes that contribute to the acid rain problem
are severely detrimental to human health and indeed that is really why
we are here, I submit. In addition, the yield from agricultural crops
and the productivity of forests can be reduced as a result of the direct
effects of acids on foliage and leaching from minerals in the soil, as
I am certain has been documented in this conference already. In short,
we are faced with a severe threat to the delicate ecological balance in
large areas of the nation.

The air pollution problems from fossil fuel combustion will be
exacerbated by the present push to curb our ravenous appetite for imported
oil. Again, another reason why this particular conference is so timely
and why the Congress will be paying particular attention, we think, to
the problems we are about to address.
For example, a recent evaluation of the Federal Department of
Energy plans to convert oil-fired power plants to coal-fired plants
indicates that sulfur dioxide emissions to the atmosphere could be
increased by as much as 400,000 tons per year in the Northeast alone.
New Jersey is fully committed to President Carter's long-term
strategy for reducing our dependence on foreign oil, let there be no
mistake about that. As Governor Byrne recently said in his State-of-
the-State message, "no more difficult problem faces us, and the nation,
than that of unstable energy prices, and unstable energy supplies."
Thus our policy decisions are complicated by the tension between our
efforts to deal with the acid rain and the national policy to conserve
oil by burning coal. In our view this tension makes it all the more
important that we develop uniform national guidelines for sulfur dioxide
air pollution emissions. Coal conversion must proceed, but this is why
we are here, rationally and prudently.
In New Jersey we have adopted a policy of coal conversion in a
manner which minimizes the resultant air pollution problem. National
guidelines, again, why we are here, are necessary to relieve the pressure
on individual States to act on behalf of a local constituency in a
manner which is detrimental to regional, national, or even global environ-
mental interests. But let's not kid ourselves. If you try to minimize

the expense at this point, the highest and best solution today may well
not be the most expensive solution when we look back on the problem from
future vantage points.
This conference, we submit, must serve as a springboard for constructive
action. It is to be taken jointly by Federal and state governments.
Administrator Costle, I pledge to you a very good staff on a day-to-day
basis and I am certain that those of the rest of us in the Northeast
will do the same, because this problem is not going away. We have long
been of the opinion that only cooperation between the States, orchestrated
and coordinated by strong Federal policy and leadership, will be effective
in combating the effects of acid rain and other problems related to the
long distance transport of pollutants.
I am pleased to be attending a conference devoted to these issues;
however, I am somewhat puzzled at the state-of-affairs that has led us
to the need for such a conference at such a late date.
Despite our knowledge of the severity of this problem and despite
the clear energy and economic pressure to worsen the situation here in
1980 we are apparently still in the very early stages of considering how
to deal with it. It is certainly not too late, again we submit, to
effect policy changes which can reverse a deteriorating situation, but I
question whether we in the Northeast can afford continued inaction in
the face of documented dangers of the nonpolicy of the past. Thus we
applaud President Carter's understanding of the issue at a very important
time in the life of the history of EPA, its tenth anniversary in which
the President named the acid rain phenomena as one of the preeminent
environmental challenges of the decade. We look to this agency which is

very distinguished to take up that challenge without delay. But we
intend to help.
In order to accomplish this goal, it is necessary to go to Congress
to seek legislative changes to the Clean Air Act, and at the same time
reexamine the national ambient air quality standards for SO to account
for the effects of derivative pollutants such as acid rain and sulfates.
The route that the Federal government chooses to accomplish this goal is
a problem to be resolved again by the Administration, the Congress, and
the States together. To be sure, New Jersey and other States will be
heard on the issue at it evolves, but our primary concern today is that
EPA understand the need for decisive positive action at the Federal
level and that such action is imperative. Again, we keep saying without
further delay, in Washington, "without further delay" is a term apart,
and in the States it takes a little longer.
March 19, before the Senate Subcommittee on Environmental Pollution,
Administrator Costle stated that less than one-half of the acid rain,
now I am going to get regional on you, that falls on the Northeast is
generated there. This observation goes to the very crux of the dilemma
about solving the acid rain problem.
Why is that less than 28% of the acid rain in New York and New
Jersey according to, again, Doug Costle, generated there? Certainly the
meteorological facts of life account for this situation to some extent,
but the real dilemma, as we see it, is caused by the inequities that
have developed between the States east of the Mississippi with regard to
the regulation of S02 emissions.

Since the late 1960s, New Jersey and the rest of the Northeast have
proven, through rigorous action, that ambient levels of sulfur dioxide
can be reduced to healthful levels even in the most urban and industrial
settings. And now I get to talk about a place in New Jersey called
Bayonne. It is a midsized American city and it is mirrored by cities
that are in all the States represented here. It is heavily industrialized,
in part, it is typical of the cities that form the heart of our nation's
industrial strength. It is rich in ethnic neighborhoods and has a
tradition of hard work, and yet it is a city just like cities in every
State that could really do with that new economic shot in the arm. The
instincts and pressures to lessen standards so that one plant will stay
there and not threaten to move out on you is very strong. However, our
monitoring stations there offer a model of the dramatic improvement of
air quality that has been achieved even in that sort of city.
As the handout shows you, people in Bayonne are supposed to feel
better because there has been an 85% reduction in sulfur dioxide pollution
in the air since our program began in earnest in late 1966. This is
not, as you know better than I, an unusual experience in the environmental
improvement in the Northeast. Bridgeport, Connecitcut; Long Island
City, New York; Walton, Massachusetts; and countless other cities demon-
strate that healthy air and sound economy are not mutually exclusive,
and that is really the point of our being here. Such ingenuity and
self-reliance have been documented time and time again.
Now I am starting to talk about some important coal issues and I
hope you will pay attention, because if we are talking about going to
the Congress, you go to the Congress with some friends. We have some

very powerful friends in the Northeast-Midwest Congressional Coalition
and in the Coalition of Northeastern Governors which has been ably
headed by the leadership of Governor^ Carey, Byrne, and Grasso to name a
few. The approach adopted in New Jersey and elsewhere to effect this
reduction was to severely limit the sulfur content in fuels burned in
our jurisdictions. In light of the economic and technological conditions,
again, prevailing at that time, this was a sensible balancing of environ-
mental concerns against social and economic effects.
However, times have changed. The effect of our approach, and
increase in our dependence on imported petroleum products has required
significant liabilites as a result of the dramatic political and economic
changes that have since occurred. But the environmental problems have
not gone away. In fact, one reason we are here today, is to consider
complications that were not even addressed, they tell me, 15 years ago.
I am not sure I believe that. I suspect that everyone knew the problem
was there but said let's do one step at a time. That other step's time
is now. This challenge must be faced head on now. We cannot simply
revert to those more comfortable policies, even though they didn't seem
comfortable at the time, of the 1960s in order to reduce our consumption
of foreign oil. New Jersey simply cannot relax sulfur in fuel standards
or coal burning emission standards to the maximum limit permitted under
the national ambient air quality standards because of economic and
energy considerations, and in so doing leave the type of legacy to
future generations that we all know will be unacceptable.
Our position is that New Jersey and the rest of the Northeast have
reached the practical limit as to what can be required of those who

would burn coal and high sulfur oil in our States without jeopardizing
the health and safety of the citizens. And second, even with existing
stringent controls, as the Administrator Costle has pointed out, the
acid rain problem will not be resolved in any event by any action taken
by the Northeast alone. The time has come to require other jurisdictions
outside the Northeast to take the lead in reducing sulfur pollution.
The maps and handouts we have brought, again, graphically illustrate
the point. In graph 1, I want you to notice how innocent New Jersey
looks. Isn't that wonderful, it is kind of this little place there and
it doesn't look so bad. This illustrates the contribution of all States
east of the Mississippi to the total SO2 emissions for the region. I
think it makes the point abundantly clear that States outside the Northeast
need to reexamine their policy toward S02 emissions, and further suggests
that one might look to significant reductions in S02 atmospheric loading.
Now you are getting to the point where you are starting to argue
about the graph, and that is a good sign. Now I have got your attention.
For example, an examination of the graph accompanying the all-states
graph shows that Ohio is the source of S02 emissions which are nearly
equal to the total amounts emitted by New Jersey, New York, and Pennsylvania
combined. Another approach to quantification, and quantification is the
easy way to do this you see, of the equity problem is to examine S02
emissions on a per capita basis, and this one they had a lot of fun
with. New Jersey continues to look very innocent. This map and the
accompanying chart provided to you illustrates that the Northeast today
has borne an inequitable share of the responsibility for reducing S02
emissions. Did you notice that Mr. Flacke left the room while we talking

about New York because his group is kind of innocent too. On the basis
of these per capita emissions, the map suggests that those areas colored
in red must be required to contribute significantly to the resolution of
the acid rain problem.
Now let's get serious, no one in Ohio or Illinois wants New York or
New Jersey residents to suffer because of transported air pollutants
emitted from their States, and similarly no one in the Northeast wants a
single coal miner out of work in Ohio, but that is the reason again that
we are here to work on this problem and to cooperate together.
I would like to conclude first of all by saying it would be grossly
unfair for us to have come to this conference, to Administrator Costle,
and said now here is the problem and you go solve it. I am very pleased
that this has been the beginnings of a rational policy put together
which I will submit to our Governor as a program that will suggest ways
of going about resolving this problem, and again I want to commend New
York State for its leadership in thinking about the problem, giving a
solution, and then saying at least we have got something here to work
from. I can hardly wait until someone explains to me that with coal
washing there is also a hazardous waste problem. The whole thing never
ends, but we all understand that, but how sensible an idea coal washing
seems to me to be. We have a challenge again about sharing these problems
equitably and understanding the costs of what we are talking about. I
think that you have, in the past two days, discovered that the technology
has been there for a long time. Much more difficult will be the question
of how to pay for it, how to develop the constituency that will ensure
that this administration and this agency has all the tools that it

requires in order to solve the problem. That will be a tough fight. It
is one that I certainly can pledge to join in, and I say one thing to
you, because I did not ask for it to rain today, however, I want you to
look closely at the Washington Monument when we get through. It is a
symbol of our national pride and it is made of marble. A substance
particularly susceptible to acid rain. If the Washington Monument
begins to look a little funny or somewhat the worse for wear, it is
because we did not do our job right here today. Thank you.

New Jersey Department of Environmental Protection








































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Mr. Hawkins: Thank you, Commissioner English. Commissioner English
relieved some of the formality in the session so far, and I think that
it will be important for us to get out of the lecture mode and into the
discussion mode as soon as possible, not to cut off Jim's speech but we
aren't going to get very far if we only listen. People ought to be
working on questions, comments, and reactions now so that we can proceed
after the formal presentation with some useful debate.
Jim Hambright: We do not know what the acid rain problem is or may be.
We do not have enough data. We have not explored the phenomena enough.
We believe that it may be a serious problem and as more information is
developed we will be able to explore the scope of that problem. Our
initial concern, which we brought to EPA, was with a certain amount of
inequities that are occurring because of long-range transported air
pollutants, and their effect on our State in making it more difficult
for us to achieve attainment in nonattainment areas, and in using our
increments in the attainment areas where we are working under prevention
of significant deterioration.
I have a series of overheads which will, to some extent, show our
concern and what we recognize as a problem which we believe that as a
State, alone, we cannot address. We do not have the legal authority to
control anything that transpires beyond our boundaries, and we have to
look to the Federal government for aid and assistance in these area.
Could I have the first slide, please. All right, the data that we are
working from here is specifically from coal-fired electric generating
plants. This shows the generation in millions of megawatt hours, and
the percent total of generation for the States listed on the left.

Next slide, this chart depicts the sulfur dioxide in thousands of
tons a year again specifically related to coal-fired plants, and the
percentages of total emissions are on the right.
Next slide, this chart shows the pounds of sulfur dioxide emitted
per megawatt hour generated from the coal-fired power plants by the
respective States. A lot of this data is self explanatory, I am just
bringing it to your attention, you can look at it and evaluate it as you
Next slide, this is a weighted sulfur dioxide emission from the
coal-fired power plants in the respective States, this takes the megawatt
capacity times the emission standard accumulated for all the plants in
the respective States divided by the total megawatt hour generating
capacity, which gives you effectively in pounds per million Btu the
weighted standard for the respective States now in place according to
the State implementation plans.
Next slide, this is one of a series of overheads. It shows the
emission limitations in pounds per million Btu for the respective generating
stations, each dot represents a generating station. The red for this
series is all those plants which have emission standards greater than
the 6 pounds per million Btu. This overlay shows all plants with emissions
standards from 4 to 6 pounds per million Btu. The next overlay brings
in the power plants with the emission standard of from 2 to 4 pounds per
million Btu.
Next overlay. Here we have the plants which fit in from 0 to 2
pounds per million Btu, again, this gives some feel for the various
emission standards in place throughout this region of the country and
the area of some particular interest to us is the entire Ohio River
Basin Power Generating Area.

Next slide, this particular slide lists specific emission standards
in place for power plants through the Ohio, West Virginia, Pennsylvania
region, all of the Ohio River Valley Basin Area. This picks out those
specific plants in this fairly narrow geographical area. The numbers
are in pounds of sulfur oxide per million Btu limitations.
Next slide, I bring this to your attention because we believe that
it points to a serious problem. We understand that EPA believes that
the oil backout, the coal conversion program, will increase sulfur dioxide
emissions in the order of 250 to perhaps 400 thousand tons in the North-
east. They have expressed their concern over that and I can understand and
sympathize with their concern. However, during the past 12 to 15 months,
EPA has considered relaxation of existing SIP standards for the power
plants listed on this particular overhead. Some of these have been
approved, some are in the process of being approved, and one, at least
the Cammer Plant, is being contemplated by the State but has not yet been
brought to EPA. The total effort, or the total result of these considera-
tions and actions by EPA results a 759,000 ton per year of sulfur oxide
relaxation or extra emissions over what the SIP would allow. This we
believe is of significance and if we are going to be serious about
addressing long-range transport of pollutants, acid rain or what have
you, I believe the Agency must give much more serious consideration to
the relaxations which they are allowing. Granted those relaxations may
be under the province of the existing Clean Air Act but they are exacerbating
a problem.
Next slide, we recognize this problem not as an acid rain problem,
we recognize it as a sulfur dioxide and as a total suspended particulate

problem in the form of sulfate. These isopleths drawn through Western
Pennsylvania show the impact of sulfur dioxide in micrograms per meter
annual average which are modeled by EPA's model, by an EPA contract to
Cramer, modeled on the basis of emission sources in Ohio and West Virginia
which are in compliance with the SIP existing in those areas. Those
emissions result in a nonattainment area in Pennsylvania 90 micrograms
per cubic meter in the small area in the extreme Western part of the
State, and they result in the series of isopleths from 60, 40, 20, 15,
out to 10 micrograms per cubic meter impact on Pennsylvania in an area
where we can ill afford that impact. The Pittsburgh metropolitan area,
the Beaver Valley industrial area, and the Monongahela Valley industrial
area. These impacts are caused by pollutants over which we have absolutely
no control, they cause us, in some areas, nonattainment where we could be
in attainment and where they do not cause nonattainment they are seriously
erroding our ability to develop and attract industry because our prevention
of significant deterioration increments are devastated. This is a
modeled result. In addition to this modeled result, our monitors placed
on the extreme Western edge of Pennsylvania have in the past five
months recorded two instances of violation of the 24-hour standard. We
have recorded an instance of 389 and 455 micrograms per cubic meter, 24-
hour violations in an area where we have what amounts to no sources.
These occurred during air stagnation inversion periods when the wind
direction, such wind as there was, was moving into the State from the West
through the Southwest quadrant.
Next slide, previously I have been speaking to the sulfur oxide
problem, I would like to move on to the sulfate problem, again, which

impacts our ability to achieve our total suspended particulate ambient
standards. This is the sulfate episode done by the OBERS study in 1974.
It shows how the sulfate increased through this area of the country and
pretty much follows the power generating complex up the Ohio River
Valley area with a cascading effect into Pennsylvania, New York, and the
New England States. The next slide shows what the air mass trajectory
are during this period of time and shows how these air mass trajectories
tend to move pollutants up the Ohio River Valley area into the Northeast.
Next slide, this is Pennsylvania monitoring results. These are
arithmetic annual averages of sulfate. This is sulfate recorded in the
Western part of Pennsylvania. Here it is 16 to 15, and down at the
lower end, it is 16 to 20 micrograms per cubic meter. We believe that
at least 80% of this is advected pollution. Again, sulfate pollution
over which we have no control, and which can constitute as much as 20 to
25% of the annual average which we are expected to achieve. We have no
control over it, but in some instances it takes us from attainment to
nonattainment and in other areas it is certainly impacting our prevention
of significant deterioration increments.
The next slide shows some 24-hour maximum figures, as much as 60
micrograms per cubic meter, in a relatively rural area of the State.
These again are 24-hour sulfate concentrations much of which we cannot
control and really cannot do anything about.
Next slide, this shows that over the last 6 years, in the Beaver
Valley, a heavily industrialized area North of Allegheny County. To
show how the total suspended particulate matter has declined over

those years from something on the order of 120 to 130 down to about 80.
During that same period of time, the bottom line, sulfate as a percent
of total suspended particulate mattei , has shown the following curvature,
indicating fairly clearly that, in fact, we have reduced total suspended
particulates significantly but that the sulfate is staying relatively
the same. The programs which we have implemented to reduce particulates
have been effective but the advected pollution is beyond our control on
the basis of local enforcement efforts.
Next slide. This again is to show the projection of sulfate impact
on the Northeast for the next decade. Presumably, if things go on the
way they are and as we have more coal conversion and perhaps no better
control we will have increasing amounts of sulfate as shown on this map,
up to 29 to 30 micrograms per cubic meter. A potential significant
impact which would be very difficult to handle economically and
developmentally in the Northeast.
Next slide. This shows deposition of sulfate from the national
atmospheric deposition program. This shows where some of the concentrations
are, and I will bet that North Carolina did not know that they were a
potential hot spot. This is relatively recent data, and again it is not
our data, it is national data.
Next slide. This is probably a set you have seen before showing
the increase in the acid rain impact in the Northeastern part of the
State from 56 through 76 showing how the area is expanded and again I
cannot speak to the way in which this particular data was developed. It
is not our data, it is Federal or national data.

