quality, reasonably the same type of degree of recognition of those indentical sources would have to take place in the entire area. Whether those were enforced in the District by the District of Columbia in the various portions of Virginia and Maryland by the local government agencies provided they carry on this acceptably would be a matter for determination.

For instance, your county, Montgomery County, having the-an agency to carry out enforcement in that area provided they enforce it to the same degree that enforcement was carried on in Virginia of the same regulation. I think it is completely unreansonable for Washington, D.C., the District of Columbia, to have one set of regulations, very stringent regulations, and then have the part of the metropolitan district in Maryland and Virginia to have some other regulations.

Mr. MACKENZIE. I wonder if I might supplement Mr. Griswold's comments on your question.

I think the thrust of our testimony has been toward the desirability of having the regulatory authority or the enforcement of the rules resident in a single agency within the District of Columbia rather than scattered in separate agencies as is the present case.

Now, specifically with regard to the rule-making authority, in most local government jurisdictions with which I am familiar, the rulemaking is retained by either the elected body or in the case of the District of Columbia, this would be presumably the new Commissioner and the Council; whereas the ordinary day-to-day business of enforcing the rules which are adopted is carried out through a single agency designated for this purpose.

Mr. GUDE. We are agreed. I think the Council of Governments approach is to get uniform standards over the metropolitan area. What I was trying to say in my proposal is, that we set the standards. I think we showed the intent of Congress here and I think the Council of the District of Columbia would be the policy-making body eventually as far as standards go.

But there have been proposals that a separate agency be set up. Some people have said let's vest this authority to control air pollution in a body and at that time it was independent of the District Commis

sioners.

In other words, the Commissioners would appoint them but they would draw up the rules and regulations.

Now what I am asking is your preference, would you rather see the Council of the District of Columbia draw up the levels, or a body appointed by the Commissioner of the District, which would not have any relationship with the Council?

Mr. MACKENZIE. Actually we have seen this operating in both of the manners which you have described. And I think that so far as the effectiveness of the air pollution control activity is concerned that this can be accomplished in either way.

From a personal standpoint I believe, however, that the ultimate authority ought to rest in the elected officials and in this case in the absence of elected officials in the District of Columbia I think this would correspond to the proposed Commissioner and Council.

Mr. GUDE. If the Council is drawing up other rules and regulations to govern the District of Columbia that involve building codes, building regulations, and matters of this kind, would it not be better if they

also draw up the air-pollution regulations which in many cases are very closely tied to these other considerations?

Mr. MACKENZIE. I think the ultimate responsibility should rest where you are indicating, Mr. Gude.

In many of these complex technical fields elected officials or those responsible for adopting local rules and ordinances may find it necessary to use the services of advisory committees of the technical aspects of the decisions which they may have to make.

These details, in my view, should be left to the official having the responsibility.

Mr. GUDE. I don't know which one of you wants to answer this. What is your opinion of the Council of Governments approach to the airpollution problem, the model ordinance and their working in the airpollution control in the metropolitan area.

Mr. GRISWOLD. So far in connection with the metropolitan problem air pollution and abatement agency we have met with representatives of the State of Maryland designated by the Governor, the State of Virginia, their duly created Air Pollution Commission, their Executive Secretary, and with the officials of the District of Columbia and with representatives of the Council of Governments.

Now in connection with the accumulation of data to come up with a program to resolve the problem here we have worked very closely with the Council of Governments and the District. In other words, the technicians of all agencies have contributed to this. This Council of Governments so far has unless this has changed, I feel that it must be eventually if there is to use the Council as a regional agency unless right now it doesn't have any enforcement powers. In other words, it can recommend and work out a program to be adopted by the elected officials in the various counties and in the District. However, eventually rules and regulations pertaining to the entire area are going to have to be enforced and at the present time it looks like there would have to be created an agency with this enforcement power, unless the units of local government undertook to do it.

Mr. GUDE. Do you prefer control by local jurisdictions as opposed to control by a regional body?

Mr. GRISWOLD. No, I would prefer the enforcement by a metropolitan body.

