was to cut up the area into two smaller projects which on paper would slip under the congressional limit.

So there are now two separate proposals: Starkweather, 246,477 acres, and Edmore, 246,118 acres. They are in the same drainage basin, linked by a single channel and draining into the same big exit ditch.

You may have noted that these two projects add up to 492,595 acres, and there are about 518,000 acres overall. Since the additional acres could not be tacked on to either project without pushing it over the limit, there is a 26,000 acre "dead area" right in the middle, undeclared in either project. Administrative genius! When someone tells you that Starkweather isn't really that big, and anyway it's the kind of project that's been popular for years in most congressional districts, you finally rebel and say, "It just doesn't make sense from any angle." Starkweather is a natural basin. The water stays where it falls, or collects in natural kettles and ponds, shallow, freshwater wildlife incubators, the stuff of prairie life. Now we plan to pull the plug, rush the water out. And call it flood control.

These wetlands will be dried up, and plowed in the fall to get a jump on spring. The winter winds will whip up the exposed soil and dry snow into brownstorms. And we call this soil conservation.

These lands will grow more surplus for government granaries, and we will pay more money to set aside more acres. And we call it a farm program.

And when you want to see those great restless movements of waterfowl rising and wheeling in the morning light, you can go to Canada for the few that remain and you can say, "We used to see them in our country too, once upon a time. . . ." The Federal Government spends millions of dollars every year to hold down crop production. It also spends milions to increase production of the same crops. Were it only money against money it would be the height of absurdity. But compounding this foolish waste is the disturbing fact that in the process irreplaceable wild.ife habitat is being lost all across the Nation.

Less than a century ago there were approximately 10 million acres of prairie wetlands in the United States-prime habitat for ducks and geese. But 60 percent of these wetlands have now been drained says the U.S. Bureau of Sport Fisheries and Wildlife. Half of this loss has been in the last 20 years. And the loss continues.

Consider, for example, Chicod Creek, a Soil Conservation Service drainage project in North Carolina. It will destroy 66 miles of river wetlands, to put 10,000 acres of new crop and into production. Yet, last year the Federal farm program paid farmers in this same county $832,234 for not farming 30,490 acres.

There is also the Cache River project in Arkansas where the Corps of Engineers will spend $54 million draining 100,000 acres of prime southern hardwood swamp. That's $540 an acre. Over 90 percent of the projected "benefits" will come from the production of more soybeans. Yet, Arkansas farmers have been paid soybeans subsidies 2 out of the last 5 years.

At the other end of our country is New Malones where a $181 million impoundment built by the Corps of Engineers will combine with a $1.5 billion Bureau of Reclamation irrigation system to put more California's central valley into surplus crops. In 1971 taxpayers paid more than $100 million in crop price subsidies to California farmers-and millions more were paid to farmers there for not farming.

Our struggle to defeat ourselves continues to escalate. We ditch, drain, cut, and plow under scarce wildlife habitat-and we increase crop surpluses which require increased subsidies. The cost in taxpayers' money is great. The cost to wildlife is its very existence.

U.S. DEPARTMENT OF THE INTERIOR,

OFFICE OF THE SECRETARY, Washington, D.C., December 12, 1972.

Hon. EARL L. BUTZ,

Secretary of Agriculture,

Washington, D.C.

DEAR MR. SECRETARY: The Starkweather watershed project, Ramsey and Cavalier Counties. N. Dak., presently being planned under the authority of Public Law 83-566, poses problems of grave concern to this Department. Our most thorough review of the draft environmental statement together with our

reassessment of project effects on natural resources have convinced us that new approaches must be made to find solutions to the problems at hand. Without question, an extended, in-depth study is required to equate the needs of agriculture with those of other environmental values both in this watershed and in the adjacent affected wetland areas.

Specifically, and of greatest concern, the Starkweather project will cause systematic and unwarranted losses of natural prairie marsh resources in the pothole area of North America. In anticipation of the construction of this project, the Bureau of Sport Fisheries and Wildlife has conducted an accelerated program of wetland acquisition. By purchasing easements or fee titles with duck stamp funds the Bureau has insured the preservation of 6,472 acres of wetlands out of the 18,400 acres that still remain undrained within the Starkweather watershed, this in accordance with an agreement between the project sponsors and the Bureau. The project sponsors had agreed to preserve an additional 2,000 acres, but it appears that only about 1,360 of these have been protected to date.

In our further review of the project and the draft environmental statement we find that the ultimate impact would be far greater than that of the Starkweather watershed alone. The channels to be built for the Starkweather project would also provide outlets for the drainage of the Edmore watershed as well as the area lying between Edmore and Starkweather. An additional 27,300 acres of top quality wetlands could be drained, a factor which the draft environmental statement fails to consider.