Next slide. This one is to speak again to the problem of the
utility coal-fired power plants. This is just a "for instance" and it is
not specifically a recommendation but just to show that if all the
States indicated, reduced their utility emissions to the same level at
which the utilities are controlled in Pennsylvania, the total mass
emission rate reduction would be somewhat in excess of 11.7 million tons
of sulfur oxide per year.
Now let's go off the slides, please. I think that we have recognized
this as a problem which we cannot control, I think we can demonstrate
with something a little harder in the way of information than modeled
results that it is a problem that we cannot do anything about. We
believe that there has to be a regional approach to this problem. We
think that a regional approach has to be done through some mechanism
controlled by the Federal government since the individual States cannot
really approach or address these problems of interstate impact. We
believe coal washing is a technique which would produce reductions of
maybe 10% to 15%. It is something which would be relatively cost
effective and which should be considered. We also believe that the
Orsanco area or the OBERS study group has a pretty good handle on data
and information in the Ohio River Valley Area. Their studies could be
expanded to show need for the Federal government to take a regionalized
approach in this area to establish perhaps more equitable control efforts,
or to provide for mass emission reductions in this area which would
benefit not only our particular problems that I have addressed, but also
the total problem of the acid rain throughout the Northeast.

I do not know that I have heard anything here today that has made
me tremendously optimistic, but I think we should all continue to work
toward a solution to the problem that we have identified. In Pennsylvania,
New Jersey, and Delaware, we developed a regional approach to the sulfur
oxide problem. This was done in cooperation and coordination with the
Federal government. It was not done under any Federal law, but it was
done as a cooperative effort. However, that cooperative effort was
pushed pretty strongly by the Federal government and I believe that we
need that type of a catalyst to get the thing going and to achieve some
of the goals that we are trying to get to. Thank you very much for your

Arkii. 2, 1'i.SO

Of Total
West Virginia
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> 6 lbs/10® Btu
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BETWEEN 4 AND 6 lbs/106 Btu
f 4 to 6

BETWEEN 2 AND 4 lbs/10^ Itu
• 2 to 4

< 2 lbs/10^ Btu
• 0 to 2

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West Virginia

Allowable Emission Increases ,n SO2
Resulting from EPA Propose. 1 or
Approved Relaxations
1.	Mitchell
2.	Harrison
3.	Kammer
L\, Avon Lake
5.	Eastlake
6.	Bayshore
Water Street
7.	Poston
Emissun Increase
162,000 TPY
mE 80() TPY
127,900 TPY
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5,500 TPY
1^000 TPY
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Figure 26.—Annual Concentrations of Sulfate for a 1900 25.7 Quads Coal-Use Scenario
(Brookhaven National Laboratory 197U*

pnqrim I

Regions affected by acid rain
figure 5 IsoDleths shewing Ai.nual Average oH for Precipitation in Eastern North America
(modifieo from Likens et al, 1979^.

Potential SO^ Reduction from Coal Cleaning
Utility Coal Fired Power Plants
Sta te
Number of
Number of
Plants Emitting >
4#/SO?/MM B7U in
Total SO2 Emissions
from those
Plants in 1977
(103 Tons per Year)
Reduction in 10 Ions SO2
per Year ff all Utilities
went to 3.7 #/W4 ETU as
an Annual Average
Reduction 0* al
Utility Coal
nil no T S
West Virginia
i ?
J. A-


Scran*; on
State Col lege 25
•	Phi ladelpffLi
Lancaster	X25
1979 Sulfate mean expressed as a percent of the secondary NAAQS for TSP (60 ug/rn3).

Mr. Carl Beard: Walt, could I make one short comment at this time? Jim
points out Cammer Mitchell in Harrisburg. Cammer Mitchell is almost
totally washed coal. While you are thinking about this, that coal is
already washed, has been for years, and better than 70% of the coal in
Harrison is washed. These are mine mouthed plants. As you are thinking
toward a solution to a problem, keep that in mind.
Mr. Hawkins: Bud Hovey from New York.
Mr. Hovey: I am going to speak with two hands. The first, STAPPA. As
most of you know, STAPPA is the State and Territorial Air Pollution
Program Administrators, and STAPPA appointed a committee on long-range
transport of pollutant. This committee was made up of representatives
from the States of Oregon, Oklahoma, Ohio, Pennsylvania, Connecticut,
Georgia, and New York. Originally Wisconsin was a member of the committee
but the Wisconsin member left the ranks of the air pollution directors
for a better job in the State of Colorado and he is no longer a member
of the committee, although he did participate in the last meeting the
committee had.
'Because of the serious problems of transported pollutants and
because of the concerns over acid precipitaiton (as only one of the
transported pollutants), the committee was put together and has come up
with some positions which were presented in the form of a resolution to
the STAPPA Executive Board. The Board approved the resolution just
before the meeting and that is why the copy that was passed around to
everybody at the table had the word proposed at the top scratched out.
As we set forth in this STAPPA position, the current law cannot adequately
address the problems of long-range transport of pollutants, particularly

through the SIP process. Thus, it appears evident that the law should
be changed to accommodate equitable control of sources of transported
pollutants. Acid rain is only one of these long-range transported
pollutants and should be treated in the same manner as the others.
If Congress would change the law in the next year or two so as to
require reasonable control measures, and if such legislation requires
EPA to develop regulations, then it would be to everyone's advantage if
EPA started now to address the acid rain precursors. We believe this
can be done under Section 111(d) of the Clean Air Act. While this is a
complicated procedure, it would get the technical work started so the
regulations would be forthcoming soon after a change in the law. Further-
more, if the law is not changed, EPA would have some mechanism, incomplete
at it may be, for dealing with the acid rain problem.
Many of you might wonder how we could use Section 111(d). For
those of you who are not completely familiar, 111(d) can only be applied
for non-criteria pollutants. Section 111 of the law requires that EPA
adopt new source performance standards. Once they have adopted it for a
non-criteria pollutant, they then can adopt a standard for existing
sources for that same noncriteria pollutant.
What is the noncriteria pollutant in this case? Is it sulfate,
nitrate, or is it total sulfur, for example? One of the approaches
would be to consider either sulfate or total sulfur as the noncriteria
pollutant. EPA has already adopted emission standards for sulfur dioxide,
which is a criteria pollutant for new power plants. By the same token,
the control of sulfur dioxide, in effect, gives you the control of the
total sulfur emissions. Using that logic, there is the possibility of

using Section 111(d) then as a mechanism for controlling total sulfur
emissions from existing power plants.
We have not tried to do any legal research on this because I think
you could argue both ways. EPA should get on with this type of work.
If there are challenges to it, so be it. But one thing, if there are
challenges to it, it may help us move forward to the necessary changes
in the Clean Air Act to address the issue of transported pollutants and
an equitable method of addressing the transport of pollutants.
To help those of you who did not get a copy of the STAPPA resolution
on the long-range transport of pollutants (and I hope all the States got
a copy) the resolve reads as follows:

A National Policy on Acid Deposition and
Regional Consistency
State Proposal Presented
April 9, 1980
Springfield, Va.
The official representatives from the states listed at the
end of this document agree with the substance of the discussion and
recommendations which follow. These states come to this conference
with the hope that the states who are participating can develop a
series of positions that will lead to the solution of long range
transported pollutants and EPA's inconsistent administration and
inequitable enforcement of the Clean Air Act. Regarding acid rain,
we are not here to blameone region of the country as the responsible
party, since all of us contribute to this serious environmental
problem. We are here to find solutions and to work collectively
with the other states in developing a position which can be supported
and utilized by us all for control of transported pollutants.
Our goal is to ensure that all states are subject to consistent
and equitable requirements under the provisions of the Clean Air
Act. And that one state or region of the country does not suffer
because of inadequate controls imposed in another state or region.
Acid deposition and the long range transport of pollutants is
a phenomenon which has become widely recognized in only the last
20 years . It is safe to assume that without the introduction
of large scale power plants which has increased sulfur and nitrogen
oxides emissions, and the "tall stack" policy which has resulted in
impacts far removed from the source, we would not be facing the
severe long range transport problem. Accordingly, we are most
interested in a program which will ultimately reduce the total
sulfate and nitrate burden to the atmosphere and allow for the
equitable and consistent administration of the Clean Air Act.
We are proposing a program which we feel can address many of
these needs and provide the United States with a solution to this
problem, as well as equity of consistency under the requirements
of Federal laws.
Our proposed program includes the following six elements:
1. Administrative and regulatory action under Section 111(d)
of the Clean Air Act

2.	Requirements for coal washing
3.	Legislative action to amend the Clean Air Act to require
national	emission limits
4.	Retrofit of existing power plants to meet national emission
5.	Nationwide emission monitoring
6.	National consistency of actions among EPA Regions.
A.	Immediate Administrative Action
Utilization of Section 111(d) of Clean Air Act to develop
emission limits for existing sulfate and nitrate emission sources
(i.e., power plant combustion installations, refineries, smelters).
1.	New Source Performance Standards (NSPS) are currently
required for sulfur dioxide and/or nitrogen oxides from these
2.	Sulfur dioxide and nitrogen oxides convert to sulfates and
nitrates in ambient air - ergo implied NSPS for sulfates and
3.	Section 111(d) requires EPA to adopt emission limits for
existing sources of "non-criteria" pollutants when NSPS are adopted
for the same pol1utant-source.
4.	Sulfates and nitrates are "non-criteria" pollutants.
5.	EPA should immediately start development of reasonable
control measures for these pollutants and sources-particularly
power plants with tall stacks. FPA should notify thP st.atP*
within 60 davs of this conference whether 1t intends t.n utlHyp
Section 111 (d)~
B.	Coal Washing
In accordance with our desire to reduce the total sulfate
burden as soon as possible, we feel that a national program
requiring coal washing should be mandated. Coal washing
represents a first step that could be taken to reduce sulfur
emissions. Current thinking tells us that a coal washing program,
using the best available technology, could achieve sulfur
reductions of between 10 and 20 percent. By requiring coal
washing on a national level, it becomes a cost-effective means to
reduce emission levels.

Certainly there are clean coals available and such a require-
ment should not be imposed on low sulfur coal. However, much
of the coal available in the East, the area adversely affected by
acid precipitation, is not low in sulfur and coal washing could
help achieve both a cleaner and more efficient fuel source.
We are well aware that some states are taking steps to
require coal washing, however, if we are to achieve national objectives
and continue our efforts to protect the environment, it is important
that the requirement that utilities burn cleaned or clean coal be
made on a national level.
C.	Legislative Action
The states and EPA should join together in a request to
Congress to amend the Clean Air Act so as to require emission
limitations on existing sources capable of emitting significant
amounts of sulfur dioxide and nitrogen oxides especially from
tal1 stacks.
1.	Administrative procedures as in "A" above may be challenged
by legal action, thus a change in the Act would provide for relief
from such a challenge.
2.	Congress would be recognizing equity of control measures
and inequity caused by current SIP process.
3.	Other transported pollutants also could be addressed in this
manner - ozone, fine particles, etc.
4.	Justification for changes could be developed by a joint
EPA-state technical committee.
5.	Industry should be asked to participate in developing this
reform approach.
D.	Alternative Legislative Action
Concurrently with "C" above consideration should be given
by Congress to require all existing power plants to be retrofitted
to be consistent with national emission limits within a reasonable
number of years so as to achieve an emissions reduction of
pollutants on a nationwide basis.
E.	Monitoring Program
As the nation becomes more and more dependent upon coal as a
fuel, it is important that we have information on the amount of
sulfur dioxide and nitrogen oxides actually emitted from power
plants. Therefore each coal-fired power plant should be required
to install continuous in-stack monitors to provide the
operators with up-to-the-minute information on plant emissions.

Such a system allows utilities to exercise much more effective
control on their day-to-day plant operations. Monitoring
systems utilizing high speed computer technology are now
available and can easily provide the information necessary
to completely monitor emissions.
F. National Consistency
To assure consistency of actions among EPA Regions, the
Administrator should establish a National Consistency Review
Council (NCRC) which will act as an appeals board and report
its recommendations to the Administrator.
The NCRC would be made up of one member from each EPA
Regional area with the members representing EPA Regional
Administrators, State Air Pollution Administrators, elected
officials, industry and commerce, and the environmental
public. This committee of ten would review requests where there
is a feeling that inequitable and inconsistent treatment has
taken place.
As an alternative (or interim measure) to this proposal,
the National Air Quality Commission, which is already established
and functioning could be given additional responsibilities to
act as a consistency board.
If the United States is to reduce its dependence on foreign
suppliers of oil, it is important that we look towards fuller
utilization of one of this Country's most abundant resources --
coal. With coal conversion comes the serious threat of extensive
environmental degradation. Therefore, it is important that we
ensure that when coal conversions take place, they be done
properly and that cert ain areas of the country are not adversely
impacted over others.
Recently the Administrations oil backout program, the
Power Plant Fuel Conservation Act of 1980 was introduced in
Congress. Contained in this legislation, as been proposed, is
the requirement that 50 plants nationwide convert to coal. This
imposes an additional burden on the states which are already most
severely impacted by transported pollutants. Also this imposes
an additional burden on the states which are currently experiencing
widespread violations of the national ambient air quality standards
for TSP unless the conversion to coal can be accomplished without
further increasing pollutant trans port and subsequent exacerbations
of these violations.

Clearly, this effort will require that strict environmental
safeguards be followed. The cost of these safeguards will be
staggering. We are prepared tn follow these requirements once
they are developed. However, before we can completely support
such tremendous effort, we must be assured that efforts to
protect the environment will also be required in other parts of
the country now heavily dependent on coal.
We also feel that the amount of money which has been targeted
in the legislation for environmental protection, $400 million, is
not sufficient to significantly address the problem and that
the amount should be substantially increased.
Certainly coal conversion represents both a great need as
well as a serious threat to the United States. Therefore, a
complete impact analysis must be done before coal conversion
can be required on a large scale. This impact analysis should
not only assess the environmental impacts of large scale coal
conversions, but should look at all other impact associated with
these changes. Without addressing such factors as availability
of fuel, price of fuel, cost of conversions, type of technology
required to properly burn the fuel, and current costs of
electricity, it is impossible to require one region of the country
to make major changes and comply with strict environmental
criteria without addressing the same requirements in another region.
To ensure that appropriate environmental safeguards are
implemented simultaneously with the oil back-out legislation,
Congress should amend the law as recommended in accordance
with items C through F above.
Under no circumstances should our recommendation be construed
as a request for additional ambient air quality standards -- especially
for pollutants transported long distances. This would only add
to the control inequity now being experienced throughout the

• 0 H_Vvi	t. ^ . -,vy .]¦ :.	*
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Now some of the measures that the STAPPA committee considered for
immediate viability would be: first, coal washing. I heard Carl Beard
mention that coal washing is already used at some of the plants. That
is true, but coal washing is not used at all facilities. It is not used
for all major coal that is being produced. It would have some impact on
the total loading of sulfur dioxide into the atmosphere. It could be
considered as a reasonable emission control measure, and from what I
have heard, the cost factors are such that it would not be as expensive
as some other things that might be considered. At this time, the
STAPPA committee did not feel it could presume to suggest a cut-off
level below which coal should not be washed. I don't think we (STAPPA)
have enough information to consider that level. I think that would best
be considered jointly by an EPA/STAPPA committee, in cooperation with
both the producers and users of coal. As stated in the resolution,
economic incentives such as early tax writeoffs, would help sell this
concept. Tax writeoffs for coal washing may be an entirely new approach,
because coal washing benefits the coal and the IRS looks askance at
trying to give a tax write-off for that. But, maybe we could get Congress
to change their minds.
While EPA is developing regulations under 111(d) and Congress is
considering the Act, the STAPPA Committee also recommends that the
States look into the possibility of requiring coal washing on a voluntary
basis, over and above any SIP requirement. The States would need some
guidance as to cutoff requirements but, in general, I think we might be
able to move faster than EPA and Congress. If the coal producing States
were to lead the way in coal washing, I am confident the other States
would very readily fall in line; I know New York would.

