jknur, a iu in Li I Kta JU-KU Ulf" "l'H lu UISAJP i'KUVAJLi AND PROMULGATION
OP THE CALIFORNIA TRANSPORTATION CONTROL PLAN
I. EPA Hearing Transcripts and Exhibit Volumes
II. State of California Submlsalona and Hearing Tranncrlptu
XII • Federal Register Notices
XV.* Studies and Background Docuroenta
I. SPA HEARING TRANSCRIPTS AND EXHIBIT VOLUMES
Document
Number
1.
2,
3.
4.
5,
Transcript of EPA Hearings on the Proposed
San Francisco Day Area Transportation
Control Plan, August 8, 1973, (including
exhibits of letters and statements).
Transcript of EPA Hearings on the Proposed
Sacramento Valley Transportation Control
Plan, August 10, 1973, (including exhibit*
of letters and statements),
Transcript of EPA Hearings on the Proposed
San Joaquin Valley Transportation Control
Plan, August 6-7, 1973.
Exhibits to EPA Hearings on the Proposed
San Joaquin Valley Transportation Control
Plan, August 6-7, 1973.
Transcript of EPA Hearings on the Proposed
oan Dingo Transportation Control Plan,
August 7, 1973, (including exhibits of
letters and statements),
Transcript of EPA Hearings on the Los Angelas
Transportation Control Plan, Reproposal,
August 9-10* 1973, (including exhibits of
letters and statements). oz
Transcript of EPA Hearings on the Original
Loo Angeloo Transportation Control Plan
MhfhiJi' March 5-22, 1173, (including
•xhiblta of littiri and •Utementa) •
Page
Number
1-1543
1544-2453
2456-3117
3110-3912
3913-6133
€134-10216
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II. STATE OP CALIFORNIA SUBMISSIONS AND HEARING TRANSCRIPTS
Document
Page
muttbar EJBber
8« Transcript of a Hearing held May 18# 1973, 10217-10268
in Fresno, California, by the California
Air Resources Board on the Proposed California
Control Plan.
9• Transcript of a Hearing held May 21, 1973, in. 10269*10422
San Francisco, California# by the California
Air Resources Board on the Proposed California
Transportation Control Plan.
10* Transcript of a Hearing held May 23, 1973, in 10423-10488
San Diego, California on the Proposed California
Transportation Control Plan.
11* , Transcript of a Hearing held May 25, 1973, in 10489-10596
Sacramento, California on the proposed California
Transportation Control Plan.
12* Selected portions of California State * 10597-10715
Implementation Plan, submitted February, 1972.
13. " Selected portions of Revialon III to Calif6rnlal0716-10789
state Implementation Plan# aubmittsd April 18-
25, 1973.
XXX* FEDERAL REGISTER NOTICES
14. "Approval and Promulgation of Implementation '10790-10801
• Plans", 37 FR 10842-10906 (May 31, 1972).
IS* "Requirements for Preparation, Adoption, and 10802-10808
Submittal of Implementation Plans—Proposed
Transportation Control Measures", 38 FR
1464-1469 (January 12, 1973).
If* "California Air Quality Standards - Approval , 10809-10816
and Promulgation of Implementation Plana*
31 m 2191-2200 (January 22, 1973).
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Document Kagu
Number ttumbor
17. "Approval and Promulgation of Implementation 10817-10819
Plang—submission of Transportation and/or
Land Use Controls", 38 FR 7323-7330
(March 20, 1973)
18* "Requirements for Preparation, Adoption, and 10820-10826
Submittal of implementation Plans-Transportation
Control Measures", 38 PR 15194-15199
(Juno 8, 1973).
19, "Approval and Promulgation of Implementation 10827-10834
Plana—Approval of Transportation and/or Land
Use Controls", 38 PR 16550-16569, (June 22, 1973)*
20. "California Air Qualify Control Approval and 10835-10839
Promulgation of Implementation Plana" 38
17683-17687 (July 2, 1973).
21* "California-Approval and Promulgation of 10840-10876
Implementation Plans?^.38 PR 18948-18961
(July 16, 1973).
22* "Approval and Promulgation of Implementation 10877-10884
• Plans—Transportation and Land Use Controls?*
38 FR 30626-30633 (November 6, 1973).
23. "Approval and Promulgation of Implementation 10885-10909
Plans-—California Transportation Control Plan*#
30 FR 31232-31255 (November 12, 1973).
IV. STUDIES AND BACKGROUND DOCUMENTS
24. !'he Clean Air Act and Transportation Controls# 10910-10950
An EPA White Paper, August 1973.
25. Tnterim Report Dated October 1972 on Motor 10951-11010
v 'ticla Emission Estimation prepared by
t' -'id Kircher and Donald Armstrong,
26. Technical Support Document for the Metropolitan
I.nn Angeles Intrastate Air Quality Control 11011-11080
Hogion, January 15, 1973.
27# Technical Support Document for tha Metropolitan
hon Angolas Intrastates Air Quality Control .11011-11096
R«glon Riproposal, ftsly 13, 1973.
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Docu/nont Pago
Number Number-
28. Technical Support Document for the Metro- 11097-11198
politan Loo Angeles Intrastate Air Quality
Control Region Final Promulgation# October#
30, 1973, (Appendix B~Methodology for Determining
Ba3C Year pxidant Level).
29. Technical Support Document for the San Diego 11199-11292
Intrastate Air Quality Control Region Pinal
Promulgation, October 30 # 1973.
' 30, TRW Study entitled "Transportation Control 11293-11711
Strategy Development for the Metropolitan Log
Angeles Region", December, 1972.
31. TRW Study entitled "A Survey of Air Pollution ) '11712-11770
in Critical California Air Baflisn", March,1973#
32* TRW,Study entitled "Air Quality Implementation 11779-11930
Plan Development for Critical California Regional
Summary Report"# July# 1973.
33* TRW Study entitled "Air Quality Implementation 11931-12213
Plan Development for Critical California Regional
Sacramento Valley Intrastate Air Quality Control
Region", July, 1973. '
34* TRW Study entitled "Air Quality Implementation 11214-12666
Plan Development for Critical California Regional
San Joaquin Valley Intrastate Air Quality Control
Region"# August# 1973.
33, TRW study entitled "Air Quality Implementation ,12667-13044
Plan Development for Critical California Region!•
San Francisco Bay Area?Intrastate Air Quality
Control Region"#-July# 1973.
36« Thesis submitted May 24# 1973# on An Economic 13045-13435
Air Pollution Control Model Application: Photo-
chemical Smog in Los Angeles County in 1975 by-
John Charlc3 Trijonis# Jr.# 2 volumes.
37« Report on Profile of Air Pollution Control by C* 13436-13521
Air Pollution Control District of Loa Angeles.
38. Coat Effectiveness of Strategies for Reducing 13522-1 IMS
Emiioionn from Fixed Source* • a ftand-XAEH *
Report, October, 1973.
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°oc!font SSSbor
Number
39. The Motor Vehicle Emission and Cost Model 13646-13740
(MOVEC)J Model Description and Illustrative
Applications - a Rand-IREM Report, October,1973#
40. A Policy-Oriented Urban Transportation Modal I 13741-13863
The San Diego Version.
41. Regulation 2, Paragraphs 1302.2, 1308, and 13864-13867
13011.1 of tha Bay Area Air Pollution Contirol
District. .
12* Rulca 11 (h) , 13, 61, and 63 of tha San Diego 13068-13877
County Air Pollution Control District.
43. Better Air and Commuting - Now - Phil Ashabraner,
April, 1971. 13878-13920
44» Los Angeles Photochemical Smog - Past, Present:# 13921-13932
and Future, Los Angeles Air Pollution Control
District, June, 1972.
I3« Position of the City of Los Angeles Relative to 13933-13930
the Transportation Control Strategy as Propoaad
by the EPA, January, 1973.
46* Comments on California Air Quality Standards I , 13939-13952
Transportation Control Strategy, Alan
Eachonroeder, undated.
"47. Revisions to Regional Transportation Plan as 13953-13994
Adopted-Metropolitan Transportation Commission,
June, 1973. • "
48. Proposed Strategies for Transportation Control® 13995-14088
Metropolitan Transportation Commission,August,
*1973.
49. A Plan for Action on Air Pollution Metropolitan 14089-14129
Transportation Commission, November, 1973*
t
B0. Smog- A Report to the People, California 14130-14303
Institute of Technology, undated.
51. Southern California Ass'n of Governments- 14304-14312
Schedule to Implement Short Range Program, undated.
22* Traffic and Transportation Analysis for the 14313-14355
Metropolitan Lot Angeles Araa of California*
McRaa-Adaaii C* 9 undated.
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Document
:iumbor
53. Systems and Costa to Control Hudrocarbon*
from Stationary Sources, Burr and Boyse#
undated.
54. Results of California Poll, Juno 26, 27,
and 28, 1973.
55. P rcaa Conference Transcript, William D.
Ruckelshaus, Los Angeles, January 15, 1973#
56. Can Vehicle Travel Be Reduced 20 Percent III •
The South Coast Air Basin?
57. Letter from Ralph Bennett, Chairman, South
Connt Air Baain Coordinating Council, to ' 1
Southern California Rapid Transit District#
transmitting recommended pollution control
plana for Los Angeles, February 8, 1973#
58. "Carpool and Bus Matching Guide (Second
Edition)", U.S. Dept. of Transportation,
May, 1973.
59. Department of Transportation, Inventory of
Resources Available Through .the U.S. Dept.,.
of Transportation to Support Transportation
Programs Significant to improvement of Air
Quality, undated.
60. Comments of the Natural Resources Defense
Council on Transportation Controls, September
1, 1973.
61. Report dated June 15, 1972, on Control of
Hydrocarbon Vapor Losses During Marketing of
Ganolino at Service Stations, by Standard
oil of California.
62. Paper prosonted on June 24-28, on Hydrocarbon
Vapor Control at Gasoline Service Stations,
V retire and Scoff, County of San Diego JUPCO
(paper presented to APCD)•
Pago
Number
14356-14404
14405-14418
14419-14452
14453-14603
14604-14605
14606-14641
14642-14663
14664-14739
14740-14784
14785-14808
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Document
Number
53, Study dated January, 1971, on feasibility and
Evaluation Study of Reserving Freeway Land for
Buses and Carpools by Department of Trans-
portation, Federal Highway Administration by
Donald G. Keppele, Voorhees, and Associates.
64. Interim Report dated April, 1973, on Cost
Effectiveness of Methods to Control Vehicle
Rafuoling Systems, Phase X, AP1~EF-14»
<55, Progress Report on Highway Public Trans-
portation from Urban Mass Transportation Admin-,
istrator and Federal Highway Administrator to
Honorable Claude S. Brinegar, with attachment#
August 6, 1973.
66* Letter to Washington Star-Newa from Norbett. T» 15194-15195
Tiemann, Federal Highway Administrator#
published July 26, 1973. I
67. Statement by Robert W. Fri, Aating EPA 15196~152194^«,
Administrator, July 27, 1973.
68. Opening Statement by Robert ,W. Fri, Acting EPA 15220-15233
Administrator, June 15, 1973.
15231*15245
69. Letter from William J, Speedie to David
Souten, enclosing Report of Traffic and Off-
street Parking Committee, Loo Angeles City
Council and motion of Councilman Bernardi#
June 5, 1973.
i
70# Letter from Robert G. Luncha to Regional 15246-15249
Administrator, EPA,Region tx, March 22, 1973.
71. Remarks by Claude S. Brinegar before L.A. 15250-15256
Chamber of Commerce, May 16, 1973 (partial}.
72. Letter from Benjamin 0. Davii£ to Robert If. Fri 15257-15267^,
May 10, 1973, with attachments.
, •
73. Article by Norman 11. Topping, President# 15268
California Rapid Transit District* Los
Angeles# Times# March 26# 1973.
Pago
Number
14809^1501*
15017-15176
15177-15193
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Document
ftumbcr
f
Page
Number
74, Oxidant Distribution and Analysis in the San 15269-15299
Bcrnadlno Basin, by Melvin D. Zeldin, S.B.
County A.P.C.D.,Tcch. Report 73-1,March, 1973.
75# Transportation Controls for Clean Air, Project 15300-15355
on Clean Air, Natural Resources Defense Council#
undated (late 1972 or early 1973).
7$» Report dated November, 1972, on Control Strategies
for In-Use Vehicles by office of Air and 15356-15361
Water Programs, Environmental Protection Agency.
77# Technical Support Document for the San Francisco
Day Area, Sacramento Valley, San Joaquin Valley 15362-15617
and South Coast Desert Interstate Air Quality
Control Regions transportation Control Plan
Final Promulgations.^
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CONDENSED COMMENTS
FRESNO TRANSPORTATION PLAN HEARING 8/16/73
Air Resources Board
The board presented Dr. Haagen-Smit1s letter to Acting
Administrator Pri as well as a description Number 3 of the
Air Implementation Plan. This same presentation is summarized
in other hearing summaries. ARB has tested catalytic con-
verter equipped autos and does not think the loaded dyna-
mometer test is necessary to check operation. ARB is consid-
ering motorcycle emission standards.
State Government
CALDOT does not think that a crash program will solve the air
pollution problem. Solution will require basic changes in
California's perceptions, attitudes and life styles. CALDOT
will submit a draft plan and final by October 15. They will
submit statistical data and identify routes for which
bus/carpool lanes are unsuitable. CALDOT is currently pre-
paring an EIS on the Fresno freeway/traffic system which will
also integrate with the regional transportation plan.
Regional Government
Fresno Board of supervisors generally disagree with all meas-
ures, feel that their county has been a leader in the field.
Will support catalytic retrofit if lead-free fuel and devices
are available. Parking restriction assumes that facilities
are at capacity? they aren't. Controls will not be effec-
tive. Few corridors are suitable for special lanes. Support
inspection/maintenance, but not the expensive loaded dyna-
mometer test. Should develop motorcycle emission standards.
Deadlines are unrealistic,
San Joaquin County Council of Governments will submit official
comments later. Feel that small towns will be unnecessarily
penalized by parking reduction. Don't think much more than
1.4% VMT reduction will result from carpools, parking reduction
and public transit. Have received UMTA funding for a transit
study. Some bus lanes could be US 99 and I 5, but more impor-
tant to have a good bus system first. Some imported oxidant
from the Livermore Valley; need further study.
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A supervisor from Kern County feels that EPA is encroaching on
local rights of land use control. EPA will have to implement
its plan without local assistance. Supports ARB position.
Local Government
Mayor of Fresno commented in detail about the proposals em-
phasizing that the controls are written for urban areas and
would not work in Fresno. Parking reduction would halt all
construction in the area, especially downtown revitalization.
Support alternatives to auto-commute, such as reduced bus fares
and bicycle routes. 95% vapor-recovery from gas stations is
not supportable economically or technically. Suggests limiting
truck deliveries to night hours, computerize home deliveries,
four-day-week, 20% reduction of monthly parking permits.
New parking construction permit processing could cause great
delays. Existing parking lots are scaled for holiday peaks
(Christmas) during which businesses do one-third of their
yearly business. Only five streets are suitable for special
lanes, signing will be very expensive. Buses will be expen-
sive and also operational costs will be high. Organic solvent
regulation may restrict paints used for pavement marking.
Tulare has reduced their parking by 50% in the course of a
redevelopment project and are just beginning to replace it.
Parking restriction would be deleterious to the program.
Oakdale has no identified public transit need. Experience
heavy recreation traffic through town and have lobbied for
a bypass. Request exemption to special lanes and parking re-
striction until Oakdale's growth indicates a need for such
a project.
Traffic Engineer for Fresno cited studies that indicate reduced
VMT after their renewal project provided downtown parking,
suspects advantages in providing more parking downtown and
college area. High peak traffic around the IRS building indicates
a car-pool potential. Are developing plans for a second
city center. Recommends a word change to "publically owned
and open to the public" to protect emergency vehicle parking.
Auto/Motorcycle Industry
Automobile Club of Southern California submitted their com-
ments on the plan proposed for Los Angeles. Feels that the
government's program for improved air quality should be com-
pletely re-evaluated. Does not think enough data exists to
support such stringent controls.
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Motorcycle Dealer's Association advocates emission standards
for motorcycles. The industry will meet standards, American
Motorcycle Association supports setting emission standards
and emphasizes advantage of fuel conservation. Thinks two
years will allow development of technology to control motor-
cycle emissions.
Petroleum Industry
Various oil jobber representatives pointed out the desireabil-
ity of an under 2000 gallon handing exemption based on prac-
tical use and existing equipment. Thinks that drop tubes
should be required in bulk delivery facilities. Prefer higher
fuel cost to limiting availability of fuels. Small jobbers
need to know what the requirements will be for vapor control
and what equipment will meet those requirements, do not have
money for experimentation.
Groups
Fresno Community Council advocates an adjustment time for pub-
lic and economy. Should reorganize city-county boundaries to
reflect need for environmental planning. Support public transit,
bicycle paths, car pools, inspection, reduced speed limits.
Federal funding will be needed for public transit. Might be
more effective to eliminate on-street rather than off-street
parking. Gasoline rationing should affect individuals as well
as distributors. Oppose motorcycle restrictions. Bicycles
should be encouraged. 42% of commute trips in Fresno are
less than five miles long. Public use of bicycle lanes has
not been studied. Cited many cases of land use consideration
which should be coordinated with transportation controls,
Merced Sierra Club supports special lanes as long as congestion
is not severe. Supports motorcycle restrictions. Aircraft
should be required to improve passenger/capacity ratio. EPA
should provide regional planning teams to aid local communities.
Project Land Use thinks that stationary sources need more control.
Gasoline prices should be allowed to rise. Mutimodal transit
should be stressed rather than mass or rapid transit. Should
regulate land use decisions that deteriorate air quality.
EPA should comply with non-degradation decisions.
Downtown Association believes that parking restriction would
only affect Christmas parking. Streets are not so crowded that
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buses would gain a time advantage with special lanes. Free
transit would help public acceptance, as would higher
gasoline tax.
League of Women Voters encourage publicizing pollution data.
Lower speed limits should be studied. Capital and operation
assistance of public transit is necessary. Recommend inter-
city high speed trains and intracity bicycle paths. Enforce-
ment will require much manpower. EPA*s plan is geared to large
metropolitan areas. Suggest a flat $1 fee for all parking
to subsidize public transit. Private parking would also have
to be regulated.
Motorcycle groups react strongly to proposals. Standards
should be determined and extensive tests performed to determine
motorcycle's role. Should differentiate between different
displacement engines as well as two and four stroke. Controls
should not involve a retrofit or operating restrictions.
Citizens
Several motorcyclists indicated the approximate life of two-
stroke motorcycles as being rather short (2-4 years).
Motorcycles are efficient, congestion-reducing transit. Reduce
horsepower, size and weight of automobiles. Others advocate
use of bicycles especially in valley towns where terrain is
level. Object to stringent motorcycle controls, feel the
Federal Government is discriminating. Some would be denied any
transportation at all if motorcycles are restricted. Motorcycle
emission standards should be established. Of the citizens that
mentioned motorcycle controls, all were opposed to EPA1s propos-
als .
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SUMMARY OF TESTIMONY PRESENTED ON
TRANSPORTATION CONTROL PLAN
AT HEARING HELD IN FRESNO
AUGUST 6, 1973
2 Mr. Eckerman, EPA; Opening statement
6 Mr. Calkins, EPA; Opening remarks (with interruptions
from the floor)
26 Mr. Mueller, EPA; Explain auho emission testing
28 Mr. John Krebs, Chairman, Board of Supervisors
Fresno County has continuously assumed a leadership role
in air pollution control in San Joaquin County through
the implementation of reasonable air pollution control
measures. Supports inspection/maintenance, but loaded
dynamometer is too expensive and ARB has stated it is not
effective in determining efficiency of some devices.
Compliance schedule is unrealistic. Supports catalytic
retrofit if devices and non-leaded fuel available. Fuel
rationing would adversely impact agricultural economy.
Motorcycle restrictions are unrealistic. Should develop
emission standards and control equipment instead.
Parking restrictions may work in urban areas, but in the
San Joaquin Valley, where mass transit is not really
practical, they won't. Strategy assumes that lots are
currently at capacity. Would shift people to private
parking facilities at shopping centers with an increased
VMT. Exclusive lanes are not applicable to Fresno, in the
few corridors in which they would be required, they would
disrupt continuous traffic flow. Board supports reduction
of maximum speed on rural highways. Existing regulations
for stationary sources are adequate. Dry cleaning es-
tablishment controls are unnecessary and not cost effec-
ive. Fuel evaporative loss control appears to be im-
possible, and not cost effective for small dealers such
as those with 2,000 gallons per day throughput. Do
NEPA under CEQA apply? Board supports the need for such
an analysis. Feels that time constraints are unrealistic.
41 QA Mr. Krebs
Parking surcharge would not discourage trips. Doubts
that it would encourage bus ridership. Would push people
to outer fringe shopping areas.
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44 Hon. Ted Wills, Mayor, Fresno
Fresno is not analagous to large metropolitan areas.
Parking restrictions would halt all local construction due
to parking requirement of zoning ordinances. Agrees
with concept of improved air quality. Secondary effects
of implementation appear to be severe and out of propor-
tion to benefits expected. Support cost-effective in-
spection/maintenance if coupled with reasonable imple-
mentation schedule. City is cooperating with regional
planning effort. Support alternatives to auto-commute.
Are supporting reduced bus fares and bicycle routes.
95% vapor recovery is ?*.ot supportable either technically
or economically. Revenues from various auto oriented
taxes would have to be replaced, could require changes
in SB90. Parking regulation will interfere with downtown
revitalization program by prompting travel to fringe
area shopping centers. Police activities would also be
diverted to expand traffic enforcement. Clean Air
Act must be re-evaluated as well as standards. Limit
engine size and enforce emission standards to reduce
pollution. Plan is designed for urban areas like Los
Angeles , not rural areas like Fresno. Agree with ARB's
criticism of loaded dynamometer tests. More effective
measures could be more one way streets, bus and bicycle
lanes and more effective signalization. Also could elim-
inate on-street parking, equally reduce all parking,
limit truck deliveries to night-time only, use two-way
TV to reduce trip need and computerize deliveries.
Four day work week appears to be a viable alternative.
Request an environmental impact study be prepared.
52 Specific comments on public parking reduction. Reduction
would only impact December parking levels, and would be
unreasonable because one-third of retail sales are made
in December. Suggest simply a 20% reduction of monthly
parking permits in public parking facilities. Regulation
could be circumvented by selling facilities to private
operators. Fears great delays in permit processing, could
result in drastic slowdown of construction in Fresno
area.
57 Bus/car pool lanes will create problems due to inadequate
street system, cost of signing and marking, conflicts
with other traffic and enforcement. Only five streets
contain short segments that would meet the criteria.
Cost of intersection signing would run $1,500 to $3,000
each depending on construction, more if they were illum-
inated . Pavement painting would be comparable on a per
mile basis.
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60 Even expanded bus systems are impractical in Fresno
due to dispersed low-density development. To provide
a tripling of bus service would require $1,800,000 for
buses and $2,800,000 for operation cost per year.
Motorcycle restriction on two stroke machines is unen-
forceable. Gas rationing does not provide for essential
services. Even if it was equitable it would be complex
and costly to administer.
63 Organic solvent regulations may restrict use of paints
currently used on street painting for traffic control.
Vapor reduction from fuel handling operation should not
be required until technology is available. Would also
affect fuel pumps at fire stations. Will government be
able to respond in a timely manner to all submittals
required by these regulations?
68 Mr. Allen B. Lemmon, Air Resources Board
Entered Dr. Haagen Smit.'s July 9, 197 3 letter to Mr. Fri
in the record (summarized in San Diego Hearing summary).
Described Revision 3 of the State Implementation Plan
(summarized in other hearing summaries).
87 QA Mr. Lemmon
ARB facility at El Monte has tested catalyst fitted
vehicles and is of the opinion that operation can be
tested without loaded dynamometer testing mode. Suggested
additional technical coordination. ARB is considering
motorcycle emission standards. ARB does not compare air-
craft and motorcycle emissions in the basin.
90 Mr. R. H. Ramey, Department of Transportation, State
oT California (CALDOT)
Essentially agrees with the City Council and Board of
Supervisors. Is also representing District X (Merced,
Mariposa, Stanislaus, Tuolumne, San Joaquin, Amador,
Calaveras and Solano countines) as well as his own
District VI (Kern, Tulare, Fresno and Madera counties).
Air pollution is a recognized problem, agrees with
intent of Clean Air Act but not with a crash program.
Solution will "require basic changes in California's
perceptions, attitudes and lifestyles. We will have
to restructure our economy, reallocate our resources and
develop new technologies." This requires time, money
and citizen support. Standards and deadlines are in-
appropriate and unattainable and must be changed.
CALDOT will submit a proposal by October 15.
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93 OA Mr. Ramey
CALDOT will provide statistical data. Will identify
those for which bus/car pool lanes are unsuitable.
Freeway access can be an important part of revitalizing
the downtown area. Are preparing an EIS for the whole
Fresno traffic area. It will be used in developing the
regional transportation plan.
100 Mr. Wilson Burum, Fresno Community Council
Most Fresno residents want clean air. Introduced
speakers: Chuck Moran, Ernestine Leas, Henry Carter,
Bruce Morris and Steven Ross.
102 Mr. Moran (Fresno Community Council)
Summarized oxidant levels since 1963 in the Fresno
area. Discussed a course offered at Fresno State College
on effects of air pollution as a public education process.
Pointed out agricultural impact of air pollution.
Supports the intent of the EPA plan. Regulations must be
fair to all segments of society, reasonable and effective.
