United States
               Environmental Protection
               Agency
               Office of
               Research and Development
               Washington D. C. 20460
EPA-600/9-80-009
March 1980
               Office of Environmental Engineering and Technology
               Energy Alternatives
               and the
               Environment 1979
EPA
600/
9-
80-
009
c.2
The Public Reviews
The Federal Nonnuclear
Energy RD&D Program

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PA/
                      transcript from the National Hearing on

                      The Federal Nonnuclear
                      Energy RD&D Program
                      conducted on
                      October 3, 4 and 5, 1979
                      Office of Personnel Management Auditorium
                      Washington, D.C.
                            Snvlronaemtal Protect Ion A««»J
                               Room 2404  P--2U-1
                      sponsored by
                      The Office of Environmental Engineering and Technology
                      within the Office of Research and Development
                      United States Environmental Protection Agency

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Foreword
      Section 11 of Public Law 93-577, the Federal
Nonnuclear Energy Research and Development (R&D)
Act of 1974, directs the responsible agency to carry out
a continuing review of the Federal Nonnuclear Energy
R&D Program to evaluate its adequacy of  attention to:

      (a)   energy conservation methods,  and

      (b)   environmental protection and the
           environmental consequences of the
           application of energy technologies.

President Carter's Executive Reorganization Plan (77-1)
transferred responsibility for this review from  the Council
on Environmental Quality to the Environmental Protec-
tion Agency. The Office of Environmental  Engineering
and Technology within EPA's Office of Research and
Development has been assigned the responsibility for
conducting  the review.

      "Section 11" requires EPA to hold yearly public
hearings as  part of its R&D review responsibilities. This
report presents the edited transcripts of a National
Hearing on the environmental conservation aspects of
the Federal Nonnuclear Energy R&D Program held
October 3-5, 1979 in Washington DC. Information
acquired at the Hearing will be of particular value as a
mechanism for surfacing problems and issues in Federal
Nonnuclear Energy R&D. EPA plans to improve the
understanding of these problems  and issues, to confirm
their significance and to further explore their dimensions.

      Readers of this report may wish to comment on
the issues presented here or on other issues concerning
the non-nuclear R&D program's adequacy of attention
to energy conservation and environmental protection.
We would greatly appreciate receiving such comments.
Please send them to:

      Section  11 Coordinator
      Office of Environmental Engineering and
        Technology (RD-681)
      U.S. Environmental Protection Agency
      Washington DC 20460
                                                     Steven R. Reznek
                                                     Deputy Assistant Administrator
                                                     for Environmental Engineering and Technology
                                                 iii

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 Table of Contents
     vli NATIONAL HEARING SUMMARY
     1 October  3,  1979

       Morning Session
      1 Introductory Remarks, Dr. Stephen Gage
      2 Further remarks by Dr. Steven Reznek
      2 Further remarks by Ms. Ruth Clusen
      3 Statement of Dr. Gordon MacDonald
      6 Statement of Dr. Toby Anthony
     10 Statement of Mr. Joel Robinson
     14 Statement of Ms. Merilyn Reeves
     19 Statement of Mr. Kevin Markey
    Afternoon Session
 27  Statement of Mr. Macauley Whiting
 30  Statement of Mr. Moss
 33  Statement of Mr. Lowell Endahl
 37  Statement of Mr. Pate
 44  Statement of Dr. Schlesinger
 49  Statement of Ms. Jones
 51  Adjournment
  57 October 4,  1979
       Morning Session
     57 Opening Remarks by Dr. Stephen Reznek
     57 Statement of Dr. Chester Richmond
     62 Statement of Dr. Kenneth Bridbord
     67 Statement 'of Dr. Ralph Perhac
     73 Statement of Mr. Michael Paparian
    Afternoon Session
 79  Statement of Mr. Reynolds
 84  Statement of Ms. Jane MacGregor
 86  Statement of Mr. Richard Pratt
 89  Statement of Mr. Scott Crytser
 93  Statement of Ms. Patricia Pelkofer
 97  Adjournment
103 October 5,  1979

       Morning Session
    103 Opening Remarks by Dr. Stephen Reznek
    103 Statement of Dr. Samuel Morris
    107 Statement of Mr. William Rogers
    111 Statement of Ms. Susan Tachau
    114 Statement of Dr. Neil Seldman
    120 Statement of Ms. Mary Jadiker
    122 Statement of Dr. Allan Hirsch
    126 Statement of Mr. Robert Thomason
    Afternoon Session
129  Opening Remarks by Mr. Gregory Ondich
129  Statement of Dr. David Anthony
135  Statement of Mr. Mark McClellan
140  Statement of Mr. Albert Slap
142  Statement of Dr. Michael Devine
146  Statement of Ms. Lore Keffer
148  Statement of Ms. Edith Chase
151  Statement of Dr. Carl Norbeck
154  Statement of Mr. Michael Seaman
158  Adjournment
159  Addendum

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National  Hearing  Summary
    The Section 11  National Hearing  was held in
Washington, D.C., on October 3, 4, and 5, 1979. The
Hearing panels included the Department of Energy
Assistant Secretary  for  Environment,  representatives
from the Environmental Protection  Agency and the
Council on Environmental  Quality,  and members of
congressional  staff,  environmental  groups,   State
governments,  and  industry.   Thirty-five  people
presented  testimony,  and  an additional  participant
subsequently submitted written testimony. Participants
represented a  broad spectrum of interests, including
industry, environmental organizations, public interest
groups, universities and research laboratories, State and
local government, and the general public. Many of the
participants had attended one or  more of the regional
workshops held earlier this year.
    Prior to the Hearing, witnesses were sent materials
discussing the focus of this  year's Section 11 activities
and  the  major  issues  that  emerged  from the
workshops. * Most of the witnesses addressed one or
more of these issues in their testimony. This report sum-
marizes comments from the National Hearing on seven
key issues and on other topics of interest to particular
witnesses.
evaluate  and  compare all  proposed and available
technologies to determine which ones offer the greatest
potential for meeting our energy needs most econom-
ically and with  the  least environmental risk. Instead,
DOE

   is hardware-oriented; it is not geared  to problem solv-
   ing.  There is no  meaningful competition  among
   technologies within each resource category. There is
   no real  competition among resources in  developing
   national  energy  plans  or determining   budgetary
   priorities.
   (Kevin Markey, Friends of the Earth)

    Witnesses felt that such comparisons of both pro-
duction and conservation options are essential to the
development of a  rational, comprehensive  energy
policy.
    In discussing the importance of performing such
assessments, one witness stressed that

   in evaluating technologies  from an environmental
   standpoint, it is crucial to compare the new technology
   with  that which it replaces or augments, as well as with
   other new competing technologies.
   (Gordon MacDonald, The MITRE Corporation)
1. Nonnuclear Research Priorities

    Many  Hearing  witnesses were  concerned  that
DOE's current nonnuclear RD&D" * policy appears to
favor large-scale, centralized technologies based on
nonrenewable resources. They felt that smaller-scale,
decentralized,  appropriate technologies are not given
the attention or support they merit. Several participants
described in detail the potential lower cost and environ-
mental advantages of alternatives such as solar energy,
recycling, and conservation when these approaches are
compared with the large projects DOE now emphasizes.
Many witnesses felt that there is an urgent need for DOE
to balance its RD&D efforts better if the nation's energy
requirements are to be met, in both the immediate and
the long-range future.
    It did not appear to witnesses that, in setting policy
and  RD&D  priorities,  DOE  planners systematically
 * Environmental Protection Agency, Background Document for
   the National Hearing. EPA 600/9-79-033. September 1979.
* * Research, Development, and Demonstration
2. Objectives of DOE Research, Development,
   and Demonstration

     In one workshop,  considerable time was spent
discussing the role of DOE as an RD&D agency, and
this question  was examined further by several Hearing
witnesses.  Witnesses said that DOE's research  goals
were not clearly articulated. The RD&D program seems
to be heavily oriented toward rapid  commercialization
of technologies rather than toward thoroughly testing
and  examining all aspects of  their  application.  One
witness outlined how  this aspect of RD&D could be
improved:

   What you need is a system which is a little more balanced
   between branches that are building things and branches
   that are considering alternatives,  rather than having a
   whole  agency...whose mission it is to build and second-
   arily to do the best it can with the consequences... You
   need a more balanced situation, where you are setting
   your energy priorities and your environmental priorities at
   the same time and then you look at those on the same
                                                  Vll

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   footings and try to ask, how can we optimize both  of
   these—rather than looking for  the best energy tech-
   nologies and then later worrying about how to  handle
   the environment.
   (Richard Pratt, Pennsylvania Sierra Club)

     Both this witness and other participants felt that
technical and environmental research should be more
closely linked and that DOE efforts in both areas should
be designed  to provide the greatest amount  of data to
be used in decisionmaking. Another witness reinforced
this idea:

   1  think  the need has to be stressed for experimental
   facilities which test not only the technological capability,
   but also the environmental issues....There's also  a need
   to emphasize decisionmaking  systems which  focus on
   incremental and adaptive decisionmaking to the greatest
   extent possible, rather than go/no-go decisions,  so that
   we can reflect,  as we move through various steps, the
   findings  of environmental research,  assessment,  or
   monitoring.
   (Allan Hirsch, U.S. Fish and Wildlife Service)
3.  Project Management and Review

     Witnesses felt  that  DOE's project management
system, which requires top-level review only of projects
involving major Federal investment, was also a  prob-
lem. Projects that do not require large outlays of capital
are managed at lower levels and therefore may  never
have their potential benefits seriously  considered by
DOE policymakers.  Witnesses believed that this lack of
attention to smaller projects reinforces a bias toward
high-technology solutions to energy problems. There-
fore, although witnesses recognized that not all projects
could be monitored regularly by top officials, they felt
that cost should not  be the primary criterion for selecting
projects for senior management review.

   The uniqueness of environmental or health considera-
   tions, and potentiality of a system should also be examined.
   (Chester Richmond, Oak Ridge National Laboratory)

     Further,  witnesses felt  that this top management
review should not be limited to determining whether a
technology is technically feasible, the cost is acceptable,
and the environmental effects are manageable; it should
also include  comparison with  alternative technology
options,  i.e.,  it should  review all  feasible  options.
Criticism of the review process included the opinion that

   the PPMS review process does not take into considera-
   tion alternative small-scale technologies when it evaluates
   a particular major  system technology. In other words, it
   does not consider other ways to obtain the energy which
   is proposed for production by the technology under con-
   sideration.
   (Susan  Tachau,  National Center  for  Appropriate
   Technology!
The witness added the consideration that

   if technological alternatives are not reviewed, then energy
   conservation possibilities will not be addressed, nor will
   appropriate technologies or other alternatives be addressed
   which might produce the same amount of energy more
   economically than the  large-scale  technologies  being
   considered.
   (Susan  Tachau,  National  Center for  Appropriate
   Technology)


Another witness contended that

   The complex procedures which were established by DOE
   to guide technology expenditures, the PPMS, appear to
   fail  to provide for adequate evaluation  of alternative
   actions on programs...By the time the DOE staff has
   committed large  amounts of time and financial resources
   to a particular project... it is  almost too late to address
   alternatives adequately in an EIS.
   (Marilyn Reeves, League of Women Voters of Maryland)

     To  ensure that alternatives are  adequately con-
sidered  in policymaking and  project  management,
several Hearing witnesses suggested that technologies
be compared according to  the efficiency of their "end
use"—that each fuel source  and technology be com-
pared with others that can be  used  to meet a given
energy need or "end use," such as residential heating or
transportation. As described by one hearing witness,

   The principle is  that the "end use" for which energy Is
   required should determine, as much as possible, the source
   and form of the energy to be  employed for that use. The
   choice should be based on consideration of conservation
   or, in other words, of  energy economy. This means that
   preference should always be  shown for forms of energy
   that, while remaining  compatible with the "end use" to
   which they are put, are as direct as possible, involve as
   little capital-intensive technology as possible, and come,
   as much as possible, from renewable sources.
    (Susan  Tachau,  National  Center  for Appropriate
   Technology)

     Another witness  cited  a  recent report by  the
Carnegie-Mellon Institute of Research, "The Least Cost
Energy Strategy," which discusses a new way of looking
at inferfuel competition—an approach called "energy
services"

    The premise is that an "energy service" is what people
    require: people  want a warm house; they, in effect, are
    neutral as to whether this comes from gas heat, electricity,
    and so forth.
    (Benjamin Schlesinger, American Gas Association)
 4. Criteria for Assessing Technologies

     Several Hearing witnesses expressed concern that
 environmental criteria do not appear to have significant
 influence in DOE technology development decisions.
                                                      viii

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Others felt that once the decision is made to invest in a
technology, it is virtually impossible to halt or even slow
its progress, even if serious environmental questions
remain  unanswered. Therefore,  many witnesses sup-
ported the development and establishment of explicit
environmental criteria which would be applied consis-
tently to all technology projects at key decision points.
Further, they felt that these criteria should be explained
to the public and that the results of the application of the
criteria to each decision  should be disclosed. As  one
Hearing witness commented

   Absence of explicit criteria gives the appearance, if not the
   reality, that decisions are arbitrary.
   (Mark  McCiellan,   Pennsylvania  Citizens  Advisory
   Council)

     Witnesses felt  that  in  addition to cost   and  net
energy  analysis, the  criteria should address  a broad
range of environmental  issues;  should  apply to the
potential local,  regional,   and  global  effects of  a
technology project; and should include consideration of
the entire  fuel cycle.  Ideally these criteria should be
measurable and observable.  In  discussing the broad
range of applicable criteria, one scientist stated that

   The  process  of evaluating  competitive  technologies
   requires explicit criteria, which should include risk evalua-
   tion, potential for environmental degradation, aesthetics
   and  social  concerns,   and  the  aspect  so  often
   overlooked—the worldwide consequences of developing
   a technology....The obvious criteria include  impacts  on
   air, land, water, and the biosphere. The changes brought
   about in these resources must then be evaluated in terms
   of how they affect man. In  this analysis,  it  is not only
   direct  health effects that  are of importance, but also the
   impact on those values that are often impossible to quan-
   tify, but are so important, such as the aesthetic impacts of
   changes in the recreational values of the environment.
   (Gordon MacDonakl, The MITRE Corporation)
He felt that these concerns should be among the earliest
issues to be discussed, studied, and resolved before
large-scale commitment to a technology is made,

   because occupational  safety  and  health issues  are
   largely  independent of siting,  occupational safety and
   health  assessments  should   really  precede  overall
   environmental assessment.
   (Kenneth Bridbord, National Institute for Occupational
   Safety and Health)

     Several  witnesses discussed potential approaches
to the  application  of environmental  criteria.  One
described two  models that could be used to integrate
environmental factors into technology decisionmaking.

   The first model is to have a periodic review to identify
   and avoid potential 'show stoppers'...things that would
   stop the technology dead and which unless overcome
   would make  continuation unwise. It is my impression
   that this is  the motivating element of the current DOE
   process. But  a second model  is to have an interactive
   process in  which environmental and energy conserva-
   tion factors are influential  in  steering the technology
   development along one path as opposed to another path.
   (Larry Moss,  National Coal Policy Project)

Another witness had a slightly different perspective on
the role of environmental criteria in the review process.

   The review process is only useful and accomplishing its
   objectives if it can result in a negative decision. This
   does not appear to be the case within the Department of
   Energy today. Once a project  enters the funding pipe-
   line for basic research, it appears to be a foregone con-
   clusion that it will proceed unmolested through the key
   decision points in the PPMS to commercialization.
   (Mark  McCiellan,  Pennsylvania  Citizens  Advisory
   Council)

The  process should be modified to include thresholds or
Another  scientist  noted that  in  evaluating  energy
technologies,

   environmental and health considerations cover a span
   from site-specific to those that are truly global in nature.
   One might look to the acid rain problem as an indication
   of growing interest in regional concerns.. .We must also
   include  the internal  environment  of an  energy-
   generating facility, which brings us  into the important
   area of worker protection, health, and safety.
   (Chester Richmond, Oak Ridge National Laboratory)

Regarding this last concern,  a representative from  the
National Institute on  Occupational Safety and Health
said that

   the issue of occupational safety and health has generally
   been given relatively low priority and visibility in the
   development of new energy technologies.
   (Kenneth Bridbord, National Institute for Occupational
   Safety and Health)
   environmental conditions which must be met during
   each development phase. Any deficiencies or unaccept-
   able environmental problems should be a condition for
   temporarily halting and in severe cases canceling a proj-
   ect. In the case of the project that does not meet the
   threshold,  the DOE Undersecretary should have the
   discretion to allow the project to proceed...but only to
   the next phase, and under conditional approval which
   would stipulate that specified environmental concerns
   must be resolved in a specified time period, or the proj-
   ect will be placed on permanent hold at that phase. No
   technology should ever be approved for commercializa-
   tion unless all thresholds are satisfactorily met.
   (Mark  McCiellan,  Pennsylvania  Citizens  Advisory
   Council)


     Environmental issues  are currently examined in
Environmental  Readiness  Documents  (ERDs).  One
witness discussed  shortcomings,  primarily  a  lack of
thoroughness,  in  the way the ERD deals with these
issues.
                                                       ix

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   ERDs should address five areas: the current state of
   knowledge about the health, safety, and environmental
   impacts that would be created by deployment  of the
   technology; available control technologies; the current
   and proposed regulations which will affect commer-
   cialization; the areas of environmental concern for
   which information is inadequate and further research is
   required; and the likelihood of significant delay in attain-
   ing program objectives because of environmental con-
   cerns. The ERDs tend to present data unsystematically
   and to  emphasize qualitative rather than quantitative
   analysis. Most ERDs treat the current state of knowledge
   about environmental concerns insufficiently. They omit
   definitions of the origin  and size of the environmental
   concerns  ....ERDs now merely list a  potpourri of
   research needs  and their dollar  value. They should
   make some effort to prioritize these needs.... Environ-
   mental issues are now identified haphazardly. A more
   logical approach,  used in  many of the analyses  at
   Brookhaven, would go through the entire fuel cycles of
   each of the technologies and identify possible environ-
   mental conflicts.
   (Samuel  Morris for  Leonard Hamilton, Brookhaven
   National Laboratory)


     Finally, a  witness  discussed  the importance  of
developing  and applying environmental criteria early in
the process

   prior to siting decisions. Today  these  considerations
   usually enter after individual sites have been selected
   and are being evaluated and after the battle  lines have
   been drawn. If we use these criteria early in the process
   of identifying candidate sites for demonstration projects
   or for full-scale  projects,  we  could  ease—if  not
   avoid—many last-minute confrontations.
   (Allan Hirsch, U.S. Fish and Wildlife Service)
5.  Appropriate Levels for Treating
    Environmental Issues

     A  concern  expressed  in  each  workshop  and
repeated at the National Hearing was  that agencies at
the State and local levels, whose residents lived  near
planned projects, were not given a clear role in the DOE
decisionmaking process.

   Most of the assessment  of the environmental  impact
   is.. .done on the national level. Most of the serious envi-
   ronmental effects of the new large-scale technologies
   will be felt most severely at the regional and local levels
   where the energy facilities are actually located. These
   effects must be examined closely.
   (Susan  Tachau,  National  Center  for  Appropriate
   Technology)

     Participants felt that more responsibility  for envi-
ronmental  assessment should  be delegated  to these
local levels to  increase  the  likelihood that local  con-
cerns, as well as generic technology concerns,  would be
dealt with at appropriate times. Local, State, or regional
officials  have a familiarity with  their own environment
that results in a deeper understanding of the potential
range and severity of impacts a project may cause. This
information  must  be considered  along with  generic
technical  data in making technology project decisions.
In discussing the importance of continued research at all
levels, another witness recommended that

   DOE...should coordinate  its  funding sources  so that
   both  site-specific... and  generic  work  can  be
   pursued...Answers to the regional and global concerns
   most probably will arise from the generic research con-
   ducted   as  part  of  the  core  programs at  various
   laboratories.

Further,

   non-Federal levels of government will become the foci
   of decisions on environmental tradeoffs among energy
   policy alternatives. Harmony between energy develop-
   ment and regional concerns will be largely defined at the
   regional level, with the Federal government defining the
   boundaries  of acceptability,  offering  incentives  for
   actions and decisions that are in the national interest,
   and helping resolve conflicts that arise between States
   and regions  whose  actions and decisions affect one
   another.

Therefore,

   DOE should make special efforts  to keep  State and
   especially local officials involved, as projects proceed
   through the environmental evaluation process, primarily
   through improved information dissemination, assistance
   to outside groups in preparing EISs, and establishing
   local planning and review groups.
   (Chester Richmond,  Oak Ridge National Laboratory)

And one  witness complained  of a present situation.

   DOE has spent millions studying the  Geysers. We're
   practically an  annuity for  the National Labs. But our
   local government still doesn't have the basic environ-
   mental  and economic information it needs in a form it
   can use. We tend to think it might  be because no one
   ever came to us and asked us. Local government is too
   often treated as the object of some anthropological field
   trip. Our geographic jurisdiction seems to be considered
   as some underdeveloped colonial possession, just right
   for exploitation.
   (Mary  Jadiker,  Lake  County,  California,  Planning
   Commission)


     Many participants stressed that the role of local and
State  agencies should  not  be limited  to  reviewing
documents or decisions.  Instead,  these  organizations
should be involved in a steering capacity  before final
siting decisions are made and then throughout the life of
a project. As one witness stated,

   We're the ones who see, hear, smell, pay for, or benefit
   from our 'go' decisions.  Obviously,  we feel  those
   ultimate decisions must be made at  the local  level.
   (Mary  Jadiker,  Lake  County,  California,  Planning
   Commission)

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6. Public Participation

    The clearest theme to emerge from the workshops
and the National Hearing was that public involvement in
DOE's management and decisionmaking systems has
been woefully inadequate. Hearing witnesses expressed
a deep sense of frustration in their efforts to participate
in DOE's decisionmaking process. Through their com-
ments, they  reinforced the four  overall  criticisms of
DOE's interactions with the public that were made at the
workshops, and they offered some specific recommenda-
tions.
    First,  the  amount and  quality  of information
available to the public is inadequate.  Important internal
documents are  not systematically disseminated,  and
documents that are supposed to be available upon request
are difficult,  if  not impossible  to  obtain.  Materials
distributed  are  frequently highly technical and  laden
with bureaucratic jargon.
    Second, opportunities for effective public participa-
tion  in  the decisionmaking process are inadequate.
DOE   technology  management  processes do  not
systematically involve  the public until mandated by
NEPA requirements. At this point in the process, many
critical decisions have already been made. The public is
never given an opportunity to affect the choices DOE
makes among alternative technology options. Accord-
ing to one witness,

   We can see that DOE is not involving a  wider public in
   the decisionmaking process, and it is our view that they
   should be doing so and doing  so very early. Early par-
   ticipation outside the agency,  we believe,  is necessary
   for the effective management of any program which  is
   ultimately going to impact the  public.  Now...the public
   has its say (only later) and often that is inefficient and
   leads to many delays which could have been prevented
   if this much broader public impact had begun early.
   (Richard Pratt, Pennsylvania Sierra Club)

    Little attempt is made to inform the public when
decisions are going to be made and what the options
are. Thus, citizens cannot actively seek involvement at
appropriate times. This situation is exacerbated by the
seemingly constant crisis atmosphere  and organizational
flux that  surrounds DOE decisionmaking, which makes
it very difficult for outsiders to discern how and when to
attempt  to influence the process. To improve com-
munication with the public on decisions, one witness
suggested that

   we need to put more emphasis not so much on the for-
   mal system of preparing and circulating documents, but
   providing opportunities for various  segments of  the
   public  who are concerned with these projects—like
   government agencies, the  industry,  environmental
   community—to meet in forums where... questions can
   be...(asked) and mutual respect can be generated.
   (William Rogers, Gulf Mineral  Resources Company)
    As an example, one witness  cited the National
Coal Policy Project, which aimed to reconcile the views
of energy developers and those of environmentalists.
The approach to reconciliation used in the project was
the "Rule of Reason," an alternative to adversary-type
processes, in which the primary aim of the parties was
to find an  accommodative solution  which  did not
seriously transgress  the  values  of  either party. This
witness suggested that DOE could  use this process to
help resolve important long term issues, such as those
involved in the development of synthetic fuels.
    The third overall criticism of existing participation
mechanisms was that they appear to favor certain inter-
ests. Advisory  committees seem  to be dominated  by
industry groups, and research review panels are com-
posed  of  narrow groups  of professionals with vested
interests in  pursuing traditional technology projects.
Groups that are not well-funded have difficulty being
involved in the public programs offered.
    Finally, participants felt that the general attitude of
DOE officials is not  favorable toward  public participa-
tion. Although certain officials in DOE have a  strong
personal commitment to public involvement, overall
there seems to be too little value attached to effective
citizen  input. Even when lip service is given to  citizen
activities,  little  time is devoted to adequate exchange
between top  officials and representatives  of  public
groups. Many  DOE representatives seem to consider
members of public groups as naive  amateurs with little
of substance to contribute. One witness countered this
attitude:

   No  management system will work without meaningful
   public involvement. It must be clear to the public  also
   how DOE responds to public... participation. Credibility
   of public  involvement  efforts demands a responsive
   Department.
   (Kevin Markey, Friends of the Earth)

     Witnesses stressed that the implementation of mean-
ingful   measures to encourage public participation
would, in fact, result in a number of benefits to DOE:
issues  would be identified  earlier,  conflicts would be
resolved more  easily, greater public support would be
fostered, and the process would be expedited. Finally, it
would meet the public's demand and legislative man-
dates for greater participation in governmental decision-
making. As one participant summarized,

   Public participation should not be viewed as an  end
   unto itself,  rather as a means of achieving goals,  and
   it should always be clear that it is providing an oppor-
   tunity... to participate in the decisionmaking...first  you
   decide  what  decisions have to be made, then  you
   decide when  you are going to make those decisions,
   and then you decide how it is best to bring in the public
   to provide advice at those key points in the decision-
   making process.
   (Edith Chase, League of Women Voters)
                                                    XI

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7.  Discussions of Specific Technologies

     A  number of witnesses discussed  the merits or
drawbacks of specific technologies. Individual witnesses
discussed the pros and cons of geothermal develop-
ment and synthetic fuels from coal and oil shale. Others
discussed the benefits that would result from an increased
DOE emphasis on recycling, improved waste manage-
ment methods, gasohol, and the increased efficiency of
electrical appliances and equipment.
     Most witnesses who discussed specific approaches
focused on  conservation, renewable resources,  and
appropriate technologies. One witness stated, regarding
conservation, that it

   must be an inherent part of our national energy policy
   and  must be viewed  as complementary  to energy
   research and development and not as an  alternative
   to it.
   (Patricia Pelkofer, Group Against Smog and Pollution)

Another pointed out the necessity of conservation.