There is another advantage to coal washing that has nothing to do
with the long-range transport of pollutants, but has to do with the
possiblity of helping to control particulate emissions for the secondary
pollutant problem. Some areas of the country do not meet the secondary
standard for total suspended particulates. If coal washing were considered
by EPA as reasonably available control technology for power plants
towards meeting the secondary standard, then this would help in those
areas which currently do not meet the secondary standard where we have
coal-fired power plants that are using coal that is not washed.
We have been mentioning the SIP requirements here, and I have heard
Dave Hawkins mention SIP requirements a number of times this morning.
It is my opinion, and it is not necessarily the opinion of STAPPA (I
want to emphasize that, because I did not clear this with the committee)
but it is my opinion that the SIP process has not been completely success-
ful. I think a lot of people would agree with that. Change is needed.
Control of existing sources on an equitable basis, without worrying
about developing SIPs and meeting ambient standards would be a better
way of deploying our very limited technical resources.
Air quality was improving before we had ambient standards and SIPs.
If you recall the New Jersey presentation, and if you looked at the
chart, you could see, for example, that there was a tremendous reduction
in sulfur dioxide before 1970 on that chart. More than half of that 85%
reduction that they were talking about was achieved well before 1970 and
well before 1971 or 72, when SIPs came into being. Air quality, as I
said, was improving then and it will continue to improve if we utilize
best technology for new sources and reasonable technology for existing

We, in New York, believe that any new ambient standards would lead
to more inequity and more paper shuffling. Because of that, and to
provide for input from the States not represented in the STAPPA Long-
Range Transport Committee, a State's position was also developed in the
past two days for your consideration. This position, hopefully, has
been given to every State, and if any State has not received a copy of
"A National Policy on Acid Deposition and Regional Consistency - State
Proposal" presented April 9, 1980, Springfield, Virginia see Peter
Fairchild and get a copy. I am going to quickly again summarize what
this document says.
What we are saying, at the very beginning, is that the official
representatives from the States listed at the end of this document agree
with the substance of the discussion and the recommendations which
follow. This is not a commitment of the Governors. It is not a commitment
by those who signed to every single word. What it is is an agreement in
the principles that are involved. We have a number of proposed programs,
basically divided into six elements: (1) the administrative and regulatory
action under 111(d) of the Clean Air Act; (2) the requirments for coal
washing; (3) legislative action to amend the Act to require national
emission limits for existing sources; (4) a retrofit of existing plants
to meet those national emission limits (that is rather redundant because
if you have national emission limits for existing sources, the retrofit
is implied anyhow); (5) a nationwide emissions monitoring program
primarily from the coal-fired power plants; and (6) national consistency
of action among EPA regions.

How do you achieve all these things? One way to achieve the regulatory
changes is to consider implementing the program in collaboration with
the oil backout legislation, the coal conversion requirements. We are
going to be converting to coal in the Northeast. Some 50 plants are
supposed to convert to coal, and 42 of these are along the East Coast of
the United States. I am not sure where the others are located, but at
least 42 are in the Eastern United States. If we are going to convert
to coal, we need some relief from the total sulfur that is being emitted
to the atmosphere. Some of these provisions would help provide for that
relief. By incorporating these changes in the President's bill or
simultaneously with the President's bill on oil backout legislation, we
could get the necessary changes that we need to make the Clean Air Act
work for us without completely opening the Clean Air Act for revision at
this time. In the interest of time, and so that we can get back on
schedule, we will save any discussion on this and I won't go on any
further until the discussion period. Thank you.
Mr. Hawkins: Thank you Bud. Dan Goodwin will be next.
Mr. Goodwin: Good morning, my name is Dan Goodwin. I am head of the
air pollution division of the Illinois Environmental Protection Agency
and my task here today is to try to present to you the acid rain problem
as viewed from the perspective of a coal State.
I would like to start by saying that I bring you greetings from
Illinois, a net exporter of corn and soybeans, coal, manufacturing jobs,
sulfur dioxide, and I am tempted to say electricity, but I have not
checked the figures on that. We may not be an exporter of electricity.
I would also like to start by saying that the entire State of Illinois

is in attainment of the national ambient air quality standards for
sulfur dioxide. With those two statements, those of you who have political
inclinations can probably figure out what the rest of my speech is going
to say.
I want to touch on five subjects. First, how we see the environmental
problem, how we see the political problem, some problems that we see
with a few of the suggested solutions, some elements of an ideal national
strategy on acid rain, and what we see as the next immediate steps that
are to be taken.
I think sufficient evidence exists that there are real problems due
to acid rain in the Northeast to warrant action. I will start today
from the point of departure that we are also going to accept that reduction
in total SCL and NO emissions loading in the Eastern part of the United
&	X
States is a rational first step in dealing with that problem. Nevertheless,
I think it is also important for you to note that neither the acid lake
problem nor the sulfate particulate formation problem has been observed
in Illinois. I think that being the case, it is going to be very difficult
to get the attention of the legislators and others at the State level to
the problem unless we approach it properly.
Let me turn to the political problem. Any regulatory action that
is perceived or portrayed by the coal industry or the electric utilities
as anti-coal will be politically difficult to accomplish in Illinois.
This will be true regardless of how convinced the environmental regulatory
agencies are of the need for regulatory action or the harmlessness of
any proposed action to coal interests. Whatever hope there may be for
successfully instituting new regulations on the use of coal lies in

convincing the coal industry that its economic interests will be well
served by such regulation.
The coal industry in Illinois !,as political influence far dispropor-
tionate to its size and overall economic importance. Working in the
mines is woven into the social fabric of the community of large areas of
Illinois, particularly in the Southern part of the State. Southern
Illinois and coal mining are concepts that are as closely identified
with one another as Cape Cod and fishing, or Maine and potato farming.
The United Mine Workers and the coal operators rarely agree on
things but they do consider further environmental regulations a serious
threat to their economic well being. Together they represent a powerful
Most coal mines in Illinois lie far from the major industrial
centers where air pollution is a highly visible problem. In terms of
citizen awareness of air pollution, it is farther from Chicago to Carbondale
than it is from Chicago to Lake Placid. Historically, legislators from
the Southern Illinois coal fields have possessed clout in the legislature
well beyond what would be expected from their numbers. With the apparent
demise of the Chicago Democratic Organization, that clout is likely to
The coal industry and the electric utilities both have long traditions
of resisting environmental regulations, and it seems reasonable to
expect them to continue in that tradition. Virtually any regulatory
action that is proposed to mitigate acid rain or sulfate formation is
likely to be perceived as having an adverse effect on either coal or the
utilities or both, whether the impact is really negative or not. This

picture will be complicated by differences in interests in owners of
high sulfur coal reserves and low sulfur coal reserves, and between
utilities who have large fractions of their generating capacity presently
burning high sulfur coal and those who do not. In other words, we
cannot necessarily assume that all members of the industry will perceive
their interests to lie in the same direction.
There is another increasingly important source of resistance to the
kinds of measures being discussed here today, namely, the citizen activist
groups who have recently emerged in Illinois as vocal and effective
spokesmen against the utility rate increases before the Illinois Commerce
Commission. These groups describe themselves as representing the interests
of residential electric customers, especially the senior citizens and
poor people. Rate increases that would have been granted almost auto-
matically five years ago are today being thoroughly challenged and
carefully scrutinized. One can no longer assume that cost increases for
the utilities will be fully passed through to their customers. In fact,
there is serious discussion in Illinois of abolishing the fuel adjustment
clause, which allows automatic pass through of fuel price inceases by
In Illinois there is little likelihood that a strong effective acid
rain lobby will come into existence in the near future. Most Illinois
envionmental groups including the Chicago Lung Association and Citizens
for a Better Environment have worked hard in recent years to portray
themselves as not being anti-coal. Their principal theme has been human
health protection. Unless acid rain or sulfate formation emerges as a
more serious and immediate threat in Illinois, it does not appear probable

that groups such as these will become highly visible in pushing for new
regulations on Illinois coal. National environmental groups such as the
National Resources Defense Council and the Environmental Defense Fund,
should they become active at the State level in Illinois would most
likely be regarded as carpetbaggers and probably do their cause more
harm than good.
I will add to all that, that in the Illinois State Government, I am
probably the greatest friend people who want a solution to the acid rain
problem have. My purpose is to try to help you understand the realities
that my agency or anybody in Illinois who is going to push for more
regulation on coal and on the electric utilities is going to be up
against in securing that at the State level.
Now I would like to talk a little bit about some of the problems
that I see with a few of the suggested solutions that have been discussed.
First, the cause/effect relationships between SOg and N0X emissions
and acid precipitation are not well understood. Because of this it is
not clear that any particular proposed remedy will be beneficial or
cost-effective. No short-term solution to this problem seems available
but there must be adequate long-term research done. I think the commitment
the U.S. EPA received from the President goes a long way in that direction.
In the short-term, I believe we must concentrate on remedies that are
low in cost, or low in risk, and that can be shown to be cost-effective
in terms of total emission reductions.
Next, problems with coal washing. I think the benefit that may be
available from a universal coal washing policy are more perceived than
real. In Illinois, roughly 90% of the coal now being burned is washed.

It is less than 1.8 pounds SO2 per million Btu, that is low sulfur
(mostly Western) or is scrubbed. I think before we jump on the coal
washing band wagon we need to do a survey to determine whether or not it
is really going to gain us enough emission reductions nationally to be
worth the debate that is likely to be generated by any mandatory policy.
Washing may be technologically difficult in water-short areas, particularly
in the West. Yet if coal washing is not to be a policy that is extended
throughout the country, particularly into the low sulfur western coal
mines, it is going to be difficult politically to get acceptance of the
policy in Illinois which is a State that finds itself particularly
vulnerable to inroads by western coal. There has to be maintained some
kind of economic equity for high sulfur versus low sulfur coal in this
In addition, coal washing can create water pollution problems that
in some instances are not that easily solved. In most cases, you can
solve the problem but we have encountered some places where there really
is not any place that is very sound to put the water that you must
dispose of.
It is argued that the nonair quality benefits of coal washing may
justify its use. I think the first response I am going to hear from
this back home is: "Well if that is true, why do we need a regulation?
Maybe all we need is better education of the coal users." Frankly, I
have no response for that question.
Moving to the idea of a cap on total SOg emissions. I think a cap
°n SO2 emissions at their present levels would offer a serious problem
of inequity among the States or substate areas or individual sources if

the cap is applied on that scale as opposed to a multistate or national
scale. Areas which are now in overcompliance with their SIP emission
levels would lose their growth capacity while those who can achieve
emissions reductions below their present levels by the simple expedient
of coal washing would get a very cheap margin of growth by doing that.
On the other hand, if we are going to try to apply a total emissions cap
on a multistate or national scale there is going to be a difficult
problem of how you allocate whatever growth margin you provide in that
arrangement. I have serious doubts that that can be done without either
Federal legislation or an interstate compact neither of which is likely
to come very quickly.
One version of an emissions cap, that I have not heard discussed
and I think might deserve further exploration, is a cap on emissions per
kilowatt hour generated, applied to the utilities on a system-wide
basis, with ample provisions for controlled trading among the utilities,
so that they can buy power from each other within the limitations of
their caps in order to meet their load demands.
Now, some elements of an ideal national strategy, and this is from
the perspective of Illinois. The ideal strategy must advance the interests
of the affected segments of the coal industry. It must not provide
further opportunity for inroads by western coal into traditional Midwestern
and Appalacian coal markets. It must open up new markets for high
sulfur coal such as displacement of oil and natural gas in the Northeast.
It must allow pass through of cost increases to the customers. It must
create new jobs in the coal fields, or at least pose no threat to existing

The ideal strategy must be acceptable to the electric utilities
including those who will not benefit from the oil backout program. They
must be able to pass cost increases through to their customers with a
high degree of certainty. Rate increases for industrial customers must
assume a relatively uniform national pattern in order not to further
displace existing industry from the Midwest and Northeast to the sun
belt. Each utility's ability to acquire adequate increases in generating
capacity must be guaranteed. The ability of each utility to finance
additional control equipment must be assured. With today's interest
rates and with the capital formation requirements that are already on
the utilities, that is an important issue. These financial costs must
be included in the rate base.
The ideal strategy must minimize the impact on industry other than
the coal and the electric utilities in order to keep them uninyolved
politically. To do that the electric rate increases resulting from the
strategy must be small and must be equitably distributed.
industrial boilers should not be included In the new control require-
ments. The ability of each economic region to accommodate industrial
growth must be retained.
The ideal strategy must not pose the prospect of large utility cost
Increases for residential customers. Active opposition by old people
and poor people villi be the death knell in Illinois should that occur.
Now, to the extent that we can devise an add rain strategy or a
total emissions reductions strategy that meets all those requirements or
comes close to them, I think we will have something that will "play in
Peoria." To the extent that we are unable to do that, it will be difficult.

I want to thank you for setting me up for the last section of my
comments, which concern what we should do over the short-term, because I
think that is where we ought to be focussing our attention today. On
the assumption that the long-term problem is going to require amendments
to Clean Air Act which are not likely to come for at least a couple of
years, I think that the first thing we need is a call to responsible
action by the States from the President. I think we can be led, speaking
for the States. I do not think we have to be coerced. We need Federal
leadership, coordination, and technical assistance. But, we do not have
to be bludgeoned into action. I think it is important that the President
stop equivocating. If acid rain is the serious problem that he has said
he believes it to be, I think he must make some forthright statements as
to what kinds of actions the States should be taking today or in the
next few months to deal with it while the Congress is considering the
legislation needed for a long-term solution to the problem. I also
think the President needs to make a definitive statement of how contemplated
solutions to the acid rain problem relate to the oil backout policy.
Secondly, I see a need for immediate joint action by U.S. EPA and
the Department of Energy to study the potential short-term emission
reductions that may be available from greater use of washing for currently
unwashed coal, and use of improved washing techniques for currently
washed coal. This needs to be done plant-by-plant for all the utilities
in the East and it ought to be done in the next six months. I think U.S.
EPA and DOE need to do more evaluation quickly of the two nonstructural
alternatives that were mentioned but not really fully discussed yesterday,
namely, least emissions load dispatching and accelerated retirement of

high emission facilities. I think both of these concepts offer the
prospect of significant emission reductions at little risk and small cost
over the short-term.
Third, immediate steps need to be taken to shorten the lead time to
obtain permits and licenses for new relatively clean facilities. More
and more, I am hearing that the emerging PSD regulations are inevitably
going to place the PSD permit process on the critical path for new coal-
fired power plants that are currently in the planning stages. To the
extent that this is the case, they stand as an obstacle to replacing old high
emissions capacity with new low emissions capacity, and I think we could
do a better job on that if we work at it.
Fourth, and please forgive me for stepping on toes, I know I am
going to do it with this topic, we have got to break the paralysis that
grips the nuclear regulatory licensing process. I think this is an
important point, whether or not you believe there should be further
investments in nuclear capacitity in this country. We have a large
number of nuclear units under construction now, and the NRC operating
license process is rapidly becoming the obstacle to getting those units
in service. One of the things that came out of the OBERS study was a
collective opinion that, looking at the total fuel cycle, there is greater
risk of premature death as a result of the coal fuel cycle than of the
uranium fuel cycle. I think it is time for us to be realistic. I am
not saying we should take any shortcuts on nuclear licensing but let's
speed it up. It can be speeded up.
Finally, I would just like to speak to the proposal that Bud Hovey
suggested and some of the other States have endorsed that we use 111(d)

authority to initiate a Federal program on acid rain. Illinois cannot
endorse this at this time. I doubt that we ever will. I think we lack
the technical basis for setting such standards, I do not think that
authority is well suited to the purpose, and if we select that course of
action, we will inevitably get tangled in two or three or four years of
litigation. That will stand as an obstacle to actions that could be
taken that will produce results much sooner than that. Nevertheless, I
think joint cooperative efforts by the States are the way to go while we
are waiting for Federal authority, and Illinois stands ready to cooperate
in developing a national strategy. Thank you.
Mr. Hawkins: Now we have Dr. Craig Weidensaul from Ohio to make a
presentation between now and 11:30. Thank you.
Dr. Craig Weidensaul: Good morning. I would like to express my appre-
ciation and that of our delegation from Ohio for having the opportunity
to meet with you and gain the benefit of your experiences and for having
the opportunity to address you. I approach this with rather mixed
emotions--they are the same as watching your mother-in-law drive off the
cliff in your new Cadillac. We had a problem deciding who was going to
perform this task this morning. Someone suggested our illustrious
football coach or exfootball coach at Ohio State but we felt that would
jeopardize the well-being of people with cameras. So I guess I am a
little less objectionable. You may feel otherwise. I am not a politician
and, therefore, do not need votes. I am not a political appointee so I
can say anything I like.
I am the Director of the Laboratory for Environmental Studies at
the Ohio Agricultural Research and Development Center and hold academic

appointments in both forestry and plant pathology. Like Ellis Cowling
and Jim Galloway and some of the others, I am a researcher and have been
studying, for the past 10 or 12 years, the effects of gaseous and metallic
pollutants, be they in air or in soil, on plants and plant metabolism.
I became actively involved in the acid rain discussions and have been
active in the National Atmospheric Deposition Program since its inception
a couple of years ago. I am, I think, very familiar with the literature
on the effects of acid precipitation and related phenomena. I have
had the good opportunity of working with Jim Galloway and others in
authoring sections of the Academy of Science's document on sulfur oxides.
That gave me a chance to refresh my memory relative to published accounts
involving not only gaseous pollutant effects per se, but those acid
gases in combination with atmospheric moisture.
Today, I wear a hat not only of an objective researcher, but also
the hat of the representative of the Governor of Ohio. In speaking to
the subject of controlling acid rain from a State's perspective, I would
like to preface my remarks by saying I hope when we are talking about
control that we are not advocating complete elimination because as Ellis
Cowling and Jim Galloway stated so eloquently yesterday, there are some
very beneficial effects of precipitation components. On the other hand,
there are some things of concern to us when acidity or any other component
is in excess quantity. Let's not indict a compound simply because it is
what it is, but only when it appears in excess amounts. We have not
experienced or observed adverse effects of precipitation acidity as far
as we know on soils and agricultural or forest crops in the State of
Ohio, also, unlike other States, we do have the attention of the Governor
and of our Legislature.

