corrective measures. Engineers and scientists, knowledgeable in the arts and science of water pollution abatement, are in short supply and in great demand. There are at present approximately 150 vacancies of professional personnel in the PHS water pollution control program despite the prestige of the organization and its ability to employ personnel through both the commissioned corps and civil service. We believe it most unlikely that a new, politically oriented administration could attract or retain needed technically competent personnel of higher caliber.

The APHA believes it unfortunate that the legislation presently under consideration by the Congress adds little to a greatly needed expanded research effort to cope with rapid scientific advances being made by our sophisticated society. In the face of this surging increase in technology, our capabilities to abate pollution as we know it today will soon be outdated. We believe it essential that greatly increased research activities be authorized and vigorously promoted in order to protect the health of the public and the recreational and conservation interests associated with clean water.

It is our further belief that increasing ceilings on grants for individual and multicommunity projects without a commensurate increase in the overall appropriation is not in the best interest of the program. We support increases in individual and multicommunity projects, but only if there is an increase in the overall appropriations. Treatment works and appurtenances sufficient for a large metropolitan area require expenditures in the range of $100 million. Increasing the per-project authorization to $2 million and raising the multimunicipal project authorization to $6 million would be of assistance to specific projects; but, as the committee can see, this remains a somewhat minor part of the total expenditure required for major projects. It is our view that both the per-project authorization and the total authorization should be increased if a truly significant assault is to be continued on the water pollution problems of the Nation.

In respect to the water quality standards section of this bill, the APHA believes that there should be authority to prevent pollution before it occurs particularly in instances where it is desirable to protect so-called wild streams. It is our view, however, that the proposals contained in H.R. 3988 and S. 4 go far beyond the granting of this authority and would, in fact, put into the political arena decisions governing the economic life of communities, of States, even of regions involved with interstate rivers or portions thereof. This, the committee will agree, includes most of the significant waters of our Nation.

lu summary, the APHA believes that programs of truly gigantic proportion are required to continue or preferably to accelerate abatement of water pollution in our Nation. We believe that significant progress has been made in recent years and is continuing at present. We believe that with continued, and hopefully, accelerated Federal support of efforts to abate water pollution, prospects for the future are heartening, irrespective of the governmental entity responsible for the administration of the program. We believe that for the most desirable results administration should remain with the technically competent, highly respected, and successful Public Health Service at the Federal level and with the public health agencies of the States. After much study, we can but conclude that those favoring transfer of this program to a political administration are doing an injustice to their own sincere objectives. Changing the bureaucratic level of an operation may help to give it increased visibility, but unless the program substance and imperfections are improved such visibility will not be ameliorating. We oppose particularly the creation of a new Water Pollution Control Administration. If it is the wisdom of the Congress that the political level is to be responsible for political decisions and the professional agency is to be responsible for the scientific work upon which decisions should be based, then there should be not only provision but the requirement that the professional agency publish its findings so that there can be an appropriate distinction between the scientific situation and the political exigencies.

We feel a great responsibility to express constructive views on water pollution control, the major justification for which remains the protection of the public's health, and we shall persist in our conviction that protection of human health is at least as important as protection of fish and game.

Hon. GEORGE H. FALLON,

Chairman, Committee on Public Works,

NATIONAL LEAGUE OF CITIES, Washington, D.C., February 24, 1965.

House of Representatives, Washington, D.C.

DEAR MR. FALLON: We are pleased to submit the following statement of the National League of Cities on legislation currently pending before your committee. We ask that the statement be made a part of the committee's record on H.R. 3988, S. 4, and related legislation.

The National League of Cities (formerly American Municipal Association), representing 13,000 municipal governments across the Nation, has a consistent record of support for constructive legislation aimed at the reduction of water pollution. On behalf of the city governments of the United States, the league has welcomed Federal interest and assistance in this most vital field. Construction grant assistance, research, enforcement assistance, and the other phases of the water pollution control program, have increased the tools available to the cities for the task of preserving and developing the water resources which are so vital to the urban population.