Adjustment time for local communities and the public must
be worked into the time table. Economics will take
even longer to adjust. It took fifty years to develop the
lifestyle of today: dependence on automobiles. Cities
have not been planned, they have just evolved, more an
indictment of decision makers than of planners. Support
public transit, bicycle paths, car pools, inspection,
reduced speed limits, improved traffic flow, reorganization
of city-county boundaries, regulate traffic at high school
and college.
114 Mrs. Ernestine Leas (Fresno Community Council)
Too bad Clean Air is not a patriotic goal. Discussed
activity of their transportation committee. Advocate
expanded bus service, Federal funding is necessary to go
further. Motorcycle restriction is unfair. Might be more
effective to eliminate on-street rather than off-street
parking.
120 Mr. Henry Carter (Fresno Community Council)
Is a bus driver. Committee feels that the valley has the
potential of a very serious air pollution problem. Need
to attract ridership to public transit. Local bicycle
lanes and bus passes can be implemented. Gas rationing
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should apply to individuals as well as distributors.
SB325 funds should allow cities more flexibility. Motor-
cycle regulations are opposed, must apply equally to all.
Bus service should be expanded.
123 QA Mr. Carter
Peels that parking reduction is feasible. But, public
transit must be adequate—less than 30 minute intervals
between buses is necessary.
124 Mr. Bruce Morris (Fresno Community Council)
Bicycles should be seriously considered. Are conducting
studies of use in local area. Currently less than five
miles of bicycle lanes in Fresno. 42% of work trips are
under four miles with single occupant in auto. Bicycle
could be substituted.
129 QA Mr. Morris
No statistics available on public use unless city devel-
oped some with the Barstow Avenue bicycle lane. Thinks
encouragement is more valuable than regulating. Wx 11
submit some information prepared by Friends for Bikecology.
133 Mr, Steve Ross (Fresno Community Council)
Transportation and land use planning cannot be separated.
EPA plan must be coordinated with regional and local land
use planning. Discussed EIR's being prepared for pro-
posed freeways 41, 168, 180. Have seen too many examples of
freeways disrupting land use planning. Several issues
need resolution:
1. Role of freeways as inter- or intra-city transit.
2. How to avoid dependence on freeways as local traffic
problem solution.
3. Phasing of street design with land use policies. Could
result in decentralized business within walking distance
of most residences.
4. Signalize for traffic flow, not service to businesses.
5. Economic incentives to influence orderly land use
development. As president of another group, urged that
an environmental impact report be prepared for EPA's
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proposals. Give motorcycles a chance, set emission
standards. Phase out on-street parking. Bus rationing
will be difficult to administer equitably,
¦^3 QA Mr. Ross
Suggested a chartered bus with employer coordination to
provide bus commute in areas where normal routes would be
impossible. Suggested free downtown parking.
146 Mr. Paul Mellon, San Joaquin County Council
Comments submitted are those of the staff, written comments
will be submitted. Time frame is too short to expect the
kind of alternate mode transportation planning that should
be done, to be accomplished this year. Major problem
seems to be centered in urban areas like Stockton, but
the regulations are imposed county-wide. Feel that the
small towns with one public parking lot are going to be
unnecessarily restricted. Doesn't feel that car pools and
public transit and parking controls will reduce VMT more
than 1.4%, not the 32% EPA claims is needed. Wants long
range solution to the problem. Even tripling the bus
service will minimally improve VMT. Have received a
UMTA grant for a transit study. State highways through a
town of 5,000 would be required to have a bus lane.
153 QA Mr. Mellon
Bus lanes could be on US99 on the east side and 15 on
the west. First thing is to get a bus system that works
though. Have some oxidant importation from Livermore
Valley, but more monitoring stations would be needed to
determine exactly what is happening.
157 Mr. Len Dredge, City of Tulare
Have spent $3 million on redevelopment which has reduced
parking by 50% and are about to restore some of it. To
deny this replacement would kill the program. Does not
have streets amenable to special lanes.
159 Mr. Vince Desimone and William Reno - Automobile Club
57 Southern California
Are concerned about the impact of the regulations on the
southern California community. Auto Club supports car
pooling and bus priority. Program for improved air quality
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does require a complete reassessment, including cost-
effectiveness, social and economic impact, and technical
feasibility. Questions support for ambient air quality
standards. Does not feel that the supporting data
justifies the stringent measure proposed. Entered ACSC
comments on Los Angeles Plan (not summarized here).
189 Mr. Warren Spacy, City of Oakdale
Oakdale has no public transit system and no identified
need of one. Have lobbied for some time to reroute
through-recreational traffic around the city. Requests an
exemption of bus/car pool lanes and parking limitations
until city's growth indicates a need for such compliance,
192 Mr. Leon Christiansen, Motorcycle Dealers1 Assoc.
Discussed the role of motorcycles in energy-short cir-
cumstances, and in the economy of the San Joaquin Valley.
". . . it is impossible to believe that it can contribute
as much pollutant as that of an automobile." Should set
emission standards for motorcycles with a compliance
schedule.
197 QA Mr. Christiansen
Business has already dropped off as a result of the pro-
posed ban on cycles. Peels that the industry can meet
standards.
199 Mr. Hal Keener, motorcycle dealer, rider
Cited noise control as an example of setting standards
and compliance schedule. Feels that cyclists are being
discriminated against. Motorcycle industry is impor-
tant and is geared up and regulated on a 12 month year,
not the 6 month year proposed. Cited efforts by
Japanese cycle industry to control pollution. Motor-
cycles tend to reduce.congestion. In January, 1973
4650 motorcycles were registered from Bakersfield to
Northern border of California. In the control area,
1783 motorcycles were registered in that period. En-
forcement would be very difficult.
212 QA Mr. Keener
Average life of motorcycle is probably around three
years. Thinks controlled motorcycles could be produced
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in 1976. Doubts that cycles are ridden even 4,000
miles/year. If that mileage was on an off-road used
cycle, it would be heavily worn,
215 Mr. Dolph Ruschhaupt, California Oil Jobbers Association
Recognizes the need for control, expect the achievement
of control to cost a lot of money, however, controls
should be applied in a reasonable and sensible manner.
Equipment is not available. Suggest a phase in type
time schedule with additional basin by basin sequence.
Nothing short of 100% rationing would accomplish the
proposed reduction. Cost of controlling small volume
tank trucks will be very high compared to tank/trailor
vehicles. Recommends exempting aggregate storage fa-
cilities of 4,000 gallons or less with no one tank over
2,000 gallons. Should require drop fuel tubes which
reduce vapor emission 37%. Also recommend exemption
of small bulk facilities with less than 20,000 gallons/day
throughput.
223 QA Mr. Ruschhaupt
Would rather have higher taxes on fuel than no supply.
Cost of recovery equipment could run to $1,000/compart-
ment on a trailer tank, more for a tank truck.
226 Mr. Joe Hohenshelt, petroleum jobber
Cited National Petroleum News Magazine article that in-
dicated costs of vapor recovery systems. Would business
loans be available to retrofit service stations? Could
not afford to do it himself without a price raise. Ad-
vocates a mandatory vehicle inspection every six months.
Favors mandatory speed control on highways with reduced
speed limits. Supports continuing LP gas exemptions
beyond 1975.
231 QA Mr. Hohenshelt
Cost is estimated at $4,000 - $6,000 per service station
(6 pumps) for vapor recovery equipment. Has been put on
a list for truck conversion, has a waiting list that puts
him four and a half years from being converted. The bulk
facility would require $20,000 - $80,000 unit unless
the vapors are just trucked back to the distribution
center.
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233 Ms. Luci Edwards
Buses pollute worse than anything. Mr conditioners also
contribute to air pollution.
237 Mr. Bruce Young, Merced Sierra Club
Supports EPA plan. Driving record could be included in
the controls to reduce speeders, alcoholics and drivers
with poor records. Supports special lanes as long as
congestion of other lanes is not severe. Supports motor-
cycle restrictions. Parking is presently ample. Replace
parking areas with lawns, trees and other vegetation.
Enforcement of special lanes would be a problem. Too
bad EPA depends on conventional alternate transit facil-
ities—car pools, trains. Public transit should be attrac-
tive, safe, fast, accessible, economical. EPA should
provide regional planning teams to aid local communities.
242 Aircraft control demands much greater consideration.
Limit flights per day, increase efficiency of use, en-
courage low-cost charters, control military aircraft near
urban centers.
242 Project Land Use
Disagree with premise that control of hydrocarbon emissions
will reduce oxidant concentrations. Stationary sources
need more control especially those emitting hydrocarbon
and nitrogen oxides from oil production facilites. Mon-
itoring is inadequate. Feel forced to respond even with
the disagreement above. Provide rapid rail and air
transportation connecting major valley cities from
Bakersfield to Sacramento. Gasoline price should be al-
lowed to rise. Remove subsidies to oil industry. Multi-
modal transit should be stressed rather than mass transit
or rapid transit—including bikeways, bus routes, etc.
Should regulate land use decisions that deteriorate air
quality. EPA should adopt and explain complex source
regulation. EPA should comply with spirit and letter of
non-degradation decisions. Motor vehicle manufacturers
should produce a safe, clean passenger vehicle.
247 Mr. Mike Henshaw, American Motorcycle Association
Cited energy and space advantages of motorcycles. Air
pollution benefit is negligible in comparison to benefits
of fuel conservation. Registration ceiling will encourage
junking motorcycles.
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251 QA Mr, Henshaw
Two years is his estimate of time required to develop
the technology to put emission limitations on motor-
cycles .
252 Mr. LeRoy Jackson, Supervisor, Kern County and
Director APCD, Kern County
Agrees that motorcycle controls are unreasonable. At-
tainment of the air standards is an impossible task.
Even though EPA disapproved implementation plans^pre-
pared by local governments, its own plan is, by -Its
own admission, impractical and unworkable. It is time for
EPA to evaluate its control program. Is EPA assuming
responsibilities in land use and transportation that
are meant for State and local governments? "Will not
be a part of wasting various resources in developing and
implementing a program that is determined, even by EPA's
standards, unworkable." Support comments and recommenda-
tions of Dr. Ilaagen-Smit of ARB. "I see no alternative
but for EPA to take on the program and run it itself. . .
and thereby eliminate completely the local control and lo-
cal responsibility."
258 QA Mr. Jackson
"... controls being proposed by EPA are basically insane
and unreasonable and unworkable." EPA should direct it-
self towards Congress for reasonable modifications, which
should place these controls with local government. Feels
that a formal regional government is not necessary, that
the Coordinating Council is working very well.
264 Mr. Daniel Green, motorcycle dealer
Doesn't think the San Joaquin Valley has a serious smog
problem, even with all the motorcycles that were used to
bring people to the hearing. Need re-evaluation of the
standards. Why not control the biggest polluter—cars.
Should reduce size, weight and horsepower. Set standards,
provide time to comply. Tested a cycle with borrowed
instrument and it was cleaner than a car.
269 Mr. James Roberts, Downtown Association, Fresno
Parking limit would have no effect on use of downtown
except at Christmas. Streets are not so crowded that
buses would be expedited by separate lanes.
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271 QA Mr. Roberts
In order to keep transit patronage increasing, would have
to make the individual car very inconvenient. Once that
was accomplished downtown, people would go to shopping
centers a greater distance away. Free transit might
be a desireable way to go. Favors increase gasoline tax
to provide a strong incentive for public transit.
274 Mrs. Marsha Lassiter, League of Women Voters
Support establishing air quality standards that will
protect public health, financial assistance to pollution
control, publicize pollution data, increase public par-
ticipation in hearings. Applaud inspections. Study
lower speed limits. Encourage control devices for motor-
cycles with compliance time. Need better public transpor-
tation, Capital and operational assistance for public
transit is needed. Parking limit would reduce VMT but
impact should be studied. Recommend intercity high speed
trains and bike paths within the city. Plan will need
more manpower for enforcement.
276 Marsha Lassiter, League of Women Voters, Fresno
Envi ronmenta I" Qua 1 i ty Commi 11ee
EPA's plan is geared to large metropolitan areas. Parking
reductions could be ineffective and may be unfair to
downtown merchants. Could also increase the number of
private parking lots. Perhaps should increase reduction
to 30% and include on-street parking around high density
employment. Private parking around shopping centers
should be included. Should exempt emergency vehicle
parking and hospital areas. Freezing gasoline supply will
increase public transit patronage, but system will have to
be considerably expanded in the city. The county system
will need even more aid in order to expand. Vapor
recovery system regulation must consider the lack of
efficient machinery available. Suggest a one-dollar
parking fee at all lots, revenues to be used for public
transit.
279 QA Mrs. Lassiter
League works with the city council, has no formal public
education activity. Have no position on car pooling but
would aid in its implementation if is finally proposed.
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281 Mr, Ron King, Nerry Brothers, Inc. (petroleum products
cTTs tributor)
Vapors from petroleum product handing represent only 5%
of stationary source emissions. Are affecting farmers,
small commercial accounts that use 500 to 2,000 gallon
tanks. Amount to "10% of these stationary product de-
liveries ." Clearly needed in large scale operations, but
is too expensive for smaller ones. Local APCD exempts
facilities with under 20 ,000 gallon/day throughput.
2,000 gallons is a good dividing point because it is a
common break between taking a compartment out of a big
truck or being delivered by a small tank-wagon delivery
vehicle. 50% of deliveries are farm and commercial with
other half to retail service stations. Need to know what
the requirements are, and what equipment will work, are
not able to replace obsolete or improper equipment. Is
the population willing to accept the changed quality and
standard of living implicit in fuel rationing?
286 QA Mr. King
Price break at 2,000 gallons due to increased handling
step. EPA's 550 gallon threshold does not reflect busi-
ness operation.
287 Mr. Fritz Weinschenk, bicycle rider
Safety of riders would be improved with bicycle paths.
Bicycles offer a great economic advantage. Used to be
able to see mountains from Fresno in the morning. Smog
has gotten worse. Fresno is ideal for bicycles, except
for lack of bike paths. Canals, railroads and freeways
are the greatest obstacles. EPA should come up with a
legal definition of a bicycle path. Buses and trains
should carry bicycles.
296 QA Mr. Weinschenk
Bicycles should be included with bus lanes and car pools.
297 Mr. Ernest Crum, motorcycle rider
Has had motorcycles last 9,000 miles. Motorcycles are
important. Control borders on fascism. Time to re-
place Mr. Fri for having said "this is our chance to
get rid of motorcycles." "Feds . . . recognized there is
a very low level of actual or potential pollution from
the bikes. It does this by exempting them from . . .
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smog attachments." "Bike engines run so much hotter
and more efficiently than automobile engines." Questioned
EPA research. Should also control motor homes, campers
pulling trailers and boats. Feels that Japan has good
public transit. Agrees that Fresno needs public transit.
The "Valley has been denied passenger service while tax-
payers' billions build more roads." Should try a gross
revenue tax on engine displacement. Would be an incentive
for smaller cars and motorcycles. Should be more severe
on older autos. Even trains pollute more than motorcycles.
Thinks EPA should go after driving license exams too,
to improve driver quality. Should ban irresponsibly
maintained or equipped vehicles.
311 Mrs. Sharon Jacinto, Stanislaus Trail Bike Association
Motorcycle restrictions are "discriminatory, technically
unfounded, counter-productive, conservationally unsound
and economically unjust." "EPA is losing the battle of
the automobile and has decided to find a weaker opponent."
EPA could win, but air will not be cleaner. Set standards
for motorcycles and provide time to comply. Test was
inadequate—should test every brand of cycle for sale.
Classification does not describe various displacement
machines, just two or four stroke. For every motorcycle
that is banned, a car will replace it. Congestion,
•parking problems, air pollution and fuel shortage will
get worse.
316 Mr, Leslie Philbrook, motorcycle rider
Have been a self-sustaining citizen for 40 or 50 years and
will be forced onto public assistance when motorcycles
are banned. Rides 200 miles per month. Is licensed to
drive only during daylight hours, EPA restriction would
prevent him from driving at all.
320 Mr. Russ Sanford, Motorcycle Riders and Enthusiasts
Worst polluting vehicle he saw on road today was a
State of California gravel truck. There has never
been a Legislative proposal to put emission standards
on motorcycles, The EPA proposal came as a total sur-
prise. Motorcycle industry is anxious and willing to
develop needed emission controls. Standards should be
based on adequate testing, imposed on a reasonable
timetable, should not involve retrofit, should have no
other operating controls or restrictions imposed on them.
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EPA "... should be geared to the public's expressed
needs and desires."
329 Petition opposing the motorcycle regulations signed by
95 people.
August 7, 1973
2 Mr. Eckerman, EPA - opening comments
2 Mr. Anders
New freeways may attract new traffic and pass-through
recreatio:a-direct*sd vehicles. These vehicles will do
little to Fresno but pollute the air. But will forbid
a local motorcyclist from riding. Rides all year round.
Sould set standards for cycles. Has 8,000 miles on a
a two stroke motorcycle and anticipates 4,000 more.
Drives about 3,000 miles/year. Computer matching might
reduce traffic enough to reduce need for new freeways.
13 Miss Elizabeth Davis, Sierra Club
Need to work together to meet the standards and deadlines
of the Clean Air Act. Should control emissions of all
vehicles and mandatory annual inspections. Support a
full, balanced transportation system. Are participating
in development of bicycle paths. Will submit more
detailed comment later.
15 QA Miss Davis
Club is trying to alert its membership to the problems
that exist. Bicycle paths might provide necessary
safety factor for bicycle riding. Should provide for a
more effective and efficient bus system. Some streets
could effectively hold bicycle lanes, especially if they
don't have excessive auto traffic.
23 Mr. Ed Prince, motorcycle rider
Curbing motorcyle use would impact dirt and competition
motorcycles. Why aren't there regulations for racing
automobiles also? Those vehicles are completely uncon-
trolled. Off-road permits are effective for two years,
the EPA regulation would deny use of permits purchased.
25 M£* Floyd Terry, motorcycle rider
Insurance companies will have reduced revenues. People
won't buy cars if they will be unused due to car pooling.
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Thinks the motorcycle industry can solve the problem.
Bus service would have to begin earlier in order to
provide adequate commuter service,
31 QA Mr. Terry
Horsepower should be reduced. Driving behind buses makes
his wife sick, would never ride one.
32 Mr. Marvin Fitch, farmer, motorcycle dealer interest
Smog devices have wasted millions of gallons of gasoline.
Cannot continue the waste and corruption of the past.
Encouraging motorcycles will reduce pollution. Horse-
power is the problem; reduce it. Should correct two
stroke motorcycle emissions.
37 QA Mr. Fitch
The real problem with fuel economy has been increased
vehicle weights. Natural resource use is disproportion-
ate .
40 Mr. Steven Keltner
Pollution hurts plants and wildlife. Motorcycles are
more efficient than cars and would solve congestion
problems. If banned, would ride anyway.
44 QA Mr. Keltner
Would ride buses if that was required to clean the air.
45 Mr. James Whitmore, City Traffic Engineer
If space reduction is required, do not just rope off the
spaces but utilize them for wider spaces and aisles.
When they closed Fulton St. and made a mall out of it
10,000 trips disappeared from their studies, central
parking reduced VMT. More parking at the colleges would
also reduce VMT. Seriously doubts that individuals would
give up individual vehicles for public transit. Parking
is designed for December peak use. One-third of retail
business occurs in that month.
50 QA Mr. Whitmore
There are two kinds of parking occuring—1) long term
from commuters, 2) short term. Currently some lots have
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-16-
a turnover rate of 7. Are trying to reach 2 1/2. During
December the rate is 3. Short term average for rest of
year is probably 1.8. There is a higher demand for long
term parking than they are providing. VMT in the Fresno
area is increasing two to three per cent per year—slightly
higher than the population increase. No ongoing proposals
or programs to cut back growth rate. Are planning a
second city center which will change traffic flow and
work-home relationships. IRS facility shows a 15 minute
peak traffic flow in morning. Might be suitable for
car pooling. Surplus of parking has not attracted busi-
ness# has been stable for last two or three years.
Shopping center at First and Shaw took away some retail
trade. Currently give financial advantage to long-term
parking. Recommends word change to "publicly owned and
open to the public" in order to avoid cutting back on
emergency vehicle parking.
Mr. Marvin Fitch
Smog devices reduce power, necessitating purchase of higher
displacement engines for same power. Buses aren't
effective in the country-rural areas.
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105 Mr. Mark Braly
Is associated with several groups and has authored articles
on air pollution, but testified as an individual. Contested
charges that the plan is unreasonable and unnecessary. Is
challenged by the very people who should be working out the
details. What is unreasonable is the severity of the problem 25
years after local programs to eliminate it were launched. Is
encouraging that local agencies have finally gotten together to
talk about the Act. Their response, unfortunately, was essentially;
go away and leave us alone. Response of the Task Force Report is
inadequate and proposes only marginal programs whose benefits will
be counterbalanced by the 4% annual VMT increase that occurs despite
population trends.
Does not agree with the analysis based on smog chambers, and finely
tuned NOx hydrocarbon balances - what is needed is more stringent
emission standards. EPA's plan contains the major ingredients
of a successful program. Does not endorse EPA's compromise 30%
VMT reduction, it is a good starting point. Past programs are not
acceptable. Any VMT reduction must be accompanied by adequate
alternatives, and must discriminate against the private automobile.
The major flaw in criticisms of EPA plan is that freeway capacity
must be assessed in people moving capacity not vehicles. Fears
a self-fulfilling negative prophesy due to the local agencies
bearing the responsibility for implementation. Local agencies
should be searching for innovative funding instead of appealing
for Federal funding.
116 Should construct special lanes for bicycles, electric carts and
properly controlled two stroke motorcycles, or dedicate side
streets to such use. Sixty percent of trips are not commuter
oriented, therefore short trips could well be supplemented by
pedal or electric transit. EPA should communicate more with
local agencies and the public. EPA should open a Los Angeles
office and staff it with the best communicators it has.
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120 Mr. Bllheimer, Central City Association
Organization favors mass transit and sponsors programs
aimed at diminishing air pollution. Transportation control is
necessary but must be in accordance with the:
1. Mobility of workers and consumers.
2. Growth necessary for economic viability
3. Need for mass transit and individual preference shift.
4. Central city development reducing VMT
5. Diversity reduces applicability of broad-brush rules.
Questions wisdom of transit control without funding of alter-
nates and very tight time table. Feel encouragement and education
in the use of bus systems is more successful than disincentives,
Special lanes should be determined based on traffic studies.
Exclusivity of these lanes limits turning mobility. Cross-traffic
could reduce the benefits of exclusive lanes. Cost is prohibi-
tive. Would be under utilized if implemented. Parking restric-
tion would stop all construction of parking facilities in the
basin. Would apply to residential as well as commerical structures.
Criteria are unacceptably vague. Will result in increased VMT
and congestion. No alternatives are available for many people.
24% of commuters need their cars during the day. Regulations
should reflect local needs.
128 Recommends that the plan emphasize mass transit first along
with emission control of vehicles. Inspection, retrofits, and
evaporative controls would be next in priority. Voluntary pro-
grams can be implemented by employers which will reduce VMT
and not sacrifice economic viability. Gave several examples
including ARCO's subscription bus. However, nothing short of a
total fuel ban will achieve Clean Air Act standards. Act must
be amended.
134 Mr. Stuart Ross, Motorcycle Industry Council, General Counsel
Submitted a written statement. Feels that it was EPA,
not the Act that exempted motorcycles. Shares desire for a
clean environment but objects to motorcycle limitations. Restric-
tion assumes a lack of control technology and need stringent
controls to dramatize measures being taken, and that shift from
autos to cycles would be counter-productive. M.I.C. disagrees.
Technology exists for hydrocarbon controls, but Southwest Report
is inadequate data base for what EPA proposes. Disagrees with
basin wide emission loading attributed to motorcycles. Regula-
tion was not aimed at solving the problem at hand: cleaning
up motorcycles. LA-4 driving mode test is inappropriate for
motorcycle testing.
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Only 7 motorcycles were tested, the auto industry claims
that 1,000 vehicles is an inadequate sample. Two of the cycles
tested were not designed for freeway speeds. One had a ring problem
and a manufacturer claims that another had improper oil used
in it. Disagrees with average mile/year operation. Shows
2,808 miles/year for two stroke; 3,348 miles/year for four
stroke; while EPA claims 3,770 miles/year for all cycles.
Submitted documentation based on warranty studies. Emissions
of hydrocarbon are high; up to a factor a two for four-stroke
machines. This does not form an adequate data bese on which
to forbid use of motorcycles.
Question motorcycle registration growth projections. Is
not occurring as rapidly as projected. Using EPA's questionable
emission factors Project 23.7 tons/day hydrocarbon on December 31,
1972, about half of projected 1977 emission.
Peels that other criteria should be weighted to, such as
energy savings, parking facility and congestion relief.
Motorcycle industry should receive similar consideration as
was afforded the auto industry. Set standards now, and establish
compliance schedule.
153 QA Mr. Ross
Test results of emission will be submitted to EPA by the
manufacturers.
159 Mr. Leo Lake, Yamaha International Corporation
EPA should give motorcycle industry the same considera-
tion that it has to the auto industry. Yamaha will produce
machines emitting less hydrocarbon. Technology and desire exist
if Yamaha is allotted time. 1975 models will reduce hydrocarbon
by 50% of that of a 1970 model. 1977 two stroke models will
emit less than 5 g/mile. If motorcycles had not been exempted
previously, the technical communications gap would not exist.
Are developing population and usage data to aid in evaluating
motorcycle contribution to air pollution.
