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is the problem of phosphate buildup arising from the widespread use of detergents. Since the introduction of detergents after World War II the concentration of phosphates in municipal sewage has increased several times. Today, 25 to 50 percent of the weight of the typical domestic detergent consists of phosphates.

Do you want to comment on that?

Mr. BUELTMAN. Unfortunately, Senator, that is part of the testimony I skipped over.

Senator MUSKIE. I thought I saw it.

Mr. BUELTMAN. With your background and I am sure with your extensive exposure to all aspects of the complex picture of eutrophication and all the factors involved, you will understand why we are looking into any possible entanglement the phosphates of our product might have with the picture of eutrophication and deterioration of lakes.

Senator MUSKIE. As I recall your statement, you really have not reached any conclusions on this?

Mr. BUELTMAN. We have not. We, in concert with the Public Health Service, many State agencies, and many experts throughout the country are trying to determine just what the factors are. I think at this time it is very premature to designate phosphates as a direct factor and especially the detergent phosphates, which are one of many sources of phosphates.

As I pointed out, our current knowledge results from deductive reasoning and not from scientific fact. We are trying to obtain the scientific facts now.

I would not want to speculate nor would I want to project, because we just don't know the actual answer at this point.

Senator MUSKIE. Can you make comparisons between ABS and LAS on this point?

Mr. BUELTMAN. I have the men knowing the product formulations much better sitting behind me, but I can say the conversion from ABS to LAS has not required any change in the phosphate content or other aspects of the product.

Senator MUSKIE. This is a separate problem.

Mr. BUELTMAN. Yes.

Senator MUSKIE. Thank you very much, gentlemen. We will of course take continuing interest in this problem since it has been our concern for 3 years. We would appreciate any information you can give us from time to time as new developments take place.

Mr. HAHN. Thank you.

At this point of the record I will direct the staff to insert any additional material that is pertinent to this problem. I realize that it has received many communications and exhibits, but I will rely on it to use judgment not to make the record cumbersome or redundant.

(The following material was ordered placed in the record :)

Hon. EDMUND S. MUSKIE,

NATIONAL WATER COMPANY CONFERENCE,
Bala-Cynwyd, Pa., May 16, 1966.

Chairman, Subcommittee on Air and Water Pollution,
Committee on Public Works,

Washington, D.C.

DEAR SENATOR MUSKIE: The National Water Company Conference is an unincorporated non-profit national association of investor-owned water utili

ties. Such utilities serve nearly twenty million people in 4500 American communities, and are regulated under the laws of the forty-seven states in which they operate.

Your Committee is presently considering S. 2987 and related bills, including your own proposal (S. 2947), that call for major programs of pollution control in river basins and other water sources throughout the nation. While our association generally supports S. 2987, we are concerned that the bill is plainly inadequate in the provision it makes for the participation by investor-owned water utilities in the nation-wide program of water pollution control that will move into high gear in the coming years.

The concern of the investor-owned water utility industry with S. 2987 is a simple one. As presently drafted, because the bill provides only for "grants to assist in financing the development costs of treatment works." it is likely that investor-owned companies will be made ineligible to receive federal funds under the bill-or at least it will be very difficult for them to do so. Indeed, we are informed that the Administration plans to propose language changes in Sec. 107(a) that would explicitly prohibit "private agencies" from receiving grants to develop treatment works.

The Water Conference believes it essential that provision be made in S. 2987 for a program of "loans"-comparable to the loan provision in S. 2947-that would enable the companies to participate actively and aggressively in the water pollution control program that the Bill contemplates. Inclusion of a loan portion in S. 2987 would permit river basin areas and communities presently served by investor-owned water utilities to continue to be served by these companies through the appropriate and timely expansion of the companies' water treatment works. The investor-owned water companies should not be placed in the position of being forced to finance mandatory water treatment works expansion programs through private market funding in circumstances under which river basin commissions provided for in S. 2987 have determined that such expansion is necessary in any particular region.

It is noteworthy that loans made by the Federal government to investorowned water utilities under the water pollution control legislation would be repaid by the companies, whereas grant money is not recoverable by the federal government.

The precedent is well established for direct loans to investor-owned companies under comparable circumstances in the telephone industry. There has existed since 1949 a major program of direct federal low-interest loans to private industry as well as to public agencies for the establishment of rural telephone service. (See the Rural Electrification Act, as amended by the Act of October 28, 1949, 7 U.S. Code Sections 921 and following.) Under this program, with which I am sure the Committee is familiar, very large sums--amounting to more than $1 billion since 1949-have been loaned to hundreds of independent telephone companies to assist them in providing telephone lines to subscribers who otherwise would lack this important utility service. The principle of federal government-private industry cooperation represented by the direct loans to the telephone industry is as equally applicable in the field of water pollution control.

