tenance of the facilities, so they will not fall into disrepair in the future (ie, through rate structures that provide adequately for maintenance). The Secretary of the Army, acting through the Chief of Engineers, is designated to administer the grant program in Titles I-III. Given the wide range of eligible capital investment projects, which fall under the jurisdiction of the Environmental Protection Agency and the Department of Transportation, as well as Army Corps of Engineers, we suggest that perhaps a jointdirection by the heads of these three agencies (EPA, DOT, Army) be considered. The formula for allocation of grant funds is based 50 percent on population and 50 percent on highway mileage. Again, given the wide range of eligible projects, we question whether simply using highway mileage is an appropriate weighting factor. Finally, Section 105 of Title I states that all Federal agencies shall review, and where necessary, revise its rules and regulations to assure that, consistent with existing law, permits for repair and rehabilitation projects be acted upon expeditiously. EPC supports elimination of unnecessary delay only if the process complies with all requirements for permits required under various existing laws. Title VI, General Provisions, states in Section 606 (a) (7) (b) Nothing in this Act shall alter the EPC suggests that to this list of important environmentally protective legislation, the following laws be added: The Department of Transportation Act, the Coastal Zone Management Act, the National Historic Preservation Act and all titles of the Clean Water Act. A major concern of EPC is how the federal government will assure consistency in the application of environmental laws if each state is overseeing its own programs. Secondly, it is unclear to us who will actually be responsible for construction: the state, the federal government, etc.? Whose designs and plans will be used? Given the fiscal constraints facing state and local governments, do they have adequate staffing to carry out these new responsibilities and tasks? Finally, EPC is unclear as to who will be legally responsible for these new projects? We believe the legislation should address these important issues in more detail. Titles II and III of S. 274 (and similarly Titles IV and V which be commented upon separately) have the special objective of creating jobs in areas of high unemployment and low income. Like Title I, Titles II and III create jobs through federal grants for construction and repair of public investment projects under the direction of the Secretary of the Army. Title II provides federal grants for public capital investment projects to increase jobs and provide long term economic revitalization to states, local governments and Indian tribes of low-income and high unemployment compared to the national average. Title III provides funds for capital investment projects, at the onset of an economic recession to help offset its impacts. Title III establishes a counter cyclical Trust Fund of $2 billion (maximum), to which $200 million is transferred each year. EPC strongly supports the vital national need to reduce high levels of unemployment. We believe this can be achieved however, through the establishment of a public works program that brings special environmental benefits and energy conservation. H.R. 1727, introduced by Congressman Robert Edgar on March 1, 1983, is such a public works program and strongly supported by EPC and many other public interest organizations. The bill encompasses a wide range of public works projects that would benefit our national parks, forests and other public lands, historic neighborhoods, cities and towns, rail passenger and mass transit systems and energy conservation. The projects would provide economic stimulus and job creation in all states, territories and geographic regions. Moreover, these projects would employ many of the same types of workers and industries employed by presently funded public works projects, but would have the added benefit of enhancing the environment. For example, jobs would be provided for repair and rehabilitation of lands and facilities of the National Park system, National Wildlife Refuge system and National Forests, directed to the millions of dollars of backlogged projects in these areas. Jobs would be provided for preservation, interpretation and development of urban resources of cultural, architectural and historic significance. Jobs would be pro vided for rehabilitation and repair of essential railbeds and development of light rail systems in cities deemed appropriate by the Urban Mass Transportation Administration. And jobs would be provided for an expanded weatherization program and for energy conservation activities. A more detailed description of H.R. 1727 is provided in Attachment 3. Jobs of this nature are labor intensive, creating numerous jobs per dollar invested, could be implemented quickly and address important national public works needs in a manner that enhances the environment. We urge the Committee to consider such a public works program for job creation and needed repair work. Titles IV and V of S. 274 create similar types of jobs to some of those mentioned above. Title IV provides $500 million for jobs to rehabilitate historic buildings, districts, objects and sites. Funds will be distributed to provide benefits to all states. An additional $25 million is targetted to non profit neighborhood organizations for housing and community development projects. EPC strongly supports such federal investments which generate jobs for needed repair of our nation's historic heritage. The jobs created are labor-intensive, can proceed immediately and, in many cases, be carried out yearround. Title V provides jobs for youth employment through a community conservation and improvement program and a young adult conservation corps. The jobs created would involve rehabilitation and improvement of public facilities, renovation of urban parks, weatherization of low income and elderly housing, energy conservation and solar techniques and maintenance and restoration of natural resources on publicly held lands. Jobs involving the Corps would entail tree planting, wildlife habitat improvements and preservation, road trail maintenance and many other improvements. Again, such jobs address important national needs, are labor intensive, creating numerous jobs per dollar invested and can be created quickly. EPC strongly supports investment in jobs in these areas. We support the American Conservation Corps legislation which has been passed by the House twice and we urge similar action in the Senate. Moreover, the type of jobs created are those we also support in HR 1727. S. 23, introduced by Senator Moynihan and co-sponsored by Senators Hart, Cranston and Bradley, calls for a national |