that this is accomplished. The Office of the President, through the Bureau of the Budget, is firmly in support of a vigorous implementation of Section 7. The latter agency has directed in its instructions to all Federal departments and agencies, that in preparing budget estimates for the design and construction of new Federal facilities, they include provisions for air and water pollution controls in accordance with technical instructions issued by the Public Health Service. Such instructions have now been developed by the Public Health Service for the guidance of Federal agencies. In addition, technical instructions, in the form of guides of good practice, for the use of Federal agencies in dealing with pollution from existing facilities are now being prepared.

The administrative and operational procedures for the operation of the permit system by the Department of Health, Education, and Welfare are being developed. The first class of pollution sources to be given attention is open burning of material for disposal or salvage. After an inventory of atmospheric emissions from Federal installations is completed, it will be possible to adequately classify the potential sources of other pollution from Federal installations.

If one were to assess the potential for success, from a strictly classical and theoretical management viewpoint, of the Department of Health, Education, and Welfare effectively operating a control program where sister departments are the objects of control, and where no administrative, bureaucratic, or hierarchial advantage exists for the Department of Health, Education, and Welfare, one might indeed be somewhat pessimistic. Classical theory notwithstanding, our experience to date gives us every reason for optimism on the future success of this program. Initial responses from the many Federal agencies which operate installations have indicated a clear recognition of their responsibilities and a desire to cooperate with the Department of Health, Education, and Welfare in carrying out Section 7 of the Clean Air Act. The Division of Air Pollution, of the Public Health Service, has established a Federal Agencies Section in its Abatement Branch, which is now implementing this program on a full-time basis. This type of program administration, involving practically daily contacts with the Federal agencies, is in contrast to the research contract type of relationship, where a Public Health Service technical monitor periodically reviews the work of the contractor agency, and consults on an intermittent basis.

There is continuing interest by the Congress in the problem of effective programs to insure exemplary air pollution control practices by Federal agencies. At this writing, the Senate has passed S. 560, which calls for the Secretary of Health, Education, and Welfare to establish automotive emission standards for Governmentally purchased vehicles. The Act would also provide for greater authority for the Secretary through a program of certification as to acceptability of proposed air pollution control measures in Federal installations.

URBAN MASS TRANSPORTATION ACT

Another area where the Department of Health, Education, and Welfare has entered into new relationships with another Federal agency, concerned with air pollution prevention and control, is in the field of urban mass transit. Section 11 of the Urban Mass Transportation Act (P.L. 88-365), enacted by Congress in 1964, directs the Administrator of the Housing and Home Finance Agency, in reviewing applications for Federal financial assistance, to take into consideration whether equipment and facilities financed under the Act will be designed and equipped to prevent and control air pollution in accordance with criteria established by the Secretary of the Department of Health, Education, and Welfare. The legislative history of this Act reveals the intent of the Congress, in encouraging needed solutions to the difficult problems of city traffic congestion, to avoid an aggravation of air pollution problems associated with the several forms of mass transit-such as bus operation and power stations for rail systems.

Technical criteria have been developed and transmitted to the Administrator of the Housing and Home Finance Agency for his use in reviewing applications for Federal financial assistance for transit equipment and facilities.

Technical representatives of the Division of Air Pollution and the Housing and Home Finance Agency plan to meet periodically to review the program under Section 11 of the Mass Transportation Act. Amendment to the air pollution criteria will be made as experience indicates a need therefor. The Division of Air Pollution anticipates being called upon periodically for specialized technical consultation in connection with special problems or questions of interpretation, which are likely to arise in the course of the administration of the mass transpor

tation program by the Housing and Home Finance Agency. The Division of Air Pollution views this new program as a promising means for preventing new air pollution problems from developing as an unwanted side effect of a broad scaled, national program to promote urban mass transportation.

