UNDERSTANDING BETWEEN OWP AND ARC The overall effort for the Monongahela River Basin identified in the appropriations legislation was discussed with Messrs. Allen Cywin and Ernest Hall in the Office of the Federal Cochairman on March 10, 1971, and agreement was reached on the following points: 1. The Office of Water Programs' (OWP) responsibility under the authorizing legislation is to implement demonstration projects of specific types, or sets, of mine drainage pollution abatement or control techniques in appropriate areas. This work necessarily includes the preparation of engineering and design specifications adequate for the implementation of the specific techniques (or sets of techniques) to be demonstrated. 2. The Commission's responsibility concerns the study and evaluation phases of an area-wide program, with particular attention to the economic development impacts of mine drainage pollution abatement. Any engineering or similar work included here would be only that sufficient to provide a basis to indicate for planning purposes, difference in cost effectiveness among possible alternative approaches. 3. The Commission's study and evaluation efforts would be undertaken in the context of the conclusions and recommendations contained in the report, Acid Mine Drainage in Appalachia; e.g., that a program of mine drainage abatement shall be part of an overall effort to improve the environmental quality of the area involved. Thus, the Commission's study efforts would be directed as assessing the full-range of activities required to improve the environment in the study area in order to assure realization of the water and land use objectives. This is discussed in greater detail below. 4. The Commission could conduct such studies either by using its own staff, consultants, or combination of both. 5. Study area designation by the Commission would be cognizant of the pending demonstration projects in mine drainage abatement submitted to OWP, interests of the three Appalachian States involved, and the recognition of the preference given to the water use objectives identified in Section 14 of the Water Quality Act of 1965, as amended. 6. OWP would transfer funds for this work to the Commission after receiving a letter indicating: (a) the nature of the individual study efforts contemplated; and (b) identification of the general areas for study. The Commission indicated that it was unlikely that it would require more than $500,000 for these efforts, and our current estimate is that actually only $350,000 is needed to carry out this research. 7. The Commission would keep OWP fully informed on the progress of the studies, and provide copies of progress reports, final reports, and other materials developed during or pertinent to these efforts. The Commission staff would also welcome comments and suggestions on the studies. NATURE OF THE STUDIES The Commission has concluded, based on evaluations of its projects and research studies that identification of the direct linkage between the abatement of any one pollutant or type of environmental degradation in an area and the economic well-being of the area is generally elusive at best. However, we have found that if a set of pollutants or environmental problems are systematically removed (by simultaneous or sequential activities), then the area becomes more responsive to opportunities which tend to improve its economic well-being. In part, this is explained by the interrelationships among various types of land and water pollutants, since specific objectives of land and water use can be frustrated by any one of a number of types of pollution occurring at one time, e.g., coal mine waste piles, abandoned unreclaimed surface mines, casual and indiscriminate solid waste dumping, acid mine drainage, municipal and industrial water pollution. Hence, the Commission has concluded that future resource and environmental development investments should be geared to area programs which identify the sets of environmental improvement activities requiring a systematic approach in each area. We recognize that improving the environmental quality of an area is a broad and possibly complex undertaking and any program to carry out environmental improvement will inevitably be comprised of significantly different mixes of individual activities among areas, depending upon their natural characteristics, existing populations and density, and the nature of present and projected development, resource use objectives, and present condition of the area resources. The general steps of a study to develop an environmental improvement program to achieve desired environmental characteristics for an area include: 1. A general analysis of the natural characteristics of the area, identifying those portions in which intensive or specific types of development should not occur because of special ecological or environmental characteristics. The analysis would include an identification of the nature of development most appropriate to the area in terms of its environmental carrying capacity. 2. Through such an analysis, one can then begin to determine the patterns of economic and social activity most likely to create the fewest harmful environmental side effects. This analysis then must be superimposed upon what already exists, and from this one identifies those areas where environmental improvement is clearly required in order to solve the problems left from past activities. In addition, an identification is made of impending problems which may result from future development in areas where the development process is only just getting underway. 