162 QA Mr. Lake
Doesn1t feel that a 90% reduction could be achieved by
1975. Will present statistical use data before the end of the
month. LA-4 test cycle would overestimate emissions. Retro-
fitting would not be feasible, both from a economic viewpoint
and spatial limits of the cycle itself. 1975 - carboration and
combustion chamber changes 1977 - includes cataytic or after
burner devices. Yamaha has been active in researching
emissions since 1970.
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16$ Mr. Dennis Hansberger - Southern California Association of
Governments
The Association has expressed basic support of efforts
to improve air quality. Any system must be practical in its
effectiveness, method and cost.
SCAG's basic planning strategy:
1. Improve and expand public transit
2. Programs to discourage auto use
3. Utilizing regional land use planning with local land
use control.
SCAG participated in the Joint Task Force. Recommends:
1. Improve EPA - Local communication
2. Continue efforts for cleaner air. Adopt California
emission standards,
3. Develop a multimodal transportation system,
4. Periodic mandatory inspection and maintenance.
5. Reduce administration processing time and expedite
implementation.
6. Uniform traffic control program.
7. Automated signal interconnects.
8. Freeway ramp metering
9. Special bus lanes
10. Subscription buses and car pools.
11. Fringe area parking for "park and ride."
12. Improve traffic operation
13. Standards for control of motorcycle emissions.
Many of above are similar to EPA proposals. Do not
support fuel rationing nor parking restrictions. SCAG supports
further investigation of emergency regulatory procedures that
would be instituted on those days when the oxidant standard
is forecast to be exceeded.
171 Urges substantial reallocation of funds for mass transit
construction in critical air quality areas. Supports develop-_
ment of a clean engine. Offers its services to EPA in continuing
to improve air qualtiy.
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172 QA Mr. Hansberqer
' Regional episode alert system would not necessarily be
run by SCAG. Each County has developed a plan for episodes
but they are not coordinated.
175 Mr. Dennis Hansberger, San Bernardino County Supervisor
(San Bernardino Associated Governments - SAHBAG)".
* Are"concerned over air pollution and are "determined
to deal with and conquer this problem."
Air pollution is mainly Imported from Los Angeles and
Orange Counties. As of August 31, 1973 they have had 18
community alerts and 6 first stage alerts. Two of West-end
communities have experienced 0.60 ppm oxidant. (One remained
at 0.6 for over an hour). Even though they can effect only
minimal improvement through own actions are determined to do
178 what they can. Are willing to absorb new mobility modes, economic
effects and life style changes in order to attain this air
quality end.
Have begun a comprehensive transit study to be completed
in April 1975. Also a 7 month UMTA funded study of a valley-wide
local bus system, to be immediately implemented. Have intiated
a local transit system (East Valley Transit System). Need pres-
sure to open up adequate and attractive corridor service to
Los Angeles, the beach, etc.
Are developing stringent stationary source controls -
a Utilities Management Plan.
Land use development must be constrained by air pollutive
secondary effects.
Feel a shift to a new engine will be necessary. A shift
to more efficient, smaller, non-polluting vehicles and fuel
sources can be accomplished by 1977.
181 The area is large enough to accomodate a special re-tooling
for their market with special standards to meet, (rotary,
stratified combustion, external combustion). Limit fuels to
synthetic natural gas during high smog seasons. Can develop
this alternate fuel supply in the time required. Would not
require retrofits.
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If all South Coast Air Basin communities committed their
SB 325 transit funds to development and implementation of these
changes from now to 1977 the job would be done.
183 While SANBAG is not sufficiently organized yet to respond
specifically to EPA rs proposals and agree with necessity for auto
dis-incentives, they feel that they will take a stronger stance
than their neighbors. They do support, in many respects, the
Task Force Report. San Bernardino is ideally suited for control
experimentation.
186 QA Mr. Hansberger
Urged SANBAG to participate in complex source regulation
review. Peels that growth rate has substantially slowed. Thinks
if Federal government would not allocate money based on population
growth, it would help.
189 Mr. Fred Lewellen, Los Angeles Area Chamber of Commerce
Feels that EPA concurs m need to amend Clean Air Act.
Economic and social chaos will result if plan is implemented.
Revised standards to a more realistic level as set forth in
earlier statement of March 6, 19 73. By 1974 major auto pollu-
tion will come from pre-1971 vehicles. Urges reactivation
and acceleration of the ARB retrofit program for 1966-1970
model cars. Endorse catalytic retrofit as well as inspec-
tion/maintenance requirements . A pilot program should be tried
first. Fines could aid in this program. Buses should be
allowed to travel more rapidly and service should be expanded.
Exclusive lanes and signal priorities would help bus service.
Cost of freeway lane restrictions will be too great to justify
that use. "The 24-hour restriction...is unreasonable and un-
needed, constituting a deliberate restriction of traffic rather
than a justifiable move to reduce air pollution."
Parking restrictions are an "unfair deprivation of property
rights, with questionable benefit." Pointed out local require-
ments for parking with any development of land, including residen-
tial, Places burden of proof on a manufacturer that a given loca-
tion will attract a work force from certain areas, thereby
reducing VMT, an impossible task. Could result in bond de-
faults. Restricts night time activities as well, when emissions
are not a problem.
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199 Chamber urges voluntary car pooling programs on days of
forecast oxidant levels in excess of 0.25 ppm. Also reducing
fleet vehicle use and inspection/maintenance are encouraged.
Support mini-buses, PRT, and people-mover systems. Support
retrofits including catalysts if it does not impose, a great
burden on automobile owner.
202 QA Mr. Lewellen
Voluntary car pools may be more successful in Los Angeles
due to obvious smog. Experiments should be run with large
employers and government employees. Surcharge would gain resent-
ment, but no results.
206 Mr. Dennis David, Kawasaki Motors Corporation
Peels that the motorcycle should have been given greater
consideration as a vehicle for attaining the primary standard.
No emission could justify the two year extension of the deadline.
Restriction will render a $60,000,000 segment of the transporta-
tion system useless. The registration ceiling will reduce annual
sales by $75,000,000. Feels total economic impact would be
$227,000,000. Will save only 12,000,000 pounds of hydrocarbon/
year. This should be judged unreasonable and not cost effective.
210 Kawasaki believes that cycle emissions can be controlled. South-
west Report is too preliminary to base such stringent regula-
tions on. LA-4 testing mode is inappropriate. Peels thay are
in cruising mode more than the test allows. Pointed out pro-
blems with the seven motorcycle test {one defective, one illegal
for freeway use). Mileage figures are grossly overstated. Have
a 900cc four stroke cycle that emits 2.1 grams of hydrocarbon/
mile. Also meets the 1975 auto NOx emission standard. EPA's
regulation would force people to use less efficient modes of
transit.
214 QA Mr. David
Will provide statistical use data. Peels that a 90%
emission reduction could be achieved from the Southwest
Report levels, but would require considerable lead time and
may not really be necessary. Encourages development of a
motorcycle testing cycle other than LA-4, had operated a
motorcycle on a dynamometer under LA-4 test conditions and
did not feel it was representative. For two-stroke machines
the LA-4 test may give overestimate of emissions due to opera-
tion outside of normal rpm range.
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219 Mr. Roger Barlow, Mayor, Indio and Chairman of Regional
Anti-Pollution Authority of Coachella Valley
EPA should make its position consistent, Coachella
Valley oxidant and CO readings are cited in South Coast
Basin justification for being a critical area, cite
South Coast Basin as meteorologically closed, but Coachella
Valley is in the South East Basin, Feels that Basins
must be redefined. Peels that standards attainment could
be phased. Propose a study to characterize Coachella
Valley air quality and relate to South Coast Basin inflence.
Need this to determine what impact their local effort could
reasonably have.
223 QA Mr. Harlow
Counties in two air basins will place emphasis in basin
with most of their represented population. Indio experienced
1348 hours exceeding 0.08 ppm oxidant in 1972. Have been
advised that readings would be lower if they increased auto
use in vicinity of monitoring stations. Potentially due to
lack of NOx to react.
227 Mr. S. W. Coleman, Birmingham Small Arms Company,
(Triumph andNorton Motorcycles) ^
Have worked on emission controls for last three years.
Are testing new combustion chambers, catalytic converters,
fuel injection, and so forth. Are experimenting with PCV
and evaportative controls. Would welcome emission controls.
EPA's proposals would not attain its own purposes. Are devel-
oping a Wankel-type motorcycle engine. Have questioned use
of LA-4 testing mode, but agree that it is representative of
the use pattern of the motorcycles that they produce.
229 QA Mr. Coleman
Will submit emission data, including dates for achieving
reductions. Predictions are based on new generation, four
cycle engines, not Wankel type.
231 Mr. William D. Hoffman, Atlantic Richfield Co.
Supports mass transit, car pools, smaller more efficient
autos, and inspection/maintenance. Question the necessity of
0.08 ppm oxidant standard in view of economic impact of 80%
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gasoline rationing. Endorse limiting catalytic retrofit to
cars that can operate on 91 octane fuels. Problem in identifying
which pre-1971 vehicles can operate on this fuel.
Should verify necessity for 0.08 ppm oxidant standard
due to impact of implementation of controls to reach it.
Rationing should be limited to smog season, May 1 to Oct. 31.
Could require inspection between March 15 and July 15, which
improves its effectiveness and may counteract need for rationing.
Are implementing vapor recovery at bulk loading facilities.
Are investigating vapor recovery for retail deliveries. Have a
subscription bus service for corporate headquarters personnel.
235 QA Mr. Hoffman
Atlantic Richfield has "announced a program...to sub-
stantially convert our gasoline base to 91 octane lead free."
239 Mr. R. Paul Robb, Motor Car Dealers Association
"Are stunned by the concept of the enormity of the disrup-
tion of life, the hardships that would be imposed and the depriva-
tions that that would result..." Stressed single purpose nature
of attaining the oxidant standard and the factors that will be
ignored in the process. Requests a postponement of implementa-
tion. The Los Angeles automobile owner is resentful of govern-
mental regulation and concern is reaching turbulent and dangerous
proportions.
244 Mr. Russell Howe, Union Bank
Supports the stand of the Central City Association.
Need an alternative to auto before disincentives are enacted.
Without this mobility the economic viability of the downtown
area could be questioned. Supports mass transit.
245 Mr. Stanley Long, Los Angeles Parking Association
Stressed the public's concern for clean air. Addi-
tionally, the need to keep the system now in use until it is
known what is proposed has been tested. Fears economic chaos.
Need an environment of public consent in order to be successful.
All regulations proposed emphasize the negative - restrict gaso-
line, ban on new parking, reduce existing parking, all tend to
create an artifical deprivation.
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253 QA Mr. Long
. Can agree to many proposals if mass transit is implemented,
providing positive relief. Concern expressed for "overkill" in
the proposals.
256 Mr. Norman Dreyfuss, Smog Abatement
Feels that looking to Detroit for a miracle or looking
for a perfect, painless program are unrealistic. Feels that
the use of natural gas as a vehicle fuel deserves more considera-
tion. Natural gas eliminates 90% of hydrocarbons, carbon monoxide
and nitrogen oxides and meets 1975 standards today. Could be
encouraged even if not made to be mandatory. Stressed that
not all proposals can hope to be 100% practical and that a lot
of ideas in combination can provide improvement.
262 QA_ Mr. Dreyfuss
ARB1s determination on natural gas was that it was
impractical to convert every vehicle in the basin. Stresses
that fleet vehicles (8% of vehicles in basin) account for 20%
of VMT and could be converted. Has converted 1500 vehicles
from a dozen companies. The economic savings is not enough
to gain total acceptance based on the relative inconvenience
of limited refueling points.
267 Dr. Richard J. Lescoe
Aircraft should increase their minimum occupancy levels.
Cars should be limited to six cylinders and of capacity only to
travel at 65 mph with air conditioning. People drive large
cars for safety benefit. If everyone drove small cars there
would be less threat of demolition in an accident. Should have
an assembly line emission check to protect consumer. None of his
patients have complained that smog aggravated their condition
unless it was accompanied by intense heat. Does not believe
that the standard should be geared to protect hypersensitive
individuals. Could be handled as is hay fever, on a patient-
doctor relationship basis with individual abatement actions.
Questions the studies on which standards were based and cited
more recent studies. Most data represent multifactorial causes
and require extensive analysis.
277 QA Dr. Lescoe
Feels that National Academy of Sciences review of standards
may also be deserving of scrutiny due to previous experiences
cited by Dr. Lescoe.
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280 Dr. Ruth Russell, Lung Association of California
Feels that initial public inconvenience and dis-
pleasure will be replaced by acceptance when public recog-
nizes the health and other benefits of air pollution reduc-
tion. May be a case of a need for best judgement where
public health would be ill served if action were withheld.
283 Mr. Mike Henshaw, American Motorcycle Association
Motorcycling has quadrupled since I960, xn no small
way influenced by economics and convenience afforded by
them. Secretary of the Interior encourages cycles due to
energy consumption savings. Restriction will force shift
to less efficient transportation. Will encourage the junking
of motorcycles through registration ceiling.
287 QA Mr. Hershaw
Will provide results of a poll the Association conducted.
Substantiates that there has been a decrease in registration
in California.
290 Mayor Jerry Matney, Huntington Beach
Cited one of the few streets which would be affected by
exclusive lanes in his town (Beach Boulevard). Would require
at least 20 buses per hour to accomodate 1/3 existing traffic
flow. Boulevard already carries many three passenger vehicles
thus counteracting any car pool/bus advantage. Presents
additional conflict on Bolsa Avenue due to commute traffic
to McDonald/Douglas Corporation. To avert safety problems
the special laws require elaborate traffic control lights.
294 Parking restrictions are serious in light of existing
growth rate of 12,000/year. Would reduce revenue thus compli-
cating bond redemption. Reduces maintenance and improvement
of funds. Aggravates an existing parking shortage.
Will adversely impact planned redevelopment project. Must
require American auto manufacturers to comply with standards.
303 Dr. Saxe Dobrin, Consulting Engineer
Wishes to stress the potentialof alternate fuels -
specifically - methanol. Has been used in numerous applica-
tions. Only adjustment needed is to carburator jets. Can be
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produced from either coal or refuse. When made from natural
gas it is cheaper than gasoline. Is just as volatile as gas
but has a higher flash point. Burns at a lower temperature and
emits no hydrocarbons in exhaust. N0X formation will be lower,
engine will not be harmed by tuning for CO control. Has an anti-
knock octane rating of 120 to 140 without lead. In existing
cars would not be as efficient as gasoline. Can be either a
total substitute, a blend with gasoline or an additive.
Emission data is limited.
313 Mr. Heinle, Southern California Rapid Transit District
Currently operates 1,659 buses, serving 180 million
passengers per year. Twenty percent of persons entering
Central Business District come by public transit. EPA plan
will result in an added 650,000 trips per day by public transit.
Will have to double present bus fleet, hire 2,200 new bus drivers
and 1,100 maintenance and administrative personnel. Would cost
$104 million for buses and facilities. Increases operating
deficit by $31 million annually. Could respond within the time
frame if funds were provided. Such an expansion has never been
implemented and success is dependant upon public reaction. Par-
ticipated in the Task Force Report.
318 SCRTD supports EPA in its efforts. Exclusive lanes and
enhanced transit will accelerate individuals' decisions to
choose public transit. Will aid EPA with expertise and effort
to make the program a success.
319 QA Mr. Heine
Will provide EPA with bus manufacturers' responses to his
letters. Had cautioned in his bus supply guestion letter that
other communities were probably facing a similar demand. Have
worked with Atlantic Richfield in a subscription bus system.
Also contacted by the county for a similar program for county
employees, SCRTD is actively campaigning for subscription
customers. Are authorized to run buses on routes which existed
in other counties when they took over the system, but not
authorized to construct mass transit in those other counties.
324 Mr. Barry Love11
Feels that riding motorcycles or other ORV's in desert
areas is an important recreational activity deserving of more
consideration.
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Motorcycle industry should be alloted time to meet
emission standards.
330 Mr. Miennert, AMF Harley-Davidson Motor Company
Entered letter o£ July 6, 1973 to EPA. Southwest
Report is not adequate support for proposed restrictions.
Motorcycle should become an important transportation mode
as energy conservation becomes more important. Industry
should be given standards and time schedule. Suggest a
five year plan. Support Motorcycle Industry Council and
will cooperate with EPA in resolving problems. Hope for
a program less economically damaging than the present
proposal.
333 LA-4 test mode is of questionable validity. The speci-
fied equivalent inertia values are too high for even a large
motorcycle, were developed for atomobile tests. Section 85.075-
19 paragraph C is not applicable to kick start vehicles because
it specifies a 10 second cranking limit. Test should also
specify driver weight since dyno horsepower will vary with
smaller displacement motorcycles. Without more development
time, emission decreases are hard to quantify, but it is felt
that significant reductions can be achieved. Recommends:
1. • Study impact of motorcycle emissions on air quality.
2. Conduct a substantial number of background tests.
3. Establish a representative test cycle.
4. Investigate applicability of known auto control
devices to motorcycles.
Are currently working on a new series of large displacement
engines and reduction of emissions is of concern. Will alter
oiling and crankcase ventilation areas in order to incorporate
a PCV system. Carburation calibration will have non-adjustable
high speed settings. Spark timing will be optimized for
reduced emissions. All production four stroke cycles will
have PCV system by July 1975. Southwest Report shows 87
percent reduction of blowby HC at 40 miles an hour with PCV.
337 AQ Mr. Miennert
Harley-Davidson currently comprises four to six percent
of the motorcycle market.
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339 Mr. Frank Alexander
Feels that sulfur trioxide produced in the catalyst
regeneration activity of oil refineries is the producer of
smog. "Heavy smog days in Los Angeles invariably a hot day
following a foggy night on the coast." Said tulle fogs coming
from the valley past the refineries produce the smog in the
San Francisco area. Testimony was stopped by Chairwoman as
not being addressed to the subject.
349 Mr. Robert Hamm, Motorcycle Owners, Riders and Enthusiasts
Critized "suddenness" of motorcycle controls. Industry
should be given standards and time to comply.
351 Mrs. Hazel Scotto
A need for more public transit exists. Many local bus
systems have started recently but are legally restrained from
serving as feeders to SCRTD or outside their own city limits.
Revenue sharing, gas tax returns and other funding are available.
Still would not be enough for a mass transit plan encompassing
the region. Should provide SCRTD feeder opportunity. Fringe
parking money should fund more buses. The public doesn't
know how expensive auto operation really is. Cited DOT data.
356 QA Mrs. Scotto
Several cities besides La Mirada are planning dial-a-ride
systems.
358 Alan Hoffman, Radio Communications Industry Association
Suggested requiring communications equipment in fleet
vehicles to make their operation more efficient.
370 Mr. Oscar Singer
Questions removing only visible pollutants and not
dealing with the poisons in the air. Thinks motorcycles
should be encouraged.
375 Mr. Robert L. Joseph, Universal Oil Products, Co.
Has researched catalysts since early *60's. Are
completing a 100 car test in cooperation with CALDOT and
ARB. Tests show substantial reduction of unburned hydro-
carbons and carbon monoxide. Urge pilot tests of retrofit
in limited basin area. Could begin installation in last
half of 1974. Could gain experience for full basin implemen-
tation. Have catalysts which have shown 50,000 miles durability.
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Entered substantiating exhibits. Subjected them to oil, mis-
fires and lead contamination at various intervals. Feel
technology is available. Can provide for California needs
with six to nine month lead time. This technology is also
applicable to heavy duty vehicles such as 3/4 ton pickup
trucks. Have tests on vehicles up to 5 tons that are also
encouraging. Agrees that technology could solve motorcycle
problem also. CALDOT has operated 340 1966-1973 vehicles on
unleased 91 ROW lead free gasoline for two years without
mechanical problems or adverse effects. Vehicles should be
inspected and maintained prior to retrofit. Can test catalyst
function easily with infrared hydrocarbon meter. Urge pilot
retrofit program beginning in 1974.
381 QA Mr. Joseph
Feel confident that 50,000 mile guarantee could be
offered, within limits of proper operation. Have developed
burn-out protection system so that screen holding pelleted
catalyst melts at 2500° while catalyst melts at 3200°. Thus
if overheating occurs the catalyst is blown out of exhaust pipe
prior to melt down. Replacement of a catalyst would be $25-30
since unit would not require total replacement. Will submit
data on platinum particulate loss from catalysts. Foresee
that a heavy duty vehicle retrofit program could be implemented
by 1977. Catalysts will not decrease engine efficiency or cause
increased fuel consumption. Could be a problem at 75-90 mph
due to back pressure, but a normal speeds fuel consumption
could be improved due to easier tuning. Results on cold starts
arent' as good as they should be, air pumps can help.
396 Mr. Peter Angelillo International Cryogenic Engineering
Questions standards, problem of reproducibility. Questioned
definitions of pollutants. VMT reduction would step back to
the dark ages. Suggests planting trees to improve air quality.
406 Ms. Dunn, EPA, Opening Statement, August 10, 1973
407 Mr. Briley, Asst. City Manager, Glendale
Feels that Glendale is representative of the area. Had
provided input to the Task Force Report. Has had much experience
with and dependance on public off street parking. Local bus-
iness have provided 463 spaces over last 17 years, to reduce
these by 20% would be anathama to them. Downtown area has
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1325 off street spaces in 20 lots, The reduction will stifle-
local economy. EPA assumes that presently inadequate public
transit will provide access. Will congest on-street parking
in neighboring residential areas. Creates city vehicle parking
problems. Off street parking at city parks would be affected
as would library facilities. Redevelopment plans also require
a 4500 space parking facility. In summary the regulations are
impossible to live with.
420 QA Mr. Briley
Glendale parking in the Montrose area was utilized at
41% capacity in July. Is sized for Christmas season when retail
merchants figure they must make their money. Suggested applying
reductions during critical times of year for air pollution,
will have a negative correlation with peak parking utiliza-
tion. Will supply data for a year of Glendale parking utiliza-
tion, Bus service is not designed for local transit, but is
intercity oriented. Glendale is not included in SCRTD master
plan for rapid transit, 40% of Glendale population works
outside Glendale, Are discussing a minibus system to aid the
redevelopment area. Does not have population concentrations
needed to support rapid transit or even bus transit,
428 Mr. Richard Perrine Sierra Club, Los Angeles Chapter
Burden of proof to change standards is on those pro-
posing the change. If all costs of air pollution are con-
sidered, standards can be met in an economically sound manner.
Do not accept less stringent emission standards. Program will
present new employment and profit opportunities. The program
may have loopholes and may cause great inconvenience and cost.
Gas rationing is artificial, provides windfall profit
opportunity.
Inspection/maintenance, is strongly supported.
Only freeways and few major streets would benefit from
exclusive lanes. No real incentive is provided. Controlled
access could be equally effective without engineering problems.
Parking restriction will be an administrative nightmare.
Due to large amount of private parking this will be ineffective.
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Urge motorcycle controls, but shouldn't be allowed
greater emissions than small cars with corresponding passen-
ger capacity. Aircraft and heavy duty vehicles also need
controls.
Support catalyst retrofits.
Sierra Club has submitted an alternate proposal. Some
alternative will prove to have greater public acceptance.
Propose a graduated emissions tax with revenues to
fund mass transit. Transit must be attractive enough to
be used on all days, not just high smog days. Keep "dirty
vehicles" off roads on thirty most smog-prone days of the
year.
437 Cecile Rosenthal, Sierra Club
Did not hear anyone mention the right to clean air,
just the right to drive cars. Citizens Planning Council
for Los Angeles did not even receive the EPA plan for review.
Hearing was an agency get-together not an opportunity for
public participation. Social costs of air pollution should
be developed and presented next to control costs.
Highway and land-use planning are not responsive to
air pollution problem. Local government has done nothing
to respond to air pollution.
Could be better to allow commnter to drive three miles
to work than to allow secondary drivers opportunities to drive.
No local transportation planning is being done, just corridor
planning. Housewife has no alternative to automobile. Free-
ways encourage longer distance more convenient trips.
Proposes bicycle facilities to provide for local transit.
Could take up to 10-15% of local traffic. Could begin in
College or University areas where ability to ride is most
likely.
EPA's parking restriction is a backhanded approach to
land use control. Buildings without parking is not the answer.
Need to give thought to population size and where it should be
located. Fringe development occurs when people who can afford to,
move away from smog. May require restoring the State Federal
money limits to curb fringe development.
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Los Angeles has not serviced the pedestrian adequately.
•i
448 QA Sierra Club
Bicycle data is limited because it has not been taken
seriously. Other countries have had great success. Inspec-
tion/maintenance would not be significantly more than what
one pays for normal manufacturer recommended maintenance.
Will provide suggested language for an alternative parking
regulation.
459 Mr. John W. McDonald, Automobile Club of Southern California
Need a complete reassessment of the government's program
for improved air quality. Implementation of this plan should
be delayed until that review is complete. Questions whether
attainment of standard can be justified in light of societal
and economic impacts.
Primary standards are debateable. Senator Muskie
recognized this in asking the National Academy of Science
to review them. EPA may be proposing regulations that are
beyond the powers granted by the Act. Reassessment should
consider the cost of each measure.
Gas rationing would not be accepted by public, there-
fore would not succeed.
Need a more effective and less expensive inspection and
maintenance program.
Exclusive lanes do not meet criteria for cost effective-
ness, efficiency, mobility, social impact or even air quality
improvement.
Approach should be positive. Recommends:
1. Continue prime consideration of clean engine.
2. Encourage small cars.
3. Facilitate car pools and subscription buses,
4. ' Give priority to car pools at metered on-ramps.
5. Continue signal interconnect systems, channeliza-
tion, spot improvements and better signing programs.
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6. Continue efforts for realistic improvement in public
transit - include minibus, dial-a-bus, people movers,
buses on metered freeways.