OTHER INTER-AGENCY RELATIONSHIPS

Principal attention in this paper has been given to the newly established Federal agency relationships outlined above because these relationships have their basis directly in recently enacted Federal legislation. Several other patterns of relationships, which have a control rather than a research emphasis, are also emerging, even though no specific legislation has conditioned or occasioned them. Thus, in the field of air pollution, mutual interests of the Public Health Service and the Housing and Home Finance Agency are based upon the character of air pollution as both a cause of urban blight and deterioration, and an effect of the various facets of urban development. This mutuality of interests has been the basis for discussions directed toward the development of cooperative efforts between the two agencies which seek (1) to develop in State and local community leaders and planning agencies a recognition of this interrelationship, (2) to encourage communities to incorporate explicitly in their community, planning and survey activities and in their community development program operations, appropriate elements reflecting this interrelationship, and (3) to develop such policies and procedures within the two Federal agencies, particularly with respect to financial aids and technical assistance, as will foster the accomplishment of these objectives.

The purpose of the Urban Planning Assistance ("701") Grants administered by the Housing and Home Finance Agency is to provide assistance for comprehensive planning for entire urban areas. Studies of air pollution are considered important, both by the Housing and Home Finance Agency and the Public Health Service, as factors in sound comprehensive urban planning; based upon this recognition, the two agencies have worked closely concerning a study of air pollution in the Chicago metropolitan area conducted jointly by the Regional Planning Agency and the State and local air pollution agencies and financed in part by a "701" grant.

The Public Health Service has had discussions with the Housing and Home Finance Agency on a series of other areas although no formal operating programs involving the Service have as yet ensued. Some of the areas of joint concern include the possible incorporation of air pollution as an element of the Workable Program for Community Improvement required as a prerequisite to various forms of HHFA financial assistance, urban transportation planning, open space planning, general zoning developments, problems concerning the disposal of demolition debris from urban renewal projects, solid waste removal problems, and community facilities financial assistance as they relate to incineration. It is probable, that as these programs develop, the air pollution component will tend to be more formally and regularly incorporated into these programs. The Public Health Service will be continuing to work with the Housing and Home Finance Agency toward this end.

An interesting and potentially productive relationship has developed in recent years between the Federal Power Commission and the Public Health Service with respect to air pollution. The Public Health Service has been requested by the Federal Power Commission to provide technical information and testimony in connection with applications before the Commission concerned with the transmission of natural gas. The air pollution issue has arisen with respect to the pollution emitting characteristics of various fuels, the location of power generating plants, and the health and other effects of various pollutants. The Chief of the Division of Air Pollution, Mr. Vernon G. MacKenzie, has served on an air pollution advisory group which provided information for the Federal Power Commission National Power Survey issued in 1964. These relationships in general indicate the recognition of the air pollution problem as a factor to be given consideration in the types of determinations the Federal Power Commission has the responsibility to make.

In its January 1965 Economic Report to the President, the Council of Economic Advisors gave explicit attention, for the first time, to air pollution. The Report pointed out the lack of economic incentives for polluters to correct their pollution problems. The Department of Health, Education, and Welfare has a representative on a working group established by the Council to explore

possible avenues for presenting financial incentives for polluters to take prevention and control measures. The Division of Air Pollution has been providing technical background on air pollution to assist in consideration and formulation of Federal policy in this area.

IMPLICATIONS FOR STATE, LOCAL, AND REGIONAL AIR POLLUTION CONTROL PROGRAMS

The various kinds of interrelationships between air pollution and other facets of public and private activities, which are the basis for the interagency relationships at the Federal level discussed above, are, of course, relevant to State and local programs for the prevention and control of air pollution. In the United States the primary responsibility for the control of air pollution at its source rests with State and local governments; consequently, the need for and the opportunity to develop a high degree of coordination and cooperation among all agencies of local government is particularly great. The keynote to this approach to air pollution control was well stated by S. Smith Griswold, Air Pollution Control Officer of the Los Angeles County Air Pollution Control District, as follows:1

"Across the country thousands of municipal, county and State officials are vitally concerned with the development and redevelopment of our Nation's urban and metropolitan communities. We're demolishing old structures, redesigning our transportation systems, and executing a wholesale physical reconstruction of our community core areas. While we're doing this, we should also be concerned with the quality of air our citizens are breathing. We should place the protection and preservation of acceptable air quality on a par with the physical reconstruction of our communities, and we should give increased attention to the many facets of community design that must affect our future community air quality configuration."

