to the President and the Congress on the progress of private and governmental programs in achieving these objectives. In his message the President outlined the federal activities that are to be moved into the newly established NOAA. We have noted and support the President's directive that the new agency be funded at the existing level of appropriations for these several components. When reorganization has been effected, we feel it important that NOAA immediately give attention to implementing other recommendations of the Stratton Commission. We are concerned that this reorganization not only be an organizational revision, but that it prove to be a new impetus in formulating a sound national oceans policy. No one needs reminding of the critical importance of the potential for food and mineral resources that the ocean holds out to our nation and the world. To assist in the effective development of these resources the NAM urges NOAA to establish a more progressive national fisheries policy to advance the harvesting and utilization of the living resources in the sea. We hope NOAA will endeavor to resolve jurisdictional differences among the states and between the states and the federal government and to foster international treaties and commissions which deal with conservation of resources and the law of the seas. NOAA should work to have the United States promptly and forthrightly assert the exclusive jurisdiction of the United States over the mineral resources of the entire submerged portion of the continent from our nation's shores seaward of state-owned offshore areas down to its junction with the abyssal floor. We look to NOAA to assist in refining and improving existing local systems, government boundaries, conflicting uses and protection of the environmental quality of the oceans. We suggest that our nation already has a proven workable body of mining claim laws which can be applied to submerged lands within national boundaries. The NAM believes implementing these recommendations is essential before the United States can consider any international regime to govern exploration and development of the deep sea ocean floor. In conclusion we want to re-emphasize that proper ocean resources development will become increasingly vital to our country's economy and security. Again, we feel that industry has proven itself in this area and should be encouraged to continue and accelerate its activities. We appreciate this opportunity to submit our views to the Subcommittee on Executive Reorganization of the Senate Committee on Government Operations. POSITION OF NATIONAL ASSOCIATION OF MANUFACTURERS ON "OCEAN RESOURCE DEVELOPMENT" Utilization of the oceans' resources offers increasing scientific, military and commercial values. Basic responsibilities in this area should continue to be shared by government and private groups. Industry has devoted considerable time and expense to obtain knowledge of these resources and to develop methods for finding and recovering them and making them available to the channels of commerce. Primary responsibility for further development of these resources in the oceans, and on or under the continental shelf should continue to reside in the private area. It is the government's responsibility to develop an orderly national and international legal framework which is required for continued progress. Research efforts that relate to national defense, weather forecasting, and the gathering and dissemination of basic information concerning the oceans are primarily federal responsibilities. A further responsibility is the extension of the present reconnaissance and mapping of the United States to include the continental shelf. In addition, basic engineering data of a non-proprietary nature may need to be developed by federal agencies, and wherever practicable such work should be performed by private industry under contract from the government. The application of the above knowledge and the actual development of resources should, and will, be pursued by private industry, facilitated and encouraged by government. The United States should adopt a progressive national fisheries policy which will advance the harvesting and utilization of the living resources of the sea. This national policy should endeavor to mitigate those jurisdictional differences among the several states and between the states and the federal government and should embrace and foster those international treaties and commissions dealing with conservation of resources and the law of the seas. The United States is urged to assert promptly and forthrightly its exclusive jurisdiction over the mineral resources of the entire submerged portion of the continent off its shores seaward of state-owned offshore areas down to its junction with the abyssal ocean floor. The United States should work with other nations toward the ultimate objective of precise demarcation of the boundaries of coastal nations' natural resources jurisdiction. There is an inadequacy of knowledge about the natural resources and environment of the deep-ocean floor and the technology of exploration and exploitation. Much more information and data will be required before realistic arrangements can be concluded for the promotion of long-range