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chemical and biological reactions involved, and it is complicated further by economics and economic balances among people and groups of people, which can be severely changed by a shift in water pollution control requirements.

First, let's establish the attitude of the coal industry with respect to water pollution and water pollution problems by quoting a policy statement adopted by the board of directors of the National Coal Association (the official pronouncement of the industry), as follows:

"The National Coal Association recognizes a responsibility for supporting efficient land use and mitigation of water and air pollution problems. Such problems can best be handled at the State level rather than for the Federal Government to usurp State obligations. Where the Federal Government has existing programs in these fields they should be coordinated with State and local projects so that they shall be conducted most effectively, efficiently, and economically."

In accordance with this policy declaration the coal industry has and is cooperating with the legislative, administrative, and executive branches of government-Federal, regional, and State-in an effort to solve water pollution control problems as they arise in the coal industry. The coal industry nationally has been a substantial contributor to research programs on the control of water pollution from acid mine drainage and has sponsored research programs at Mellon Institute, Bituminous Coal Research, West Virginia University, and other research institutions.

Having established that the coal industry is vitally and actively concerned with the problems of water pollution, we should like to touch on the problem of long-range water supplies. Projections of water needs have been made for the year 1980 and for the year 2000, indicating that we are running out of water. This has led some individuals to make unlikely projections of our water supply problems. Several experts have pointed out that these predictions are probably inaccurate due to the ever-increasing industrial reuse of water, and further made unreliable because they have failed to consider the supply-demand-cost relationship where water is concerned. Dr. R. D. Hoak of Mellon Institute, Mr. Albert von Frank of the Manufacturing Chemists Association, and Mr. Stewart H. Bogue of Pate, Hirn & Bogue, Detroit, Mich., are among the many experts who have examined the water supply problem and have concluded, on the basis of their studies, that the Nation really is not running out of water and that our water supply will be adequate to meet any foreseeable demands made against it. This opinion has been further confirmed in some official Government statements. The gross inaccuracies in previous long-range projections, such as a predicted population ceiling of 165 million, or the prophesied inability of our farmland to produce an adequate food supply should be remembered when we view this prediction of future water shortages.

We cite this issue simply to illlustrate that our water problem is not a crisis problem to be solved by an emergency crash program but, rather, simply another problem which should be given rational consideration and solved in a reasonable and considered manner.

The legislation which your committee is considering proposes some far-reaching and drastic changes in our water pollution control laws changes which we believe are unwarranted by existing conditions. Possibly the most effective ac tion which this committee could take, from the standpoint of effective water pollution control, would be to recommend that no changes in legislation be made for a reasonable period of time, until the full effects of present legislation, which was amended as recently as 1961, can be adequately evaluated.

The proposed legislation contains provisions establishing a so-called positive national water pollution control policy which, if enacted and administratively pursued, could result in industrial and economic chaos. This proposed policy of "keeping water as clean as possible as opposed to the negative policy of attempting to use the full capacity of such waters for waste assimilation" does not realistically consider the necessary multiple-use philosophy of true conservation. If we consider the basic needs for water we must look at the necessary uses of water. The major uses of water may be divided into five broad categories, including (1) basic water supplies, (2) as a carrier of wastes, (3) for agricultural uses, (4) as a medium of transportation, and (5) for recreational purposes. Each of these broad categories could be further broken into several other clas sifications and the total might be extended to 10, 20, or even 100 items. These however, cover the major uses of water and are listed in their order of basic importance. Note that the use of water as a carrier of wastes is listed as the second most important use of water.

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Historically, flowing water has been the principal carrier of human waste and no significant civilization has ever been able to exist without making such use of water. As a result of the technology of our modern civilization, we are able to eliminate a considerable amount of wastes which formerly would have been disposed of into water, yet even today we are dependent on water as a carrier of our waste. From time to time glib, off-the-cuff statements have been made to the effect that it is, or might be, technologically possible to completely treat various wastes so that it would not be necessary to dispose of any waste materials into water. This has yet to be proved and, even if true, the cost and economic impact might be prohibitive.

This above-mentioned policy can be traced to the 1960 National Conference on Water Pollution, where it was a recommendation of one of the four working panels. In an attempt to reconcile differences among the four panels, the wording was inserted as the recommendation of the conference over the protests of 1 majority of the conferees. That a majority of the conferees did not agree with the conference report was demonstrated by a standing vote of those present at the final session. This standing vote was reported by the New York Times although it was not recorded in the official conference proceedings.

The National Technical Task Committee on Industrial Wastes, a technical advisory committee to the Surgeon General of the United States, noted this diference of opinion and recommended that the conference express the goal of polluion abatement:

"(a) To protect and enhance the capacity of the water resources to serve the widest possible range of human needs; and

"(b) That this goal can be approached only by accepting the policy of keeping water clean consistent with the variabilities within and among different river basins."

We believe that the recommendation of NTTCIW is more appropriate to our ational water needs than the "clean as possible" policy, and we would recomnend that it be considered for adoption as our national water policy if, indeed, uch a policy is found to be necessary.

