The Water Pollution Control Federation was established in 1928 as a non-profit, technical membership organization. Its objectives are to advance the fundamental and practical knowledge of all aspects of water pollution control by the dissemination of technical knowledge through publications, technical conferences, improvement of the professional status of those engaged in the field, promotion of public understanding and participation, and encouragement of the adoption and implementation of sound regulations aimed toward effective water pollution control. The more than 22,000 member-subscribers in more than 79 countries throughout the world receive the JOURNAL and HIGHLIGHTS on a monthly basis. Member associations represent Australia, Canada, Germany, India, Israel, Italy, Japan, Mexico, The Netherlands, New Zealand, Philippines, Puerto Rico, Sweden, Switzerland, United Kingdom, Venezuela, and all of the 50 United States. Publishers of: • JOURNAL WATER POLLUTION CONTROL FEDERATION • HIGHLIGHTS with DEEDS AND DATA for wastewater collection system and treatment plant personnel • Manuals of Practice • Operator Training Aids Safety Promotional Materials • Proceedings of the 3rd International Conference on Water Pollution Research • Other Special Publications 10M-11-70 For Further Information Contact: WATER POLLUTION CONTROL FEDERATION 3900 Wisconsin Ave. Washington, D. C. 20016 Telephone: (202) 362-4100 PRINTED IN THE USA Senator EAGLETON. We have one additional witness that we would like to hear, Mr. Charles C. Johnson, Jr., on behalf of the American Public Health Association. Mr. Johnson. STATEMENT OF CHARLES C. JOHNSON, JR., ON BEHALF OF Mr. JOHNSON. I thank you, Mr. Chairman, for working me into this morning's testimony. I have a prepared statement that I would submit to you for the record. I would like to paraphrase some aspects of that statement. Senator EAGLETON. Your full statement will be made a part of the record after your testimony. Mr. JOHNSON. Mr. Chairman, I represent the American Public Health Association as associate executive director. For many, many years, I was in the Public Health Service. I last served there in January. My last position was the Administrator of Environmental Health Service. I come before you today to speak for the many health professionals that feel that the environment in many respects is basically a concern for man's health. There are some 25,000 health professionals in our organization. This is amplified by another like amount of people that aline themselves with us as affiliated organizations. First, I would like to say that we applaud the action of the Congress and administration to support and broaden the objectives of water pollution control. While we note differences in the approaches that would be taken to achieve the objectives that are stated, we will not take time today to interject our specific comments on these differences. Instead, we would like to note some principles which we believe should be covered in final legislation that is passed and, second, we would like to discuss what we believe is a paramount deficiency in the proposals that are before us today. That is, the failure to recognize and support the need for basic and applied research with respect to health effects. Such research is essential for the realistic development of water qual ity criteria and standards. Mr. Chairman, the objective of our organization has for the last 98 years been to further the protection and enhancement of the public health and well-being. The development of strong legislation to protect the water environment can be an important tool in man's arsenal to help achieve this objective. Thus, we are pleased to recognize the strong efforts put forth to consider protecting and enhancing all aspects of the water environment to the maximum benefit of man. To this end, we wish to encourage legislation that incorporates among other things these concepts: 1. The requirement that any comprehensive program for water pollution control include measures which are necessary to assure protection of the public health and well-being. 2. To approve the State or agency plans and construction grants on the basis of approval water quality standards. 3. The encouraging of comprehensive planning and the development of comprehensive water pollution control programs based on the water resource needs in the total river basin. 4. The provision of specific time limits for development of State or agency plans, water quality standards, and effluent limitation standards if they are included. 5. A provision which supports nondegradation and enhancement of the water environment. 6. Requirement to develop a self-sufficient capability for continued operation, maintenance, and expansion of facilities aided by the act. 7. Encouraging of provisions for reimbursement from municipal treatment of industrial waste. 8. Provision of the most expeditious implementation of enforcement procedures commensurate with ultimate appeal opportunity to protect against malicious or capricious action. 9. Provision of delegation for monitoring, inspection, and other responsibilities to the States when they are determined to be equally as responsible as Federal Government for carrying out this type of action. 10. Provision for rapid action and injunctive relief when the public health and welfare is believed to be in jeopardy. 11. A provision for direct action by enforcement authority when prohibited, hazardous substances are being discharged to the water environment. 12. The encouraging of international cooperation in matters associated with protection of the water environment. 13. A provision for penalties whenever an enforcement action is required, including instances when permits systems are instituted. 14. A provision which requires a periodic report to the Congress with respect to operations under the act. I said that our primary concern was the concern of the water quality criteria and standards provision of the act. In far too many communities, one man's sewage effluent is another man's drinking water supply, swimming hole, fishing ponds, and the like. It is pleasing to note that the proposals that we have here place a great deal of emphasis on the protection of the public health. Yet, there exists in our opinion a possibility for the expenditures of large sums of money without really knowing whether what we have constructed, is sufficient unto the need. As a matter of fact, it is this failure to provide for establishment of: (1) A sound technical and scientific basis for describing the extent of the need; and (2) A surveillance and monitoring system for evaluating the success or failure ascribed to these efforts associated with water pollution control programs that is our cause for concern. I think if we were to give careful consideration to this that we would see that we need to develop a very sound scientific basis in terms of basic and applied research that is necessary for the development of any water pollution control effort. Even then we must make special effort to assure ourselves that the needs of people and not physical facilities remain in the forefront of our water pollution planning. In this regard, I am pleased to see that we do have at least in words the basis for the development of this type of program. But the development of water quality criteria and standards, in my opinion, is the heart and most significant factor in the water pollution control process. If this is true, it is most disappointing to find that the authorization for research funds covering this factor have at worst not been extended