Ohio's efforts to control sulfur oxide emissions begin with the
identification of what we hope are the real problems, not imagined
problems. We then rigorously scrutinize published accounts, support
research, recommend alternative courses of action, and implement control
strategies and technologies. I might say that Ohio is the first State,
and as far as I know the only State in the United States, to form and
support a Scientific Advisory Task Force on the subject of acid rain.
This does not serve a political function. It is a task force of which I
have the distinction of being Chairman, appointed by the Governor, to
objectively assess the importance of the acid rain problem.
Secondly, Ohio is the first and only State to introduce a mandatory
coal-washing bill. This legislation would require that all coal used for
steam generation (that is called electric power generation) in Ohio
would be washed. This bill is expected to pass the Ohio Senate shortly.
In the case of Ohio, we feel that this is a practical and advisable
procedure to follow especially considering our geographic location, the
sulfur levels present in coal, and the availability of washing water.
Thirdly, Ohio is the first State to fund from its own budget a
fluidized bed boiler at a State facility.
Fourth, Ohio has been involved in the National Atmospheric Deposition
Program since its inception, and I would like to think we were somewhat
influential in its being sponsored by the Northcentral States Agricultural
Experiment Stations. There are presently three deposition monitoring
sites in the State of Ohio, one operated by the United States Department
of Agriculture, Forest Service, and the other two by the Agricultural
Experiment Station in Ohio. I anticipate that within the next year there

will be probably at least three more, possibly more. At this point, I
would like to echo Dr. Cowling's request for the participation of additional
States in this monitoring effort. I am still one of those people who
believes that, at least from a research standpoint, conclusions can only
be legitimately drawn from conclusive data, and presently our network,
although functioning and running smoothly, is deficient in monitoring
sites at strategic locations. We need sites and we need monitoring
equipment in different sections of the United States where they presently
do not exist.
I would like to compliment yesterday's speakers particularly those
who addressed the subjects of meteorology, transport, and effects
because what you were subjected to in a few one-hour doses--each one of
those presentations really could take at least a day to cover adequately.
I think the speakers did an excellent job. We must be very careful to
separate known facts or areas about which we have conclusive knowledge
from those we know are either fictitious or must yet be determined.
In addition to certain recognized and accepted adverse effects,
rain acidity has been given much credit (or blame) recently for phenomena
that cannot possibly be associated with rain or that have not yet even
been investigated. I disagree that this "problem" is of very recent
origin. Sometimes problems surface simultaneously with our particular
interests and our ability to detect them, and as you saw yesterday the
problem has existed in Scandinavia for quite a number of years. I
sincerely doubt if the situation is much different here in the United

We cannot safely or legitimately extrapolate real-world effects
from rainbucket research. Mr. Robinson indicated yesterday the difficulty
in associating real-world phenomena relative to terrestrial ecosystems
with the suspected causes, i.e., precipitation quality. There have been
laboratory studies conducted around the world, many of which have involved
simulated rain (in the common vernacular that is called dilute acid; it
is acidified distilled water). This is not rain. The reactions that
normally occur in rainwater do not occur because many of the cations and
anions are not present. Researchers in the artificial version now
realize this and more and more, normal components of rain are added to
the solution or natural rain is acidified to get a little better perspec-
tive of what might occur in nature. Also, many of the studies with
simulated rain involve continued or repeated exposure to given concentra-
tions of acid and this is not the way the situation exists in the real
world. During a rain event, particularly after a dry period, the initial
part of that event can often be quite acidic, but becomes less acidic as
the acid gases are scrubbed from the atmosphere.
I think we have to be very careful in drawing conclusions from
field and laboratory research at this point. There is a lot of informa-
tion we really do not have. My next statement is not made to frustrate
you, but having reviewed the literature for months and months, there are
presently few to absolutely no published accounts, in the literature
available to the public, that can withstand rigorous scientific scrutiny
which demonstrate significant deleterious effects on terrestrial vegeta-
tion, either in terms of visible injury or reduced yield of food and
fiber crops as a result of naturally occurring precipitation. A

combination of distinctive voids in scientific information along with
public concern generated—in part, by poorly documented and often miscon-
strued information--point out a need to objectively, carefully, and
methodically research the nature, distribution, and effects of materials
in precipitation. I commend the President and the Environmental Protection
Agency for placing research emphasis in this area and for placing it
high on their list of priorities.
The United States faces a severe energy problem, both from concerns
of availability and cost as well as possible environmental insults.
Until the breeder reactor is perfected, and I should add, accepted, our
increasing energy demands, particularly those for electricity, can only
be met by using coal. Eighty-two percent of this country's energy reserves
is in the form of coal which supplies only 18 percent of our energy
needs. Ohio is an exporter of electricity. As a matter of fact, 14
percent of all the electricity generated in Ohio in a given year is
exported to other States.
We have a problem in Ohio. We have the dubious distinction of
having coal with some of the highest sulfur levels of any in the country.
Be that as it may, electricity is generated where fossil fuel reserves
are located, generally due to the cost of transportation of fuel. Power
generation is also dependent on the location of cooling water and, as
we are soon going to experience, coal-washing water. Power plant siting
is also dependent on the feasibility and costs of electricity distribution
to consumers.
r think I have adequately indicated to you at the outset that we
recognize the sulfur problem and are willing to pitch in and help solve

it. We are taking steps now to do that. We need environmentally acceptable
ways to utilize coal. Coal does cause problems and there is no doubt
about that, but it also offers opportunities.
One would be quite naive to suggest or a'dvocate ambient air quality
and emission standards that would, even if they were effective, eliminate
all risks to all populations, and by populations I include humans as
well as terrestrial and aquatic plants and animals. The cost/benefit
ratio would be staggering in terms of control equipment, capital investments
and operations costs of we advocated near-zero levels. One alternative
is simply to reduce our gluttonous use and misuse of energy. Similarly,
we cannot permit irreversible adverse effects to our many environments
and ecosystems. There is a happy medium and our wildest expectations
and desires must be tempered, I am afraid, with moderation. Identifying
and solving any environmental problem associated with precipitation
quality will take time just as perfection of open heart surgery techniques
took time. We must not be like the Indian chief in the movies who
mounted his horse and "rode off simultaneously in all directions." We
will not be any closer to solving our problem nor taking advantage of
our opportunities if we leap at real and/or imaginary problems with
shrieks of frenzy and tear-jerking testimonials. This does not get us
anywhere. Let's identify our problems, sort out the real ones, design a
sensible course of action, and deal with the situation step-by-step and
by all means, let's get on with it. Talk is cheap, but good conscientious
work speaks for itself. I thank you.
Mr. Hawkins: Thank you, Dr. Weidensaul. Those of the participants who
want to make remarks, I think in the interest of being able to have the

maximum number of people talk we would like to try to adhere to a rule
of shortness of statement. At the outside I will be telling people when
they have been going on for more than five minutes, and I hope that will
be the outside. There is not going to be any order of presentation and
I will try to be fair in recognizing individuals. The gentleman from
Indiana, first, Mr. Strazino.
Mr. Strazino: I just wanted to second what Illinois and Ohio said. I
think that goes for Indiana too.
Bob Flacke from New York: We have been very pleased both yesterday and
today to see that there is some consensus. . . We have been very pleased
to listen to the scientific and academic community rationally point out
that the evidence and data that is available in today's scientific and
academic community makes us all realize that acid deposition is a genuine
problem. I think that there is basic concurrence that there is a necessity
to continue to study the problem. However, the role that was outlined
this morning by Ohio and Illinois does give some credence to the fact
that we in the Northeast and in the Midwest sit at opposite poles. It
is very difficult for people in the Northeast to understand the Land of
Oz-like attitude, if I may describe it as such, that the political
realities in the Midwest will only result in agreement on national
policies connected with acid deposition, if they satisfy a criteria that
lists things that are only good for that particular State or that particular
region. We are facing a crisis situation in the country economically
and environmentally in that we have a great desire to assume the use of
coal in this country in an environmentally sound manner. It is no secret
at all that the Federal government has pinpointed a great majority of

the power plants in the Northeast for coal conversion. In order for us
to successfully go through a process that will use the Northeast's
money, the Northeast's time, the Northeast's effort in the process of
conversion, it must be done in an environmentally sound manner. The
Northeast can only accept the fact that there is acid deposition that
adversely affects it, and that the rules of the game that we have been
using for the past few years are no longer acceptable for the future.
The way we have been administering and managing those rules are no
longer acceptable for the future. So we as a group of States in the
Northeast urge those in the Midwest to join with us in a serious discussion
about how we are going to resolve this very difficult problem. We
offer, as our suggestion for your consideration, that basic six-point
program that Bud Hovey mentioned. Let's not take two or three years to
determine whether or not the Environmental Protection Agency can or
should have the authority to do something under 111(d). Let's do it.
Let's find out if our brothers in the Midwest will contest that in
court. We believe that some immediate administrative action should be
taken. Let's have a national coal-washing policy. Let's begin immediately
to take a look at the Clean Air Act and go back to something that has
been proven long before the establishment of the Clean Air Act. That
some type of point source control that will limit sulfur and nitrate
emissions into the air are not only necessary but are a proven method of
solving the acid deposition problem. Along with that let's establish
and use part of that money for a national monitoring system. Last, but
not least, let's ask the Environmental Protection Agency to establish
some consistency among the Regions so that we do not have to consider

when we discuss with our brother or sister States the fact that EPA
Region V does it this way, or EPA Region 1 does it that way, or EPA
Region II does it this way. Then we find out that it takes, for example,
several months for a review process in Region II for a special limitation,
but during that time several special limitations surface and are approved
in another Region. I think we need an action program. I think that the
action program presented by the coalition that Bud Hovey presented this
morning is good, workable, and should be accepted by the Environmental
Protection Agency as their program. I hope that they will respond to it
in a short period of time.
Mr. Hawkins: Thank you, Bob. I will not make a practice of interjecting
my own remarks after each speaker, but I would want to offer one point
for Bob. One of the things that I heard Dan Goodwin saying was, if you
who are sitting around the table, want a program which will get political
acceptability in Illinois, here are some of the obstacles that must be
overcome. He talked about an ideal strategy and I think he used the
word ideal, recognizing that whatever strategy we come up with is going
to represent a departure from the ideal in a number of respects. I
think what Dan and others from the coal-producing States would be interested
in hearing is discussions of the extent to which some of those political
obstacles can be overcome.
Tony Cortese, Environmental Commissioner, Massachusetts: I would like
to suggest several things. First of all, I agree with Dr. Weidensaul
that we would like to have conclusive evidence before we take action.
But my biggest concern is if we wait for conclusive evidence, the effects
°iay be irreversible. We want to burn coal in Massachusetts; we want to

burn coal in New England; we are burning coal in Massachusetts, but we
are doing it with what we call high sulfur coal, which is one and a half
percent sulfur. I say that half jokingly because up in Region I we talk
about that as high sulfur coal and it compares to the four to six percent
sulfur coal that is used in other areas of the country. I would hope
that, as States, we can try to get together on this problem and do
something about it right now. The obstacles that Dan Goodwin has laid
out are there and they are real. Let's do something about them. I
would like to make the following suggestions about those kinds of things.
First of all, it does not bother me to see that if we are going to push
for a national coal policy that there should be some way of incorporating
into the rate setting for electric utility rates the cost of pollution
controls. If we were to do that, I think that is one of the major
obstacles to the use of locally available coal because you want, in the
Midwest, to use your own coal and I do not blame you for that. You want
to keep the jobs in your own State. The major obstacles there are two
things: 1) you need a law that prevents the utility industries from
burning low sulfur western coal, and whether that has to be a national
law or whether it can be a State law I am not exactly sure, but we have
the opportunity to put that in the oil backout legislation; 2) you need a
law which may be either Federal or State which changes the rate structure
for utilities such that pollution control equipment can be added right
into the rate structure. The reason that I suggest these two options is
this. We have some calculations, and I can show you the data, which
indicate that our cost of electricity in New England will still be
higher, even if you apply the best available control technology to the

use of high sulfur coal in the Midwest, ours will still be higher. Our
cost of oil, 1 percent oil, 1/2 percent oil, is in the area of $30 to 34
per barrel. The cost of 1 1/2 percent coal in New England is the equivalent
of $14.50 per barrel. The coal that you are burning in the Midwestern
States is at a cost of $7 to 8 per barrel. That is four to five times
lower than what we are paying in the Northeast. My point is this, even
if you apply the best available control technology to the coal that is
being burned right now, your electrical costs will still be lower than
they are in the Northeast. We are bearing those costs now and we are
receiving the environmental damage from the increased emissions, the
sins of omissions and emissions as was pointed out yesterday. I think
the major obstacles, really, are how can we get around the issue of low
sulfur Western coal and how can we get around the issue of burning oil
and high sulfur coal. I submit that the two major impediments can be
solved with either changes to the oil backout legislation or State laws
which would change the rate setting and would also apply the use of
locally available coal.
Will Brown, New Hampshire, Acting Chairman, Water Pollution Agency: I
would like to endorse, without repeating, the comments made by our
colleagues from New York and Massachusetts. What I really want to do is
add some additional thoughts. One is that Commissioner English from New
Jersey did us a great favor. She got us out of the unenviable status of
being a wearer of a white hat this morning by showing on her map that
New Hampshire was the wrong color in the midst of that whole New England
area, thanks to using per capita figures and thanks to the fact that we
do have a coal burning plant in New Hampohire. I do not believe they

are washing the coal at the present time. We only have an electrostatic
precipitator which works occasionally. What I wanted to comment on
specifically was the contention made by our good friends from around the
Great Lakes that we lack adequate data on damage. If the change in the
pH of the lakes over a 40-year period of record is important, we have
some such data. We are aware that the Fish and Game Department did
extensive measurements back in the late 30's in many of our lakes at
various stratified levels. In anticipation of this meeting, our staff
was able to take a dozen of those lakes where such data is available and
get current data and compare them. Practically all the data in the late
30's showed lake readings above 6 pH, in every case at the surface
level. There were two lakes where it dropped into the 5 to 6 range
below the surface. In every single case at every level, the pH has
dropped substantially over that period. I suspect that, though we do
not have the interim data to show it, that is a relatively recent decline.
I would say, that on the average, it is a decline of anywhere from a
half a pH point to a full pH point or more. I think that is significant.
Now, my question would be. Is there a Branch within EPA where this type
of data from individual States can be received and correlated and put on
a broadscale basis?
Mr. Hawkins: I think that Steve Gage's presentations yesterday, and the
presentations by people on yesterday's program, indicate that we, in
fact, have a variety of research programs that are collecting that kind
of information on the . . . Lowell Smith or someone else might be able
to speak to the way in which that data comes to our attention. But we

do have a variety of active projects where we are continually evaluating
information that does come into the Agency, principally by having these
research projects continue to update information. For example, we have
recently finished some new maps of the United States that will identify
all of the sensitive areas much more comprehensively than before. We
are doing a variety of projects to try to improve the comprehensiveness
of the data base.
Mr. Will Brown: I was thinking particularly of where we have data as
far back for these ponds as 1936, 1937, 1938, That is getting far
enough back so that if you can use it, we could dig it out with the
comparative data for the last few years that a large number of additions
are on.
Mr. Hawkins: The ORD representatives are nodding vigorously, so I will
put you in touch with Lowell Smith. I thought I saw Dennis Tirpak's
hand up there, but it has now gone down. Do you want to say anything, Dennis?
Mr. Dennis Tirpak: Comments could not be heard. Mr. Hawkins: I will
repeat that. The Research Office of EPA will be contacting the States
to find out what information you have, and also to tell you what our
interests are in terms of data, so that you will have an idea of what in
particular we would like to see.
Dr. Craig Weidensaul: I would like to respond to Mr. Brown's statement.
Relative to the fact that it is a matter of record, no mention was made
of a lack of data regarding aquatic ecosystems. The only mention made
relative to a lack of data, relative to decreased fiber in food crop
productivity in terrestrial ecosystems. We all acknowledge that there
a^e harmful effects in poorly buffered lakes with unusual amounts of

acidity. No question about that. We recognize the preponderance of
data over the years, sure.
Mr. Will Brown: Well I commented on the relation between the aquatic
and terrestrial factors yesterday, so I don't think I should repeat
Mr. Hawkins: The gentleman from Wisconsin.
Bob Martini, Wisconsin Department of Natural Resources: I would just
like to make a comment relative to Dan Goodwin's discussion of political
acceptance of the idea of preventing or alleviating the acid rain problem
with some information from our State. You may not be getting very much
in the way of reaction from your public on the acid rain problem. One
of the reasons could be that many of the people from Illinois end up in
our neck of the woods. A lot of these letters are coming into our
Agency and there is quite a lot of support, in fact, more support from
Illinois residents on acid rain than there is from Wisconsin. I would
just like to point out that you shouldn't underestimate the ground swell
of support for protection of our vast resources.
Mr. Hawkins: I suggest that you trade letters. Get your Xerox machine
Dr. Weidensaul: No, I will subside as long as there is interest.
Mr. Carl Beard, West Virginia: I made a comment . . . that I suppose
West Virginia . . . But the matter of coal cleaning is not answered.
One thing that has not been addressed as far as I am concerned is, if
coal cleaning was universally done, how much is that going to improve
quantitatively, the so-called acid deposition problem? How do you

you speak to the economic question, problem one. Problem two, the
people in my State who are not cleaning coal are the little producers.
Where are they going to get the capital ... to do this and not go out
of business . . . ?
Mr. Hawkins: Carl.
Carl: Jim Kilgroe has prepared a paper which we handed out to you with
some of our upperbound estimates on what we think coal cleaning could
get. There are two errata sheets that we distributed during the break
which everybody got, in case you are wondering what the two tables we
handed out are. That is our estimate of what the potential is if you
cleaned it all and you used the best cleaning techniques currently
practiced on all the coal, and it is several million tons. You have to
then discount the parts of it that are not going to be cleanable because
of small producers or other problems. But, that still seems to be
something greater than a million tons, or perhaps two, that is available
from a broader scale uniform high-quality coal washing effort. These
estimates, like all estimates, are imperfect. But, I think in terms of
scale, if we have on the order of 18 or 20 million tons of emissions
from steam electric power plants now (and I forget the fraction that is
coal, but maybe it's 14 or 15 million) you can start to talk about 10
percent maybe as being in the range of reasonableness. I would submit
that any time you talk about a million tons, a nontrivial quantity of
emissions. If in fact you can get it, if in fact after you get the
logical exclusions for the lower sulfur coals, the very lowest, if
that's a logical exclusion* and it may not be, given what Dan was saying
about competition and/or the small producers, which may be a logical

