ment in the next 25 to 50 years with serious threats to the continued productivity of the oceans.

Thus, what concerns me about it is where the responsibility for coastal zone management would go, the responsibility respecting control of pollutants going into the oceans, the responsibility in the whole marine environmental effort, and that issue remains unresolved at the

moment.

Do you have any view about where that aspect of environmental responsibility should be put?

Mr. ROUSE. Our view is that any authority created by Congress that deals with setting pollution control standards should not be placed in a resource using or promoting agency; so that, if Congress creates authority to set standards with regard to ocean pollution control, that authority should be placed in the Environmental Protection Agency and not in a resource using agency.

Senator RIBICOFF. Will the Senator yield?

Do you conceive then that this Environmental Protection Agency would take precedence over NOAA when it came to matters of pollution-setting standards?

Mr. ROUSE. I guess the short answer to your question, Senator, is "Yes." The question of precedence bothers me a little, but our belief is that the standard-setting activity ought not to be in a resource using, promoting or exploiting agency.

OCEAN AND SHORELINE MUST BE PROTECTED

Senator RIBICOFF. In other words, you agree with the position that Senator Nelson takes, that we must do everything possible to protect the ocean and the shoreline, and that if we do create NOAA which has development aspects we must make sure that the overdevelopment in NOAA does not do to the environment what overdevelopment in this Nation has done to the entire environment?

Mr. ROUSE. I agree, entirely.

Senator RIBICOFF. So, when Senator Nelson makes a statement that he would hope that the report would make this very clear, irrespective of if we decide to vote favorably on the report, you would feel that it would certainly be appropriate for the report to have very strong language as to the intention of the Senate as to the role of the environment in NOAA?

Mr. ROUSE. I agree with you. I think it should.

Senator NELSON. Just so I am clear on this, you think the Environmental Protection Agency would be a more appropriate place than any other Federal agency for this responsibility, coastal zone management, and so forth; is that correct?

Mr. ROUSE. Let me say, first, that we did not study the coastal zone bill or the authorities created in it simply because it was pending legislation and our mandate related primarily to existing legislation. But my view on that, Senator Nelson, is that those activities associated with grants to States proposed in the coastal zone bill, both to establish organizations for coastal management and then the operating grants subsequent to that probably need not be in EPA. But if there is authority in that bill which establishes standard setting and enforcement functions, those functions should be in EPA. That is, it is

possible to separate a grant-giving activity from a standard-setting activity.

Senator NELSON. But so far as the environmental aspect of the oceans are concerned then, standard setting and enforcement respecting the environment, you believe this ought to go in the Environmental Protection Agency?

Mr. ROUSE. Yes, sir.

Senator NELSON. Thank you, Mr. Chairman.
Senator RIBICOFF. Thank you very much.

Mr. Clapper, Mr. Clement, and Mr. Penfold.

We welcome you three gentlemen who have great responsibility in the field of conservation and environment.

I imagine these must be rather happy days for you, to see the country finally catch up to your many years of effort.

And, of course, Mr. Clement, you testified before me on trying to save Long Island Sound, so I am very sympathetic with the objective that Senator Nelson wishes to achieve. And, of course, I could not be for any NOAA if it were really going to destroy the environment or the ocean. I want to save Long Island Sound and save the ocean. I do not want to destroy it.

It is difficult for me to see why the creation of NOAA and the saving of the environment should be inconsistent.

I would like to have you gentlemen address yourselves in your discussion to that point and come up with some suggestions as to how we could assure that NOAA does not destroy or pollute the ocean as a source of great meaning and great need to be saved.

As I understand, you have no prepared statement but are going to be sort of panelists and have a general discussion of what is concerning Senator Nelson.

STATEMENT OF ROLAND C. CLEMENT, VICE PRESIDENT, NATIONAL AUDUBON SOCIETY

Mr. CLEMENT. Senator, I consider myself rather junior in this group. These two other gentlemen have much more experience in Washington. So, if I may lead off I will introduce a few inputs.

