Senate Committee on Environment and Public Works
Subcommittee on Clean Air, Wetlands, Private Property and Nuclear Safety
Comments of Mayor M. Susan Savage
Tulsa, Oklahoma
March 3, 1997

Thank you for this opportunity to address the Senate Subcommittee on Clean Air, Wetlands, Private Property and Nuclear Safety today. I am here to speak on behalf of the nation's mayors and especially as Chair of the Energy and Environment Committee for the U.S. Conference of Mayors

The primary responsibility of a mayor is to protect the public health and safety of the citizens in our communities. However, proposed new air quality standards encompass far more than just a debate about the levels of ozone and particulate matter that we will determine to be acceptable in our air. The outcome of this discussion will speak volumes about the livability of our cities well into the future.

Clean air is a laudable, responsible goal. Governments, industry and citizens have an obligation to ensure that the air we breathe is clean and safe across this country. Yet, the discussion of the proposed new air quality standards is being held in isolation from the discussion of any implementation plans for the new standard. Will communities be held to a more severe standard for the pollution which originates in and is transported from other areas? Will communities be held responsible for the hydrocarbon emissions of those automobiles driving into or through an urban area on a daily or periodic basis? How can communities mitigate the effects of unfavorable weather patterns which contribute to the ozone levels due to high temperatures or a lack of wind?

This discussion of the proposed new air quality standards is being held without consideration of the significant and substantial policy decisions this committee will face this year in its deliberations on the reauthorization of ISTEA, Brownfields, Superfund, the future of Congestion Mitigation Air Quality funds and other significant environmental policy issues which dramatically impact the liveability of cities and for which well coordinated policy goals need to be articulated and pursued.

Talk to any mayor of any sized city and what you hear is the same -- years of federally imposed mandates to meet uniformly applied environmental standards have contributed to urban sprawl, creating a greater reliance upon the automobile while at the same time, reductions in public transit operating dollars and the proposed elimination of the Congestion Mitigation Air Quality funds remove essential tools for communities who work to improve air quality.

In fact, cities like Tulsa, which has made enormous strides towards cleaner air and remained in compliance with air quality standards, are penalized by receiving fewer CMAQ dollars than other cities which have not taken proactive positions and find themselves in non-attainment.

Mayors across the country whose cities are currently in attainment and who I've worked to maintain that status, need to understand the purpose and the value of being redesignated into non-attainment. It is unclear how this causes an improvement in air quality. A health benefit analysis is the basis for the recommendation to change the standards yet the lack of inclusion of an implementation strategy, no commitment to adequate funding for impacted communities, and definitive knowledge about the precursors of ozone impede progress toward the creation of effective, local responses.

Other pressing matters need to be addressed, even if the rules for implementation evolve subsequent to the promulgation of the standard. As a group of diverse communities, we question the wisdom of putting the two standards, ozone and particulate matter in the same category. While their effects may be similar in the health based data, the available technology to monitor the two pollutants is vastly different. The country is ill-prepared to monitor for .25 particulate matter since few monitors exist. Additionally, there are no guidelines for their placement and evaluation, leaving community leaders unable to construct a workable strategy.

In the materials released from the Environmental Protection Agency there has been mention of development and implementation of Innovative technologies. Cities are interested in being part of any initiative which involves new technology. At the same time we would like to see the Agency acknowledge and credit some of the effective pollution reduction methods which use little or no technology but are based on public awareness and leadership commitment.

Have other measures to improve air quality been examined as we as a nation strive to improve air quality? Does the focus on a more difficult standard provide the impetus needed to generate the public and private support needed to provide a desirable air quality? We encourage further research to explain the origin of the precursors for ozone. The sources of background ozone, which come from biogenic sources, will seriously affect any community's mitigation strategies.

The definition of nonattainment and its implications is another issue we would like to explore farther. With the prospect of so many potential new nonattainment areas, there exists the possibility to create new locally designed programs and strategies without adding the burden of punitive economic measures. Nonattainment could be a measure at which further implementation begins; it need not be not a threat to economic development. Incentives, rather than punitive measures ought to be afforded to communities and industries which produce and burn cleaner fuels.

Tulsa is ready to use the new health advisory system described by EPA to encourage at risk individuals to stay indoors when high ozone is anticipated. Our Ozone Alert! alternate commute program is premised on the availability of information reaching 250 large companies before 4 p.m. on the day before the air quality is predicted to be poor. That information network is augmented by media announcements which begin during the afternoon commute and are carried on television in the evening. The addition of specific pollution information would be very little extra trouble and provide a most beneficial service. This service should be included in a State Implementation Plan.

In Tulsa, we created the nation's first Flexible Attainment Region or FAR in partnership with the EPA. The FAR allows an area to custom-design programs to improve air quality when there is a violation of the standard and to add more measures as they are necessary without redesignation to nonattainment. These partnerships should be encouraged to ensure local responses to air quality concerns. Local leaders are best positioned to make the decisions which world in their communities.

Mayors care deeply about the health and safety of their citizens. We believe that we can work cooperatively with state and federal officials to find the best strategies to improve air quality for all Americans.