Senator HASKELL. If we have any further questions on the amendments, we will be in touch with you. Thank you.

The next witness is Mr. Robert Riley of the American Institute of Architects.

Mr. Riley, I might make the same suggestion to you that I did with others, if you could summarize your statement it would be particularly helpful.

STATEMENT OF ROBERT B. RILEY, MEMBER, REGIONAL DEVELOP. MENT AND NATURAL RESOURCES COMMITTEE OF THE AMERICAN INSTITUTE OF ARCHITECTS; ACCOMPANIED BY JOHN GAILLARD, DIRECTOR OF HOUSING AND URBAN PROGRAMS

Mr. RILEY. My name is Robert Riley, a member of the Regional Development and Natural Resources Committee of the American Institute of Architects. Accompanying me today is John Gaillard, the institute's director of housing and urban programs.

Today, the American Institute of Architects, the national society for the architectural profession, wishes to express its views on the need for sound management and planning of the natural resource lands, with special emphasis on S. 507 and S. 1292, proposals for a National Resource Lands Management Act.

The AIA has developed a policy statement on the National Resource Lands. I request that this be entered in the hearing record as part of our full statement. I will not take your time by reading it now, but would like to summarize, briefly, some of the points we consider most important.

We believe that Congress should clearly affirm Federal intent to keep the bulk of these lands in public ownership, affirming thereby what has in fact been the policy of the last several decades, but not the letter of the existing but ancient legislation. We also feel that such a policy must be supplemented by a process of acquisition, trade, interagency transfer, and disposal aimed at getting land under the management most appropriate to its use.

Once such long-term Federal control has been affirmed, there is immediate need for three steps: (1) clear definition of the goals and policy of BLM land management, including careful distinction between such goals and policies and those more appropriate to other Federal agencies and to the private sector; (2) a comprehensive inventory of the capability and suitability of all Federal and certain relevant private lands in relation to those goals; and (3) a comprehensive land use plan for the public lands to achieve those goals.

When, but not until, those steps have been achieved, the necessary acquisition, transfer, and disposal process should begin. In general, we feel that where there is any doubt as to land use or suitability, land must remain in public ownership; in general, we feel that exchange is preferable to sale. Acquisition, transfer, or disposal must aim at assembling workable and identifiable packages of land and at ending the decades-long "picking over" process which has left the Federal Government with the lands no one wanted, and a crazy quilted, unmanageable intermingling of holdings. Mineral rights should be retained by the public and, since lands would be disposed of only in relation to a long-range land use plan, controls

should insure that land released for a specific purpose be developed only for that purpose. In any case, public land should be disposed of only upon clear demonstration that the larger public interest is better served by private ownership of a particular piece of land.

Policy and plans should clearly establish the priority of public use over private use; the priority of long run, truly sustained yield over short run uses responding to quickened cycles of market changes; and the priority, in general, of multiple-use over single- or dominantuse concepts. Single- or dominant-use management should be used to protect critical or unique values or resources, but not to minimize economic return nor to simplify decision making or management.

The BLM should be given the power to classify lands for specific uses rather than having to rely upon withdrawal, the power of policing all lands under its authority, and the power to institute and enforce controls over lands released to private ownership.

BLM lands should be included under the Wilderness Act. Wilderness establishment and maintenance should be consistent across all Federal lands and subject to the will and scrutiny of Congress, not dependent upon the changing policies and personnel of administrative agencies.

Legislation and management programs should clearly spell out the goal of protecting and promoting overall environmental quality on the public lands. This includes not only the maintenance of physical productivity but the preservation and enhancement of visual, social, historical, and cultural values as well. Control programs should protect and enhance the entire range of socially desirable assets and resources, and not concentrate only on "uniqueness" or "irreplaceable resources."

On the question of mining and mineral extractions, we believe strongly that the Mining Act of 1872 must be repealed and replaced by legislation which recognizes the needs and life of this country in the 20th century.

Senator HASKELL. I believe the administration sent up a bill to change the 1872 law and I think Senator Metcalf has some amendments to that. That is the place to address that question.

Mr. RILEY. We realize that such legislation might best be treated separately from a BLM Organic Act, but we wish to emphasize its importance. We believe that any legislation in this area, however, must aim at three goals. First is clear recognition that mining or energy development is only one land use to be balanced against others on the merits of each proposal and each land unit: automatic priority of mineral or energy development over any other use, whether explicit in law or implied in policy, is unwise and unacceptable. Second, all mineral leasing legislation should provide for strict and specific environmental quality standards, including air quality, water quality, and land use. Lastly, legislation and enforcement should insure that land patented for mining is not used for other purposes, and that where public mineral rights are relinquished, because of conflict with other uses, such rights are not subsequently used for private profit.