   Conservation has been our only source of new supplies in
   me recent past and will be our only source in the near
   term. Conservation, along with the use of renewable
   sources, should be our major source in the long term.
   (Lore Keffer, Group for Recycling in Pennsylvania)


     Finally,  in discussing the urgency of the need to
place more emphasis on renewable sources of energy,
one witness  stressed that the national energy program
must soon see
   the beginning of a transition in economic and political advan-
   tage from the fossil  and nudear proyiams to the more
   benign renewable fuel forms. The purpose of this Hear-
   ing is to establish a document for congressional and
   executive review. I  think it  has to be established  here
   that the people have gone on record as being concerned
   about a future that is  dominated by dead ends and
   disappointments.  A  self-sustaining  renewable  fuel
   should be priced below the use of our rapidly depleting
   reserves by policy. To give  the petroleum or synthetic
   fuels programs artktfical supports and financial benefits
   is to work counter to baste principle, and it is to succumb
   to political irrelevance  and  cowardice, to oppose the
   inevitable, to delay the day until we must face our cold
   and hungry children in the darkness of our own selfish
   short-sightedness because we waited too long.
   (Scott Crytser, Pennsylvania Gasohol Commission)
                                                      xii

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October 3,  1979
Panel:

DR. STEPHEN GAGE, Assistant Administrator
    for Research and Development, Environmental Protection Agency

DR.STEVEN REZNEK, Deputy Assistant Administrator
    for Environmental Engineering and Technology, Environmental Protection Agency

RUTH CLUSEN, Assistant Secretary for Environment
    Department of Energy

WILLIAM HEDEMAN, Director, Office of Environmental Review,
    Environmental Protection Agency

GEORGE PATTON, Environmental Affairs Director,
    American Petroleum Institute

TOBY PIERCE, Environmental Protection Specialist
    Environmental Protection Agency

ROBERT SIEK, Departmental Executive Director,
    Colorado Department of Natural Resources
                                       Xlll

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Contents
MORNING SESSION
  PAGE
PAGE
     1  Introductory remarks, DR. STEPHEN GAGE
     2  Further remarks, DR. STEVEN REZNEK
                    MS. RUTH CLUSEN
     2  Statement of DR. GORDON MACDONALD
           MITRE Corporation
           Questions and remarks
              4 MS. CLUSEN
              4 DR. PATTON
              5 DR. REZNEK
              5 DR. GAGE
              6 MR. HEDEMAN
              6 DR. REZNEK

     6  Statement of MR. TOBY ANTHONY
           Research - Cottrell
           Questions and remarks
              8 MS. CLUSEN
              8 DR. REZNEK
              9 DR. GAGE
              9 MR. HEDEMAN

     10  Statement of MR. JOEL ROBINSON
           Union Oil Company
           Questions and remarks
              11 MR. SIEK
              12 MR. SIEK
              12 DR. REZNEK
              13 MR. HEDEMAN
              13 MS. CLUSEN
              13 MR. SIEK
              14 DR. PATTON
   14  Statement of MS. MERILYN REEVES
         League of Women Voters of Maryland
         Questions and remarks
             16 DR. PATTON
             17 MS. CLUSEN
             18 DR. REZNEK

   19  Statement of MR. KEVIN MARKEY
         Friends of the Earth
         Questions and remarks
             22 DR. PATTON
             23 MS. CLUSEN
             23 DR. REZNEK
             24 MR. HEDEMAN
             25 MS. REEVES
             25 DR. REZNEK
                                      xiv

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Contents (Continued)
AFTERNOON SESSION
  PAGE
PAGE
    27  Statement of MR. MACAULEY WHITING
           Dow Chemical Company - National Coal Policy
             Project
           Questions and remarks
              29 DR. REZNEK
              29 MR. MOSS
              29 MR. PIERCE
              30 MR. MOSS
              30 MS. CLUSEN
              30 DR. REZNEK

    31  Statement of MR. LARRY MOSS
           National Coal Policy Project
           Questions and remarks
              32 MS. CLUSEN
              33 MR. WHITING
              33 DR. REZNEK
              33 MR. PIERCE

    33  Statement of MR. LOWELL ENDAHL
           National Rural Electric Cooperative Association
           Questions and remarks
              36 DR. REZNEK
              36 MR. IVES
              36 MR. PIERCE
              37 MS. CLUSEN
              37 DR. REZNEK
   37  Statement of MR. DAVID PATE
         Alabama Solar Energy Coalition
         Questions and remarks
             41 MR. STEVENS
             42 MR. STEVENS
             42 DR. REZNEK
             42 DR. PATTON
             43 DR. REZNEK
             43 DR. PATTON
             44 DR. PATTON

   44  Statement of DR. BENJAMIN SCHLESINGER
         American Gas Association
         Questions and remarks
             46 MR. PIERCE
             47 MR. PIERCE
             47 MR. SIEK
             47 DR. REZNEK
             48 DR. REZNEK

   49  Statement of MS. JO JONES
         Georgia Clean Water Coalition
         Questions and remarks
             50 DR. REZNEK
         Adjournment
                                      xv

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Proceedings
                                                                                  Introductory Remarks
     DR. GAGE: Good morning. I am Stephen Gage,
Assistant Administrator for Research and Development
at the Environmental Protection Agency and I would
like  to welcome all of you to the 1979 Section  11
National Hearing.
     The impetus for this Hearing is the Federal Non-
nuclear Energy  Research and  Development  Act of
1974. That  Act created a  National  program  for
research, development, and demonstration in the non-
nuclear energy technologies with a total Federal invest-
ment of nearly $20 billion over a  10-year period.
     Further,  it required  the  development of "tech-
nological capabilities to support the broadest range of
energy policy options through conservation and the use
of domestic resources by socially  and  environmentally
acceptable means."
     Originally,  Section  11 directed the Council on
Environmental  Quality to carry out  "a continuing
analysis of  the adequacy of attention given to energy
conservation and environmental protection" in energy
technology development. CEQ  was also directed to
hold  annual  hearings  to involve the public  in their
analysis and report the results of that analysis to  the
President and to the Congress.
     Since  1974, there have  been a few changes, of
course. ERDA has been replaced by DOE, and the Sec-
tion  11 review has been reassigned from CEQ to  the
Office of Research and Development within EPA.
     However, despite the changes in organization,  the
Section 11 review is as important today as it was in
1974. Perhaps even more so  because as this country
brings major new initiatives in synthetic fuels and solar
energy, a more opportune time for the public to help
influence the direction those initiatives take will probably
not come again.
     The  President has emphasized the seriousness of
our energy situation. He is also committed to protecting
the environment.
     In his July 15, 1979 address, he juxtaposed two
very  important and interesting ideas. He said, "We  will
protect our environment, but when this nation critically
needs a refinery or a pipeline,  we will build it."
     We are entering a very crucial period. The deci-
sions made in the next few years will determine  the
nation's energy security, its economic  well-being, and
the quality of its environment. These decisions will be
made and will be made soon. The pace of events really
allows no other alternative. What we do now or what
we don't do will profoundly affect our future.
    Federal decisionmaking  on  energy  and environ-
mental issues is becoming even more critical than it has
been in the past. This Section 11 Hearing can help to
improve those decisions.
    Last year's  Section 11  review  focused on the
allocation of research and development dollars among
different energy technologies.   We  discovered  that
reasonable men and women  could disagree quite elo-
quently and strongly on whether or  not the research
budget reflected  adequate attention to environmental
protection and energy conservation.
    This year we have concentrated  on  the  DOE
decisionmaking process  rather than  the results of those
decisions. We've tried to find out how information on
environmental concerns is used in the major manage-
ment  decisions concerning DOE's technology research
programs and projects.
    As you know,  a  new  Secretary of Energy has
recently been appointed, a departmental reorganization
has been announced, and a major review of DOE proj-
ect management is underway. Thus, it  is particularly
timely to make findings and recommendations  as  to
how  environmental factors  should  be incorporated  in
the decisionmaking process.
    We believe that the underlying issues, which are
the  focus of  this year's Section 11  evaluation, are
applicable. We hope that you will help us examine these
issues further and that Congress and DOE will use your
comments in developing the research program necessary
to ensure that environmental concerns are  fully inte-
grated into our search for an end to the dependence on
foreign energy.
    We feel  especially fortunate to have assembled
both a .Hearing panel and a group of witnesses of great
distinction. These people represent  a wide spectrum of
energy and environmental interests. I'd particularly like
to welcome to our panel my distinguished colleague,
Ms. Ruth Clusen who  is the Assistant  Secretary for
Environment in the Department of  Energy and whose
office in DOE will play a  critical role in implementing the
results of such deliberations.
    Now I  would like to introduce Dr. Steve Reznek
who  heads  the Office  of Environmental Engineering

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Hearing of October 3, 1979
and Technology in EPA.  This office is responsible for
organizing the  Section 11 Hearing and conducting
the entire review.  Steve will introduce the other panel
members and describe how we'll be proceeding during
the next three days. Steve.
    DR. REZNEK: Thank you. Let me introduce the
other members  of the Panel, Starting at the far end is
Dr. George Patton of the American Petroleum Institute.
Sitting next to him is Robert Siek, Deputy Commissioner
in the Colorado  Department of Natural Resources. Next
to him is William  Hedeman of the Office of Environ-
mental Review in the Environmental Protection Agency.
    I would like to ask Ruth Clusen if she would like to
make some opening remarks or statement.
    MS. CLUSEN: Thank you, Dr. Reznek. I would
simply like to say that I have followed the process of the
Section 11 review with considerable interest during the
months it has been evolving. I have had good reports
on the workshops that were held around the country. I
have read the documents  including the report which is
the basis for the Hearing  today and  1 look forward to
hearing the opinions of a really remarkable  group of
witnesses.
    I think my commitment personally to the process of
public participation in the decisionmaking process in
any part of the government is well known and 1 want to
underscore the fact that it is an on-going commitment in
my role at the Department of Energy. It is one I  have
vigorously pursued during the year that I have been at
the Agency.
    I think that  there is a  great deal to be gained from
holding this  Hearing just at this time. As Dr.  Gage
indicated, we are once again undergoing changes in the
decisionmaking  process  at the Department of Energy so
this is perhaps a time when it is appropriate to attempt
to have a different kind of  input, a different kind of pro-
cess. So the timing has worked out so that there is an
opportunity to  do some  things differently as we see
Secretary Duncan and his administration unfold.
    Other than  that,  I can only say that there are any
number of witnesses who are appearing  in the next
three  days with  whom I have had a long personal or
professional association. I respect their opinions and I
believe that we  are all here for the same purpose, to
make suggestions that  will result in improving public
participation  at  the Department of Energy, especially
through my office. Thank  you.
    DR. REZNEK: Thank you, Ruth.  As Steve Gage
said, last year we concentrated on  the relative division
of the  resources  in the  Department  of  Energy's
Research,  Development, and Demonstration Program.
We heard very eloquently that there  was very little
agreement or consensus  about how to allocate those
funds between competing technologies.
    The people who represented solar interests believed
very strongly there was  not enough money in the solar
programs. The people who represented the develop-
ment of synthetic natural gas, for example, pointed out
the environmental benefits with replacing natural gas
with a clean-burning fuel and indicated there was not
enough emphasis in the development of those processes.
    Because of this extremely wide and strongly held
divergence of opinion, we tried to approach the subject
this year in a slightly different way. Rather than center-
ing discussion on the allocation of resources between
programs, we  examined the  decisionmaking process
that is used in DOE in deciding whether to  go ahead
and develop a technology or not. In particular, how
environmental  information is used in that  decision-
making process and how it affects the actual decisions
that are made.
    We also  very much wanted to not make this a
study  of  professional management  analysts, environ-
mental analysts  done  in  Washington.  So we  put
together a document that described the process in some
detail and went to a series of four regional workshops
where we invited members of the public in  to review
that process.
    Many of the witnesses that you will hear over the
next three days were people who participated in those
workshops, and much of the comments that we hope to
hear in the next three days of hearings are the analysis
and thinking of the people who attended those work-
shops and have reviewed the DOE planning  process.
    We have also invited a set of witnesses who are the
professionals in the health and environmental sciences
area who are concerned with the development of new
energy technologies and  they will  comment on the
same questions.
    Each witness will have 10 minutes for  testimony
and we will then open the discussion for questioning by
the panel for 15 minutes.  If any member of the au-
dience wishes  to address  a  question to the witness,
there will be 3x5 cards available which will be collected
by  two representatives of  our staff and they will  be
brought to me  for addressing the question.
    We have a variety of documents available outside.
We have the transcript of the  hearing we had last year,
our summary report that we  prepared last  year. We
have the document describing the DOE planning process
that we used for the regional workshops this summer
and we have a prehearing document outlining the  six
major issues that we will hope to receive testimony on.
    We will complete the  3 days of hearings and the
record will remain open for 14 days. We will  be glad to
receive written comments from any of the  witnesses or
any members of the public. At the end of that period,
we will proceed under the charge of Section 11 to
prepare the report to the  Congress,  to the Assistant
Secretaries, and to the Administrator of the Environ-
mental Protection Agency on our findings regarding the
relative emphasis given to environmental protection in
energy conservation.

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                                                                              Statement of Dr. MacDonald
    That concludes my opening remarks. We will pro-
ceed to the first witness. Our first witness is Dr. Gordon
MacDonald. Dr. MacDonald is currently with the Mitre
Corporation where he is Senior Scientist in Residence.
Gordon.
    DR. MacDONALD: Thank you, Steve.  After a
most trying summer of long gasoline lines and curtailed
vacations, it is now autumn and cool nights seem to
remind us that winter is approaching.  It was the fall of
1973, six years ago, that put into focus the great U.S.
dependence on liquid hydrocarbon fuel and increased
awareness that a growing percentage of this supply of
fuel was coming in from outside the borders  of the
United States.
    This led to the creation of a new agency, devoted
to the  research,  development, and  demonstration of
energy technologies to solve our nation's energy prob-
lems in an "environmentally acceptable" manner.  That
agency's life  was brief and the  mission it had been
designated to perform was given to a new entity—the
Department of Energy.
    i have been asked to present my views on the ade-
quacy of that Department's  attention to environmental
concerns in the pursuit  of  developing and deploying
new energy technologies and conservation measures.
Attention  to  such  concerns can only be  adequately
addressed in a stable organization,  and it cannot be
claimed that the Department of Energy's short  history
has been one of stability. The task of taking into account
environmental concerns requires the successful balanc-
ing  of  technological,  environmental,  social,   and
economic  factors.   Such balancing  demands  strong
leadership, exceptional managerial and administrative
skills,  technical  excellence  in  both  technological
development and environmental matters, and a com-
mitment to national goals and objectives. There is, of
course, no organization that meets,  in  full,  these
requirements, and  DOE certainly does not at present.
That presents a dilemma in trying to evaluate the effec-
tiveness of a function which  must be included as an
integral part of each developing energy technology.
    In evaluating technologies from an environmental
standpoint, it is crucial to compare the new technology
with what it replaces or augments as well as with other
new competing technologies. In any research organiza-
tion, there is a natural hesitancy to compare the value of
one research project against another for fear that some
major breakthrough may be squelched. However, this
attitude cannot be carried  into  the development  and
demonstration stages.
    The cost of research, while often considerable, is
usually much  less  than  that  of  developing   and
demonstrating a new technology. Trade-offs must be
made  and the decisionmaking  system must evaluate
and incorporate economic and environmental trade-offs
at all stages of development and demonstration.
    The process of evaluating competitive technologies
requires  explicit  criteria  which  should include risk
evaluation, potential for  environmental degradation,
aesthetics and social concerns, and one aspect so often
overlooked—the worldwide consequences of developing
a technology.
    All energy technologies pose some risk to man. For
energy technologies, these  risks  must  be  evaluated
through the entire fuel cycle from raw material produc-
tion to the  disposal of wastes. The obvious criteria
include impacts of air, land, water, and the biosphere.
The changes brought about in these resources must
then be evaluated in terms of how they affect man.
    In this analysis, it is not only direct health effects
that are of importance, but also the impact on  those
values that are often impossible to quantify,  but are so
important, such as the aesthetic impacts or changes in
the recreational values of the environment.
    When I spoke of worldwide concerns, I was not just
alluding to consumption of the non-renewable  wprld
resources, I  also mean  the environmental impacts on
the world, of energy usage in the  United States, such
as, altering the  acidity of rain or even changing world
climate.
    The  burning of coal, oil, natural gas, and biomass
produces carbon dioxide in differing amounts per unit of
thermal energy delivered.  The conversion of  these
resources from one form  to another—coal to oil or
biomass to alcohol also generates  carbon dioxide and
the amount  generated is highly  dependent  on the
technology that is employed. Carbon dioxide is known
to affect the energy balance in the atmosphere and large
increases in the  carbon dioxide content could  alter
worldwide climate. Future  generations (and the future
generation may well be the  next) may see major shifts in
world climate.  The comparative potential impact on
world climate of various energy technologies has, I am
afraid, been given scant attention by the Department
of Energy.
    I  will now focus more specifically on the Depart-
ment  and the opportunity for non-DOE interests to
participate in the decisionmaking process.
    An examination of the present system reveals that
environmental research on a  developing technology
often gets done only because of the interest of particular
individuals rather than because there is a system which
drives the research.
    The  priorities for funding environmental research
in DOE have tended toward support of long-term, more
esoteric research rather than developing research pro-
grams to  meet the needs of developing technologies.
    In the past, the developers of technology have not
been overjoyed to use  project funds to support envi-
ronmental activities. It is my observation that  the adver-
sary positions taken in the past in such  situations are
starting to change. The technologists have  started to
realize that solving environmental concerns may be the

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Hearing of October 3, 1979
key to rapid, successful commercialization of a tech-
nology. The environmentalists within DOE have started
to play a more active role in the formulation of program
objectives.  Those  shifts in attitude are the keys to
the successful merging of environmental and technical
concerns.
    For example,  let us examine a small program in
fossil energy, Underground Coal Gasification (UCG).
There  is  a program  plan   and  an   Environmental
Development Plan (EDP) both of which were recently
updated. The environmental  research-associated with
the program has been funded by  the  Environmental
Control Technology Division under DOE's  Assistant
Secretary  for  Environment  and   EPA's Extraction
Technology Branch as well as by direct program funding.
These funding arrangements were put in place prior to
the development of the first  Environmental Develop-
ment Plan and in my view illustrate the kind of working
together between environmentalists and technologists
that will change the situation within the  Department.
    Although there has been considerable effort expended
in the  comparison of Underground Coal Gasification
economics with all of the technologies it may replace,
augment,  or compete with, no such undertaking has
been attempted in the environmental area.
    Some effort has been made to inform local public
interest groups and State and local governmental agen-
cies about activities in the Underground Coal Gasifica-
tion on a project-ty-project basis. The involvement of
the public  has been by the initiative  of the various proj-
ect leaders rather than by a deliberate effort to include
local interests in the planning  and analysis of projects.
Mechanisms to involve the public on a regular basis will
need to be built into the system as projects mature.
    The next procurement action  for  that program,
Underground Coal Gasification, will be a major system
acquisition. At this stage, there will be an opportunity
for input to both environmental and technical decisions
through the  Project Environmental Plan (PEP).
    Thus, there will be an opportunity to allow non-
Department of Energy interests a voice in the decision-
making process. What remains uncertain, at least in my
mind, is how the public will have that voice. The Project
Environmental Plan, in  principal, will focus for the first
time on the necessary environmental R&D with its funding
levels and milestones.
    It is not quite fair to pick out one specific example
from the multitude of DOE projects. However, Under-
ground Coal Gasification has  many desirable features
for comparison  with other technologies and may be
viewed as proto typical.  It is at an early stage in develop-
ment with promise for  commercialization in the late
1980's and  there is the beginning  of a good working
relationship between the technologists and the environ-
mentalists  in DOE. DOE is moving,  however slowly, in
the direction to accomplish  the objective of energy
development in  an environmentally acceptable manner.
It still, though, has a way to go.
    To carefully scrutinize all of the technologies using
the same resource and producing the same project, and
compare them using environmental criteria, then do this
technology area by technology  area  at the  varying
stages  of  development, and then cross-comparing
technologies  is a difficult,  arduous,  and  politically
dangerous effort. However, these are the comparisons
which must be made. They cannot be done by DOE
technology developers alone. They cannot be done by
DOE environmental researchers alone.  EPA cannot do
the task alone. There are vital interests at stake here.
    Yes, the  United States needs new energy sources.
The United States also needs to have its energy policy
evaluated from environmental as well as technological
perspectives.  An informed public  which includes indus-
try, public interest groups, and  the local population
must be aware of and be able to influence the course
and choices being made for our energy future and for
their particular locale. Thank you, Dr. Reznek.
    DR. REZNEK:  Thank you  very  much. We will
take  some questions from the panel. Does  the  panel
have some questions?
    MS. CLUSEN:  Perhaps I could begin, Dr. Mac-
Donald. Thank you for your statement. I agree with you
that  the  Project  Environmental  Plans,  which are
relatively new, offer the potential for doing what we
have been wanting to do. I would be interested in hear-
ing you pursue in some detail, if  you can, exactly that
question of how we  can do this, particularly  when it
comes to local involvement?
    I am wondering whether you are thinking of site-
specific kinds of activities, documents that are written
for the public rather than for technical specialists, or
other means you think we might  use?
    DR. MacDONALD: I think it is  very important
in projects such  as Underground Coal Gasification,
since  I have  used that  as  an illustration, to  be site-
specific. The people in the immediate vicinity, and that
immediate vicinity may actually be a larger  area than
just a few square miles, will be affected.
    Often, the documents prepared in proceeding with
such a project are highly technical, contain a great deal
of the necessary technical detail, engineering detail, envi-
ronmental control technologies, but presented in such a
way that the public would have a  very great difficulty in
evaluating them and in understanding the impact of that
project on their community or their locale.
    So I believe the point that you make of the necessity,
Ms. Clusen, of putting together documents which spell
out what is going to  happen in the language that the
general public will understand is critically important if
the Project Environmental Plan  is going to have the
desired effect of bringing the non-DOE interests into the
decisionmaking process.
    DR.  PATTON: I  am  George Pattern  with the
American Petroleum  Institute. It seems  to me that