exclusion. It looks to us like it is in that range. So taking those
estimates as just estimates, that is our . . .
Carl Beard: All right, let me respond to that in this way. Three
plants that Jim Hambright discussed, Cammer, Mitchell, and Harrison; all
of Cammer, all of Mitchell at their . . . plants, coal has been washed
for years from the beginning. Now, about 70+ percent of the coal for
the Harrison plant is washed and more of that will be coming on stream
for other purposes, not for SO2 removal because that is Pittsburgh Paint
coal. We have the same problem universally distributed throughout West
Virginia ... a sulfate problem ... He does not have a corner on
this market. But if you say universal washing of coal, what Virginia
stands well . . . because if anybody wants to buy some low sulfur washed
coal, it is available because the miners are out of work. Washed coal
today sitting on the ground cannot be sold. I don't think it is an
answer to the problem if you look at my State. We would be happy to
take that as one step toward solution because we are already there.
Mr. Hawkins: Dan.
Dan Goodwin: I think Carl Beard is reinforcing one of the points I was
trying to make, which is that the emissions reductions that are to be
gained in several of the States as a result of coal washing may be more
than real. In the first place most of the numbers that I have seen
thrown around are based on allowable emissions in the SIP not actual
emissions that are occurring today. In the case of most Illinois utilities,
the actual emissions are substantially less than the allowable if they
are located in a rural area. Now there is another phenomena that is
occurring in Illinois and I am confident in other States as well and

that is this. The coal that is being mined for minemouthed power plants
is getting higher in sulfur as the mine working pace progresses into new
areas. One example of that in Illinois is the Commonwealth Edison
Kincaid Plant just a short distance south of Springfield located adjacent
to what is usually referred to as the largest underground coal mine in
the world. I don't know whether it really is or not, that is what
Peabody says. That coal is washed under an order from the Illinois
Pollution Control Board and yet they still have to have an increase in
their SIP limit at that power plant which they just got recently because
even with washing they cannot meet the old number. The reason is that
as the coal face moves it is getting higher in sulfur. There doesn t
seem to be any solution to that problem other than a change in coal
supplies which is a pretty radical measure for one of the largest power
plants in the Midwest. I don't think anybody has done enough homework
on this subject. I don't think we really know whether coal washing is
going to produce much real benefit or not, and before we go off half-
cocked, that is something that we ought to look into further. It can be
done within a matter of a few months. The data is available. It is
not a big research effort. It is a matter of somebody sitting down in
each State and figuring out what the real situation is and contacting
the utilities, and contacting the mine operators, and finding out what
their expectations for the next few years are going to be.
Walt Barber: Dan, is that a reasonable request that we could make of
the States?
Jim Hambright: Now you want to put another burden (let me respond for
Dan, if I may) on the States. And I think that they have a lot of

burdens already, Walt. We would be willing to do what we can in that
area, but do you have any idea how many of those things are out there to
look at? We tried to do a survey as part of our research in dealing
with this, of all the coal prep plants in the State, to get the information
on how they cleaned it and what type of reductions they were getting.
That, on a voluntary basis, got us about a 30 to 40 percent response,
which is not indicative of what the total coal prep availability may be,
nor is it indicative of the various types of coal cleaning that there
Walt Barber: I am going to let Jim Kilgroe take two minutes and describe
what he thinks we know about this. I have a problem when we say we need
more information about coal cleaning. We need to know what the actual
practices are at steam generators and/or coal mines and then I get a
reaction to a question that says we cannot find it out. If you cannot
do it from Pennsylvania, I sure cannot do it from North Carolina. I
don't know how to get it done. I don't know how to get from where we
are to where we will have that good set of facts because everyone of you
guys has had one of our contractors troop through your offices, which is
the principal source of air information, and you don't like that approach.
Jim Hambright: Well, if that was a mail out attempt, if we rigorously
went into it and went door-to-door, I am sure we would get a better
idea. Let me say one thing further if I may in regard to coal preparation.
There is coal cleaning and then there is coal cleaning. Some will do
one thing and some will do something else. If we are contemplating a
strategy that would contain the best features of coal cleaning, perhaps
we could get a little more, Carl, than some of them are doing and maybe

we will get less in some other places. It is something that needs to be
looked at. But a strategy, if there is to be such a strategy, should be
devised around good coal preparation, which would give us the best
features of the available technology.
Dave Hawkins: Bud Hovey wants to interject.
Bud Hovey: I would like to ask Dan Goodwin a question. Dan, what is
the useful remaining life of that particular plant you were talking
Dan Goodwin: Probably at least 20 years.
Bud Hovey: Okay. If it has a 20-year useful life, and I assume that
the plant is only using coal washing, are they using any other kind of
emission control for sulfur?
Dan Goodwin: No.
Bud Hovey: What about the consideration of some kind of retrofit emission
Dan Goodwin: For that particular facility it might be altogether feasible
and technologically possible and all that, but you are not going to get
it very quickly unless it is part of some larger national strategy,
which is what I think we should be trying to develop. If the idea is
for the Illinois Pollution Control Board to unilaterally adopt some new
regulations to require retrofitting of scrubbers on facilities such as
the ones that are currently in compliance with ambient standards it will
be a long time coming unless it can be seen to be a part of a larger
program. I would like to respond to Walt's question about State cooperation.
You can get our cooperation on this and I think we have some information
that will be helpful from our permit records and other places. But I

think it needs to be done as a national study in order to get data that
is consistent State-to-State and also to get it organized and presented
in a fashion that is useful to everybody. If you want to send one of
your ubiquitous consultants out to work with us for a while, we would be
glad to cooperate with you.
Walt Barber: All right, a bit from Jim Kilgroe now on what we think we
do know about coal cleaning and we will consider whether EPA can provide
a coordinating role in terms of some sort of uniform information request
on additional coal cleaning practices that we could distribute among all
the States. Jim.
Jim Kilgroe: I am Manager of EPA's coal cleaning program. We have been
looking at the desulfurization of coal since about 1965. With the
Department of Energy and the Bureau of Mines, we have developed a number
of data bases on coal sulfur levels and on the manner and the degree to
which you can clean coals. I prepared a paper for today's conference
and one of the reasons I prepared the paper is that there is a lot of
misunderstanding about coal and how much sulfur can be removed. I
think, we don't advocate coal cleaning as a universal policy for sulfur
emission control. There are a lot of coals which can get 10 percent
sulfur removal. We don't think that represents an adequate cost benefit
for cleaning. With a lot of the high sulfur coals, however, you can get
30 to 40 percent of the sulfur out by cleaning. And this of course
varies from State-to-State and it also varies within each individual
State. So that, you really cannot make a decision on a coal until you
look at that individual coal and look at the individual characteristics
of the coal. Carl Beard brings out the fact that a lot of the West

Virginia coals are cleaned and also Dan Goodwin says a lot of the Illinois
coals are cleaned. That is true. We have some information, it shows on
our handout here, that roughly over 70 percent of the coals in Illinois
are currently cleaned. However, we feel that a large portion of those
coals may be cleaned at levels which could be improved. Also, we feel
that by cleaning the other 25 percent of the coal and by improving the
coal cleaning process you could get additional amounts of coal sulfur
out. We are embarked on what I would call a national study to evaluate
the cleanability of U.S. coal and what additional improvements can be
achieved by coal cleaning. The timeframe for doing this study is probably
over the neighborhood of the next six months. We already have some
preliminary results which have to be confirmed by going back to the
individual States, by going to the people like the National Coal Association
and by asking people who are experts on coal if our conclusions are
right, but I think we are developing the type of information that you
need to make policy decisions.
Dave Tudor, State of Maine: There probably is no one panacea for this
problem. What I would like to hear Mr. Goodwin address further is a
point that he made on 111(d), we lack technology to set the standards
Dan Goodwin: My point is simply that I have serious doubts that the
U.S. EPA has adequate technical data on which to base those kinds of
standards, such that the standard will stand up to the inevitable legal
challenges that are going to come from the utilites and the coal companies
and I do not know who else. I do not know any reason why the States
would have any desire to challenge those standards if they seem appropriate,

despite what somebody back on the other side of the table suggested
while ago. The States are not the ones that are going to count on that
anyhow. It could be that the coal interests and the utilities--and if
you look at the agony that U.S. EPA went through in their NSPS exercise
for utility boilers—know they are going to be up against the same kind
of agony trying to set 111(d) standards. I suspect they have got a
whole lot less data to work with to back it up. What we might very well
end up with if that course of action is taken is that we spend three or
four or five years pursuing that course only to have the thing thrown
out in the appelate court or somewhere and we are back to square 1
whereas if we took less dramatic action, if we do a whole bunch of
little things that we can do here and now under present authority or
with relatively minor changes in existing State programs, while we are
also developing the data base and the political groundwork for providing
a more explicit and well focused authority in the Clean Air Act as a
part of the next round of Amendments, I think we may end up where we all
want to go on this problem with a great deal more certainty and probably
Tony Cortese: I guess I would like to ask this question of my brethren
of the coal-producing States. If there were national legislation that
said that the cost of pollution controls--whatever is determined as the
most appropriate, and I am not suggesting that certain scrubbers are the
most appropriate—but, that the cost of pollution controls could be
directly passed on to the consumers and there was national legislation
that said that locally available coal had to be used, which meant that
coal could continue to be used, would there still be objections on the

part of your States do you think, to the use of pollution control technology
to reduce sulfur dioxide, assuming the premises that: it is a national
policy to burn coal; that we all agree that we should burn more coal,
less oil, with nuclear being in limbo at the moment, and with the
understanding that we have a problem that we have to make a significant
reduction in sulfur dioxide emissions?
Chuch Taylor, Ohio: You have described a situation in Ohio that I think
has unfolded over the last year or so. I do not know how many of you
are familiar with Section 125 of the Clean Air Act. Ohio's utilities
have to come to the conclusion that if confronted with stringent sulfur
dioxide emission limitations the most cost-effective way for them to
proceed to attain those standards is through the purchase of low sulfur,
in our case, out-of-State coal. When comparing the options of continuing
to use the locally available high sulfur coal with the option of including
scrubbing as opposed to going out of State to low sulfur coal, they have
reached the decision that for cost-effective reduction the most appropriate
way for them to go is with low sulfur coal.
Mr. Hawkins: Let me just interrupt there for a moment. I think I heard
Tony suggesting legislation which would remove that option by saying
that controls would be put on and then the utiUtiles would be . . .
Chuck Taylor: Well I know, what I was getting to is they are going to
oppose that kind of legislation, violently because . . .
Tony Cortese: Are we going let the utility industries determine what is
going to be the equitable ... and environmental future of this country?
Chuck Taylor: I am not suggesting that that is an appropriate role for
them to play, I am just suggesting that if that type of legislation were

introduced, you can expect opposition from them and a lot of their
consumers are going to agree with that opposition given the cost involved.
Tony Cortese: But that is because tiiey have that fuel adjustment clause,
which allows them to bring in low sulfur coal and . . .
Chuck Taylor: That is part of it and they can eventually acquire the
cost of the associated control equipment, the scrubbing technology.
There are a lot of practical constraints associated with the installation
of scrubbers as retrofits on many of the urban utilities also.
Tony Cortese: I am not suggesting that scrubbers is the only solution.
What I am suggesting is that whatever the most cost-effective solution
is for reducing sulfur dioxide emissions in a substantial way, the coal
cleaning--let's face it— I mean if we talk about coal cleaning maybe we
will get 15% maybe 20 or 25%, but you are not going to get 75 or 80%
reduction in emissions and what I am suggesting is you know we would be
willing to support legislation which would allow the passing through of
that cost directly to the consumer because it is a national policy to
burn coal, but it is a national policy to burn coal in an environmentally
acceptable manner. I am sure we all agree with that, those are two
things I am sure we agree with.
Dan Goodwin, Illinois: Tony, if one accepts your premise, it probably
eases the situation, but I do not think your premises are necessarily
very realistic. First of all, even though your are saying legislation
to allow the passing through of the cost, I assume what you mean is to
require the passing through of cost. As far as I know all the utilities
rate-making bodies allow pollution control costs to be passed through,
but there is no guarantee that they will be fully passed through without

a full rate-making proceeding and a lot of local opposition. If there
were Federal legislation that required them to be passed through and
required the capital expenditures for pollution control equipment to be
added to the rate base such that the utilities could earn the same rate
of return on those investments as they earn on the generator, that would
probably largely diffuse the utilities opposition. It is not necessarily
going to solve the coal problem, because to the extent that they are
still going to be able to use low sulfur coal instead of scrubbers in
order to keep the rates lower and attract additional industrial customers
in their service area, that is going to be a difficult problem for the
coal industry. So, if you make your legislation say that you have to
have a scrubber to meet certain criteria whether . . . that may deal
with the coal and utility folks, but now you are going to have the
senior citizens and the poor people that were referred to on your backs.
I do not think I can see that kind of legislation coming down from the
Federal level in anything close to the next two or three years. It is
going to be too politically volatile to get out of Congress, certainly
not this year, you are not going to get it in an election year.
George Ferreri of Maryland: I would like to offer a couple of suggestions.
You mentioned what can be done, immediate steps that could be taken to
stop the continuing exacerbation of this problem. Should EPA possibly
consider the moratorium effective immediately on any further SIP relaxations
involving sulfur dioxide? There have been some figures gathered by both
Massachusetts and New Jersey. I cannot attest to the accuracy of them.
I think they got them from NEDS and if they got them from NEDS I am not
going to question the accuracy of those figures. But I think I would

like to see put together a chart showing what the SO2 emissions ... is
being generated by the Eastern States, so we could try to normalize it
and we could get a comparison of where everybody is in terms of each
Mr. Hawkins: One such chart was in Jim Hambright's presentation, I do
not recall . . .
George Ferreri: Well he did not have it for all sources and he certainly
left me out which may be just as well, he figured I was going to show
him up so he wanted to leave me out. But I think I should contend that
that be done so we could get a better understanding of who is doing what
in the production of electricity. Professor . . . and one of the
premises that he has developed . . . reasonably available . . . then
came the ambient air quality data base and we all zeroed in on that and
obviously it is beginning to show that that is not the way to go because
in spite of the fact that we can demonstrate that we are meeting national
ambient air quality standards we are still talking about ... in some
States. . . . where we see the brunt of this problem. So I do not know
exactly how you are going to do this but apparently we are going to have
. . . In some way shape or form we are going to have to start gearing
the act to address the need for effective utilization of reasonably
available technology regardless of whether you are below the ambient air
quality standard or not. I would like to suggest that EPA bite the
bullet and start enforcing wherever appropriate the implementation
plans. We should all recognize we all have our political problems. I
think in certain cases without mentioning any names of any States, EPA
has bent over backwards to bite that bullet. We in the Northeast who

have had aggressive SIPs with rather low sulfur emission limitations are
paying for it, and I do not think it is fair, the burden that is being
placed on the States on the Eastern Seaboard. One other consideration
with regard to PSD--here again in the Northern and Eastern States since
we have most of the oil-fired pi ants--is that we are going to have to
get them converted to coal and we are going to be penalized as far as
PSD goes. For instance, a 1% sulfur oil going to 1% sulfur coal is
going to be a one and one-half times increase in emissions of sulfur
oxide. I recognize the acid rain problem, but I want to keep that
separate from this PSD issue. What I am saying is, whatever increase in
groundlevel concentrations that is caused by converting to coal should
be included in the baseline if that plant meets the SIP that was in
effect as of August 7, 1977. Going on to the acid rain problem then,
let us address it as a technology issue and deal with it across the
board rather than through the PSD.
Stanley Pack of Connecticut: Let me say right at the outset that we
vociferously oppose any moritorium on SIP revision and I will tell you
why. To use the venacular of one of the speakers, let me tell you what
the State of Connecticut is up against. We have had a restriction on
the sulfur content of our energy producting fuels of 0.5, and we have
never had a revision in the history since we adopted that standard. It
was adopted somewhere in about 1973. We are now in a difficult situation.
The EPA, rather the DOE, has come out ordering our utilities to convert
to coal in several instances. The Bridgeport Harbor is already under
orders. We have anticipated orders for two units at Norwalk Harbor
also. We derive close to 50% of our energy needs from our nuclear power

plants so we have sacrificed. We have in a sense rolled back the use of
oil in Connecticut. I have legislators, representatives of consumer
groups, and the utility industry, all pounding a path to my door. They
are looking for relief. We have tried to hold the line. They are not
unaware of the fine statistics and graphs that we have seen over the
last two days, however, what we are saying is that determined effort by
some States to continue as they have is not enough. Tony Cortese put it
very well. He highlights the acuta! cost that the consumers in the
generating States are faced with as compared with the cost in our State.
I think that is a very good illustration. There is no equality of
sacrifice, keep that in mind. We should have an equality of sacrifice,
an equality in the sharing of this burden, and so far I see no indication
that we are ready to take up our share. What are we facing in this
State under the provisions of the Clean Air Act, the chief executive of
any States has the right to go in and ask to have emissions exempt from
the total loading in the case of coal conversion. I see that happening
repeatedly. What we are facing is a disintegration of the real role,
the higher level of performance that we have reached in several States.
Unless we address ourselves to it and start on that road immediately,
hopefully with the cooperation of some of the States who have pointed
out why they cannot do it such as cost. These are the same costs that
we are facing, exactly the same costs. I have before me now at least 40
requests for variances and I do not want to talk about any moritori urns
because we seriously will be looking at these variances. I think what
we are involved in here is something that we all should get together,
work together on it. Let us figure out what the costs of our power are

in the various States of this country, we are all American citizens, we
are all consumers, and let us share the burden, and so far I have not
heard any of that. It seems that you want to build in some age old
costs that relate to 1.5 cents per kilowatt hour while we are stuck with
7 and 8 cents per kilowatt hour. That is unfair. I do not think geography
should determine it. I think the natural resources of this country
belong to all the citizens of this country and not to any particular
State. I would like to put one question to you, Mr. Hawkins. You are
very familiar with the implications of the Alabama case on the PSD.
What kind of action activates the application of PSD in a State? Is it
merely the adoption of the SIP or is it some other action? I have never
received a satisfactory answer to that point.
Mr. Hawkins: The PSD program, the baseline for determination of whether
sources had to apply, is established by Congress picking up on the EPA
regulations. We run the program until the States pick it up, but the
sources do apply, and are subject to, PSD requirements and if they have
started construction after a certain date and January 1975 is the principal
date. The question is: What triggers the baseline that is in rulemaking?
Right now we have comments on a variety of alternatives and the reason
you have not received an answer is that we have not completed the rulemaking.
We have promised the Court to do so by June 2, and a promise to the
Court is better than a promise to somebody else. We will try to get it
done. With that note I would like recess this session for lunch.
Mr. Hawkins: The limo from this hotel to the airport leaves at 4:00 and
we will try to wrap up by then. We will resume. Could I start off with
a question of my own, and then I am going to call on the gentleman from