Accordingly, the National Water Company Conference proposes the following specific amendment to S. 2987:

Sec. 107(b) [replaces present (b), which becomes (c)]

The Secretary of the Interior may also accept applications and make long-term loans to investor-owned, regulated water distribution companies to assist in financing the development cost of treatment works. The same limitations shall apply to these loans as are applicable to grants described in Sec. 107(a).

Appropriate changes elsewhere in the statute would be called for to make provision for the availability of loans as well as grants.

With regard to S. 2947, all that would be called for is the addition of such words as "or to a private agency authorized to provide water supply or disposal of sewage and sewage treatment" at an appropriate place in Section 7. (At page 8, line 3 of S. 2947, between the words "section," and "for the purpose.")

We have assumed throughout that S. 2987, by its use of the words "private agencies authorized to provide water supply or disposal of sewage and sewage treatment" in Section 113(1), is designed to include investor

owned water companies within its terms. We are informed that there has been no opposition to the inclusion of private companies in the planning and other phases of the water pollution control program provided for by S. 2987-other than in the program of grants for the construction of treatment works.

We welcome and encourage the public-private partnership in programs of water pollution control that will be developed under S. 2987.

The history of tax-paying, regulated, investor-owned water systems is a proud one. They have maintained an outstanding service record throughout the drought-stricken northeastern states. We know you are acquainted with the outstanding service rendered by such companies to nearly 150,000 people in the State of Maine.

Our organization stands firm in its support of antipollution measures. We wish, as you have yourself expressed on recent occasions, that the states would accept their responsibility as outlined by the Water Quality Act of 1965; but, if the states refuse to do so, we recognize the importance of legislation to accomplish the desired end.

With the firm conviction that both Congress and the Administration welcome the continuing cooperation of investor-owned water service companies in a mutual effort to promote our nation's growth, we respectfully urge your Committee's consideration of the amendments we have proposed. Respectfully,

JAMES M. MILLIGAN.

MIDDLE ATLANTIC UTILITIES CO..
Westfield, N.J., April 28, 1966.

Hon. EDMUND S. MUSKIE,

U.S. Senator,

Senate Office Building,

Committee on Banking and Currency,
Washington, D.C.

DEAR SENATOR MUSKIE: Thank you very much for your letter of March 25th, enclosing six (6) copies of S. 2947 a bill which would amend the Federal Pollution Control Act.

Our company considers itself one of the pioneers in the field of privately owned sewerage disposal systems, owning one of the first privately owned sewerage systems in the State of New York. We have been viewing, with satisfaction, the recent enactment of bills to safeguard our water supplies and encourage the anti-pollution aspects in conjunction with same, however, we feel that the programs, although perhaps not intending to have the objective of discriminating against the privately owned segment of the anti-pollution field, never-the-less, by omitting from the provisions of the various aid programs provisions enabling privately owned sewerage disposal systems to obtain the same federal aid that municipalities, and other government entities, are being offered, and that the net effect is discrimination against privately owned segments, which we feel is not either the intention of Congress or for the benefit of the country.

Without wishing to make this letter unduly long, suffice to say it would be appreciated if your Committee would study the adding of provisions into the proposed Act S. 2947, enabling private anti-pollution companies to obtain the same aid and assistance that is being offered to government subdivisions. Precedent exists for government placing the private segment and public segment on an equal basis under the rural electrification program wherein both private electric companies and private telephone companies were entitled to receive the same loans and grants that cooperatives were afforded. We think this program has shown that it works well as regards rural electrification and we feel that the same yardsticks could be applied in the anti-pollution field.

Very truly yours,

MIDDLE ATLANTIC UTILITIES CO.,
SIDNEY L. JAFFE, President.

LAWRENCE DEVELOPMENT AND INDUSTRIAL COMMISSION,

BAY STATE BUILDING. Lawrence, Mass., April 13, 1966.

Hon. EDMUND S. MUSKIE,

U.S. Senator,

Senate Office Building,

Washington, D.C.

DEAR SENATOR MUSKIE: At the April 11th monthly meeting of the Lawrence Development and Industrial Commission, the Commission members passed a resolution supporting your bill S. 2947 and also that of Senator Edward M. Kennedy of Massachusetts, S. 2851.

The members of this Commission feel that if this bill is enacted, it would be a tremendous asset in partially relieving the financial burden that will fall on the local communities in the removal of pollution in the Merrimack River Basin.

If there is any further assistance that the members of this Commission can further extend to you on behalf of this bill and other matters, they would appreciate hearing from you.

Thanking you, Senator Muskie, for your kind cooperation, and wishing you success in having this bill passed. Sincerely yours,

JAMES B. COFFEY,
Executive Director.

Hon. EDMUND S. MUSKIE,

NATIONAL SOCIETY OF PROFESSIONAL ENGINEERS,
Washington, D.C., April 21, 1966.