and at best extended for only 1 year. Further, it is noted that no funds at all have been mandated for health effect research. We ask, What is the basis for the establishment of water quality standards, how do we determine the degree of efficiency to assign to sewage treatment plant, or what treatment requirements can reasonably be left to the water treatment plant? How do we know which standards are satisfactory for swimming or other recreational pursuits? How do we know how the Administrator evaluates effectiveness of State or agency plan in terms of health and well-being; or determines the most serious pollution problem in setting priorities or establishing regulations providing for specifications for effluent standards; or many other requirements that are contained in the proposals in the absence of essential knowledge associated with today's situations which is surely to worsen by continuing technological and industrial progress in this country. Not only is there a dearth of scientific knowledge in these areas of concern; even if the proposals required evaluation of all situations, agencies would be hard pressed to proceed in the absence of reliable scientific tools required for such evaluation and assessment. În our opinion, we are then left to a shotgun approach in a hope that these efforts and results will be worth the cost. In my testimony, my prepared statement, Mr. Chairman, I list a number of areas in which I think there is without question a need for additional research. I give statements of others that support our opinion in this regard, and I state further that it is certainly not our desire to say that we cannot move ahead with the kind of water pollution control program that is envisioned in these proposals. I think we must move ahead. But I think we must recognize that we are doing so in the absence of or with insufficient knowledge and scientific background that is really needed to assure the American public that they are indeed getting a full dollar measure of value for the dollar expended in the construction process. I hope I will awaken some concern on your part for this concern of ours and perhaps something can be done to assure that not only do we progress in the construction area but we progress in a way that assures us that the public health is indeed being protected and that we are continuing to construct our treatment plants to meet a total need, the needs of the people, and the needs of our future generations. Thank you. Senator EAGLETON. Thank you very much, Mr. Johnson. (Mr. Johnson's prepared statement follows:) PREPARED STATEMENT OF CHARLES C. JOHNSON, Jr. Mr. Chairman and members of the committee, I would like to express my pleasure and the pleasure of the American Public Health Association in being invited to appear here before you today. The American Public Health Association has a membership of approximately 25,000 health professionals. Interlocking affiliates at the State and local levels brings an equal number of people into the overall organizations. The members come from all walks of life, but they have one characteristic in common. For almost a century, the Association has worked to improve the health and well-being of people. Despite all of the pronouncements, dialog, and reorganization activities, it seems to us that the APHA, as a single organization, today comes closest to really representing all facets of the interrelationships between man's health and well-being and his environment. It is against this background that we have evaluated and will comment on the proposals contained in S. 523, S. 1012, S. 1013, S. 1014, and S. 1015 for amending the Federal Water Pollution Control Act, as amended. First, let me say that the Association applauds and supports the broad objectives put forth by these proposals to expand and strengthen the water pollution control efforts on the part of the Federal government in cooperation with state and regional agencies. And while we note differences in approaches that would be taken to achieve these objectives, we do not choose to interject our specific comments on these differences at this time. Instead we will first note some principal areas which we believe should be covered in final legislation which is passed, and second will discuss what we believe is a paramount deficiency in the proposals before us today, i.e. the failure to recognize and support the need for basic and applied research with respect to health effects. Such research is essential for the realistic development of water quality criteria and standards. Mr. Chairman, the majority objective of our organization is furthering the protection and enhancement of the public's health and well-being. The development of strong legislation to protect the water environment can be an important tool in man's arsenal to help achieve this objective. Thus we are pleased to recognize the strong efforts being put forth to consider, protect, and enhance all aspects of the water environment to the maximum benefit of man. To this end, we wish to encourage legislation that incorporates among other things the following concepts: 1. The requirement that any comprehensive program for water pollution control include measures which are necessary to assure protection of the public health and well being. 2 The approval of State or agency plans, and construction grants on the basis of approved water quality standards. 3. The encouraging of comprehensive planning and the development of comprehensive water pollution control programs based on the water resources needs in the total river basin. 4. The provision of specific time limits for the development of State or agency plans, water quality standards and effluent limitation standards. 5. A provision which supports nondegradation and enhancement of the water environment. 6. The requirement to develop a self-sufficient capability for continued operation, maintenance and expansion of facilities aided by the act. 7. The encouraging of provisions for reimbursement for municipal treatment of industrial wastes. 8. The provision for the most expeditious implementation of enforcement procedures, commensurate with an ultimate appeal opportunity to protect against malicious and capricious action. 9. A provision for delegation of monitoring, inspection and other responsi bilities to States when they are determined to be as capable as the Federal government to carry out such responsibilities. 10. A provision for rapid action and injunctive relief when the public's health and welfare is believed to be in jeopardy. 11. A provision for direct action by enforcement authority when prohibited, hazardous substances are being discharged to the water environment. 12. The encouraging of international cooperation in matters associated with protection of the water environment. 13. The prohibition against awarding government contracts to convicted violators of water pollution control regulations until such regulations have been complied with. 14. A provision for penalties whenever an enforcement action is required, including instances when permits systems are instituted. 15. A provision which requires a periodic report to the Congress with respect to operations under the Act. Let us turn now to a discussion of water quality criteria and standards. In far too many of our communities one man's sewage effluent is another man's drinking water supply, swimming hole, fishing pond, etc. Thus, it is pleasing to note that the proposals we are considering here today recognize the need to consider the water environment as a total system. We note also, that substantial |