7. Staggered work hours, four day week.
8. Continue research in inspection and retrofit.
9. Refine and implement episode approach.
10. Explore improved land use planning and growth
control.
469 QA Mr. McDonald
AAA does not support using highway trust funds for
mass transit improvement. Based on belief that the tax
was specially earmarked for the special interest. If a
change is necessary, then reduce that special tax. Will
supply gasoline use data for Southern California, based on
taxes at distribution level. Encourage episode strategy
despite adverse publicity.
477 Mr. Reed Lawton, Industrial Association of San Fernando
Valley
Need for both prevention and elimination of all
pollutants. Also a need for a major educational program.
Indicated a concensus that the LA Plan will not work and
proposed a way of achieving the air quality goal. First,
the problem is not just the engine, it is the whole vehicle
that is inefficient. Should provide an incentive to small
business such as research and development funding or a
cash award for a clean vehicle. Need a aggressive do-some-
thing program. Advocate massive infusion of money to research
air pollution. Proposes a positive publicity program, every
one should attend hearings like this. EPA needs the same
kind of challenge and public awareness NASA had.
490 QA Mr. Lawton
Clean car program was discussed, which provides an
incentive for manufacturers to produce a clean car.
492 Mr. Jim Barrett, Regional Council of Shopping Centers
There are extreme positions on both side of the
clean air issue, but many more people lie between the
extremes»
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Reasonable substitute transporatiori must be provided
before taking away automobiles. Would not be desirable to
tie EPA up with lawsuits involved with the parking regulation
alone. Need something that not only satisfies all the various
interests concerned but something that practically works.
Physical act of permitting every parking structure is an
impossibility.
Feels that shopping centers are already providing air
quality data in environmental impact reports. The job has
already been done for them.
Would expect to see a lot of contracts let to qualify
for "grandfather" exemptions especially in cities that have
been planning redevelopment projects for some time. Funding
will be unavailable due to uncertainty. Shopping centers
should be exempt from permits.
507 QA Mr. Barrett
Analyses of shopping center includes VMT, gasoline
consumed, service area, and many other factors. These are
presented in EIR design reports and studies. EIR process
does not implicitly deny the right to construct if the analysis
reveals an adverse impact on air quality. Mr. Jaconi of same
law firm commented on the California Environmental Quality Act
process.
520 Mr. Daniel Collins, City of Torrence
Torrence agrees with the Task Force Report that EPA's
proposal would have a drastic effect on the economy and over-
all welfare of the region.
There has been insufficient time and lack of coordina-
tion in preparation and review of the plan. Transportation
planning must be integrated with the plan.
523 Mr. John Green, Omega Clean Air Converstions in Santa Ana
Runs a natural gas conversion business for private owner
automobiles, not fleet-type conversion. Dirty fuels should
be limited, even increasing Federal and state gasoline taxes.
Revenues could be applied to convert low income areas to
natural gas fuels. Vehicles can be filled at home, improves
availability of fuels. Feels that fifty to a hundred thousand
vehicles a month could be supplied. Maintains natural gas
is a clean fuel, no hydrocarbon emission products that are
photo-reactive.
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528 QA Mr. Green
With a 90 day cycle, could produce fifty to a hundred
thousand units for immediate installation. With that volume,
price would be competitive with catalytic converter. Natural
gas is cheaper, about 7 1/2 to 8 cents/gallon. Would suggest
extending natural gas state tax exemption to 1980. Typical
installation provides a range of 150 miles, could be extended
to 200 miles with pressure increase variance and even further
with removal of un-needed smog controls.
Mr. Green emphasized that proposed regulation would
not be mandatory, but would entice owners into non-polluting,
cheaper fuel.
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Condensed Comments - San Diego Hearing, August 7, 1973
Air Resources Board (45-90)
Urged coordination with IREM and CALDOT before finalizing plan.
Limit catalytic retrofit and unleaded gas requirements to San
Francisco and South Coast Basins. Controls are too firm based
on inherent inaccuracies in VMT reduction predictions. Pointed
out differences in state plan and Federal strategy - urges
acceptance of the state proposal in lieu of EPA proposal.
Thinks Clean Air Act Amendments is necessary to provide necessary
flexibility.
Local Government
Concerned about parking restrictions impact on inner city
renewal project, feel it could result in more sprawl. Transit
projects would require massive funding. Generally agree to goal
of clean air. Outer towns don't agree to the need to control
them; see economic hardship, gasoline shortages. A councilman
expressed a "minority viewpoint" favoring controls and added
concern about Tijuana's contributions to problems. Feels that
San Diego should subsidize transit, not parking.
Regional Government
CPO keynotes the necessity for land-use planning. Urge compat-
ibility with long-term planning. Agree that 20% VMT reduction
is more reasonable. Car pooling in major employment firms could
reduce VMT 7%. Also recommended maximum speed limit reduction,
4 day week, gas tax, special parking fees, horsepower tax,
reduced aircraft operations, motorcycle emission control including
retrofit.
IREM - Office of Environmental Management
Recommends: catalytic retrofit of 68-74 cars, evaporative
loss retrofit on 68 & 69 used cars, idle mode testing program,
only 2 or 3 times bus expansion instead of 5 or 6.
Does not recommend: parking restriction, motorcycle regula-
tion or bus/car pool lanes.
Feels program is more cost-effective. Would accept EPA plan
if theirs doesn't work.
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County Department of Transportation
Standards must be changed. Are developing another transporta-
tion plan. Urges full analysis before implementation.
Comprehensive Health Planning
Wants monitoring system improved and expanded. Recommends
specific consideration for new source review. Need alternative
transit before reducing VMT.
Citizens Groups
Comment varied according to special interest. Environ-
mental groups supported plan, urged further analysis.
High speed bicycle lanes, reduced speed limits, stringent
aircraft emission standards, and land-use planning were pro-
posed as alternatives. Wants citizen committee to input
EPA, Pointed out problems with Executive Order 11507 and
Federal facility compliance. Conflict of Clean Air Act and
FWPCA was pointed out - EPA built large treatment systems in
San Diego, plans consolidation that would remove limits on
growth. Don't feel that Tijuana is that much of an air
quality problem. Some prefer rationing to higher taxes.
Want to see plan for Lindbergh field expansion, would favor
it being a transportation center. Favor breaking highway
trust fund.
Community groups support clean air goal, some think standards
are not realistic. Business groups do not favor parking
restrictions. Pointed out the city renewal project.
Do favor public transit and employer subsidized car pools,
bus fares. Favor highrise in city center. Advocate EPA's
pushing for a clean engine. Want social/economic impact
analysis of plan. Some suggest one-way streets as additional
alternatives. Some foresee social and economic chaos.
Suggest two standards, one to be reached regardless of cost,
other to be balanced against cost and social effects.
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Industry - Auto
AAA and motor car dealers of San Diego.
Support car pooling and priority laws, but wish reassessment
of plan. Need for data, re-evaluate standards and review
the Act are all recommendations. Stress a clean engine
first. Improve traffic flow with signaling, signing and
channelization. AAA does not support breaking highway trust
fund. Concern for economic effects and impact on California
lifestyle.
Industry Petroleum
Numerous comments on state of the art and phasing of con-
trols. Set back deadlines to facilitate phasing. Comments
on inspection technique and evaporative cost control-
favors direct replacement system.
Industry, Miscellaneous
Advisor to Hughes-Nevada cautioned on reliance on pollution
models. Felt standards should reflect local conditions.
Discussed methanal/gasoline mixtures for fuel.
Scientific Community
Rand representative reviewed the situation and clarified
definitions. Expressed technique preferences for modeling,
assumptions, etc.
Mr. Crane proposed hydrogen fuel system and elevated transit
system for fuel/transportations solution.
Citizens
Generally question motorcycle controls, especially 2 stroke.
If motorcycles pollute as much as '65 autos why not ban
them too? Economic hardship on small business and motor-
cyle dealers, repair shops.
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A Dr. Schneider proposed unique gas rationing system
utilizing coupons with an exchange market to provide gas
to those who need more than their allotment. Propane
conversion would provide alternative to rationing for
police, doctors, emergency vehicles, etc.
300 signature petition protesting motorcycle control
submitted.
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Summary
Public Hearing, August 7, 1973
San Diego
3-8 Mr. Walker, EPA - Opening Remarks.
8-14 Mr. Souten, EPA - Opening remarks, summarization of proposed
control plan.
14-15 Mr. Walker, EPA - Called for public comments. Invited Mayor
Pete Wilson of San Diego to begin comments.
15 Mr. Wilson, Mayor, San Diego - Submitted written statement
for City of San Diego (Ex. 3). Also submitted statement
he presented on behalf of National League of Cities at
the U. S. Conference of Mayors to Subcommittee on Urban
Mass Transit (Ex. 4).
1. Agreed to desirability of clean air.
2. Concerned with enforcing automobile disincentives
without providing incentives for expanded transit
service.
3. Concerned with land use implications.
4. Hopes that Congress will force auto manufacturers to
produce cleaner cars.
5. Favors mass transit even without air pollution
benefits.
6. Fears that land use implications of regulations would
be counter-productive to achievement of city land use
goals - especially complex source review and parking
limitations. (Are striving for inner city renewal/
curbing sprawl.)
7. Transit is desirable, but expensive. Needs a Federal
subsidy.
8. Advocates horsepower tax.
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21 9. EPA has no land use jurisdiction nor money to augment
public transit? both are needed.
10. Cites costs needed to expand bus service, fiscally out
of reach.
11. Land use policies incorporating air pollution criteria
may encourage sprawl.
24 12. "We are concerned that what has been proposed is not
in fact realistic."
25 Mr. Walker, EPA - Thanked Wilson, noted Administrator's
Lobbyrole.
25 Mr. Wilson, San Diego - Expressed concern that emissions
from Tijuana (600,000 persons) are within the San Diego
Air Basin. Urged cooperation with Mexico in attaining
clean air.
26 Mr. Walker, EPA - Added that water pollution was already a
border issue and air should be added. Introduced
Mr. Rypinski of the Comprehensive Planning Organization,
26 Mr. Rypinski, Comprehensive Planning Organization - CPO is
the Council of Governments for the San Diego Region and
has land use jurisdiction in the area. Are currently
developing land use and transportation plans for adoption.
28 Personally advocates a national population policy.
Commends objectives of clean air, however, feels the
clean engine should be highest priority and that auto-
dependence will continue in the area. Wants reasonable,
workable rules. Short-run strategy should be compatible
with long-run transportation and land use objectives,
for which the CPO is responsible. Transportation
30 plan's first five-year strategy will contain a program
for achieving acceptable clean air standards. Urges
cost effectiveness criteria for control methods.
31 Concur that 20% VMT reduction is more reasonable,
however, must address the problem of separate efforts -
ARB, EPA, CAPCD and U.S.DOT, CALDOT, CPO to develop
transportation plans - should be coordinated.
32 Wants all cities and private sectors within the region
to agree to controls needed by 1977.
33 Quoted Automobile Research and Development Act to
support plea for clean engine.
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33 EPA1s reliance on buses encourages multi-model approach,
but isn't a long-term commitment to that mode - allowing
future transportation plan implementation.
35 Doesn't feel that congesting the single passenger
vehicles will be effective, and that an alternative to
carpooling should be sought. Suggests carpooling for
major employers (50% of all employees work in only 2%
of county's firms) including governmental bodies = 7% VMT
reduction. Other 13% reduction requires 1500 new buses.
36 Reconsider parking restrictions - adversely affects
revitalization of downtown area. May encourage sprawl
by businesses preferring outer areas with more parking.
37 Suggested:
1. Reduced speed limits to 50-55 mph
2. Adopt 4-day work week
38 3. Gas tax to aid fixed rail mass transit
4. Special fees on parking
5. Horsepower tax
6. Reduced aircraft operations
39 7. Control motorcycle emissions; include retrofit.
Question: The willingness of the basin to change travel
habits; should survey public; is willing to undertake
one with EPA.
40 QA - Only small portions of freeway has not kept up
with peak demand. CPO will ultimately control freeway
construction. Would have pragmatic control if not
jurisdiction.
4 3 HC reduction with reduced speed data. Would submit
data later.
44 Gas tax could be at State level. Parking and horsepower
taxes would be local level; ordinances have not been
proposed for parking taxes, but EPA could provide the
incentive.
45 Mr. Walker, EPA - Introduced Harold Sullivan, Vice Chairman,
State Air Resources Board - asked about benefit of speed
reduction.
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4-
45 Mr. Sullivan, Vice Chairman, State Air Resources Board -
Agreed that reduced speed would conserve energy but
emission reductions would likely be minimal,
46 Submitted written statements as well as a letter of
July 9, 1973 from ARB Chairman, Dr. Haagen-Smit, to
Mr. Pri.
47 Gave brief background of events. ARB has prepared
Revision 3 to the implementation plan, EPA testified on
May 23, 1973, the revision was adopted June 21, 1973 and
recently submitted to EPA by Governor Reagan. Objectives
of plans are the same although approaches differ. ARB's
is the same as EPA's except:
48 1. Vehicle inspection program does not rely on loaded
dynamometer emission test.
2. EPA will control aircraft emissions to level commen-
surate with auto emission reductions.
49 (Touched on military and other Federal vehicle
emission control needs.)
50 3. Sets emission standards for motorcycles.
4. Does not limit fuel supplies.
50-51 5. Recognizes need to limit VMT, however, depends on
Integrated Regional Environmental Management Project
(IREM) recommendations for transportation plan.
Urges EPA to work with IREM and CALDOT in finalizing
plan. Should limit catalytic retrofit to South Coast
and San Francisco Air Basins due to limited supply of
control system and unleaded gasoline.
52 Estimates of necessary VMT reductions are sufficiently
imprecise to render conclusions unreliable at best;
therefore, not adequate basis for as drastic a measure
as rationing. Curtailment of gasoline sales by October 1,
1973 may not be practical - since promulgation would not
occur until shortly after that date.
53 Urges acceptance of California plan. Urges support of
alternative transportation funding.
54
Clean Air Act amendments will be necessary to provide
greater flexibility.
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Mr. Walker, EPA - Noted that EPA was acting under court
order first, and the time schedule calls for promulgation
by October 15.
55-56 QA Mr. Sullivan - State is letting contract to compare
idle and loaded dynamometer emission testing procedures
and alternatives. State is also researching motorcycle
emissions with results due in 60 days.
57 Mr. Wong-Woo, Chief, Air Pollution Section, was asked
for comments. It was to be complete by end of August.
It is not a base line emission study, but will give
data on which to base control measures.
58 Verified that refineries are not prepared to produce
the volumes of unleaded gasoline for the statewide
market. Catalysts too are being planned for new car
and replacement part distribution; no mention of
retrofit provision.
59 Copy of letter from Reagan to President and California
Congressional Delegation asking for re-evaluation of
Clean Air Act to be submitted.
59 Mr. Walker, EPA - Called for Councilman Bates - not present.
Called for Mr. D. D. Williams of the Board of Port
Commissioners, San Diego. Written statement submitted;
Mr. Williams not present.
60 Called Mr. Allan H. Coleman, County of San Diego-
Environmental Development Agency.
60 Mr. Nielsen, Director, Office of Environmental Management,
County of San Diego (previously of the IREM project) -
Entered a report (Ex. 7) into the record.
61 Recommends catalytic converters on 1968-1974 automobiles.
Evaporative loss retrofits on 1968 and 1969 used cars.
Inspection and maintenance program using idle testing.
Anticipates bus system expansion by factor of 2 or 3
rather than 5 or 6 required by EPA, Does not recommend
parking limits, motorcycle restrictions or exclusive
bus or carpool lanes. Their proposal costs $73xl06,
EPA's $10®. Theirs has less social cost.
63 This report was adopted by County Supervisors as comment
on EPA Plan. Supervisors favor highway trust fund
diversion for mass transit. County task force will
submit a transportation plan by December 1, 1973 includ-
ing the Tijuana problem. Finally, if this plan doesn't
work, would then favor EPA proposals. They feel their
plan would meet standards of 1977.
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Introduced Mr. Mikolowsky of Rand Corp. for statement.
64 Mr. Mikolowsky, Rand Corporation, Santa Monica - Stressed
technical assumptions:
65 1. Effectiveness of catalysts in HC reduction in
light-duty vehicles and LDMV's.
2. Availability of retrofit device.
3. LDMV emission factors.
4. Fraction of total hydrocarbon emissions that enter
photochemical reaction.
5. Worst day oxidant levels to determine rollback
needed.
All of above are not well defined.
66 Catalytic retrofit is being tested, preliminary results
show 70% reactive hydrocarbon reduction. ARB assumes 73%.
67 1971-1974 plus some pre-'71 autos can use no-lead fuel.
Alternatively, can produce higher octane, no-lead fuels.
Durability of catalyst is questionable. Retrofit for
evaporative loss is not available for 1969-'68 vehicles.
ARB is studying feasibility.
6 8 LDMV emission factors are controversial. Three procedures,
7-mode, CVS-1, CVS-2, are used for mass emission estima-
tion.
69 CVS-2 is much more pessimistic in terms of meeting stand-
ards, 7-mode are regarded by some as being inappropriate.
70 Recognize that use of hydrocarbon as a proxy for oxidant
formation involves a large number of chemical and
meteorological assumptions. Defined reactivity - limit
reactivity, worst day reactivity and legal reactivity.
Does not feel that limit reactivity occurs in San Diego,
but limit reactivity understates the expected dwell time,
therefore, supports worst day definition.
71 Disagrees with use of 1972 Escondido oxidant concentra-
tion (0.32 ppm) or rollback. Thirty Larson model
statistically worst day condition would be preferrable
(El Cajon - 0.31 ppm). Details in final report of
San Diego Clean Air Project submitted in draft to EPA;
final expected in a month.
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72 QA Mr. Mikolowsky - County-wide model would provide maximum
reading anywhere in basin, not county-wide nor average.
73-74 Feels that both catalyst and no-lead gasoline would be
available by 1977.
75 Mr. Walker - Called Councilman Bates - not present. Called
Jacob Dekema, District Director of Transportation, San
Diego.
75 Mr. Dekema - District Director of Transportation, San Diego.
Requirements of Clean Air Act are not achievable.
Standards are neither appropriate nor obtainable? must
be changed.
76 CALDOT will propose specific amendments. Does not reject
plan, but wants cautious implementation of full analysis.
Are developing a plan using transportation planning
structure of California which can be implemented if
funds are available.
77 List of proposals will be submitted to EPA before deadline.
Copy of statement submitted.
78 Mr. Walker, EPA - It is EPA policy to substitute approved
State plans for EPA plans if such are made available.
Called Mrs. Vickie Coordt, League of Women Voters.
Ms. Coordt, League of Women Voters -
79 Supports standards as goals, and feels they are minimal.
Supports alternative publically controlled transit.
80 Feels plan would be effective if implemented.
80 Mr. Arnold Klaus, Director, Comprehensive Health Planning
Association -
81 Recommended considerations for new source performance:
1. Current condition
82 2. Relation to standards
3. Potential impact
4. Supporting infrastructure needed.
83 Recommends expanded air monitoring network in San Diego
County.
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84 Need better transit before curtailing existing systems.
Submitted a paper to the record.
85 QA Mr. Klaus - CHPA is a Federal health grant review
organization.
86 Mr. George A. Scott, San Diegans, Inc. - Had submitted
written statement. Group is 15 years old, devoted to
central San Diego improvement.
87 Favors clean air - have been aware of "this Day of Judg-
ment" for years.
88 Have supported inner city development.
89 Tijuana has 1/3 of the air basin population. EPA does
not recognize the bi-national nature of air pollution
control in San Diego basin.
90 EPA has shown leniency to auto industry while placing
unrealistic compliance restraints, workable timetables
and severely restrictive regulations on local develop-
ment and vehicular movement. Have encouraged employer
subsidized bus fares, reduced speed limits.
91 Recommend re-evaluation of standards based on existing
studies. Recommends more high rise in San Diego.
Supports Multi-mode transit systems. EPA should be
sensitive to the time requried to implement such a system.
92 Recommends revision of Clean Air Act to require a
really clean engine. No reduction in parking spaces.
Copy of comments submitted.
94 Mr. Jim Williams, Asst. Director, SEED Corporations -
95 Plan is drastic and impractical. Plan should have been
prepared with full coordination of State and local
government. EPA could invoke sanctions against State
and local government if they refuse to enforce regulations.
96 Paralysis of economy could result with VMT reduction. Gas
rationing would result in black market and would not be
effective.
Parking reduction would wreck central city. Would
eliminate cultural, recreational and sports activities.
Are inconsistent because they would reduce airport
parking.
97 Bus or carpool lanes require competent transportation
engineering. Impractical in San Diego.
Requires expensive retrofit; but even then use would be
prohibited.
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Impossible to expand bus system as fast as required.
98 Proposed rules would do violence to San Diego.
Suggest two sets of standards are necessary regardless of
cost, the other desirable but balanced against cost and
social upheaval.
Suggest review by organization like National Academy of
Sciences.
Clean Air Act should be ammended to consider short-term
and to eliminate inconsistencies as indicated in this plan.
99 Rules should be issued only after California ARB review.
Clean Air Act should require future automobile to comply
with the Act.
99 QA Mr. Williams - Coordination Department of Defense regarding
hospital, commissary, post exchange, etc, may not have
begun in San Diego, but has in Los Angeles.
101 Submitted written statement; Souten indicated Academy of
Sciences review of standards and Senate oversight hearings
on the Act itself.
102 Councilman Jim Bates, City of San Diego - Official city posi-
tion' submitted by the Mayor; Mr. Bates represents himself
as a citizen with a minority viewpoint.
103 Goals are positive and long overdue. Supports them
strongly. Economic and social impact studies should be
done.
City of Tijuana should be involved both in goals and
implementation. Tijuana should become an ex officio
member of CPO.
Supports no new parking in downtown; what it needs is
transit access since lack of parking is what the area's
major problem is in an auto-oriented society.
104 Supports bus lanes, people movers, fixed rail transit
and peripheral parking as the solution to work trips
problem. City should eliminate requirements for parking
within the City core.
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105 City should subsidize transit, not parking.
106 Mr. William Watson, Asst. Vice President for Planning,
San Diego Chamber of Commerce -
107 Supports spirit of Clean Air Act. The plan, however,
would disrupt overall quality of life.
Recommends a social and economic impact analysis of
control plan.
108 Give community as much time as industry to adjust to
change.
San Diego would meet standard in 1982 and 1987; wants
cost-benefit analysis of the San Diego Plan.
EPA should show credible evidence that plan is workable.
109 Concern that mass transit funds will have to be devoted
to bus aquisition. Endangers long-term solution.
Economy is based on consumer mobility, thus plan will
restrict trade. Will cause a moratorium on construction.
110 Concern that plan will induce sprawl which may be counter
productive.
Recommends a stay of submission of compliance schedules
be sought for one year in which to perform cost-benefit
analysis and workability study.
111 Ms. Susan Steigerwalt, San Diego Chapter Sieera Club -
Supports the proposed strategies.
Harshness of VMT is necessitated by "cop out" to Detroit.
112 Supports carpool or bus lanes, sees no problem with good
enforcement.
Motorcycle restriction is justified. Are afraid that
off-road only registered motorcycles would not be
affected.
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113 Notes that previous witnesses escalate each estimate on
number of buses required. Wants foreign bus manufactur-
ing capability to be assessed too. Suggest a national
used bus program.
114 Disappointed in lack of economic incentive for driving
clean cars or reducing VMT. Referenced March 6, 1973
testimony in Los Angeles and technical support document.
114 Reduced speed limit could be made not applicable for
carpools and buses.
115 Suggested high speed bicycle lanes for commuters.
Wants stringent aircraft emission standards - allow local
116 districts to control operations to improve air quality.
40% of Lindbergh Field passenger departures are for
intrastate travel. Suggests high speed intercity rail
transit.
Land use planning is ignored in the plan. Form a task
force to develop means to control growth that is legally
acceptable. Views 3.4% growth rate as a serious problem.
117 Transfer of Navy vessels from Los Angeles to San Diego
was a Federally precipitated growth crisis. Adds 86,000
people to the basin. Strongly recommend Federal Coordi-
nation to assess environmental damage of such actions.
Supports complex source review and recommends moratorium,
until local procedures are adopted.
118 Wants a citizens committee to provide input to EPA.
Need Federal assistance in resolving legal problems
(specifically p. 118 1 25 - p. 119 110 referring to
EO 11507 implementation).
121 Wants Federal Compliance schedule for all Federal
facilities to be brought into compliance with local,
State and Federal regulations.
Hopes plan is flexible enough to ease restrictions if
air quality improves more rapidly than anticipated.
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QA Steigerwalt - Federal facility compliance is under review.
123 EPA doesn't have authority to place moratorium on complex
sources. Sierra Club wants to avoid coastal initiative
and California Environmental Quality Act type problems
with action dates,
125 Mr. Louis J. Alfano (no affiliation in record) - Entered
article in American Automobile Club News. Feels erroneous
information was presented to Congress. Thinks catalytic
converters aren't enough. Clean fuels are necessary.
Referenced a patent application for a clean fuel.
Feels Department of Health, Education and Welfare
submitted erroneous, non-scientifically verified data
and presumptions to Congress.
Referenced letter to Miss Dunn, EPA, San Francisco, and
requested it be placed in the record.
Mr. Alfano is bringing fifty billion dollar class action
suit against all oil companies and Congress to bring
about a better method of eliminating pollution problem.
» Dominick M. Capozzi - represents 300 submitted petition
with 300 motorcyclists signatures. Petition is Exhibit #16.
QA Mr. Capozzi - Hearing was also noticed for 7:00 p.m.