As you know, probably, the National Audubon Society has already provided a preliminary statement, but as the society's chief scientist, I would like to share additional views prompted by my examination of this plan, since I was not present when our first statement was drafted. (See exhibit 13, p. 156.)

I would like to call particular attention to the fact that NOAA as outlined by the President would be almost wholly oriented toward the physical aspects of the marine environment.

Now, these are important elements of our planet, but I would, for this very reason, question including the biologically oriented Bureau of Commercial Fisheries work. It would be, in my view, a mere appendage. This Bureau has been no special champion of conservation resource use, having been dominated by exploitation-minded interests from the first. But it would be completely swamped in NOAA especially if NOAA is put under the Department of Commerce.

Senator, what I am saying is that NOAA would make more sense without a diminutive biological appendage. As an experienced biol

ogist, I urge your committee and the Congress to leave fisheries and marine mammal research in the Department of the Interior at least for the time being.

One reason for my view is that at least two-thirds of our marine fish are dependent on the estuarine zone for part of their life cycle, so it makes more sense to keep fisheries and coastal zone management together in a biologically oriented unit.

Research is not just data collecting, but it is thinking about the implications of these data, and it is best done in conjunction with like-minded colleagues since it is a matter of asking questions.

I feel that Mr. Nixon was misinformed when he justified his inclusion of fisheries work in NOAA on the basis that "food from the oceans will increasingly be a key element in the world's fight against hunger."

OCEANS REMAIN A COMMONS

Ninety percent of the ocean surface is of very low biological productivity, and we are already overexploiting many fisheries' resources because the oceans remain a commons over which neither we nor the United Nations have succeeded in imposing responsibility, and even if there were significant untapped resources there, which I question, we are up against the same economic obstacle called effective demand that plagues food production on land.

Mr. Nixon has urged moving a step at a time. We, of the National Audubon Society and the other conservation groups, have already endorsed Reorganization Plan No. 3.

I would urge your committee and the Congress to defer action on NOAA until more study of its full implications has been conducted by all of us.

Thank you, Senator.

Senator RIBICOFF. Whichever one of you, Mr. Clapper or Mr. Penfold-as you please?

STATEMENT OF LOUIS S. CLAPPER, CONSERVATION DIRECTOR, NATIONAL WILDLIFE FEDERATION

Mr. CLAPPER. I will go ahead, then, Senator.

I am Mr. Clapper. Before I begin my brief statement, I would like to express the interest and concern of many other conservation organizations, and, due to a conflict, many of them could not be here but they do have statements that have been filed-I hope-with the committee. And I think that a wide segment of the conservation movement is with us at least in spirit today as we testify against this plan. Mr. Chairman, a segment of the conservation movement not represented by a witness here today are the official State fish and wildlife agencies. Their responsibilities for managing fish and wildlife resources parallel those of the Federal Government and, in the cases of interstate and inland waters, their jurisdictions often are concurrent with those of the Federal Government. Thus, they have close relationships with Federal agencies involved in fisheries work. Their opinions of organizational alinements should merit respect and consideration. The International Association of Game, Fish, and Conservation Commissioners is composed of the administrators of all of the State and Provincial wildlife agencies. This organization will not be able to

act upon Reorganization Plan No. 4 until its annual meeting to be held September 17-18 in New York City. However, we are confident that it will oppose plan 4 because two of its four regional subdivisions already have adopted resolutions in opposition. These are the Western Association of State Game and Fish Commissioners and the Association of Midwest Fish and Game Commissioners, and copies of these resolutions are attached. (See exhibit 14, p. 157.)

Colorado is a member of both Associations. The composition of the groups, otherwise, is: Western Association-Alaska, Arizona, California, Hawaii, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, Washington, and Wyoming; Midwest-Illinois, Indiana, Iowa, Kansas, Kentucky, Michigan, Minnesota, Missouri, Nebraska, North Dakota, Ohio, South Dakota, and Wisconsin.

I would like to second Senator Nelson's concern about the environment and, perhaps, add another aspect or two to this plan and difficulties that we foresee with it, and, then, let Mr. Penfold carry on with at least another aspect of this problem.