However, there would have to be undertaken through the agency the mechanism of an interstate compact establishing this. I think that as in the case of New York there are certain areas in New York that would very much like the City of New York to undertake the enforcement of rules and regulations within the city and possibly in New Jersey, for instance, here the State of New Jersey would undertake it because the individual cities in that metropolitan area would not want to have it or be qualified to undertake it. I think these sorts of things can be worked out in connection with the organization.

Mr. GUDE. Well, you feel there should be enforcement by a regional agency. You say you prefer this.

But would the air be any cleaner if it were enforced on a regional basis or even enforced on a local basis?

Mr. GRISWOLD. I think you would reasonably have more equitable enforcement of the entire area.

However, this does not mean that for instance the District of Columbia, if it had such an agency to carry on enforcement, could not accomplish this effectively within the area in a manner acceptable by the metropolitan commission.

Mr. MACKENZIE. I wonder if I could comment further on this also. I don't think we have the final answers to the problems of providing services generally in the metropolitan areas. This is a subject of government administration that many people have been struggling with now for a long, long time. In general, in the air-pollution control area we see a necessity for a uniform approach on a regional basis in many metropolitan areas, and I think this includes the Washington, D.C., metropolitan area. The degree to which substitutions should be made of the authorities conducted by local government units by a strictly metropolitan area organization, I think may well vary from one locality to another.

Mr. Griswold mentioned the New York metropolitan area and there the problem is extremely complex because of the very, very large number of local government agencies whose actions would need to be coordinated if one were to have a uniform approach in the entire area.

In the Washington, D.C., area, on the other hand, you have a much smaller number of local government agencies whose actions would need to be coordinated for a uniform approach in the entire area. It may well be because of this lesser complexity here, due to the smaller number of local government units, that it could prove feasible to accomplish the desired objectives by a voluntary coordination of activity. I would not like personally to rule out this possibility and if it can be done this way in my view it would be preferable and would eliminate further multiplication of government agencies which I think is undesirable unless a strict need can be demonstrated.

Mr. GUDE. Thank you very much. I certainly associate myself with your last remarks. We have quite a few governmental agencies in the metropolitan area now and to see a new one arise would create more problems while trying to solve some old ones. I appreciate your support of a voluntary approach. On these standards which are set forth in the COG model ordinance, do you think these are an improvement over what we have in the District of Columbia now?

Mr. GRISWOLD. I don't think there is any question that they are an improvement over what we have, Congressman.

Mr. GUDE. We could have better air if we could adopt this legislation?

Mr. GRISWOLD. That is certainly true. The representatives of the Council at our consultation asked for comments as to whether they should proceed to try and place these recommendations in effect in the various participants in the Council of Governments, and we felt that this would certainly be in the best interests of the program in the entire area and as a result of these studies we are now undertaking more stringent standards or requirements

Mr. GUDE. What concerns me is that I know you feel that looking with the judgment of scientists these standards may not be perfect. We could certainly perfect these standards and get them down to another decimal point. At the same time, individuals who don't like these regulations and institutions for other motives can say they ought

to be refined, too, perhaps by this, unwittingly, you are combining with them and delaying the day when we really get down to the job. Mr. GRISWOLD. Not intentionally, Congressman.

Mr. MULTER. I might call the Committee's attention to the fact that S. 780 passed the Senate on July 18 and the House Interstate Foreign Commerce Committee will start its hearings on that bill probably tomorrow and conclude them within the next two weeks; and it may be necessary for us to integrate our bill with theirs because their bill covers interstate commerce throughout the country and it specifically includes the District of Columbia. I think in that bill they do set forth specific criteria. It may be we can merely adopt that criteria by reference or on the other hand add to this bill sufficient directives to the local government to implement those provisions by regulation. Thank you very much, gentlemen.

Mr. WINN. I am sorry, Mr. Griswold, but I had to leave the room a minute. But I would like a little more clarification so that I can get a better understanding. I have seen these test stations around the District and in Virginia. I don't believe I have seen any in Maryland. I suppose there are some. Are those run by the National Center for Air Pollution Control? Who puts those up?

