If you take the lead out the octane drops and you put the aromatics back into build up. I think I can answer this. In a recent trade publication or trade statement to distributors of American Oil Co., the president of Amoco was asked why it is necessary to charge more for unleaded regular than leaded regular.

He pointed out that in order to attain the octane for today's cars, he had to add the expensive components which are the aromatics from his pool, and this adds to the cost.

I think I am far from alone in the feeling that there is an excellent chance, certainly in the near future, that aromatics would have to be added to keep today's cars running and this would add to the smog problem according to information developed by the Bureau of Mines at Bartlesville, the report to which I have referred and which has been made a part of the record.

The CHAIRMAN. Are there any further questions? If not, we thank you Mr. Kimberley. Our next witness is Dr. Edwin A. Gee. If you will identify yourself for our committee, we will be glad to recognize you, sir.

STATEMENT OF DR. EDWIN A. GEE, JR., VICE PRESIDENT, E. I. du PONT de NEMOURS & CO., CHAIRMAN, ENVIRONMENTAL QUALITY COMMITTEE; ACCOMPANIED BY DR. DONALD DIGGS, CHAIRMAN, EMISSION TASK FORCE, ENVIRONMENTAL QUALITY COMMITTEE; AND CHARLES E. WELCH, MEMBER, ENVIRONMENTAL QUALITY COMMITTEE

Dr. GEE. Mr. Chairman and members of the committee, my name is Edwin A. Gee. I am vice president and director of E. I. du Pont de Nemours & Co. and I serve as chairman of Du Pont's environmental quality committee. Accompanying me is Charles E. Welch, also a member of that committee.

The CHAIRMAN. We welcome you to the committee, Dr. Gee and Mr. Welch, and you are recognized.

STATEMENT OF INTEREST AND POSITION

Dr. GEE. The opportunity to appear and present the Du Pont Co.'s views on this bill, which you are considering, is appreciated very much. My comments will be restricted to the portion of the bill which proposes that a tax be imposed on lead additives used in gasoline and, as a major producer of such additives, we are concerned with this proposal.

In presenting the proposal to tax lead additives, the proponents indicated that one of the purposes was to advance the elimination of air pollution. If our experience convinced us that this was a fact, we would be here in support of this proposal rather than opposing it. In addition to our conviction that such legislation will not improve the environment, we are also of the opinion that punitive taxation is not the best approach from the view of the overall public interest.

Third, the proposal appears to have minimized the complex technical problems that those involved in the effort to abate automobile pollution must face and overcome.

As a reverse measure, the proposal is designed to secure an estimated $1.1 billion during the first year, with decreasing receipts thereafter as fuel manufacturers convert to the production of low leaded and unleaded fuels. Thus, the measure is a self-defeating source of revenue as well as being inequitable in application among fuel manufacturers and oppressive with respect to lead additive manufacturers, their suppliers, and the motoring public.

The effects of the proposed tax provide a good illustration of the pitfalls of trying to accomplish control of automotive emisions through the use of taxation, rather than the use of more appropriate measures based upon an analysis of the technical implications of the problem. 'The disorderly reduction in the use of lead in gasoline, which would result from enactment of the proposed tax, would not be an effective means of environmental control and, indeed, might well make air pollution worse, rather than better, at least in the short term. This arises for a number of reasons.

NECESSITY FOR REDUCING LEAD IS QUESTIONABLE

First, the lead tax prejudges the necessity of rapidly removing lead from gasoline and bypasses the considerable scientific investigations now being conducted by both industry and government to ascertain the facts in this complex and controversial matter. The research which the DuPont Co. has been conducting for many years in this area leads us to conclude that there is no currently indicated need to reduce the use of lead in gasoline, either to assure the development of advanced emission control devices or to remove an existing threat to the public health. If it should be found necessary to reduce the amount of lead exhausted from automobiles, particulate traps are available to remove 90 percent to 95 percent of the lead particles from the tailpipe.

THE LEAD TAX IS AN INFLEXIBLE, INDISCRIMINATE AND POSSIBLY HARMFUL TOOL

Second, and of fundamental importance, the inflexible and arbitrarily applied tax approach provides no opportunity for evaluation of possible adverse effects of the precipitous removal of lead. It is well recognized that changes in gasoline composition will be necessary as lead is removed. These changes involve the inclusion of significantly more aromatic hydrocarbons and these materials have been shown to increase the emission of suspected cancer-producing materials.1

In the exhaust gas and to increase the potential of the exhaust gas to form photochemical smog. Information on the increased photochemical reactivity of gasolines containing increased amounts of aromatics has been published by the Bureau of Mines 2 and by General Motors,3 as well as by other organizations.