We do welcome the opportunity to comment upon this plan, and we are thankful for this hearing.

CONSERVATION "WISE USE" REQUIRES SOUND MANAGEMENT

Throughout its existence, Mr. Chairman, the National Wildlife Federation has stood for the conservation of natural resources. In this context, we construe conservation as being "wise use" rather than pure preservation. And, of course, wise use requires sound management. And to be sound, we believe management must be predicated upon principles which can be ascertained only through sound basic research. So, in our opinion, management and development is so closely interrelated with research that the functions are inseparable.

Senator RIBICOFF. Do you think that the Commerce Department is so marked that it could not undertake responsibilities in the conservation field?

Mr. CLAPPER. Well, Senator, it is our belief that the Commerce Department is oriented principally toward exploitive types of activities, which we do not believe are in context with the best management of natural resources. This is why we would like to see at least the management and the research portions of the Bureau of Commerical Fisheries kept in the same department or the same agency with the Bureau of Sport Fisheries and Wildlife.

WE HAVE EXPLOITED OUR WATER TO THE DANGER POINT

Senator RIBICOFF. I understand, but, of course, the whole American complex has been exploited. We have exploited all of our resources. We have exploited our lands; we have exploited our water to the present danger point.

Now, it is through the efforts of men like Senator Nelson and others, the deep concern for the environment that I believe the country is turning around that, though the exploiters are now being concerned, even selfishly, they see the potential damage to their own future and their own interests. And I think they are starting to see—not all of them see it-the great changes that are taking place in the ecology and the need for them to have a different philosophy, too.

Now, even though Commerce did take the idea of development, and they are supposed to develop the commercial aspects, if commercial aspects now mean also conservation in the long run, why are you pessimistic that this branch of Government would not be going along with EPA or the Council on Environment Quality in preservation and in conservation work as well?

I mean, do you think that they would hold out against the President and the Congress?

Mr. CLAPPER. Well, frankly, we fear this, Senator.

And we would rather not have the mechanism set up in order to make this more easy.

The Bureau of Commercial Fisheries in the past in many respects has oriented itself toward the exploitation or the development of the fisheries resources.

Senator RIBICOFF. May I say this? I must confess ignorance, in not knowing too much about the Bureau of Commercial Fisheries. Will you tell the committee what there is about the Bureau of Commercial Fisheries that concerns you?

Mr. CLAPPER. Most of the research is oriented toward methods of taking fish, of determining where fishery stock are located, and of getting a greater harvest of fisheries, rather than upon the biological or protective side of the commercial fisheries program.

Senator RIBICOFF. Couldn't they both go together? Because, after all, you can take too many fish out of the sea.

Mr. CLAPPER. Surely.

Senator RIBICOFF. I mean, we have to make sure that there is a continuing supply of fish.

Mr. CLAPPER. That is our purpose, sir, to maintain a sustained yield of fishery stocks.

A PROGRAM IN CONNECTICUT

Senator RIBICOFF. As Governor, we had quite a program. The fish and game department made sure that you had seasons where you could fish, and, then, you had fish hatcheries. And we tried to do all we could to have more fish in the streams and rivers of Connecticut instead of less.

Now, why could this not be a part of the program of the NOAA? Why would they just be exploitive to catch fish without developing larger supplies of fish?

Mr. CLAPPER. Exactly what you have outlined, Senator, is what we hope can be managed, can be effected. We hope that management of fisheries resources can be done in accordance with scientific principles that will protect and will provide a sustained yield, for both commercial aspects and for sport fisheries, too. We simply feel that the Department of Commerce is oriented principally toward commerce and toward exploitation and development. There is nothing wrong with this except that we think that it gives the heaviest emphasis to this aspect, and we want the scientific management of a resource kept with the sport fisheries.

Now, there is a distinct interrelationship in our opinion between commercial fisheries and sport fisheries in the marine areas. There are many species of fish which migrate between the marine salt waters and fresh waters, and there are commercial fisheries of great importance in fresh waters which might not be covered by this in many