133 Discussed two cylce and four cycle motorcycles. Ques-
tioned motorcylce vs. auto emissions data.
136 Wants to continue growth of motorcycle industry.
137 Mr. Richard G. Bailey, Regional Manager, Automobile Club of
Southern California - Introduced Mr. David Grayson.
139 Mr. David Grayson, Manager, Highway and Transportation
Engineering, Auto Club of Southern California.
126
127
1 "3 A M*-
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140 Concerned about total impact of control measures. Support
carpooling and priority lanes for buses, however, wants
reassessment of total Federal program? do not implement
plan until reassessment is done.
Have offered alternative strategy in the belief that a
detailed plan is premature.
141 Need more data. Re-evaluate standards, explore feasible
modifications of transit systems. Feels that EPA failed
in attempts to reassess these factors.
142 Enforces Senate Public Works Committee review of Clean Air
Act, especially the stringent standards.
Feels that EPA leaves economic and societal effect evalua-
tion up to the State. Says EPA admits the lack of impact
data.
144 Primary standards are too stringent and their supporting
data is controversial.
Questions the wisdom of changing Southern California's
life style.
145 Compared EPA reticence to favor technologies that are
not socially optimal but willingness to force radical
social changes in transportation controls.
Stressed cost effectiveness analysis.
146 Submitted comments on Los Angeles Plan, feeling control
and comments to be similar.
147 Stressed need for clean engine first; then carpooling
and independent bus commuter systems. Accelerate measures
to give priority to high occupancy vehicles.
Improve traffic flow through signal interconnections,
channelization, spot improvements and signing,
148 Improve public transit, stagger work hours, intensify
retrofit and maintenance research, develop episode
approach. Explore land use planning.
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149 The plan could cause problems greater than air pollution
itself.
149 QA Mr. Grayson -
150 Policy of Auto Club of Southern California is to leave
the highway trust fund for highway improvements. AAA in
151 Southern California has implemented limited four-day
week and staggered hour scheduling for their employees.
Copy of report on their experience will be submitted,
152 Mr. Edward H. Reynolds, Director of Environmental Protection
West, Atlantic Richfield Co. -
153 Have voluntarily studied emissions. Have invested in
facilities for unleaded gasoline production for 19 75
cars. Research underway for clean fuels. Are investigat-
ing vapor control methods and equipment for retail market-
ing operations.
154 Suggests setting back Clean Air Act deadline in order to
reduce impacts and allow gradual phasing of alternatives
and controls.
155 ARCo subsidizes employee bus service. Supports highway
trust fund diversion. Parking restrictions may increase
mass transit patronage, but would be detrimental until
that alternative is available.
156 Recommends official idle mode inspection centers.
Should measure hydrocarbon and carbon monoxide plus have
an electronic engine analyzer available. Re-inspect
following corrective measures.
Believes retrofit such as USAD and LIAF to be beneficial
to emissions but some risk to long-term operations and
engine performance.
Does not feel that catalytic retrofit is feasible;
research shows variable results.
157 Catalytic retrofit puts economic penalty on those not able
to afford a new car. Retrofit cost could be equivalent to
the value of the used car in question. If implemented,
restrict to post-1971 vehicles. Normal attrition of pre-
1971 cars should be allowed.
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158 Vapor loss at service station and terminal operation is
minimal. These losses become'more.significant over the
next few years. Retail operation control is experimental.
Can control 90% of vapor loss from bulk handling with
proven systems. Delay vehicle refueling control until
system is commercially available.
159 Discussed prototype vehicle refueling vapor loss control
systems. Some are currently being tested at an ARCo
"facility at Harvey, Illinois. Systems include direct
replacement, carbon absorbers, refrigeration, catalytic
destruction.
161 Nozzle design is also being investigated, problems in
achieving adequate seal and durability.
162 Regulations should stipulate required minimum precent of
vapor loss that must be,recovered in any filling operation.
Total plan is too ambitious to 'be practical and feasible.
163 QA Mr. Reynolds - Change of life style can be accomplished
but not within the time limits.
165 Regulation or other control could limit spillage asso-
ciated with "topping off" filled gasoline tanks.
166 Favors direct replacement vapor control system for tank
filling operations.
166 Mr. Hale Aders, Executive Secretary, Motor Car Aealus
' Association of San Diego -
167 Presented written comments for Mr. McFarland .of the
Motor Car Aealus Association of San Diego.
Views regulations with alarm. Would disrupt economy
and work unlimitless'hardship on people whose living
depends on automotive transportation.
168 Stressed redevelopment in city center is dependent on
parking. Auto is responsible 'for high quality of life*
in California. "The result (of the plan) is obvious,
economic chaos and a death blow.to freedom of mobility
in this country and a shattering impact on our life style.
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169
170
171
172
173
174
175
175
176
178
178
180
182
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Referenced costs of $1000/year/auto for transportation
control. Peels that motorist is given no alternative
except inadequate mass transit.
The cure takes care of sickness, kills the patient.
Requests that auto curbs not be adopted since they
represent environmental overkill.
Recommends Congressional re-evaluation of Act with
interim suspension of implementation of standards.
Endorsed by National Automobile Dealers Association
(copy submitted).
Curran, Executive Vice President of Central City Associa-
tion of San Diego - Had served as Mayor and Councilman
for San Diego. Endorses goal of higher environmental
standards.
Began urban core redevelopment in 1960.
Doesn't understand why parking is to be limited.
VMT reduction assumes instant transit service. Impossible
to finance transit in short time.
Parking restriction will increase VMT.
Will support any regulations adopted but feels that other
controls such as oneway streets, carpools, Reminds that
city core residents need space for their vehicles.
Recommends adoption of State air standards in lieu of
Federal standards.
QA Mr. Curran {mislabeled Mr, Anders in transcript)
Lloyd von Haden, Citizen - Critics of EPA are wrong,
but so is EPA because it doesn't address population
issue.
Nuclear power is not a solution to energy need because
of radiation. Technology exists to produce pollution-free
industrial exhaust; references Dr. Gerhart Wolter, San
Diego State University. Review other Federal actions
including those that influence gross national product.
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183 Major upheaval is needed to get people out of cars.
Recommends small, low polluting bugs or solar powered
vehicles.
184 Mrs. Selroa von Haden, Citizen - Questions nuclear power
alternative, unit housing is unlivable, highrise is not
the answer. Bus systems would be underutilized;
regimentation of traffic is undesirable. Clean fuel
should be the priority, not retrofit. Thinks industrial
pollution is more of a cancer producer than cigarettes.
Life style change is needed.
187 Mr. Bill Bradley, City Engineer, City Manager -
188 Doesn't feel that hydrocarbon control will solve any
health problems. Foresees gasoline shortage in north
San Diego County if supply is limited and population grows.
189 Lane limits impossible on two lane freeways.
190 Buses or bicyles do not solve suburban housewives' needs.
191 Recommend education of people to accept carpools volun-
tarily rather than restrictions or laws,
192 Business impact of motorcycle restriction would be
severe. Ought to put the plan to a vote. Sees people
crossing Mexican border to buy gasoline. No smog
problem in north San Diego County.
19 3 QA Mr. Bradley - Referenced an alternative fuel system
dating toWorld War I. Supply of diesel fuel to run
buses should be verified.
195 Mr. George Roth, Scientific coordination, Hughes-Nevada
Operations in Las Vegas -
197 Hopes the Administrator would subtract "the corona
effect which frequently goes with the reports of" Rand.
Computer models are limited by data input...
198 Feels reports do not address problems unique to San Diego.
Does not endorse a uniform, nation-wide set of standards.
They are arbitrary and theoretical.
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199 Feels sulfur could be removed from all fuel oil in
California for $.50/barrell. The rationing plan is
"part and parcel*1 of oil company plans to raise gasoline
prices.
Feels stress should be for electric transit, not more
buses.
200 EPA's proposals may be purposefully drastic to force
modification of laws.
201 Indicates sensitivity to legal requirement of adequate
public notice before final plan could be legal. "Failure
at any stage of these hearings will only offer opportunity
to opponents of correction of air pollution to intervene
successfully in preventing establishment of adequate
regulations."
203 Read letter to Russel Train (when Train was Chairman of
President Nixon's Task Force on Environment, December 23,
1968) on air pollution control.
205 Standards should be tailored to specific areas.
207 Discussed rr.ethanol/gasoline mixtures for fuels. Methanol
produced from agricultural wastes.
211 Feels that prior engineering can eliminate many new indus-
trial plant emissions.
212 Mignon Scherer, President, Lesser San Diego County -
213 Pointed to conflicts in Clean Air Act and Federal Water
Pollution Control projects growth beyond five years.
Any growth should not be allowed until the problem is
solved if acts are to be consistent.
Doesn't agree that Tijuana is as big a problems as
previous speakers indicate. Few cars there due to
poorer economic condition.
215 Fears impact of solving air pollution and ensuing growth
which will be accompanied by technological controls that
reduce amenities.
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216 Land use and population control is needed.
217 City living produces societal costs including crime,
psychological stress, limits freedom, etc.
219 Dr. Alan Schneider - Necessary to achieve clean air and
is willing to take the steps necessary. Welcomes imple-
mentation of the proposals.
Gas rationing is ideal because it is positive, effective,
and can be finely adjusted. Easily implemented.
221 His rationing scheme involves coupons which would be
tradable in a free market place, so that users of more
gas could buy more coupons. Coupons dated and would
expire. Initially issued to every person over 16. Is
an incentive to get people to use public transit.
Also, relating amount of gasoline sold to number of
people will increase public awareness of growth issues.
Suggests reduced rationing in zones closest to border
to prevent excessive trips.
224 Feels that NOx should be considered more closely in
oxidant reactions, Much electrical generation is
switching from gas to oil, thus increasing both NOx and
S02.
225 QA Dr. Schneider - No exceptions to rationing, but propane
could serve for emergency vehicle needs. No more fossil
fuel electrical generating plants in the basin, even if
it means electrical rationing.
227 Retane Neuman, read into record - Motorcyle restrictions
unrealistic. Projected increase in use is unrealistic.
Two stroke engines are cleaner than four stroke.
228 Mr. John Crane, Inventor -
229 Suggests hydrogen from seawater as non-polluting fuel.
231 Has a system of utilizing solar energy to make steam to
drive turbines for electricity generation to power
electrolysis units to make hydrogen.
Introduced several publications outlining the systems.
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239
240
241
242
243
245
246
247
249
250
251
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Proposes an elevated rapid transit system which could also
replace Alaska Pipeline. Disinfects wastewater with
electricity.
Rapid transit system adaptable to freight, passengers
or drive-on system.
Alan Athley - Criticized population control, used
Hitler analogy. Only system he would accept would be one
he controlled.
Questioned legal authority of EPA to regulate motorcycles.
Questioned emission data for motorcycles.
Two stroke motorcycles don't run well when out of tune.
Thomas Pirle - Feels cost of retrofitting should have
ceiling to protect lower income people. Suggests
including autos with motorcycles in terms of limiting
new registrations. Also, a surtax based on weight,
emissions and passenger capacity.
Public losses due to political inefficiencies at local
levels. Need a no-strike clause in public transit.
Taxi regulations should permit multiple person pickup
along with no-cruising regulations.
Car rentals should be restricted to low emission vehicles.
Bicycle alternative needs consideration in compatibility
with buses and security in downtown areas.
Suggests putting more trains on existing San Diego-
Los Angeles tracks.
Andrea Lyon - Controls would destroy motel and other
small businesses.
Would reduce comparative shopping.
Approach problem through education and publicity.
Endorses reduced speed limit.
Lending institutions should make inner city financing
more attractive.
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Encourage and publicize gasoline-saving driving practices,
along with types of cars inherently more efficient.
252 Stimulate automakers to devise a better engine,
253 Mr. Leonard Thomas - Not pleased with Los Angeles APCD.
Need more monitoring equipment, slow to measure in
outlying areas.
254 Supports an emission fee tax. Also emission controls
for motorcycles.
255 Recess
256 Mr. Walker, EPA - Introductory comments
259 Mr. Abramhamson, Lesser San Diego -
261 Peels parking restrictions would be detrimental to inner
city renewal. But Mayor and City have no control on
peripheral growth either.
264 Inconsistency with Agency's programs with Department of
Agriculture example.
267 EPA, Clean Air Act versus FWPCA. Especially in regard
276 to San Diego metro treatment facility. Consolidation to
Point Loma would aggravate growth problem.
278 QA Mr. Abrahamson - Denial authority under complex sources
review was discussed,
280 Entered letter from Mr. Abrahamson to EPA as well as
"Control of Urban Growth, Provocative Key Note Speech
by J. W. Forrester in the APWA Reporter, 1972."
2 81 Mr. Roger D. House - Entered article from Motorcycle
Industry Council "Courier." Pointed out EPA1s non-
setting of emissions followed by ban on use. Industry
is willing to try to meet standards if set.
285 QA Mr, House - Souten indicated has requested data from M.I.C.
286 Mr. Karl Phaler, Citizen - Agrees data on motorcylces is
inadequate. Since emissions are similar to pre-1966
cars, why not ban them too?
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-22-
288 Should offer emission controls on motorcyles.
289 Doubts that a shift to motorcycles would occur with con-
trol of auto use.
291 Feels that with no hard data, the motorcycle control
ruling should be the subject of impact statement.
291 Agrees with tenon approach and goals but the motorcycle
control is an inadequately informed attempt to meet the
problem.
293 Mr. Robert Leffler, Citizens Coordinate for Century 3 -
Environmental Group of 500 members representing a cross
section of San Diegans.
294 Questions attainability of standards. But agrees that
they'd like to try.
Public education is crucial to gaining support for any
program.
296 Buses will not solve transportation needs, but will help.
Prefers gasoline rationing to higher taxes.
297 Wants Lindbergh field plan completed. Especially the
concept of it becoming a transportation center. Need
a transportation agency to implement regional plans
generated by CPO. A citizens advisory group would aid
in assessing situation and aid in attaining goals.
298 Tax cars with more than 4 cylinders. EPA should lead
fight to break highway trust fund.
299 International agreement is needed to solve Tijuana
contribution problem.
303 Mrs. Marge Earl - Need two stroke motorcyles - work on a clean
engine for them. Control cigar and cigarette smoking in
public places.
303 Mrs. M. P. Isle, Jr., - Clean up air that's already here.
Pump water to Nevada to raise trees to produce oxygen
to purify air. Reharness power as water runs off
mountains.
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-23-
Close of Hearing. Read in additional exhibits.
Certificate of transcripts.
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-24-
Reading file
FLeif 9/4/73 J
44 024 0,2 3 8232,2 376 82,2 30553,2 39 396,4 264 37,
2 39058,084492,084491,084490,084489,084488,
084487,084486,084485,084484,084483,084482,
238718,239136,426872,363918,230521 HC 8/24 10:46AM
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Page
315
335
339
341
342
343
344
345
347
348A
349A
3A
Exhibit
1 40 CFR Part 52 Subpart F - California
2 Statement by the Environmental Protection Agency
3 Statement by Hon. Pete Wilson, Mayor of San Diego.
Have reduced bus fares to 25£, improved service and
have experienced increased ridership.
City is committed to adjust land-use and transporta-
tion decisions to meet air quality standards.
Requests at least six months of hearings and local
analysis prior to implementation of plan.
Wants costs of expanding bus system to be evaluated.
Will need expanded air monitoring system.
Plan will encourage peripheral development. Parking
control should be left up to city.
Should allow local government to prepare implemen-
tation plan subject to state and EPA approval.
Problem of "international air basin" identified.
City feels their land use controls and transporta-
tion efforts will be effective without money and
modification, questions enforceability and effective-
ness of the plan.
4 Statement by Hon. Pete Wilson on Behalf of the
National League of Cities on Air Pollution Strategies....
Requested Federal assistance for transit operation.
Although San Diego is committed to clean air, it is
not willing to reverse City Center renewal progress
or sprawl control efforts.
City should have been consulted on details of the plan
earlier.
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352
352A
353A
354
355
6
357
360
361
363
365
372
-2-
The Air Pollution Control District board of directors
should reflect on other cities than just San Diego,
Strategy will increase demand for fuel. Additionally,
transit costs will also rise due to increased fuel
costs.
Should require Detroit to build small, 4 cylinder
auto that meets emission requirements before forcing
the public transit issue.
5 Statement of Richard G. Rypinski - C.P.O.
Answer lies in clean engines not add-on devices.
Are proceeding with a five year transit plan, one
of whose goals is clean air. Concerned with integrating
long range planning with attaining air quality standards.
Pointed out four areas needing coordination in the
planning for air quality.
The congestion required by EPA plan to encourage
switch to pbulic transit would require extreme
measures in San Diego.
Problems with exclusive lanes and congestion
strategy. Also must reconsider parking restric-
tions .
Recommends reduced speed limit, four day week, gas
tax, special parking fees, horsepower tax, reduce
aircraft operations, control motorcycle emissions.
Recommend evaluated other controls before implemen-
ting the proposed plan.
6 Statement of Air Resources Board - See comment
summary for pp. 45-59.
7 Statement, Office of Environmental Management,
San Dxego County
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-3-
375 Submitted a report on their evaluation of the
plan. Contains alternatives and their proposal.
381 EPA's assumptions are pessimistic. The Rand pro-
posal calls for more retrofit, less VMT reduction,
fewer new buses? parking, motorcycle or special
lane restrictions.
384 Gas rationing is fraught with enforcement difficulties,
385 Problems with inspection and maintenance program.
High cost of implementation and enforcement is
foremost concern. Scarcity of trained manpower
and difficulty of setting the 50% failure criteria
before testing are also problems. Suggest that
even properly retrofitted maintained autos may fail
at 50% level. Recommend the ARB 20% failure level
instead. Dynamoneters are not necessary to test
effectiveness of catalytic converters. Do not argue
the benefits to be gained by the program.
387 Feel that access to car pool/bus lanes may be hampered
and would be dangerous. Emissions would increase
in congested lanes.
389 Parking restrictions may not be effective due to
private facilities. Is in conflict with other
agency policies. Could increase congestion and
therefore increase emissions. Also could increase
VMT (if worker was driven to work by spouse).
390 Motorcycle restrictions will be expensive to enforce,
ARB has no control over them at present, and will
overburden local courts.
391 Support catalytic retrofit. Rand calls for program
to affect 1955-1965 vehicles as well. The CARB
plan also retrofits heavy duty vehicles. Calls
for large supply of unleaded gasoline. Payment
scheme is not equitable. Involves increased gaso-
line consumption. Capital investment is short-term.
394 Bus system is implementable. Success is dependant
on other control measures success. Limiting factor
is availability of funds. Some questions as to
national bus production capacity.
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Car pooling is supported, has lower costs
with it. Requires incentives for implementation
and suffers long term instability.
Stationary source control especially if dry cleaning
establishment is supported. The 1977 emission of
52.3 tons per day is contrasted with the most recent
inventory showing a 1977 emission of 94 tons per day.
The APCD predicts a 43.3 tons per day reduction, EPA
estimates 31.7 tons. APCD feels that remaining
emission will be 33.7 tons per day not 4.8 tons per
day. APCD feels this underestimation could reflect
on vehicle control planning.
Question assumptions used for planning reductions:
1. catalytic converter effectiveness, 2. LDMV
emission factors, 3. fraction of hydrocarbons
that react to form smog. Basically feel that EPA's
pessimism has brought about an overcontrol plan.
Tabular comparision of RAND, CARB, EPA plans.
EPA's program is least cost-effective and has greater
impacts. County favors RAND strategy.
Urge the expansion of the defined air basin to include
Tijuana.
Technical appendices in support of above comments.
Statement of J. Dekema - District Director of
Transportation
mi iii i , i n > I. it i i, i „
Stressing the team approach, CALDOT wants to
evaluate the impacts of the plan before implemen-
tation. CALDOT is presently preparing a plan which
will be submitted to EPA before the deadline.
CALDOT feels that they should play a larger role
in the plan as it impacts transportation matters,
and are anxious to cooperate with EPA in plan
development.
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Statement of the League of Women Voters, San
Diego County
See oral summary, pp. 78-80
Statement of Comprehensive Health Planning
Association
See oral statement summary, pp. 80-85
Statement of San Diegans, Inc.
See oral statement summary, pp. 86-97
Statement of Seed, Inc.
See oral statement summary, pp. 94-102
Statement of Jim Williams, USMC Ret.
1/3 of all retired Naval personnel checks are
mailed to San Diego and Orange County -
consideration for this large group should be
in the plan. Parking around and in military
facilities is critical and will become more
so with planned expansion of Naval facilities
in San Diego.
Statement of the San Diego Chamber of Commerce
See oral statement summary, pp. 107-111. In
addition requests proof that the 0.08 ppm oxidant
standard is required, when the state found 0.10 ppm
oxidant to be acceptable.
Statement of the San Diego Chapter of the Sierra Club
See oral statement summary, pp. 111-123.
Petition with 300 signitures opposing motorcycle
control feature of the plan.
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Statement of Automobile Club of Southern California
See oral statement summary, pp. 139-149
Comments on Los Angeles Plan also submitted in
support of comments on San Diego Plan. Summarized
in the review of comments received at that hearing.
Statement of Motor Car Dealers' Association
San Diego County
See oral statement summary, pp. 167-172. Appendix A
of statement reviews National Auto Dealers Associa-
tion position. Question cost, maintenance and dur-
ability of controls.
Statement of Central City Association
See oral statement summary, pp. 172-179
Statement of Mr. Lloyd Von Haden
See oral statement summary, pp. 180-183
Statement of Mrs. Selma Von Haden
See oral statement summary, pp. 187-197
Statement of George Roth, General Research Con-
sultants.
See oral statement summary, pp. 186-202.
Statement of Alan M. Schneider 8c.D.
See oral statements summary, pp. 219-227, Graph
of electric power demand and capacity in San Diego
from 1950 - 1975 on page 503.
You'll go for this...turning routes into places
where people can discover "A Way to Get Through."
by John F. Crane.
Description of a monorail/multimode compatible
transit system.
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Testimony of R. J. Wilson, President J. F. Crane Corp.
to U.S. Senate Committee on Commerce.
Discussion of Crane Rapid Transit System before
the Senate Committee. Additionally this exhibit
contains "Just the Beginning" by John F. Crane -
a discussion of sewage and refuse recovery.
Statement of Mrs. Andrea W. Lyon
See oral statement summary, pp. 249-252.
Statement of Clean Air Council by Leonard Thomas
Feels that little citizen input was incorporated in
state or county plans, but is encouraged that some
were a part of EPA's plan.
Recommends an emission fee schedule for 1975 and
later automobiles and stationary sources. Also
recommends motorcycle emission standards and change
oxidant standard to 0.1 ppm.
Recommends a ban on all street parking and use
spaces for bicycle lanes. Should also assess tax
on all parking provided by business enterprise,
except in transit stations in outlying areas.
Should also limit the amount of gasoline brought
into the air basin.
Does not support off-street parking restriction
or retrofit program of catalytic converters.
Also suggest public education with report of
violations and worst readings during each day.
Recommends a first stage alert when a primary stan-
dard is violated for any of the three major pollutants.
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Statement of James Abrahamson, Lesser San Diego
See oral statement summary, pp. 259-281.
Control of Urban Growth - Provocative Keynote Speech
Discusses growth in economic, social and technological
contexts and theorizes on projecting growth and anti-
growth factors in the future. Concludes that local
control can provide leadership in determining local
goals and attainment in the absence of a national
consensus.
Motorcycle Industry Council - Courier Vol. 3, No. 6
July/August 1573
Stresses the motorcycle industry view that the ceiling
on registrations and the restriction of two strobe cycle
use during certain months is not reasonable especially
since the industry had expressed willingness to meet
any reasonable emission standards.
Statement of Karl J. Phaler
See oral statement summary, pp. 286-293. Also, in
summary:
1. Questions motorcycle emission data.
2. No emission standards set.
3. Doesn't feel there would be a shift towards
motorcycles.
4. Energy use should be included, as should
refinery pollution accompanying fuel production.
5. Feels that an impact statement should accompany
the action.
6. Plan does not respond to need of people who
have only a motorcycle for transportation needs
not satisfied by public transit, bicycle or walking.
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-9-
549 35 Statement of Citizens Coordinate for Century 3
See oral statement summary, pp. 293-303.
552 36 Statement of L. E. Grinnell
Proposes 50 mph nationwide speed limit. Reduce
traffic signals and signs slowing or stopping
vehicles to encourage constant speed driving. Make
employers responsible for employees commute. Reduce
randdmness of shopper/shopping center trips through
system administered by center. Reduce long distance
auto trips by fuel rationing and mileage limits.
A tax on emissions is also recommended. Also recom-
mended a curb on visual air pollution by setting out-
door' advertising rates. Plan should look towards pre-
venting future deterioration as well as initial attain-
ment of' standards through land use consideration.
556 37 Statement of Lung Association of San Diego and
Imperial Counties
The' Association supports the EPA transportation
controls as a method of improving air quality.
558 38 Statement of San Diego Unified Port District
Are concerned about the parking restrictions.
Such'limits would restrict the Parks ability to
fulfill the community's need.. Parking near the
airport is an especially important necessity.
Since 40% of Lindberg Field flights are intracity,
alternative mass transit may be a goal, but is not
yet a reality." Feel that EPA is misguided, and wishes
to express "the strongest objection to what we (the
, Port) conceive to be a very ill-tempered approach..."
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-10-
Statement of Pancontinental Enterprises, Inc.
Stated that they have developed a device that may
be very useful in the retrofit program. Will submit
technical information.
City of San Diego, Bikeways - Technical Report and
Design Guidelines, Revised July 197?
Discussion of bicycling as a transportation
alternative in San Diego, and provides guidelines
for implementation.