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                                                                             Statement of Dr. MacDonald
if DOE were to pursue their Energy Development Pro-
gram, and the example you raised, Underground Coal
Gasification, and do so within the existing framework of
law, you would then have them controlling emissions to
the point where they didn't violate national ambient air
quality standards, which are presumably set to protect
public health. They presumably would work within the
restrictions of the Clean Air Act and the Clean Water
Act, Solid Waste Recovery Act, and if they do those
things, that is, if they do their job legally, I wonder what
it is that necessitates a more intensive local involvement—
I didn't  even  get  into  State  and  local  laws that
presumably the area would have certain additional, if
necessary, and my concern is that while  on the one
hand we recognize that collectively we should be trying
to do something to ease our  energy dilemma, it also
seems that that can run head on  into,  quote,  "micro
concerns," local concerns if you will, and so my concern
is that in an effort to try to have additional energy for the
nation as a whole  we offer additional impediments  to
that goal if we adopt a policy  you  just propose, which
is  more  local  involvement. Don't  forget that as  a
backdrop I have said I suppose and presume that DOE
will work within existing law. So  they are going  to
protect the public health and all known media.
    I would be interested in  some specific examples
where you feel that the local public would be in some
way harmed were they not informed through this local
education program that you have recommended.
    DR. MacDONALD:  In  addition to  protecting
public health, and it is a point that I made in my remarks
here, is the need to take into account those impacts that
are not related to public health.  That is,  the social
impacts, the impacts on recreational values, the impacts
on the community as a whole.
    I think if you bring a project into  a community,
there will be some economic benefits, the tax base will
be increased, services may increase, but there also may
be some negative impacts on the community as a whole.
I think it is proper that the community have  a voice  in
those decisions. I agree, there is always going  to be a
national interest, that national interest  may be over-
riding, but the local participation and the local  interest
should be weighed against the national interest. In the
end, DOE may wish to proceed with the project on the
grounds of national need but in making that decision it
should,  at the very minimum, be aware of any local
concern.
    As a specific example, I  have followed over the
years, as many have done, what coal development  in
the vicinity of GHIette, Wyoming has done or how it has
changed that community. It has some obvious positive
benefits  and some disbenefits to that development. I
think the acceptance of the community of the new proj-
ect, Underground Coal Gasification Project, in the par-
ticular community will be greater if the citizens have a
voice or at least are given the opportunity to voice their
concern and to perhaps make suggestions of ways of
making that particular project more compatible with the
interests of the community.
    DR. REZNEK: Dr.  MacDonald,  1 would like to
return to some of your remarks about intercomparisons
between technologies that are using the same resource
and producing  competing products and comparisons
between technologies. Does that mean that there are
well-defined ways, for example, emissions per unit of
energy produced,  for different kinds of pollutants or
different kinds of resource use like water resource use,
land disturbance, that can be laid out for each and every
technology?
    DR. MacDONALD: I won't claim that the meth-
odology  is available to carry out such  a  compara-
tive  analysis  for  all technology, but   I think we
should be  working towards  developing that method-
ology.  The examples you  quote are, I think,  very
appropriate. One can look at a variety of technologies
to gasify coal to high Btu gas and these technologies will
have different requirements with respect to water, there
will be different emissions, whether they are nitrogen
oxides or carbon dioxide, or whatever, that one can,  I
think, attempt to carry out this comparative analysis.
    My point is that I think that kind of comparison
should certainly begin in the developmental, and carry
through the demonstration phase to guide decisions as
to what should  eventually enter the commercialization
process.
    DR. REZNEK: Is that type of information relatively
available now in the EISs and could it be understood
by either a technical person or a reasonably informed
layjjerson?
    DR. MacDONALD: In my view— in the first
place,  there are relatively  few assessments that are
going on as far as Environmental Impact Statements.
There are environmental assessments that one can look
at. I think  that  some of  that information  is contained
within the documentation. I wouldn't say that it is con-
tained  in a way that everybody could pick it out and
make this comparative analysis on their own, just the
manner and way  of preparing information for either
environmental assessments of environmental  impact
statements  has to be improved.
    But I think it is important to make this comparative
analyst's because the environmental impacts in making
the final commercialization decision should be weighed
along with the technical and economic consequences of
that decision.
    DR. GAGE: You have probably been one of the
most vigorous spokespersons in the country pointing
out the potential problems with the climate modification
resulting from buildup of carbon dioxide in the atmos-
phere.  That, of course, is an effect which reaches far
beyond the effects that I think we are talking about
implicitly here, at least.

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Hearing of October 3, 1979
     Most of the assessments which have been done in
the past typically focused on the effects which occur
within the  general vicinity  of a  plant or  the general
vicinity of an energy development. How do  you  take
into account such large regional impacts as acid rain or
even such global impacts as carbon dioxide buildup in
carrying out these comparative assessments?
     DR. MacDONALD: 1 think in the development
of any particular technology or in the early comparison
of competitive technology, the carbon dioxide compo-
nent is one that should enter into consideration as well
as the local effects of the acid rain impact should go
along. I think the important point is that fuel resources
or energy  process is  an incremental one. We make
decision-by-decision on a technology, then on site, and
given one set of decisions, this then tends to channel the
direction in which our fuel resources will be obtained.
     If we don't at every incremental  step look to see
whether some of the potential worldwide impacts, and I
think the overall view is incomplete, clearly the impact
of one or two commercialized synthetic gas plants are
going to have a very, very small impact on the carbon
dioxide content of the atmosphere  worldwide and,
therefore, on climate.  However,  if those two early
plants lead to a massive development of synthetic fuel
through incremental decisions, at which stage you say
the next little step is just going to have a very small
effect, the  sum of those very small effects can  be
very major.
     MR. HEDEMAN: Following up on that question,
it seems to me I am not sure that I fully understood your
answer but the  one problem that I  had hoped you
would get to is one that I think we face in  terms of
understanding the cumulative impacts of what we are
doing  with those that are being  sponsored or under-
taken by other countries.
     Personally, I had the fortune last week of attending
an international conference of the European  countries
where that was discussed.  It became apparent to me
that the United States appears to be far more willing and
able to discuss this problem than many of the  other
countries, which leads to the rather logical conclusion
that the information available in other countries, which
the United  States would need to  compare or to use in
assessing the cumulative impact is simply not available.
     I  have described the problem.  The  question I
would have is do you have a suggestion as to how that
information can be better developed on an international
sphere?
     DR. MacDONALD: Yes, I think  that there are
several international  organizations which  I  turn to,
perhaps first to the International Energy Agency as a
logical agency to attempt to collect information  with
respect to,  let's say, the generation of carbon dioxide.
     In fact, one  can make a pretty  good worldwide
estimate right now knowing the quantities and kinds of
fuels that  the  individual nations  use.  But as  new
technologies come in in which coal is converted to oil or
gas or similar synthetic fuels, then we will need to know
a good deal more in  detail about the character of that
technology in order to evaluate the emissions of CO2
and the contribution  of that technology to the world-
wide loading of the atmosphere by carbon dioxide.
    I think the agency, such as the International Energy
Agency,  perhaps the United Nations Environmental
Program, UNEP, as being two agencies that could assist
in bringing that kind of information together.
    DR. REZNEK:  Dr. MacDonald, I have one  final
question. You have mentioned local impacts, impacts
on aesthetics  around a certain site, you mentioned
global problems and international problems, it seems to
me that one of the important concerns is to separate
those types of issues and allow them to be addressed
and  decided  and  those decisions communicated in
separate forums. If all forums have to participate in all
issues, it will slow down very important decisionmaking.
Would you care to comment on that?
     DR.  MacDONALD:  I would  agree completely
with you. I think that  for the local kinds of interests and
problems that the process by which the Project Environ-
mental Plan is put together or commented  on, that that
document  is  the  appropriate document  to take  into
account local interest.
    For  these broader concerns, the  questions of
worldwide climate changes, I think those should be  inte-
gral parts of generic environmental impact statement on
particular  technologies.  For example,  a  project not
related to DOE, but  I think it provides an appropriate
example, the Environmental Impact Statement, on our
coal releasing program  certainly should  have  had a
comparative analysis  of the impact on CO2 proceeding
in various ways with  co-leasing, and I think that policy
documents such as'the  National Energy Plan, NEP 2
that was issued a few months ago, should have had a
clear statement of the implications to the carbon dioxide
problem of the proposals contained within that Plan.
     DR. REZNEK:  Thank you. Before moving on to
the next witness, let me remind you that if  any member
of the audience wants to discuss a question, there are
3x5 cards available. I also neglected to say that we will
take an open period for any witness who is not scheduled
now to testify. We  would like to hold testimony to
about five minutes per person,  unscheduled witnesses.
That period will start at 4:30, at the close  of the day.
     Our next witness is Dr. Toby Anthony of Research-
Cottrell. Research-Cottrell  is one of the major suppliers
of pollution control technology.
     MR.  ANTHONY:  I  have to get rid of the title
"Doctor" because I don't deserve it. I am not a Ph.D.
but thank you anyway, Steve.
     Good morning. I am privileged to be here today to
comment on the very important subject of whether envi-
ronmental consequences of the application of energy
technologies are being addressed properly.

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                                                                                Statement of Mr. Anthony
    Research-Cottrell is probably the  oldest pollution
control company in the world, with interests in nearly
every phase of environmental control, and most recently
energy development. I think we have  insights into the
problems of developing energy resources in an environ-
mentally safe way. Hopefully,  these  insights will  be
helpful.  1 am Director of Business Development and
Washington Affairs here in the Washington office.
    I did not attend any of the  regional workshops in
July, but I have studied the background document sup-
plied by EPA and am fully aware of the findings reached
at those workshops. I might also add parenthetically
that  Research-Cottrell  has no  major  contracts  with
either EPA  or DOE for developing environmental
technologies. Most of the funding for our R&D projects
come from internal sources and  is used for product
improvement. So I feel I can speak with much less bias
than I would have  some 10 years ago.
    I would like to address my comments to the roles of
interested parties involved in the  decision making and
information dissemination  process. My objective is to
pinpoint the difficulties caused  by the interaction of
interested parties, to discuss the underlying factors caus-
ing these difficulties, and  to define what I  think the
proper roles should be.
    I will assume  at the outset that all the parties, that
is, the public, DOE, EPA, state and local officials, and I
might add private firms engaged in pollution control and
energy R&D have one purpose  in mind.
    I am persuaded that we have a singleminded pur-
pose, namely, developing our energy resources in  an
environmentally safe manner as  rapidly as possible and
in the most cost-effective way.
    To accomplish this purpose  I submit the first step is
to identify who is responsible for measuring the threat of
pollutants to health and the environment and who is to
assure   the existence of  best  control  or  substitute
technology.  Clearly,   Congress  has  assigned   this
authority to the EPA with the assistance of the public
and the scientific  community. To back this authority,
Congress has permitted EPA to conduct health effects
studies and R&D to develop the best available control
technology.
    We are all  aware of the input from the public and
scientific community particularly during the technical
assessment process prior to  issuing standards, and of
the numerous management advisory groups at a good
number of levels within EPA and DOE,  and of the many
interactions resulting from EPA's various publications.
    However, this is not to say that each interested party
is or ever will be fully informed. That would be nearly
impossible to accomplish. This point is well documented
in the findings resulting from the workshops.
    As  I view it, the problem is not so much insufficient
dissemination of  information.  On the contrary,  we
know only  too  well pollution control  is a horrendous
task. Since we are trying  to control an  exceptional
number of pollutants, it is an overwhelming task to con-
vey confidence and sufficient data to each interested
party.
    Prior  to the 70's,  our concerns  were directed
primarily at  aggregate pollutants such as flyash in air
and biological-oxygen-demand material in water. These
pollutants  were clearly threats,  easily measurable, and
rather simple to control. Currently our threats involve
specific  chemicals such  as  SO2 and  chlorophenols
perhaps contained in those aggregates but extremely
complex to control or to find substitute processes. So
while it is clear to the public these chemicals are threats,
it is not so clear to them when  they will be controlled.
    This produces frustration which will  worsen  as we
deal with a constant stream of threats. We are dealing
with hundreds growing  into thousands of chemicals
located in hundreds of thousands of products,  waste
streams, and sites which the public demands must be
controlled.  This will take years  and perhaps  some
pollutants  will never be  controlled, but those facts do
not appear to be  satisfactory. This realization which is
creeping into the public's consciousness is what I think is
causing the frustration. There is much information avail-
able on these realities, not too little, which deepens this
frustration.
    Energy waste streams are simply another source of
chemicals considered to be carcinogens or pollutants. It
is clear in the laws that the EPA has the essential author-
ity to define, measure, and control the threat. It is the
only sector motivated by law to exercise these functions.
    Their responsibility  is  to  do the  health  effects
studies with participation  from public and scientific com-
munities  and  to  develop the  best  available control
technology and demonstrate it.
    Neither DOE nor R&D firms are motivated to do
this. DOE's job is to develop energy resources that meet
environmental standards set by EPA.  Ruth Clusen's
shop, as I view it, bridges the gap between EPA and
DOE  technology  centers. She translates  and imple-
ments EPA policy as if she were an arm of the EPA.
    Several  weeks  ago, Congressman Toby  Moffet
erroneously  chastised Ruth  Clusen for  not being an
environmental advocate. DOE  is no place for environ-
mental advocacy, EPA is. It is not inherent in DOE's
purpose to develop "best available control technology."
The law says the  EPA Administrator is responsible for
that. DOE's purpose is  to develop  the  best available
energy technology.  So  while  EPA is  motivated  to
develop BACT, DOE is motivated to modify it for long
term cost-effective use.
    Let me  emphasize  this point.  No  demonstrated
major technology  is ready for continuous, reliable, and
economical operation over the life of the equipment. All
equipment must  go  through stages  of  redesign and
improvement until it reaches a steady-state of optimum
performance. That is what DOE is concerned with, and

-------
Hearing of October 3,  1979
rightfully so. That is not necessarily of concern to EPA
and according to the law, rightly so.
    What about the role of RD&D firms? Pollution con-
trol companies are not motivated to develop BACT. It is
to their advantage to do  product improvement work,
but not develop new pollution control technologies.
The reason being environmental standards change too
frequently.
    For example,  the Clean Air Act 1977 says stan-
dards should be reviewed every four years. That word
"review" creates uncertainty, not risk, to pollution con-
trol companies. It takes roughly 5 to 10 years to develop
a technology and another 5 to  10 years to recover the
investment in RD&D and marketing. Clearly, the two
schedules are  out  of sync.  As long  as EPA  needs to
develop new standards and new BACT involving the
same pollutant, the uncertainty of return from potentially
obsolete technology will preclude  exclusive private
investment so funding by  agencies must fill the gap.
    But DOE and EPA funds are limited, too. So here
we find ourselves with threats popping up every day,
much more difficult to solve than in the past, outstripping
our capability to ward those threats off. It is no wonder
we are all frustrated.
    But no amount of public intercession in DOE's or
EPA's decisionmaking system will help. If the public
intervenes any  further into the system,  it will make it
even more difficult to satisfy our objectives. Congress
senses that environmental decisions are already imped-
ing progress in  developing energy resources. That is the
reason the Energy Mobilization Board was conceived. It
was conceived by three men having lunch in Sans Souci
who convinced a few Senators too  many people are
involved in decisions on energy.
    Make no  mistake,  if  the existing system will not
work efficiently to develop energy resources in an envi-
ronmentally safe manner as rapidly as possible and in a
most cost-effective way, we will end up with a mobiliza-
tion board not the  public, not DOE,  not EPA making
those decisions.
    I can find no fault with the management system as
described in DOE.  It allows for  oversight by the public
on  health  threat  issues,  but excludes them  where
engineering decisions are made. That is as it should be.
While EPA and the public should watch-dog DOE to
assure  compliance with the law,  it must be left  to
engineers with designated responsibilities to provide the
proper hardware. If the results are unsatisfactory, it may
be  we  are trying  to do too  much, too  soon, too
idealistically. Thank you.
    DR.  REZNEK:  Thank  you.  I  thought  your
remarks were very incisive.  Are there questions from
the panel?
    MS. CLUSEN: Thank you, Mr. Anthony. I have a
particular problem right now that relates to the  hearings
of the House Committee on Government Operations,
and I would like to pose this question to you since you
touched upon it.
    What would you see as the proper role of the Office
of Environment in the instance of coal conversion of
public utilities?
    MR. ANTHONY: Well, we have  some responsi-
bilities given to DOE in the Energy Act, which surprise
me because those responsibilities are also called out in
the Clean Air Act. Namely, that coal conversion should
be instituted except for some 21  exceptions,  one of
them being where it impacts the non-attainment area,
for example.
    I think Congress got themselves mixed up. 1 think
that that responsibility rests with EPA. Under the old
ESECA, DOE had to check with EPA on every prohibi-
tion order,  or any conversion order, for their approval
and I can only assume that practice will continue which
in effect gives veto authority over environmental matters
to EPA. I do  not  see how you can exercise that
responsibility.
    DR.  REZNEK: I would  like to return  to our
remarks about public involvement in decisions.  Your
last comments that the public has an overview function
rather than involvement in the actual decision process,
can you elaborate on how they would  exercise that
overview function and the responsibilities to the agen-
cies to make sure that the information is available for
that overview.
    MR. ANTHONY: I think that the system already
exists.  Unfortunately, not everybody in the public can
participate in the system. For example, underway right
now at Research Triangle Park is a technical assessment
process which will lead to new  source  performance
standards for small industrial boilers.
    I know the EPA at Research Triangle Park has tried
to solicit as many interested parties as possible and has
members of the public on their NAPTAC board. Their
judgments  are on technical matters which cannot be
dealt with by all the public. Yet, EPA has involved the
public anyway. Standards will result from their delibera-
tions which must be followed by DOE. But, the public
need  not help  DOE meet the standards  but simply
watch them to see that they do.
    The public also participates in such groups as the
Management Advisory  Group for construction grants
programs,  Ruth  Clusen has a Management Advisory
Group. Much  of the public doesn't know who is  on
those groups and their actions cannot be funneled back
to the  public. Nor do I think the  public  has to  know
everything  that is going on.
    When it comes to the oversight, this occurs when
we are ready to site a plant or when plans are underway
to site  a developed energy technology somewhere. A
whole  reeducation process has to take place because
there are local people who didn't know it was going to
be sited there, don't understand what the energy project

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                                                                                 Statement of Mr. Anthony
is, and are not quite sure that the pollution control
facilities are going to be sufficient.
    But at this point it is too late to stop the project. It
should be DOE's or EPA's responsibility to inform loca1
people during pilot stages when a full scale plant will bt
located in their area.
    DR.  GAGE: Mr. Anthony,  your last response
seemed to give me a little more insight into some of the
implicit meanings in your original statement. You indi-
cated the public oversight should occur more at the time
when individual sites are selected and being reviewed.
    MR.  ANTHONY: Two places; one,  when the
health effects studies are underway.
    DR. GAGE: Okay. That then I think sharpens it
even further.  I guess, then, implicit in what you are say-
ing in terms of allowing the engineers, once objectives
are set, to continue along a  particular path until  that
path is completed leaves us with a bit of a problem,
especially with respect to  technologies that are going
to be developed only over decades or at least 10, 15,
20 years.
    If you recall, most of the environmental concerns
that  are  worried about today in  dealing  with  toxic
chemicals in particular have become apparent only in
the last  five to eight years. Your rather sweeping
approach here of setting  a technology on a track and
allowing  it to  work  its  way through,  allowing the
engineers to come to the final solution seems to sweep
away some very serious concerns that I think those of us
in the environmental community are trying to wrestle
with and that is how do we at least periodically review
what societal objectives are with respect to protecting
public health.
    It  may  be  all right  to  grandfather  existing
technologies  for a period  of time or until a very  per-
suasive case to change might be made.  It may even be
all right to grandfather near-term technologies with a
new set of regulations at the time they are beginning to
emerge into commercial application. But to  make such
a sweeping statement for all energy technologies appears
to really fly into the face of our experience  for the last
10 years. Would you like to comment on that?
    MR. ANTHONY: Yes. I would like to distinguish
between two stages involving technologies. I would like
to first talk about the technologies that are in the pilot
stage or in the study stage and are being developed.
Then  I would like  to address  different remarks to
technologies that are being sited, this is after the com-
mercialization or demonstration phase. I think you have
to look at them in two different ways.
    Technologies  that are  in  the predemonstration
period can be stopped, restarted and redirected usually
at low cost and at stages where changes are easy to make.
    The  technologies go from  study to  pilot to
predemonstration to demonstration. At any time, in the
puristic sense, those technologies can be reevaluated,
and in many  cases are reevaluated,  to determine
whether the next stage funding should take place or not.
     I think that the system  doesn't work  all that well
and that is the problem.  The procedure  is there but
insufficient manpower, political influences,  etc.  prevent
the system from  working ideally,  that is,  incorporate
changes or cancel projects.
     DR. GAGE: I take quite a bit of comfort from your
clarification—
     MR.  ANTHONY: When we  arrive at the  point
when  we  have decided to  site a large  plant incor-
porating BACT  it  is  too  late to  incorporate new
discoveries made that day. A gasification plant costing
maybe $400 million to $1 billion incorporate technology
developed 5-10 years  ago.  If you have discovered a
new environmental threat it is too late to  incorporate
new controls,  usually.  That  may be the way to build
rockets and airplanes because the threat or risk cannot
be measured at all, but we cannot afford to build energy
facilities that way.
     I am sure most people will state we cannot afford to
build armaments that way either.
     MR. HEDEMAN: I want to react to I think the last
remark which  you made which in  effect was that the
public and EPA should be, I  think  you used the term,
"watch-dogs" with respect to the public health concerns
but that once those standards and concerns were estab-
lished that the technologies and judgment  calls by the
engineering profession should be, as I understand what
you were saying,  pretty much left to that profession.
     I suppose I am  having a little bit of difficulty focus-
ing on  that because to the extent that I get involved in
the analysis of energy projects, public health is not the
sole reason. It is equally controversial and equally the
subject  of discussion are the development of natural
resources  and the impact on those resources which,
frankly, go beyond the public health issue. It has been
traditionally the role of  the public  to  assist  in  that
analysis.
     I find  it rather  difficult to leave the decisions on
engineering technology to the engineers if those deci-
sions are  perhaps consistent with  public health  stan-
dards  but  rather inconsistent  or  controversial  with
respect to natural resource issue. I  wonder if you have
some thoughts on that.
     MR. ANTHONY: Yes.  The engineer  is trained to
meet standards or task statements. That is his  nature.
Specify for him how big, how wide,  how tall it should be
and then he will attempt to design a new technology or
improve on  an  existing technology  to  satisfy the
specification.
    Standards must incorporate some quantification of
the degree to which the  natural resource should be
preserved.  If it is clearly defined, the engineer  can re-
spond to it or not respond. I think our problem has been
that we are talking about extremely difficult situations to
define  5, 6, 10 years ahead of time and  this  is  what