Delaware. I was listening pretty carefully to Dr. WeidensauVs comments
and I noted that he stated no adverse effects on soils, agricultural or
forest crops, have yet been shown in Ohio. Now aquatic systems are not
in that list and I wonder whether there has been any indication of those
kinds of effects in Ohio?
Dr. Weidensaul: As far as aquatic effects, there have been no observed
effects as far as we can discern due to acidity in precipitation. We
have had problems in Ohio with surface runoff from mine drainage from
acid mine spoils and have been successful in controlling and reversing
the situation in the lakes to where they are now extremely productive.
This is a much different situation. Over the time period that acidifica-
tion of the lakes took place, there apparently was no significant release
of heavy metal cations into the water to cause any permanent harm. As
far as rainfall acidity effects we have not observed this at all.
Bob French, Delaware: It seems we cannot solve some of the problems
that are coming at us in the near future. For the present, I would like
to raise some questions having to do with fuel conversion. I may have
to put one or two of my neighboring States on the spot, but I think I
have known them long enough to do that. It has to do with how we are
going to treat these fuel conversion instances that are coming upon us
relatively soon and how we are going to treat it at the borders. For
instance, George mentioned an additional 50 percent increase in sulfur
emissions for those States like Delaware that have a percent sulfur
limitation. I think Jim Hambright alluded to the Regional agreement of
the three States and the City of Philadelphia on the question of under a
DOE order for a fuel conversion project. Well, we know at what increment

the PSD does not apply. I presume we would not hear any objections from
neighboring States because of those increased emissions under a DOE
order. I would like to extend that further and raise the question of
interstate increment disputes or the possibility thereof under a voluntary
conversion situation by industry. There is also the question of whether
or not there really is a DOE order where the notice of effectiveness has
not been issued. There is also a possibility that industry could team
up with the utilities and agree to build a new, separate unit to supply
the energy needs for the adjoining industry. In these situations are we
going to be quarreling about increment consumption at each others
borders? Then a question for EPA. It would be helpful to know your
schedule for establishing a new source performance standard for industrial-
size boilers. These disputes could force us into the business of trying
to grab at numbers again. You might clarify the PSD requirements under
these voluntary fuel conversion situations and the situations where
there is no notice of effectiveness.
Mr. Hawkins: There are a lot of questions there. On the PSD questions,
the 5-year exemption from increment consumption that is in the statute
at the Governor's request is available for facilities which have been
ordered to convert. That is a straightforward interpretation. Voluntary
conversions would not, in the words of the statute, fall within that.
The other question on the industrial boilers schedule: Is it still a
proposal in this calendar year? Walt?
Walt Barber: Yes.
Mr. Hawkins: Proposal of an industrial boiler new source performance
standard in this calendar year, promulgation in the next.

Bob French: One question. Just to question your response, that 5-year
exemption: Is that five years from the date of the order?
Mr. Hawkins: Well, I don't remember.
Bob French: It is a key point because it gets back to this notice of
effectiveness. The date of the order, a couple or three years ago,
perhaps but the notice has never been issued. So when does the five
years start?
Mr. Hawkins: I will tell you a common sense reaction which may or may
not be the way it will wind up. It seems to me that it would be five
years from the date at which you would normally be consuming increments.
That's a kind of detailed question and a look at the statute can give an
answer to it. Rather than try to do that now, we can get back to you
and anyone else who is interested. Did Bob Collom have a question? I
don't think anyone has yet picked up on Bob French's invitation to
respond to the questions of PSD increment consumption at the border but
maybe Bob's proceeding to do that.
Bob Collom, Georgia: I would just like to make a few observations and
comments. I have heard a lot of "you guys/us guys" comments basically
between the Northeast and the Midwest. I think that we all agree there
is some degree of acid rain problems created where they exist. The
degree and the mechanism is still not totally understood. I don't see
why we cannot agree on what can be shown almost cost-effective by itself
in the way of either coal cleaning or other mechanisms that might work
in certain regions. If necessary, change the Clean Air Act so a regional
approach can be allowed without one State taking the full burden of the
cost or the inconvenience of taking whatever action is cost-effective.

Obviously, coupled with that, we need more ambient monitoring as well as
effects research. We don't need to go pellmell. I don't think we know
the solutions. We could not write a new law today or even next month to
solve what we think is the acid rain problem. I would comment that PSD
in my opinion would get in the way of an awful lot of the alternative
solutions that have been offered today. I think it's a shame that one
part of the Act is so intransigent, that through the law itself or the
regulations or administration of it, that it may eliminate very good
alternative solutions to another problem which is more real. More
effects can be linked to it than to PSD which are primarily aesthetic
effects. I would also ask that people try to define their terms. Coal
washing has been bounced around a lot today and obviously there are
different types of coal washing, different degrees of effectiveness, and
different costs. It varies from mine to mine, types of coal, not just
sulfur content but ash content, and also things such as low sulfur-high
sulfur. I suspect that means different things to everybody who use
these terms. I would think that if education and some consistent defini-
tions and bases could be established, possibly by EPA, and I think EPA
has been sort of lacking in establishing any real leadership in this or
many areas. Obviously, it's politically sensitive, the answers are not
readily available, but we can, at least, educate each other and get on a
common ground of definitions of terms and the like which I don't see
existing today.
Mr. Hawkins: Yes, from Pennsylvania, Mr. Middendorf.
William Middendorf, Pennsylvania: I would like to try to accomplish
several things if I could. One, to perhaps give you the perspective of

a coal-producing State that is geographically in the Northeast, and
therefore, shares some of the problems that have been raised by the
Northeastern States. Secondly, since we are a major coal-producing
State, we have somewhat the same problems as the other coal-producing
States. The other thing I would like to accomplish is to put into
perspective where we are now as a group. We have spent a great deal of
time discussing what the technical problems are in facing the reality
that yes we do have a problem. We have discussed the political situation--
that in the Northeastern States we have a number of States that have
bent over backwards to comply with the Federal Clean Air Act because
they felt that the Act meant exactly what it said. We have a case where
in the Western or Midwestern States compliance has not come about as
rapidly or at least we certainly have a difference in emission rates in
comparison with the Northeastern States. So we have a difference of
opinion on just how tough the standards are and what the impacts are.
Being a coal-producing State, I would like to give you the realities of
life from our perspective. We have tried to comply. We are geographically
located in the Northeast as I said before. We have reduced our sulfur
output. We feel that we certainly have a tough political situation
especially if we have to go back to our coal miners or our utilities and
say that you have to tighten up even more when we have States to the
West who are also coal-producing States that are not doing the same job.
So if you want to swallow a tough political pill, try the one that we
have where we must constantly defend. Why we have been tough and yet
are achieving in many instances the national ambient air quality standard
and in some instances we are not because of the influence of the neighbors

to the West. It is more than apparent as we listen to the discussion
that is going on today that each one of us has its own parochial interest.
We defend those interests. Those are the realities of life. It should
be equally discernible to everybody here that you cannot have your cake
and eat it too in all instances. What is going to be needed is exertion
of some leadership at the national level; of taking some of the political
heat that we all face back in our own States; of saying that we are
going to have to tighten up in certain instances. But not to go ahead
and grab, shall we say, technical solutions that are applicable across
the United States, that are going to make it tougher for those States
that have already tried to comply. This means that you can't just grab
coal washing as the permanent solution equally across the United States.
You cannot grab the idea of retrofitting all existing plants equally
across the United States because then you are putting an unfair burden
again on those States that are attempting to comply. It is time for EPA
to start setting the example by stopping the relaxations that have been
going on, by beginning to realize that one State does affect another,
that through the SIP process that we have right now, you cannot allow a
situation to exist where you simply approve the SIP with no recognition
being given as to how one State impacts another State. One of the
greatest fears that the six States had when they went to see Mr. Costle
about the problem initially, was that when he mentioned this particular
type of conference that the States would be thrown into a pit, eaoh
sitting there defending what their parochial interests are; each showing
the political realities of light from their particular point of view;
and then EPA throwing up their hands and saying, "My gosh! If you

people in this room can't agree on the solution, how do you expect us,
EPA, to do so?" We do expect EPA to do so, we do expect EPA to take the
leadership, and I think that every Slate in this room will pledge to sit
down and work cooperatively with EPA in arriving at those solutions.
One of the first things that can be done under the law that now exists
is to get some of these States that have avected border pollution
problems to sit down and work out reasonable solutions as in the case of
Philadelphia, New Jersey, and Pennsylvania. All the rhetoric aside, I
think the time for action is now.
Mr. Hawkins: Perhaps just a short response is in order. I fully agree,
and I know that Doug agrees, with Bill's comment that it would be very
inappropriate for EPA to throw up its hands and point to all the States
and say we demand unanimity of views among the States before EPA is
prepared to doing anything. That would be an unrealistic expectation if
we held it. But, we don't hold it, we don't expect there to be unanimity
of view. I think that what we have seen is that the States, for very
good and proper reasons, do have different perspectives. You have coal-
producing States, you have oil-consuming States, you have States which
are able to document effects, you have States which are not yet able to
document effects. There is a mix of costs and benefits which, at least
at this point, aren't perceived to occur in the same places. We understand
that and I think it's our feeling that it is our responsibility to see
what can be made of that situation that will lead us all in a positive
direction. We are going to pursue that with vigor and I think with a
lot of ideas generated out of this conference. I do not want to try to
give you the summary of the conference before we finish the discussion

this afternoon, but I think it is a point well taken. Let me jump to
Wisconsin, Tony, first. Wisconsin.
Mr. Dawson: My name is Tom Dawson. I am an Assistant Attorney General
of the State of Wisconsin and have been designated as a public intervener,
which is an environmental public rights advocate in the State. I have
a question, but I would like to preface it with an observation. This
part of the discussion, supposedly, is aimed at alternative strategies
for solutions to the acid precipitation deposition problem. Mr. Hawkins,
you listed several alternative strategies that might be implemented.
Mr. Goodwin listed some of the political realities connected with those
strategies. I assume that there is no one exclusive strategy that would
be advisable or should be advisable exclusive of any other. I take it
that when we talk about alternative strategies we talk about an inter-
disciplinary approach to the solution to this problem. With the assumption
that this is going to be an interdisciplinary interrelated solution
seeking idea, I wonder why there has not been discussion of what I
consider to be one of the central issues to this acid precipitation
problem. That is, one of energy policy itself. It seems to me that
solutions to acid precipitation and air pollution should necessarily
include a discussion of energy policy at both the State and Federal
level. My question is why this has not been considered part of that
interdisciplinary approach. Again, I am not emphasizing that conservation
or alternative energy stategies are an exclusive means of answering this
problem, but I am asking why these questions have not been included as
one of the many factors that may go into that interdisciplinary approach
to solving the problem? Are the DOE people here and are there DOE
people who might care to respond to my question?

Mr. Hawkins: There are DOE representatives invited and I think DOE and
EPA both believe that energy conservation needs to be pushed as far and
as fast as it can be. I personally came to this meeting with the assumption
that that was the case. I would also come to the meeting, however, with
the personal concern that if history is any indication, we cannot count
on a large near-term reduction due to conservation. Except the conservation
that seems to be induced by the market changes which we have been seeing
in the last 12 months. We certainly need to keep on talking about the
benefits of conservation and obviously they are directly there. Any Btu
of energy that is not consumed is not going to have any externalities
associated with it.
Mr. Dawson: But then we come back to the issue of leadership in the
area of conservation and in the area of alternative energy sources; the
lack of a cohesive and comprehensive energy policy that must be the
basis upon which we create these other solutions; and the issue of
trying to anticipate what the demands for coal, for nuclear energy, and
the other forms are going to be and how we are going to respond to those
demands. Especially in the long term. I guess I am basically speaking
to the long-term rather than just the short-term.
Mr. Hawkins: The logic of everything you are saying is unassailable.
The thing that a lot of us have observed is that mandatory energy conser-
vation programs seem to be one of the areas that Congress is most sensitive
about, and has the most difficulty getting through in any form that does
not wind up having little effectiveness because so many special groups
have gotten their exceptions identified. The Administration has had a
difficult time getting real energy conservation programs through Congress,

and those in Congress who have tried to get real energy conservation
programs through have also encountered that same difficulty. It does
not mean we should stop trying. Ray Robinson asked me some time ago if
he could be recognized for a moment.
Mr. Robinson: Thank you very much Mr. Chairman. I might make an obser-
vation before asking a question. Some time ago when we were first
briefed by the U.S. authorities on some aspects of the acid rain problem,
particularly the projections for increases in the emissions of SOg and
oxides of nitrogen over the next few years, it was put to us that one of
the factors that would bring down S02 emissions toward the end of the
century or early into the next would be the retirement of old plants.
Since then we have seen skyrocketing interest rates, and I am interested
to know from people who are far more knowledgeable than I am about this
subject, as to what implications that might have for retirement projections.
Obviously it is worrying from the standpoint of retirement projections.
I might make the further comment that the projections we received at the
time, while showing that SO^ would go up 10% and then start to go down
in the next century, showed perhaps a doubling of NO in that same
period. We have had almost no discussion at all of NO except during
some of the technical discussions earlier in the day. That is very
troubling too. By and large, our situation in Canada is that while we
have significant SO2 emissions our N0X emissions are very much smaller
in proportion. We are determined to go after the SO2 emissions and I am
confident that we are going to be able to bring them down. We do have a
happy situation in that the principal polluters are located in the
Provinces where many of the effects are taking place, and I realize that

is part of your difficulty here. That has become very obvious. But,
nonetheless, the fact remains that we could be facing a situation in
which we take significant action to bring down our SOg emissions and yet
with a reduction in retirement expectation for some of your power
plants, which I am assuming might well be the result of higher interest
rates together with what seems to be a lack of concerted approach to the
NO problem. With respect, ladies and gentlemen you may be occupying the
territory we would be vacating, and that is no small matter. We are
very concerned about that, so I put that before you as something that
might be kicked around a little bit.
Mr. Hawkins: Not too hard. Anyone want to offer any observations on
that. Tony?
Mr. Cortese: Thank you Dave. I am getting very concerned that we have
spent a day and a half here and as the witching hour is approaching
people are getting up and leaving and I think it would be a genuine
waste of the taxpayers money and a genuine waste of all the talents and
the great debate that has gone on here if we don't talk for a minute
about a process to continue this. We are just not going to settle a
problem of this magnitude in one afternoon and I would like to suggest
for the groups consideration to include Mr. Robinson's concern that we
form some subset of this group--I am indifferent as to how it gets set
up but obviously representation from every region--to work with you,
Dave, and Doug at the highest levels of EPA maybe taking the New York
proposal as an example. To get together and work on some real possible
solutions to this problem with the concept of coming back in the near
future, say the next two to three months, with some proposals on what

actions we can take. We have a New York proposal which many of us
agreed could serve as a starting point. I would suggest we look at the
back-out legislation to consider the issues that I raised before about
the rate structure for electric utilities and the use of local coal. I
am saying this in the spirit that Bob Collom raised, which is one of
trying to sit down and cooperate to find some solutions as opposed to
just a continuing debate between different regions of the country. What
I would like to do is throw this out for the consideration of the group.
I think EPA has made one good suggestion on the idea of coal-washing and
getting some information from the States. I think we have got to take
some action, and I think that action—in the absence of suggesting a
control strategy that everybody can agree to in the next 45 minutes-
should be that we do form some subset of this group to get together to
work cooperatively to begin to settle this problem. Also to help EPA
outline the research program that they have initiated in looking into
this problem in the future. I would like to get some reaction from the
group on that.
Bob Flacke: Dave and Tony, I would agree wholeheartedly that there has
to be some continuation of dialogue, especially the dialogue that was
given to us by EPA to interact with our Midwestern States. There is no
question that we have regional parochial interests here. Hopefully, the
original Six State Coalition that worked with Doug toward the formation
of this meeting will expand itself and continue its effort by working
with their Congressmen towards an understanding of the Northeast's
position on the oil back-out legislation and the impending changes to
the Clean Air Act so that we do not continue the lack of equity that has

