Good morning. My name is James M. Lents. I am Director of the Environmental Policy and Atmospheric Research Laboratory for the Center for Environmental Research and Technology at the University of California, Riverside, Bourns College of Engineering. Prior to my present position, I served 8 years, from 1971 to 1979, as Technical Director for the Chattanooga-Hamilton County Air Pollution Control Program, 7 years, from 1979 to 1986, as Director of the Colorado Air Pollution Control Program, and 11 years, from 1986 to 1997, as Executive Officer for the South Coast Air Quality Management District in California. 

My environmental career began at the adoption of the 1970 Clean Air Act Amendments working in the Chattanooga, Tennessee, air pollution control program. I continued to work in air pollution control programs following the 1977 and 1990 Clean Air Act Amendments in Colorado and California respectively. In each of these assignments, the Clean Air Act played an important and critical role in supporting and even engendering the air quality improvement that has occurred in each location. News releases by the Mayor of Chattanooga in the early 1980s and by the Governor of Colorado and the leaders in Southern California more recently illustrate the pride that each of these areas has taken in the significant air quality improvements that have been achieved. 

In 1970, Chattanooga suffered some of the dirtiest air in the nation. This included particulate levels in the downtown region that were among the highest in the nation, NO₂ levels that served as the laboratory for the early development of NO₂ health standards, and violations of the Carbon Monoxide and Ozone standards. Although Chattanooga had operated a smoke abatement program since the 1930s, the rules had little effect. Air quality was so poor that auto dealers and homeowners washed their cars daily to avoid permanent paint damage, and high ambient NO₂ levels even damaged women's nylon hose while they were being worn. A local health study demonstrated that children living in areas that were at the lower end of the Chattanooga air pollution spectrum had significantly above normal respiratory problems. The effects on the minority communities that existed in the worst part of the pollution were never documented. 

In association with the 1970 Clean Air Act Amendments, Federal funding was withdrawn from Chattanooga and a Federal Implementation Plan was threatened to inspire serious actions by local and state officials. These steps, along with the establishment of nationally accepted health standards called for in the 1970 Amendments, inspired the local city and county governments to revamp their air pollution control effort. The Federal government then provided funding that allowed the city and county to hire a small staff of air pollution control experts to oversee the cleanup effort. In the face of medical testimony from local company doctors that air pollution in Chattanooga was not a problem and threats by local manufacturers to close their plants if air pollution rules were adopted, the region implemented tough emission standards in the early 1970s. Controls on sources were completed between 1973 and 1979. Particulate levels dropped noticeably in the 1970s and early 1980s, and Chattanooga came into compliance with existing standards in the mid-1980s. Following this achievement, Chattanooga transformed its formerly grimy downtown area - where you once could not see across the street - into a beautiful mall and riverfront park. Chattanooga's economy has continued to grow, becoming a poster child for what could be done to control air pollution. A national article in Time magazine and an EPA film titled "What One City Did" documented the efforts by Chattanooga to resolve its air quality problems. Today, Chattanooga takes great pride in its much cleaner air. The 1970 Clear Air Act was the seminal event that stimulated these important changes. Figure 1 shows the change in particulate levels in Chattanooga between 1970 and 1990. 

Denver, Colorado, experienced the worst Carbon Monoxide levels in the United States in the 1970s, close to 4 times the national health standard, with levels getting worse year by year along with a burgeoning "Brown Cloud" problem and concern about Ozone. The 1970 and 1977 Clean Air Act Amendments required Colorado to produce a compliance plan, referred to as a State Implementation Plan in the Clean Air Act, by 1982 to demonstrate how the Carbon Monoxide problem would be solved. The 1977 Clean Air Act Amendments also mandated a vehicle inspection and maintenance (I/M) program for the Denver area. More importantly, however, the Federal law set a strict deadline to attain healthy air and included sanctions for not making a good faith effort to meet cleanup requirements. After a brief application of Federal sanctions to get legislative action, Colorado adopted an I/M program in 1980, and with the aid of automobile emission standards set forth by the Clean Air Act began its development of an attainment plan. The local planning process resulted in the conclusion that I/M and the Federal automobile emission standards were inadequate to meet ambient-air quality levels by the 1987 deadline. This conclusion resulted in the development of a pilot episodic no-drive program and research into cleaner-burning fuels. While the no-drive program did not produce the desired results, the cleaner-burning gasoline did. The tightening automobile emission standards as specified in the Clean Air Act combined with the I/M program and cleaner-burning gasoline produced significant Carbon Monoxide reductions before 1990 and attainment of the Carbon Monoxide standard in the early 1990s. A synopsis of the change in Carbon Monoxide levels between 1970 and 2000 is shown in Figure 2.