development. Present consideration regarding legal arrangements for deep-ocean areas should be focused on the formulation of standards of conduct, including the protection of proprietary technology, of individual nations and persons engaging in activity pursuant to existing law in order to encourage orderly recovery of resources. A step which might follow would be the establishment of an international registry, to serve as a public record of exploratory activity. It is premature to move toward the establishment of an international agency with licensing authority. It would be highly undesirable and indeed irresponsible for the United States to commit itself now to any international regime to govern exploration and exploitation in these areas; however, activities among nations to explore deep-ocean areas should be encouraged by such international cooperation as that conceived in the International Decade of Ocean Exploration. As a step prior to solution of international problems, it is urged that the United States improve and refine existing legal systems for the exploration, exploitation and protection of natural resources within the national jurisdiction, including such matters as fixing boundary lines, accommodation of conflicting uses and environmental quality. In this connection the United States has a proven workable body of mining claim laws and unless clear reason is shown to the contrary these tested principles should apply to the submerged lands within national jurisdiction. The National Association of Manufacturers supports the creation of a National Advisory Committee for the Oceans. This committee should be composed of individuals from outside the federal government, broadly representative of the states, industry, science, and other appropriate areas. It should provide continuing guidance for a national program for development of ocean resources, and report to the President and the Congress on the progress of private and governmental programs in achieving the objectives of the national program. The National Association of Manufacturers supports the creation of a new independent agency, reporting directly to the President, to administer and execute federal ocean resources programs, allocate priorities and responsibilities, eliminate duplications and conflicts, and serve as a focal point for industrygovernment relations in this field. It should not function so as to proliferate government programs and expand government expenditures. Both the Senate and the House of Representatives should establish ocean resources committees to oversee the operations of this agency. EXHIBIT 26 STATE OF MICHIGAN, Hon. JOHN L. MCCLELLAN, DEPARTMENT OF NATURAL RESOURCES Chairman, Committee on Government Operations, DEAR SENATOR MCCLLEAN: I am writing to you in behalf of the Association of Midwest Fish and Game Commissioners which includes the States of Colorado, Illinois, Indiana, Iowa, Kansas, Kentucky, Michigan, Minnesota, Missouri, Nebraska, North Dakota, Ohio, South Dakota, and Wisconsin. Our Association has carefully reviewed House Documents 91-365 and 91-366 which relate to the administration's Reorganization Plan No. 4 which was sub mitted to the Congress by the President on July 9, 1970. We are strongly opposed to this reorganizational plan which would transfer the Bureau of Commercial Fisheries to a new National Oceanic and Atmospheric Administration in the Department of Commerce. We favor creating a broad scope Department of Natural Resources rather than to take the backward step of returning the Bureau of Commercial Fisheries to the Department of Commerce. I am enclosing a copy of a resolution which was adopted by our association while meeting in Winnipeg, Manitoba, on August 1, 1970. We strongly urge the Congress to take immediate action rejecting Reorganization Plan No. 4. We would also welcome an opportunity to present additional testimony from our member States if this matter is further considered by your committee. Sincerely, A. GENE GAZLAY, Assistant Director. RESOLUTION No. 7. REORGANIZATION PLAN No. 4.-U.S. GOVERNMENT Whereas, the Administration's Reorganization Plan No. 4 would transfer the Bureau of Commercial Fisheries and the marine game fish research program of the Bureau of Sport Fisheries and Wildlife to the Department of Commerce; and Whereas, it also is proposed that the oceanic portion of the anadromous fisheries program be transferred to the Department of Commerce; and Whereas, the reproductive success or failure of these anadromous fish will be determined within inland waters and within estuaries; and Whereas, the Department of Commerce is an agency having limited biological research capability; and Whereas, it is the opinion of the Association of Midwest Fish and Game Commissioners that it would be preferable to establish a broad scope department which would include the present Department of the Interior as its nucleus; Now, therefore, be it resolved that the Association of Midwest Fish and Game Commissioners, assembled at their 37th Annual Meeting this first day of August, 1970, at the International Inn in Winnipeg, Manitabo, Canada, opposes Reorganization Plan No. 4 and urges the Congress to reject this reorganization proposal; and Be it further resolved that