1 Begeman, C. R., and Colucci, J. M., "Polynuclear Aromatic Hydrocarbon Emissions From Automotive Engines," Society of Automotive Engines," Society of Automotive Engineers Paper No. 700469, presented May 1970, McKee, H. C., and McMahon, W. A., "Polynuclear Aromatic Content of Vehicle Emissions," American Petroleum Institute technical report No. 1, project No. 212139, Aug. 28, 1967.

2 Eccleston, B. H., and Hurn, R. W., "Comparative Emissions From Some Leaded and Prototype Lead-Free Automobile Fuels." U.S. Department of Interior, Bureau of Mines, report of investigations RI 7390, May 1970.

Heuss, J. M., and Glasson, W. A., "Hydrocarbon Reactivity and Eye Irritation," American Chemical Society, San Francisco, Apr. 2, 1968.

We believe that provisions must be made to assure that fuel compositions selected as substitutes for leaded gasoline will not create higher smog levels, present new health questions, or place unnecessary economic burdens on the driving public. It would be unfortunate to force the removal of lead from gasoline by a tax measure which makes no provision for continuing consideration of these factors.

INFLATIONARY EFFECT OF PROPOSED TAX

Third, the proposed lead tax will force a rapid expansion of refinery capabilities and will increase consumption of aromatic hydrocarbons. Refiners have different abilities to manufacture gasoline without lead and, thus, the tax will fall inequitable upon them. The necessity to equalize their position, with respect to their competitors, through added refinery facilities will force a disruptive and inflationary situation upon both the petrochemical construction industry and the production of chemicals which rely on aromatics as raw materials.

The usefulness and, thus, the economic value of aromatics as blending components in gasoline will increase significantly if this lead tax is approved by Congress. These aromatics are widely used as basic raw materials in the chemical and petrochemical industry and their increased value in gasoline will force their price upward in other applications.

The current economic climate indicates that this is a particularly inappropriate time to introduce these inflationary forces into two basic industries without careful evaluation of both the necessity and the timing of such action.

In a similar vein, the increases in prices of leaded gasoline to the consumer with older cars comes at a time when additional economic burdens cannot be absorbed without substantial strain. Major reconstruction of retail marketing outlets might also be required, and this would represent an additional cost to the consumer that should be avoided.

OTHER APPROACHES TO AUTO POLLUTION CONTROL

While we do not agree that the proposed tax is an effective means of dealing with the problem, there is no question that emissions from automobiles must be reduced further. But in our view, this problem is being aggressively attacked by government and the industries involved. Today's vehicles emit 80 percent less unburned hydrocarbons and 70 percent less carbon monoxide than vehicles without emission control. But still greater improvements must be achieved. The Federal Government, acting through the Secretary of Health, Education, and Welfare, is moving progressively through a series of programs under existing law to reduce this source of pollution, and new legislation is being considered by the Congress which could accelerate this process.* The soundest approach to the control of vehicle emissions is through the establishment of tailpipe emission standards, an approach which the Du Pont Co, supports.

The automobile industry is currently designing engines and emission control devices to meet the increasingly stringent tailpipe stand

H.R. 17255, 91st Cong., second sess., passed the House of Representatives June 10, 1970. Unnumbered Senate proposal approved by Senate Public Works Committee on Sept. 11, 1970. Report not printed.

ards. Where the automobile industry had indicated that changes in present fuel composition may be required to permit satisfactory operation of some kinds of devices under consideration, the petroleum industry has already moved to meet this need.

I do not believe that the development of future emission control devices is impeded by the use of leaded gasoline in automobiles. For the past 7 years, the Du Pont Co. has been engaged in a research program directed toward the development of highly efficient emission control devices which would operate effectively with leaded gasoline. We have developed such a device called an exhaust manifold thermal reactor. Testing of cars equipped with an advanced system employing this device using the current Federal test cycle for certification has demonstrated that the 1975 standards can be met and the 1980 goals closely approached.

Test results obtained by Du Pont have been verified by the laboratories of the National Air Pollution Control Administration 5 and the California Air Resources Board."