Statement of Associated General Contractors of America
Pelt that stationary sources were to be asked for
excessive reductions compared to mobile source emissions.
(18 7% reduced auto emissions, 1094% reduction in
stationary sources).
Statement of San Diego Building Contractors Association
Questions the economic viability of the plan when
standards would be met anyway by 1982-1986. Questions
if the difference is worth upsetting the life style of
San Diego and making substantial investment in bus
transit.
Commend the SDAPCD plan to EPA for consideration.
Statement of Bob Schaefer
Feels EPA should set standards for motorcycles
and then encourage them as an alternative. Such
a procedure would reduce the necessity for new
off-ramps and put resources behind vapor seals on
gasoline pumps, industrial control, cleaner jet
"engines and other problems. !
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Editorial, Congress Should Amend the Clean Air Act
of 1970, Auto Club News Pictorial
Questions derivation of standards. Discusses
congressional "intent" and the limitations placed
on EPA by the Act. Urges new standards similar to
those set by California. Summarizes EPA proposed
plan.
Intentional congestion will aggravate pollution rather
than encourage buses and car pools. Gasoline limits
would require massive public support which is non-
existant and would lead to black marketing and out
of basin travel. Parking restrictions will increase
congestion and emissions. Questions motorcycle control
generally. Catalyst retrofit depends on unleaded
gasoline supply and large expenditives of money.
Statement of California Air Resources Board
in Letter""of July 9, 1973 to Robert Fri
Agree that vehicle maintenance, extension of imple-
mentation time and catalytic retrofit are necessary.
Disagree with other proposals due to feasibility and
enforcement problems.
1. Do not believe EPA has power to seek sanctions
against state or local agencies for non-implemen-
tation.
2. If use of autos is to be extensively controlled
in 1977, then it is inconsistent to require exten-
sive emission control devices in 1976,
3. Lack of alternative transit will result in severe
social impacts.
4. Restriction of gasoline sales would be virtually
impossible to enforce.
5. Do not support inspection and maintenance program.
It would be unsatisfactory for catalytic retrofit
vehicles. Service industry is unprepared for this
program.
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-12-
6. Bus/car pool lanes should be selected for benefit of
users, not congestion of single occupant vehicles.
7. Private facilities are not included under parking
restrictions.
8. Motorcycle restriction is easily circumvented and
difficult to enforce.
9. Retrofit program is sound.
10. Air pollution control should also affect Federal
transportation policies, power plant licensing.
Fuel allocation, etc.
605 The Clean Air Act does not empower EPA to require
implementation of the plan under threat of fine or
imprisonment.
Plan is inconsistent in requiring many expensive measures
prior to 1977, then ban use of many vehicles included
in retrofit program.
606 VMT reduction success is dependant upon availability
of alternatives. In San Diego this amounts to 15,000
additional buses with initial cost of approximately
§750 million. Support and operation of these buses
would be an additional financial burden.
Gasoline limitation would probably not receive necessary
public support to be successful. 1977 levels would
require elimination of sales to passenger cars and
less than half o the diesal fuel sales.
607 While questioning the locaded dynamometer test's
effectiveness with catalytic. Retrofit vehicles,
the ARB also pointed out that 50% rejection is ex-
cessive. Recent data show that control of the worst
20% of vehicles is almost as effective as controlling
them all.
Bus and car pool lane proposal cannot be implemented
in the time schedule proposed. Is based on congestion
factors rather than convenience or incentive. Could
aggravate emissions rather than solve the problem.
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Parking regulations may also increase emissions rather
than reduce them but will fail unless applied to
private facilities also.
Motorcycle restrictions will be hard to enforce, a
better approach would be control through emission
standards.
ARB argues with principals of catalytic retrofit
program. Success of implementation and feasibility
generally is dependant upon availability of unleaded
gasoline and prevent use of leaded fuel in catalyst-
equipped vehicles.
EPA should stress Federal funding to carry out pro-
posals. Low pollution fuel should be made available
to the region by Federal Power Commission policy
changes. Propose more stringent control for aircraft
emissions. Should promote a Federal policy of encourage-
ing nuclear power generating facilities. Should propose
danger in the Clean Air Act to avoid mandating requirements
that cannot be met.
Notice of Public Hearing
Notice of Public Hearing
Request for plan from Mr. N. Saslove
Statement of Marilyn Colombo
Supports clean air, explains the disadvantages
of walking and bicycling. Request alternative
to automobile transit.
Request to testify, San Diego Comprehensive
Health Planning Association
Statement of Mr. Sam S. Blane
Appeal to reconsider catalytic retrofit of 1966-70
high compression engine vehicles due to necessity of
using high octane fuels for responsible operation.
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-14-
Letter from Mr. Louis Alfano
Notes that fuels should be cleansed of pollutants
before sale. Additional testimony in oral record
pp. 125-128.
Letter from Elwith Hirth
Request for plan and additonal information.
Statement of BMW Riders of America
Questions motorcycle emission assumptions.
Advocates more motorcycles from traffic, energy
and parking point of view.
Letter form Legislative correspondant of BMW Riders
of America
Makes same proposals as letter on p. 23.
Letter from Mrs. Mary Fitzpatrick
Smokers and tobacco companies should also be
controlled.
Statement of San Diego Unified School District/
Community College District
Parking restriction will endanger long planned
expansion of presently inadequate parking facilities.
Restriction will degrade student - college relation-
ships as well as discourage attendance.
Statement of California Oil Jobbers Association
Oppose gasoline restrictions, two cycle motorcycle
ban, catalytic converters, stationary source controls
vapor controls. It's a complex problem and suggest a
basin by basin approach.
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Testimony scheduling request, County of San Diego,
Environmental Development Agency.
Letter from Lutheran Hospital Society
Response to telephone conversation regarding
applicability of plan to get project underway in
September.
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CONDENSED COMMENTS - LOS ANGELES HEARING AUGUST 9-10, 1973
Air Resources Board
While ARB's goals are similar to EPA's, ARB proposes a
different approach to solving the air quality problem in
California, but has not detailed a plan for the South Coast
Basin. ARB feels transportation controls should be planned ..
by local agencies once the lead agency has determined the
necessary reduction. ARB is concerned about lack of N0X
control. Particularly ARB does not support gas rationing
or loaded dynamometer testing, but stresses aircraft emission
control, emission standards for motorcycles and the impera-
tive of public support. Federal funds must be available for
mass transit.
Local Government
Much concern was expressed regarding the parking restric-
tions, especially 20% roll-back. Would result in severe econo-
mic problems such as bond redemption. Suggest fee surcharge as
alternate. Will adversely impact redevelopment projects.
Recommend further study on pollution importation to Coachella
Valley. Exclussive lanes will create problems and aggravate
congestion in Huntington Beach. Plans ignore growth trends.,
Local merchants will not tolerate parking reduction; capacity
is determined by peak loads at Christmas, Easter, etc. All
agree with Task Force recommendations. EPA should press
for a clean auto engine. EPA should work with local agencies
to reach a consensus on technical data concerning air quality
and control.
Regional Government
Supports improved air quality, but control system should
be practical in its effectiveness, method and cost. Task Force
Report endorsed by sixty cities recommends:
(1) improve EPA-local communication; (2) mandatory inspec-
tion/maintenance; (3) develop multimodal transit system (4)
adopt California emission standards; (5) expedite implementa-
tion; (6) uniform traffic control program; (7) automated signal
interconnects; (8) freeway ramp metering; (9)* special bus lanes,*
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(10) subscription buses and car pools; (11) fringe area parking?
(12) improve traffic operation; (13) emission standards for
motorcycles. No fuel rationing or parking restrictions.
Encourages episode planning. Urges reallocation of funds to
support mass transit.
San Bernardino County is determined to do what they can
to change land use, mobility modes; economics and life style
to improve air quality. Encourages use of San Bernardino as
testing area for controls. Federal funding should not be tied
to population growth.
SCRTD will have to double bus fleet to meet demands for
expansion. Increases operating deficit by $31 million/year.
Capital cost of expansion would run $104 million. Such an
expansion is without precident and success is dependant on
public reaction.
State Government
California Department of Transportation (CALDOT) volun-
teers its services as experienced transportation planners in
solving problems. Standards must be changed and will propose
amendments to the Act. Implementation of the proposed plan
must be analyzed for economic, social and environmental impact.
Will submit a plan by October 15 with a preliminary one by
August 31. Are presently testing bus lanes, ramp metering and
other controlled experimental projects. EPA time table is too
short and inflexible.
Los Angeles County Air Pollution Control District
Supplemented letter of August 1. The plan must deal
with hydrocarbon/nitrogen oxides ratio if adequate oxidant
control is to be achieved. Requested a waiver for California.
Program recommended involved:
(1) mass transit; (2) transit feeder service; (3) reduced
fares; (4) tax deductible parking and transit fares; (5) pre-
ferential car pool parking; (6) mini-bus system downtown;
(7) all new buses operated on LNG: (8) review all standards,
revise if necessary; (9) disperse new industrial and commercial
development; (10) special laning only where justified; (11).
encourage and support all approaches to improved vehicle flow;
(12) time extension to 1980 for standards compliance; (13)
allow California to run own program until 19 80 and then apply
more control if needed.
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Motorcycle/Auto Industry
Motorcycle industry disagrees with LA-4 testing cycle.
Disagrees with Southwest Report. Requests standards and
compliance schedule. Motorcycles can be controlled. Need
more data to justify severe restrictions. Question legality
of controls. Energy conservation is an important feature.
Disagree with mileage estimates, will submit additional data.
Motorcycle retrofit does not seem to be reasonable.
Auto industry spokesmen were: dealer association, parking
association and auto club. First two are concerned about
public reaction, economic chaos. Need for alternative prior
to strict control. Thinks the regulations are "overkill."
Regulations should be more positive.
Automobile club of Southern California wants complete
reassessment of government's program to improve air quality.
Primary standards are debatable, should be verified before
implementation. Should consider cost of each control measure.
Inspection/maintenance and exclusive lanes are not cost effec-
tive. Recommends: (1) clean engine; (2) smaller cars; (3)
car pools and subscription buses; (4) car pool priority at
metered on-ramps; (5) signal interconnects, channelization,
spot improvements, better signing; (6) realistic improvement
in public transit; (7) staggered work hours; (8) research
inspection and retrofit; (9) refine and implement episode
approach; (10) explore land use planning and growth control.
AAA does not support diversion from highway trust fund.
Petroleum Industry
Atlantic Richfield Co. support mass transit, smaller
autos, retrofit on applicable vehicles. Limit rationing to
smog season. Are researching vapor recovery systems for
bulk loading and retail operations. Question need for 0.08
ppm oxidant standard in view of impact of controls necessary
to achieve it.
Universal oil products reported on catalyst research,
applicability, problem solving, fuel consumption and avail-
ability of converters.
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Indus try, Mi scellaneous
Two groups that perform natural gas conversions on
automobiles commented on the benefits of this fuel, relative
cost, limited refueling points was the main inconvenience
in fleet operation. Vehicles converted could refuel at
home garage. Suggest tax on gasoline to subsidize low income
persons' conversions. Natural gas is cheaper. Could convert
50 to 100 thousand units with a 90 day lead time.
Shopping center group feels that centers should be exempt
from parking restrictions. Will submit data on VMT. Feel that
ElRs fulfill air quality analysis requirements.
Groups
Center for Law in the Public Interest feels plan is good
as far as it goes. Should provide curb on VMT growth through
land use control. Need a ban on fringe area development and
new freeways. County and highway planning do not consider air
quality constraints. The Lung Association thinks acceptance
will follow initial displeasure when benefits are visible.
Public health would be ill served by withholding action.
Sierra Club adds that new economic opportunities will arise
which will offset initial fears. Standard changes must be
proven by those advocating change. Problems in enforcing
parking regulations and limited advantages of exclusive lanes
may reduce effectiveness of the program. Support most other
proposals but have submitted an alternative program which,
they feel, would have greater public acceptance. Suggest
restriction of all "dirty vehicles" on 30 worst smog potential
days per year. Emphasize the right to clean air. Did not
feel the hearing had enough citizen participation. Transporta-
tion planning does not consider local needs, just corridors.
Bicycles may be able to reduce VMT 10-15%. Don't feel that
inspection and maintenance program would be much more than
present factory specified maintenance.
Industrial and business groups are all concerned about
economic and social impacts of proposals. Most advocate mass
transit, but it must be available before restriction the auto-
mobile. Say that 24% commuters need their cars during the day.
Traffic flow will be impeded by exclusive lanes. Parking restric-
tion will stop all construction projects. Clean Air Act must
be amended. Chamber of Commerce encourages retrofit program and
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suggests a pilot program. Pines for vehicles that don't pass
inspections. Urges voluntary car pooling. Parking restriction
places unreasonable burden of proof on new industrial/commer-
cial operations. Parking fee surcharge would not be effective.
Others indicated need for educational program. Alternative
to whole automobile must be developed, not just the engine.
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Citizens
Most people tended to express feelings similar to group
expressions summarized above.
Concerned that forcing mass transit now could cause
selection of a poor system. Urged considering alternatives
to internal combustion engine, like turbine, rail transit.
Should also control off-road activity such as race tracks.
Inconsistency of planning both freeways and gas rationing
concurrently.
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Auto/Motorcycle Industry
Expressed concern for VMT reduction, parking restriction
impact on life style. Alternate transit should be provided
before implementation. Should review air quality standards.
Should set standards that won't upset social and economic
life. Motorcycle industry wants standards set rather than
registration ceiling and use restriction~ Anxious to
cooperate.
Petroleum Industry
Atlantic Richfield presented information on their
research into evaporative loss reduction systems for fuel
transfers. Recommended catalytic retrofit for post-19 71
vehicles only. Gas rationing is not acceptable, Support
alternative transit, including diversion from Highway Trust
Fund.
Scientific Community
Research engineer advocated use of probability analysis
for predicting concentrations of oxidants. Showed EPA's plan
has an 80% chance of success in attaining standards.
Groups
Most stressed need for alternative transit. Business
groups protest parking and VMT restrictions. Many environ-
mental groups support all proposals. Motorcycle group
protested two-stroke cycle ban, requested emission standards.
If two-stroke cycles are controlled, then lawn mowers, out-
board motors, etc., should also be controlled. Many discussed
desirability of bicycle paths, walkways and other alternative
systems. One suggested ban on operation of all uncontrolled
vehicles, not just motorcycles. One recommended implementing
fuel rationing earlier in the program. Should also be trying
to reduce the need to travel as well as discouraging trips.
Suggest increasing efficiency of airplane trips by increasing
percentage occupancy, as well as more stringent emission
controls. Private parking must also be regulated. On-street
parking should be eliminated. A lot of concern for new
freeway construction in the Sacramento area was expressed.
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Condensed Comments,
Sacramento Transportation Plan Hearing - 8/10/73
Air Resources Board
The ARB stated that EPA lacked power to require State and
local agencies to enforce the plan. Described revision 3 of
the State's strategy and described differences. (Essentially
identical testimony as presented at other hearings) 1. No
loaded dynamometer testing, 2. Greater aircraft emission
control, 3. Controls motorcycle emission, 4. No fuel
rationing, 5. No VMT reduction, 6. No 1955-65 vehicle
retrofit, 7. Catalytic retrofit in San Francisco only,
8. Already have organic solvent controls, 9. Greater vapor
loss reduction at bulk and retail petroleum transfers.
State Government
CALDOT emphasized their role in VMT reduction planning,
problems with Clean Air Act and unattainable standards, impact
on economic and social systems. Stressed their experience in
traffic flow planning and exclusive lane implementation.
Dept. of Food and Agriculture cautioned on restricting
agricultural production. Most farm implements run on gasoline.
Seed extraction industry uses organic solvents and may be
restricted by non-reactive hydrocarbon emission limits. Agricul-
ture is sensitive to the problem as experienced by crop damage
due to air pollution.
Regional/County Government
Sacramento County Health Department will submit written
comments. Solono-Yolo APCD emphasizes corridor problem.
They are affected by proximity. Plan may overlook freight
moving contributions. Models are inaccurate.
Local Government
City of Modesto is too small for implementation of
special lanes to be effective.
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SUMMARY OF TESTIMONY TRANSFORATION CONTROL PLAN HEARING
LOS ANGELES AIR BASIN, AUGUST 9, 1973
3 Ms. Cassandra Dunn, EPA - Opening statement
9 Mr. David Calkins, EPA - Technical background statement
14 Mr. David Souten, EPA~~- Explanation of graphics
15 Mr. Calkins, EPA - Concluded technical remarks
21 Mayor Tom Bradley, Los Angeles
Announced that the City had formed a task force to
review the plan. Introduced Co-chairman for first statement.
Mr. Pete Schabarum, Chairman, Los Angeles Board of Supervisors
and Southern California Multiagency Governmental Task Force
Discussed background of represented groups, also history
of their review.
23 Plan could have a devastating effect on the economy
and well being of the region. Even implementing this plan,
air quality will not improve to the extent desired. Has
developed an alternate plan which could be implemented if
funding is made available. Sent the plan to EPA on July 30,
1973. Have had local level review and 60 cities and 5
counties have officially endorsed it. Agree with some of
the control concepts but usually not with the implementation
method proposed. EPA should push for a clean auto engine.
Urges EPA to work with local control agencies to reach a
concensus on technical data concerning air quality and
control. Entered July 30 letter into record.
28 Mayor Bradley, Los Angeles
Submitted a package of information. Cited Benjamin Davis
of DOT in questioning the value of parking restriction. Federal
government should cross-communicate within itself. Suggested
pushing for clean car from Detroit as well as tax disincentive
for vehicles with more than four cylinders. Parking must be
provided at feeder locations for buses and car pools. Suggested
surcharge on parking fees. Is not prepared to accept gas
rationing, additional taxes might be a proper direction to take.
Alternate transit will need operating as well as capital subsidy.
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QA Mayor of Bradley
Endorses region-wide transportation planning. Board has
not commented on, but is reviewing state legislation for applying
gas tax funds to mass transit support. EPA could provide guide-
lines for approaching parking surcharge. Do not object to basin
definition of air pollution control districts, especially with
problems that cross county or other governmental boundaries.
Much information exists which could be used in preparing an
environmental impact statement of the plan.
44 Glen Anderson, Congressman (statement read by Mrs. Anderson)
Acknowledges the severity of the existing pollution pro-
blem, however wants controls that will not "turn the Los
Angeles basin into a series of ghost towns." People will not
buy an unreasonable plan.
Rationing is unreasonable because of bootlegging, counter-
feit coupons, diversion of business, relocating development,
lack of auto alternatives. Would not receive public support.
Plan is inconsistent in requiring expenditure of massive
amounts of money, and then restricts vehicle use anyway.
Recommends improved traffic patterns, required control devices,
car pool incentives, taxes on cars with higher emissions and
a rapid transit system that can compete and surpass the auto
in speed, cost, comfort and efficiency. Should reduce speed
50 limit 50 55 mph. Additional highways do not meet the trans-
portation need. Supports tough air quality standards.
52 QA Mrs. Anderson
~ Will try to provide data indicating emission reduction
associated with rapid accident removals.
53 Mr. Baagen-Smit, California Air Resources Board
Referenced letter to Administrator Fri (summarized in
San Diego Hearing Summary) of July 9, 1973. Essentially
ARB has same goals as EPA but their plan differs:
1. No loaded dynamoneter testing.
2. Aircraft will be controlled to same degree as autos,
otherwise other sources require more control.
3. Does not support gas rationing.
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4. Plan needs public support.
5. Set emission standards for motorcycles, without retrofit,
without curtailment of use,
6. While VMT must be reduced, alternative transit must be
available. SCAG and other local agencies are working on a
transportation plan for short-term VMT reduction. CALDOT is
working with this effort.
Clean Air Act must be amended to provide flexibility
and orderly development of alternative transportation systems... ,
59 QA Dr. Haacjen-Smit
ARB dxd not propose a plan for Los Angeles area because of
time conflicts with EPA hearings, also wanted to reduce public
confusion. Was not able to design a plan to meet 1975 deadline
without having to decide when rationing would have to occur.
ARB is prepared to require 100% gasoline rationing if it is
necessary. Important to allow local agencies propose trans-
portation plans because they will be the ones to implement public
transit. Latest ARB revision of the implementation plan cites ARB
funding of research into the contribution of sources not typical
of motor vehicles or automobiles - including motorcycles, farm
implements, off road vehicles, boats, lawnmowers, etc. will con-
sider emission controls on these sources upon submission of the
report which is due in a month or so. Preliminary data will be
made available to EPA. Concerned that EPA's plan, is not directed
towards NOx control. Pederal funding should be recognized as a
necessary vehicle in attaining clean air, just as it was for
clean water.
67 Mr. Jack Cox for Congressman Barry Goldwater, Jr.
TheCongressman supports many of the proposals, but. not
parking and gasoline regulations. Standards should be flexible
The economic impact of clean air should be considered. All areas
of the country must comply, but special consideration should be
given Los Angeles. He will introduce legislation to provide
additional time for compliance. Cannot shelve the air pollution
problem until Los Angeles completes a mass transit system.. EPA
should work closely with DOT in solving transportation/pollution
problems. Mass transit funding should be prioritized to aid
urban areas with the most pressing problems. First, catalytic-,
converters are short-term devices, efficiency is also important
due to energy shortage. Advocates a smaller family car until
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a 'irijew, pollution free, engine can be produced. Either tax
incentive or governmental regulation could accelerate this
change. Will introduce legislation to promote disincentive on
large car use. Wants to amend Clean Air Act.
74 QA Mr. Cox
Proposed change would provide for economic factors being
considered in air pollution control.
76 Mr. A. C. Bernie for Mr. Haig Ayanian, CALDOT, District 7
Also represents Districts 5 & 8. They support the Task
Force Report as they were involved in that review.
CALDOT has the necessary experience in transportation
problem solving including car pooling, priority bus lanes and
freeway controls to assist EPA in solving problems. Standards
must be changed and will propose needed changes. Any implemen-
tation must be previously analyzed for economic, social and
environmental impacts. Would use prior existing transportation
planning structure to develop transportation control and alterna-
tive analysis. Will submit proposals prior to October 15. Will
have less impact, more in line with need for modal shift, but
would require substantial funding.
79 QA Mr. Bernie
CALDOT will be able to submit a preliminary copy of their
proposal by August 31. Freeway surveillance and controlled
experimental projects are currently being tried and would be
instituted on a wider basis. Cited current progress on bus
lanes, ramp metering, etc. Are in agreement with EPA objectives
but the time tables are far too short and too restrictive.
8 2 Mr. Robert Lunch, Los Angeles County Air Pollution Control
District
LACAPCD had commented in a letter of August 1, 1973 but
submits additional information. Written comments cited several
fundamental considerations that should be taken into account
before finalizing the regulation. Used charts indicating hydro-
carbon/NOx ratios with the various oxidant concentrations that
would occur. Indicated that oxidant concentration would be
reduced with NOx reduction. The 196 0 smog abatement action was
aimed at just hydrocarbon, it aggravated the air pollution situa-
tion from moderate to more severe. It wasn't until 1971 when
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NOx emissions were reduced that improvement merit was indicated.
Does not feel that the ratios selected in the emission standards
is proper to allow attainment of the standard. The California
program based on interim Federal standards would make progress
in meeting oxidant goals by 1985, but not for NOx, and the
oxidant standards is not met by 1980. Requested that California
be granted its waiver to enact a program designed to solve
California's problem. Recommend:
1. Encourage mass transit (rail, bus or others).
2. Expand transit feeder services.
3. Reduce fares to increase attractiveness,
4. Make both parking and transit employer supported
and tax deductible.
5. Encourage preferential parking for car pools
carrying three or more.
6. Expand mini-bus system in central Los Angeles.
7. All new buses to operate on LNG.
8. Review all standards with a view towards their
revision where called for.
9. Encourage the dispersion of new industrial and
commercial development to sparsely populated areas.
10. Impose special laws for buses and car pools only
where justified.
11. Encourage and financially support all proven
approaches to improve vehicle flow,
12. Request time extension to 1980 for meeting
standards,
13, Establish the 1975 emission standards that California
originally requested, or grant a permanant waiver to
establish its own vehicle emission control standards
and program.
14. Review California's air quality after 19 80 and
establish more stringent regulations as required.
QA Mr. Lunch
CO Standard could be met without cataytic converters,
just with a revised emission standard which could meet both
CO and NOx. CO emission standard was set low purposely to
force use of catalytic converters. Mr. Lunch's charts apply to
all of the South Coast Air Basin, Explains the concept that if
all cars were taken off the road the standard would not met due
to natural background levels. That the standard can be met,
if vehicle emission standards are set in the proper proportion.
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97 Mrs. Whitecraft, Transit Action Chairwoman, League of
Women Voters of Los Angeles County
Endorses car pool/bus lanes. Buses are not a permanent
answer, will need mass transit. Would rather see no changes
in local agencies if such changes would delay mass transit.
Need a regional authority for air quality, land use and
transportation for long-range coordination. Support inspection/
maintenance proposal. Support parking and fuel restrictions
to reduce VMT. Requires substantial funding, but deserve it
due to large tax revenue derived from the area.
99 Mr. James Neal, City Manager, Fountain Valley
Supports the Task Force Alternate program. Submitted
written comments.
00 Mrs. Mary Nichols, Center for Law in the Public Interest
Think EPA plan xs good as far as it goes. Must be designed
to curb VMT growth. Clean Air Act mandates land use controls in
areas where necessary to meet ambient air quality standards.
Recommends:
1. Ban on development in fringe areas; includes stringent
enforcement of complex source regulations.