The Starkweather-Edmore wetlands are among the highest producers of ducks per acre on the North American Continent, yielding more than 100,000 ducklings each year. Most importantly, they produce nearly 10 percent of the total canvasback and up to 30 percent of the total redhead production in North Dakota, the country's most significant breeding State for these two depleted species. As you undoubtedly know, I have closed the hunting season on canvasbacks throughout the country and redheads in all but the Pacific flyway this year because of the serious decline in their populations, and I have launched an expanded research program in hopes of restoring their numbers. We feel that loss of habitat in certain key areas, such as the Starkweather-Edmore wetlands, is a major contributing cause to their decline.

We estimate that the Starkweather project could result in the loss of up to 71 percent of the remaining wetlands in the Starkweather-Edmore drainage area. Furthermore, it would reduce the water levels of Dry Lake and the lakes and marshes to the west, including our recently acquired Federal wildlife refuge at Lake Alice. These lakes and marshes are also extremely important breeding, brood and staging areas for migratory waterfowl.

In conclusion, we believe that there are vital environmental factors pertaining to the Starkweather project which give this Department strong reason to oppose it in its present form. At the very least we feel that the circumstances require a thorough reevaluation of the project, its relationship to projects and programs of other Departments, its mitigation features and alternative ways of accom plishing its goals.

Sincerely yours,

ROGERS C. B. MORTON,
Secretary of the Interior.

Mr. REUSS. We will now hear from Mr. John L. Franson, central midwest representative of the National Audubon Society.

STATEMENT OF JOHN L. FRANSON, CENTRAL MIDWEST REPRESENTATIVE, NATIONAL AUDUBON SOCIETY; ACCOMPANIED BY EDWARD M. BRIGHAM III, NORTH MIDWEST REPRESENTATIVE; AND JOHN SPINKS, SOUTHWEST REPRESENTATIVE

Mr. FRANSON. Thank you, Congressman Reuss.

Congressman Reuss and committee members, I am pleased to be here today on behalf of Dr. Elvis J. Stahr to present the view of the National Audubon Society on stream channelization. Dr. Stahr asked me to express his regrets that he could not be here personally since

the discouragement of Government-sponsored stream channelization is one of the major priorities of the National Audubon Society together with our 287 local chapters and 265 other affiliate organizations. We interpret the committee's invitation to testify here as an opportunity to update our reports on stream channelization and we thank the committee for giving us this opportunity. Since the last subcommittee hearings, in May and June of 1971, a number of events have taken place which have been well outlined by your staff in "Issues and Matters for Discussion at Hearings," and I especially want to compliment the staff for that. This is an excellent document and very helpful. Probably the most important consequence has been a growing public awareness of stream channelization projects and their environmental effects. The agencies involved are now also becoming more sensitive to the issue.

Largely at the urging of concerned citizens and because of the initiative of State fish and game divisions, some States are taking it upon themselves to act on and oppose stream channelization projects. Ohio, for example, interceded with a moratorium and has held statewide. hearings on channelization which proved devastating to Soil Conservation Service (SCS) projects; North Carolina Governor Holshouser called for an investigation of the practice; Louisiana's Wild Life and Fisheries Commission resolved in opposition to these programs; the Idaho Legislature passed a stream protection act; Virginia Fish and Game Commission resolved to "vigorously oppose stream channelization"; Arkansas' Governor and Fish and Game Commission has expressed appropriate opposition to the channelization of the Cache River; Kentucky's Governor has promised an investigation of channelization in his opposition to it during electionssee attachments to record.

Lately it is becoming apparent that the SCS, in many cases, does not have the majority support of their constituents in their own watershed districts which they claim are promoting these projects. Near Bloomington, Ind., the Lost River-Springs Valley Conservancy District is being opposed by 3,000 landowners that eventually hope to abolish it; in southern Indiana landowners are attempting to sue the Indian Creek Conservancy District that is initiating programs contrary to the desires of the majority of landowners. In Ohio disenchanted farmers are rebelling after observing the Auglaize River channelization project; in the Pine Creek watershed in Ohio, landowners are literally up in arms over the SCS's plans to channelize 57.2 miles of streams in the watershed, and the State department of natural resources has again had to intercede.

To date, of the various Federal agencies responsible for stream channelization, neither the SCS nor the Army Corps of Engineers, nor the Bureau of Reclamation have bestirred themselves to substantially alter or cancel programs in the face of environmental concerns. The major justification remains economic feasibility, which in almost all cases is based on calculations of highly dubious validity.

The corps has revised its hearing procedure to allow for better public participation. It has not been determined what the effects of adverse public reaction will be on these programs. The corps has attempted at times to mitigate environmental damage and compromise.

Their enthusiasm to continue with the project, however, is directly proportional to the size of the project. In some cases they ally with the SCS in promoting a project-Mayfield Creek, Ky., for instance. At other times they assist environmental concerns as they have done lately in Cameron Creole, La. There have been some attempts to comply with the Fish and Wildlife Coordination Act, and the corps seems to make an extra effort to comply with the National Environmental Policy Act (NEPA) and alert the public to proposals.