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Hearing of October 3, 1979
poses a particular threat to the successful development
of a technology.
    So in other words, what I am saying is if we are
going beyond public health, that is fine. The engineer
doesn't care. If it is required to take a surface  mine
restore it to the original contour of the land, just tell the
engineer, he will do it.
    But once having set  this requirement you cannot
continue to change your standards because the first set
did not work  well  without considering  costs  and
benefits. Obsolescence is  common in our lines. Some
standards will have to remain marginally effective until
we can afford to change them.
    MR. HEDEMAN: I  guess  I have to react that it
seems to me much  easier to deal with numerical
engineering type of standards for public health than it
does natural resources.
    MR. ANTHONY: Yes.
    MR. HEDEMAN: And I think that is an issue that
has to be put out on the table for discussion.
    DR. REZNEK: Thank  you,  Mr. Anthony.  Our
next witness is Joel Robinson from Union Oil Company.
    MR. ROBINSON:  Thank you,  Dr.  Reznek.  1
appreciate the opportunity to be here today and I would
like to amplify on the comments that I made at the San
Francisco meeting on geothermal power. I apologize if I
read most of this because 1 don't want to miss  most of
the things I want to say so please bear with me.
    Union is the operator  of the world's largest geother-
mal project in The Geysers in Northern California. We
also operate two  major  geothermal facilities in the
Philippines and are constructing a demonstration geo-
thermal project in Imperial County in California. We are
also applying for permits for another similar plant nearby.
    In New Mexico, Union, Public Service Company of
New Mexico and DOE are joining together to fund a 50
megawatt demonstration plant. Union is also exploring
in most of the western states and pursuing international
geothermal developments in several Latin American,
Asian, and European countries.
    Union has  considerable experience  with  DOE
through our New Mexico project which we call the Baca
project (due to historic land  ownership). I  understand
that this Baca demonstration project is the first and only
geothermal project that has been subject to this Program
and Project Management System,  PPMS.  Although  I
understand your major issue  today is with the PPMS, I
would like to expand my  discussion to cover nearly all
of DOE's environmental activities.
    I would like to give just a brief background  of some
of the  geothermal constraints.  Geothermal does not
have  many distinct complex technologies such  as other
fuel sources do. In all electrical cases we must drill wells,
pipe fluids, spin turbines, and condense and cool fluids.
Even direct heat use of geothermal power is simple and
small.  Hence,  the environmental issues  are pretty
well known.
    Just last week at the Geothermal Resources Council
Conference in Reno  it  was remarked that there were
really no new environmental issues, mostly the same
ones that we  have known about for some time.
    Since  this  is the case,   major  environmental
research on the discovery of new environmental prob-
lems due to geothermal development is in my opinion a
misallocation  of funds.  DOE should spend its  efforts
more on site-specific aspects of individual projects and
on abatement technologies that will and must go hand-
in-hand with that development.
    Because  geothermal is such a site-specific fuel
source and because  it  is relatively small and benign
compared to other, quote "large module" fuel systems,
the five issues raised in  the Background Document are
relatively easy to answer.
    The first issue regards the appropriate government
levels for treating environmental issues. It is our opinion
that DOE serves the public best by addressing local site-
specific concerns. Each plant must be located  at the
resources, and these impacts  will occur  where the
resource is, and nearby. Establishment of an adequate
data baseline is imperative if  new areas are  to be
developed. This data will  help the public and local
officials plan properly for future development.
    The Imperial Valley Environmental Project, the
IVEP, developed such a data base and I  believe it has
helped Imperial Valley immensely. Similar work should
be continued.
    Regional  issues  are  not quite so  important in
geothermal as in other fuel sources primarily because of
its small modular nature.  However, national concerns
are important to introduce because sometimes local
issues lose the necessary national perspective needed
when examining a new fuel source. We feel that on
environmental grounds geothermal can compete with
and excel any new fuel source. The national perspective
will help keep that fact on the  table as local decisions
are made.
    The second  issue regards the type of projects
receiving major management attention. We feel that the
amount of attention a project gets should be commen-
surate with its size and cost and a lower limit should con-
tinue to be used to limit  unnecessary paperwork.  So far,
the Baca project has been the only geothermal  project
to  undergo  this  major review. We are  dissatisfied
because that project has  already been  delayed well
beyond its originally planned decision date and the EIS
is much too long.
     Some DOE staff are making an effort to keep it on
the track, but if the PPMS were to be applied to small
projects as well as large  ones with the same scrutiny that
the Baca project has received, we feel that geothermal
development could be relegated to the 21st century.
     Nor should small  projects be aggregated to pro-
gram status and  then  submitted to the PPMS. That
                                                   10

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                                                                               Statement of Mr. Robinson
would only delay many small, environmentally inconse-
quential projects to the detriment of the national inter-
est. We feel that it is critical that this nation identify wha
geothermal resources it has and then decide the best
way to develop or not to develop those resources.
     Aggregating the small resource identification efforts
into  a program for the PPMS would only serve as  a
delaying activity for opponents of particular local proj-
ects. I sense that an opponent would want to  delay the
resource  evaluation  because once  it is known  the\
would feel that the public might want it to be developed.
     Back on  the issue, California has recognized that
scaling the environmental review to the size of the proj-
ect is a good  way to encourage industry to explore for
other resources. California has compressed the environ-
mental review process for exploration projects to 135
days  while development projects can take a year to
study. This system works in California and  we think
DOE should  scale  its  environmental reviews in  a
similar way.
    The  third  issue  regards  criteria  to  be used  in
evaluating  individual  technologies.  As  I  mentioned
earlier, geothermal  projects have  very  site-specific
impacts and we feel  that explicit criteria are  the most
value for review by DOE. We also feel that DOE should
ask every question germane to the project but, once
they are answered, they should make a decision and
move on.
     It is imperative to remember that there will always
be unavoidable impacts on every project. No  project is
totally invisible or totally silent. However, there can be
some mitigation of most of these impacts. DOE should
develop explicit criteria of comparison, not only between
technologies within the same industry, but across indus-
tries. We think geothermal will compare favorably with
other fuel  sources.
    The  fourth issue regards the role  of non-DOE
groups in  evaluating  environmental issues. The public
should be involved. We need known points of informa-
tion  receiving and giving. DOE should  make special
efforts to keep state and especially local officials involved
as projects proceed through the environmental evalua-
tion process. However, conferences are not the way to
do this. Conferences  are self-defeating.  They do  not
answer any question, they only intensify emotions over
controversial  issues. They do  not speed solutions to
problems  and  they overly sensitize uninformed  members
of the public to non-issues and already resolved issues.
     I was once told  that conferences are much  like
bridge parties. If you  don't go, everyone gossips  about
you. So I think you must attend these things.
    Assistance to outside groups preparing EISs or, in
California as  we call them,  Environmental Impact
Reports,  is a  valuable way for DOE to involve  the
public. This assistance reduces the financial burden of
local  and  state agencies, it  teaches the public  about
geothermal power, and it prepares the citizens to plan
for geothermal development before it arrives.
    The establishment of the IVEP, that is the Imperial
Valley Environmental Project, is a good example of
this.  I understand that  DOE  has  recently funded a
geothermal officer and  a planner for Imperial County
and this effort should be continued. However,  direct
involvement of the  public in  reviewing internal DOE
documents would be of little value for geothermal proj-
ects because  each is so site-specific  that it would be
impossible to get local representation on each project
and still maintain the necessary continuity and perspective
that this representation requires.
    The last issue regards the integration of the envi-
ronmental factors into technology decisionmaking. We
feel that all of the proposals we make, either to DOE or
to anyone else, have environmental planning intimately
integrated into the technology to be proposed. Admit-
tedly, we don't have every answer. No one does. But
we feel we are on the right track for those answers. We
hope  that DOE can, in a similar manner, integrate its
environmental planning into technological decisions at
the earliest time. However, it seems that each tech-
nology should speak for itself and that the Office of the
Environment  should not stand as an advocate of one
fuel source over another. We feel this nation needs a
diversity of energy sources and that each and all should
contribute to that mix.
    A peripheral issue  raised here  is  whether DOE
should sponsor sub-demonstration size experiments on
a variety of technologies. If this means no demonstration
plants, it would be a big mistake.
    In geothermal, the technical options are only in a
narrow range. What is urgently needed is the demon-
stration  of cbntinuous, reliable economic operation of
full scale plants. Experimental facilities could not do
this.   Experimental  facilities  have  not  and will  not
demonstrate   these characteristics  to   encourage
developers and utilities to jump into geothermal.
    In closing, I would like to emphasize that we are
very enthusiastic about geothermal and we think it is a
significant  resource for America. DOE must serve the
public interest by encouraging geothermal development
to get that power on  line just as much as by careful envi-
ronmental scrutiny of each  technological option. These
should both occur simultaneously but promptly. We feel
that the most important addition to the PPMS would be
a strict timetable which DOE could adhere to once a
proposal was submitted. We and the rest of the industry
are ready to move ahead and such a timetable would
serve the national interest by encouraging progress in an
environmentally sound manner. Thank you.
    DR. REZNEK: Thank you. Are there questions
from the panel?
    MR. SIEK: I was encouraged to hear for the first
time that the states and locals were addressed as having
                                                   11

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Hearing of October 3,  1979
a part to play in the decisionmaking on some of these
environmental decisions. Some of the things I think that
have been overlooked in some of the energy develop-
ment  scenarios which have  been discussed, are the
synergistic development impacts to a region or to  an
area of various multiple energy  developments.  And
although on an ad hoc basis  DOE or EPA can look at
the control technology for a particular development,
sometimes  local  governments and the  local com-
munities as  well as the states become involved with
varied developments in an area.
    I would kind of like to get your reaction  since you
have been working with the State of California on how
you feel that the state  governments can become more
involved with standard setting, evaluation of that stan-
dard setting as it relates to  multiple development in
a region.
    MR. ROBINSON: Well, as you can guess,  I will
probably have to stick solely to geothermal, that is really
my area of knowledge,  but I think our experience in
California has  really amplified the fact that  the locals
have a very important role to play, in fact, even more so
than the State does, in setting standards.
    Also, in technology development, at The Geysers
we found that the local agencies are probably the most
conversant and most able group that we have encoun-
tered in assisting us to develop technology and working
with us in setting standards.
    The geothermal industry, as I mentioned, we feel is
rather benign and in fact there are few national envi-
ronmental standards on geothermal. What we find are
mostly State and local standards. We have worked very
closely with the State and local agencies on them.
    The role that the state could play in setting Federal
standards—is that what your  question is?
    MR. SIEK: Yes.
    MR. ROBINSON: Well, I think-all I can advo-
cate is that the State  continually remind the Federal
Government that it is primarily a State and local prob-
lem and that I would encourage DOE and the Office of
the Environment to involve the States wherever possi-
ble. In terms of specific guidance points that I could
advocate, I  am afraid I am at a loss.
    MR. SIEK: Well, of course,  I wasn't suggesting
that States  become involved with actually number-
setting and  research activities, but I can give you  an
example out of Ruth Clusen's shop, for example. They
have set up a DOE-state task force on oil shale develop-
ment primarily with the universities in Colorado, but
they have included State government on that task force
to participate in evaluation of certain research activities
and evaluation of those results and possibly develop-
ment of some standards for the future. So I think that is
an example of a way a State can become involved and
have an input to the general standard setting area.
    MR. ROBINSON: In California we have a State
Energy Commission which in the last couple of years
has sort of become a central state clearinghouse, if you
will, for geothermal activities. The DOE makes an effort
to touch base with the Energy Commission quite regu-
larly. There is not a formal organization that I am aware
of where DOE presents and receives comments to the
State academics or agencies but rather most of it goes
through contacts with the State Energy Commission.
    MR. ANTHONY: Considering the air part of stan-
dard setting,  Don  Goodwin  and  Walt  Barber  of
Research Triangle Park, EPA, have an advisory group
called NAPTAC. I am not sure whether someone repre-
senting the State is on that group, but that would be One
place where you would review all the air standards that
would go through that group.
    1 don't think there is a comparable group on the
effluent guidelines side, the water side, and that might
be something to create.
    DR. REZNEK:  Geothermal  is an energy tech-
nology which in terms of  conventional  national con-
cerns  of air pollutants and water pollutants  is more
benign than some of its competitors, but it is located for
the  most  part  in  areas which have great  national
resource value in terms of aesthetics, wilderness areas,
et cetera. You have indicated that you believe that the
State or local authorities should play a clear role on that.
Can you amplify for the  questions  of location and
natural resource preservation of wilderness areas what
the  Federal involvement may be? You also indicated
that Federal support for surveys of resources is impor-
tant. Can you amplify a little bit on what you feel is an
appropriate role for the Federal involvement?
  ~~MR. ROBINSON: Yes. In fact, we are deeply
involved with that problem right now, as ypu may be
aware. The Baca project that I mentioned in New Mex-
ico  is located in  a very attractive area and  it is, I
suppose, a candidate for public ownership.
    One of the things that disturbed  us greatly at the
outset  was that different agencies within the Federal
Government  did not participate  uniformly  in  the
preparation of the EIS.
    Our understanding  of the NEPA process is that
agencies should all combine their activities such that one
document really  addresses ail their needs.  We found
that there were internecine rivalries that  resulted in a
document that some  agencies feel is not  adequate for
their purposes and  hence they have to prepare an
additional document.
    I think this is really to  the detriment of the project
and of DOE's effort to demonstrate geothermal power. I
think what I would propose is that early in the stage that
DOE either directly or through the Interagency Coor-
dinating Council draw these other agencies into a joint
document such that one document is prepared and does
answer the questions satisfactorily for all of those agencies.
    DR. REZNEK: So, the Federal role is to make the
resources available for the quality EIS on the individual
                                                  12

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                                                                               Statement of Mr. Robinson
 project and to assure widespread Federal agreement on
 that EIS, is that what you are saying?
     MR. ROBINSON: I feel that should be a primary
 involvement of DOE as they prepare that EIS. Yes.
     MR.  HEDEMAN: It may be  unfair to  ask  thi;
 question, but there are now new procedures applicable
 to all Federal agencies that, among other things, would
 be intended to avoid the very problems you have raised. 1
 guess it is unfair because the procedures have only been
 effective for two months and so you may not be familiar
 with them to begin with and maybe I would just like to
 go  on record to note the procedures  and note thai
 maybe there is an opportunity now to solve the problem
 that you are raising.
     MR. ROBINSON: If I may respond, 1 am familiar
 with those and unfortunately what is  determined is that
 we would take the worst conditions of the old ones and
 new ones and combine them and that would apply to
 the DOE's Impact Statements. If  I recall one of their
 guidelines within those  new CEQ guidelines is a limita-
 tion of 150 pages. I referred in my presentation that this
 EIS is too long. This is not a very complex project com-
 pared to many other projects, and yet this  EIS is well
 over 300 pages already and growing.  I think if either the
 new or the old guidelines had been stuck to religiously, I
 think things would have gone smoother. They just don't
 seem to be adhered to.
     MS. CLUSEN: Obviously, I am not going to com-
 ment since my office reviews the EIS,  although we don't
 write it. I want to  go on record as saying that. But 1 do
 have an interest in your remarks about conferences and
 means of getting public inputs.
     We also are reviewing in my office the geothermal
 pilot project we have been doing as far as public par-
 ticipation is concerned. We have looked  at all the
 documentation and made some visits and talked with a
 lot of people.
     I was interested in your statement that conferences
 are not the best way. By and large, I  tend to agree with
 you and yet, I ask  you, how you would address  the
 problem of a Federal agency that wants to get substan-
 tial, informed input from knowledgeable segments of
 the public on what can only be a one-time pr at most a
 two step process? What other routes would you see? !
 ask this in all sincerity since we are grappling with this
 problem right now.  We have spent a lot of money on
 conferences and  I am trying to  decide whether it is
 worth it.
    MR. ROBINSON: As you are  aware,  there are
two DOE offices in Albuquerque and if we are talking
particularly about  this demonstration  project as an ex-
ample, the Operations Office and the  Project Office are
the  two that are there.
    I would propose that although it is currently prob-
ably understaffed,  the Project Office could serve as sort
of a clearinghouse and an information/dissemination
 center for this project. The two chief officials that are
 there I think would be overburdened if this was dumped
 on them unannounced, but I think they are probably the
 most conversant with the subject and could get the most
 academic and  most unbiased input from any  point
 within DOE. So 1 would advocate that the Project Office
 be the center of this dissemination and receiving. I think
 this would be a great addition to DOE's efforts.
     DR. REZNEK: You would say that specific funds
 be made available for that outreach program.
     MR. ROBINSON:  Yes.
     DR. REZNEK: What should be the involvement
 of the local  authorities, State  and  local, in  that
 dissemination activity?
     MR. ROBINSON: I think you will find that many
 of those State  and local agencies would be on the
 receiving end rather than on the disseminating end and
 that  they would appreciate  such an  effort by DOE to
 show DOE's involvement. I think they would like to see
 that.
     MR. SIEK: You know, it is kind of confusing to
 me sitting here listening to how we are proceeding. 1 am
 not  sure myself whether EPA should  be  doing this
 primary responsibility in  the research area or if  DOE
 should be and whether we are talking about the project
 development stage or the research stage.
     My understanding is that what we are talking about
 now is a proposed development that is undergoing an
 Environmental  Impact Statement and  that you are
 discussing public participation opportunities.
     MR. ROBINSON: That is what I am discussing.
     MR. SIEK: Yes, okay. If that is the case then, I
 would say that—you know, when you  are dealing in
 that  kind of a situation, it would seem that the States
 and  the local areas have a very important role to play
 because you  are  going  to  have to obtain  your en-
 vironmental permits, those that are required at the State
 level, in order to proceed with your project.
     MR. ROBINSON: That is correct.
     MR. SIEK: And if this is the case, then, you know,
 it is necessary for the public to become involved early on
 to assist in the review and the evaluation of that pro-
 posal. And Colorado is deeply involved with develop-
 ing a streamlined permitting process that does just that.
 And again, that is being funded out of Ruth Clusen's
 shop to try to address that specific problem of bringing
the public and the various levels of government in early
 on to understand and review a project. I think that is so
important  for  any energy  development now,  rapid
development that is  going on in the western  states, to
have some kind of a system available to do just that,
bring the people in where they understand the project.
     MR. ROBINSON: I think that is exactly right. I am
 addressing this, Mr. Siek, from the applicant's viewpoint
 of how do I get information into DOE  and  the State
 agencies. I think your point is very good. I mentioned in
                                                  13

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Hearing of October 3, 1979
my presentation  that DOE has  recently  funded  in
Imperial  County  a geothermal officer and  planner.
I think what these will do is the same thing that you are
talking about, help streamline and prepare and plan for
the incoming geothermal power plants.  Right now  in
Imperial  County  there are no operating geothermal
power plants but they perceive a  curve  that  goes ex-
ponentially upward and they want to be ready for this.
I think this is another path that  certainly would be
worthwhile and should be expanded.
    DR. REZNEK: Thank you.
    DR.  PATTON:  Mr.  Chairman? You  know,  I
visited the geothermal facility in The Geysers, California
and I would ask just a couple of  questions. First, the
Geysers facility has been in operation for quite some
time,  hasn't it?
    MR.  ROBINSON: The first power plant was in-
stalled in 1960. The first drilling occurred there in the
mid-'50s.
    DR.  PATTON:  So  we are  not talking about
something where the technology is relatively uncertain,
right?
    MR. ROBINSON: That is correct.
    DR.  PATTON:  Now,  when I  was  there, my
understanding was that it was located in a little valley
where few people, if any live, I guess there  was one
house that I recall  seeing. Steam was  naturally coming
to the surface of the earth at this place,  people found
that there was this geothermal potential, and so now
what you have done is drilled holes, capped the steam,
and used it to spin turbines, and generate electricity.
Compared with other alternatives, I  would  have  to
describe it as relatively clean. Right?
    MR. ROBINSON: I agree.
    DR.  PATTON:  Is the technology to be used in,
say, the New Mexico project significantly different? Is it
wet steam?
    MR.  ROBINSON: It is  wet steam but it is not
significantly different. You still drill wells, you still pipe
fluids, spin turbines.
    DR. PATTON: All right. Then my concern is not
for the people who are participating in  the development
of the 300 page environmental impact statement, my
concern is for the nation as a whole, for  the silent ma-
jority, for the people who still think we  would like  to
have jobs and fuel and so on, and 1 wonder if we aren't
in danger of going too far in trying to involve each and
every individual  in  each and every  decision—you
know, that is why we have a Congress,  why we have
public officials, et cetera. It seems to me EPA's job is to
look  after  the public-at-Iarge; DOE's  job is  to try  to
develop additional energy facilities; and I do concern
myself that by trying to pay homage to the concern  of
each  individual who takes a position on each issue we
run the risk of stalling the entire nation for us all. I think
you have brought up geothermal and  I am kind  of
pleased you  did  because it is a  strikingly simple and
clean technology and yet the experiences you have had
to date can best be described as frustrating delays. Do 1
over-simplify the issue?
    MR. ROBINSON: You said it much better than I
could.
    DR. PATTON: Thank you.
    MR. ROBINSON: 1 think you are right, we need a
national perspective. Our historical experiences are that
local and State opposition, the people living next door,
have really retarded the growth of this benign source but
I think it is imperative, however, that these people be in-
cluded in the decision that is made. But once the deci-
sion is made, we ought to move ahead.
    DR. REZNEK: Thank you. We will take  a 15
minute  break.  I believe  coffee is  available.  We will
reconvene at 11:00.
    (Brief recess)
    DR. REZNEK: The first witness in this session will
be  Merilyn Reeves.  David Pate's plane has  been
delayed and we will try to pick him up at the end of the
day. Once again, if any member  of the audience is
unscheduled and wants to testify,  please let us know so
we  can prepare in the afternoon  closing sessions  to
allow for you.  Ms. Reeves?
    MS. REEVES: Members of the Hearing Panel and
ladies and gentlemen, I appreciate  this opportunity to
come before you.  I am a citizen volunteer. 1 am not an
expert.  I am a lay individual.  I am bringing with me
today my perspective as it deals with my participation to
the  Department of Energy's Environmental Advisory
Committee. I  in  no  way am  here to represent that
Environmental Advisory  Committee. I also  bring the
perspective of more than 10 years of experience serving
on  various advisory committees,  commissions,  task
forces, et cetera on environmental  and energy issues,
on the local, State, and Federal level.
    I think my remarks will have the greatest effect in
areas that I know  the most about. First, the techniques
and second, the productivity of public participation, and
I am concerned about both of these.
    I differ from one of the previous speakers. I do not
share  his great faith in the engineering community  to
solve energy problems. I believe that our energy prob-
lems are more of a social, environmental nature which
may defy engineering solutions.
    I believe that the public clearly understands that too
many mistakes have been made in the past because we
have  failed  to recognize the importance of social,
environmental, health, and other related effects. We
cannot  expect instant public  confidence for  future
reviews of projects.
    1  watched the TV show last night, "The Plague of
Children," I have seen  "The Killing Ground," and I
have seen the Three  Mile Island publicity. I serve  as
chairman of Maryland's Hazardous Substance Advisory
Committee and I  share no illusions about the difficulty
                                                   14

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                                                                                 Statement of Ms. Reeves
of educating the general public to the problems that we
face in regard to environmental risks and hazards.
     Last year I presented a paper on public participa-
tion at the National Conference on Citizen Participation
and I am  submitting a  copy of this for  the  record
because it clearly defines what I think public participa-
tion is  and  provides two   examples of  successful
programs.
     For this hearing I want  to limit my comments to
three major questions which were listed in the letter re-
questing me to testify. The first question asked if there
were sufficient opportunities  for non-DOE  interests to
participate  in  the  decision making process  and  the
answer is no. There are not sufficient opportunities.
    This should not mean that  there are  individuals
within DOE who are to blame.  DOE and its agencies
which proceeded it, the Federal Energy Office through
the Federal Energy Administration through  ERDA and
on down to DOE, has operated in a crisis atmosphere
replete with reorganization and political indecision. All
of this has superceded efforts to establish a good public
participation program.
    From the  ill-advised decision to store  oil  in salt
domes to the most recent impossible synfuel proposal, it
is  very obvious to me that the Department of Energy
could benefit  from  an  effective public participation
program.
     It think it is doubtful  if anyone knows how DOE's
decisionmaking process works and how or when  the
public could provide timely advice. In the past year the
Environmental Advisory Committee for the Department
of Energy has not been able to successfully participate in
the decisionmaking process. The  former Secretary met
with the Committee at its first meeting and provided no
advice on what  he  needed or what he wanted. The
Assistant Secretary Ruth  Clusen  felt that it was better
that we struggle without  her advice.  Our Committee
finally did pass a motion requesting that she give  us
guidance on what  particular  issues she would  like  to
have the  Environmental  Advisory Committee  specif-
ically deal with.
     At every meeting of this Committee the members
have noted that it is difficult to  understand how  the
system works or  how the  public can influence the deci-
sionmaking process.
     During the course of high interest in energy DOE,
and, of course, the preceding Federal energy agencies,
have conducted many  public information  meetings.
They have solicited comments. I have participated and
prepared many  statements over the years.  But it is
never clear how DOE uses citizen comment.  There is no
feedback to the citizens that tell us, "okay, as a result of
testimony, we  didn't like  this  advice and we  accepted
that advice." Feedback is desperately needed.
    I recommend  that DOE provide greater oppor-
tunities for public participation in  all of  its activities and
programs. But it must be developed so that all citizens
and interest groups have equal opportunity to influence
decisions,  and  a  process must be  set  up that is
somewhat simple to follow.
    Also, a process must be established to respond to
public comment.  DOE  should  give  very  special
encouragement,  including  financial  assistance if
necessary, to ensure that  all interests are represented at
hearings. We all know that business and industry, par-
ticularly those which have an economic interest at stake,
will participate. Public interest organizations and citizens
do not have the financial wherewithal to  participate
as well.
    The  second question I was asked to deal with is
what  explicit criteria  should be used in  evaluating
technology development. It seems very apparent to me
that  the  Department  of  Energy  continues to be
dominated by a bias  toward nuclear energy and by
other centralized, high technology sources. I believe this
dominance is reflected in the National Energy Plans,
particularly NEP 2; it is reflected in the budget; and it is
even  reflected in the internal R&D review procedures.
    Energy  conservation, small-scale decentralized
non-nuclear technology is provided less funding, much
less Departmental time and attention, certainly much
less than nuclear energy  with all of the waste related
problems that have received heavy funding.
    I  believe that proposals for research and develop-
ment,  even the funding  level decisions,  need to be
reviewed by  more members  of  the general scientific
community and the public. I would like to give a specific
example.
    In the Office of the Environment, many unsolicited
proposals are received. We understand that these are
reviewed by a volunteer  peer process. Many of these
peers may have volunteered during the heyday of the
Atomic Energy Commission. This peer process may not
be biased against nonnuclear technology, but it is very
important that research and development proposals be
reviewed by a multi-disciplinary scientific committee
which includes members of the lay  public. It is not im-
possible to do this.
    The  complex procedures which were established
by DOE to guide the technology expenditures, the Pro-
gram  and Project Management System and its compo-
nent parts, appear to me to fail to provide for adequate
evaluation of alternative actions or programs. We get
trapped on  these single  track programs  which don't
allow  adequate evaluation of alternatives.  By the  time
that DOE staff has committed large amounts of time and
financial resources  to a particular project  through the
PPMS review, it is too late to adequately address alter-
natives in an  Environmental Impact Statement.
    There appears to  be  very inadequate opportunity
for public comment at key decision points. Perhaps this
is because the PPMS is very new.  It appears that the
                                                   15