the President be urged to establish a Department of Natural Resources which would include the U.S. Forest Service, U.S. Soil Conservation Service and the civil functions of the U.S. Army Corps of Engineers, in addition to the Department of the Interior bureaus. EXHIBIT 27 Hon. JOHN L. MCCLELLAN, THE AMERICAN PAPER INSTITUTE, Chairman, Senate Government Operations Committee, MY DEAR SENator McClelLAN: The American Paper Institute, which represents some 200 member companies, comprising 90 percent of the pulp, paper and paperboard industry, fully supports Government Reorganization Plan #3 to create an Environmental Protection Agency. The country has long needed a fully coordinated attack on environmental problems. The fragmentation of executive powers in this field, on both federal and state levels, is today a serious obstacle to the vigorous progress that our national situation requires. As a case in point, industrial enterprises must deal with a number of agencies, depending upon the nature of their pollution problems, and commonly find themselves up against conflicting, inconsistent or uncoordinated decisions. Pollution in one media can often be cured at the expense of causing pollution in another, and yet the vital interests of society call for the improvement of the total environment. Only through the consistent and coordinated development and enforcement of quality standards can we expect to achieve the results required. Many of the States are in a comparable position to that of the Federal Government, with a multiplicity of departments working piecemeal on environmental problems. We believe that the establishment of the new Environmental Protection Agency will encourage those States which have not yet done so to emulate the Federal Government in creating a single organization where all key aspects of waste disposal and pollution will be handled. Although President Nixon's message of July 9 to the Congress states the overall case for the new agency with great clarity and effectiveness, we stand ready, if your Committee so desires, to testify in favor of Plan #3 from the point of view of the benefits we believe it will bring to the paper industry's long and steadily growing efforts to improve the environment. Most sincerely, EXHIBIT 28 EDWIN A. LOCKE, Jr., President. STATEMENT REGARDING REORGANIZATION PLAN No. 3 of 1970 ESTABLISHING THE ENVIRONMENTAL PROTECTION AGENCY (By Edgar M. Cleaver, M.D., Director, Weld County Health Department, and Andrew Gurtner, Chairman, Weld County Board of Health, Colorado Health and Environmental Council, August 7, 1970) We would like to express our appreciation for the opportunity of having a statement placed in the records of the hearings regarding Reorganization Plan Number 3. We represent a local governmental agency and a state-wide health and environmental organization. We are vitally concerned about the implementation of health and environmental control measures at the State and local level. While it is with trepidation that we go on record as opposing policies recommended by both the President of the United States and his advisors and policies recommended by a leading political figure of the Senate majority, namely, Senator Muskie of Maine, we nevertheless feel that our position of strategic importance in implementing environmental health measures at the local level allows us to reasonably proceed with critical remarks and alternative suggestions. Frankly, we feel that Reorganization Plan Number 3, while it does pull together a number of environmental concerns into a more coordinated agency, nevertheless does not pull all concerns together and does fragment what we conceive to be the vital health aspects of the environment even further. This occurs in that the largest reorganizational change perhaps comes in the removal of a number of important functions from the Department of Health, Education, and Welfare. We feel that the President was more nearly right in his first inclination of not forming additional administrative agencies, but of consolidating programs under existing agencies. Many of us here in Colorado feel that the only answer to both the pressing personal health problems with their economic implications and our environmental health crisis (and it is a health crisis as well as an environmental crisis) is the development of a comprehensive department of health at the Cabinet level. Conversely, we feel that it would have been more appropriate to have placed the environmental functions of other agencies in the Department of HEW, if a new department of health were not to be formed. We feel that much of the concern about the environment today is entirely justified. However, there is an element of radicalism, extremism and political exploitation involved. We hate to see members of Congress from either party or the President responding to these extremist elements, rather than to the attitudes of experienced men from schools of public health and state and local health departments. I would refer you to two additional sources as representing attitudes which should not be overlooked_by those considering health and environmental reorganization or legislation. One source is that of the article "The rise of anti-ecology", noted on page 42 