Section 313 of the act specifically requires Federal agencies engaged in activities which result in the discharge or runoff of pollutants to comply with all Federal, State, interstate, and local requirements respecting control and abatement of water pollution. Under section 208(b) of the act, States must develop areawide waste treatment management plans for designated areas which include procedures and methods to control to the extent feasible construction activity related sources of pollution.

Consequently, the control system for Federal nonpoint sources of pollution provided by sections 208 and 313 reflects the decision of Congress to place primary responsibility for the control of nonpoint sources of pollution with the States.

The preceding discussion of our relationship with other Federal agencies leads naturally to the second question posed at the outset: the effectiveness from the Environmental Protection Agency's viewpoint of the impact statement process in insuring that environmental considerations are fully weighed as part of the decisionmaking process in stream channelization projects. This question breaks down into two components: the quality of the statements themselves, and the degree to which our comments are reflected in the final plans of the agency constructing the project.

In regard to the first point, while the quality of the statements as a whole is improving, many impact statements we receive continue to lack the kind of scientific documentation that can serve as a real basis for predicting a project's environmental effects. We hope to help remedy this through a series of impact statement review guidelines that are being prepared for the use of the Environmental Protection Agency personnel. It is hoped that these guidelines will also prove valuable to the construction agencies in preparing their impact statements. The first set of guidelines on highway projects is in draft form and work on channelization guidelines will be commenced with the final release of the Council on Educational Quality channelization study.

A further ingredient of the problem is our ignorance. We don't know the longterm impact of these projects. In our mind this not only demands a policy of prudence in undertaking these projects, but also should compel the construction agencies to initiate long-term studies to document these changes.

I would like to call the committee's attention to one further deficiency that is largely conceptual in nature. This is the failure to consider nonstructural flood plain management as an alternative to proposed flood control projects. This failure extends not only to considering alternatives to the project itself. It involves a failure to consider the secondary effects of the projects-to evaluate such large-scale transformations in land use as the conversion of wetlands or bottom land hardwood forests to agricultural and commercial production that frequently follow in the wake of channelization projects.

By ignoring these secondary effects, some agencies have explained that channelization projects do not involve an "irretrievable commitment of resources" under NEPA. The basis for this is the claim that over time untended channels approach their original condition. However that may be, this explanation completely ignores the disappearance of wetland areas that accompany channelization. We feel that control of these secondary effects through flood plain management should be considered and documented as alternatives in the impact statement process, both as an alternative to the project, and as an adjunct to such projects in minimizing secondary effects.

A collateral problem that arises from this failure to adopt a larger perspective is that the cumulative effects of these channels are not fully considered. One project serves to create the need for another, thus effectively committing the Government to a continuing program. Certainly, a project's long-range implications for the entire watershed area should be evaluated at an early stage in the impact statement process.

As something of a sidenote, the subcommittee has asked us for our opinion of the use by the construction agencies of economic justifications for projects under the heading of "environmental impacts." Although we do not always concur with much of the reasoning that occurs within such justifications, we do not in principle object to their inclusion. It is this portion of the statements that often detail the secondary impacts of the project. Although we would encourage more analysis in these sections, valuable information is frequently derived from the inclusion of these economic justifications.

In approaching the second part of the problem, the degree to which our comments are embodied in the final impact statements and plans of the construction agencies, I can say that to date we feel we have received inadequate feedback, but we are unable to make a definitive judgment at this time.

In order to provide answers to precisely this question, the Environmental Protection Agency's Office of Federal Activities, which is responsible for managing the review of these statements within the Evironmental Protection Agency, initiated an internal management study in November of 1972. The first objective of the study is to identify and quantify the types of substantive comments our Agency has been providing in its draft statement comments. The second phase, which will be undertaken following completion of the first, is to study a selected range of final statements and determine the degree of responsiveness to our comments. Perhaps at your next set of hearings, or during the interim, we will be able to give you a more complete rundown on the degree of responsiveness with which our comments have been received.

In concluding, I should like to address the question posed by the issue paper which asks if this Nation should continue to ignore the harmful effects of channelization. The obvious response is not only that we should not, but that we have not. Our comments on the Starkweather project, included in the subcommittee's materials, are indicative of the strong position we are taking on a case-by-case basis in regard to channelization. We are also revamping our impact statement review process to provide for evaluating the extent to which our advice is being listened to.

Thank you, Mr. Chairman, I would be pleased to answer any questions you might have.

Mr. REUSS. Thank you, Dr. Greenfield. Mr. Berg?