The test results obtained by the California Air Resources Control Board looked so promising that the group is starting a 2 year test of six 1970 model cars equipped with the system. These cars, prepared by Du Pont, will be turned over to the Air Resources Board next week.

The assumption appears to have been made in many quarters and is reiterated by the proponents of this bill that the only system which will satisfactorily meet future vehicle emission standards is one employing catalysts, and that catalysts are rendered inoperative by the presence of lead in gasoline. To the best of our knowledge, no such catalytic system is available today, and no developmental model of such a system has been shown to give results as good as those obtained with the thermal reactor system.

Indeed, the National Air Pollution Control Administration has evaluated the potential of 11 different emission control systems and concluded that the catalytic system operating on unleaded gasoline has a zero probability of being able to control hydrocarbons and carbon monoxide to the level required by 1980.7

In contrast, the same report states that the thermal rector system has an 80-90 percent probability of meeting the 1980 emission goal. This is the system which DuPont has brought to an advanced state of development and which operates effectively with leaded fuels. DuPont has placed the technology behind its development of the thermal reactor in the public domain. The domestic automobile industry is working actively to develop commercial versions of such a system and two foreign automobiles are being sold in this country which are already equipped with production versions of this device.

While the thermal reactor system provides excellent control of carbon monoxide, hydrocarbon, and nitrogen oxide emissions it does not change the amount of lead particulate emitted by a vehicle. This can be accomplished by an inertial separation system using cyclone collectors and installed in place of the conventional exhaust system.

National Air Pollution Control Association Tests, Ypsilanti, Michigan, July 1, 1970. Letter dated Mar. 26, 1970, from A. J. Hocker, Air Resources Laboratory, Air Resources Board. State of California, to Daniel Pastell, E. I. du Pont de Nemours & Co. Letter dated July 10, 1970, from A. J. Hocker, Air Resources Laboratory. Air Resources Board, State of California, to Daniel Pastell. E. I. du Pont de Nemours & Co.

7 "Control Techniques for Carbon Monoxide, Nitrogen Oxide, and Hydrocarbon Emissions From Mobile Sources," National Air Pollution Control Administration Publication AP-66.

Tests of up to 67,000 miles show that the emission of lead particulate can be reduced by at least 90 percent. The system requires no maintenance or periodic cleaning and does not affect vehicle performance. It seems probable that particulate traps will be required on all cars designed to meet the 1975 particulate emission standard whether fuels are leaded or unleaded.

CONCLUSION

In conclusion, we believe that the Congress should reject the proposed lead tax. The concept of punitive taxation to solve the problem of automotive pollution is not sound. The proposed lead tax would force a disorderly and inflationary action upon the petroleum industry in a matter where the approach which best serves the public interest is not yet apparent. The precipitous removal of lead from gasoline, and the attendant changes in gasoline composition necessary to provide for the continued satisfactory operation of 85 million cars now on the road, might make air pollution worse but not better.

DuPont believes that the automobile emission problem can be solved, and indeed will be solved, through the application of systems now under development which are compatible with the continued use of lead in gasoline.

We recognize, however, that there are differences of opinion in this area, and there are those who believe that unleaded gasoline will be required. If this is the case, we submit that the petroleum industry will move in the marketplace to provide the fuels which are necessary. Indeed, this is already occurring although there are not now, nor will there be for several years, vehicles produced by the automobile industry which will require gasolines with reduced lead content.

We believe that the solution of the automobile emission problem will be most rapidly and efficiently effected if the Federal Government sets tailpipe emission standards and requires these standards be met by adequate legal sanction. We do not feel the Government should limit the means of meeting these standards, or require the needless expenditure of money, to achieve a solution, as would result from the proposed tax. It is our position that alternative less costly methods would serve as well to achieve a solution.

Mr. ULLMAN. Dr. Gee, are you the people who developed the thermal reactor that had been tested in California?

Dr. GEE. Yes, sir.

Mr. ULLMAN. Has California accepted it?

Dr. GEE. It is my understanding that they have confirmed our observations that it will meet the 1975 emission standards and that it has a reasonable possibility of meeting the 1980 standards.

The confirming work is now underway with the automobiles which are being sent to California, some six in numbers.

Mr. ULLMAN. Will it be a 2-year test with these automobiles?
Dr. GEE. Yes, sir.

Mr. ULLMAN. And they will presumably be using leaded gasoline?
Dr. GEE. Presumably, yes, sir.

Mr. ULLMAN. What is the principle of the thermal reactor?