plant it is necessary to boil down a boiler, otherwise as the solid builds up, it is carried over in steam. There has to be a certain blowdown from a boiler to maintain an operating condition.

You have this blowdown and you may consider the paper machine as a process by which you take a mixture of wood fiber and water and suspension; you pass it over the paper machine which you consider as a giant filter and then the white water, as we call it, percolates through the sheet of paper as it is formed on the machine and this white water is recycled and we average reuse of water in the pulp and paper mill probably around three and a half times; every drop of water is reused three and a half times.

We are constantly striving to reduce the amount of water being utilized. But there has to be some, one system, a blowdown from which the buildup in dissolved solids can be controlled.

Senator EAGLETON. From a technical point of view, is it not easier to remove contaminants from a closed cycle system than from an open-ended system?

Mr. GOULD. To remove contaminants from water is about independent of the type of system. There are certain established methods for doing this and not a general application.

Senator EAGLETON. Aren't those methods different in closed-cycles vis-a-vis open?

Mr. GOULD. No; I would not say that.

Senator EAGLETON. You don't think it is any easier to remove contaminants from a closed-cycle system in terms of cost, effort, success of removal, contaminants, et cetera-it is six of one and half a dozen of the other?

Mr. GOULD. Right. I think you have a certain amount of material that has to be disposed of and the only variable is how much water is that contained in.

Senator EAGLETON. Mr. Chisholm, I think all of us would agree that one of the key elements of effective water pollution control is a sound land-use-policy.

Should any legislation coming from this committee mandate the development of federally approved land-use plans which would protect against the location of new plants in areas where the environment cannot absorb such new plans?

Mr. CHISHOLM. It would be my understanding under the proposals today that a new plant could not be established unless it could meet environmental requirements. Certainly under EPA permit, this is true. Senator EAGLETON. Does that make a modicum of sense to you, that requirement?

Mr. CHISHOLM. Yes; it makes some sense. I would have to qualify it. Mr. GOULD. I would add, and I think this was mentioned before, that we have some 200 operations in 36 States and I would say that it is almost universal today that you have to have a permit before you can build a new plant anywhere. Part of the requirement for building a new plant is a public hearing in which the public has an opportunity to speak out against the new plants and locations of them and the environmental considerations are taken into consideration before per

mission is given to build new plants. It is getting quite difficult to build a new plant any more.

Senator EAGLETON. Thank you very much, gentlemen. We appre ciate your appearance before us this morning.

That concludes, ladies and gentlemen, this morning's testimony.

This committee will once again be in session tomorrow morning at 10 a.m., on the same subject matter.

(Whereupon, at 12:45 p.m., the Subcommittee on Air and Water Pollution of the Senate Committee on Public Works, recessed, to reconvene at 10 a.m., Tuesday, March 23, 1971.)

(Appendix to this day's hearing follows:)

APPENDIX-MARCH 22, 1971

The following material, received subsequent to the hearing, is included in the printed record of the hearing at the request of Chairman Muskie.

Hon. EDMUND S. MUSKIE,

NATIONAL ASSOCIATION OF MANUFACTURERS,

New York, N.Y., March 29, 1971.

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

DEAR CHAIRMAN MUSKIE: During the appearance of Mr. M. P. Venema on behalf of the National Association of Manufacturers before the Senate Subcommittee on Air and Water Pollution on March 22, Senator Eagleton and I engaged in a colloquy regarding the Association's policy position entitled "Environmental Quality Control."

In order to complete the record, a copy of the full text of this policy position is enclosed. We respectfully request that the complete text be included in the record of the hearing. Your courtesy in this regard would be greatly appreciated. Sincerely,

DANIEL W. CANNON, Director of Envnronmental Affairs.

OFFICIAL POLICY POSITION OF NATIONAL ASSOCIATION OF MANUFACTURERS ON "ENVIRONMENTAL QUALITY CONTROL"

The National Association of Manufacturers shares the National concern for the quality of the physical environment. The Association supports efforts to ensure the highest degree of compatability between industrial activities and the environment.

