Coordination Act of 1934 is designed to more fully protect the wildlife interests of the Nation in connection with future construction programs, largely in the nature of flood control and power dams." (See page 3, Hearings before the Committee on Agriculture, House of Representatives, 79th Congress, 2d Session, on H.R. 3821 and H.R. 6097.) Similar references to power dams, flood areas and reclamation projects are made throughout the hearings.

There is, of course, nothing to preclude a district from requesting the assistance of the Fish and Wildlife Service whenever it is deemed desirable, but we find nothing in the provisions of the act which requires that the Fish and Wildlife Service be consulted before the district undertakes drainage operations. The file which was informally referred to us is attached.

Sincerely yours,

Attachment.

W. CARROLL HUNTER, Solicitor.

Mr. FINNEGAN. Mr. Reed, you mention on page 3 of your statement the 108 review of channelization projects. Can you tell us what some of the deficiencies are that you have found in that review of the projects?

Mr. REED. We just do not think that basic environmental data have been provided in all cases, Mr. Finnegan. I refer to it a number of times in the statement-that we think a biological assessment is mandated by the NEPA, but is not available to us for proper assessment purposes, and that is one of the major weaknesses of the environmental impact statement process to date. I concur with Mr. Berg's statement that the SCS is attempting to upgrade their 102 processes and I congratulate him and the Service for that.

Mr. FINNEGAN. Again, on page 5 of your statement, you mention a difference of fact concerning the number of miles of stream scheduled to be channelized and I understand that SCS recently compiled an inventory of the channelization work planned and completed. Did your agency participate in that?

Mr. REED. No, we did not.

Mr. FINNEGAN. SCS stressed that only about 3,200 miles of natural streams out of 200,000 miles of streams would be affected by channelization. They concluded-they seemed to conclude anyway-that channelization of the remaining streams would not be detrimental or should not be given as great an importance. Do you agree with that statement? Mr. REED. No, sir. I cannot say that categorically. It has been said. this morning, by Chairman Train and by Dr. Greenfield, that much of this should be and must be interpreted on a project-by-project basis. There is no such thing as a good or bad stream channelization. For every action, there will be a reaction, and each and every individual case must be studied on its own merits. This is not a simplified situation. This is a very complex environmental problem, and one on which simplified answers fall far short of the mark.

Mr. FINNEGAN. Is it true that the so-called manmade streams or those which were changed by man, years ago, have had substantial growth of vegetation, and are now equivalent, or nearly equivalent, to a natural stream?

Mr. REED. Mr. Finnegan, I have been on an old channelized stream, sections of which have totally recovered and which have regrown in a number of different States. The areas that the SCS has inventoried contain some of those areas. They contain other areas of natural drainage leading into other areas, which they wish to modify. I cannot say that it is 100 percent previously manmade. There are a lot of natural areas involved in this, case-by-case.

Mr. FINNEGAN. Your agency's October 1972 report on SCS projects shows a high priority given for this fiscal year on 152 projects in 37 States, and I think the channelization plan was about 5,700 miles. Your report indicates, though, for example, that in Louisiana there are over 1,400 miles of channelization. Your attempts to get work plans changed there were not very good, while in North Carolina this was not the case. Is this a problem in working with the State conservationists, or was it something else?

Mr. REED. Yes, sir; it is a problem working with the sponsors in the States and the State conservationists.

Mr. FINNEGAN. Do you have any suggestions on how this problem could be resolved?

Mr. REED. I have a number of suggestions but Mr. Berg and I are attempting to work them out, and I think we are going to make significant progress this year.

Mr. FINNEGAN. Can you tell the committee some of those suggestions,

sir?

Mr. REED. Well, I think the courts have given us a mandate in 102 areas, which I think are pertinent to our discussions with the State conservationists. I think this will reinforce the fact that if we want to avoid lengthy litigation the alternatives mandated under the NEPA are going to have to be clearly spelled out. This has been a difficult process. I think it is only fair to have the record very clear on this, but it has been a difficult process for the development agencies. The court cases have come with a great rapidity at the same time agencies were trying to learn how to implement their basic understanding of NEPA. We are in an evolving situation with more court cases expected in the near future, which may shed more light on the continuing process of trying to learn to live within what seemed at the time a very simple act, but which turned out to be a very complex system of having to analyze what we do before we do it.