2. Absolute ban on construction of new freeways in the basin
until standards are attained.
Wish to highlight county master plan which calls for
expansion and sprawl into outlying areas. Also Division of
Highway's own figures for 1-105 show a 25% VMT increase in
the corridor once it is constructed. State and County have
failed to recognize the logical implications of the Clean Air
Act.
104
QA Ms. Nichols
Will suggest legal language to conform to Clean Air Act
requirements.
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194 Mr. Joseph Sarkees, California Motorcycle Industry Council -
Economic impact of registration ceiling will be severe.
Publicity alone has affected sales. Standards should be
set. Industry is willing to cooperate. Doesn't agree
with 3-4 year life expectancy of two-stroke motorcycles,
most don't last that long.
200-202 End of hearing comments by Mr. Walker.
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Condensed Comments - San Francisco Hearing, August 8, 1973
Local Government - Concerned about parking restrictions' effect
on urban renewal projects. Exclusive lanes are diffi-
cult to implement. Flan should integrate with MTC's
RTF and other local master plans. Advocate Highway
Trust fund allocation to mass transit. Support CALDOT
program. Question standards.
Regional Government - Supports the Regional Transportation
Plan developed by MTC. Question standards. Model for
predicting oxidant rollback is inaccurate. Caution on
retrofit program is VMT reduction is unavoidable.
Motorcycles should be retrofit and emission controlled.
Single-day rationing wouldn't work. Parking restric-
tions shouldn't impact BART Parking.
State Government - The University wants an exemption to parking
restriction. CALDOT urges review of Clean Air Act.
CALDOT is willing to cooperate fully in revising the
program. Peel that State program would be effective
if funded.
ARB proposes emission standards for motorcycles,
greater control of aircraft, idle emission tests, no
fuel rationing, relies on MTC for VMT reduction. Cata-
lytic retrofit applied to only South Coast and San.
Francisco basins.
Groups - Expressed varying viewpoints. Business related groups
were highly critical of parking and VMT restrictions.
Environmental groups advocate holding the line. Im-
portant to provide alternative transportation systems.
Bicycle organizations emphasize the VMT reducing po-
tential of that mode and want bikeways placed as an
equal partner to car pools, bus lanes, etc. Health
organizations urge maintaining the proposals; data is
sufficient to justify standards; Public Health should
be given primacy in decision making, not weighed against
economic cost. League of women voters advocate a
regional, elected government to deal with these matters.
San Francisco Airport expansion should be reviewed
based on increased auto and aircraft emissions. Al-
ternative airport service expansion must be explored.
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Auto Industry and Motorcycle interests - critical of program,
especially VMT reduction, parking restrictions, inspec-
tion program, dangers of retrofitting and lack of con-
sideration for motorcycle industry.
•
Industry - DuPont de Nemours and Company presented technical
evaluation of stationary source control program. Spe-
cific wording changes and regulation changes suggested.
Citizens - Many viewpoints were expressed both for and against
parts of the proposal. Motorcycle enthusiasts advocate
setting emission standards once adequate data is avail-
able. Motorcycles should be controlled but encouraged
due to energy economies.
Detroit should be required to produce clean automobiles.
One suggested a limit on idle time of buses and taxis
with fines payable by the driver for enforcement.
Government should lead the way by buying lower horse-
power autos. Must provide good alternative transit.
Gasoline taxes should pay for vapor control systems at
gasoline stations. Parking restrictions should re-
flect shopper/commuter mix. Should enact 207(b) of the
act as well as other warranty provisions for consumer
protection and to reduce backlash. Tobacco smoke may
be important in causing smog. Auto industry blamed as
well as trucks and buses. Plan is all right conceptu-
ally but errs in degree. Must take another look at
role of NOx.
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Summary Of Testimony: Public Hearing On
Transportation Plan for California -
Sacramento Valley Air Basin, August 10, 1973
1 Mr. Mathew Walker, EPA - Opening statement,
5 Mr. Allen B. Lemmon, Air Resources Board - Entered
Dr. Haagen-Smit's July 9, 1973 letter to Administrator Fri
regarding the South Coast Transportation Control Plan
{summarized in San Diego Hearing Summary}. Essentially,
ARB doesn't agree that EPA has the power to force local
agencies to implement the plan. EPA was aware that
California had completed revision 3 to the implementation
plan including controls in the Sacramento Region.
Governor Reagan has transmitted that plan to EPA. ARB's
plan:
1. Does not use loaded dynamometer testing
2. Assumes greater aircraft emission control
3. Sets emission standards for motorcycles
4. Does not support fuel rationing
5. Does not propose VMT reduction
6. Does not plan to retrofit 1955-65 vehicles
7. Proposed catalytic retrofit in San Francisco Air Basin
8. Already have stringent organic solvent limits in
Sacramento and Yolo Counties
9. More vapor control at petroleum distribution and
marketing points in urban areas.
Prediction techniques are not accurate enough to justify
fuel rationing. Compliance schedules are unrealistic.
Urges EPA to determine amount and sources for funding
each measure. State urges revision of the Clean Air Act
to allow EPA more flexibility and an orderly development
of alternate transportation systems.
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13 Mr. Ron Meuller, EPA - Technical background statement.
24 Mr, John Mltchiner, Research Engineer, U.C. Davis - Discussed
probability analysis m predicting oxidant concentrations.
It is impossible to guarantee compliance with oxidant
standard with any rollback level. The greater the roll-
back, the greater the assurance of meeting the standard.
The EPA rollback has about 80% probability of meeting the
required level. Increasing the number of days on which
the 0.08 ppm level can be reached, decreases the level of
rollback required. With a 33% emission reduction one
summer out of two would show one day with 0.20 ppm oxidant,
three days per summer would reach 0.15 ppm and 20 days per
sximmer at the 0.10 ppm level. While not recommending
relaxing the standard, does encourage a strong look at
the 0.08 ppm oxidant level.
31 QA_ Mr. Mitchiner - The analysis assumes 100% enforcement.
EPA proposal would not, in all likelihood, meet the
oxidant standard,
33 Mr. Qrren Turner, Sacramento County Health Agency - Sacramento
County intends to comment in writing. Inserted a letter
to EPA from Joseph Sheedy of August 6, 1973. The review
time allowed is too short in which to respond. Will try
to respond by August 31, 1973, but would appreciate an
additional 30 days.
35 QA Mr. Turner - EPA is not able to accomodate extensions of
time dueto court imposed deadlines.
37 Mr. James Koslow, Air Pollution Control Officer, Yolo-Solono
Mr Pollution ControlDistrict -Their district becomesa
part of the Sacramento control problem by proximity to the
Sacramento-San Francisco corridor. Control in Sacramento
will shift problem to Yolo County.
Feels that consideration for people is lacking in the
proposals. Requirement for vapor recovery system is for
an unknown automobile and an unproven (perhaps unreliable)
system. Enforcement should be consistent with what is
available. Freight transfer might be a greater problem
than is recognized. Rollback model is inaccurate; how
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can sincle point rollback prediction be applied to the whole
Sacramento Regional Planning Commission area.
40 Mr. Carmody, City of Modesto - Submitted written statement.
City xs too small for special lanes, carpools, etc., to
make much sense.
43 Mr. Don Cox, Asst. Manager, Greater Modesto Chamber of
Commerce - Submitted written comment. Unanimously opposes
the EPA plan. Plan is inflexible, unworkable and would
create economic chaos. Reduction of VMT could seriously
impact the "agri-business" industry. The price is too
high to pay for clean air.
45 Mr. Tom Berglund, Director, Downtown Improvement District
(Modesto) and President CaliforniaDowntown Executives
Association - Parking is critical tourban redevelopment.
Should distinguish 8-hour from 2-hour parking. Smog
stations are located in the worst air areas, makes most
severe controls needed.
47 Jane Hagedern, Environmental Council of Sacramento - Although
everyone prefers a local solution, the air pollution/
automobile problem is such that it will not be solved
without Federal planning. Local APCD controls the sta-
tionary sources, but the major problem is now auto
emissions. Freeways, planned 10-15 years ago, and not
needed today, are being built for no reason, but will
allow further pollution. ARB has shown itself to be
incapable of even emission control retrofit program.
ECOS supports the Clean Air Act. It is one "of the few
tools that...the people can rely upon to help...work for
a decent environment." Proposed control measures are
feasible, reasonable and compare favorably in cost with
constructing more freeways. Want alternatives to auto
transit. Incumbent on the Federal Government to fund
(divert from Highway Trust Fund) various transit modes.
Urge the plan to be enforced as soon as possible.
Strongly oppose amendment of the Clean Air Act.
53 Mrs. Virginia Zbur, Sacramento Transportation-Zero Pollution
Organization - Recently submitted Sacramento County
supervisors with a 5,462 signature petition requesting a
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halt to freeways 65, 143, 102, 244 in favor of balanced
transit system available to non-auto users. EPA's plan
is very good. Air standards must not be lowered. More
is necessary. Therefore, do not build unnecessary free-
ways and place a yearly tax on larger cars and trucks.
Differential speed limits with carpools allowed a higher
limit than single occupancy autos. Concerned for children
having to restrict activity as is done in Los Angeles.
55 Ms. Carolyn'Martin, Amercian Association of University Women,
Sacramento Branch - ARB *s plan was too passive. EPA
offers reasonable alternatives to the public. County's
bikeways are attractive, but should include commuter
routes as well as recreation. Public re-education is
necessary to change habits, but must provide alternative
transportation. Welcome Federal standards.
S? Miss Katherine Agruss, League of Women Voters - Supports the
Clean Air Act and standards promulgated under it. Enforce-
ment should be local with Federal retaining ultimate power.
League is willing to work for more controls on individual
use of fuels and vehicles. Want improvement soon.
Opposes changing air standards. Favor a more balanced
transit system. Increase parking fees, eliminate on-street
parking, discourage more downtown parking, regulate com-
plex sources, are all suggested to reduce emissions.
Employers should provide incentives for patronizing
transit systems, carpools, etc. Must also control private
parking. Motorcycles must be emission controlled at least,
ban seems to be unfair. Even without enough buses, car-
pooling could make difference to not require gas rationing
and avert economic or social disruption.
62 Clifford Trammel, Director of Environmental Services,
Engineering and Grading Contractors Association - Agency
should have some flexibility in proposing workable,
feasible plans. Favor bus mode transit additions. Fixed
rail system is too fixed and inflexible. Would support
true rapid transit system if it would work, until then
supports the automobile as closest mode preserving inde-
pendence of movement. Catalytic converters should be
mandated. Should consider: freeways with no access
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through town, access only at urban center, ban autos in
urban center but provide electric vehicles. Mass rail
transit will be inflexible to technologic change - highways
will always be adaptable. If Clean Air Act requires
unworkable solutions, then change it.
6 7 QA Mr. Trammel - Not all EPA1s proposals are necessarily
unworkable or impracticable, but EPA is under court order
to proceed. EPA will inform Congress of attainable levels.
6 9 Clifford Humphrey, Ecology Action Educational Institute -
Local officials are too economically competitive to view
the problem of air quality in its proper context. EAEI
supports the thrust of all EPA control proposals. Gaso-
line rationing can have additional benefits beside air
quality. Bicycles should receive more visibility, along
with better storage facilities, more bike paths and
statewide computer registry to control theft problem.
Curbside parking should be restricted first, then as gas
tax revenues accumulate, could provide parking support-
ive of mass transit system. Consider propane conversions
for intensive use vehicles. Crops may be more sensitive
to pollutants than humans, which may indicate the desir-
ability of attaining higher quality air to protect the
agricultural economy. Wil submit additional written
comments.
73 Mr. Clark Graham, Auto Dealer - Has submitted written comments.
Concerned about the lifestyle change necessitated by EPA
proposals. Due to nature of Sacramento, mobility is
critical. Would be an undue hardship on all who depend
on auto transportation for their livelihood. Until other
transit is available, the plan is unreasonable. Will
result in eonomic chaos. Great chance of adopting the
wrong type of system. Calls attention to BART and time
required to get it "somewhat functional." Cost would be
staggering. Congress must balance economic and social
needs against "desire for clean air." Urges review of
"automotive environmental standards", and delay implemen-
tation until review is complete.
Must establish health standards for air quality that can
be obtained without upsetting our economic and social life.
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78 QA Mr. Graham - People are tending to purchase smaller autos.
78 Mr. Virgil Anderson, California State Automobile Association -
Has submitted written comments. Previously testified at
San Francisco and Fresno. Expect improving air quality-
trend to continue. The Act and court order have combined
to necessitate unworkable, unrealistic proposals. Feels
that State has achieved much progress in improving air
quality. Did not repeat testimony presented at other
hearings.
82 Mr. Bob Fereshatian - Supports EPA proposals, has already
joined a carpool. Expressed specific support for all
measures. Concerned about highways 143, 244, 102 and 65.
Wishes these projects to be discouraged,
85 Mr. David Conklin, Manager of Environmental Protection,
Aerojet. Solid Propulsion Company - Supports EPA efforts in
achieving clean air standards. However, disagree with
Section 52.521, Control of Degreasing Operations. Cited
reasons why Aerojet must use trichloroethylene in hot
degreasing of aluminum items and finely divided aluminum
particulate. Hot trichloroethane degreasing would evolve
hydrogen gas, resulting in a safety hazard. Perchloro-
ethylene would be the introduction of an unknown into the
process requiring extensive testing of the process. Such
a substitution would have to be precluded in the produc-
tion of a weapons system wherein all possible failure
modes have been thoroughly analyzed and eliminated.
Have installed cold traps which comply with SCAPCD regu-
lation. Feels that control should be aimed at the major
offenders - automobiles - instead of the 1.6 ton/day
degreasers.
89 QA Mr. Conklin ~ Urges EPA to cease delays in controlling auto
emissions. EPA has a good program. Aerojet has 2,500
employees with free parking designed for 20,700. Company
is open to suggestions regarding alternative employee
transit.
90 Mr. Walker, EPA - Opening statement.
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94 Mr. Sam Helver, Directory State Department of Transportation,
District III - Are in agreement with intent of Clean Air
Act, but recognize specific requirements as unachievable.
Congress must resolve this dilemma.
Standards are neither appropriate nor attainable. State
will recommend changes. While actions should not be
dismissed, they must be evaluated in social, economic,
environmental impact terms. State is using a team approach
in a "crash" program. Have extensive experience with
preferential lanes and traffic control. Are cooperating
with Regional Planning Agencies in developing transporta-
tion proposals which will improve air quality, can be
implemented if funded, have general support of RTPA's.
A written statement will be submitted.
9 7 QA Mr. Helwer - State DOT has a full-time bicycle coordinator.
Local agencies are still responsible for developing a
bicycle path master plan,
9 8 Mr. C. F. Kay, Atlantic Richfield Co. - Standards will not be
met by 1977 without severe economic and social impacts.
ARCo has devoted much effort in researching associated
problems. Support diversion of Highway Trust Fund to
support upgrading public transportation systems. Gas
rationing is not acceptable. Support the inspection
program. Effectiveness of retrofit is variable. Catalytic
retrofit should be restricted to post-1971 vehicles.
Should allow normal attrition of pre-1971 vehicles. ARCo
agrees with vapor emission recovery program from fuel
handling operations. ARCo is researching retail sale
control systems, should delay implementation until proven
systems are developed. Of all systems under consideration,
experience is too limited to demonstrate reliability.
Regulation should just stipulate the minimum percent of
vapor loss that must be recovered. The system itself
should not be described beyond a demonstration of safe
and reliable operation. Section 52.254, change 95%
recovery to 90%. This would be in line with systems in
operation in Los Angeles and Washington, D.C.
105 QA Mr. Kay - Recovery systems are several years away for
proper development. ARCo is testing systems at Harvey
Technical Research Center outside Chicago, Illinois.
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Testing both bulk and retail operation control. ARCo
subsidizes special bus transit for employees at their
Los Angeles headquarters. Mr. Mrstick of ARCo indicated
that bladder type or floating membranes in vehicle
gasoline tanks were more of an automobile manufacturer's
concern than the petroleum industry's. American Petroleum
Industry is also researching evaporative loss recovery
systems.
Ill Mr. Frank Cancilla, Jr., Motorcycle Distributor (Hodaka) -
Requested access to motorcycle emission data. Protested
restrictions on motorcycles. Wants extension of time for
motorcycle control.
116 Ms. Myra Erwin - We are fortunate to have the Clean Air Act.
Supports all the controls. Need alternatives to the
automobile.
117 Mr. Jack Dennison - Wanted to know procedures by which
standards were established. Felt industries should have
made their point previously.
124 Mr. Harry Krade, California State Department of Food and
Agriculture, and the State Board of Agriculture - Cautioned
rationing gasoline in prime agricultural areas. Base year
selected had below-normal farm vehicle use due to adverse
weather conditions. Fuel priorities should be established
recognizing these factors. VMT reduction measures like
special lanes are inappropriate in rural towns.
Restrictions on organic solvents could disrupt large seed
extraction process industries (cottonseed oil, safflower
oil, etc.). Should reflect size of operation and process
requirements.
3000 pound/day organic material emission limit for non-
photochemical ly reactive organic solvent or material
containing such solvent, needs interpretations. Does this
include deliydrators, grain dryers, canneries, other
agricultural processes? The agriculture industry is
anxious to assist to meeting standards since air pollution
impact on crops is known.
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130 QA Mr. Krade - Will try to provide information on solvents
used in seed extraction industry. Most farm vehicles are
gasoline powered, transport and processing are generally
diesel powered.
131 Mr. John Hoeflich, Graduate Student in Physics - Can present
data on five alternatives to the internal combusion
engine (vapor turbine of duPont, steam bus). Does not
feel that industry would need until 1983 to produce an
alternative power plant for automobiles. If money spent
on highways and autos had been spent for rail systems,
it would have been a great system. Cities would require
redesigning for other than auto transportation.
136 Mrs. Thomas Allen - Protests development of highway 5 through
South Sacramento.
143 Mr. Peter Vacco, Motorcycle Dealer - Questions source and data
of motorcycle emissions. Wants clean air and to be in
business too. Industry should have some time to develop
controls.
148 Mrs. Dixie Richard, South Placer Association for County
Environment - SPACE was organized to gather information on
planning and development. Hope that EPA's proposal will
affect master plan revision in Roseville area. Are
appalled that air has degraded so far. Urges government
coordination of programs. Government should encourage its
own employees to carpool or bus. Is Sacramento Basin
suffering from Bay Area smog? Urges control of aircraft
emissions and increase number of persons on planes before
flights are permitted. Private parking must also be
regulated.
154 Mr. Leo Lake, Yamaha International Corporation - Yamaha will
produce machines that emit lesser amounts of hydrocarbon.
Will refine their product in the same developmental time
span accorded auto industry. Will attempt a 1975 vehicle
with 50% reduced hydrocarbon from 1970 motorcycle. Pro-
vided latest emission data from their two-stroke cycles
(from 9.8 g/mile to 25 g/mile). Will comment also in
writing on testing procedures. Hopes to continue good
working relationship with EPA.
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158 QA Mr. Lake - Retrofit does not appear to be practical.
Present hydrocarbon emission is too great for catalytic
converter to be practical.
Average life of motorcycles is between three and four
years.
160 Mr. Leonard Wood - Agree with intent of EPA plan. It does
not control off-road operations, however. Auto races at
Placer County Fairgrounds create both noise and air
pollution. Related the history of his unfruitful struggle
with local authorities in gaining relief from fairgrounds
pollution.
175 Mr. C. M. Auble, Fair Oaks Citizen's Advisory Committee -
Committee wants alternative to automobiles, especially
walkways, bike paths and improved public transportation.
Wants the need for freeways to be re-evaluated.
Ban on operation should apply to all uncontrolled vehicles
of any design with an emission standard used as criterion.
Public transportation must be approached on a system basis
and be made convenient. Rationing fuels should be insti-
tuted earlier in the planning schedule. Could use ration
coupons as rewards for clean cars, buying bus tickets,
etc. Should try to reduce the need to travel.
Improve communication, good electronics could reduce
travel need.
181 Mr. Bruce Quinn - More tests should be run before restricting
two-stroke motorcycles. Feels great need for mass transit.
Incongruous to discuss gas rationing when freeways are
being planned and constructed. Opposed to catalysts and
gas rationing,
185 Mr. Walker, EPA - Opening remarks - evening session.
188 Mr. Henry Schroeder, Lodi Trail Breakers - Opposes restric-
tions on two-stroke cycles. Doesn't restrict lawn
mowers, outboard motors, private aircraft, commercial
vehicles, farm implements and others. Apply standards
for new motorcycles. Seems as though restriction is
disproportionate. Doesn't consider that motorcyclists
will use other forms of transportation.
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Transportation Control Plan Hearing Summary
San Francisco, August 8, 1973
1 Index
2 Mr• Eckerman, EPA - Opening remarks
3 Mr, Calkins, EPA - Technical background statement
24 Mayor Reading, Oakland - City of Oakland unanimously
opposes thecontrols and will submit specific comments
*• later. Feels that parking limits are not attuned to
existing plans. Creates a bias against central cities.
ABAG favors city-centered structure to refocus growth,
the EPA proposals would not encourage this plan,
26 Threatens community endorsed projects like the Oakland
City Center Project. This urban renewal project would
be "completely dead" with these parking restrictions.
27 Plan should refer to vehicular parking so as to prevent
private interests from undertaking open-space reducing
parking lot construction, in the interests of even-
handed consideration.
28-40 Written submittal of City of Oakland.
28 Permit for parking construction should provide assurance
of planning compatability, full detail of use of the
facility, how it enhances other environmental programs
(BART), and requires public hearing.
36 Regulation does not differentiate between short and
long term parking. Effect is not known in terms of
decreasing retail activity. Reduction in public
parking in bond-funded lots might result in legal
suits by bond holders.
37 Signs for exclusive lanes would create excessive visual
pollution.
38 Exclusive lanes in city are hard to visualize due to
lane changes, turning requirements, etc.
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40 Should integrate plan through MTC into Regional Trans-
portation Plan.
41 0^. Mayor Reading - Urban redevelopment could reduce VMT
as well as parking restrictions. Is not the goal of
plan to stall redevelopment.
42 Thomas Lammers, Business Director, CALDOT - urges that
EPA request Congress to consider what is desired and
what is attainable within the time frame imposed by the
act.
CALDOT is willing to cooperate in revising the plan.
Plan would require 20,000 more bases in the Bay area.
44 Assembly Bill 69 provides an effective framework for
planning transportation proposals in order to improve
air quality, feasible if funded, have general support,
long term environmental benefits.
46 QA Mr. Lammers - 20% VMT reduction year-round. The
additional 65% reduction would occur on high smog po-
tential days only.
46 Mr. Allen B. Lemmon, California State Air Resources
Board - Entered ARB letter of July 9, 1973 to Acting
Administrator Fri into record (summarized in San Diego
Hearing Summary).
48 ARB has completed revision 3 of the air implementation
plan which dealt with San Francisco.
1. Plan does not rely on loaded dynamometer testing.
2. Control aircraft emissions to same degree as are
auto emissions. EPA proposes less than 30%
emission reduction.
3. ARB proposes emission standards for motorcycles
in preference to use or registration restrictions.
4. ARB does not propose nor support fuel rationing.
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5. Recognizes VMT reduction necessity. MTC is to
propose plan to achieve necessary reduction.
ARB urges EPA to work with ARB, CALDOT and MTC
in developing a feasible plan.
6. Catalytic retrofit should be limited to San
Francisco and South Coast basins.
7. ARB requires BAAPCD to adopt regulations limiting
organic solvent usage, but dropped a proposal to
control dry cleaning operations.
51 Pointed out inaccuracies inherent in predicting rollback
of emissions and VMT required to meet standard.
Urges EPA to determine funding necessary to carry out
each measure.
53 Letter to Dr. Fri. (summarized in San Diego Hearing
Summary).
66 QA Mr. Leroroon
State plan, (including MTC's RTP) if acceptable, would
be implemented in preference to EPA proposals. ARB
has not done any testing of aircraft emission reductions
due to Federal preemption. ARB will seek authority to
require catalytic retrofit, if testing shows success.
70 Mr. P. J. Callaghan, Air Pollution Control Officer,
Bay Area - Introduced Joseph Bort of MTC to make joint
BAAPCD/MTC presentation
70 Mr. Joseph Bort, Metropolitan Transportation Commission
- Bay Area Air Pollution Control District - MTC is
involved in transportation planning in the Bay area.
It has developed a "transit first policy deemphasizing
highways. The RTP developed, the MTC feels, is con-
cerned with improving air quality and is realistic and
achievable.
-------
73 EPA plan is based on inaccurate, unscientific assump-
tions, is singleminded, short-term, unrealistic, im-
practical and legally questionable.
75 Questions SPA adoption of the 0.08 ppm maximum 1-hour
oxidant standard. The impacts associated with 84% VMT
reduction involves too severe an economic and social
impact, especially since the reduction is determined
based on the inaccurate linear rollback model. BAAPCD
is working with Lawrence Livermore Laboratory, NASA/
Ames to develop a model that incorporates topography,
meterology and photochemical factors. Feels that NOx
may prove to be more important than RHC.
77 Questions base year concept for predicting rollback.
Also the assumptions used in predicting emissions are
imprecise and do not reflect "real vehicles."
78 VMT reductions should be aimed at the morning commute
period rather than at 24 hr. average emissions.
79 Controls cannot be supported until vmt reductions needed
are accurately predictable.
80 BAAPCD has regulations requiring retail sale gasoline
vapor recovery systems at all new gas stations and for
all existing ones in July 1974.
81 Cautions requiring retrofit if severe VMT reductions
are to follow anyway.
Better motorcyle regulation would involve retrofit,
emission standard, or total elimination.