STATEMENT OF NORMAN A. BERG, ASSOCIATE ADMINISTRATOR, SOIL CONSERVATION SERVICE, U.S. DEPARTMENT OF AGRICULTURE; ACCOMPANIED BY WILLIAM B. DAVEY, DEPUTY ADMINISTRATOR FOR WATERSHEDS; JOSEPH W. HAAS, ASSISTANT DEPUTY ADMINISTRATOR FOR WATERSHEDS; LAWRENCE V. COMPTON, CHIEF BIOLOGIST; MELVIN M. CULP, CHIEF, DESIGN BRANCH; RICHARD B. PARKER, ECONOMIST; MARY GARNER, DEPUTY DIRECTOR, FORESTRY AND SOIL CONSERVATION DIVISION, OFFICE OF THE GENERAL COUNSEL, USDA; AND BEVERLY D. TURNER, JR., OFFICE OF THE GENERAL COUNSEL, USDA

Mr. BERG. Mr. Chairman, in your letter to Administrator Kenneth E. Grant dated February 23, 1973, you requested the comments and views of the Soil Conservation Service on 28 issues and matters for discussion. These items have required lengthy and pointed replies, and our detailed responses are in writing for the record.

[NOTE. The data referred to by Mr. Berg are printed at pp. 28502872.]

Mr. BERG. In the process of developing this country, man has wrought considerable changes in the native American landscape. He felled forests and built roads, canals, seaports, cities, and railroads and mined for coal and other minerals. He plowed land that had always been in the grass or trees. We noted for too long, he marched his row crops up and down hillsides without regard to soil erosion. He irrigated some of the dry lands of the West and drained some of the wetlands of the East and South.

Many of man's actions to help transform this country from a hunting and fishing society to an agricultural society and then to an industrial, urbanized society were harmful to someone's environment. Growing public awareness of this fact led to the beginnings of the conservation movement in the United States in the late 19th century, and later to the creation of my particular agency.

Many of the problems inherited by later generations were a direct

result of these well-meant but often ill-advised practices of the first settlers gullied land, lost topsoil, streams filled with sediment, water courses so clogged that they no longer performed their original functions.

Water management practices for flood prevention were not inventions of the Soil Conservation Service. Much of this work, in fact, was completed several years before SCS was created in the midthirties. By 1930, more than 84 million acres of land had been included in legalized drainage enterprises and about 140,000 miles of waterways and control structures had been installed.

This work has had great impact on the productivity of American agriculture. At one time, for example, fully 25 percent of the State of Illinois was wetland; today that State's agricultural plant produces one-fourth of the corn grown in the United States and leads the Nation in exports of agricultural commodities.

The acres with good water management which were developed between 1850 and 1930 are among the most productive cropland in the United States and the least subject to soil erosion and sediment production. Land and water management is one of the reasons why our agriculture is so productive and why it stays that way year after year. That productivity has enabled us to feed and clothe a large population in our own country and to help keep alive uncounted millions of people in other countries who would have starved without our abundance.

It is to the Nation's advantage to retain this productive land as cropland and to continue to maintain those flood prevention and water management facilities which keep soil moisture right for crops.

The value of this cropland base and the techniques that keep it productive was indicated recently by Secretary Butz in speaking to a group of environmental writers. He said:

For farmers and ranchers to carry out their missions of food production for the consumers of America, and to meet the rising demands of world markets, they must increase rather than diminish both their actual volume of production and their output rate. They need every tool they can find. The results of their efforts will benefit every man, woman, and child in this land-in terms of plentiful, wholesome food supply and in terms of America's leadership role toward peaceful cooperation among the nations of the world. We are entering a dynamic new era for agriculture-we intend to maintain the thrust for expanding new markets. We have everything to gain and nothing to lose least of all, the environment.

I want to make the point that water management is neither good nor bad per se. It can be judged only in terms of the values you want to emphasize, or in terms of the purposes to which you want to dedicate the land.

I would suggest, Mr. Chairman, that the controversy, as Mr. Train has pointed out, which has arisen over channel improvement and other flood prevention measures is but a symptom of a larger and more complex problem-that of determining land use.

Our present method of deciding land use was described accurately by Sterling Brobaker in his book. "To Live on Earth." And I will skip that portion. It is a good quote.

A rational beginning to solving land use conflicts would be afforded by passage of H.R. 4862, the administration's bill to establish national land use policy.