Chairman, Subcommittee on Air and Water Pollution,
Committee on Public Works,

U.S. Senate,

Washington, D.C.

DEAR SENATOR MUSKIE: The National Society of Professional Engineers has reviewed S. 2987, the Administration's proposed "Clean Rivers Restoration Act of 1966" now pending before the subcommittee, and wishes to record its opposition to this measure.

As set forth in the attached copy of our Society's policy on water pollution, we believe that primary responsibility for preventing and controlling water pollution should rest with state and local governments, and that legislation dealing with the exercise of Federal responsibility, with respect to international, interstate and navigable waters, should preserve proper Federal-State relationships. While we feel strongly that pollution of our nation's streams, lakes and other waters constitutes a serious problem requiring continuing attention and effective action, we think S. 2987, as written, would destroy, rather than preserve, proper Federal-State relationships in this area. Accordingly, we urge the subcommittee to reject this far-reaching legislation.

We respectfully request that this letter and the enclosed policy statement be made a part of the record of the hearing on this bill. Following completion of our review of the other pending water pollution bills now under consideration by the subcommittee, we would appreciate the opportunity to present an additional statement of our views.

Very truly yours,

PAUL H. ROBBINS, P.E..
Executive Director.

NSPE POLICY No. 46-B. WATER POLLUTION

The pollution of the streams, lakes and other waters of the United States is a serious problem which requires continuing attention. In accordance with the principle expressed by the National Conference on Water Pollution held in 1960, NSPE believes that the goal of pollution abatement is to protect and enhance the capacity of water resources to serve the widest possible range of human needs. The Society considers that this goal can be realized most effectively through a positive policy of providing the best possible water quality consistent with engineering and economic factors and the public interest.

The Society recognizes that the primary responsibility for preventing and controlling water pollution rests with state and local governments. The exercise of Federal responsibility, with respect to international, interstate and navigable waters, should recognize state rights regarding pollution control. Federal aid, when necessary, should be designed to supplement non-Federal efforts, and the programs of Federal financial aid should be administered through appropriate state and local agencies and the existing facilities of Federal agencies with responsibilities for water pollution prevention.

The Society considers the current Federal water pollution control laws to be consistent with the foregoing policy. Any future revisions in these laws should preserve the existing Federal-State relationships.

The Society considers that granting authority to any Federal agency to establish and promulgate water quality standards would be contrary to the NSPE policy of preserving proper Federal-State relationships. The Federal Government should provide research and technical assistance to facilitate the establishment of water quality criteria by the states.

ROCKVILLE CENTRE, LONG ISLAND, April 21, 1966.

Hon. JOSEPH TYDINGS,
Senate Office Building,
Washington, D.C.

DEAR MR. TYDINGS: This is to express endorsement of your Amendment S-3226 to the Water Pollution Control Act. After forty years of design and construction of sewage treatment and disposal plants from the primitive to the sophisticated, I am well aware of the need for qualified operators.

New York State presently has a program for training operators which at various colleges and times during the year enables future operators to be instructed in the basic knowledge of sewage treatment and plant operation. The course covers a period of two weeks, a fully daily schedule and daily exams. Courses are given by qualified instructors in biology, chemistry and sanitary engineering. Classes are limited to twenty persons, and the courses being pretty stiff, many fail to win qualification from the State Board of Health.

My son is presently taking this course at Syracuse University, after his application for it had been approved and endorsed by the Westchester County Board of Health. The minimum requirement for taking the course for Grades III and II operators is high school graduation and experience working in sewage treatment plants. The highest grade operators, Grade I, must have a Bachelor of Science degree from a recognized college and experience in large treatment plants.

Competent and well qualified operators are essential for all treatment plants because of the complexity of the process and the changes that often occur in the flows to the plant. Disaster to water supplies can readily occur in almost any plant should trouble occur and the operator in charge be ill equipped to guide his operating personnel.

Because of an existing shortage of supervisory skilled operators, responsible to local health authorities, too many treatment plants are being operated in an unsatisfactory manner with the ever present possibility of continued pollution in critical areas. Even the short course provided in your bill is an absolute minimum, and may have to be extended. Your bill is a public health necessity.

Very truly yours,

J. MOOSBRUGGER.

THE DEPARTMENT OF PUBLIC HEALTH AND WELFARE OF MISSOURI,

Hon. EDWARD MUSKIE,

U.S. Senator,

Senate Post Office,

Washington, D.C.:

WATER POLLUTION BOARD, Jefferson City, Mo., April 28, 1966.

The Missouri Water Pollution Board at its meeting on March 31, 1966 instructed me to advise the Missouri Congressional Delegation of the Missouri Water Pollution Board's opposition to the provision of S 2987, 89th Congress,

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