The SCS continues to adamantly defend its channelization program regardless of size in the face of growing public opposition. Contrary to Administrator Grant's memorandums that the justification would not be agricultural production, economic benefits based on increased crop yields remain the major justification for existing programs although sometimes under the guise of flood control. There is a need, we think, to declare a moratorium on these projects. The SCS is attempting in some States and for the most part unsatisfactorily, to mitigate and compromise these programs, but the agency contends that it is not subject to the Fish and Wildlife Coordination Act and in our opinion largely ignores that act.

The SCS did review all its channelization programs and decide, contrary to NEPA, which projects they would reconsider and file impact statements on. They have issued several memoranda in this regard, all with appropriate loopholes, aimed at better environmental consideration of projects. This has been more or less a procedural effort and we see no real effort to reduce channelization programs.

The SCS has made some attempts at public education on channelization projects. These meetings are usually dominated by project beneficiaries and turn into shouting matches should there be disagreement with channelization. There is little public participation in SCS projects other than by those persons leading the local sponsoring organization.

If the agency responsible for stream channelization has not taken the appropriate initiative to discourage programs and forestall environmental damage, likewise neither have the Council on Environmental Quality (CEQ) nor the Environmental Protection Agency (EPA) asserted themselves. Nor has Congress really. Only the Department of Interior has taken a firm position discouraging channelization. Interior's recent guidelines for minimizing environmental damage from channelization is still the best document published by any agency.

CEQ prompted the A. D. Little study. The best information in this study was the contribution by the Philadelphia Academy of Natural Sciences which fielded the scientific investigative team. The academy team corroborated the claims of concerned citizen's groups on environmental damage taking place as a result of channelization. The A. D. Little analysis ignored many of these findings in the draft report. We are waiting the final report which we hope will be vastly improved.

The National Audubon Society is surveying State agencies regarding their views on mitigation procedures. So far all the States contacted have responded in the vein that, although some steps can be taken to minimize environmental damage, as reflected in Interior's report, there is really no way to mitigate the loss of a stream and its adjoining habitat.

Compliance with NEPA is largely procedural. Impact statements are defensive, and vague as to fish and wildlife damage. SCS statements emphasize agricultural land improvement and refuse to recognize the ecological and social value of flood plains. Often the project cannot be economically justified and we do have attachments to back these statements up.

Impact statements by the SCS are rare so far. We have had difficulty obtaining them in the beginning and work plans are difficult, if not impossible, to obtain from the SCS. On the other hand, the Corps of Engineers is filing statements-although inadequate and encourages their distribution.

The channelizing agencies do not take alternatives such as flood plain zoning seriously, they reply to comments made by other agencies and by citizens groups in such a way as to further justify the project. The problem exists because the very agency promoting a project becomes the final arbiter in reviewing it.

Lately, the SCS has responded to criticisms from citizens by saying the criticisms are reactionary and misleading. They emphasize that some streams they are ditching are intermittent or have been worked on before and ignore the fact that sometimes a watershed can restore itself if it is left alone. They intimate that because it has been tampered with before, it has not regained its value as a natural watershed with associated fish and wildlife values.

We continue to feel that Congress must direct and insure a realistic analysis of costs versus benefits, and also compliance with the Fish and Wildlife Coordination Act. There must be independent review by another agency of stream channelization projects (especially those of the SCS). We would like to submit additional testimony and material for the record on siltation, effects of channelization, public reaction, and on the Starkweather and Cameron Creole projects which will help to support our previous statements.

I have listed on the end of my statement here 22 exhibits which we feel will help the committee in understanding our concerns. This is with the exception now, I understand, of the exhibit 23 on Cameron Creole watershed project. I understand that we have previously submitted supplemental data, so that exhibit will not be included."

And at this time, Mr. Chairman, I would like to introduce two of my colleagues that have been working on channelization projects, the Starkweather watershed controversy, my counterpart, Mr. Ed Brigham.

Mr. REUSS. Welcome, Mr. Brigham.

Mr. FRANSON. Mr. John Spinks who has been working on the Cameron Creole project. These two gentlemen are here in the event you would like to direct any questions to them on these two projects. They have been working as regional representatives, particularly on these two projects.

Mr. REUSS. Welcome, Mr. Spinks. Thank you, Mr. Franson, and under the rules and without objection the additional exhibits to which you have referred are herewith made a part of the record.

[NOTE.-With the exception of exhibits 19, 21, and 22, which follow, and exhibit 17-"Effects of Stream Channeling on Wetlands in a Minnesota Watershed," by Jerry S. Choate-which is printed in app. 39, pp. 3619-3623, the data submitted by Mr. Franson are in the subcommittee files.]