to meet the next loan payment who overstocks. Raising grazing permits in sec. 15 leases is liable to have about the same result as rising taxes have on farming operations throughout the nation; intensification of use leading eventually to disposal. I have no doubt that an organic act, written and slanted as this proposed legislation, and that of the administration, are written and slanted, would have the effect of accelerating the takeover of the West by speculators and big corporations, and hasten the demise of independent ranching operations. I would urge the committee, if it is intent on raising leases and permits to exempt at least the first several hundred animal units per

owner.

We are opposed to any granting of powers of eminent domain to the Bureau of Land Management, not only for condemnation of tracts of land but for condemnation of rights of way. The massive misuse and abuse of eminent domain power by the Bureau of Reclamation, and by numerous other Federal agencies, have convinced us that such powers must be limited rather than increased. As far as road corridors are concerned, there are already far, far too many roads in the West, without providing the BLM a pretext to construct

more.

The misuse and abuse of eminent domain power by the Bureau of Reclamation, and by numerous other Federal agencies, have convinced us that such power must be limited, rather than increased. As far as road corridors are concerned, there are already far far too many roads in the West, without providing the BLM a pretext to construct more. The prospect of the BLM using such powers to force roads through Indian lands in Alaska, claiming such routes represented the only feasible access to lands which they administer cannot be discounted.

I will not take up the committee's time in belaboring those areas where our views are identical to those of the spectrum of fellow conservation organizations. We feel that it is most important that all areas of more than 5,000 contiguous acres be reviewed for inclusion in the national wilderness preservation system, and that protection should be afforded these lands during the review period to prevent destruction which might affect their status.

We believe that not only California desert lands, but all desert lands should be included under a special desert lands section. We agree with our colleagues in other propositions they have endorsed.

We believe most of all, that the committee should not plunge into any legislation until it is quite sure that it undertsands all of the implications. The conservation movement, which though it understood all it needed to understand, is beginning to perceive that it has become entrapped by earlier rhetoric. There is occuring now a period of reassessment and realinement among all of the people affected by this issue. While we may become impatient over a protracted gestation period, I believe that it is better to spend additional time in analysis than to let the internal impetus attaching to this act carry us blindly on to a new disaster in public land policy.

The key question is: Should that agency charged with management of living resources on public lands be entirely separate from that engaging in other administrative functions. I am increasingly convinced that it should.

Thank you, sir.

Senator HASKELL. How would you separate out public lands where oil and gas is to be sought from public lands that are to be used for other purposes? What is your organizational concept?

Mr. GARRETT. Mr. Haskell, it is really a forming concept. Because we have been so concerned about the permit that the BLM is showing and I must say that I agree with George, Mr. Alderson, that there is a distinct energy bias emerging inside the BLM. It seems to me the initial bifurcation has never healed over the merging of the general land offices and the grazing service. It might be best to leave the management of grazing and the management of the wagon road lands. and the California and Oregon railroad grant lands and other timber and wildlife resources that exist on BLM lands, better to leave those to one completely separate agency as the grazing service was once, and let another separate agency handle mineral leasing and the oil and gas leasing and that sort of thing, so one fraction would not come to predominate another. So the people who are entrusted with looking after living resources can devote their full attentions to living resources and get in there and lobby for their point of view, rather than being overridden by a commissioner or an assistant secretary who has voted to exploit energy sources and that sort of thing. That is, of course, what we have now.

Senator HASKELL. I see your viewpoint but I don't know whether I agree with it or not. It is a difficult administrative problem. I appreciate your coming here. Thank you very much.

[Subsequent to the hearings Mr. Garrett supplied the following:] I should like to talk first about grazing. There is no doubt that overgrazing is occurring on public lands, and that this has led to vegetational changes, favoring brush over grasses and forbes, and hastened the invasion of undesirable exotics such as cheat grass and halogeten. There is no doubt that overgrazing can produce irrevocable damage. Francois Bourierre, the French mammogologist, once aptly remarked that the Near East nomod, with his flocks, was far less a son of the desert than his father.

On Iceland, which I visited last summer, the introduction of sheep in the 15th Century has resulted in the almost total deforestation of the island, which was once 80% clothed in scrub birch. According to Dr. Bjarnson, the island's chief forester, Iceland has lost half its topsoil through wind and water erosion caused by improper grazing. I observed erosion continuing on steep slopes, and dust blowing against the backdrop of the central glaciers.