of the August 3, 1970, issue of Time Magazine. The second source is that of Issue Paper No. 4 on ecology and administration published by Community Health, Inc. of New York. Our interpretation of Reorganization Plan Number 3 is that while attempting to provide better standard setting and control of the entire environmental problem, there is indeed a definite possibility that health aspects of the environment per se will be given less attention. If there is truly an environmental crisis this cannot be allowed to happen. We from Colorado would strongly recommend that a resolution be introduced in the Congress to postpone the adoption of Reorgani zation Plan Number 3 until alternative possibilities of environmental coordination and reorganization can be considered. We would suggest that among these alternate possibilities is the development of a Cabinet level department of health, with a division of environmental protection. We would recommend the retention of the Council on Environmental Quality as an advisory and coordinating body. We would also suggest the formation of a joint legislative council to coordinate legislative action on environmental programming. We feel that these measures would give the environmental health crisis the attention that it needs at this time without fragmenting and disorganizing federal, state and local relationships necessary for cooperative action in enforcing laws, rules and regulations for environmental control and improvement. We greatly fear that we on the local level will have too many agencies and commissions to relate to, and that we ourselves will be enventually fragmented and will be unable to coordinate our own efforts because of the need to communicate with and receive directives and information from a myriad of agencies and commissions above us. In short increasing the number of administrative agencies and personnel at higher levels of government is not the answer to more effective elimination of environmental hazards at the local level. We appreciate the attention of Congressional Committees to the point of view of local people working in the field of environmental health as we attempt to protect the American people at the vital local level. HEALTH PLANNING ISSUE PAPER FROM COMMUNITY HEALTH, INC., Issue Paper No. 4, ECOLOGY AND ADMINISTRATION, MAY 1970 The ecological perspective toward man and his world has taught us that there are literally thousands of finely articulated subsystems in an all-encompassing ecosystem. Man's actions as a manipulative species cause changes in this environment whose effects may be proximate or distant, anticipated or unanticipated. In the current environmental crisis, we are harvesting the fruits of centuries of lack of concern or lack of appreciation of the ecologic consequences of human activity. The cumulative insult to the environment has risen continuously, while the response in society has been highly incremental and oriented toward single problems. One result of this incremental, uncoordinated approach to societal programming for the environment has been the development of a multitude of administrative subdivisions in government that deal with one subsystem or another without efforts to achieve integration. Environmental control programs have grown out of concerns as diverse as preservation of wildlife, management of natural resources, protection against communicable disease and increasing agricultural production. In addition, there are many other governmental programs that are related to environmental problems, either as part of the cause or part of the solution. As a result, we find programs of considerable environmental impact distributed widely within government-in departments of commerce, health, housing, conservation, urban affairs, agriculture, and transportation to cite a few. Such subdivisions seldom share goals or information and many operate in direct competition. There is obvious need for better coordinating the programs dealing with the environment, the causes of its deterioration, and the means for its enhancement. As government at every level strives to respond to the ecological crisis, the solution emerging tends-more frequently than not-to be an attempt to create some type of "ecological superagency". Such agencies-according to their proponents-will unite the fragmented enviromental programs that have grown in number in recent years, and create combinations which will be what the Governor of New York calls "an ecological whole". In our view, creation of such agencies represents an approach that is neither logical nor ecological. There is a real danger that—while appearing to "do something" to improve enviromental programming such agencies will merely perpetuate fragmentation at a time when a coordinated response is essential. In exploring the ecological aspect of our concern, it is necessary to distinguish between environment and ecology. Environment has traditionally been used to designate the physical world-outside of man and his social systems-in which man operates as an autonomous manipulator. Ecology refers to the study of the totality of patterns of relations between organisms and their environment. The environment's response and adaptation to man sets up new relationships which |