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Hearing of October 3, 1979
process does not delineate those key decision points
even for DOE staff.
     I believe  a multi-disciplinary and  lay committee
should be established to monitor and to provide advice
on DOE's environmental research planning and assess-
ment process. I still share great concern that the PPMS,
since it is only used for major projects, will cause the
small,  decentralized nonnuclear  projects, and  par-
ticularly the advantages of energy conservation, to be
lost in the shuffle.
     The last point I would like to make in regard to
criteria which  should be used to evaluate technology
development  is that  a greater  emphasis should  be
placed on the concept of net energy. I do not believe
that there is an adequate examination of how much
energy it takes to produce new energy so that the cost
benefits of that net energy can be fully analyzed.
     The third  question that  I was asked to address,
concerns what is the appropriate government level for
dealing with environment issues.
     I will duck that question because 1 don't believe that
the level of responsibility is an important issue. If all the
issues  are addressed,  and  all appropriate  levels of
government are involved in the process, then it may not
be important which level is designated as  the lead.
     Past  decisions of  DOE  clearly indicate that en-
vironmental review has not involved all affected levels
of government,  or even all environmental issues. I go
back to the two examples, the decision to put a strategic
oil reserve in salt domes or the most recent administra-
tion proposal for a crash synfuel process. These needed
much greater public participation prior to  the decision-
making.  Some of this decisionmaking needs to be site
oriented.
     Local and state governments should  be given op-
portunity  for  a  greater  degree  of   involvement.
However,  these same  governments  may  be  too
parochial to be designated as the only level of govern-
ment to deal with environmental issues.
     I believe that a thorough environmental review of
energy proposals will result in a more cost-effective proj-
ect.  I do not believe that haste is all that necessary in
looking towards our future energy needs. The long term
public interest is best served by wise use  of all natural
resources. Crash energy programs and hasty govern-
ment decisions may not yield the most cost effective,
environmentally sound  energy sources. For example,
far too much public money has been used for nuclear
research and development and there is no evidence that
it is the most cost effective source for the future. A
thorough environmental review may prevent spending
millions of dollars of public money for a nonnuclear
energy  source which is not environmentally sound or
cost effective. I think I  am basically saying that the en-
vironmental review is the best economic tool we have.
     I have attached to the copy of the testimony that  I
have given  for the recorder,  some observations that  I
made after the Enviromental Energy Committee toured
the pilot  solvent refined  coal  plant  at  Fort  Lewis,
Washington.  These  personal  observations  were
distributed to members of the DOE  Environmental Ad-
visory Committee and I only had one available copy,
I regret to say, for this Panel today.
    I also have submitted with my testimony comments
on.public participation, the techniques and the produc-
tivity of it. It is obvious  that some  people view public
participation as a delaying tactic. I do not view this as a
delaying tactic. I believe that public participation is ab-
solutely essential if  we are to  achieve energy  source
development.  It is not going to work when you try to
bypass public involvement and you are going to have
more problems. 1 am  very concerned that public par-
ticipation is becoming  almost an  end unto itself rather
than a means of achieving goals. I would caution that as
the Department of Energy  and EPA seek to encourage
more and more public participation, they always seek it
in  terms of decisionmaking. This is  different from pro-
viding information, educating, but it is providing an op-
portunity clearly understood by all to participate in the
decisionmaking.
    Thank you  for this opportunity to  present  my
views. ! hope they are helpful to you. 1 think that you
have a very difficult problem in looking at the issues that
you have before you.
    DR. REZNEK: Thank you very much.  Does the
Panel have questions?
    DR. PATTON: You mentioned that  you feel it is
essential that all citizens have equal opportunity to in-
fluence  decisions, and  1 believe you also felt it  ap-
propriate that there  be financial assistance to aid this. I
guess 1 would  be interested in our  views  on  how you
contrast that decision with the fact that in our particular
form of government we have a Congress where you try
to get representation  in the  House on  the basis of
population and, of course,  representation in the  Senate
on the basis of each State, and it seems to me, and I
have always assumed  and understood, that that is the
principal avenue for  the  public to influence what it
wishes its governments to do. Of course, the Congress
then has established agencies and the agency is given a
mandate to  carry out  some particular thing and if, in
fact, the public finds they are not happy with what that  '
agency is doing, it seems  to me the public still has its
recourse through Congress. Through the appropria-
tions process,  you can stop an agency cold within  12
months.
    I just wonder why that particular process doesn't
provide us  with what  you sought, which  was that
citizens have an opportunity to influence decisions. Of
course, I can appreciate that getting all citizens to have
equal opportunity is particularly difficult. Furthermore,
it  would seem to me to be very difficult to try  to give
financial assistance  to all  citizens to give them equal
opportunity, and considering that we as taxpayers are
                                                   16

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                                                                                  Statement of Ms. Reeves
the ultimate source  of the financial assistance,  how
would you go about doling out the monies to give some
citizens an opportunity to speak to these issues.  You
obviously couldn't give financial assistance equal to all
citizens.
    MS. REEVES: I think when you talk about Con-
gress you are describing something that no longer exists
in terms of the general public influencing decisions only
through Congress.
    Congress once it enacted  the Clean Water Act, the
Water Pollution Control Amendments PL92-500  back
in 1972, clearly indicated that they wanted the public to
follow agency implementation  of that Act. This then has
come about in Law after Law in which we now have the
situation  in  which our  elected  representatives have
given authority to the public, so to speak, to work and
participate in agency  implementation decisions.
    That was not the case, say, 30 years ago in which
you did go back to Congress and say "do  something for
us." But now we, the public,  at various levels, have a
mandated responsibility to participate in agency deci-
sions. The agencies have a responsibility to seek out the
public so they can participate in decisionmaking within
the bureaucracy.
    It is this type of public participation that I think we
need to direct a great deal of time and attention to so it
will be productive. Agencies are strapped for finances. It
is very easy to set up a committee and say "see, we
have public participation." But if the public participation
system is not satisfactory to members of the public, then
you will find that delays occur, and you will find suspi-
cions  and confrontation.
    I would like to talk a little bit about financing public
participation. Because agencies  are required  to  hold
public hearings, generally  required by the very laws that
have been enacted by Congress, it is difficult then to say
"can we  hold a public hearing  in Philadelphia" and
expect to get  a  broad-based  comment  at  that public
hearing. Can we expect that citizens who should have
their views represented wit! travel  to Philadelphia to
testify? i would like to point out that I am talking about
public interest groups perhaps more than  individual
citizens. Citizens who represent public interest groups
may need financial assistance.
    If such groups cannot be  heard at the public hear-
ing in Philadelphia, for example, because they  have no
transportation or funds provided, then 1 do not believe
the agency has lived up to its congressional mandate to
seek out the views of the public. So I believe that there
has to be financial assistance for public participation.
The precedent was set in 1972, by requiring public par-
ticipation. When you  invite a witness to give testimony
you must provide some assistance to do  this.
    There are various ways that  the  agency,  the
Department of Energy, or the Environmental Protection
Agency, can assist in getting broad-based public com-
ment and public participation. The expenditure  of funds
will not necessarily be very large in comparison to the
total expenditure of a project.
    This has been borne out in waste water treatment
plants where you will talk about building a $29 million
waste water treatment plant, and you will talk about
spending maybe less than $50,000 to ensure that there
is a public review or participation. Those are small funds
spent in order to hopefully get a better product.
    MS. CLUSEN: Mrs. Reeves, needless to say, I
share many of your  attitudes  given our  common
background.  In addition  to that, 1  think many of the
things that you have to say about  the process of the
Department of Energy and indeed to the Office of En-
vironment are on target.
    I would like to say two things and then  ask you
something else. One is that I am sure you understand
that the reason for my refusal, up until I was asked to
direct the Environmental Advisory committee et al, is
related to the fact  that, according to the statute, it
reports to the Secretary of the  Department, and it was
primarily  appointed by him, and  reports to  the
Secretary through me.
    Nevertheless, since the request came  in from the
Committee, I have indeed suggested to you some possi-
ble fieldsjjf investigation.   _
    With regard to money, I would like to tell you that I
think  the Department, and this is  proven by budget
statistics for  '80 and '81 both,  has consistently moved
under a mandate for equalizing the spending on nuclear
technologies and fossil and other technologies. I think
this is somewhat represented by the fact that the budget
for the Office of Environment for fiscal '80, which we
are now in, and the one which we are about to propose
for '81,  spends substantially  more amounts of money
on  fossil because that is the  direction  in which  the
Administration is going as is the Department of Energy.
    With regard  to  funding for public participation,
once  again, this is  something in which I have long
believed. I must tell you, and in fact I think Dr. Reznek
would bear me out in this also, that we in the agencies
are encountering  some  resistance on the  part of  the
Congress and the Office  of Management and Budget
regarding this kind  of  thing.  Sometimes assertion is
even made that we are building a constituency when we
do this. I would be glad to have you react to that.
    I can say that this is not constituency building. But if
someone from the outside believes that there is no ele-
ment of that, it would be helpful for someone like you to
say so to press the point.
    MS. REEVES: Having dealt with various aspects
of the public in various committees, I would say there is
no  possibility for  constituent building because of  the
adversarial position  which invariably arises on every
diverse issue.
    However, if the Office of the  Budget and if the
Congress is concerned about the constituent building,
perhaps they should be more concerned about the lack
                                                   17

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Hearing of October 3, 1979
of constituent building in terms of looking at future
energy needs and solving energy problems. If funds can
be spent which will help to achieve that goal, they are
going to be funds well spent  all the way across the
board.
    I really have no fears that the Environmental Pro-
tection Agency or the Department of Energy is capable
of developing a coherent constituency out there which
will always respond in some favorable way.  Like all
things in public life, there are strange bedfellows when
one opposes or supports projects and the constituencies
change. One time the  League of  Women Voters will
find itself aligned with the Chamber of Commerce, and
another time we will find ourselves aligned with the
Audubon Society.
    I do not believe that this is a valid point of view. I
brought up the issues that we have made  too many
mistakes in the past, and I view public participation as
an effort to try to broaden public knowledge, to involve
individuals in decisionmaking because they are going to
be involved anyway. It would be far better to develop a
systematic approach, a constructive approach to do this
than to leave it in the confrontation and adversary posi-
tion in which  it is going to occur if you don't.
    DR. REZNEK: I have a series of three or so ques-
tions I would like to go over. One relates to two of your
statements about the appropriate level and you seem to
indicate that all levels should be involved in all decisions
and tie  that also to the question  of haste  not  being
necessary in energy decisions.
    There are many people who disagree and feel the
decisionmaking process needs  to be streamlined, that
decisions and responsibilities for these decisions need to
be allocated,  decisions have  to be made, and we
must move ahead. Can you comment a little bit on the
feeling?
    MS. REEVES: First, 1 do not necessarily believe
that all levels  of government  should be participating in
all decisions, and I would hope that it would be only the
appropriate levels of government.
    When it comes to actual siting of a gasification of
coal project, it doesn't really matter how much evidence
the Department of Energy or EPA have accumulated,
and how much work has been done in terms of the
Federal  level if in fact local government, the one that is
directly responsible where the plant is going to be, has
been left out of the process.
    Haste makes waste. ! believe  that we have  to be
very  careful  that we  develop  a  process  so people
understand what decisions need to be  made and in
what timeframe. We really don't have this. So if you are
going to short circuit decisions or fast track energy deci-
sions in any way, we have to make certain that you
haven't  hastily put together something which will not
yield the most cost effective energy program, an en-
vironmentally sound  energy  program. This is what  I
really fear.
     I do not believe that this country has faced up to
the energy conservation opportunities that are available
to it. The more that we face the energy conservation
opportunities that are available, and the more we work
on  tightening up the  waste across  the board in  all
segments of energy use, the more time we will have to
analyze alternatives, and the more time we will have to
perfect a PPMS system within DOE to be able to analyze
these. And we will have to involve local government
and answer questions.  It disturbs me that we are not
taking advantage of energy conservation. We are look-
ing at nuclear fission, and  other big processes.  When
you look at the 30 major projects in the PPMS system
these are all major, long-range projects. We are not giv-
ing enough time to the  short-term needs.
     DR. REZNEK: The second question relates par-
tially to your answer and second, to the observation that
you felt the net energy calculation should be done on all
proposed supply technologies. Do you feel that that can
be  done meaningfully,  and that net  energy yields  of
supply technologies could be compared to investments
in conservation technologies?
     MS. REEVES: I would like to see a stab at it. I am
not going to say that it probably can be done and it is
easy to be done,  but I would like  to see more done
along those lines.  I would like to see more information
put out for public review and for scientific comment on
net energy. You will not really be able to analyze how
effective it is until there  are some good net energy
studies done of some  of these various new energy
sources.
     DR. REZNEK: In your comments on public par-
ticipation,  you indicated  that  there are really two
aspects; one is involvement in decisions, the other is an
outreach or public information supply  prior to the deci-
sion process.  Have you thought about ways of identify-
ing  and institutionalizing the responsibility for that, and
to be able to track the responsibility  for that within a
bureaucracy, and in your experience,  are there any in-
stitutionalizations in any of the bureaucracies that do it
better than others?
    MS. REEVES: It is almost impossible to establish
an office in anything as diverse as  the Department  of
Energy or the Environmental Protection Agency which
will cut across the various interests. So the best public
participation is always that which is done in  a smaller,
more site-specific way or  on a project that is oriented
toward a key decision.
    My idea with public participation is first you decide
what decisions have to be made, and then you decide
when are you going to make those decisions, and then
you decide how is it best to bring in the public  to provide
advice at key points in  the  decisionmaking process. If
we did this, it would help to simplify the matter. I am not
sure that we need elaborate institutional arrangements,
and much better  institutional arrangements, when it
comes to the  dissemination  of informtion.
                                                   18

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                                                                                Statement of Mr. Markey
    I see these as two different types of functions, all
within DOE and within EPA. There is the constant need
to make certain that  information is provided to the
various interest groups in a timely fashion. This is a job
that has to be borne by the agency. Some people say it
is best in the old PR departments, or in departments
with a different look.
    But when it comes to true public participation which
involves asking the public for advice, and receiving ad-
vice from various interest groups at key decision points,
first the agency has to tell us what are your key decision
points and  what is your timeframe. Then I think it is
going to be relatively easy to figure out the methodology
for doing this.
    DR. REZNEK: Thank you. Any other questions?
    (No response)
    DR. REZNEK: Our next witness is Kevin Markey,
member of Friends of the Earth.
    MR. MARKEY: Thank you, Dr. Reznek.  Those
were very thoughtful comments (to previous witnesses).
First of all, I will bring you greetings of a fiscal new year
and  hopefully my testimony  today will  perfect the
PPMS system. We will see whether we can do that.
    Friends of the Earth appreciates this opportunity to
address the adequacy of attention to environmental
protection and energy conservation within the Depart-
ment  of   Energy's   research,  development,   and
demonstration management process.
    We have actively followed progress of DOE's pro-
grams since its establishment and before that, during
the tenure of the Energy Research and Development
Administration.
    Today we monitor DOE directly in regular discus-
sions with the Department as well as through  our par-
ticipation in various panels which advise or evaluate the
Department, including the National Petroleum Council,
the House  Science and Technology Committee  Ad-
visory Panel on Synthetic  Fuels, the Department of the
Interior's Oil Shale Environmental Advisory Panel, Of-
fice of  Technology Assessment studies, and other
bodies.
    We have been impressed by EPA's preparation for
this hearing which included an in-depth evaluation of
DOE's management system,  field workshops,  and fur-
ther analysis of workshop results. I will address some of
the questions  which  EPA has posed in the  Hearing
Background Document. My written testimony, which  I
have submitted to you, I would ask be included in the
record. I will leave out some portions of it for my  oral
presentation.

Appropriate Governmental Level for
Treating Environmental Concerns

    The appropriate governmental level for the treat-
ment of environmental concerns depends on the type of
government action anticipated. A hierarchical organiza-
tion makes sense for environmental regulation due to
our Federal legal system.
    However, DOE has  an RD&D mission. A strict
hierarchical organization of its functions would not ex-
pedite or improve the quality of its research, it  would
only complicate an already difficult to manage program.
    There  are important roles  for other levels and
agencies of government to fill in research and develop-
ment activities. DOE needs to involve other govern-
ment agencies, especially  those who will ultimately be
responsible to regulate the impacts which DOE is now
investigating,  in  identifying  environmental  RD&D
needs.
    DOE  must better communicate the  results of its
research with regulatory agencies at all levels of govern-
ment and the public, including legislators responsible for
the enactment of new regulatory programs, and the
establishment of energy policy.
    Thirdly, many  agencies possess expertise  which
DOE might be able to use to conduct research under
direct contract or interagency agreement.
    DOE should also consider how its RD&D responsi-
bilities can help local governments or states mitigate the
impacts of energy development, especially synthetic
fuel commercialization. We refer to those monitoring ef-
forts which might be appropriately funded as an RD&D
effort, not strictly as socioeconomic mitigation.
    Congress, by prematurely stimulating an oil shale
industry for example,  will unfortunately create one of
the largest social and biological science laboratories ever
imagined.  From an academic point of view, that might
be attractive, but particularly from the perspective of a
community which needs accurate socioeconomic data
to correct problems, assistance to provide the data, or
health, water quality, or other monitoring on a regional
basis is appropriate.
    Finally, local and state governments and the public
need to be consulted when DOE makes  decisions  on
specific sites and specific projects.

Types of Projects Receiving
Major Management Attention

    There was a question about the types of projects
receiving  major  management  attention. EPA asks
whether criteria other than budget commitments should
be used in designating energy systems as "major." We
believe that criteria such  as "potential environmental
consequences"  and  "energy  industry  significance"
should  be  used. In addition, subject to the conditions
and the suggestions that  I am about to  make, small
related projects should be combined  into  programs
which should be subject to the  Program and Project
Management System (PPMS).
                                                  19

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Hearing of October 3, 1979
PPMS Structure

    By far the most significant issue, though, is  the
structure of the PPMS system itself, not how projects
are designated as major or minor.
    The most intractible problem with technology
development programs is the single purpose momen-
tum which they generate to carry each new technology
into full commercialization whether it is desirable to do
so or not.
    Unfortunately, DOE's management system does
everything possible to reinforce  rather than  to correct
this fault. It is hardware  oriented; it is not  geared to
problem solving. There is no meaningful competition
among  technologies  within  each  resource  category.
There  is no  real  competition  among  resources  in
developing  national  energy plans  or  determining
budgetary priorities. There are  limited environmental
criteria to judge among technologies.
    Congress,  however, when it enacted  the Non-
Nuclear Energy Research and Development Act, clearly
desired the development of a diverse, almost pluralistic
set of technology choices; yet it clearly directed DOE,
than ERDA, to give preference to those processes with
the least environmental impact.
    Despite its intent to  facilitate the timely develop-
ment  of new technologies, the  PPMS has  not led to
rapid progress. DOE  decisionmaking languishes. Con-
gress, the President, and DOE's  Resource Applications
Office (RA) have consequently sidestepped the RD&D
process and are proceeding directly to commercializa-
tion efforts most prematurely.
    Congressional action makes a shambles of  the
orderly progression of technology acquisition  from basic
research to commercial acceptance in many steps when
it decides to make the transition in one or two steps.
    Independently of  the Assistant  Secretaries  for
Energy Technologies  (ET), Fossil Energy  (FE), and En-
vironment (EV), and  prior to any departmental finding
or the preparation of Environmental Impact Statement,
RA was heavily pushing the $3 per barrel tax credit on
the Hill  and in the Administration.
    On the other hand,  in terms of RD&D progress,
DOE  processing of a  congressionally  authorized oil
shale surface retort is one example of delay which is not
even  subject to the highly structured  and  formalized
PPMS process.
    Authorized in 1977 and appropriated in  1978,
only during this summer was  a project opportunity
notice for a first retort design phase issued. After retort
designs, there will be a competition among  alternative
designs for construction. A decision on actual construc-
tion will be several years in the  making.  In related
action, the draft Environmental Impact Statement for
the construction of fullscale retort at Anvil Points, Col-
orado went through four preliminary drafts.
    On the other hand, there as no guarantee that the
process and the delays  and protections that are pro-
vided in the PPMS offer any environmental advantages.
The suggestion made in one of the workshops for an
audit of the effectiveness of the PPMS system is a good
one.
    Thus, the question before us is how to resolve the
conflicting needs for rapid technological progress unen-
cumbered by bureaucratic delay with the presumably
opposite need to assess environmental problems, com-
pare technologies, and make choices.
    We would like to suggest some changes in PPMS
which might achieve both of these goals without disrupt-
ing the entire system.
    First of all, the system should be organized on a
program not a project basis. Second, programs should
be hardware oriented, they should be aimed at problem
solving.
    An appropriate division of  programs under  this
scheme might be by resource type and product (or
product substitution). For example,  dividing among
liquids from oil shale, gas from  oil shale, liquids from
coal, liquids from biomass,  et cetera.  Dividing DOE
RD&D activities into programs in this manner, though
this is  certainly not the only alternative, has several
advantages.
    Classifying programs  by resources and products
forms the framework in which programs can be com-
pared and priorities set. For example, comparing liquids
from oil shale with liquids from biomass, saving liquids
through  conservation,  and  liquids  through  coal.
Ultimately technologies  should  be compared on  the
basis of their end uses (See below).
    It is likely that research problems within each pro-
gram   will  be  similar.  For   example,  resource
characterization, environmental  baselines, certain air
pollution controls, and other environmental impacts will
be similar among all oil shale technologies.
    Several hardware-oriented projects will certainly be
included in each program offering the  opportunity to
compare them directly. For example, in oil shale there
would be Occidental, Equity, Geokinetics as well as sur-
face retorting technologies.
    Environmental  and energy  technology RD&D ef-
forts'" can be  coordinated  within each program.  One
example of this is the current effort of ET (now FE) and
EV to coordinate their activities in oil shale.
    Each program, regardless  of its size or budget,
should be subject to the same review and evaluation
criteria.
    The third design criteria is the establishment of a
competitive system for prioritizing programs on the basis
of costs and technical readiness  and impacts for deter-
mining RD&D resources and commercialization efforts
devoted to each program.
    Fourth, similarly, a  system for competition among
technologies within each program should  be established.
                                                   20

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                                                                                 Statement of Mr. Markey
     Decisions regarding technologies within programs
and competition among programs must be based on the
comparison  of impacts  for entire fuel cycles among
similar  end-use applications.  For  example:  Coal/
combustion/electricity/space heating vs. coal/slagging
Lurgi/gas/space heating vs. solar/annual storage water
system/space heating vs. etc.
     Fifth, within each program, technology develop-
ment efforts should proceed along parallel paths where
appropriate rather than along  a single track. Long term
program plans can be established to chart the expected
program progress. The  program plan should  clearly
define decision points and opportunities for,public in-
volvement  in  affecting  those decisions.  Technical
roadblocks, environmental concerns, project competi-
tion, and program reevaluations will affect the progress
of each  project with that program plan.
     Sixth,   a  programmatic   Environmental Impact
Statement prepared on the program plan would be the
tool used by the Department and by the public to assign
priorities among competing technologies, evaluate pro-
gram options,  identify research needs, and coordinate
technology and environmental RD&D.
     Seventh,  likewise, the tool which can be used to
compare programs  and make commercialization and
budgetary decisions would be  the  biennial National
Energy Plan Environmental Impact Statement.
     There are two partial precedents for the system I
have outlined above. First, DOE has recently released a
draft program  management plan for oil shale RD&D. It
undertakes a  coordinated  technology and environ-
mental RD&D program to be  undertaken jointly by ET
and EV. It coordinates parallel resource characteriza-
tion, environmental baseline, environmental control,
and technology development  plans.
     Of interest is its emphasis on problem solving rather
than on hardware. DOE in that plan starts with a state-
ment of the problem, it then identifies RD&D needs to
solve the problem, designs  projects  to meet  those
needs, and then coordinates the projects.
     Second of all, the Department of the Interior has
established a  coal management program  which  has
several  tiers of environmental  impact statements to
decide on leasing and the availablility of resources.
     In that system,  regional environmental statements
will access alternative leasing tracts and rank such tracts
on the  basis  of  environmental acceptability.  Com-
parably, the DOE Program Plan  E1S could evaluate
alternative projects and rank them on various bases.
     Back to the Department  of Interior, the national
coal EIS would set national  and regional  production
goals. Similarly, a  National  Energy Plan  EIS would
assess each program's place in DOE's budget and com-
mercialization  efforts. Recall that the principal goal of
the National Environmental Policy Act is the compari-
sion of alternatives. This is perfectly suited to making
the choice among competing programs and projects.
     The Energy System's Acquisition Advisory Board
would still have a role in this process although it will
primarily assess the design of programs and priorities
among energy sources.
     The ninth  design criteria is that certain individual
projects  will themselves  be  major  Federal actions
significantly  affecting  the environment. NEPA com-
pliance is essential. However, a coordinated program
plan  can anticipate  such  a need  and  avoid  EIS
preparation-generated delays.
     Finally, it is essential to integrate Resource Applica-
tions (RA) activities within RD&D activities.
     Too often  RA acts to promote commercialization
efforts without the benefit of expert technical assistance
and  makes unsubstantiated claims in promoting various
technologies. Closer communication may eliminate this
problem if DOE is willing  to see it eliminated. The goal
to integrate  environmental factors in  technology deci-
sionmaking will be frustrated  if some  portions of DOE
insist on acting  entirely without constraint.
     Another purpose for closer RA coordination with
ET and EV is to assist in technology transfer or commer-
cialization of small advances in technology and  en-
vironmental R&D. Of particular interest is the use of RD
marketing and  other skills to accelerate the impact of
new pollution control strategies.
     One example raised at  a recent  Oil Shale  En-
vironmental Advisory  Panel  meeting  reveals efforts in
Colorado to develop a seed bank and adequate plant
materials for oil shale and coal reclamation  activities.
The  effort does not fit into  conventional divisions of
RD&D but  does  involve the carrying of  results of
research activities in reclamation closer to commercial
readiness. This  is  probably a role in the environmental
area for RA.
     Integration of RA activities into the program plan is
also important to assure that all environmental concerns
are addressed. One of the weaknesses, for example, in
DOE's oil shale  management plan is the emphasis on in
situ retorting to the virtual  exclusion of surface retorting.
As a result, the  environmental tasks  largely  ignore
still outstanding environmental  concerns with surface
retorting.