In New Mexico, the Rio Puerco River Basin has changed from a thriving agricultural area a century ago to a virtual desert because of riparian erosion brought about by overgrazing. The deepening of the stream channel, which in places now reaches 40 feet, has drained aquifers, and critically lowered the water table of the valley floor. The same thing has happened, and is happening, elsewhere in the Southwest and to a lesser extent further north.

Overgrazing, rather than climatic change, was the real cause of the disaster in the Sahel, as evidenced by the presence of various fenced enclaves which have remained productive in the midst of almost lunar desolation. One fenced 250,000 acre ranch in western Niger had, as of May, 1974, retained an evidently sustainable carrying capacity of about one cow per 25 acres, which is just as good as Eastern Montana though the surrounding region had been abandoned by the nomads and appeared totally devastated.

However, before becoming too enthused by evidence of the success of modern range management, I think it best to point out that modern technology in fact caused the disaster.

The period of intense overgrazing which destroyed the carrying capacity of the region was a function of a sudden explosion in livestock numbers. In Mali,

for example, the number of cattle increased from six to eleven million in five years. The population explosion of domestic herbivores was made possible by the drilling of hundreds of deep wells through the Sahel, permitting the nomads to intensely utilize areas which were unavailable to them for grazing during dry periods as long as they were dependent on natural sources of water.

If the major natural check on overgrazing had not been eliminated, the initial expansion of herds could not have occured. With the advent of drought, and the disappearance of surface water, large areas of the Sahel would simply have had to have been vacated by the nomads with their flocks for the duration of the dry period, and the calamity could not have occurred.

The United Nations agencies, UNESCO and the others, by the way, who drilled the wells, were searching for a technological solution to mitigate social problems which they had previously helped create themselves by promoting commercial over subsistance agriculture. The nomads were becoming restive over the usurpation of much of their best range in the southern Sahel for peanut and cotton farming. This was undertaken in party by agribusiness interests, tenderly encouraged by the food and agricultural organization.

I guess the point I am striving here to illustrate, is that we must be chary of technological panaceas to social and economic problems. It is always comforting to swallow a technological nostrum. While various range improvement techniques are clearly valuable in mitigating the effects of overgrazing, this is not where the solution is to be found. The only long term solution of overgrazing is a limitation of livestock numbers.

There are several things about overgrazing which I think alot of people overlook. One thing is that overgrazing in our country is an overfunction of financial instability. I have noticed that the long established incumbent families who have had time to adapt to the land, who maintained stable financial operations for a long time, are not likely to overgraze. Some of the best preserved land I have seen anywhere, including parks, is on privately owned land held by the old families.

On the other hand, if the bank is breathing down a rancher's neck for its interest on his loan, while taxes and expenses are rising and livestock prices are falling, he is liable to abuse the land as an alternative to immediate financial collapse.

Now, the fact is that in the states of Wyoming and Montana particularly, the public interest lands are arranged in a checkerboard pattern with private land. It is rarely feasible to fence off such lands and manage them separately. This means that management of privately owned rangeland inevitably spills over onto public land. It also means, if the relationship which I have suggested between financial stability and grazing practices is valid, any person interested in public lands has some stake in stability of western ranching and farming operations.

I believe that the stake is far greater however, than this. The success which the conservation movement has had in the past few years in brunting the invasion of the West by multinational oil and mining corporations has been dependent on the stubborn resistance of western landowners, and on the development of a close alliance between these landowners and the national conservation movement.

If it is not possible for livestock raisers to make a living because of depressed prices, it does precious little good to protect them from condemnation at the hands of strip-miners, as was painfully accomplished in the strip mining bill.

Now this is one reason why we support your attempt to attach the grazing fees to the market conditions. I think that is a very laudable section of your bill, one that we can wholeheartedly support.

Senator HASKELL. Our next witness is Mr. Doug MacCleery of the National Forest Products Association.

If possible, if you could possibly summarize your statement in view of the fact I know we are going to have a lot of votes this afternoon and we have other witnesses, I will include your entire statement in the record.

Mr. MACCLEERY. Very well. I will do that.