We reviewed with interest, therefore, H.R. 3988 and S. 4, when these bills were introduced. There is much in both bills which will add to our resources to deal with water pollution. There is also much in both bills which the league supports as a matter of policy.

H.R. 3988 and S. 4 both propose an increase in Federal participation in individual construction projects, combined (multimunicipal) projects, as well as establishing a 10-percent incentive increase for projects in conformance with comprehensive sewage treatment plans for the area. These proposals are directly in line with our policy which calls for a minimum of one-third Federal share of total project cost. It is clear that larger construction projects have, for too long, borne a disproportionate share of the costs at the local level. We support, therefore, that adjustment which these bills propose on this matter. We hope, however, that this issue will be reviewed in more detail in the near future and that further adjustments of the formula may be considered. We further note that the bills do not extend the expiration of the construction program nor increase the total construction grant funds available for apportionment to the States. Both of these matters should be undertaken in the near future. It is particularly imperative that more construction grant funds be made available beyond the present annual maximum authorization of $100 million if the larger Federal participation formulas are to be meaningful. The present restriction on State allotment of construction grant funds does not meet the water pollution contról need in populous States. A larger annual authorization for construction grants would allow individual projects to receive more Federal funds without detracting from the total number of projects which may be undertaken in a State. The league supports comprehensive planning for sewage treatment. We believe the incentive proposed in the legislation would aid in achieving this goal. It is, in our judgment, a proper use of Federal funds.

In August 1964, the Water Resources Committee of the National League of Cities considered then current proposals relating to the problem of pollution from combined storm and sanitary sewer systems. The committee approved the following statement on the problem :

"The Congress is urged to continue and expand the 1956 Water Pollution Control Act by providing authorization and appropriations for Federal grants to municipalities for the purpose of assisting in the development of projects which will demonstrate new or improved methods for the control of pollution from mixtures of sewage and storm water discharged into any waters from combined sewer systems."

This position was unanimously adopted by delegates representing all of our member municipal governments. It is clear, therefore, that we support the proposed research and demonstration grant program of H.R. 3988 and S. 4 relating to combined storm and sanitary systems.

Our national municipal policy contains the following language concerning the question of enforcement:

"The Federal Water Pollution Control Act Amendments of 1961 provide a comprehensive definition of the Federal Government's role in the control of water pollution, extend Federal pollution control on navigable waters and strengthen Federal enforcement authority. Municipalities are accorded a measure of partnership with Federal and State authorities in the enforcement process. The

Congress is commended for great progress in the field of water pollution control and in the development of research, technical, and enforcement facilities supporting, but not duplicating, municipal and State activities."

It is our belief, therefore, that section 5 of H.R. 3988 and S. 4 proposes a standards and enforcement section which conforms to this statement. The legislation would empower the Secretary of Health, Education, and Welfare, in consultation with State, interstate, and local pollution control agencies, to establish water quality standards for interstate waters in the absence of State standards or after a finding that State standards are inadequate. This maintains State and local participitation in the direction of standards establishment and enforcement.

The matter of administration of the water pollution control program appears to be the only significant difference between the two bills. H.R. 3988 proposes that the entire program be placed in a new water pollution control administration, while S. 4 proposes that certain parts of the program be placed in a new administration. The national municipal policy relating to program administration contains the following proposal:

"The Congress is urged to continue and expand the 1956 Water Pollution Control Act by the establishment of a national office of water pollution control. The responsibility of the national office should include national leadership and direction of a national water pollution control program as directed by the Congress under the Federal Water Pollution Control Act, as formulated and recommended to the Congress from time to time by the House and Senate Committees on Public Works. An Assistant Surgeon General Engineering Officer of the Public Health Service should be assigned by the Surgeon General as the Director of the National Office of Water Pollution Control. The Director of the National Office of Water Pollution Control should be directly responsible to the Surgeon General, under the general delegation and supervisory authority of the Secretary of the Department of Health, Education, and Welfare, as now provided under existing law. To make effective such delegation and supervisory authority of the Secretary there should be authorized an additional Assistant Secretary of the Department of Health, Education, and Welfare."