Criteria Used  for Evaluating
Individual Technologies

     The  background  document identifies several  ap-
propriate criteria for technology evaluation. We believe
it  is  important to apply  these criteria within  the
framework we have outlined above.  That is, impacts
should be  identified  and compared  among energy
technologies on an entire fuel cycle basis according to
energy end-use applications.
    We would only at this point reiterate the concerns
expressed by others, and identified in the workshops
and  the Background Document for more meaningful
                                                   21

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Hearing of October 3,  1979
and  vigorous involvement of the public in decision-
making and education of the public.
    The recommendations  which  came  from  the
workshops regarding public and non-DOE involvement
are all important. DOE needs to give a greater commit-
ment to implementing those reforms  which  it  has
already  planned, and should incorporate those addi-
tional suggestions made during the course of these
hearings and the previous  workshops.  We have at-
tached our own  July comments and the Background
Document  public  involvement  summary  to  our
testimony.
    We should point out that some individuals in DOE
are making new public involvement commitments. For
example,  making  the oil  shale  management  plan
available to the public for comment is a major departure
from normal practice.
    DOE should not limit its dissemination of materials
and  information to  policy  documents  though. The
dissemination of RD&D results is perhaps even more
important. Public feedback must be encouraged. Efforts
are needed to facilitate peer review of DOE activities
and research, including multidisciplinary peer review,
and other energy RD&D which  has progressed much
faster than can  be  handled by traditional academic
journals.
    No management system will work without mean-
ingful public involvement. It must be clear to the public
how DOE responds  to public involvement and par-
ticipation. Credibility  of  public  involvement  efforts
demands a responsive department.

Integration of Environmental Factors
Into Technology Decisionmaking
    Our discussion of PPMS structure and operation
was exhaustive on this topic. Three additional sugges-
tions may help  further. First, the Memorandum of
Understanding   is  an  adequate  mechanism  for
establishing the framework for program  management.
Despite the appearance of creating a separate series of
DOE divisions, the establishment of programs such as
that done in oil shale requires only the cooperation of
appropriate personnel in each of DOE's main offices,
ET, EV, and RA.
    Second, consideration might be given to requiring
EV concurrence  to  implement  program  decisions.
Third,  greater respect for  NEPA is needed  in  the
Department. A year after the  Department started to ac-
tively push tax credits for oil shale  production, and
several months after the President announced his sup-
port for the credits, we still await (probably indefinitely)
DOE's environmental statement on the tax credit.
    In  closing, we shall share our hope that this entire
discussion in these hearings  will not be made moot by
synthetic fuels initiatives undertaken  by  the Congress
and the President. Any large scale shale oil commer-
cialization effort  is premature. If  it is to proceed,  it
should be limited in  scope to pioneer plants, and  it
should be fully coordinated with the Department of
Energy's nonnuclear energy programs in a way which
will help protect the public's interest and environmental
balance. Thank you.
    DR. REZNEK: Thank you, Mr. Markey. I feel I
should comment that this is an  excellent piece of
testimony, one difficult to react to on a short timeframe.
1 think it is an excellent demonstration of the ability of
the public to formulate some very interesting and mean-
ingful ideas. Are there any questions?

    DR. PATTON: I enjoyed your presentation and I
tried to follow it as best I could. I realize you said a lot
there. In addition to your concern that each individual
project be carefully reviewed, and that we not pursue
one that would be in any way harmful, how do you add
to this a care or concern that there  be a balance such
that while worrying about the cost in any one particular
program we also must balance off the total cost to the
nation for our present economic and energy  predica-
ment? 1 don't mean to recite the litany but it is that we
are importing foreign oil which at first blush is marvelous
from  an environmental standpoint  because it is pro-
duced overseas; however, we have to pay for that oil
with exports, and those exports have environmental im-
pact here at home, and whatever it  is that we  produce
and then export, whether it is rubber tires, pharma-
ceuticals, munitions, you name it, and so once again I
have a concern here today for that silent portion of the
public, and it is clearly a majority  of the public,  that
doesn't see each of them in the micro. I would like to
know how we continue to see that there is some con-
cern for the public at large, and for the macroeconomic
problem of energy for the country,  which means jobs,
the standard  of living that we  have come  to accept,
and overall health and well-being as well as  national
security.
    MR. MARKEY: Friends of the Earth is clearly in
the public record that it is concerned with our over-
dependence on foreign petroleum,  the costs that that
involves, and the risks that it creates.
    The  question is how do we get out  of of  that
predicament. What I am presenting is both a process to
compare research and development  efforts, and energy
commercialization efforts  within the Federal  Govern-
ment to address those problems so that the whole pro-
gram is balanced, so that you are using your most cost-
effective options, so that the program as a whole is cost-
effective, and so that you are protecting the  environ-
mental public health and welfare.
    If we are to proceed with a crash program, we are
probably going  to end up taking more risks than  if we
properly design a balanced approach to  the  situation
which recognizes the uncertainties in the synthetic fuels
technologies,  and also   recognizes the  promise of
changes in the energy economy, and additional efforts
                                                  22

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                                                                                 Statement of Mr. Markey
in renewable resource applications  and conservation
applications.
    The Senate Budget Committee has just released a
report on synthetic fuels which very clearly defines the
limits on any crash program and also puts into context
the opportunities for conservation and other means to
reduce our dependence on foreign oil.
    The opportunities  for synthetic  fuels commer-
cialization in the near-term  are  very limited,  and it
makes that clear. What DOE has got to do and what the
Administration and future administrations have got to
do is to very clearly work into its decisionmaking and
budgetary process a rational, reasonable way of figuring
out where its priorities lie.

    MS. CLUSEN: I would like, Mr. Markey, to com-
mend your thoughtful comments on the PPMS process,
and tell you that it is  undergoing some review at this
time through the Office of the Under Secretary, and that
I shall communicate your proposal to them.

    DR. REZNEK: I would like to view briefly two
points. In your statement on page five it says "each pro-
gram, regardless of its size or budget, will be subject to
the same review and evaluation," and you list a set of
criteria. I would like to have your thoughts on including
the question of public involvement in those criteria, and
your  general thoughts on the  idea of how to  institu-
tionalize that as part of the operating program.

    MR. MARKEY:  Okay. One  of the pieces of this
evaluation is NEPA, and NEPA is the ultimate public in-
volvement  tool  that Congress has  established,  and
which has evolved over the past 10 years. That is one
entry  point into this.
    Let me just outline a little bit differently, from a dif-
ferent tack, how these programs would be dealt with.
When I say each program regardless of its size would be
subject to the same review and evaluation, I mean you
are dividing essentially the energy budget into various
programs. The budget of each program is in different
pieces; some of it is in RA, some of it is in ET, some of it
is in  EV, and some of it is in other commercialization
efforts.
    The design of that program would itself be subject
to a  program  management  plan  document  which
outlines how it would be structured and how it would be
undertaken, and also to an environmental impact state-
ment, the  programmatic impact statement,  which
would evaluate the program, identify additional RD&D
efforts, and compare and evaluate different alternative
approaches to that program.
    The public hearing involved in that EIS as well as
specific public review,  workshops included,  advisory
committees, you name it, which address that particular
program over the long term could all have a role  in
assessing in  each of those programs whether it is oil
shale, whether it is a conservation program, whatever.
    On top of this whole program structure you would
have the National Energy Plan which by law is estab-
lished and revised every two years. Already there is an
Environmental Impact Statement which  is connected
with that National Energy Plan (NEP).
    That process got entirely  buried this  year because
in the middle of  it the President, who is not subject to
NEPA, comes out and proposes this colossal program
which has no relationship to reality. All I am saying is we
have got the tools there, what we ought to do is make
sure that everything is within a program so that you are
comparing everything as equals in the NEP process and
the NEP document, including public hearings nation-
wide or workshops—I like workshops a lot better than
public hearings because you get a better opportunity for
exchange of information for argument, for discussion,
and that sort of thing. They have got to be done right so
that you record everything that goes on in  them but you
also provide the opportunity for written  comments as
well, that the  workshop stimulates.
    All those mechanisms,  in particular  the EIS, and
ESAAB review of this  whole thing would be important
in establishing the National Energy Plan.
    Over the past several years out in  Colorado we
have  been very intimately involved with something
called energy forecasting methods, primarily for electric
gas utilities. We reviewed  the operation of energy
forecasting  methods throughout the country and pro-
posed  a program for  Colorado which was  ultimately
adopted by the State Legislature.
    The National Energy Plan process is in essence an
energy  forecasting and  an  energy strategic  planning
process for the  entire nation which spans  all  of the
energy  sources and has to address the question of
reducing our  oil imports.  That  process  is  entirely
unknown, there  is no preliminary assessment which is
available to the public for its review and evaluation prior
to making any comments on the National Energy Plan
in terms of what the  technical assessment is of our
needs, and the opportunities  for reducing our needs,
and that sort of thing.
    One of the most important things in that process is
to establish a methodology for at least figuring out what
the needs are, and  then a  process for proposing dif-
ferent ways to get to that end point 20 years down the
line which is forecasted  on  a  technical basis. But the
decision among different routes to get to that point is a
public process; it is not a technology process; it is one
which involves policy decisions which have social, en-
vironmental, and economic and other consequences
and that may be the EIS process coordinated with the
NEP process which is used by the Federal Governments
as absolutely essential.
    DR. REZNEK: One other observation. By struc-
turing your program to resolve problems, structuring the
program by  problem-solving  area, bringing in the
                                                  23

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Hearing of October 3, 1979
various components as necessary to do that, you in-
dicate you end up with a very changed spectrum of
activities for the commercialization of resource applica-
tions area, that some of these are the commercialization
of the entire mitigation efforts. That activity to have it
phrased and identified in  that way, whether it  is
developing seeds for reseeding or developing what  is
necessary to  introduce chemical process technology
into an industry dominated by mechanical engineers,
seems to me to offer a number of advantages. I would
just like to comment that I think that that aspect of this
approach certainly seems to hold some promises.
    MR. MARKEY: It would certainly give RA more
than one thing to do and would expand their mission
and their one track mind somewhat, or at least I would
hope it could.
    MR. HEDEMAN: I would like to make an obser-
vation and perhaps get your reaction. In the morning
that I have listened, two  concerns seem to be raised.
One, that there is an expected delay in decisionmaking
and implementation because of the public participation
in an adequate sort of way.
    You and Ms.  Reeves have, I think, brought that
second point out, and I couldn't agree more that NEPA
and  the impact assessment process is probably the
ultimate, as you say,  way to get that involvement.
    The one thing that everyone seems to be scurrying
around, and I am not sure that I am altogether on board
on this in terms of  whether I am going to pinpoint the
issue or not, is that the R&D program is in effect a pro-
gram that provides  the opportunity to plant the seed. If
the public is not involved in that planting, then ironically
they become involved in the maturing of the plant itself
and that often—
    MR. MARKEY: Or the prevention of the maturing
of the plant.
    MR. HEDEMAN: That is exactly what I guess 1
am driving at. That maturity ironically in our Federa'
system often  does not  involve  the Department oi
Energy. Instead, it involves other Federal agencies who
up until then  have had  relatively  no input into the
development of the R&D program.
    For example, Ms. Reeves mentioned the salt dome
project in Louisiana which is a project that presumably
had  some  sort of R&D impetus but  then requires
government approvals from other Federal agencies tha'
really were not directly involved in the inception of the
projects.
    All this leads to  a question as to whether in your
view public participation in an active and early stage of
R&D may not indeed produce less delay in that deci-
sionmaking of energy-related projects.
    MR. MARKEY: Two things. Number one, to really
answer your last question, "Can  earlier participation
reduce delay later?", the obvious answer is yes. There
has been more than one study to address that,  one
which I thought was quite well done, and which ad-
dresses both geothermal and oil shale technologies, was
a little study done by the Rand Corporation which com-
pared them as case studies; one involving the public at a
very early stage, the other involving the public when
you are starting to build demonstration plants and com-
mercializing the industry. The response of the public
was entirely different in each case.
    The other thing is  whether public participation,
public  involvement, basically has to delay decision-
making in the acquisition of energy systems. I don't
think that it has to and there are plenty of examples.
    One recent look at the question from a regulatory
point of view is an analysis done by EPA Region VIII of
the time  required to obtain  PSD  permits. The biggest
reason for delay was the fact that EPA always receives
incomplete applications. In other words, the biggest
reason for delay is a lack of understanding on the point
of view of the applicant, of the energy developer, of the
system, the decisionmaking system.
    They found that there was minimal delay caused
by any public  participation  activities. The one place
where there was delay was due more than anything else
to the—and it  was a delay which Friends of the Earth
and  other organizations actually  requested  by the
developer went along with—was in the review of the
Colony Development Operation PSD permit. That hap-
pened because Colony told EPA "you can take your
time on this permit because we don't need it right away,
we don't have immediate plans to build  a plant."
    When public  participation time came along, there
were two months left in the 12 month clock for decision-
making, but it  found by and large that there was ade-
quate public involvement where necessary, and that it
did not delay the process.
    If you look at the process, the PPMS process, and
the decisionmaking process, this is what creates delay.
The linear extension of one stage after another during
which  there is a key  decision  in each  stage  and
everything else, and having to stop all progress, so to
speak, in between each phase of a project. Between
each phase of  a project a technology within a program
may proceed in a linear fashion and has to proceed  in
somewhat linear fashion, but at the same time there are
all sorts  of side programs which are going on which
have  to support and expedite this technology acquisi-
tion system.
    I just compare  that  to the charts for the program
management plan for the oil shale R&D program where
essentially you have got four major categories of the
program ranging  from resource,  characterization, en-
vironment, down to retorting and preparation.  Each of
these is going on simultaneously. They all, or a number
of them feed into a demonstration program called the
so-called "moon shot" and they are parallel. That is the
sort of thing which speeds up the process, and if you
have  a public  review of the plan as a whole and you
                                                  24

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                                                                                Statement of Mr. Markey
have various little mechanisms for public review when
there is an important decision to be made, and the plan
identifies those decision points in the plan, you can pro-
ceed without this cumbrous linear process which takes
forever.
    MS. REEVES: Dr. Reznek, may I make a com-
ment on a question I was not asked but about which I
feel guilty. Mrs1. Clusen asked the other members about
conferences arid I have to—I can't—I would  like to be
able to say. Conferences, and public workshops, and
public seminars, or whatever you wish to call them are
probably the best general adult education  mechanism
we have in spite of their problems. No matter how much
difficulty all of us have with another conference and
another workshop, the truth of the matter  is in the
school of life we don't have any other place to even go
to class. So I would not like to have the record go away
with a negative connotation. I  am fully aware of the
problems that we have in developing good conferences
and workshops, but I believe that in order to get people
of different persuasions  and different points of  view
together, a conference is one mechanism that does it,
and if  you structure  it properly so most people can
argue among themselves instead of creating an adver-
sary position between the participants of the conference
and a particular agency, it is very productive.
    So I just have to add that. I am a long term advo-
cate in spite of the problems that  conferences cause,
and I hope that DOE continues to fund, to encourage,
and to improve them.
    DR. REZNEK: Thank you.  I have been handed a
note which says the outlook is bleak for food. There are
two cafeterias, one is across the hall and one is in the
Department of Interior building. I think we should try to
reassemble by  1:30. We have drifted over our time, as
conferences and workshops tend to do. But if we can
begin  promptly at 1:30 we can  move into the list of
witnesses this afternoon.
    (Whereupon, at 12:15 p.m., the hearing recessed
for lunch to reconvene at  1:30  p.m.  the  same day.)
                                                 25

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Afternoon  Session
                                                                               Statement of Mr. Whiting
 (1:30 p.m.)
     DR.  REZNEK: Mr.  Hedeman  was called  this
 afternoon, Toby Pierce  will be  replacing him on the
 Panel. I am hoping for the return of Mr. Siek. Our first
 witness this afternoon will be  Macauley Whiting from
 the National Coal Policy Project. Mr. Whiting?
     MR.  WHITING: My name  is Macauley Whiting. I
 am employed by the Dow Chemical Company as a con-
 sultant  on energy  and  am  here representing  the
 National  Coal  Policy Project as  Mr.  Reznek  said.
     I am Chairman of the Project's industry group. This
 project (NCPP) aims to achieve  a reconciliation of the
 views of those whose prime concern is energy develop-
 ment on  the one hand and  those of environmental
 priority on the other.
     The project is now nearly complete and is deemed
 to have been successful. It is felt that  the approach or
 process might be useful to the  Department of Energy's
 research,  development,  and demonstration  manage-
 ment process. This approach to reconciliation is called
 the "Rule  of Reason" process.
     In my testimony, I  plan  to describe the general
 process, to give the history of NCPP as an example,
 and finally to explain how I think the process might be
 used by DOE.
     Stephen  Gage of your Panel was one of the  first
 people in government to  encourage  the initiators of
 NCPP to go forward.
    The "Rule of Reason" has recently been described
by attorney Milton Wessel in  his book by  the same
name. He cites it as an alternative to the normal court-
room adversary proceeding in which the aim of each
party is to defeat the opponent,  and in which games-
manship is a major element of the tactics.
    Conversely, gamesmanship is avoided in the "Rule
of Reason" process  for  dispute resolution,  and  the
primary aim of the parties is to  find an  accommodative
solution which does not seriously transgress the values
of either.
    Mr. Wessel sees the  "Rule of Reason" as adapted
to the resolution of complex socio-technical issues such
as are confronted every day  by the  Department of
Energy in the development of new energy technology.
It is not adapted  to  more simple  questions like, for
instance, the guilt of a burglary suspect.
    The employment of the "Rule of Reason" depends
on negotiation between qualified experts on each side
of the issue and it does not rely  on  the wisdom of an
inexperienced lay person like a judge. It also depends
on the development of a trusting relationship between
the partisans over the course of an extended period
of negotiation.
    Application  of  the "Rule of  Reason" generally
follows this code of conduct and I would like to read to
you from Mr. Wessel's book.  The code has sometimes
jokingly and lovingly been referred to as a substitute for
the Boy Scout code.
    First,  "data will not  be withheld  because it is
'negative' or 'unhelpful.' Concealment will not be prac-
ticed for concealment's sake. Delay will not be employed
as a tactic to avoid an undesired result. Unfair tricks
designed to mislead will not  be employed. Borderline
ethical disingenuity will not be practiced."
    "Motivation of adversaries will not unnecessarily or
lightly be impugned. An opponent's personal habits and
characteristics will not be questioned unless relevant.
Wherever possible, opportunity will be left for an oppo-
nent's orderly retreat and 'exit with honor'."
    "Extremism may be countered forcefully and with
emotionalism where justified  but will not be fought or
matched with extremism. Dogmatism will be avoided.
Complex concepts will be simplified as much as possible
so as to achieve maximum  communication and lay
understanding."
    "Effort will be made to identify and isolate subjective
considerations involved in reaching a technical conclu-
sion. Relevant data will be disclosed when ready for
analysis and peer review—even to an extremist opposi-
tion and without legal obligation. Socially desirable pro-
fessional disclosure will not be postponed for tactical
advantage. Hypothesis, uncertainty, and  inadequate
knowledge will  be stated affirmatively—not conceded
only reluctantly  or under pressure."
    "Unjustified assumption and off-the-cuff comment
will be avoided. Interest in an outcome, relationship to
a proponent, and bias, prejudice, and proclivity of any
kind  will be  disclosed voluntarily  and as a  matter
of course."
    "Research  and investigation will  be conducted
appropriate to  the problem  involved.  Although  the
precise extent of the efforts will vary with the nature of
the issues, it will be consistent with  stated overall
responsibility to the solution of the  problem. Integrity
will always be given first priority."
                                                 27

