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WATER POLLUTION CONTROL FEDERATION,

Washington, D.C., April 8, 1966. Senator ABRAHAM A. RIBICOFF, Chairman, Subcommittee on Executive Reorganization, Senate Committee on

Government Operations, Senate Office Building, Washington, D.C. DEAR SIR: Responsive to your invitation extended at the time of adjournment of your subcommittee hearings on yesterday, we are pleased to present herewith the views of this organization on Reorganization Plan No. 2 of 1966 which would transfer the Federal Water Pollution Control Administration from the Department of Health, Education, and Welfare to the Department of the Interior.

This federation is an organization joining the efforts of 39 State and regional associations serving all of the 50 United States and Puerto Rico. Through the combined membership in this area of well over 10,000, the federation serves approximately 50,000 persons concerned with the technology of water pollution control through the proper collection and treatment of domestic and industrial wastewaters. The membership is comprised of engineers and other professional men engaged in the design, promotion, regulation, construction, research, and operation of water pollution control facilities. While these remarks are given on behalf of the U.S. associations, it is interesting to note that there are 13 organizations outside the United States who have found it advantageous to affiliate with the federation primarily for the value of the federation's technical publication, Journal Water Pollution Control Federation. The total paid circulation of this journal now nearing 15,000 retains for the federation the position by far of being the world's largest publisher of water pollution control information. The federation is a nonprofit member organization incorporated in Illinois and has been serving the field as the principal fountain of technical knowledge since its initial organization in 1928. Its primary objectives are to disseminate technical knowledge in the field as well as outside the field in order to cope with all aspects of water pollution control techniques. In recent years its monthly newsletter Highlights has been going to the same list of readers for supplying less technical information and news to the field.

The year 1965 brought recognition for the water pollution control activity by its separation from the Public Health Service and the legislative creation of the Federal Water Pollution Administration under the Secretary of Health, Education, and Welfare. As has already been expressed by both subcommittee members and witnesses, the time that has been lost in further reorganizational change of this matter is deeply regretted. However, a vigorous program promptly applied can soon overcome this loss and bring the citizens of the United States the actions and, hopefully, the results that are envisioned for this program. This organization believes strongly that which Federal department has jurisdiction in this field is less important than maintenance of the Water Pollution Control Administration as an entity separate from existing organizations. It further believes that the most important aspect which has not been discussed by the subcommittee in its 2 days of hearings is the obvious importance of properly qualified personnel in the leadership and staffing of the new administration.

During the history of water pollution control activity in the Public Health Service there has developed a great deal of technology which is positively essential to a solution to water pollution problems of the Nation. These gains must by held, and with them must continue research, especially that which can be developed and applied to actual solution of water pollution problems. The application of such research as well as the proper administration of construction grants is essentially an engineering function, and these activities should find a proper place in the Department of Interior which is quite appropriately an activity highly dependent upon the work of civil engineers. In the water pollution control field engineering talents are available through such men and particularly those who have specialized in sanitary engineering which is beginning to become known as environmental engineering. The knowledge and experience of these men, unfortunately limited in number, must be organized along with the allied professions to make a full scale attack on water pollution problems.

This organization pledges its full support and aid to this program which fortunately has the backing of President Johnson. This is in keeping with the statement of policy of the federation, a copy of which is attached hereto. Respectfully submitted.

RALPH E. FUHRMAN, Executive Secretary.

STATEMENT OF POLICY ON WATER POLLUTION CONTROL IN THE UNITED STATES (Revised by the Board of Control of the Water Pollution Control Federation,

October 14, 1965)

(This statement of policy was adopted originally by the board of control on October 6, 1960. Since then, revisions have been made to keep the statement abreast of expanding and rapidly changing activities in the water pollution control field.

(The Federation has an important responsibility to the public as well as to its membership. In order to fulfill this responsibility it intends to pursue aggressively the objectives set forth in this statement.)

Pollution of the Nation's inland surface waters, coastal waters, and ground waters is a continuing threat to the national health, comfort, safety, and economic welfare. National survival, in terms of future urban, industrial, and commercial growth and prosperity, dictates the protection of all water resources from any acts, such as the discharging of harmful substances, which cause unreasonable impairment of water quality and adversely affect their highest level of usefulness. While considerable progress has been made in pollution control by many municipalities and industries, many water resources are being degraded, impaired, and damaged by such discharges and acts, and they will be further adversely affected by the degree and pattern of population growth, industrial processing, commercial expansion, chemical usages, and other technological advancements.

The Water Pollution Control Federation believes that, to assure the conservation and protection of the Nation's water resources

(1) The discharge of pollutional wastes into the waters of the Nation should be controlled.

(2) Decisions on the type and degree of treatment and control of wastes, and the disposal and use of adequately treated waste water, must be based on thorough consideration of all the technical and related factors in each portion of each drainage basin.