Mr. GRISWOLD. Those were installed here last January, last December, to measure the air quality at strategic locations in the metropolitan area in connection with the abatement action which the Secretary initiated last October.

Mr. WINN. How many do you have in the general area?

Mr. GRISWOLD. We have, as I understand it, five stations in addition to the camp station, the permanent station which we have here.

These are what you call temporary or mobile air monitoring stations and we move them from place to place.

Prior to this time they were in New York when we were working on that abatement agency.

Mr. WINN. What type of air pollution are you looking for in that type of station?

Mr. GRISWOLD. That type of station would measure five different contaminants. We are getting sulfur dioxide and carbon monoxide and oxygen. They are operated 24 hours a day seven days a week and we utilize this in connection with meteorology, our meteorological data to determine the air quality in the Washington area during different times of the year.

Mr. WINN. Now back to the Kenilworth dump, which is pretty well known as one of the trouble spots. Do you have a station close to that where you can pick up the pollution from the dump?

Mr. GRISWOLD. During certain conditions when the wind is blowing in that direction it will show that. We don't have one established just for the specific purpose of measuring the quantity of the material that comes from that. That we pretty much know. We have undertaken to evaluate the quantity of air pollution that is coming from that, the amount of material that is burned along with all the other open burning dumps and incinerators and other sources of pollution in the area.

Mr. WINN. How many open dumps do we have in the district? Mr. GRISWOLD. There are about five.

Mr. WINN. Are they similar types?

Mr. GRISWOLD. Not as large as that and not quite as well known. Mr. WINN. What steps have been taken to get rid of the Kennilworth dump or to change the system?

In other words, you know it's an immediate problem. You know that is where part of the trouble source is for the entire area. What steps have been taken?

Mr. GRISWOLD. Well, this would take quite a bit of time to go through, Congressman, but it is a well-known source of pollution. There have been several studies made of this. The way the city now exists, the problem of disposing of the material that is taken to the dump there is a more acceptable means from an anti-pollution standpoint. There is no question about the fact that dump that has been in operation has to be terminated. Hopefully it could be done by sanitary land fill. I am hoping that as a result of the abatement conference we will arrive at an agreement on a more acceptable alternate solution to the Kenilworth dump.

Mr. WINN. How long has this been a problem?

Mr. GRISWOLD. This has been a problem, I think, for over a decade. Mr. WINN. I have no more comment.

Mr. GUDE. General Mathe has been working on this problem. It is a tough one.

Mr. GRISWOLD. That is right.

Mr. GUDE. He hasn't had a decade to work on it yet.

Do you share the information you get from your monitoring stations with the Council of Governments?

Mr. GRISWOLD. Yes, we do; in fact the measurement of how much material, what type and quantity of pollutants that come from all sources including all types of incinerators and the open dump and all of this is developed with a team operation of technicians from the two States and the city and the Council of Governments and they, of course, have ready access to all this data.

Mr. MULTER. Now, then, the representatives of the District Government, will you please come forward, Lieutenant Colonel Henson, Dr. Grant, and Mr. Gimble.

STATEMENTS OF LT. COL. WILLIAM F. HENSON, ASSISTANT ENGINEER COMMISSIONER, DISTRICT OF COLUMBIA; MURRAY GRANT, M.D., DIRECTOR, DEPARTMENT OF PUBLIC HEALTH; AND GILBERT GIMBLE, ASSISTANT CORPORATION COUNSEL; AND ROY L. ORNDORF, DIRECTOR, DEPARTMENT OF SANITARY ENGINEERING Colonel HENSON. Sir, I am Lieutenant Colonel William F. Henson, Assistant Engineer Commissioner of the District of Columbia. On my left is Dr. Murray Grant, the Director of the District of Columbia Department of Public Health, and on my right is Mr. Roi Orndoff, Director of the Department of Sanitary Engineering.

It is a pleasure to represent the Engineer Commissioner at your hearing this morning.

The Commissioners are concerned about the increasingly severe airpollution problem in the District of Columbia and appreciate this Committee's interest in helping us set up the necessary machinery for effective air pollution control. We are convinced the aid and guidance of Congress is essential if our effort is to succeed here in the Nation's Capital.