Mr. FINNEGAN. In January of 1972, your Department issued a revised "Policy and Guidelines for the Planning and Review of Stream Channel Alteration Projects." Are those guidelines still in effect, and if so do you plan to keep them in effect?

Mr. REED. Yes, sir; they are in effect and I do plan to keep them in effect.

Mr. FINNEGAN. Would you be publishing them as a policy statement in the Federal Register?

Mr. REED. That is to be discussed with the Secretary, and depending upon his advice on that subject, we will take the steps indicated. At the moment, they are before the Bureau.

Mr. FINNEGAN. Has the SCS commented on those guidelines at all? Mr. REED. Yes.

Mr. FINNEGAN. Mr. Berg, could we have a copy of those comments? Mr. REED. I think they have only commented, in fairness, in SCS in a very generalized way and I think the way we left it, is that we look forward to sitting down in the near future and going over pertinent areas of conflict.

Mr. FINNEGAN. That is fine. But, can we have a copy of whatever comments were provided?

Mr. BERG. The request of Secretary Reed and the Department of the Interior came to our Secretary and we provided the comments for his reaction.

Mr. FINNEGAN. I see. But did you have any written comments or letters that you had sent to Interior?

Mr. BERG. Mr. Davey, what is the status?

Mr. DAVEY. Yes; comments have been forwarded to the Department of the Interior, specifically on these guidelines.

Mr. FINNEGAN. Would you provide us a copy of those?

Mr. BERG. The answer is, yes.

Mr. DAVEY. If Mr. Reed has no objection, we have none. Mr. Reed, do you have any objections?

Mr. REED. No.

[SUBCOMMITTEE NOTE.-The Bureau of Sport Fisheries and Wildlife's "Policy and Guidelines for the Planning and Review of Stream Channel Alteration Projects"-Revised, January 18, 1972, and agency comments thereon are printed as app. 36, p. 3279 of this hearing.]

Mr. FINNEGAN. Mr. Reed, what is the Bureau's budget for reviewing channelization projects for fiscal years 1973 and 1974?

Mr. REED. It is very hard to break any funding figure out of the river basins and migratory waterfowl programs. As best I can calculate, on all small watershed projects, the Bureau expended $494,000or simply stated, for every $100 spent on planning and construction of watershed projects, we spent 39 cents on environmental evaluation.

Mr. FINNEGAN. So that you have spent a very small portion of the amount in comparison to the amount of actual money?

Mr. REED. We have a very, very narrow funding base, which I hope will be helped in our new search for priorities within the Bureau. We have sent forward to the Congress a budget this year which reflects our getting out of some things we have been doing a long time, for not very good reasons. If the predatory control bill passes and turns that responsibility over to the States, which I testified on yesterday, it will give us an opportunity to reallocate resources. And one of the primary areas of reallocation would be in river basin.

Mr. FINNEGAN. Is it fair to say that channelization encourages landowners to drain adjacent lands and to change their use-particularly wetland areas?

Mr. REED. Well, Mr. Finnegan, again without getting into specific instances, we are on dangerous ground in generalizations and you recognize the problems of that. That is too broad a brush for me.

Mr. FINNEGAN. All right. I just want to ask Dr. Greenfield one final question.

The SCS said, in its statement to us, that channel improvement facilitates the transport of dissolved nutrients downstream and ultimately to the ocean where they are needed to sustain various forms of marine life. Do you agree with that statement?

[NOTE.-See pp. 2850-2872 of this record.]

Dr. GREENFIELD. No. Once again, there may be cases where this occurs. But, in general, I think what you are doing is just moving the problem downstream because, obviously, what you have done in the channelization is increased the velocity and increased the ability of the stream to carry various substances. But, as soon as the velocity decreases, as when the stream enters a larger lake or what have you, then the stream drops the substances at that point and you start to increase sedimentation and siltation. You have just transferred

that whole nutrient enrichment problem, along with the sedimentation, downstream to where it settles out.