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Hearing of October 3, 1979
    To be more explicit, let's examine the employment
of the "Rule of Reason" process by the National Coal
Policy Project as described in its report titled "Where We
Agree." I,will have several copies of this summary and
synthesis of the report for the Panel for inspection later
on. I  would like to read certain  excerpts from the
chapter on the history of this project.
    "The idea of the National Coal Policy Project
(NCPP) originated with Gerald  L.  Decker, Corporate
Energy Manager of The Dow Chemical Company, and
certain of his colleagues in industry. They believed,  in
part as a result of their participation in studies performed
under the auspices of the Department of Commerce's
Technical Advisory Board (CTAB) that it was important
for the United States to shift from the use of oil and
natural gas to coal. It appeared to them, however, that
this would not occur without a reconciliation of environ-
mental and industrial interests.
    "In connection with Mr. Decker's service on the
Federal Energy Administration's Environmental  Advi-
sory Committee, he met Laurence I. Moss," who will be
here shortly, "former Sierra  Club president and  chair-
man of that committee. Decker, with the support and
encouragement of key executives of several major com-
panies, approached Moss and other environmentalists in
January, 1976, to enlist their support for the project."
    "The  environmentalists  were  not enthusiastic.
Some had met with representatives from industry on
previous occasions and found the discussions unpro-
ductive. The environmentalists felt that they could not
afford to set aside the considerable time required for the
proposed project unless there was a  reasonable likeli-
hood that it would be productive. On the other hand,
many of them were not fully  satisfied with  existing
mechanisms for resolving disputes,  and were receptive
to exploring new approaches. From the environmental
point of view,  there  was a growing feeling that the
industry had business to transact with the environmental
movement just  as  it  does  with  shareholders,  labor
unions, customers, and regulatory authorities. The lack
of a non adversarial forum to conduct such business
was impeding progress on issues upon which agreement
might be possible."
    "It was agreed, accordingly, to test the concept
with a single two-day meeting on a limited agenda. This
meeting, held in July, 1976, was judged productive  by
the participants.  Industrialists  and environmentalists
meeting  in separate caucuses endorsed continuing and
expanding the project to address important coal-related
environmental  and energy policy issues. Decker and
Moss  were elected Co-Chairmen  by their respective
caucuses."
    "Five  Task Forces were organized to cover the
spectrum of coal-related energy and environmental
policy issues. They were: Mining;  Transportation; Air
Pollution;  Fuel  Utilization  and  Conservation; and
Energy Pricing. Later an ad hoc task force, Emission
Charges, was organized, drawing from members of the
Air Pollution and Energy Pricing Task Force. Each side
was represented equally on each Task Force."
    "The Task  Force Co-Chairmen  and Vice  Co-
Chairmen," 20 people in all,  "were formal members of
the Plenary Group, the governing body for the project.
Other members were the NCPP Co-Chairmen, Decker
and  Moss; and, Father Francis Quinn, the Plenary
Chairman."
    "The Plenary Group defined the scope of the Task
Forces'  activites, provided guidance and redirection,
and reviewed and approved their recommendations.
The Plenary was responsible for resolving disagreements
between Task Forces."
    "The fact that the Plenary group  approved the final
task force reports does not mean that every member of
the Plenary is in full agreement with the more than 200
recommendations contained  therein. Most Task Force
recommendations were accepted by the Plenary with-
out dissent. The more  controversial  recommendations
were discussed  until a consensus of the Plenary group
emerged but, in a few cases,  agreement was not unani-
mous. Those dissenting had been provided the opportunity
to submit for the record their minority views."
    "The participants in the project took part as individ-
uals. Although  they  were  selected in part because of
their leadership roles in environmental and industrial
organizations, they do  not support to speak either for
their organizations or for the  environmental and indus-
trial communities at large.  The issues are too complex
and controversial for either side to speak with a single
voice."
    Following the test meeting in the summer of 1976,
the full scale effort  got underway  in  the winter of
1976-77. The task forces met over the course of more
than a  year. Nearly half  a year later was  taken in
preparation and approval of reports, and this phase was
completed nearly a year ago. Implementation and the
tying up of loose ends  are now in progress.
    To arrive at final agreement on the 200 recommen-
dations of NCPP then took the direct and extensive
involvement  of over 50 industrial and environmental
representatives, together with  supporting staff, nearly
three years of time arid nearly one million dollars of
budget. As you can see, the  "Rule of Reason" is not a
process to be casually undertaken.
    Among the 200 recommendations are some out-
standing syntheses, such as the recommendation for a
single hearing process to lead to site approvals by the
many agencies  involved in granting  these. In this pro-
cess,  the  reasonable  expenses  of participation by
selected public interest groups would  be paid by govern-
ment.  The participants at NCPP  felt that  this recom-
mendation for such a combined hearing process would
yield faster and better site decisions. I mention that as
one example of a synthesis recommendation.
                                                   28

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                                                                                Statement of Mr. Whiting
    Now, it seems to Mr. Moss and me that this "Rule
of Reason" proceeding would have limited  but impor-
tant application in DOE's RD&D management process
to best assure consideration of environmental  and
energy conservation matters.
    Of course, the subject would have to be  of sufficient
importance to command the high budget, of sufficient
permanence to permit the long time, and of sufficient
interest to attract qualified environmental and energy
development representatives.
    Given such conditions, DOE could well assemble
qualified groups who would adhere to the code of con-
duct of "Rule of Reason" to deal over time with environ-
mental and energy conservation issues which arise in
the course of important energy developments.
    One timely subject, as an example, is the develop-
ment of synthetic fuels. Even any one of  the synthetic
technologies would qualify as a subject that is important,
long-lived, and interesting.
    I  hope that you can visualize now the "Rule of
Reason" process as demonstrated by  the National Coal
Policy Project,  and its potential application to the issues
faced by DOE.
    I thank you very much for the opportunity to appear
before you and would be pleased to answer any questions.
    DR. REZNEK: Mr. Whiting, should we ask Mr.
Moss to testify and ask  questions of both  of you or
should ask you questions now?
    MR. WHITING: It might be  well to address the
questions now and let me be sure—I think Mr. Moss
plans to testify directly about DOE matters  and not to
talk as much about the "Rule of Reason"  process.
    MR.  MOSS:  Yes,  I will be covering two other
questions in my testimony.
    DR. REZNEK: Are there questions?
    (No response)
    DR. REZNEK: Let me start off by asking the ques-
tion of—the people involved certainly reach a consen-
sus if there are 20 people on each side, but have you
been able to translate the consensus that  is reached
between the participants  into a broader political context
such that the recommendations are finding a constituency
that is  actually leading to modification of government
programs?
    MR. WHITING: That is very difficult. The other
day I used the  examples  that nobody from industry has
taken out a full page ad in the Wall  Street  Journal on
behalf of our recommendations, nor have any environ-
mental groups staged a rock concert on their behalf, but
we have achieved a general acceptance of these as an
accommodative solution. There have been issues taken
with some of  the  findings  by some people, but the
instances in which that has happened have been minor.
    We have presented  the findings  in San Francisco,
California; in Houston,  Texas; in Billings, Montana;
and Pittsburgh, Pennsylvania. I would say that well over
1,000 people have attended presentations and we have
answered their questions. As a result, there have been
two or three issues that have not been accepted, but
there has been very, very general and large, if unemo-
tional, kind of acceptance of that recommendation.
    MR. MOSS: Let me comment on that. It is always
very difficult to establish cause and effect relationships in
the complex business of policy  formulation. A lot of
people are speaking out on various sides of any par-
ticular issue. We didn't duck any issues, and we made
some  very controversial recommendations that were
not. only controversial but quite  broad in scope. But  I
think we have  had an impact although I will  by  no
means claim total credit for such impact.
    For example, it  seems to me that three or four
years ago, before we undertook this project, it was a lot
harder to find people in the public interest sector who
thought that there might be some problems associated
with controlling energy prices to low levels than there
are today. And partly as a result of the work in the proj-
ect where we pointed  out that  without energy being
priced at replacement cost levels, you weren't going to
get the right amount of investment in conservation or
solar energy or any end-use technology that some of
that shift has occurred.
    We made a lot of recommendations and had a lot
of findings on reclamation of strip mine lands, and for
the first time we had a body  of technical information
agreed to by both sides that no  one had had there to
work with before. I think that was quite useful.
    In specific  areas in the reclamation of strip mine
lands, we have come up with rather detailed recom-
mendations on  things like bonding  provisions  of the
law, things like assistance to small mine operators. And
we found  a receptive audience among the regulators,
and, in fact, in the case of bonding provisions the deci-
sion to  go ahead with  the rulemaking procedure at
which we and others would be given the chance to sub-
mit our recommendations so that we have high hopes
that we will have impact there.
    I could go on in the other areas as well, but 1 think
those  of us who have  been  associated with trying to
influence policy over the last  10  or 15 years are a little
bit humble about what can be accomplished overnight.
    I remember Ed Wayburn, who is a well-known per-
son in the Sierra Club, instructing some of the  newer
directors of the  Sierra Club back about 10 or 12 years
ago on what it took to assemble a political consensus,
and get legislation passed to create a new national park.
We had to plan on a 7 or 8 year campaign on average in
order to accomplish that.
    Some of the issues we are talking about here are
just as controversial as creating a new national park; in
many respects,  more controversial because they affect
more people more directly.
    MR. PIERCE: Early this morning we heard Gor-
don MacDonald talk about the CO2 greenhouse issue.
This is an example of a long-range issue which we are
                                                  29

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Hearing of October 3, 1979
going to be grappling with in the years to come. I would
be interested how a group like yours with people from
industry, from environmental groups handle an issue
like that.
    MR. WHITING: I would say that in an issue like
that you are dealing with a great many unknowns, and
the process would be particularly valuable in that point
because between the knowledgeable partisans you can
work out strategies which minimize the risk both to envi-
ronmental concerns and also to economic development
while  the process of finding out what the true nature of
the risk is.
    ! think particularly in an adaptive situation like that
that the "Rule of Reason" process is applicable where
the knowledge is not complete, and where you are try-
ing to figure out a way of progressing without too much
danger while  the full scientific knowledge is  being
accumulated.
    MR. MOSS: I am not entirely  satisfied with how
we handled that in phase one of our project. In effect,
we pointed  attention to  the fact that there could very
well be a problem and ask for further research on it to be
conducted and expedited. A lot of other people have
made  that recommendation  as well and  there  is a
research program currently underway.  But  that is the
kind of an issue that undermines the whole question of
using more coal or fossil fuels in the future, and it is very
difficult for people on both sides of the project who were
brought together to consider how decisions  should be
made if more coal was to be used to grapple with such a
fundamental question. Maybe we can do a better job on
that in the future. Certainly, if more damaging informa-
tion is uncovered  about CO2 in future years, we or
others will have to discuss, and eventually implement
policy initiatives which will prevent the uncontrolled
increase in CO2 concentrations.
    MS. CLUSEN: Would one of you suggest a current
or near term Department of Energy issue that would
lend itself to this process?
    MR. WHITING: I  mentioned the synthetics as
one that seems very much adapted to it. Really, the
development of any new energy technology in which
environmental cautions have been raised, we thought
as we prepared for this hearing, would be adapted to
the formation of "Rule of Reason" group to follow the
process, the full process of the development of the
technology. In other words, we don't see the "Rule of
Reason" proceeding as kind of a spot thing, but rather
something that would follow the course of a development
right through.
    MS.  CLUSENj  It  would of  necessity  then,  I
gather, have to be a long term project and a well-funded
one. It is not an answer for dealing with our  immediate
decision.
    MR. WHITING: Right. I would not use it to pre-
pare an Environmental Impact Statement, for instance.
I think that would be a poor use of it as spot in a thing
like that.
    MR. MOSS:  But my  experience has been  that
immediate decisions almost always have a history of
turning into decisions that last over years, and people
come back to the same questions, they have the same
conflicts, the same  unresolved issues. They reconsider
and reconsider, and if a process like this was begun,
then at least a year or two further down the road you
would begin to resolve some of those conflicts,  and
maybe produce some better considered decisions.
    DR. REZNEK: Begun with Federal money behind
it. One of your successes was the lack of bias and lack of
prejudice in  the way in which you were funded  and
selected your members. Can you expect the Federal
Government to operate or to fund a process such as
yours, and allow it  to maintain the unbiased reputation
that your project has?
    MR. WHITING:  That is a difficult question to
answer exactly. We were much more cautious at the
start. At the  start, environmentalists would not tolerate
any funding from  any industry that stood to benefit
directly, to profit directly from the energy business. We
had no oil company funding, et cetera, which made it
extremely difficult,  of course, to get funding initially. As
time went on,  1 think the  environmentalists felt  that
there was much less pressue or bias applied by the fund-
ing than they had feared initially,  and thus, my answer
to that question would be that even though the govern-
ment's direct interest is in the development of energy
technology it ought not to  be impossible to have the
money dispensed in an even-handed way, or  to put
controls to guard against the bias that might otherwise
come from development-oriented funding.
    MR. MOSS:  There is an interesting story about
this. The Project did receive some government funds,
although it was much  less than half. One contribution
was a grant from DOE. When this was being discussed
with Secretary Schlesinger, two of the Georgetown
University CSIS people were discussing it with him, and
he asked them what DOE would buy with this grant.
One of them said "nothing," and the other one thought
that answer was too harsh and started to hem and haw.
Mr. Schlesinger interrupted him and said, "The first guy
gave the right answer, don't say any more or you will
spoil it." So it depends a lot on leadership at the top.
    There  still may be a perception  of  a conflict,
though, and that is  why the National Coal Policy Project
was set up so that all the  environmentalist expenses
were  covered by  grants  from either foundations or
government agencies.  But there is a long term problem
with that.
    Foundations are interested in funding this as a pro-
totype to see if it can be done, so that other, people will
consider non-adversarial processes in dealing with these
and other problems, but they are unlikely to fund this
sort of activity indefinitely.
    Thus, it is necessary to find other kinds of institu-
tional mechanisms in order to make this thing possible in
                                                   30

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                                                                                   Statement of Mr. Moss
the future. Expanded funding by Government agencies
may be part of the solution.
     DR. REZNEK: I guess,  Larry, you could continue
with your testimony.
     MR. MOSS: I am going to present my individual
views on two important questions that are before you. I
have not made a careful or comprehensive study of the
present institutional arrangements for including environ-
mental and energy conservation factors in the planning
for research, development,  and  demonstration, but I
have formed certain impressions as a result of my chair-
manship of first, the FEO, and then the FEA's environ-
mental advisory committees over a period of five years,
as well as  impressions obtained from other contacts
during and since that period.
     The two questions I would like to focus on are:
first, the integration of environmental  and energy con-
servation factors into technology decisionmaking, and
second, the role of advisory committees in this process,
and in the more general matter of advising the Department.
     Mac Whiting, as you know, has already commented
on the possible role of non-adversarial processes in giving
advice, and I won't get into that in my remarks.
     First, I'll address the integration of environmental
factors into technology decisionmaking. There are two
models that I think of in describing how this could be
done. The first model is to have a periodic review to
identify and avoid  potential "show stoppers," as DOE
and  others put it,  impacts that would stop the tech-
nology  dead,  and which,  unless overcome,  would
make continuation  unwise. It is my impression that  this
is the motivating element of the current DOE process.
     A second model is to have an interactive process in
which environmental and energy conservation  factors
are influential in steering the technology development
along one path as opposed to another path. This would
be not  necessarily because  of "show stoppers,"  but
because of relative  advantages and disadvantages from
the viewpoint of environmental impact and energy con-
servation considered  along with  the  more  traditional
elements of the planning process.
     Let me give you an example. DOE has a number
of development  programs in the gasification of coal.
The  expected  emissions  of  air pollutants from these
processes are less than those expected from a conven-
tional coal combustion plant using a scrubber. But it
would be possible to make the emissions still less, in fact
so much less  that air pollutant  emissions  would  no
longer be a factor in the siting of these  plants, by using
gas produced from coal, rather than conventional coal
combustion, for in-plant energy services.
     This would be  done at  some  additional cost,
obviously, and there would be some sacrifice in  energy
efficiency unless you did other things to compensate, of
which I will speak in a moment. The cost might be 20 or
30 percent higher at the upper limit. When we are talk-
ing about a cost of production of gas from coal that is
already marginal in economic terms, it is understand-
able that the developers of these sytems don't like to do
anything that would increase the costs still further. But it
would be possible to recapture some of the energy lost
in conversion with combined cycle electric generation
and cogeneration.  A higher  temperature thermo-
dynamic cycle is possible using  gas than with conven-
tional coal combustion. With the feature of having close
to zero emissions as well as acceptable conversion effi-
ciency, and with electricity as a  useful and high value-
added byproduct to help recover the additional capital
costs, this could be an attractive line of development.
    The question I want to ask is how would this line of
development be proposed and pursued within the deci-
sionmaking and evaluation processes that is  either cur-
rently in place at DOE, or something that might replace
it? I do think that we need an interactive process, along
the line of the second model I have given, in addition to
the first model, the identification of show stoppers.
    In  other words, I believe we should think of envi-
ronmental and energy conservation analysis as  part of
the solution rather than part of the problem in developing
new technologies.
    How  do we accomplish  that? We obviously need
appropriate institutional arrangements, with the various
agency divisions given roles at important stages in the
decisionmaking process, so that people with primary
responsibilities in energy conservation and environmen-
tal protection are able to evaluate and comment at the
right time.
    We also need the right people in place in the dif-
ferent parts of the organization. I think you need people
with strong motivation towards  environmental protec-
tion values on the technology development side, and
you need  people  with a strong  technical background,
with competence  in  engineering and  design,  on  the
energy  conservation and environmental assessment
side. Otherwise, you are not going to get the right play
between the two groups, the  right kind of tension, and
the discussion won't take place to the desired depth.
    These are ways that I think of possibly accomplish-
ing it. I  am sure there are others and perhaps we can
discuss the importance of accomplishing this  interactive
process, and how it might be fostered, later in this hearing.
    The second issue I would like to address is that of
the rgle of advisory committees in helping to impact on
the DOE decisionmaking process. My experience, as I
said, is with the FEA Environmental Advisory Commit-
tee. There we often  had a feeling of frustration  with
members of the Committee  doubting  that they were
having  any impact on the FEA.  But that was leavened
with assertions from FEA officials, and perhaps more
important from former FEA officials who had no reason
to tell us  so, if they didn't  believe it, that we were
highly effective.
    I remember one visit we had from a former FEA
official  who was appointed Assistant Secretary of the
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Hearing of October 3,  1979
Department of the Interior who took time out from a
busy schedule to come to one  of our  meetings to
explain how we had had an important impact on the
FEA decisionmaking process. In fact, I think we were
influential in such areas as the importance of proper
pricing, the need to focus on improvements on end-use
efficiency which were cheaper than the marginal costs
of supply alternatives, the need for the Federal Govern-
ment to get its act together on  cogeneration, and the
need for consideration of certain environmental impacts.
     What makes an advisory committee effective? The
first  is  an obvious one:  You  need talented,  highly
motivated  members and they  should come from a
cross-section  of  disciplines,  including  technical,
economic, and experience with public policy formula-
tion. They should have a range of values, but in an
environmental advisory committee obviously environ-
mental values should rank high.
     In the case of the FEA Environmental Advisory
Committee,  its members went  on to  become the
Administrator of EPA, the Chairman of  CEQ, the
Chairman of the CAB (and then the President's Infla-
tion  Advisor), the General Counsel of CEQ, an Assis-
tant Administrator of EPA, an Assistant to the Secretary
of Interior,  a member of the White House Domestic
Policy Staff, and so on. So we had a talented group
of people.
     On the question of whether you could assemble a
comparable group now, I think the answer is yes, if you
do the  job  carefully.  I know  that I  am continually
impressed by the number of talented, committed people
in all sectors of our society who  have yet to receive
widespread recognition  despite their outstanding work.
This constitutes a pool from which committee member-
ship  can be  drawn. The committee chairman,  by the
way, should be involved in the selection process.  That
was  the case with  the FEA Environmental Advisory
Committee, and I think it worked  rather well.
     You need good staff support, which  we had with
the   FEA Environmental  Advisory  Committee.  You
need good  working relationships  with  top agency
people, which we had, though I must confess to a cer-
tain amount of frustration arising from the frequent turn-
over of the top people.
     I would alsoj mention the ability to form task forces
on specific issues) and add to them people not members
of the  committee when their contributions would be
important. That sends out roots from the committee to
the community-at-large, and involves people who are
very competent who may not happen to be members of
the committee.
     Something we did not have on the FEA Environ-
mental Advisory Committee but  I  think is also very
important, and would have increased our effectiveness,
is to have funds available to support those members of
the committee, or those people brought in from outside
who were employees of public interest groups, or non-
affiliated  individuals  when they  were working  on
committee business.
    We have done that in the National Coal Policy
Project. We provide an honorarium for each day of
attendance  at a regular committee meeting  plus an
equal amount presumed to be in  preparation for the
meeting or in follow-up to it. This may have made a dif-
ference with some people who are faced with  all kinds
of demands on their time but who felt that at  least we
took this seriously enough to compensate, in part, them
or their non-profit organizations for the time we were
asking them to spend on the project. We also budgeted
funds for a part-time staff assistant to each of the task
force environmental co-chairmen.
    1 think  that similar funding would be especially
important if the advisory committee were to play a role
in the interactive process 1 described before, since it
requires  a  pretty   thorough   review  of  alternative
technological options   in  making  recommendations
about which lines to pursue.
    These comments touch on only two of a multitude
of issues that I am sure are in front of you, but are the
things I felt most strongly about and most knowledge-
able about.  So  that is what I  chose to include in my
testimony. Thank you.
    DR. REZNEK: Thank you. Are there questions?
    MS. CLUSEN: I think you gave some very helpful
advice on the role of advisory committees, particularly
regarding the advisory committee with which I deal.
Some of it could be adopted to the model at DOE and
some of it could not. But I too have heard good things
about the advisory committee to FEA/FEO.  Perhaps
there was some particular value attached to being in the
game in  the formative stages that gave you greater
opportunity than perhaps exists now with an  ongoing
agency having a broad mission for energy development.
    I was curious  about one  statement you  made. I
want to be sure that I  do  not misunderstand it. Was
there  some implication, and if this is true  I can even
understand how you might have arrived at  this conclu-
sion, that there is inequality in the scientific or technical
competence required by those, for instance, who work
in the energy technology side, and those who  do a job
on what is regarded by some as the softer side, the envi-
ronmental side,  or conservation side, or in the technical
competence that exists on those two sides?
    MR. MOSS: I have not made a careful  study of
this, so I draw no conclusions about it, but I do think it is
important that there be a rough equivalence of technical
competence, and that you have people on the  environ-
mental assessment side who know a lot about process
development as well as knowing a lot about  scientific
assessments of  environmental impact.  In considering
technological alternatives in evaluating different paths
that might be taken  in development, they have to know
                                                  32

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                                                                                Statement of Mr. Endahl
when someone on the development side is being honest
with them, for example, when claiming that a line of
development is impractical or impossible. That takes a
certain amount  of sophistication  in the game that is
played by the development people.
    MS. CLUSEN: There is no judgmental factor
involved in your saying that at this time?
    DR. MOSS: No, I have not made a study of the
present situation at DOE, I would be curious, though, if
the example I gave of possibly using product  gases to
fuel the in-plant energy services, and combine that with
combined cycle, and possibly  cogeneration has  ever
been seriously considered on  either the development
side or the environmental assessment side within DOE
in defining an optimum path of development. I am not
saying  it is the solution, but I am just saying it is one of
the kinds of things that should be carefully evaluated. If
something like that hasn't been carefully evaluated, it
may point to either some inadequacies in the  process,
or inadequacies in not having the broad spectrum of
talents  that you  need in different parts of the organiza-
tion, and values motivating the people that would help
identify things like that.
    MR. WHITING: If I could add to that answer just
a little bit. I think generally what you are looking for, if
the problems in DOE are the same as the problems we
faced in the National Coal Policy Project, they were
problems of getting accomodative solutions or problems
of making very creative syntheses to problems  that had
been there for a long time and haven't been solved before.
    We found  out  that people who understood the
technology had the resources with which to make these
accommodative solutions or syntheses, whereas people
who were of very good will and very much motivated to
solve it, if they didn't have the technical resources they
were not able to contribute much to the solution.
     MS. CLUSEN: I think I should reply for my office
that we have a highly professional and technically com-
petent staff, and that it cannot be compared with that
kind of an operation.
    MR. WHITING: By no means did I mean to imply
that, I  was thinking more of a  volunteer as well—
     MS. CLUSEN: I know you were, and that is why I
wanted to clarify it.
     MR. MOSS: Mac, you  weren't saying  that the
environmentalists in  the Coal Policy  Project lacked
technical competence, were you?
     MR.  WHITING:  No,   I was saying  just  the
opposite.
     MS. CLUSEN: Sorry I raised the question.
     MR. MOSS: We have all got to defend our turf.
     DR. REZNEK: Let me dwell on that a little bit. We
heard some testimony this morning that it is the job of
people schooled in the environmental sciences to set
standards, and  then for the  engineers to meet those
standards in the most efficient way. That testimony was
given this morning rather forcefully.
    What you are suggesting is the development process
itself, the engineering development process itself, which
should somehow or  other  incorporate  in NEPA for
making sure—or an ethic to make sure that the environ-
mental performance is maximized as welt. That implies
an engineering capability with that particular goal to find
an  institutional  organization within  the Department
of Energy.
    MR. MOSS: That is a good summary of what I
have said, with one small caveat. I don't like to use
words like "maximize" when I am talking about  only
one of the criteria that is involved in an optimization. If
you maximize one, you have not regarded anything
else as being of importance. But in the overall optimiza-
tion process, the lessening  of adverse environmental
impact can perhaps be given greater weight than it has
been. In order to do that,  I think we  do need  this
engineering kind  of competence on the environmental
side to participate in  the  assessments and to interact
with people on the development side.  Again, no judg-
ment is implied on whether or not that presently exists.
    MR. PIERCE: It would seem to me that one of the
indicators of success,  if not the major indicator of suc-
cess, is  the  degree to which an advisory committee
recommendations are listened to, the degree to which
you are  causing change to occur. I am just wondering
whether in light of your own time and the time of other
people on advisory committees do you have a kind of
evaluation or perhaps  even a  quantification  of the
degree  of  success that your recommendations  are
adhered to? In other words, if you have, say, 20 recom-
mendations a year, or  two  years from now are  they
being listended to,  are they being looked at, do you
analyze your action on advisory committees in that way
at all?
    MR. MOSS: We  don't quantify it. I  think that
would be very difficult or impossible, but we do review
our progress. We did that on the FEA Environmental
Advisory Committee. And if we saw things weren't being
implemented, we didn't drop them, we kept on calling
the people back who would be the ones responsible for
implementing them and  kept on raising the issues.
Similarly,  in the  National  Coal Policy  Project, we
periodically review what has been  happening, either
consistent with or inconsistent with our recommenda-
tions, and try  to bring our recommendations to the
attention of more people  who are in a position to act
on them.
    The business of influencing policy is very complex
and there are no clearcut answers to it. Nevertheless, I
think we have had enough of an impact in both cases to
make the activity worthwhile.
    DR. REZNEK: Thank you. Our next witness is
Lowell  Endahl  from  the  National  Rural  Electric
Cooperative Association.
    MR. ENDAHL: Thank you, Mr. Chairman and
Members of the Hearing Committee.  My  name is
                                                  33