STATEMENT OF DOUG MacCLEERY, FORESTER, NATIONAL FOREST PRODUCTS ASSOCIATION; ACCOMPANIED BY JOHN F. HALL, VICE PRESIDENT FOR FORESTRY AFFAIRS

I am Douglas W. MacCleery, a forester for the National Forest Products Association, headquartered in Washington, D.C. Appearing with me today is John F. Hall, vice president for forestry affairs. We appreciate this opportunity to appear before you to give testimony on S. 507, the National Resource Lands Management Act of 1975. NFPA is a federation of 26 regional and wood products associations representing the growers, manufacturers, and wholesalers of wood products throughout the country.

Our industry is vitally concerned with timber management on all of our Nation's commercial forest lands. We are as concerned about achieving constructive public policies and programs affecting timber growth and harvest on Federal lands as we are on lands owned by the forest industry or on nonindustrial private lands. The forest products industry supports legislation which would enable productive management of federally owned commercial forest lands.

The Bureau of Land Management has long been in need of legislation clearly defining its mission. It is the only major Federal land management agency without such basic authority. We believe that S. 507, with appropriate amendment, could provide the congressional direction needed for management of lands currently administered by BLM.

However, we have several major areas of concern about the bill as presently drafted. For each of these areas of concern we have offered suggested amendments, which are included at the end of my written testimony.

Senator HASKELL. I noticed that. They will be included in the hearing record.

Mr. MACCLEERY. On the subject of reclamation, section 101 (2), authorizes the Secretary to require land reclamation as a condition of use for those engaged in "extractive or other" activities likely to cause significant disturbance or alteration of land. The language is not clear that this is intended to apply to land disturbing activities, such as strip mining. Timber harvest activities are not extractive because they are followed promptly by reforestation and forest renewal. This reforestation has historically been the responsibility of the forest landowner.

It is our understanding that the intention here is primarily to exercise authority over major extractions of nonrenewable resources. That being the case, section 101 (2) should be amended so that it applies solely to extraction activities, not to timber harvest. Section 101 (3) would authorize revocation or suspension of any permit, license, lease, or other authorization for a violation of any agency regulation promulgated under the act, or of any State or Federal air or water quality standard or implementation plan. This provision would inject extreme uncertainty into the continuance of federally granted permits. The revision of air and water quality stand

ards after the permit had been granted would subject the instrument to revocation upon finding of a violation of the new standard. Section 101 (3) was written due to the legitimate concern that permits issued by the Federal Government comply with appropriate environmental standards. However, existing laws already provide penalties for noncompliance with applicable State air and water quality laws that should be adequate to insure that environmental standards are met.

Section 101 (3), as presently worded, would authorize revocation. of permits and similar instruments upon the finding of even a minor violation of air and water quality standards. For instance, a power line right-of-way granted to a utility might be put in jeopardy upon finding that some of the emission control devices on motor vehicles owned by the utility were not operating properly. In addition, a violation by the permittee in another region unrelated to the permit could, under the present wording, subject the permit to possible revocation. This is clearly undesirable. We recommend major modifications to this and call your attention to suggested modifications, which are in my statement.

We have similar objections to section 103 (d). This section would subject permits, leases, and licenses to modification due to changes. in land classification. Here again a permitee has a right to expect that the conditions under which his permit was granted will remain in effect until the established renewal date, or at the very least, that he should be adequately compensated for economic loss resulting from any modification of the permit arising from a unilateral revision of the existing land classification by the Secretary.

While giving cursory recognition to land exchanges in sections 207 and 213, title II does not give the attention to the land exchange program which we believe is needed. Land exchanges are treated only as a method of adding lands to the public domain, but not as an appropriate method of developing more efficient management of existing public ownership. Full authority should be explicitly provided which would allow the exchange of lands or interests free from onerous conditions such as the strict land disposal criteria established under section 202. BLM administrators should be allowed flexibility needed to exchange lands for purposes advantageous to the public, such as the consolidation of ownership and simplification of land management. Such flexibility under S. 507 is very restricted. I have attached some suggested amendments which would allow greater flexibility in this regard.

In regard to conveyance of mineral interests, section 208 (a) allows the Secretary to convey mineral interests owned by the United States where the surface is in non-Federal ownership if he finds that there are no mineral values in the land, or that the reservation of the mineral rights of the United States is interfering with the appropriate nonmineral development of the land, and that such development is more a beneficial use of the land than mineral development. A new subsection should be added to this subsection which allows the Secretary to convey mineral interests owned by the United States where the surface is in non-Federal ownership, if he