The time for such a policy is overdue. The land use policy approach would be fitting companion legislation to the National Environmental Policy Act, which opened up a new era in decisionmaking. All of us are weighing far more carefully than we have in the past the consequences of our actions upon the natural world. Conflicts that have occurred since 1970 make it clear that NEPA is but a beginning, and that rational, balanced land use policy must follow if environmental concern is to be transformed into meaningful plans for the future of America. But NEPA was quite a beginning.

NEPA describes very well the guiding philosophy of the Soil Conservation Service. SCS has been dedicated to environmental improvement throughout its history. We welcomed passage of this new law and the renewed interest in conservation. We have tried in every way to be responsive to both its letter and spirit. We intend that each of our programs be fully characterized by a commitment to blending the needs of natural resources and the needs of the people and the community.

That commitment fits both the operation of the small watershed program under Public Law 566 and the responsibility of the Soil Conservation Service in administering the prograin.

(1) It is our job to consider the protection and development of all resources, and to work with local sponsors and all other interested parties in trying to achieve the best possible blend of improvements. (2) It is our job to give full weight to man's needs because he is an integral part of the environment.

(3) It is our job, once planning decisions have been made and approved, to see that works of improvement are installed in the right order and the right timing, using the most up-to-date techniques in construction and maintenance to respect environmental values.

(4) It is our job, finally, to evaluate our work periodically and to respond to efforts of interested parties to improve the watershed program.

We carry out those assignments to the best of our ability at every level.

In our evaluations, for example, we have found that in some older projects there was an opportunity based on today's standards and community priorities to reduce or eliminate some earlier planned. channel modification work. We have found that newer construction techniques could be used on some of the work-for example, constructing from only one side, leaving shade trees within the right-ofway, or following the original channel alinement more closely and leaving some oxbows of the original channel to be managed specifically for wildlife.

These changes reflect a dynamic, responsive program. They also reflect responsible action by landowners and local sponsors, who have the biggest stake in the success of a watershed project and put a lot of their time and money into it. When they aggressively work to complete land treatment work; to make their problems and needs understood by local governments and SCS; and to understand the problems and needs of their neighbors, their community, and their State and Nation as a whole, then they help create the best watershed projects for everyone.

Responsibility for good projects, however, does not rest alone with local sponsors and the SCS. Special interest groups, other organizations, and other agencies have assignments, too:

(1) They have the job of making their interests known to local sponsors and SCS in time to assure consideration of their views in project planning to participate from the beginning, not give a critical overview later.

(2) They have the job of looking beyond their own specific interests known to local sponsors and SCS in time to assure consideration of their views in project planning-to participate from the beginning, not give a critical overview later.

(3) They have the job of looking beyond their own specific interests to consider the total needs of a local community, a region, or the Nation.

(4) They have the job of looking at the total program, or a total project, rather than any single aspect of it.

(5) They have the job of seeking and using facts; facing issues squarely and openly; and suggesting viable alternatives for the traditional methods or practices that are not favorable.

Just one example: Some organizations have said that SCS plans to dig up 150,000 miles of natural, perennial streams. The total work planned or constructed since 1954 is 21.000 miles, with 15 percent of that on "natural streams." A third of the modification work in all projects is or is to be on channels that flow only when there is surface runoff. Another third is on channels with intermittent flow. Eleven percent of the work where there is water flow all year is on manmade ditches or channels that were already modified years ago. The rest involves only clearing and debris removal or streambank and grade stabilization.

Facts need to be discussed.

Where the facts are not readily at hand regarding natural resources or the aims of people, we all need to work together to get the facts. It is in this setting that environmental planning through NEPA and land-use policy and planning through the bills now being considered will have to interface. We can help decide what a community has in the way of land and water and other resources and what the community really wants to do with them.

Until some of those basic conflicts in resource use are resolved, there will continue to be spin-off conflicts in specific environmental actions such as watershed projects.

To quote again from the talk of Secretary Butz before the environmental writers:

As Natural Resources Counselor, my philosophy will be that all of us must search ceaselessly for the solid common ground between economic interests and environmental concern. It will serve neither side to perpetuate the polarization that exists. Furthermore, this is a false separation because a vibrant economy and inventive technology are basic prerequisites to solving our environmental problems.

I believe we must forge a practical, commonsense, working partnership between man's technology and the ecology of nature. That will require technology attuned and responsive to environmental needs; it will require a new breed of ecologists who are able and willing to collaborate early with the engineers, well before the new powerplant or airport or highway interchange is built.

The Soil Conservation Service is committed to a practical, commonsense, working partnership with all who have an interest in preserving and using the natural resources of this Nation.