Mr. FINNEGAN. Thank you. No further questions.

Mr. REUSS. Mr. Steelman?

Mr. STEELMAN. Thank you, Mr. Chairman.

General Kelly, I have two areas that I would like to explore with you-one having to do with the general philosophy of the corps as regards channelization, and the second one having to do with a specific project.

As a matter of information, do you consider in a technical sense that canals and channels are the same? Can we discuss this question and use those two interchangeably?

General KELLY. I think a lot would depend on what your question about them is. They certainly have a lot in common in that they are both watercourses, but their purposes are basically different. But, they have certain similarities as well.

Mr. REUSS. If I may interrupt for just a minute. Dr. Greenfield, I have been told that you have an appointment uptown and we will be very happy to excuse you right now. Is there somebody else from EPA here?

Dr. GREENFIELD. Yes; I have at least three other people here.

Mr. REUSS. If something comes up we can address our questions to them. Thank you very much for your help.

Thank you, Mr. Steelman.

Mr. STEELMAN. During my questioning, I will use the two terms interchangeably, and if I am off course anywhere-no pun intendedwould you let me know?

There are three categories, I understand, where corps projects, with regard to their financing, stand. One would be those that have been authorized by Congress but to which no engineering and design money has been applied, nor construction money. That would be the first category.

The second category would be those which have been authorized and are in the process of engineering and design, but have received no con struction money. And the third would be those which have been authorized, the engineering and design have been completed, and the first construction dollar has been committed to them.

How many corps navigation projects are there around the country falling into these three categories?

General KELLY. I would like to provide the specifics for the record, sir. I just do not happen to have that data with me. But, for instance, in the latter category, we are talking about the 300 range.

Mr. STEELMAN. In the latter category-that being all three phases are complete?

General KELLY. No. Projects that are under construction-about 350 total.

Mr. STEELMAN. Channelization?

General KELLY. No; that is total and you mentioned navigation specifically. That is total. That would be all of our active projects. The other numbers I will just have to supply. They are considerably larger than that but I just did not have them.

Mr. STEELMAN. OK. For my purposes and the purposes of the record,

would you supply us with how many total corps navigation projects are in any of these three stages?

General KELLY. By "navigation," do you mean "channelization"? Mr. STEELMAN. I mean navigation.

General KELLY. Yes, sir.

[By letter of March 29, 1973, General Kelly submitted the following table on authorized active navigation projects of the Corps of Engineers:]

1 There are 4 other projects in this category classed as multiple purpose including power, which incorporate a lock and dam to serve navigation, but allocable costs have not been included in the dollar totals.

2 There are 11 other projects in this category classed as multiple purpose including power, which incorporate a lock and dam to serve navigation, but allocable costs have not been included in the dollar totals.

Note: Category I-Authorized, yet no advance engineering and design or construction funds appropriated. Category IIAuthorized, advance engineering and design complete or underway. Category III-Authorized, under construction.

Mr. STEELMAN. On page 1 of your testimony there is a quotation from a statement by General Koisch, and I will read:

The real conflict for planners such as the corps and for the decisionmakers in Congress is the reconciliation of the undisputed needs for conserving our natural resources for the benefit of mankind now, and in the future, with the economic demands of our growing population and its affluent standard of living and the extension of economic well-being to the poorer members of our population.

My experience over the years has been that there is less philanthropy here than your statement would imply, and more special interest benefits that are keeping the corps working and benefiting those who have land investments involved. And, in that vein, I would like to ask you whether in your cost-benefit analysis you assign a particular costbenefit ratio to a project and imply, therefore, that those people who are paying for the project, likewise, will reap whatever benefit you assign to it. It seems to me, for example, if we are assigning a 1.5 to 1 cost-benefit ratio in a project, you are implying that the taxpayers who are being looked upon for the finance in these areas are, likewise, going to reap all of that benefit. Now, we, I think, know that is not true. The cost of the projects are borne by the taxpayer, and the special interest picks up the benefit. Would you agree with that statement?

General KELLY. That is rather a broad statement to agree with, sir. I understand what you said. I would say that the law which put us into the flood control business is rather pertinent. It is quite lengthy