(3) The responsibilities for the adequate treatment and control of wastes to overcome pollution must be assumed individually and jointly by industry and local, State, and Federal Governments.

(4) Basic and applied research by competent personnel must be encouraged by broad efforts to develop new knowledge that will solve water pollution problems.

(5) The administration of pollution control must be firm, effective, and equitable.

(6) The administration of State and interstate pollution control programs should remain in the hands of State and interstate water pollution control agencies, which must be supported by increased budgets and adequately staffed by well-trained and compensated engineers, scientists, and other personnel. The rights of State and interstate agencies to control and protect water resources must be accompanied by equal responsibilities to perform their functions effectively.

(7) The federation and its members should give full support to all constructive efforts, public and private, which contribute to the control of water pollution.

(8) While the primary objective of pollution control must be the protection of the public health, other objectives, such as the need for the use and reuse of surface and ground waters which receive and dilute liquid wastes, add impelling reasons for protecting the Nation's water resources.

(9) Waste water represents an increasing fraction of the Nation's total water resource and is of such value that it might well be reclaimed for beneficial reuse through the restoration of an appropriate degree of quality. To this end the development of methods for waste water reclamation and criteria for such reuse should be encouraged.

(10) The public must be made fully aware of the hazards of pollution and of the workable means for control so that it will sponsor and support construction and proper operation of all necessary facilities.

(11) Mandatory certification or licensing of better trained and compensated operating personnel is the best ultimate means for assuring the most effective operation and maintenance of pollution control facilities.

(12) Standards for radiation hazards in water pollution control should be primarily for the protection of the public health.

(13) To the maximum extent practicable, the control of toxic and exotie chemicals should be exercised at the source in order to prevent problems in water pollution control.

(14) Federal, State, and local laws and practices should be derised and modified to assure the most economical and effective means for financing the construction, operation, and upgrading of waste water treatment works

CHEYENNE, WYO., April 15, 1966, Hon. JILWARD SIMPSON, U.S. Senate, Washington, D.C.:

The Wyoming Health Association has voted to protest the transfer of the water pollution control from the Health, Education, and Welfare to the Department of the Interior.

RORERT GILSTRAP, President, Wyoming Health Association.

KIMBERLY-CLARK CORP.,

Neenah, Wis., April 12, 1966. Hon. A. A. RIBICOFF, Senate Office Building, Washington, D.C.

DEAR SENATOR RIBICOFF: Executive Reorganization Plan No. 2 would transfer the Water Pollution Control Administration from the Department of Health, Education, and Welfare to the Department of the Interior. The announced purpose of this organizational move is to consolidate most water pollution control activities in one place. Kimberly-Clark Corp. opposes this shift for a number of reasons :

(1) Water pollution and control is first and foremost a health problem, and this has been recognized as the intent of Congress in passing the various pieces of legislation which have become law in the last two decades. Interior has no expertise in this area and can be expected to emphasize the conservation and recreation aspects which, although important, are not the prime concern.

(2) A working organization has been established in HEW, the disruption caused by transfer will result in confusion and delay of programs initiated under the Water Quality Act of 1965.

(3) Competent trained personnel in the water pollution field are in extremely short supply nationally. Transfer of these activities now can only mean a worsening of this situation as Interior tries to "man-up" to handle the job.

(4) The proposed transfer of responsibility will actually fragment the present Federal pollution control program, rather than effect any consolidation.

I am writing this letter to all Senators and Representatives in those 14 States in which Kimberly-Clark Corp. has, or is contemplating, major manufacturing installations. We hope that before the deadline of April 28, 1966, is reached, you will consider the detrimental effects of this transfer of responsibility and offer, or support, a resolution to veto. Sincerely,

ABBOTT BYFIELD,

Director of Public Affairs. o

A. Grithi Rao

(Health Functions—Department of Health, Education, and Welfare)

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NOISIAIO

BEFORE THE

OF THE

SUBCOMMITTEE ON
EXECUTIVE REORGANIZATIORENT

COMMITTEE ON
GOVERNMENT OPERATIONS

UNITED STATES SENATE

EIGHTY-NINTH CONGRESS

SECOND SESSION

ON

REORGANIZATION PLAN NO. 3 OF 1966, PREPARED IN ACCORDANCE WITH THE PROVISIONS OF THE REORGANIZATION ACT OF 1949, AS AMENDED, AND PROVIDING FOR REORGANIZATION OF HEALTH FUNCTIONS OF THE DEPARTMENT OF HEALTH, EDU

CATION, AND WELFARE

JUNE 17, 1966

Printed for the use of the Committee on Government Operations

U.S. GOVERNMENT PRINTING OFFICE

66-429 O

WASHINGTON : 1966

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