The possible ways in which this concept might be implemented are discussed below:

(1) An obvious parallel at the State and local levels to the Federal program for control of air pollution from Federal installations, discussed above, is the importance of making sure that the State, county, and city conduct their activities with the least possible contribution to local air pollution problems. Steps need to be taken to insure that the very best available technology for controlling air pollution is incorporated in the plans and specifications for the construction of public facilities such as schools, hospitals, public housing, public works operations, incinerators and similar types of projects. There are many ways that this can be administratively accomplished but the essential ingredient is that an explicit element of the planning for such facilities be consideration of their air pollution potential. This can be accomplished by requiring all such plans to be reviewed by the air pollution agency or requiring adherence to technical criteria established by the air pollution control agency. The effective implementation of any such system will obviously require the strong support and commitment of top officials and legislative bodies to the need for air pollution control.

(2) Many of the crucial decisions concerning whether or not we are presently creating air pollution problems for the future are made prior to the actual time that a particular construction program is implemented. These decisions are made in connection with community planning with regard to land uses and the subsequent zoning decisions to administratively implement such plans. The kinds of uses to which land will be put and the criteria or standards used for determining the specific characteristics of activities permitted to be conducted can be crucial in determining the air quality of our communities in the future. As such, there is a clear need for the consideration of the air pollution potential involved in such decisions. In the light of these considerations, the air pollution agency should be recognized as an important technical advisor to planning and zoning agencies. There are, of course, in addition to the air pollution factor, a number of other important considerations and issues which will affect the final decisions which are made. It is important, however, that air pollution considerations be explicitly available to the decision-maker; the lack of information available to the decision-maker should not be the basis for creation of new air pollution problems by default.

1 "Response: The Reasonable Approach to Air Pollution Control," National Conference on Air Pollution (1962), Proceedings (Washington: U.S. Government Printing Office, 1963), p. 14.

(3) Considerable room for cooperation and coordination, particularly at the municipal level, exists with regard to the regulatory programs concerning the health and safety aspects of housing and other types of construction. Such agencies as health departments, building departments, fire departments as well as air pollution agencies are frequently concerned with the inspection, surveillance, and enforcement of various local ordinances, rules, and regulations in this field. The difficult problems involved in attempting to coordinate these activities so as to avoid inefficiencies, overlaps, duplications and conflicting requirements upon those subject to such regulation have long been a matter of discussion and controversy. It is, however, an area of great importance to the overall quality of local government and should be of intense interest to air pollution agencies as a possible means of strengthening their programs while conserving scarce resources, funds and personnel.

(4) Greater coordination between air pollution agencies and agencies concerned with the construction of highways, urban renewal projects and other operations of this nature is desirable with respect to the problem of preventing air pollution associated with the disposal of demolition debris. Although improved technology is vitally needed with respect to this problem, greater attention to the utilization of presently available methods and practices can do much to improve existing situations. Further, concerted attention by all agencies and groups concerned is likely to stimulate needed research and development activities concerning this problem.

(5) A particular aspect of the general problem of governmentally controlled or aided construction and facilities relates to urban renewal projects and public housing. With respect to public housing, careful attention needs to be given to the incorporation in such projects of appropriate design criteria with respect to heating and incineration equipment. Further, attention needs to be given to the employment and training of personnel responsible for the maintenance and operation of such equipment. With regard to urban renewal projects, inter-agency coordination in developing criteria and standards with respect to demolition debris disposal, heating, incineration, and other potential sources of air pollution, to which the private developer would agree to conform, would be highly desirable. This, of course, is a special application of a more general problem of carrying out the responsibilities of air pollution control agencies with respect to apartment houses, commercial buildings and other sources under private as well as public control.