 Los Angeles, which suffered severe photochemical smog by the 1950s, is the birthplace of the understanding of the source and causes of much of our urban air pollution. It initiated the control of automobile emissions in the 1950s, ahead of anyone else in the United States. However, by the 1970s, the air pollution problem in Los Angeles had become generally worse in spite of these local county air pollution control efforts. The advent of the 1970 and 1977 Clean Air Act Amendments accelerated the development of a region-wide air pollution control agency called the South Coast Air Quality Management District, and the far-reaching automobile standards in the 1970 Clean Air Act Amendments set California on an aggressive path toward cleaner air. Inspired by the results of the Clean Air Act's automobile emission standards, California, as the only state allowed to set separate mobile source standards, took over the lead from the U.S. EPA in driving vehicle emission standards through the 1980s and 1990s. 

The citizen suit provisions in the Clean Air Act Amendments played an important role in fostering clean air in Los Angeles. After the failure of the South Coast Air Quality Management District to develop a suitable State Implementation Plan by 1982, environmental groups used the citizen suit sections of the Clean Air Act to get a judicial ruling requiring the U.S. EPA to develop a Federal Implementation Plan for the region. This embarrassment to the local leadership along with subsequent State and Congressional hearings resulted in a much more activated South Coast air pollution control program, advancing progress toward clean air and producing important experience needed for the 1990 Clean Air Act Amendments.

Once adopted, the 1990 Clean Air Act Amendments gave Los Angeles a reasonable time frame to solve its problems. With this more realistic deadline, the South Coast Air Quality Management District in association with the California Air Resources Board and Southern California Association of Governments produced the first State Implementation Plan to ever be approved by the U.S. EPA for Southern California. Implementation of this Plan has produced remarkable results. In spite of some of the largest population and economic growth in the nation, California has reduced the number of violation days of air quality standards by 80% since the 1970s and has had no air pollution alerts since 1999 for the first time in the history of air monitoring there. Figure 3 illustrates the changes in Ozone levels in Southern California since the 1977 Clean Air Act Amendments. 

As I close my testimony, I want to note three important issues. First, there was clearly a need for the Federal government to intervene at times and to push states to develop adequate clean air programs; however, the Clean Air Act would not have succeed as it has without a close partnership between state and local air pollution control efforts and the Federal government. Second, there has been difficulty in achieving the flexibility for state programs and businesses that were envisioned in the discussions surrounding the Clean Air Act Amendments. This needs to be improved in the future. Third, the air pollution problem is far from solved and will require even more complex actions as we proceed into the 21^st Century. 

State and local programs established and now maintain almost all of the nation's air monitoring stations, wrote and continue to adopt most of the applicable stationary source regulations, and operate and enforce most of the local compliance programs. No success would have been achieved if these programs had not been effective. The California automobile control program has provided much of the leadership for the clean vehicles that are being produced today. The Colorado air pollution control program combined with subsequent efforts in California pointed the way toward the development of today's cleaner burning gasoline and diesel fuel. 

The processes employed by the U.S. EPA to enforce Federal requirements in the Clean Air Act have not always enabled the level of flexibility that could have been included in the process. Examples can be cited concerning experiences with I/M programs, the specific design of State Implementation Plans, and most notably the recent application of the Title V Federal permitting program. Greater effort needs to be made in future Clean Air Act implementation to find more flexible ways of applying its requirements. Although not a panacea, an important potential for the future can be a further move away from command and control regulation toward more flexible market-based solutions. It appears that Federal regulatory programs along with many state and local programs are now recognizing the benefits of market-based solutions in many key regulatory programs. 

There is still a long way to go to achieve the goal of healthy air in the United States. Chattanooga and much of the Eastern United States are likely in violation of the new PM_2.5 and Ozone standards. Acid deposition is another significant problem that needs continued focus, especially in the East. Los Angeles along with many other areas in California and Texas still suffers from Ozone air pollution and will violate the new PM_2.5 standards. Western visibility is significantly reduced in many locations, leaving Denver and many other areas without the beautiful vistas that they once enjoyed. A unifying theme surrounding these 21^st Century issues is the need to address the multi-jurisdictional, regional aspects of smog. When the Clean Air Act was envisioned in 1963, 1970, and 1977, air pollution was seen as primarily a local or state problem that simply needed a boost from the Federal government to reach attainment goals. It is clear today that air pollution problems cross state lines and international boundaries and in some case are global in nature. Future air quality improvement programs must address these complex inter-jurisdictional issues. 

Finally, the population of the earth will pass 10 billion during this century. Available land for humans and ecosystems to operate has dropped from about 17 acres per person in the 1950s to 8 acres per person today. This decline will continue in this century to levels possibly below 5 acres per person. This increasing human density along with continued economic growth will further exacerbate air quality and other environmental problems. It is imperative that Congress continues to provide both national and international leadership towards cleaner air. 

This concludes my testimony. I will be pleased to answer questions at the appropriate time.