It is further proposed to establish national stream standards and national ffluent standards and to provide for Federal enforcement of these standards on all navigable or interstate streams. The imposition of such Federal standards combined with Federal enforcement, could and probably would have great and ar-reaching undesirable effects on water pollution control activities.

Each river basin is an entity and no two are exactly alike. Natural factors affecting water quality, such as climatology, geography, geology, etc., often differ adically between river basins. Similarly, manmade factors affecting water quality such as population density and concentration, industrial development. nineral extraction, and farming-differ, making each river basin even more of n individual. The needs and requirements of people residing within these arious river basins also differ widely. When all of these variables are conidered, the disadvantage of national stream and effluent standards, which would e common to all, become apparent. A particular standard which is correct, roper, and necessary in a particular location might be unreasonably and detrinentally harsh in another location while being completely insufficient for a third ituation. Even within river basins a single standard has been found to be nadequate at times; and it has been necessary to apply zone standards to a large iver; or stream classifications to smaller rivers in the same basin. Some States, uch as Pennsylvania, use a stream classification system effectively in their vater pollution control programs. It would seem to be unrealistic to destroy hese effective systems by imposing Federal stream standards on them.

The proposal for the establishment of Federal standards and Federal enforcenent of them constitutes a major encroachment in the field of water pollution ontrol. Pollution problems are usually local in origin and local, or at most asinwide, in their effect; therefore, the solutions are primarily a matter of ocal, or at most basinwide concern. If the Federal Government were to furher encroach on local and regional rights, local problems and controversies would be settled primarily by Federal authority rather than local authority and s a result judgments would probably fail to evaluate the value, the needs, nd the problems of local people and local situations. If further encroachment y the Federal Government is permitted, compacts for drainage basin authoriies would become empty shells. These interstate agencies are designed, have een developed, and exist for the purpose of bringing about necessary and reasonble coordination of water pollution protection for those individuals, industries, nd communities within a particular drainage area. The amount of effort which

has gone into these interstate agencies would be lost or destroyed, and it is quite likely that the agencies, which now represent the highest development in water pollution control administration and techniques, would deteriorate into merely representatives of specific areas before Federal hearing bodies.

In this discussion regarding expansion of Federal activities in this field, no responsibility of Federal Government has been proposed that cannot be equallyand possibly more effectively, efficiently, and economically-accomplished through State or basin controls. When the problems of water pollution control become involved with other States, these States can join together under a compact agreement to effect necessary and reasonable coordination of water pollution control. The Ohio River Valley Water Sanitation Commission (ORSANCO) is an outstanding example of an effective interstate water pollution control agency. ORSANCO was formed in 1948 (the same year as the passage of the first Federal water pollution control law) and has enforcement authority coupled with political balance which I believe to be unique among interstate compact agencies. During its 15 years' existence ORSANCO has worked cooperatively with the eight member States and with generic groups within the Ohio Basin to achieve an outstanding record of achievement in water pollution control. Among its many achievements are the conception and development of the robot monitor system for stream quality surveillance, the development of an excellent public-awareness program of water pollution for the Ohio Valley, and the effective yet voluntary coordination of water pollution control activities of the member States on such pollutants as oil, chlorides. and acid mine drainage. In recognition of this achievement ORSANCO re ceived the American Society of Civil Engineers award for the outstanding civï engineering achievement of the year on May 27 of this year. The accomplishbent of ORSANCO is widely recognized and it should be noted that it has been achieved on an annual budget of only $232,000.

The first water pollution control law (Public Law 845, 1948) and its suecessor (Public Law 660, 1956, as amended 1961) contain provisions directing the Surgeon General to encourage the formation of interstate water pollution control compacts. Had the Surgeon General, or Secretary of HEW, aggressively complied with this directive of Congress in compliance with the 1948 law or subsequent laws, we would possibly today have ORSANCO's on all of our major river basins and have adequate water pollution control without even needing to be here today discussing Federal water pollution control and enforcement If it is found necessary to enact additional water pollution control legislation. more positive consideration should be given to the formation of basin-wide interstate water pollution control compacts using as a model, ORSANCO, which is eminently successful.

The Federal Government does indeed have responsibilities in the water pollution control field. We believe that these responsibilities can best be met through research, technical training of personnel, and dissemination of technical information to the various State and basin agencies who have primary responsibility for water pollution control in their areas. For example, it might be very helpful to these organizations to have the criteria for determining proper stream standards and effluent standards analyzed and detailed so that they can use this information in establishing the necessary and reasonable leve of water pollution control needed in their own local situations.

If our great natural resources, water, is to be of maximum benefit to the greatest number of people, and in the public interest, then local conditions needs, and requirements must be considered in any effective and realistic control program. This can be done on the local or, at most, the drainage basin basis so full import can be given to the local factors which are essential even though those factors may not appear to be of major significance nationally.

Hon. EDMUND S. MUSKIE,

AMERICAN FEDERATION OF LABOR AND
CONGRESS OF INDUSTRIAL ORGANIZATIONS,
Washington, D.C., June 28, 1963.

Chairman, Special Subcommittee on Air and Water Pollution,
Committee on Public Works,
U.S. Senate, Washington, D.C'.