SUMMARY

Under the first Federal Air Pollution Act of 1955, which assigned the responsibility for developing a national program to the Public Health Service, a significant phase of the program involved other Federal agencies through a series of contractual relationships. These interdepartmental relationships were limited, however, to the objective of capitalizing on the diverse research facilities and specialized competencies within the Federal establishment, as a means of accelerating the research and technical assistance program authorized under the Act.

With the passage of the Clean Air Act of 1963, a major new emphasis has been added to the Federal air pollution control program. Application of technical knowledge, through broadly accelerated control programs, is the predominant theme of this Act. This emphasis is reflected in current trends in the nature and type of the Public Health Service's developing relationships with other Federal agencies. The emerging PHS programs to prevent and control air pollution from Federal facilities, the PHS role in preventing pollution arising from transportation systems aided under the new Urban Mass Transportation Act, and other developing interagency relationships and problem areas are examples of this recent trend. There are important parallels and implications of these new Federal relationships for State, local, and regional air pollution control programs.

Coordination of Federal efforts in the closely related fields of air pollution control and solid waste management is facilitated by the fact that both Federal programs are located within the same Bureau of the Public Health Service. Furthermore, close liaison is maintained between the staffs of the Office of Solid Wastes and the Division of Air Pollution to assure complete and productive coordination of the research and development activities of the two programs in areas where their interests and responsibilities merge.

The Department of the Interior is assigned certain responsibilities under the Solid Waste Disposal Act of 1965. A memorandum of understanding entered into by the Departments of Health, Education, and Welfare and the Interior, a copy of which is printed below, outlines the mechanism of coordination whereby the two Departments coordinate their respective efforts under the Solid Waste Disposal Act. Coordination with the water pollution program of the Department of the Interior is managed through the Office of the Secretary of Health, Education, and Welfare. The recent transfer of the Federal Water Pollution Control Administration from the Department of Health, Education, and Welfare to the Department of the Interior has caused some disruption of communication between this Office and the FWPCA. It will be necessary to redefine effective avenues through which coordination in the area of solid waste research and development can be achieved.

Because the Department of Housing and Urban Development has certain programs and responsibilities relating to urban planning, which can involve solid waste management planning, close contact is maintained between the Office of Solid Wastes and appropriate agencies and officials of the Department of Housing and Urban Development to assure that the efforts of these two agencies complement, rather than conflict with, one another.

Enclosed for the information of the Subcommittee is a copy of a cooperative project agreement involving the Office of Solid Wastes, the Tennessee Valley Authority, and Johnson City, Tenn. (see p. 709). This agreement illustrates the type of cooperative coordinated effort which will increasingly call on the resources of two or more Federal agencies involved in programs directly or tangentially relating to the management of solid wastes and research and development in this field.

Attachments.

MEMORANDUM OF UNDERSTANDING; DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE, PUBLIC HEALTH SERVICE; AND THE DEPARTMENT OF THE INTERIOR, BUREAU OF MINES

IMPLEMENTATION OF TITLE II, THE SOLID WASTE DISPOSAL ACT OF 1965, PUBLIC LAW 89-272

The Department of Health, Education, and Welfare, Public Health Service, and the Department of the Interior, Bureau of Mines, each has an area of responsibility for implementing the provisions of Public Law 89-272, the Solid Waste Disposal Act, and are mutually desirous of developing a coordinated program toward the attainment of common objectives under the Act. The report of the House Committee on Interstate and Foreign Commerce (Report No. 899, Page 27, lines 19 through 36), states that, under the provisions of the bill, subsequently enacted as Public Law 89-272, the Department of Health, Education, and Welfare "would be responsible for administration of the Act, except that the Secretary of the Interior will be responsible for 'solid waste resulting from the extraction, processing or utilization of minerals and fossile fuels where the generation, production, or reuse of such wastes is or may be controlled within the extraction, processing or utilization facility or facilities and where such control is a feature of the technology or economy of the operation of such facility or facilities'. This arrangement would make the Secretary of Health, Education, and Welfare responsible for administration of the Act with respect to solid waste problems of communities, including those problems which may affect the general environments of communities, and including those solid wastes or solid waste residues that result from business and industrial activities and become part of the community's solid waste disposal system. The Department of the Interior,