The NAM shares in the increasing concern about the proliferation of agencies— federal, regional, state and local. The Association believes there should be a national environmental coordinating agency with responsibility for providing factual environmental information. The Association also believes such a national coordinating agency should be adequately staffed and funded to obtain, supply, interpret and disseminate such information.

When an agency at any level of government is designed as having primary responsibility for regulating or enforcing, then requirements of that agency should control, subject always to the right of judicial review. NAM supports the elimination of overlapping interpretive authorities and requirements for a multiplicity of certifications when licenses or permits are required by multiple levels of government.

There is a need for priorities to make possible a systematic approach to environmental protection. The approach is essential so that we can achieve the maximum rate of progress with available capabilites. The Association continues to support the concept of permitting innovative solutions as well as trailoring such specific control requirements as are necessary to achieve environmental quality objectives in a particular region.

The Association encourages industrial participation in the establishment of standards that are necessary and economically feasible. Where technology is not available, industry should assist in setting up studies and experiments which will produce adequate methods of controlling pollution, and time should be granted for such investigative work. It should be noted that blanket and excessive requirements can be highly unrealistic and result in unjustified economic costs to the consumer and the taxpayer, and in the further loss of job opportunities.

It is recognized that amibent air and water quality standards must be protective of public health and beneficial uses. These should be established, based on

guides set on the national level. Emission of effluent limitations needed to achieve these should be established by regional, state or local agencies recognizing local conditions.

Once pollution abatement standards are adopted, such standards should be made applicable to existing sources for a period of five years unless current research indicates that a particular standard is not adequate to protect the public health and welfare. This will permit the design of pollution abatement facilities in an orderly fashion.

The Association encourages the further strengthening of efforts to conserve natural resources by minimizing waste materials at the sources and by developing more effective methods for the recycling and reclaiming of useful components. There are broad social benefits which accrue to all the people of the nation through environmental quality control efforts. Because of this and because in most instances money invested for abatement facilities does not bring an economic return, the Association believes there should be some recognition of the cost of installing environmental quality control facilities in relation to the general public interest and the uneconomic portion of the investment. This recognition should take the form of:

1. Accelerated amortization up to and including the immediate write-off of the facility at the option of the taxpayer; but this accelerated amortization should not eliminate any investment credit.

2. Tax credits to enterprises which expend private capital for such facilities. 3. State and local tax exemptions.

4. Certification of the facility by the State or local agency responsible for environmental quality.

The NAM believes that taxes on effluents and emissions represent an unmanageable, uneconomic and negative approach and in principle would allow polluters to continue to adversely use our environment by payment of a tax.

(The following supplementary material was received subsequent to the hearing and is referred to on p. 746 of the text :)

SUPPLEMENTARY STATEMENT OF THE AMERICAN PAPER INSTITUTE CONCERNING WATER POLLUTION LEGISLATION PENDING BEFORE THE SUBCOMMITTEE ON AIR AND WATER POLLUTION OF THE COMMITTEE ON PUBLIC WORKS, U.S. SENATE, APRIL 16, 1971

The American Paper Institute, on March 22, made a formal presentation to the Subcommittee on Air and Water Pollution. The March 22 statement described our industry's concern with the increasing complexity of pollution abatement legislation and regulation and the confusion and delay being created because of this complexity.

On March 22 statement, because of time limitations, did not deal with specific aspects of the legislation before the Subcommittee. We should like to do so in this supplementary statement which is being submitted for the hearing record.

We very much appreciate the opportunity to present these additional comments, and emphasize, as we did in our oral testimony, that our industry pledges its wholehearted support of the basic objective of the legislation under consideration.

We endorse Chairman Muskie's statement at the start of the hearings, in which he spoke of being impressed by how much general agreement exists on the specific points in the pending bills. He went on to note that the real question was not what will we do about pollution, but how will we do it.