DEAR MR. CHAIRMAN: On behalf of the American Federation of Labor and Congress of Industrial Organizations I wish to express the following views on S. 649, a bill to amend and liberalize the Federal Water Pollution Control Act. The AFL-CIO endorses the purposes of this bill which will make possible another vitally needed step toward the goal of assuring adequate supplies of clean water for all human uses in the years to come.

For many years the AFL-CIO has participated in efforts to achieve adequate Federal legislation to cope with the increasingly serious problem of pollution of our Nation's waters, with its serious effects upon health, urban and economic growth, fish and wildlife, and recreational resources.

We particularly support the enforcement provisions of S. 649, which direct the Secretary of Health, Education, and Welfare to establish standards of water quality applicable to various navigable waters, and to relate them to effluents discharged directly into such waters, with the power of abatement.

Furthermore, we support the proposal to put the Federal water pollution control program under a new Federal Water Pollution Control Administration in the Office of the Secretary of Health, Education, and Welfare. This proposal reflects the general shift in thinking from public health aspects to water supply aspects as the most serious aspect of water pollution immediately facing our Nation.

We hope that enactment of this administrative change will not mean merely the establishment of another bureau with more jurisdictional rivalries. Vigorous, coordinated, adequate Federal enforcement powers are essential to prevent water pollution.

Water pollution is a national problem of the utmost seriousness and requires a vigorous national effort now and in the future to protect our national well being. Mr. Chairman, I respectfully request that this letter be included in the record of hearings by your subcommittee on S. 649.

Sincerely,

ANDREW J. BIEMILLER,

Director, Department of Legislation.

DEPARTMENT OF PUBLIC HEALTH AND WELFARE OF MISSOURI,

WATER POLLUTION BOARD, Jefferson City, Mo., June 12, 1963.

Hon. STUART SYMINGTON,

U.S. Senate, Senate Post Office,
Washington, D.C.

The Missouri Water Pollution Board, at its regular meeting on June 4, 1963, here in Jefferson City, reviewed the provisions of S. 649, amendment to the Federal Water Pollution Control Act. The board instructed me to advise you of their opposition to the bill as written.

JACK K. SMITH, Executive Secretary.

DEPARTMENT OF PUBLIC HEALTH AND WELFARE OF MISSOURI,

WATER POLLUTION BOARD, Jefferson City, Mo., June 21, 1963.

Hon. STUART SYMINGTON,

U.S. Senate, Senate Post Office,
Washington, D.C.

The Missouri Water Pollution Board reasons for opposing S. 649 are briefly stated as follows:

1. Section 1 of the bill opposes the principle of reasonable use. The Missouri water pollution law and the law in many other States defines pollution as the discharge of waste into the waters in such condition, manner, or quantity as to interfere with reasonable uses of the stream.

2. Grants are authorized for the separation of combined sewers. It is our opinion that this separation is not justified in Missouri. This would be an extremely expensive program. Reconstruction of a sewer system in downtown Kansas City, St. Louis, or St. Joseph would disrupt traffic and business for a considerable period of time. There have been no studies to indicate that this separation is necessary or that it is the only solution to the problem.

3. The bill provides for the establishment of standards of water quality. We do not believe that this is desirable. At the present time we use water quality objectives which we believe are adequate. The matter of establishment of standards would be very expensive and would require a continuing program for establishment of standards and keeping up to date. Furthermore, the establishment of standards by the Federal Government would remove the authority and responsibility of State and local governments.

JACK K. SMITH, Executive Secretary.

OFFICE OF CHAIRMAN,

AMERICAN WATER WORKS ASSOCIATION,
COMMITTEE ON LEGISLATIVE ACTIVITIES,
Ardmore, Pa., June 25, 1963.

Re H.R. 3166, H.R. 3167, H.R. 6494, and S. 649.
Hon. EDMUND S. MUSKIE,
Senate Office Building,

Washington, D.C.

DEAR SENATOR MUSKIE: The four bills mentioned above have come to the attention of the board of directors of the American Water Works Association and are of interest to the association because each one would, among other things, remove the Federal water pollution control program from the jurisdiction of the U.S. Public Health Service. The association opposes this feature of the bills. On May 24, 1963, the association's board of directors adopted a resolution, a copy of which is attached hereto. to the effect that the association believes it to be in the public interest to continue Federal responsibility for water pollu tion control within the Public Health Service of the Department of Health, Education, and Welfare.

The association asks that this letter and the resolution be incorporated in the record of hearings on any of the bills mentioned. A representative of the association will be available to speak on any of the bills in a public hearing Yours very truly,

JOHN H. MURDOCH, Jr., Chairman.

POLICY STATEMENT TO AWWA LEGISLATIVE ACTIVITIES COMMITTEE Resolution to continue the Federal water pollution control program within the Public Health Service, Department of Health, Education, and Welfare. adopted May 24, 1963, by AWWA directors

Whereas the Federal water pollution control program in the United States has traditionally been administered by the Public Health Service;

Whereas the Public Health Service water pollution control program has achieved a high degree of success in protecting all water uses, particularly sources of municipal water supply;

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