[The following information was subsequently received for the rec

ord:]

EXECUTIVE OFFICE OF THE PRESIDENT,
COUNCIL ON ENVIRONMENTAL QUALITY,
Washington, D.C., April 2, 1973.

Hon. ERNEST F. HOLLINGS,
U.S. Senate,

Washington, D.C.

DEAR SENATOR HOLLINGS: In my testimony before your committee on March 6, 1973 concerning S. 80, I promised to provide, for the record, an analysis of the relationship of tanker casualties in U.S. waters and of U.S. flag tanker casualties to the worldwide analysis. The worldwide analysis served as the basis from which the Coast Guard projected the frequency and magnitude of tanker oil spills. As you will recall, Senator Stevens expressed his belief that the worldwide analysis was a "worst case" approach and that an examination limited to the U.S. experience would produce a better methodology.

Coast Guard analyses demonstrate that, based on the proportion of the world volume of oil carried in U.S. waters, the frequency of tanker casualties is somewhat less than proportional, but the amount of oil spilled in U.S. waters is slighty greater. The following outline compares the pertinent figures on casualties and oil pollution in U.S. waters versus worldwide:

1. 23.5% of the total world volume of oil carriage occurred in U.S.

coastal waters.

2. 18.5% of the worldwide tanker casualties in 1969–70 occurred in U.S.

coastal waters.

3. 18.8% of these worldwide casualties resulted in oil polluting incidents. 18% of these pollution incidents occurred in U.S. coastal waters.

4. 24.9% of the total oil spilled from these polluting incidents occurred in U.S. coastal waters, (excluding catastrophic incidents from the totals, 32% of the oil spilled worldwide occurred in U.S. coastal waters). The experience with U.S. flag tankers is roughly proportional. These tankers make up 9.2% of the world fleet and they represented 10% of the worldwide casualties in 1969-70 and 8.2% of the polluting incidents.

I hope this information will be helpful to you. Please let me know if you need anything further on this matter.

Sincerely,

RUSSELL E. TRAIN,

Chairman.

Senator HOLLINGS. Is it convenient for Mr. Robert Hallman and Mr. Greenberg to testify at this particular time?

Mr. HALLMAN. Yes, it is.

Senator HOLLINGS. All right.

STATEMENTS OF ROBERT M. HALLMAN, ELDON V. C. GREENBERG, AND PETER BORELLI ON BEHALF OF THE SIERRA CLUB, ENVIRONMENTAL DEFENSE FUND, NATURAL RESOURCES DEFENSE COUNCIL, NATIONAL PARKS AND CONSERVATION ASSOCIATION, ENVIRONMENTAL POLICY CENTER, AND FRIENDS OF THE EARTH Mr. HALLMAN. Senator Hollings and other members of the committee, I am Robert Hallman. With me are Eldon V. C. Greenberg and Peter Borelli. Mr. Greenberg and I are staff members of the center for law and social policy and are here on behalf of six environmental organizations to present their views on S. 80 and the important issues of national energy and environmental policy which it

raises.

The groups that we represent are as follows: The Sierra Club, the Environmental Defense Fund, Natural Resources Defense Council, National Parks and Conservation Association, Environmental Policy Center and Friends of the Earth. With the exception of the Environmental Policy Center, all of these organizations are nonprofit membership groups with a total membership of a little more than 250,000 people. They have a long history of active concern about and taking action with respect to protecting and preserving the marine and coastal environments and they are vitally concerned about the issues of deepwater port development to which S. 80 is addressed.

We have submitted to the committee a 29-page statement. Rather than read it, we would prefer to have it printed in the record and to summarize our positions and then stand available for questions.

Senator HOLLINGS. The statement will be printed in its entirety. Mr. HALLMAN. Our written and oral testimony will focus on the application of S. 80 to deepwater port development, although the bill does cover other offshore, artificial structures, because we understand this is an important object of the bill and a major concern of this committee.

I will outline briefly the problems posed by deepwater port development as we see them and then outline some general principles that we believe ought to be reflected in any national deepwater port policy if we decide one is appropriate to develop, and Mr. Greenberg will summarize our specific comments on S. 80. We have both some supporting statements and some suggestions for improvements regarding the bill and Mr. Greenberg will outline those.

Senator Hollings, we believe that deepwater port development poses some very troublesome, complex, and fundamental issues relating to energy policy, environmental policy, and land use policy, which we simply do not have an adequate information base or institutional capacity presently to resolve.

In addition, proposals to develop deepwater ports raise and confront substantial institutional problems of overlapping jurisdictions which ought to be sorted out in an intelligent manner before committing definitely to a deepwater port project or a deepwater port policy.

As I am sure you are well aware, any proposal for a deepwater port raises fundamentally three basic issues-issues which we believe are far from resolved at present. The first issue, which relates to energy policy problems is whether this country really needs the amount of energy resources which are projected in some quarters, and particularly needs such energy in the form of imported fossil fuel. The answers to that question vary quite significantly, depending on the energy policy assumptions which underlie the projections.

The second issue is: Assuming that we are going to have a significant increase in petroleum imports, are deepwater ports an economically justifiable method for receiving those imports into the United States?

The third issue is: Assuming the deepwater ports are economically justifiable, are deepwater ports environmentally acceptable, particularly in view of present and reasonably foreseeable alternatives for providing us with the imported fossil fuel?