3. From this, the overall area is divided into a priority list of sub-areas for an environmental improvemet program. Emphasis is given to those sub-areas where environmental factors most seriously affect the most people or most seriously detract from the economic and social development of that sub-area. 4. For those sub-areas at the top of the priority list where programs are to be implemented first a detailed environmental improvement plan would be prepared. This would consist of: (a) An assessment of each of the environmental deficiencies defined in terms of: (1) Its constraining influence on development and use of the area and its resources; (2) The expected rate of increase and/or continuation of the severity of problems and their impact, assuming no specific corrective actions; (3) The irreversibility of environmental impacts without appropriate controls; (4) The linkages among individual environmental problems requiring concurrent or sequential action; and (5) The use of benefit-cost and other analysis to choose among alternative technical approaches identified in order to meet the environmental improvement quality objectives of the area. (b) Establishment of priorities for action based on the assessment made in Item a. above, including identification of linkages among particular environmental deficiencies which require simultaneous or sequential action. (c) Development of an implementation plan which would identify for each of the actions contained in the established priorities: (1) Estimated costs; (2) Identification of the legal, administrative, and financial responsibilities for activities by Federal, State, and local governments; (3) Identification of the legal and financial responsibilities for activities within the private sector; and (4) Specifically identify those public and private investments which must be made within a systematic framework in order to protect both types of investment and assure that the resource use or environmental improvement objectives are not frustrated by selected inactivity. AREAS FOR STUDY The geographic areas for study have been preliminarily identified using the procedure agreed upon and considering also: existing public (State and Federal) resource investments and recreational facilities, and ongoing State activities focusing on specific aspects of environmental improvement. The areas are: 1. Youghiogheny River Sub-basin of the Monongahela River Basin : (a) The Casselman River tributary area; and (b) The Upper Youghiogheny area including Deep Creek Lake and other tributaries; 2. Morgantown, West Virginia area, including Dent's Run, Cheat Lake, Marion and Monongahela Counties; and 3. West Fork River or Tygart River tributary areas. It appears reasonable to leave the exact geographic bounds of each study area flexible at this time, and require as part of the early phases of each study the determination of the exact boundary for analysis purposes. This depends in part on the environmental characteristics of the areas as discussed in the study description. It is also generally anticipated that the studies would be initiated in the sequence above. CONDUCT OF STUDIES The Commission plans to have these environmental improvement plans prepared largely by consultants. Our staff's best estimate of the direct cost of this work is $350,000, and this is the amount requested to be transferred for this work. The necessary fiscal arrangements should be made with our Budget Officer, Mr. Brinley J. Lewis, telephone 967-3106 (IDS Code 189). I have asked our General Counsel, Mr. Robert L. McCloskey, to prepare a brief interagency memorandum of understanding which would incorporate the foregoing work program. The Commission staff is prepared to initiate these studies by issuing a formal request for proposals after funds are provided. It is anticipated that results from these studies will be available one year after their initiation. We look forward to the successful completion of these studies with the objective that it will help provide the basis for local communities, States, Federal agencies, and private parties to focus sufficient efforts for improving the environment of the areas involved. Sincerely, DONALD W. WHITEHEAD, Federal Cochairman. JOHN D. WHISMAN, States' Regional Representative. DEPARTMENT OF THE ARMY Hon. EDMUND S. MUSKIE, Corps of Engineers DEPARTMENT OF THE ARMY, Chairman, Subcommittee on Air and Water Pollution, Committee on Public Works, U.S. Senate, Washington, D.C. DEAR SENATOR MUSKIE: This is in reply to your recent letter concerning Corps of Engineers research activities in environmental science and technology. Information is furnished on both the Civil Works and Military programs of the Corps. The following information is provided for your record on Corps of Engineers activities: 1. What is the organizational structure of your enviromental research program? How many separate laboratories or installations in your agency are engaged in this research? What is the size and composition of the staff of each? Research on environmental questions is related to the Corps Civil Works or Military missions and may be accomplished as part of a general research program or as part of a specific project. The organization structure for accom plishing general research is coordinated by the Chief Scientist and the R&D Coordinating Office with the Civil Works, Military Construction, and Military Engineering Directorates. Each Directorate has an R&D coordinating element at the policy level to assist the Directors in formulating their research programs. When environmental research is undertaken as part of Civil Works projects it is coordinated at OCE level by that Directorate. Corps involvement in environmental research may be undertaken by the U. S. Army Coastal Engineering Research Center, the U. S. Army Waterways Experiment Station, the U. S. Army Cold Regions Research and Engineering Laboratory, the U. S. Army Construction Engineering Research Laboratory, the Institute for Water Resources, the U. S. Army Engineer Topographic Laboratories or any one of the Civil Works Districts or Divisions when specifically oriented to a given preauthorization study for a construction project. When research is conducted by the Division or District it may be contracted to either one of the Corps laboratories, another Federal agency, a State agency or any academic institution. The size and composition of each of the Corps research laboratories is provided in Enclosure 1. 