clearly been emphasized by the Pennsylvania/Ohio border situation. I am
hopeful that we can use . . . EPA really to kind of schedule some dialogue
with the Midwestern States who have taken the opportunity to invite some
of the Ohio delegation to visit New York and to go up into the Adirondacks.
We have already scheduled with some of the Pennsylvania people to take a
trip to the 100 lakes and find out exactly what is happening along with
some of our specialty fruit crops and if anybody wants to go along with
Ohio, we will be happy to take them along on that trip. So I know that
what we will be doing is working with Tony, New Hampshire, Maine, and
the original coalition towards organizing some type of formal structure.
If we are not able to resolve these parochial interests then we do have
to strengthen the power that we do have within those various localities
so that we are insured that during the legislative process we do not
have a continuation of inequity that is now quite apparent under the
current Clean Air Act. I pledge ourselves to work together to continue
that dialogue and hopefully then we will be able to work with EPA to
continue the dialogue that exists around the table here today.
Bob Collom: I would like to second what has been said here recently,
and the STAPPA resolution that was presented this morning although broad
and conceptual. I haven't heard anyone try to take it apart. The New
York proposal which I understand is endorsed by several other Northeastern
States goes further and puts a little meat on the concepts that the
STAPPA resolution contained if the definitions can be pinned down, words
like significant, equity, or inequity. Then I think we have something
that we can use if not through actual legal and regulatory bases with
the concurrence of a major group such as this representing State air

pollution agencies, departments, representatives from the Governors
offices sitting around the room. If there is a consensus there even
before any legislation goes through Congress, I feel certain that action
can and will be taken. People are not out to cut each others throats.
We do recognize the interrelationships we have with one another. If a
problem is already occurring in New York, it could well occur in Georgia
or Wisconsin or what have you. We are paid to prevent problems and
certainly it is a lot cheaper to do that than to cure them afterwards.
I would recommend Tony's suggestion and say that in the next three
months, if not another meeting of this magnitude since it is hard to get
this number of people together, at least regular mailings from a core
group of State and Federal officials that promote and keep this going
with some initial easy control strategies being proposed within the next
four months.
Will Brown, New Hampshire: We would strongly support Tony"s suggestion
and I would like to ask a question. Does EPA have it within their
existing authority to set up a State advisory board on acid rain, or
would this require Congressional action?
Mr. Hawkins: Well I don't think that it would require Congressional
action, I think if it were an official advisory committee, it would
require 0MB approval, but an informational advisory group, while it may
be subject to the advisory committee act could probably established
without that formal approval. There are a couple of procedural questions
and they are: How would the group like to have this core group established?
Should we try now to identify three or four States which would then
among the four of them decide how big an advisory group to select and

try to have some balance among that four? I could think of four that
would at least to me appear to have a balance. Do we want ask STAPPA?
I notice Del Rector is not here, so that is a logical choice. Do we
want to ask STAPPA to identify a group of States with some instructions
that they be balanced among coal producers, Northeastern States with
demonstrated impacts, States like Georgia that may be a little bit of
both, States like Pennsylvania? One possiblity is to have the States
of Massachusetts, Pennsylvania, Illinois, and Georgia be a core group
which can expand to a large core group. I can throw that one out and
see if anyone wants to modify that by changing those four States to some
other States. What process would people like to follow?
Jim Hambright: If I may Dave, we could sit as a core group and gripe
and complain to each other forever and not get anywhere. We really need
to have some group in EPA working toward solutions that can be achieved
with our participation in their deliberations and trying to aid them and
to explore what we believe to be feasible that they come up with and to
broaden or maybe to work within that concept. I cannot see this as
States getting together to solve this problem because it just isn't very
likely to happen. We need to have that national presence, that national
guidance, that national development, of some type of a program which
would be equitably applied across the country.
Mr. Hawkins: Yes, can I just say, I hear you very clearly on that. I
will say again, that EPA's intention is not to say to the State, go sit
in the room and figure out the solution and when you have it come back
to us. What I heard as the value in Tony's suggestion, and in Bob's
reaction as well, was that there is a possiblity that groups of States

may perceive themselves as being further apart on these issues than they
really are. Any leadership that EPA attempts to exercise is going to
make it more difficult to produce successful results if there is a
perception that there is a very definite political split, or a split in
interest between groups of States, and that EPA is going to have to come
down on one side or the other. I think it is in all our interests that
there be communication between the States where this perception may be
present to find out how much of it is real because if you are closer
together it will be much easier for us to do more than pound the table
and demand action and quote "exercise leadership". We are prepared to
exercise leadership, but I would like to have some positive results come
out of it as well. Bob.
Bob Flacke: Dave, I would like EPA, you or Doug, to respond to what we
have called the coalition position. Although kindly referred to as New
York's, I believe Connecticut wrote the summary; Massachusetts negotiated
items 1 and 2; and Pennsylvania did not leave the room at all until it
was written (afraid that wrong words would get in); so I really cannot
say that the entire idea or even the result is New York's. As a matter
of fact I think New York agreed with everyone else. That is a proposal.
It is on the table. We really want everyone to look at it. We really
want the coal producing States to take a look at it. We are willing to
modify those proposals. Frankly, I think that is a start. Maybe the
next step would be to take that coalition and continue to negotiate them
with EPA within a reasonable length of time, say 60 days, to see if we
can get some kind of response as to the next direction that we should be
taking. I offer that as a very positive first step.

John Daniel, Virginia: There are several comments I would like to make.
One, I would like a summary of this meeting if at all possible. . . list
of those States that are in favor of those proposals that are on the
table and those that are not, the names of the representatives from
those States and whether they in fact are authorized to commit their
State one way or another. I guess the other question that I have is:
Has EPA, and this goes back to something that Dan said this morning, has
EPA considered going to the Nuclear Regulatory Commission (NRC) to get
them to speed up licensing of nuclear plants that are already planned
because obviously that is one way to minimize the S02 problem. The
third question is: Is EPA actively supporting the President's coal
conversion program?
Mr. Hawkins: A variety of questions there. We have not, to my knowledge,
petitioned or tried to induce the NRC to speed up the licensing process.
Our involvement in the Three Mile Island incident was sufficient to
make us feel that there is good reason for NRC to be taking a good hard
look at its procedures. Personally, I have not come to the conclusion that
that hard look at its procedures has been dragging along for an unduly long
time. With respect to the coal conversion proposal, the Administrator
has testified publicly on a number of occasions that he would have
preferred an approach which would not have raised the issue of increasing
emissions and possibly making the acid rain problem worse. The President's
decision was to do something about acid rain after further discussions
with Congress rather than trying to do it in the context of this particular
legislation. The Administrator has testified that he does support coal
conversion and supports legislation that will speed the process, and he

has been pointing out the reality of the fact that actually getting that
coal burned is going to depend on the political willingness of the
communities where the coal is sought to be burned. That means making
the perception of coal being burned there something that is acceptable
to these communities. Obviously, price differentials help a lot but it
is not clear that those by themselves will carry the day, if there is
active neighborhood concern about the problems, Bob.
Bob Collom: I would like to suggest that the National Governors Association
be involved in this deliberative group over the next few months. We
have all heard the political and economic factors that come into these
decisions. Most of us around this table are agency people, we do not
make the political decisions and do not deal with the legislators on a
day to day basis, this is what the Governors have to do. I believe the
Governors Association has a subcommittee and a committee structure
already set up that would be more than appropriate to assign this sort
of topic to. STAPPA does have some experience working with the Governor's
Association in such technical issues and I am sure EPA does as well.
George Ferreri from Maryland. Dave the few words you just mentioned
causes me considerable concern. First of all I would like to apologize
to the State of Connecticut, I was willing to amend my recommendation
that their ... be allowed to . . . Since I think Pennsylvania seems
to agree with my recommendation that a SIP moratorium be implemented, I
would like to ask you: Do you feel that under the existing laws you
have enough authority to implement a moritorium on SIP revisions. I
think it is very evident we are going to get to coal, and in order to
get to coal in a more expeditious, practical, feasible manner there is

going to be a lot of provisions to relax SIPs in order to facilitate
this conversion. I think we are all going to be placed under the gun to
do this and somewhere along the line someone is going to stand up and
say no. Now does EPA feel that under the existing law you have the
authority to place a moritorium on SIP regulation?
Mr. Hawkins: Well let me answer by saying there are too many lawyers
taking notes for me to want to give you a legal opinion. So what I will
say as a policy matter, is that I think it is obvious that there are
distinctions that can be made in SIP changes. There are distinctions
that can be made in terms of the size of the emission difference that is
involved; what level you are going from; what level you are going to;
and whether you are dealing with an actual emissions increase or an
allowable emissions increase. All of those things are distinctions.
They all have a substantive difference on the acid rain concern that we
are talking about. So as a policy matter, any policy on evaluation of
SIP revisions as a method of dealing with this problem would have to
take those kinds of differences into account. You want a follow up
question, George?
George Ferreri: Another observation here. We all recognize the Clean
Air Act as it is structured which says meet the ambient air quality
standard. There is no other consideration in it for what we are discussing
right now and that is why we are in trouble. I want to remind you of a
situation that occurred back in 1973 when the first oil embargo hit us.
One of EPA's officials went about indicating that the reason we were in
trouble was because the States were overly aggressive and consequently
did more than what was necessary to meet the intent of the Act.. On that

basis, a lot of us had a . . . I was one of them. We had a one percent
sulfur regulation in our State and we had them adjust it to be more
reasonable to meet the intent of the Act. I think this is one of the
reasons we are here today. We recognize that meeting the ambient air
quality standards is not the only thing we should have been doing, that
there were other considerations which we did not take into account.
That is why I am asking that if the Clean Air Act remains the same . . .
the ambient air quality standards that we are going to exacerbate this
problem just as sure as I am sitting here talking into this microphone
because they are going to request SIP relaxations under the Act as
everybody interprets it right now. There is nothing anybody is going to
do about it unless somebody is willing to stand up and say we are not
going to because there are other considerations that we have to take
into account. That is something that EPA, it is going to be in your
hands because we cannot do it unless you people do.
Mr. Hawkins: Let me just say that this morning •! did try to go through
a list of possible options, techniques, that could have an influence on
total loadings. Those are options that the Agency is going to be deciding
as to whether there is potential to use them or not. I am going to be
deciding that in the next couple of months. Did New Hampshire have a
question? No? Tony.
Tony Cortese: I am reminded of the First Continental Congress in which
North Carolina kept yielding to South Carolina. I would like to get
back to the issue, with all due respect to my friend from Maryland, of
forming a subset of this group to do something. I would like to hear
what other people think. We have had some suggestions about getting

together with the NGA; Virginia had suggested to reacting to the proposal
I incorrectly characterized as being put forth by New York. I would
like to suggest that maybe the STAPPA Executive Board designate some
group of people in each Region and go back and consult among themselves
to appoint one or two people. We would like to have input from as many
of the coal producing States as possible to try to work out something
that would be mutually acceptable to all of us. Use our proposal here
as a basis for figuring out what could be done in the short run and take
off from there, get some response from that. Then consult with the NGA
and consult with other groups including Congress on what might be the
potential solutions to this problem. The only modification I would make
to Bob is that I am afraid if we don't convene some group like this
again that we won't be able to make this thing go forward. I would like
to view ourselves as the board of directors and some subset of this
group should work with EPA to come up with some proposed solutions and
try it out in their own States and them come back and make suggestions
to this group again at some definite time period whether it be three
months or two months or what have you. I am indifferent, as long as it
is in the short-term rather than the long-term. I would like to hear
some reactions from some of the coal producing States on this idea.
Mr. Hawkins: Carl?
Carl Beard: I'm not reacting to you Tony. This is just a suggestion.
There are people you are not hearing from which you are going to hear
from. You are not hearing from coal folks; you are not hearing from
utility people; you are not hearing from miners. While I agree with
Tony's suggestion on a subcommittee, EPA cannot wash their hands. I

have very strong doubts that the States will every get together on the
economic . . . EPA has to be involved in this process; it's pure and
simple. My recommendation is to the opposite of that. Call a meeting,
call a conference, but broaden it and give the other perspective. Get
them on record. You are going to hear them sooner or later, why not
Mr. Hawkins: Any other reactions to Tony's suggestion. Dan?
Dan Goodwin: Yeah, I think some kind of an amalgam of several of the
suggestions that have been made would perhaps be the best course of
action. I think having STAPPA designate some kind of an advisory group
or a steering committee of some sort charged with defining what our
short-term and long-term objectives ought to be and some plan of action
geared to the timeframe of the objectives, I think that would be appropriate.
That is something that could be done, I am not sure in two months, Tony,
but in six months. I think it should be done with the participation of
U.S. EPA and consultation with the utilities, the coal interest, etc. I
also think that there needs to be another round of the kind of discussions
that we were having here today in a fairly public forum where that
group, call it whatever you want to, can come back, bring the ideas that
they have come up with in a less public and less intense sort of forum,
back to the group. Hopefully, the ideas will have sorted themselves out
into a manageable number of issues and suggested actions that can then be
taken up by U.S. EPA as a proposal that reflects consensus where it
exists and well defined disagreement where consensus does not exist. I
think Bob Collum's idea of involving NGA is a good one but I think the
State air people need to do some work on the problem first before we get

NGA too actively involved, so that they will have the benefit of our
sorting out of the problems before they start on it.
Mr. Hawkins: Yes, John.
John Daniel: I would just like to say, before the comment Carl Beard
made because I think that the . . . the input from the coal companies
and the utilities ... it may be just a little unfair to say this, this
is a sort of one-sided meeting and I want them to be able . . . and I
think it would be a lot more beneficial if we could get in a meeting
with them, and discuss this issue further.
Mr. Hawkins: O.k., the woman from Kentucky.
Nancy Osborne, Kentucky: I think if you are going to involve these
outside groups, you ought to also get together consumer groups, because
they are the ones that are going to bear the brunt of this anyway,
whatever solution we abide by, we have got to involve those people.
Mr. Hawkins: Any other, yeah Craig.
Dr. Weidensaul, Ohio: While we are throwing different kinds of things
into the pot to consider for whatever kind of a meeting that transpires
in the future, I would just like to reemphasize the point that was made
and dwelt upon for a significant time yesterday and was not mentioned
since midafternoon yesterday, until Ray Robinson mentioned it here
before lunch regarding NO . By the way I am not trying to get away from
the subject of sulfur, I am adding something to the subject of sulfur.
The air trajectory data shown in the graphs and so forth showing the
mixing patterns and effects of cyclonic and anticyclonic patterns, I
think shows pretty clearly and this is I think generally accepted among
meteorologists, that there is a tremendous amount of mixing of whatever

is in the air and often it is not inconceivable that what Ohio generates,
Ohio receives, again the same thing happens in Pennsylvania, New York,
and all the way down in Kentucky and Tennessee. It is not restricted to
the Ohio River Valley. It is not restricted to the coalition States if
I may refer to them as such in the Northeast. What is generated in one
particular area does not necessarily go in the direction of these prevailing
winds relative to the jet stream, such as we heard yesterday. I would
like to throw into the pot the serious consideration of oxides of nitrogen.
Along with sulfur oxides, it was considered as one of the two major
contributers to acidity in precipitation. There are others such as
hydrogen chloride gas, hydrogen chloride, and various other acid gases.
But NO and SO were considered the two primary contributers. Further,
X	x
I think the data showed rather conclusively—at least I was convinced—
that the importance of oxides of nitrogen relative to the important of
sulfur oxide is increasing, and is projected to increase quite substantially
in the future. I think any effort made to consider limiting emissions
from wherever would be remiss if the other primary contributor to acidity
is not considered. There are reactions, interactions among these components
of rain in the ambient air, and people from the Northeast would agree
that the NO generated primarily by the internal combustion engine is
mixed with materials in their area often transported in the opposite
direction from what we recognize as the prevailing winds, mixed with the
good things that we can produce in the Ohio River Valley, transported
across the Great Lakes, given to Ray Robinson and back up to the Northeast.
It is not a simple thing, and I think to just pick out one segment of
the pie may be limiting the effectiveness of the entire strategy. I

would like to hear a response on the part of the Northeast States
relative to the mobile sources of NO . It is a tough one to get at, I
do not deny that, but nevertheless, they are there, the preponderance to
NO emissions are in the Northeast, the megalopolis from Boston to
Richmond. How do these things fit into the picture of control strategy
relative to limiting emissions contributing to the acidity of precipitation?
Mr. Hawkins: Bud.
Bud Hovey: O.k., if you looked at the STAPPA proposal, we did not limit
the proposal to sulfur dioxide, we talked about all transported pollutants.
NO and nitrates are transported pollutants. We recognize that there is
NO from motor vehicles. We concentrated mainly on dealing with stationary
sources. The motor vehicle provisions of the Clean Air Act should, if
Congress does not keep relaxing them, eventually start dealing with the
issues of NO . There have been a number of relaxations on the part of
NO over time and the motor vehicle industry obviously is trying to get
more relaxation so they can put more diesels on the road. I think this
is an important issue for EPA to address because we agree that it is
probably an important part of that whole mess that causes acid precipitation.
Dr. Weidensaul: I agree, and in response to that I would like to say
that here we were either facetiously or seriously alluding to court
action in the coal producing States of the Midwest, and it seems we were
trying to regionalize the emissions. What I am pointing out is that no
one is sitting in an ivory tower. Regardless of whether they are
stationary sources or mobile sources, we have got a mix, and you mix
with us, and we mix with you, and I do not think it is anyone's individual
problem, whether they are mobile source, stationary sources, or what

have you. We are talking about compounds in the atmosphere such as
oxides of nitrogen and oxides of sulfur. I fail to see the relevance of
who drives what car or the fact that it is a mobile source or that EPA
has relaxed standards or whatever. We are talking about the effects of
acid precipitation, and that if we are going to dig into solving the
problem and looking at the contributing factors to acidity, that we
would not be properly and objectively addressing the whole problem if we
did not consider all the constituents, regardless of their source of
Bud Hovey: I think you completely missed the point. We are not saying
that something should not be done about mobile sources, we are saying
they should be. But we are saying that there are a lot of stationary
sources; that there is an inequity problem; that there are a lot more
emissions from stationary sources in some places than there are from
others; that that ought to be looked at very carefully; that the SIP
process itself does not work and because of that there seems to be a
need for change in the Clean Air Act. To address the issue of treating
these sources on an equitable basis in terms of some kind of emission
technology, whether we are talking about an emission limit, or about the
plan that Dan talked about where you use technology related to the total
megawatts generated, or what have you, we are talking about some kind of
technology not only for the utility industry, that is probably the first
step because they some of the biggest sources, but there are others.
Incidentally I agree with something that Carl said earlier that we
cannot neglect industries that we have been talking about, the coal
industry and the utility industry. Whether you can bring them into the

group meeting we were talking about, or whether you are going to have to
go outside and set up a separate meeting at some time with these industries
and the consumer groups and what have you. We cannot neglect that
forever. It has got to be addressed sooner or later and probably the
sooner the better.
Unknown Person: Are you suggesting that we also contact the automotive
Dr. Weidensaul: Yes.
Mr. Hawkins: New Hampshire.
Will Brown: Perhaps what we need to do is sort out process from substance
at this point and stick to process because that is what Tony started us
off with. As I see it, what is coming out of the group in various forms
is a strong desire that the EPA take clear leadership in establishing an
appropriate follow-through mechanism regardless of what form that mechanism
takes. I think that is the number one point that we are really after.
We cannot decide here what that process will be. We have all sorts of
suggestions, you are the only central body that can sort those out and
make some sense out of them and act on them.
Mr. Hawkins: I have a proposal and it is that we, we being EPA, ask the
STAPPA executive committee to identify a workable core group of State
representatives that has a balance among the different views as we have
sorted them out that have been presented here, and that group make its
decision about how it wants to involve institutions other than the State
representatives themselves. The group when it gets together would
make its own decisions about the processes for involving the variety of
industrial, consumer, and other groups such as the Governors Association.
Is that something that strikes you as useful? George.