We offer the following comments in the sincere hope that they will be a hepful contribution toward resolving the question of how we, as a nation, can even more productively continue our efforts to achieve cleaner waters.

GRANTS FOR CONSTRUCTION OF TREATMENT WORKS

Nearly every state faces an urgent need for new or expanded municipal treatment facilities, and, of course, a particular need for the funds to build such facilities.

If a national goal of more rapid cleanup of polluted waterways is to be met. the federal government must be ready to provide the necessary funds for these grants.

The proposed amendments to Section 8 of the Federal Water Pollution Control Act contained in both S. 523 and S. 1013 are designed to provide adequate funds for existing needs. But funding authorizations are not enough. The true test of Congress' concern for cleaner waters will come when appropriations are considered. In view of the significant municipal waste discharges into the nation's waters, appropriations must be reasonably close to authorizations or municipalities will not be able to treat wastes effectively and a major gap will exist in the nation's water quality control effort.

We strongly urge the adoption of the general approach of S. 523 in regard to grants for waste treatment works (specifically Section 8(e). It is consistent with past actions of the Congress which have encouraged river basin planning and the establishment of joint municipal-industrial waste treatment facilities wherever possible in order to avoid unnecessary proliferation of treatment plants.

In contrast, Section 8(a) (2) (I) of S. 1013 would drastically change the rules under which grants for joint treatment facilities are now made. Substantially higher costs would be imposed on industry, thus discouraging participation in joint treatment ventures.

We do, of course, favor a system of charges to assure that each user of a municipal treatment plant pays his fair share of operation and maintenance costs. Both S. 523 and S. 1013, in the sections referred to, require this. S. 1013, Section 8(a) (9), however, defines "industrial wastes" in such a way as to eliminate from the responsibility of shouldering user charges some industries and businesses that could be a source of greater pollution than others. Companies in manufacturing industries identified in the Bureau of the Budget's 1967 Standard Industrial Classification Manual would have to foot part of the treatment bill, while others not so identified could get a free ride.

S. 523 requires, very appropriately, that each user participate equitably in the non-federal construction costs of treatment facilities and in the costs of their operation and maintenance.

Both bills require the state to provide adequate reserves to offset the cost of future treatment works, but only S. 1031 requires such reserves be created from user charges. We support this latter provision of Section 8(a) (2) (I) which would require user charges to be set aside to underwrite not only future expansion and replacement costs but also assure adequate operation and maintenance.

EXTENSION OF WATER QUALITY STANDARDS TO INTRASTATE WATERS

The requirement in both S. 523 and S. 1014 that water quality standards apply to intrastate waters as well as interstate waters is a development that could dilute the authority of the States and possibly lead to friction between the States and the federal government on decision affecting economic growth within the States.

The landmark water pollution legislation-the Water Quality Act of 1965recognized the need for the involvement of all levels of government but assigned primary authority for development, implementation and enforcement of water quality standards to the individual States.

The States must continue to play a primary role in water quality, even as our nation's pollution laws become broader and more rigorous. While we recognize the necessity of extending water quality standards to cover all waters in a State, we urge Congress to make sure that the vital role of the States in this process be stressed.

It is essential not to risk diluting State incentive or authority, in order to make maximum progress toward cleaner water. In the period since the Water Quality Act of 1965 the States have acquired and trained increasingly experienced and competent staffs. The nation is just begining to benefit from this investment of effort, time and money. To transfer major responsibility to EPA can only mean lost momentum and benefits while EPA goes through the same time-consuming organizational process. We urge that the legislation as finalized or the accompanying report include language to preserve the States' primary role in water quality administration.

EFFLUENT REQUREMENTS

The adoption and enforcement of effluent requirements, as proposed in S. 523 and S. 1014, are designed to strengthen the State role in pollution abatement. Thus we support this proposal to the extent that "effluent requirements" mean

59-068 0-71-pt. 2-11