Our policy, moreover, makes this statement concerning the work which the Public Health Service has done in this important program:

The Public Health Service has acquired an especially competent staff of water pollution control engineers and scientists. As demonstrated, given resources, it can plan and administer in collaboration with State and municipal governments, on other interests an effective national water pollution control program which gives full consideration to all water uses. The Federal water pollution control program, therefore, should be maintained as a major operating unit in the Public Health Service, reporting directly to the Surgeon General.

We request, therefore, that the committee consider amending the bills accordingly. We do believe, however, that S. 4 is the more preferable of the bills measures on the matter of administration. Our judgment on this matter is derived from the satisfactory experience which cities have had in working with the Public Health Service in the effort to control water pollution. We feel that the Public Health Service experience and personnel in this field should be kept active in the program. We suggest that the complete elimination of the Service from the program would immeasurably retard efforts aimed at eliminating water pollution.

We respectfully submit these views on H.R. 3988 and S. 4 for the consideration of the committee.

DEAR CONGRESSMAN FALLON: On behalf of the New England Council, I would like to take this opportunity to submit for your consideration our views on S. 4, as passed by the Senate, and H.R. 3988, similar bills to amend the Federal Water Pollution Control Act.

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The provisions of these two bills have been the subject of thorough and extensive hearings and it is not necessary for us to review them in detail. However, we would like to discuss certain aspects of the bills which we believe deserve the careful attention of your committee.

Section 5 of the proposed Water Quality Act of 1965 would grant the Secretary of Health, Education, and Welfare authority to establish water quality standards designed to enhance the quality of interstate waters. In establishing such standards, the Secretary is required to consider the use and value of such interstate waters for public water supplies, propagation of fish and wildlife, recreational purposes, and agricultural, industrial, and other legitimate uses. Such standards shall be published only if, within a reasonable time after being requested by the Secretary to do so, the appropriate State and interstate agencies have not developed satisfactory standards.

The authority provided by this section involves extremely complicated and complex issues relating to the public interest. One difficulty in establishing water quality standards is that a stream in its natural state varies considerably from its source to its mouth. In addition, the water quality standards which are appropriate vary according to the use which is to be made of the water. Accordingly, water which is usable for one purpose may well lose its desirable qualities for another use. Because water flowing from its source to its mouth changes in its composition and noture several times, the difficulty of establishing any uniform standards is accentuated.

It is with knowledge of the complexity of this matter that it has long been a firm tenet of public policy that primary responsibility in setting water pollution standards should properly rest with appropriate interstate and State bodies which possess intimate knowledge of local conditions.

For example, the New England Interstate Water Pollution Control Commission, in existence since 1947 and representing the States of Connecticut, Maine, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont, has based its water pollution control efforts on a system of water classification involving accepted water quality standards. Under the existing interstate compact each of the States pledges to maintain its waters consistent with the highest classified uses adopted. The compact provides a method for classifying interstate waters according to uses which will best serve all the interests concerned-industrial development, population growth, and recreational opportunity, among other things. Each State assumes responsibility under the compact to obtain action by municipalities and industries to install facilities to meet the classification requirements. Under this system of interstate cooperation impressive progress has been made in abating water pollution. It should be noted that in the matter of classification almost all interstate waters in the seven-State area have been approved by the interstate commission.

It is with this record of achievement in mind that the New England Council believes that the Federal Government in exercising any new authority should, whenever possible, defer to the action of interstate and State groups in their exercise of judgment as to what water classification best reflects local needs. It is not possible in this brief statement to develop a detailed or adequate set of guidelines which should govern the operation of any standards which are applied-whether the standards are Federal or State in origin. It must be emphasized, however, that it is of major importance that the practicability and economic feasibility of obtaining uses of significance in the public interest be considered at the earliest possible time. In this connection, we need to have a thorough study and better information on the ability of individual industries to comply with standards which are set. Possibilities for special Federal aid to help industries meet required standards should be considered, such as special low interest Federal loans or tax relief to encourage the construction of necessary treatment plants. There can be no question that the cooperation of industry is essential if a successful water pollution control program is to be mounted. There is a basic need to encourage and stimulate industry cooperation and participation. We are concerned with the possibility that Federal standards might be promulgated before adequate attention has been given for developing a sound program of Federal assistance to affected industries.