2. What are the fields of specialization of the scientific investigators in your laboratories? What advanced degrees do they hold? This information is provided in Enclosure 2. 3. What is your present level of funding for environmental research? What is your present level of authorization for environmental research? For how many years? Funding for the military activities is provided through the Department of Defense and details are provided in Enclosure 3. Civil Works funding for environmental research is not as easily identifiable as it is composed of two elements, general and project funding. The detailed answer on FY 69 through FY 72 funding is provided in Enclosure 3; however, the Civil Works funding has no established level of authorization for environmental research. In reply as to how many years the Corps has been accomplishing environmental research depends on the definition utilized. Environmental research defined in its broadest context has always been considered by the Corps. Recent national interest in ecology has broadened the scope of Civil Works research. 4. What kinds of problems are you addressing under the category "environmental" research? What proportion of this work would you consider "basic" research, defined as research producing fundamental, theoretical knowledge which was not sought for immediate problem-solving purposes? What proportion is devoted to technology development? To technology assessment? (675) The types of problems addressed by the Corps research elements are provided in Enclosure 4. An analysis of the Corps research program indicates that approximately 7 to 10 percent might be classified as basic research but is required in order to accomplish the problems addressed by applied research. Approximately 65 percent of the Corps research effort is devoted to technological development while the remaining percentage addresses technological assessment. 5. List your current research projects on ecosystem structure and function, if any. Since these two items are biologically oriented and not related to the Corps mission, no research is conducted by this agency on the ecosystem structure or function. However, some research conducted by the Corps may have an indirect relationship. 6. How much of your environmental research is conducted at your own facilities? How much is done by contract to other institutions? Please indicate the proportion of contract work assigned to each of various types of institutions (university, independent research firm, industry, etc.). The percentage of research accomplished in house ranges from 99 percent to 40 percent according to the fields of expertise involved. That portion of research accomplished out of house is evenly distributed between academic institutions and industry. 7. What mechanism, if any, do you have for identifying and addressing largescale environmental questions by interdisciplinary teams? What mechanism do you have for coordinating your activities with the Environmental Protection Agency? Please include copies of any memoranda or letters of agreement which detail your coordination mechanism. a. The Corps of Engineers has a built-in mechanism for identifying and addressing large-scale environmental questions by interdisciplinary teams. This is accomplished by internal systems evaluation groups consisting of key individuals with responsibilities for planning, design, construction, and operation and maintenance. This concept is applied at OCE and in each Division and District. Whenever an element lacks particular expertise in a given scientific discipline an attempt is made to utilize the internal resources of the next higher echelon or the laboratories. However, when the desired skill is not available within the Corps consultants are hired from academic institutions or industrial sources, or contracts are made with other Federal agencies, State governmental agencies, academic institutions, or industrial sources. The information reported in Enclosure 2 provides a sample of the multidisciplinary capabilities of the Corps laboratories. b. At each level of operation the Corps utilizes informal and formal coordination with EPA representatives to assure collaboration or projects or programs where possible. In addition the Corps has representation on interagency committees, where research programs related to water resources development, the Actic, environmental quality, marine science and engineering, marine prediction, pollution poblems, and many others are discussed and coordinated. To date the Corps has two approved working agreements which are provided in Enclosure 5. 8. What important questions, if any, are you unable to research adequately within your existing research structure? What are the main hindrances to proceeding with such research? A major obstacle faced by the Corps in directing its long-range research program stems from three problems. The first of these is the lack of baseline data and continuous monitoring of the environment in order to identify changes and discover the causes. Second is the manner in which environmental data that has been collected tends to be discipline oriented and time is required to translate findings into engineer design solutions. Third is the difficulty of quantifying environmental values for justification and decision making to provide a choice in selecting alternatives. However, some effort under the military sponsorship has been conducted under the RDT&E program on the third problem and the results accomplished to date appear most promising. In an attempt to improve its capabilities to collect and utilize environmental data the Corps is implementing a remote sensing program under its Civil Works area of responsibility in FY 72. The years of expertise gained under its military program will be applied to this effort. Sincerely yours, [ENCLOSURES:] C. H. DUNN, Major General, USA, Deputy Chief of Engineers. |