82 Agreed with Mayor Reading on impact of other restric-
tions and the need to integrate planning. EPA plan
should define sources of funding that will provide
alternative transit.
84 Questions feasibility of single-day rationing of gaso-
line due to large quantity in service on any given day,
therefore leaves VMT reduction up to individual discre-
tion.
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85 QA Mr. Bort - Mr. Bort contends that EPA's consideration
of social impacts of the controls did not come through.
90 Although MTC does not have implementing authority over
the RTP, they would welcome it if accompanied by
funding and control over other transit systems (bridges,
etc.). Mr. Souten of EPA reviewed the similarities
of MTC/BAAPCD plan to EPA's.
94 Mr. George Merrill, Chief, Auxilliary and Business
Services, California State University and College
System - submitted a copy of letter sent to Mr. Pri.
Parking limits would affect schools in achieving ade-
quate facilities to serve the majority commuting student
body. Only 2% of staff/students are presently able to
use public transportation. Request an exemption of
parking restrictions for universities and colleges.
Introduced Mr. Chapman.
98 Mr. Mayer Chapman, Associate General Counsel,
California State University and College System - Revenue
bonds finance parking program and would be endangered
by parking restrictions. Regulation is worded such
that all "public agency parking" is affected.
99 Letter to Administrator Fri from Edroond Macias,
(Assistant Vice Chancellor, Business Affairs, California
State University and College System) - The State
University and College System conducted a two-year study
of commute habits and tried to coordinate commute
services. Found it to be a very complex problem due
to staggered hours and needs of students. Control of
20% of spaces would reduce student/parking ratio from
four to 1, to five to one. Projects increase VMT due
to parking space search.
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105 The revenue bonds specify that the Board cannot remove,
dispose or sell any parking spaces. Legal propriety
of regulations which threaten the fiscal structure of
the bonds.
107 QA Mr. Merrill - Student parking is self supporting
fErough fees. Does not feel that a bicycle lane system
would reduce parking need by 20%.
110 Mr. Bill Doreus, San Francisco Muni Railway - Muni
Figures a 20% reduction in parking (and therefore VMT)
would require 33% increase in public transit. This
more funding. Trolleys will be replaced by modern
electrified equipment over the next two or three years.
Muni is also constructing the "muni-metro" subway along
Market Street. Busways and car pools are band aid
solutions to the basic transit problem. Long-term,
comfortable solutions are rail forms and take a long
time to build.
113 QA Mr. Doreus - Muni feels bus lanes could stabilize
service and improve quality of ride on some corridors.
116 Mr. Mike Henshaw, American Motorcycle Association -
Motorcycles should be encouraged due to energy conser-
vation. EPA admits lack of data but bans the use of
two stroke cycles for much of the year. Recommends
developing a control technology for motorcycles.
120 QA Mr. Henshaw - Motorcycle industry should benefit by
same delays given the auto industry.
123 Mr. Mark Owens, Assistant Vice-President, Director of
Business Affairs, Unive"rsity of California - Comments
are not limitedto this region alone, butto all trans-
portation control areas where the University has cam-
pus.
Is not sure that that Administrator intended to impact
educational institutions. Has filed comments with the
Administrator in this regard.
University is actively researching pollution control
systems (electrostatic precipitators, recirculating
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.¦ ( t carburetor-,; new ^catalysts) ,..;.b:Odd working and class hours
make, public (transit, eventless reliable. .Serious parking
problems presently exist* Bicycles are not the safest
• . solution.,either-. Feels'the-public university if being
controlled, .unfairly if: .the. .private, college is. not also
controlled.
129 ; , : Qi\-toQv^e|iSi r-r .wo.uldr>.f a.v.orvr.eceiving a plan con- £
sTdering all -facilities', operated: by the University
within..;,th.e-, basin., The.aUniversity.diS.. working .with Mayor
Bra,di.eyJ.s ;people .i-nrL,Q.s;transit,might offset- parking
reduction.,;;,but bond
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the principles of exploitation and more quantity for
the principles of cooperation and better quality. BART
must not be allowed to become overcrowded.
142 Motorcycles should have both noise and emissions con-
trolled and regular inspections. Bus, truck and air-
craft emission controls should also be kept on a tight
schedule.
143 Land use vs. transportation system should also be ba-
lanced.
Need multi-mode transit such that should one fail, the
transportation system will not fail. Complex sources
deserve special attention. Federal funding should be
more available for transit. Generally supports pro-
posals. Trust fund should be used for non-highway
transit. Should condition all Federal grants with
proviso for meeting this plan.
146 Mayor Joe Alioto, San Francisco - submitted written
statement on regulations. Ought to use Highway Trust
Fund to build transit systems. Wishes EPA to re-open
the consent decree to auto manufacturers removing mo-
tives for developing pollution abatement equipment.
157 Written statement of Mayor Alioto. Supports CALDOT's
program. Feel that VMT reduction measures combined with
bus/car pool lanes will shunt 35,000 VMT onto adjacent
streets adding to congestion, adversely impacting
"Neighborhood Protected Streets Program". Similarly
the 87,000 VMT reduction from freeways may be shifted
to the City street system.
161 Signing would be a visual blight. Enforcement would be
very difficult. Parking restrictions in neighborhoods
would adversely effect local business districts.
166 Recommends: Federal development of a pollution free
engine, stringent new and retrofit vehicle emission re-
quirements, control of vapor and industrial emissions,
more financial support of mass transit.
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167 Mr. Werner S. Zimmt - Research Fellow, Marshall Labor-
atory, E. I. du Pont de Nemours and Company - Comments
related to~~organic solvent usage. Supports Los Angeles'
Rule 66 as proposed by EPA.
169 Called to EPA's attention subdivision (m) of the San
Diego regulation and subparagraph (m) of Section
52.253 both eliminating emission exemption for small
sources of organic materials in January 1, 1975 - feel
that it should be qualified "as was previously allowed
under subdivision (b) of this rule" from the first sen-
tence of Section 52.253, Paragraph (m), appearing on
Page 18959 of July 16th Federal Register.
Questions the removal of that exemption anyway. Feel
the contribution is very small, in fact unmeasurable
in oxidant levels. Would be economically significant
to small users. Would result in many products being
taken off the market because the 85% reduction require-
ment is too expensive. Reduction would not be required
of a heat cured coating. Recommend deletions of para-
graph (m) from both 52.252 and 52.253. If not deleted,
then limit should be no lower than the 15 lbs/day es-
tablished for heat cured coating systems.
Recommends limits only on products manufactured after
1975 due to large warehouse stocks.
The August 31, 1974 date for limiting organic emissions
to 3000 lbs/day or 85% control is unrealistic. One
year lead time would not be adequate to design, procure
and install appropriate equipment. Los Angeles allowed
three years of lead time.
172 Supports principle of high-solids coatings, however not
50% solvent evaporation before first heated zone stipu-
lation. Suggest exempting high solids coating systems
where the coating media does not contain more than 20%
organic solvent.
173 Recommend changing Section 52.253 paragraph (k) sub-
paragraph (2) defining reactive organic materials: "A
combination of aromatic hydrocarbons with eight or more
carbon atoms to the molecule except ethyl benzene."
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Recommend a definition of bake, heat cured, or
heat polymerized.
175 QA Dr. Zimmt - Reformulation can occur by the deadlines
lor" most products. This does not reflect stocks that
would exist in warehouses. Also, there is no guaran-
tee that reformulated paints would be satisfactory in
large scale industrial applications. Recommended con-
tacting the printing ink council to find out informa-
tion on reactive emissions from printing ink use,
178 Mr. George Lee, Motorcycle Rider - Motorcycles have
PCV valves in'"some models and have improved efficiency
right along. Controls are unamerican. Surcharges
discriminate along economic lines.
181 Mr. Rex B, Link, Parking Consultant - If parking is
enforced on government facilities, 50% of government
autos would be in private facilities.
183 Pointed out a conflict in convincing one group that a
facility will not overflow while another facility down
the road is being cut back 20%.
Brought up a California law establishing eminent domain
condemnation for parking and conflict with proposed
EPA plan. Los Angeles Planning Department is recom-
mending doubling available parking spaces.
185 Ruling on parking can place EPA in a veto position for
almost any urban construction. Should distinguish be-
tween visitor and all-day employee parking.
186 Biggest impact would be on the employee parking because
of established habits. There is a direct relationship
between parking and demand.
188 L.A. County provides free employee parking: 72% drive,
16% ride as passengers, 12% ride transit. Federal
employees in Los Angeles, no parking provided: 40%
drive, 28% rode as passengers and 32% use public transit.
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190 EPA could have a great effect by simply requesting that
employers not subsidize employee parking.
192 QA Mr. Link - Surcharge system misses those who receive
Free parking. Trips generated per square foot of
building is much higher in outlying area than in the
city core where some people ride transit. Many parking
facilities are not full in Los Angeles today, more
spaces would reduce fees until heavily patronized.
Calkins clarified how the city-wide 20% reduction
was to be accomplished; would be up to local decision
makers - that it was not an across-the-board reduction.
199 Jim Woulfe, Ford Motor Dealership, Albany, New Car
Dealers of Northern California - The intent of the
proposals is to remove the automobile from daily life.
Measures single out motorists for punative punishment.
Submitted a copy of National Auto Dealer's Association
position paper.
207 Mr. Edward Lawson City Planning Manager, Greater San
Francisco Chamber of Commerce - Detroit should provide
answers to vehicle pollution, the State and local air
pollution authorities have shown the way to clean air.
The chamber was instrumental in getting six bus lanes
in San Francisco. Are advocating removal of on-street
parking in downtown areas.
211 The EPA plan is disastrous to San Francisco. Economic
effects are unpredictable, but probably severe.
Wouldn't affect the employee as much as clients,
shoppers and visitors ie., those who essentially create
the jobs.
214 Question the validity of the oxidant standard, glad
it is being investigated by the National Academy of
Sciences.
213 QA Mr. Lawson - Agreed that preferential parking for
car pools would be interesting. More money is necessary
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to provide improved public transit including operational
subsidy.
221 Mrs. Holly 0'Konski League of Women Voters, Bay Area -
The EPA plan clearly emphasizes the interrelationship
between transportation and land use to air quality.
Imperative to develop rapid mass transit and equally
important feeder service. Environmental, social,
economic impacts of system must be carefully weighed.
Paramount consideration should be given to human needs.
223 Support parking restrictions. Also changes in fuel
composition and engine design combined with inspections
are supported. Support a multipurpose, elected regional
agency to implement the plan. Such an agency could be
merged with MTC.
224 Specific Federal funding should be made available for
mass transit application. Pollutions control should
a cost of doing business.
225 QA Mrs. Okonski - Need a multipurpose regional agency
- too many single purpose agencies in the region now.
Regional voters are disenfranchised.
226 Mrs. Sally Cooper, Airport Expansion Plan Task Force
for the Northern California Regional Conservation
Committeeof the Sierra Club - Discussed San Francisco
Airport expansion in terms of additional parking and
surface access requirements. Additional flight oper-
ations of planes burning more fuel would aggravate
CO and NOx pollution.
230 Propose limits on flight operations - Assign an optimum
number of operations, raise minimum load factor, inform
customers. Concept was expressed that consumer's
demand for convenience was generated through advertising
and competition. Polls indicate San Mateo residents
prefer high quality environment to air transport con-
venience .
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232 Propose considerations of high speed rail transit from
San Francisco to Los Angeles.
Propose increasing operations at Oakland Airport
(without new runway).
234 Change Federal funding priorities for socially bene-
ficial programs.
234 QA Mrs. Cooper - Economic health should not be depen-
dent on automobile parking facilities.
236 Mrs. Connie Parrish, Friends of the Earth - Fully
supports EPA's transportation control proposals. 4
out of 5 adults agree that air pollution is a serious
problem. Basic habits must be changed if air pollu-
tion is to be abated. Calculations show that a 40-mile
round trip commuter can save $100/month by using public
transportation. Entered article by Bill Dorais of
KQED on costs of commuting and San Francisco Chronicle
article on results of a Field Poll.
246 Mr. Countryman, Bay Area Air Pollution Control
District - Recommend parking restrictions not be
imposed on those associated with public transportation,
especially BART.
249 QA Mr. Countryman - Regulation is worded such that there
I¥ no superficial reason why such facilities would be
restricted by it. Mr. Countryman would like a more
specific statement.
251 Mr. Ronald Kagan - Disagrees with methodology and data
base for motorcycle emission levels used in calculations.
Feels that motorcycle retrofitting could be implemented,
especially important with the energy shortage, and that
the ban is not a good solution.
254 If NOx is determined to be a more important problem,
then something should be done about it. A surcharge
on parking will not stop wealthy commuters but will
hinder economically disadvantaged. Suggests a pro-
portional fee based on auto value to be applied to
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transit or parking for feeder routes.
255 QA. Mr. Kagen - Cornell University has worked on con-
verters for motorcycles. Large bore motorcycles
pollute more than small bore cycles due to inherent
differences in efficiency.
257 Mrs. Marian Letz - Support EPA proposals because:
1. VMT reduction is unavoidable.
2. Habit patterns must be changed - difficult.
3. Don't amend the Clean Mr Act to extend deadlines.
4. Time for amending the Act later.
5. Deadline is important tool of the act.
6. Staff of BAAPCD should be expanded.
7. Give auto and oil interests an incentive to work
on mass transit.
260 Mr. Eckerman - opening remarks
261 Mr. Tom Standing - San Francisco Bicycle Coalition -
Bxkeways could supplement mass transit. Discussed
guidelines for establishing such a system. Trip ef-
ficiency should be encouraged. Bicycle use could be
encouraged by auto parking restrictions.
2^8 Mr. David Neal, Attorney - Submitted paper (volume 2,
number 2, Golden Gate Law Review) - Thinks EPA should
be encouraging motorcycles. Benefits are too great to
ban them.
273 Mr. Bob Kerns - Blames auto industry for pollution.
Trucks and buses are also responsible.
277 Mr. Raymond 0. Heaps - Plan is too extreme. Not satis-
fied that standards are reasonable. Believes errors
are in degree, not conceptual.
283 Mr. Virgil Anderson - California State Automobile
Association- Submitted writtencomments. Standards
are unreasonable, damages citizen's mobility. Some
plan features are unworkable. Gas rationing is un-
desirable. Bus and car pool lanes are arbitrary, should
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be studied and judged independently. Tourism as an
industry would suffer. Retrofit-catalysts program is
unfair based on previous control program expense.
Loaded dynamoter testing is more expensive than is
indicated. Sales tax on gasoline will be spent on
mass transit. Congress should change EPA's mandate
under the Clean Air Act.
288 Written Submittal of Mr. Anderson
Have been impressed with ARB's success.
291 Do not support gasoline rationing - would cause more
problems than it solves. Bus/car pool lanes should
reflect traffic engineering studies. Lanes
should not be for purposes of creating congestion.
Bus lanes should be responsive to corridor needs.
292 Parking restrictions have serious implications for the
social and economic life of the community.
29 3 Catalytic retrofit will be rejected and condemned by
the public unless implementation is reasonable and
moderate. 80-90% retrofit has even greater potential
for public dissatisfaction and lack of acceptance.
Testing plan needs elements of quality control and con-
sumer protection in the manufacture of vehicles and
in their service and repair.
294 California and especially the San Francisco area lead
the nation in public transit. How can the new gas sales
tax be used to do more than maintain the status quo?
Motorcycle control is arbitrary and capricious. Amounts
to taking property without compensation.
Urge amendment to Clean Air Act.
0^. Mr* Anderson - Retrofit program is long standing in
California, however catalytic device is expensive -
though ARB had not tested it.
CSAA's loaded dynamometer testing service cost breakdown
will be available to EPA.
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303 Mr. William Green - Research Technician, University of
California - Thinks tobacco smoke may contribute to
smog situation. Is unwilling to accept auto as major
contributor without proof, but is willing to test
principle. Contests motorcycle emission data. Motor-
cycle control is probably unconstitutional, unless also
controls all two cycle engines (lawn mowers, outboard
motors, chain saws, etc.)
Smooth traffic flow is important in emission control.
Testing could be simplified, not the CSAA diagnostic
test.
309 QA Mr. Green - Has analyzed emissions himself for carbon
monoxide content, two stroke cycle can meet '70, '71, '72
CO standard.
311 Miss Susan Smith - San Francisco Tomorrow - Discussed
the San Francisco Airport expansion in its context of
tripling airline passenger trips. Feels that the
Metropolitan Transportation Commission Regional Trans-
portation Plan should assess the regional air quality
impact of the plan, Oakland Airport is better suited
to mass transit access with BART/Bus connection. Thinks
that the MTC is too closely connected to conventional
transit (highway-airport) interests.
319 Mr. Thomas Latham - Is ready to give up convenience in
favor of air quality. However, control measures should
be no more abrasive or restrictive than necessary.
Fears a broad public backlash to seven proposed control
measures (inspection and maintenance, motorcycle re-
striction, catalyst retrofit, parking restriction,
pre-66 vehicle retrofit, car pool lanes).
Inspection should be limited to vehicles whose owners
reside within the affected region. Tourists and visi-
tors would be needlessly aggravated if they were re-
quired to be inspected.
Failure criteria should be based on emissions not on
percentage failure. Should also be varied by model
year of the vehicle. EPA should activate the warranty
provisions of Section 207(b) of the Clean Air Act.
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Discussed provisions and activation of this section.
Inspection stations should compile data on charges and
failure rates of various repair stations' work.
329 Mr, Alexander Zuckerman, East Bay Bicycle Coalition -
Supports VMT reduction. Buses and BART should have,
bicycle carrying provisions. Bicycle lockers at BART
stations cost $5/month while parking is free, should
be equalized.
332 Mr. William Wigert, Sierra Club - Will submit written
statement by August 31. Hopes EPA will stand behind
its proposals.
334 Mr. Andrew Baldwin - Decline in demand for automobiles
""will result in upsurge in other parts of the economy.
The automobile shaped today's land use policy and has
destroyed the American City.
341 Mr. Tom Kelly, Mechanic - 1973 controls on cars aren't
Functioning properly. Results in stalling on hot days
and engine damage. Retrofitting the vacuum spark ad-
vance disconnect device would do consumers a disser-
vice. Should require tune-up once a year, and a manda-
tory inspection program. Feels that this will do a
better job than catalytic retrofit.
344 Mr. Norman Freitag, Modern Transit Society - Federal
coordination is needed ifauto isto be restricted -
HUD is funding thousands of parking spaces in rede-
velopment projects. FHWA should not fund traffic
increasing projects. Mass transit aid and guaranteed
"no-strike" provisions are necessary.
347 Mr, Russell - Parking restrictions should reflect
commuter/shopping mix. Parking limits are an interim
solution. Instead of requiring a licensed repair
operation, just specify a schedule of compliance (10
days to pass the test).
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350 Mr. John McCarthy - 1977 deadline is arbitrary, agrees
with California's approach to air pollution. EPA has
wasted time and money in a bureaucracy that will be
changed by Congress.
354 Mr. Jeffrey Draple, Gas Station Owner, Has installed
a third tank for non-lead gasoline, vapor-recovery
system for bulk loading and provision for retail sales
recovery. APCD did not bother to come inspect it. Gas
tax should fund vapor recovery system, too expensive
for individual operators.
Solution lies in requiring people who work in cities to
live there.
358 Mr. Lawrence Cohn, Associated With Motorcycle Industry -
EPA chose poor test motorcycles and used poor testing
procedures. Motorcycles fill a low cost transportation
need. Should explore more alternatives.
359 Mr. Eceacy - Related story on military aircraft dumping
fuel into the atmosphere.
360 Mr. Gerald L. Po^e, Port of Oakland - VMT reduction will
Have tremendous impact on the Port of Oakland, an im-
portant employer and service to the city. Airport
cannot grow without additional parking. Are evaluating
BART service to the airport. Air pollution is a prob-
lem. Economic chaos is not the answer.
367 Mr. Robert Moses, National Institute for Cooperative
and Economic Development - Supports EPA proposals.
Must consider energy, industrial development, employ-
ment, urban development, mass transit and economic
development. Plan would begin a move towards a strong
new economic base. It would be founded on concepts of
group travel and travel industry growth and opportunities
for the disadvantaged.
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372 Mr. George Williams, San Francisco City Planning
Department - Plan is unworkable. Without clean vehicles,
clean air cannot be reached by 1977 and still allow
San Francisco to function. Alternative transit is not
available. Clean Air Act needs to be revised. Have
finished a plan which gives public transit a preference.
Although the city doesn't .foresee 84% VMT reduction
they do intend to expand public transit. Will need
massive financial assistance. Gave costs of expansions
$550 million in city, $216 million - rapid transit to
Marin. Bus/car pools lanes are not compatible with the
Urban Design Plan.
378 Mrs. Lois Young, Pacifica - Questioned motorcyle emis-
sions data. Need standards for all vehicles and sta-
tionary sources.
380 Mrs. Artemas, Ginzton, California Association of
Bicycling Organization - Wants bicycling tobe placed
along with car pools, bus lanes, retrofits, etc. as an
effective VMT reducing factor. Pollutant reductions
should be estimated based on bicycle ridership. Should
estimate emission reductions possible due to, say, 100
bicycle riders replacing 100 autos over a 10 mile dis-
tance. Bicycle path planning should incorporate align-
ments parallel to existing arterials. Remind EPA that
condemnation for right-of-way was originally for bi-
cycle and horse-and-buggy paths, not just for the
automobiles.
386 Chairman Eckerman, EPA - Opening remarks
3^7 John Newell - Advocates reduced horsepower, reduced
speed limits, increased tire pressure, subsidized tran-
sit, in order to reduce pollution and conserve energy.
Purchase cars and buses with Clean Air Certificates.
EPA should encourage auto manufacturer research for
clean cars, electrics, stratified charge engines.
Assist in developing BART feeder systems. Provide in-
centives for clean cars. Discontinue subsidies to air
industry, subsidize railroads. Develop nuclear power.
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389 QA Mr. Newell - Government can lead way in purchasing
lower horsepower automobiles. In London the shift to
lower horsepower smoothed out and increased average
speed of congested traffic. Clean Air Act authorizes
Government to pay more for a "clean car,"- therefore a
clean car certificate program could be implemented,
bearer's should have Government should not subsidize
aircraft.
394 Mr. Frank Stead, California Lung Association - The
Association has supported similar measures for a long
time. The opposition to the measures use three false
assumptions - 1) plan came without warning, 2) standards
are without sufficient documentation, 3) air quality
must be balanced against other factors. We have not
balanced the public health against economics in water
pollutions where it is a public health violation. The
association feels that the public health must be given
primacy in this matter.
Standards are to be attained, not held out as an even-
tual goal.
402 Written testimony as presented to the California Air
Resources Board, by Tuberculosis and Respiratory
Disease Association ofCalifornia - Compared State
and Federal standards, implementation of control pro-
grams under each. Suggested a daily allocation of
tolerable emissions on a basin or sub-basin basis.
Permit or licensing of mobile and stationary sources
is necessary. Land use control including population
pattern and infrastructure development is necessary for
long-term success.
408 Mr. Sidney Shaw, San Francisco Department of City
Planning - (see pp. 372-378 - Mr. Williams entered the
same document)
414
Mr. Charles Starbuck, San Francisco Ecology Center -
50% of Oakland and San Francisco work forces are com-
muters. Main polluter in the Bay Area is the auto.
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AC transit feels they have attained maximum trans-bay
ridership and will not lure more people out of their
autos. Downtown transit is limited by auto congestion.
BART will only handle 5-15% of current trans-bay trips.
Chamber of Commerce has requested a study for Bay Bridge
to Golden Gate Bridge freeway despite testimony. Down-
town congestion is critical, all measures tried just
move the congestion. Cited examples from city planning
department actions that demonstrate an "auto-first"
policy.
Request that parking reductions be expanded to 30% in
downtown San Francisco as it is the key area for the
plan to work. Need an immediate moratorium on construc-
tion of new off-street public or private parking facili-
ties in the downtown area.
424 QA Mr. Starbuck - Sprawl is directly related to growth.
As long as Bay Area expands, sprawl will occur no matter
what controls are placed on parking. Not enough incen-
tive exists to get people into car pools.
429 Dr. Ruth Smith, San Mateo County Medical Society, Environ-
mental Pollution Committee - Endorse all controls. Ex-
pansion of San Francisco Airport will increase emissions
from aircraft and autos. Planning airport facilities
should be on a regional basis.
430 Mr. Dudley Perkins, Harley Davidson dealer, California
Motorcycle Industry Council, Zone 1^ - Stress willingness
to cooperate xn noise and gaseous emissions control.
The motorcycle industry should receive the same consi-
deration that the auto industry does.
434 QA Mr. Perkins - Will contact their President to present
a status report on emission control systems researched
by Harley Davidson.
437 Mr. Tom Latham - Basically supports EPA proposals.
Large potential for public backlash from inspection
with 50% failure rate. There should be two warranties:
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1) on repairs, 2) under Section 207(b) for new car com-
pliance. Implementing the loaded dynamometer test in
the statutory language necessary would implement the
warranty. Inspection stations should compile records
on the repair stations.
442 QA Mr. Latham - Failure criteria should be expressed in
grams per mile, not a frequency rate. Regulation will
needlessly affect tourists and visitors.
444 Mrs. Caralee McGowan - Pollution endangers foliage.
Should makepersonal fines for bus and cab drivers who
idle longer than 3 minutes. Limiting parking will
restrict resident's use.
451 Mrs. Ruth Williams - Afraid that retrofits will ruin
cars. Should push Detroit for a smog free car. Would
rather drive less than risk ruining her car. Buses
don't provide for shopper's packages.
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