Some of these proposals will be opposed on the grounds that they will restrict the production or raise the cost of energy and food, or that they will bankrupt small ranching as a business and a way of life, claims which might seem understandable and persuasive. We believe that there are two compelling answers to most such arguments:

first, that even should these proposals result in small increases of food and energy costs to the public-an argument that at any rate should be examined case by case-the public is now paying such costs anyway, through the gave away of public resources at less than market value. Secondly, that the problem of short-term economic costs or inequities should be solved by other short-term, flexible, and reversible economic measures, including direct subsidies where required, and not by permitting or encouraging the accelerated, irreversible wasting away of our irreplaceable land resources.

We believe that enactment of either S. 507 or S. 1292 would be a much-needed first step in achieving these goals. Both affirm a policy of keeping the bulk of the national resource lands in Federal ownership. They would at last give the Bureau of Land Management the basic statutory powers needed for administering its lands and enforcing its regulations. They would repeal many of the long obsolete laws which now apply to the natural resource lands. They call for a land inventory and land planning effort for use of these lands. They formalize the goals of multiple use and sustained yield; they call for protection of overall environmental quality, including not only irreplaceable physical and biological resources, but scientific, scenic, and historic values; and air and water resources. They require land reclamation as a condition of use; they allow for necessary rights-of-way, but require their consolidation where feasible. They set out mechanisms for sale, acquisition and exchange, with both public safeguards and administrative flexibility.

We consider both S. 507 and S. 1292 to be incomplete in some important respects. While both proposals require identification of potential wilderness areas and require subsequent review of such areas for inclusion under the Wilderness Act of 1964, neither of the bills seems to insure protection of such areas. Many of such lands could have had their irreplaceable characteristics irretrievably damaged before protection is established.

The proposed legislation does little to address the environmental problems caused by the Mining Act of 1872. We believe that repeal of that act and its replacement by modern legislation which calls for environmental controls and reclamation and for balanced review of use priorities instead of an automatic priority for mining, is essential for safeguarding the public lands of this country for future generations. This problem might indeed be best handled by separate legislation, but we wish to emphasize its importance.

We have one other major reservation, one which stems more from the political and environmental context within which any legislation will be enacted than from the specifics of either S. 507 or S. 1292. The national resource lands, as they exist today, are in fact the public lands which have not been set aside for specific uses, or defined as having specific characteristics, which properly place them under the administration of other Federal bodies such as the Forest Service or National Park Service. Both S. 507 and S. 1292 reaffirm the principle of managing these lands for multiple use and sustained long-term vield.

We believe that this philosophy is both wise and necessary, and that it must be maintained in practice as well as in theory. We have some misgivings over what appears to be the dual charge of the Bureau of Land Management-that of encouraging multiple use on he one hand, and developing mineral and energy resources on the

other hand. Our fear is that current demands for the development of energy resources might well override concerns for the long-term preservation of other values. We also feel that in the required inventory of national resource lands, high priority should be given to the identification of those lands of special environmental values which might better be administered by other special-purpose Federal agencies. Such lands should then be transferred to the jurisdiction of the appropriate agencies.

We believe that S. 507 is the more comprehensive of the two bills now before this committee.

Senator HASKELL. If I may interrupt, Mr. Riley, it seems to me that other people are suggesting separating out management for energy purposes, or any kind of developmental purposes, as opposed to other uses. But it seems that it is all the same land. I don't know how you divide it up.

Mr. RILEY. It is the same land, indeed, sir, and if you ask me for solutions and recommendations, I would have a hard time making them. I could see the problem clearly. I would say that one answer to the possibility is a very careful look-I think there are three types of land involved. Land whose capabilities and resources do give it a specific character that now may more strictly belong to other agencies and mineral development lands. I think the BLM holdings should be carefully inventoried for transfer to other special agencies, such as the Forest Service. I don't know the administrative complications of setting out the two categories of land. I think the request, for example, that BLM holdings be subdivided into named units, which I believe has been suggested by some groups, might be a step in that direction.

Senator HASKELL. I see. Fine.

Mr. RILEY. Some of the aspects of 507 which make us prefer it are the power of revocation or suspension of application for use or occupancy. While we are not happy with the wilderness provision in either bill, we prefer those in 507 which sets time limits for both the identification and review for inclusion in the wilderness section. One thing that we find quite objectionable in S. 1292 is the provision that the entire inventory of wilderness areas be limited to those including 50,000 contiguous, roadless acres. I would say cost is certainly a factor in evaluating wilderness lands, but restricting it to areas greater than 80 square miles could in fact lose some precious and irreplaceable land.

I don't need to impress the committee with the need for legislation in this area.

I would like to say in closing that continued recreation pressures and particularly continued pressures for energy development make me think the timing is critical. We surely hope that something can come out of this session of the Congress.

Thank you.

Senator HASKELL. I certainly hope so. Thank you Mr. Riley very much for appearing.

The next witness, Mr. Edwards, submitted his testimony for the record.

[The prepared statements of Mr. Riley and Mr. Edwards follow:]