George Tyler, New Jersey: I like your suggestion, I endorse it, but the
only thing that scares me now, is that you talk about it in the third
person. . . . inviting me to chair it, at least that would be my suggestion
. . . some technical kinds of solutions that we have proposed and that
you have proposed, we are also on the criteria that Dan Goodwin quite
correctly set forth in his statement as to what the necessary prerequisites
are for the implementation of those solutions. Are we going to have to
address the political problem? Otherwise, we could have the greatest
technical audience in the world and we not going to go anywhere. That
may be what you meant by bringing in at the appropriate time the other
interest groups.
Mr. Hawkins: Well one of the main advantages of such a group may be
the flexibility it has in being able to contact EPA and others on an
informal and frequent basis. Why don't you let EPA decide whether our
being a formal member of such a group would increase that flexibility or
decrease it. I can assure you that we want to be an active discussant
with any such group. From our point of veiw, it is a group of States
that would be bringing in others that would allow us to have a point of
contact and one that we would want to be working with, so I would not
regard it as something that we would watch go about its business as
though it were some separate independent entity that we were interested
in watching but rather something that we would be working with. Yes,
New Hampshire.
Will Brown: As a minimum, couldn't EPA take the responsibility for
being the convener? Otherwise, I do not see how this effort will get
off the ground. With regard to STAPPA, they have the advantage of being

airborne whereas some of us are water bound, and I would hope that you
might consider the water pollution organizations as well.
Mr. Hawkins: O.k. As I say, I am perfectly willing to have EPA write a
letter to the STAPPA Executive Committee communicating the fact that it
was the consensus of this group that the STAPPA Executive Committee form
a group of States. The point about bringing in the water interests and
asking STAPPA to see that is done can also be made. Bob Collom.
Bob Collom, Georgia: STAPPA has a committee and it has been meeting for
several months and has committed itself to preparing a more detailed
recommendation to the full membership when they meet in June. We will
continue to function under Bud Hovey's chairmanship and the STAPPA
President, Del Rector. As you say we are much more free to contact
other groups than EPA without worrying about legal clearances and the
like. Certainly we will be more than happy to work with EPA. I think
we will need some technical input and comment from EPA in order to
effectively make sensible recommendations.
Mr. Hawkins: Well now I guess that raises the question of whether the
group that already exists as a STAPPA committee is regarded as a broad
enough group or whether it is one that people would want to have made
broader. Your views are solicited.
Bud Hovey: I would like to make a suggestion, because as chairman of
that group it may not be completely broad enough. We have one represen-
tative from Ohio on the group, we do not necessarily have the right mix
for this meeting because at least three of the members of that committee
are from completely outside this region. I would suggest that since Jim
Hambright serves on that committee and also is the Vice President of

STAPPA and currently the ranking STAPPA member here of the executive
board, that the consideration still should be given by the executive
board as to whether or not they want their committee, which I chair, to
do this work, or to augment the committee to do it, or to set up a
separate ad hoc committee. I would rather leave it to the executive
board to make that decision.
Jim Hambright: I would like to ask a question, Dave. Do you have a
legal problem with EPA chairing the group because I, and I think my
fellow State representatives, here do not like the concept that we would
be sort of meeting alone and then just consulting with EPA. We feel
that this has got to be a true State/EPA partnership and that is the
only way it can work, and I would like to hear why that cannot be?
Mr. Hawkins: I have no problem at all with the objective of it being
regarded as a two way street between EPA and the States. The mechanism
for accomplishing that and keeping this to be a workable group is what I
would like to identify as the best technique. It may be that EPA member-
ship will be feasible, it may be that it would be better to not have EPA
membership, but the objective is not in issue as far as I am concerned.
Now as I understand the proposal as it has been modified, we would have
EPA writing a letter to STAPPA asking that the executive committee see
that a group of core States be set up to work with EPA and to establish
procedures for contacting others and involving them and that STAPPA
would be asked to look at three options for establishing that group.
Either the current group chaired by Bud Hovey, a modification or augmen-
tation of that group, or an entirely separate committee. The letter
will not indicate any preferences because I have heard none.

Tony Cortese: 0. k., I agree with that, although I would like to suggest
that with all the States that are here today, we could, after this
meeting, make that decision and let you know by the time you write the
letter. I guess what I am saying is that I am not interested in wasting
any more time, and I don't want a letter writing campaign that is going
to take a month to get back and forth. I would also like to suggest to
the group here that we convene again in three months and in effect serve
as the board of directors to listen to what has been done in the three-
month period, to keep this issue on track, and see where we might have
to go from here. What do you think of that?
Will Brown: Why not? I would like to respond to the question the
Virginia gentleman asked a while ago, it is a very difficult question,
and that is how each State stood with regard to that resolution. Well,
New York is gone, I hate to say this after Bob Flacke's departure—it
would seem as though I was afraid of him being bigger--but he neglected
to mention that the original draft that was submitted to NESCAUM, out of
which this document grew, was drawn up in New Hampshire. Your question
was how does each State react or respond to that document. It is an
impossible question to answer because many of us saw that completed
document for the first time today. We have had no opportunity to refer
it back to our homeground committees. In New Hampshire's case, that
would be the Acid Rain Coordinating Committee which I chair, or, more
importantly, our Governors. If EPA or this steering committee that may
derive out of STAPPA were to see fit, they could write each State within
the next suitable period and enquire how they stand on it, after time
for due reflection and determination. That might be helpful.

Mr. Hawkins: All right, we are losing participants and at this time,
the schedule calls for summing up, so let me try to solicit a last round
of questions. I think we have agreement on the process for establishing
a follow-up subgroup of the States, and I would suggest that that subgroup
also be charged with the task of deciding whether another preliminary
session of the States in three months would be useful or not. George
Tyler, you had a question?
George Tyler: I was just going to suggest to you, if you would not
mind, assuming the possibility for reconvening a meeting like this
inside of three months, whatever happens . . . the subsequent review is
worth and also I am not sure I understand the problem that you forsee
with EPA participation unless maybe . . .
Mr. Hawkins: I am just being cautious, just being a lawyer.
George Tyler: I understand. Consider that seriously.
Mr. Hawkins: Yes, yes.
George Tyler: Before it gets too far along and then perhaps consider
the question of . . .
Mr, Hawkins: Yes, I assure you it does not represent any policy difference
with people who do not want EPA sitting on the sidelines holding up
score cards that say we will give you a five for difficulty and a six
for performance. We do not intend to take that role.
George Tyler: I was just trying to suggest that the solution to this
kind of a problem . . . not for any individual solution but just for a
solution. Someone to keep pushing and pulling things together and
getting people to sit down and talk. Anyone who has a regional interest
is not going to be trusted with doing that.

Mr. Hawkins: I suggest that all of you read Doug Costle's printed
statement opening this conference when you have the opportunity because
you may not have caught all the things he said as he delivered it. Let
me try to sum up in a couple of minutes what EPA is going to be doing
over the next few weeks. What I heard today did not suprise me. I
heard a variety of statements from different points of view. Statements
from States which perceive themselves to be the recipients of emissions
from other areas, who perceive that they are having adverse economic and
environmental effects in their States due to sources which they do not
have the jurisdiction to control. I heard statements from coal-
producing States which pointed out the political realities of finding a
coalition in the States which has an interest in producing coal, in
burning that coal to provide electricity to its own consumers, and which
has, apparently, yet to identify a collection of adverse impacts in its
own State resulting from those practices. Interestingly enough, something
that I heard yesterday was not stressed quite as much today, except just
recently by Craig Weidensaul, and that is that there may be adverse
impacts in the coal-producing States that are not necessarily identified
with the aquatic ecosystem acid rain effects that the Northeastern
States have been identifying but are identified with the one, two, or
several day episodes of very high levels of pollution affecting visibility
and elevated pollution levels especially during the summer which can
come from almost any direction and can come from States which are not
coal-producing States. It can come from States which may be burning
coal from a coal-producing State or maybe burning other fuels. So one
point that I would find useful to leave with all the States is: what

are the possible areas of common concern here? I guess if there was one
focus that would be most useful, it would be for each of the State
representatives to consider the problem from the perspective of the
State which he or she thinks is most apparently on the other side, if
you will. In putting together a political strategy for a solution,
because a political strategy as well as a legal and a technical strategy
is necessary, people have to help answer each others needs. The needs I
heard expressed by the Midwestern States were find a way of portraying
this so that it does not appear to our constituents to be all cost and
no benefits. The needs I heard expressed by the Northeastern States
were: find a way to convince your constituents to recognize that we in
the Northeast have been exposed to both costs of our own bearing and
yours. That we are being exposed to pressures to relax our environmental
controls which we do not want to relax because we do believe that there
are adverse impacts associated with increased levels of emissions from
our own sources as well as from yours. Find a way to communicate that.
I think from a State like Georgia or Pennsylvania which tends to have
some issues on both sides of this dichotomy, I heard the expression that
there are, in fact, States where this clear dichotomy is not present.
For all those things, it was not a large surprise, and to EPA it was not
a disappointment even, that there would be these expressions of concern.
But I think it is important for the States to hear them said directly to
each other, in a forum that is devoted to that purpose rather than
having a hallway conversation at the annual APCA meeting. We at EPA are
going to be doing the following things:

° Prepare a report on this conference which will be sent to everyone;
° Prepare a resource document on acid rain and sources, emissions,
technical fixes, economic, and social issues which will also be
made available;
° Analyze some of the issues that many of you pointed out needed to
be analyzed. What is the cost-effectiveness of coal-washing on a
regional basis, on a Statewide basis, on a plant-by-plant basis?
What is the cost-effectiveness of those techniques versus other
sulfur control techniques versus NO control techniques. Those
evaluations are in process as Lowell Smith indicated to you and in
May we will be reviewing them internally and we will be providing
them in a publishable form as soon thereafter as we can;
° Expand some of the nontechnical fixes like the dispatch system,
the early retirement. That we will be doing over the course of the
summer •,
° Put together a series of cost-effectiveness analyses that will
allow people to look at different techniques, see what they buy in
terms of emission reductions and how much they cost, different
packages with different costs and a whole range of alternatives;
° Continue the review of our current legal authorities to see what
holds promise for some early action to try to move in the right
direction on this problem and if we identify something that holds
promise, then we will pursue it. We hope we will have that review
completed in the next two months;
° Work on legislative options during the same timeframe so that we
will not have just one arrow in our quiver.

We are going to put ourselves in the position of having plausible
legislative options available either as a backup to current regulatory
initiatives or as a supplement. So we are going to be undertaking a
number of activities and we will be very happy to work with the States
and the various interest groups that we did invite as observers to this
meeting. For workability we did set up procedures that had the States
be the participants because it was the States that asked for a meeting
among themselves. That is where we are proceeding and we will follow
the suggestion of this group, that we ask STAPPA to establish a subgroup
that would provide a mechanism for the States to keep the ball moving,
but EPA will be keeping the ball moving as well and working with you to
do that. Tony.
Tony Cortese: I think there is another conclusion that we should also
reach. In the past two days, I did not hear anybody say that we should
not follow the President's initiative to burn more coal as long as it
was done in an environmentally sound manner. I think that conclusion
ought to come out very clear. We, the Northeastern States, are not
anticoal. We just believe that coal ought to be burned with the proper
pollution controls so that we do not endanger either our health, our
environment, or our economy. I think that conclusion ought to be one of
the ones that is reached as a report of the conference.
Mr. Hawkins: Very well. At the break, Doug Costle, at the break, told
me that he had been involved with a White House meeting which he was
going to attempt to reschedule in order to come back here and preside
over the conclusion. I assume, from his absence, that has not been
possible, so unless there is additional statements, and I see Ellis
Cowling has one, so I will not complete that sentence. Go ahead, Ellis.

Ellis Cowling: Dave, I think it is important for us to discuss, at
least very briefly, the issue of conservation. I am not talking about
mandatory conservation but rather voluntary conservation. I think it is
remarkable that this subject did not enter the discussions in this room
until 2:15 this afternoon. Does that mean that the States have no faith
that the American public will respond to leadership on the issue of
conservation in the interest of better fishing opportunities? What is
the potential for public education that would result in modified behavior
in terms of automobile use as Craig was indicating, in terms of their
own use of electrical power, on the issues of cogeneration of electrical
power, which is a policy that is not found in favor among the public
utilities, but is widely used in Europe. I think it is also important
for us to realize that our nation is very consumptive of energy. Sweden,
with a very similar distribution of population over a land area essentially
similar, use half as much energy per capita as we do and certainly enjoy
a much higher standard of living than we enjoy in North Carolina. So I
would hope that there might be some comments about the potential public
education on that.
Mr. Hawkins: George.
George Ferreri: Dr. Cowling I do not think anybody is ignoring the
potential of conservation, the benefits that could be extracted from it.
I guess if I may be a good bureaucrat, it is not my job to institute
conservation, there are other incentives being put forth by the Federal
government for the States that develop energy conservation programs which
are really the responsibility of other agencies. As far as the conserva-
tion of gasoline, the price is going to make people want to conserve.

We have been able to identify enough issues that we can handle, that we
have some direct control over to keep us busy for a long time, and again
it is not a case of whether we think conservation will work but rather
that we have enough problems of our own without trying to take on somebody
else's problems.
Dr. Cowling: Is that being done in Maryland?
George Ferrerf: Yes it is. If each State could come up with approximately
the same reductions, I think we would be eligible for some kind of a
bone that they would throw our way.
Dr. Cowling: In terms of percentages we have achieved a 9% decrease in
gasoline consumption in North Carolina, now that means a 9% decrease in
NO presumably. You were talking about near-term options that would
make a real dent in the SO and NO emissions, is it not feasible to
achieve 10%, 15%?
George Ferreri: It would be impossible to achieve a decrease in gasoline
usage now because the Governor is going to increase the gas line tax to
make up for the drop in revenue. We are all suffering from this.
Tony Cortese: Come to New England and see what has been going on for
the last three or four years because of the price of fuel and you will
see conservation and you will see industries that have cut down their
energy usage by 50%, and 40% by homeowners and drivers. If you want to
talk about a regional problem, you should see what happens to us with
allocation of fuels and basing allocation of fuels on historical records
by the Federal government which means the more you conserve, the less
you get in the future if rationing occurs. If you want to talk about
conservation, we have been there and we will continue to be there as

long as the price of oil and fuel is there. I guess that is why we did
not bring up conservation. Dr. Cowling, your point is very well taken,
we will continue conservation, but conservation has got to be uniform
across the country just like environmental controls have to be uniform.
Dr. Cowling: Yes, and I think we can learn from your experience and it
might be useful for EPA and the special committee that they are going to
be working with to examine such regulatory policies for the attitude of
the utilities cormiissions in States toward the issue of cogeneration.
Will Brown: The best way for an oil dealer to survive in New Hampshire
now is to go into the business of installing wood furnaces.
Mr. Hawkins: Well we have appropriately noted the opportunity that
conservation presents, it is one that apart from figuring out how to
convince everyone to do it, is obviously a very cost-effective approach.
I want to thank all of you for coming here. I think the conference has
been a good start. That is all it is though, is a start. We told you
what we are pursuing at EPA. We have a process established that will
allow the States to have a group that can provide a source of contact
for EPA and we will look forward to talking with all of you more about
this subject in the coming weeks. Thank you once again.