Considerable attention has been devoted to the adequacy of the review accorded water pollution standards to determine their practicability and economic feasibility. As we understand it, an industry or other interested party can test the standards if an abatement proceeding is initiated and court review is sought.

However, it would seem preferable if these standards could be reviewed prior to a punitive court action. We urge the committee to consider with care the adequacy of the proposed legislation in this respect.

We would hope that it is not necessary to invest considerable Federal staff, time, and money in the establishment of broad standards which may or may not properly reflect the interests of an interstate or State area. Rather we would prefer to have such resources directed toward assisting municipalities and industry in achieving goals that are, for the most part, already well defined by impressive on-going efforts such as the New England Interstate Water Pollution Control Commission represents.

To control our waters so as to achieve the proper mix of economic development, recreational, and household uses deserves the continued attention of those most familiar with local problems. Hopefully, the Department of Health, Education, and Welfare will view any new authority it is given to set standards as something to hold in reserve for use only in those unusual and extreme cases where appropriate interstate and State groups fail to meet their responsibilities. There can be no question that the problem of water pollution poses a major threat to the maximum development of our natural resources. Only by the strengthened efforts of all levels of Government in close cooperation with private interests can we hope to conquer this severe problem. We believe that the record of the New England region has been noteworthy in the past and we know that the region will continue to bend its best efforts toward achieving the objectives expressed in the Water Pollution Control Act.

Very truly yours,

GARDNER A. CAVERLY,
Executive Vice President.

REMARKS OF STATE SENATOR JOHN H. DOERR, OF THE 55TH DISTRICT OF

NEW YORK STATE

Chairman Blatnik, Congressman McCarthy, honorable members, my name is John H. Doerr. I am the New York State senator from the 55th district which lies in the northern half of Erie County and is contiguous with the 39th Congressional District represented by Congressman McCarthy. It is no accident, therefore, that I share Congressman McCarthy's concern for the prevention and control of water pollution. I speak in favor of H.R. 4264.

The concern shared by Congressman McCarthy and myself-indeed, by all of the residents of the Niagara frontier whose livelihood is directly or indirectly affected by the Great Lakes-is prompted by the fact that if it were not for Lake Erie, Buffalo would not exist today as the center of one of the Nation's major industrial, commercial, and transportation complexes.

As I see it, this bill will substantially strengthen our efforts to deal with the critical problems of water pollution which already have materially jeopardized the economic vitality of our region. I am particularly impressed with the bill's provisions for creation of a Federal Water Pollution Control Administration for the funding of intensive research aimed at finding new and effective control measures and for the raising of limits on Federal assistance for control projects. The members of the committee may be aware that the Governor of the State of New York has recently proposed an ambitious antiwater pollution program for the State. Admirable as this aim may be, I am persuaded that such a program runs the serious risk of costly and ineffective duplication of Federal activities, and when the Governor does submit specific proposals I intend to subject them to close scrutiny to eliminate duplication wherever possible. Further, I am convinced that by its nature, the problem of water pollution can only be effectively solved at the Federal level. Water pollution is no respecter of State boundaries. The problems of water pollution in the eastern end of Lake Erie are, in some measure, the result of the lack of, or ineffective, pollution control by certain communities and industries in western New York. However, correction of these relatively few shortcomings would not really solve the total problem of pollution we face. The treasury of the State of New York could be drained to provide the most modern water treatment facilities and pollution-control systems within the boundaries of the State. And yet, our beaches on Lake Erie would still be closed; our industries would still be starved for clean, cool water and fully 25 percent of the waters of Lake Erie would still be incapable of sustaining marine life.