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Hearing of October 3, 1979
Lowell  Endahl,  coordinator   of  Research  and
Technological Development for the National Rural Elec-
tric Cooperative Association. 1 have with me Joe Ives,
our environmental counsel, and who is also a member
of the Environmental Advisory Committee.
     I would  like to deal mainly with areas of energy
conservation  and I am sure if you have questions con-
cerning environmental issues, Joe will be happy to assist
in answering  those.
     NRECA  is a national service organization represent-
ing more than 1,000 non-profit, consumer-owned rural
electric systems that deliver electric power to about 7.5
million farms and rural residences throughout the nation,
that is about 25 million people, that are beyond the
natural gas mains  in the rural and sparsely populated
agricultural areas of 46 states.
     These cooperatively owned utilities are located in
some 2,600  of the nations's 3,100 counties and they
own and operate more than 40 percent of the distribu-
tion lines  to  serve about nine percent of the nation's
population.
     NRECA  and  its member systems are concerned
about how the energy policies made here in  Washing-
ton will affect the little guy at the end of the line. We still
build our  programs and policies on the belief that we
must have an adequate supply of energy at reasonable
prices  in  order to  maintain a  strong,  prosperous
America and the  standard  of living  we enjoy.  We
believe that we must have a  healthy environment but
also that  costs as well as benefits of  environmental
initiatives should be carefully weighed.
     We believe  that the development and rapid com-
mercialization of new technology and constant efforts to
.improve efficiencies of our current methods of produc-
ing, distributing, and using energy are essential to the
nation's future. From that standpoint, the work of the
U.S. Department of Energy is vital to that effort and we
have given strong support to many of the  programs
within DOE.
     At the regional meetings  this fall,  the NRECA
members approved a resolution which I believe clearly
speaks their views on the need for reduced dependence
on petroleum through research.
     I think all members of the Committee have a copy
of the statement and the resolution therein.
     "Continuation of policies and energy use approaches
that encourage increased oil imports  will  have  a
disastrous effect on this nation's  economy  and living
standards. Recent predictions indicate that imported oil
prices will soon reach $40.00 per barrel."
     "We believe that this nation must act promptly and
do everything possible to reduce dependence on im-
ported oil, and a major part of that effort should involve
an expanded research, development, and demonstra-
tion (RD&D) and commercialization program."
     "We believe that emphasis on the following pro-
grams are essential to  ultimately  achieve reduction of
dependence  on  foreign oil:
    1. development  and  commercialization   of
economical and environmentally acceptable processes
to produce synthetic fuels from existing abundant fossil
fuels and renewable energy resources;
    2. development  and  demonstration  of electric
power production  emphasizing economically feasible
alternative energy resources and improved efficiencies
in coal utilization; and
    3. a concerted effort to establish  policies to shift
from  an  oil  based economy to  an electric economy
where abundant coal and nuclear  resources can  be
maximized through conservation by development and
commercialization of more efficient electric appliances
and equipment (i.e., energy efficient heat pump water
heaters) and by commercialization  of electric vehicles
which, in many instances, can substitute for gasoline
powered  vehicles."
    "We therefore respectfully urge the President and
Congress to act promptly in establishing policies and in
the funding of major RD&D and commercialization pro-
grams, as  outlined, that can begin  to reduce  the
stranglehold  that oil producing  nations now have over
us.  We  further  urge  that electric cooperatives,  as
consumer-owned organizations, be recognized as ideal
utilities to implement demonstration and commercializa-
tion   programs and  that  the  Rural  Electrification
Administration be given the authority and the funding
to carry  out  these  programs  with  the  assistance
of NRECA."
    Note that the rural electric membership encourages
conservation in the broadest and purest sense, it urges
environmentally acceptable processes of producing syn-
thetic fuels, supports research to improve etficiencies of
power production and to develop supplemental energy
resources, and urges policies that will  result  in a shift
away from an oil-based economy to one  which utilizes
our abundant resources.     -
    There is also a separate resolution attached which
speaks to building standards and which I  believe in-
dicates that some of our policies within DOE are really
not aimed at reduced dependence upon petroleum. We
want to call that to your attention.
    We believe that a strong research and development
and demonstration program is essential to resolving our
energy supply and use problems. While we have gone
on record in support of many of the DOE programs, we
believe that there is room for improvement in the deci-
sionmaking process and in areas involving priorities and
procedures for demonstration and commercialization.
    We  believe that  we  need to  explore all  the
possibilities and make use of all the technologies that
show promise  for resolving the energy problem.  But
because of the urgency  of the energy  situation,  we
believe that  the greatest attention should be given to
those technologies that have greatest immediate prom-
ise for saving, or producing,  substantial amounts of
energy quickly,  reliably, and  economically,  as  well
as safely.
                                                   34

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                                                                                  Statement of Mr. Endahl
    We think there is a great temptation to base deci-
sions on what is politically acceptable than what is prac-
tical or technically achievable. I was interested in the
discussion earlier, and I think some good ideas were ex-
pressed on how groups that  would ordinarily oppose
one another might be able to get together and resolve
some of these problems.
    We support, for example, a strong solar and space
heating program as having the greatest potential of the
solar technologies that are available to us today and par-
ticularly for people  in rural areas that we are  serving.
But I  think we have to be realistic about what kind of
fuel savings can be achieved with this kind of a conser-
vation policy.
    Conservation to us means a lot more than curtail-
ing the use of energy. It means utilizing not only solar
energy, but more efficient appliances.  In  addition,  it
means greater attention to the energy savings  that can
be achieved by improved efficiency in the  generation,
transmission, and distribution of electric power. For that
reason, we have strongly supported the work  done by
the Division of Electric Energy Systems at the Depart-
ment of Energy.
    The potential for conservation by improving the
efficiency  of electric power production and distribution
is enormous. One percent increase in efficiency would
give us well over 5500 megawatts of electric power. Yet
very little  attention, and even less funding,  is  given to
these areas.
    We believe that there is  a great tendency for the
Department of Energy to engage in paper  studies and
surveys rather than the kind of research and develop-
ment that produces hardware and eventually results in
introduction of new technology.
    Volumes of reports and attitude surveys and com-
puter models by themselves are not going to solve the
energy problem. At some point in the near future, that
technology has to be demonstrated and commercialized.
    I guess we get a little impatient.  We would like to
see some of the things  that have been researched,
developed and put into practice.
    It is in that demonstration phase that the rural elec-
tric systems and  other utilities can play an important
role. Programs involving large scale power  generation
and transmission usually are conducted with utility input
so that results can be implemented quickly. It is equally
important  that  utilities  be  involved  in   small-scale
technology and even in the programs involving conser-
vation and solar space conditioning and water heating.
    We are getting an opportunity to make  an input in
many of these areas and especially in an area involving
the demonstration of a new technology which has been
developed by the  Department  of  Energy, the  heat
pump water heater. There are  some 100  heat pump
water heaters being demonstrated now by cooperatives
and  other utilities throughout the nation. This device
could do the work of a solar  water heater  at less than
half the initial cost.
    We believe that rural electric systems, in particular,
can play  an important  role in the  implementation
of technologies such  as these. As consumer-owned
organizations, they are responsive to the needs of their
members and as such are in a position to advise and
assist them and to encourage the use of energy saving
technologies.
    In addition, we believe that it is essential that the
utility be a part of the team because the introduction of
such technologies as consumer-owned power genera-
tion facilities and solar space heating systems can have
an impact on the electric system. By working together,
the utility and the consumer can both benefit from these
technologies.
    The transfer of technology we think is the greatest
problem that DOE faces. We believe much more atten-
tion needs to be given to this area.  The tendency is to
hold a conference and hope that you get the right peo-
ple there and that the information that is disseminated
gets out to the people who use it.
    We think that there ought to be someone responsi-
ble for initiating an innovative marketing program, an
effective  marketing  plan,  to  make  sure  that  the
technology is put to use. This is as much the responsi-
bility of DOE as developing the technology. We under-
stand that this is being considered and that DOE is trying
to do this.
    Some  system  of  measurement  should be
developed to determine the effectiveness of any given
department  in  marketing  its  ideas. We suggest that
perhaps one way to do this would be  a close working
relationship with the Electric Power Research Institute
which has close contacts with utilities, all segments of
the utility industry,  and has the capability of technology
transfer.
    With respect to the adequacy of attention given by
the Department of Energy to environmental protection,
we just do not know of situations where adequate atten-
tion is not being given. We think it is being done quite
well. But we do caution against imposing such stringent
environmental  constraints that  the needed research
never gets done, or is so severely hampered or delayed
that the real purpose of DOE, which is to help solve the
energy problem, is never really achieved.
    1 would like to call the Committee's attention to the
resolutions in the rear of the statement,  especially the
one having to do with energy performance standards.
We are concerned about the attitude that the use of
electricity for space conditioning is by definition wasteful
and that it should be discouraged without considering
the resource used  for generating the electricity. Rural
electric systems generate most of their power with coal
fired units. They are also beyond the natural gas mains.
Their  only choices are oil or  electricity,  so here is
something that we  are very concerned about.
    With respect to the resolution on "price forced con-
servation," we  oppose any energy conservation plan
                                                   35

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Hearing of October 3, 1979
based solely on  increased energy prices or increased
taxes.
    On the question of research on  cost-of-service
studies, we believe that these studies are necessary but
we believe that  the Department of Energy ought to
come up with some plans and a program to try to find a
low cost, simplified uniform approach to data gathering.
This would be very useful to us.
    We have  outlined suggested priorities in research
funding, and we  have already discussed some of those,
and the support for Federal energy-related research and
the support for fuel cell commercialization.
    We appreciate the opportunity to present this
statement.
    DR. REZNEK: Thank you. Are there questions?
    (No response)
    DR. REZNEK: I have some questions. The com-
parison of research investment between efficiency and
generation  and  conservation  measures is—do  you
foresee a way of  deciding at the margin how to allocate
the Federal resources between investments in, say, tur-
bine development or MHD or those kinds of questions
and Federal investments in conservation measures, the
experiments on  having the financing  for  tightening
up homes.
    MR. ENDAHL: We think both are important and
one should not be slighted for the other. I am not sure
that I can answer your  question as to exactly how do
you  determine  the  dollar  value  for  each  of the
technologies.
    In allocating resources, we believe that greatest at-
tention should be given to those areas that can produce
greatest results with minimum effect on lifestyle. That
means concentrating on achieving greater efficiencies in
energy technologies such as generation, transmission
and distribution,  where  small improvements can pro-
duce large energy savings.
    DR. REZNEK:  In your testimony you say we
need  to  explore all possibilities  but  money  is not
available in infinite supply.
    MR, IVES:  The biggest problem that we think can
be overcome  rapidly in the  near term is the improve-
ment  of power  plant reliability.  If, for example, as
Lowell mentioned in the testimony, we can improve it
one percent, it gives us a tremendously large increase in
capacity utilization which in itself keeps us from having
to build additional power generating stations, so that the
reliability can  be  handled. If these  efficiency  im-
provements  can  be applied  to  the   electric  utility
industry, we think there can be immediate payoff. By
immediate,  I am  talking 4, 5,  10 years, possibly. With
the other  technologies, you are  talking  about the
year 2000.
    DR. REZNEK: Since the-
    MR. IVES:  This is immediately. If these analyses
are carried out properly, we might be able to change a
few pumps or a valve and increase our availability by a
very large amount.
    DR. REZNEK: The current split between oil fired
and coal fired power plants is—will, hopefully, switch in
the future as we become more  dependent  on coal.
Therefore, won't that program impede the replacement
of oil power with coal power?
    MR. IVES: We are largely on coal. About 90 per-
cent of our capacity is coal fired. The oil, (most of the
rest is oil and gas), is a fairly small amount. So for us I
don't think it will be a substantial problem.
    MR. PIERCE: There are a number of utilities—the
ones I know about are mainly on the West Coast—that
have found that it is cheaper to support energy conser-
vation measures as opposed to building new generating
capacity. My question to you is how serious do you feel
the conservation alternative is being taken in  planning
for future capacity and, number two, how acceptable do
you think that conservation measure alternative  would
be in terms of customer receptivity?
    MR.  ENDAHL:  We think  our rural electric
systems are taking conservation seriously and have
been for a good many years. 1 can recall 20 years ago
we were trying to get the insulation standards improved.
We had a meeting on that with a number of people from
NEMA,  TVA, and  several organizations that should
have been very much interested in insulation of homes.
At the time rural electric systems in Minnesota were
recommending 13 inches of insulation in the attic. That
was 20 years ago.
    We had a terrible time getting those insulation
standards raised. So our people have been very much
involved with that kind of thing for a long time.
    We don't see though that conservation is going to
eliminate the need for additional power generation. Our
loads are growing at the rate of a little less than six per-
cent per year currently which is a little faster  than the
investor-owned segment and we think it is going to con-
tinue simply because there are more people moving out
there. There are many more needs for energy.
    Also as I mentioned earlier, there is the  need for
substitution for oil. If we substitute electricity for oil,
which is really our biggest problem, we will minimize our
dependence upon imported oil. Using something other
than oil and electricity generated by coal, we  think,
makes a lot of sense.
    MR. IVES: One other point I think is very impor-
tant to supplement what Lowell said is the fact that we
produce power, not energy. Where you may conserve
energy, we don't see any decrease in the production of
power. You might say that there is a good substitution
by using low level energy like solar heating to replace
power consumption because you can get away  with a
low level type of  energy.  But not in  factories—our
standard of living depends on power production.
    MR. ENDAHL: Let me give you one  example
taken from an EPRI report. If 25 percent of  the new
residences that we build today were outfitted with solar
space heating equipment, between now and  the year
2000, that would provide a seven percent reduction in
                                                  36

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                                                                                   Statement of Mr. Pate
space heating energy required. If it is possible to retrofit
another 3.5 million homes, that would increase this
figure to nine percent. But the combined savings of total
energy would be about one percent reduction in total
energy used in this country.
    You see, what we are trying to say is that we ought
to do those things that result in energy conservation.
There is  no question about this. I have a solar water
heater myself. But we have to be realistic about how
much  energy  conservation  can  reduce our energy
needs and  how much we really need to increase our
supplies of energy in the future. We need to do both.
    MS. CLUSEN: Mr.  Endahl, I would like to com-
ment on two statements in your testimony. One had to
do with  your belief that there should be  someone
responsible in DOE for the commercialization of new
technologies and innovative approaches. Let me assure
you that there is. For the  last two years, the Deputy to
the Under Secretary has been responsible. At this point
in the realignment that responsibility  is located in the
Office of Resource Applications.
    I would also like to add that we indeed have had a
long ongoing arrangement  with  the Electric Power
Research Institute,  which has recently entered  into
some joint funding of projects.
    MR. ENDAHL: Very good. We think that is a very
good  approach.
    DR. REZNEK:  One of  the questions  in your
resolutions are "We strongly oppose a massive infusion
in Federal research funds in solar research to the near
exclusion of developing other forms of energy such as
nuclear that are more economical and environmentally
acceptable."
    How do you compare solar energy in terms of its
environmental acceptability to nuclear?
    MR. ENDAHL: Solar space conditioning  and
solar water heating—we don't see any serious environ-
mental problems to that. Solar thermal electric requires
a good bit of space. We really don't see any serious
environmental problems with the solar technology. You
have  to  remember that these are resolutions of our
membership. The  NRECA membership is concerned
about  the  economic  as  well  as the  environmental
aspects of these technologies.
    DR. REZNEK: Thank you very much.  We will
take  a  15 minute  break and  then  reconvene at
3:00 o'clock.
(Brief recess)
    DR. REZNEK:  We will start again.  Our next
speaker is Mr. Pate from this morning. His  flight was
delayed. Mr. Pate is from the Alabama Solar Energy
Coalition.
    MR. PATE: Thank you. I appreciate the oppor-
tunity to be here with you today in order to present my
views on the adequacy of environmental impacts of the
Department of  Energy's decisionmaking process with
respect to  nonnuclear research,  development,  and
demonstration programs.
      I would like to make a comment on Mr. Whiting's
  presentation. I really don't think he has to worry about
  rock stars doing a benefit for coal-related projects.
      It is impossible to discuss this subject in isolation
  because the issues we hope  to  address  are  so far-
  reaching. Our decisions in developing energy  tech-
.  nologies have got to be the best possible because they
  don't just affect people's lives today but will be extremely
  important for many generations to come.
      Our energy crisis is real and will require more than
  paper studies to solve.  However, it is extremely impor-
  tant to note that development of nonrenewable energy
  technologies will place  very uncomfortable  burdens on
  future lives, since depletion of finite resources which are
  nonrenewable will severely hamper availability of goods
  dependent  upon fossil reserves  for production; i.e.,
  plastics, drugs, stainless steel, and fertilizer.
      I am an unsalaried, non-staffed officer and Board
  member in a public  interest,  not-for-profit  group,
  educating and promoting solar and renewable energies
  and appropriate technology in  Alabama.
      I can safely say that 1 have  no vested interest in any
  energy technology that DOE, (which by the way could
  stand for the Department of Entropy) can concoct, with
  the  notable exception that I  will be  forced to pay
  possibly through  the  nose for  those  energy tech-
  nologies,  both financially  and physically  with  their
  environmentally related impacts.
      Since I live within sight of strip mining operations, I
  can  attest to the adverse environmental impacts of that
  energy resource, including audible pollution, water and
  air pollution, erosion of the land, and visual pollution.
  Raped earth is not a very pretty sight.
      From  an  environmental standpoint, let me  state
  preference for decentralized, renewable-income sources
  of energy technologies, as they are without fail the most
  environmentally benign.
      With respect to the Background Document on this
  hearing, let me begin by noting that  the Department of
  Energy PPMS is rather farcical as decisions are already
  made before they  (the PPMS's) are even prepared. For
  heaven's sake, what would it take to cancel an energy
  technology from being developed?
      To begin with, PPMS comparisons  aren't  even
  made between competing energy technologies. Also, it
  appears to me that PPMS's are done as a cursory dip of
  the  hat to the NEPA.
      I would call  for equal representation  in decision-
  making with senior DOE officials by environmentalists
  and public interest representatives, each having equal
  representation  and  authority  to override  research,
  development,  and  demonstration  for  energy  tech-
  nologies having adverse environmental impacts.
      Having actual authority in  the decisionmaking pro-
  cess would in all probability,  assure environmentally
  sound  energy  technology development.  All  four
  regional workshops have called for public input in this
                                                   37

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Hearing of October 3, 1979
matter and, by God, if environmental protection is to be
accomplished, we must have that representation.
    Also, on page 21, note the terminology,  "to syn-
chronize required,"  and  "intended  to insure  envi-
ronmentally  responsible  decisionmaking"—note  the
sign as you came in "Required Public Hearings," and
finally, the over-abundance of should's, could's, and
designed to's in the text.  If the Environmental Protec-
tion Agency were the environmental protection agency
I would call for, it would  have the authority vested by
Congress  to  override policy  decisions made by  the
Department of Energy, the Department of Defense, or
any other Federal agency with respect to environmental
degradation.
    Also note that PPMS and the environmental plan-
ning and  assessment process which are intended to
ensure environmentally responsible decisionmaking are
pure crapola, or else we have a batch of unadulterated
idiots making decisions at DOE.
    As testament,  consider the adverse environmental
impacts of the solar satellite power systems, SSPS, yet it
appears  that $25  million will  be  appropriated  to
evaluate that  boondoggle next year.
    This is an evaluation of  SSPS.  There are  many
proposals to use space satellites to trap solar energy and
microwave the energy to earth. The most popular plant
size is to use about 50 square miles of photovoltaic cells
to generate electricity to  microwave  to a  100 square
mile receiving rectenna on earth.
    The Boeing Sunsat  System employs a series of
reflectors to heat a closed loop helium turbine. This tur-
bine electric system weighs a great deal more  per watt
than the photovoltaic system and is not considered to be
as viable"as the photovoltaic system but stitl continues to
receive considerable government funding.
     Other plans including building large scale manufac-
turing and transport facilities both on the moon and in
space for using lunar material to build the system. This
plan, O'Neill/Nasa,  would require much larger initial
funding, perhaps 10 to 100 times, and would probably
deliver no  power until well after the year 2000, yet it
continues to receive significant funding.
     The  basic plan  is to build perhaps  60 5,000
megawatt plants in space which would provide perhaps
 10 percent of our domestic electricity in the year 2000
at a cost of perhaps one trillion dollars, neglecting infla-
tion,  cost over-runs,  and unanticipated  difficulties,
et cetera.
     The cost of the first 5,000 megawatt plant would be
about $100 billion which is about 15 times the  cost of a
comparable terrestrial nuclear power  plant.
     All of this assumes that the cost of photovoltaic
sales would drop to about five cents per watt,  at which
point the cost of sales to provide electricity on the roof
of an average house would be only $250.
     The plan appears to be  outrageously  expensive.
Each plant would require the firing of about 100 heavy
launch  lift vehicles.  The  HLLV,  heavy  lift launch
vehicles, not yet developed would be much larger than
the Saturn rocket and would have to carry about 500
tons apiece as opposed to the 30 to 60 ton capacity of
the Saturn space shuttle system.
    There  are  many  environmental problems.  The
HLLV  would  punch  unprecedented  holes in  the
ionosphere, the microwaves would totally dry up  the
area under  the rectenna, birds flying through  the
microwave beam would become "uncomfortably warm"
at best.  We might advise the birds that they should fly
directly through and not lull around.
    The beam  might wander by accident and radiate
human population or could be deliberately trained on
human populations as  a military weapon. The space
platform is vulnerable to attack. The cells may have a
very short life in space due to micrometeorite bombard-
ment, perhaps as much as 10 percent loss of capacity in
only 10 years.
    The centralized power plant of rectennas would
require massive new land-line systems and would con-
tinue  the present oligarchic system of power distribu-
tion. The beam would  disrupt police, taxi, C.B., and
defense electronic communication equipment within a
distance of perhaps 100 miles of the rectenna.
    The SSPS system adds heat which would normally
not reach the earth to the earth's heat budget. The
question arises, who is  promoting the SSPS and why?
Most  of the promotion has come from NASA, large
aerospace corporations, notably Boeing and Lockheed,
and  major  nuclear   boiler   suppliers  such   as
Westinghouse and General Electric. All of these  are
industries whose support base is eroding. NASA cannot
justify continued  manned exploration  of  near  space
unless there are more  massive direct human benefits
than resulted from Apollo-Skylab kinds  of programs.
    The large  American  aerospace corporations  are
finding their sales slipping as European manufacturers
are beginning to build more efficient aerospace vehicles.
Orders for nuclear plants and other conventional plants
are being cancelled as conservation and economics are
beginning to take effect.
    All  of this  means that these major industries and
the congressmen who represent them, such as Ronnio
Flippo,  who  I  regret to  say is a representative from
Alabama, are the major influences in the SSPS move-
ment. Most energy-related consumer organizations who
support solar programs  have taken strong stands against
SSPS. Such  organizations include Solar Lobby, Envi-
ronmental Action, Center for Renewable Resources,
and Citizens Energy Project. The Sierra Club, Audubon
Society, and other environmental groups have pub-
lished critiques of what has been called  "pork  barrel
in the sky," "a solar boondoggle to rival nuclear  and
synfuels."
    I am probably the most intense solar advocate in
the universe, but don't think for one minute that just
because energy technology has solar incorporated that I
will fall  for it. I really  can't  quite come to grips with
                                                   38

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                                                                                     Statement of Mr. Pate
DOE's supposedly sincere approach to "public candor"
while throwing out such unmitigated bull all the time.
    It is critical to know at this time that any research
and development monies appropriated to an energy tech-
nology merely adds impetus  to further expenditures in
order to  justify  the initial expenditures; i.e., nuclear
energy.
    I  would  like  to  reiterate  the  call  for  active
dissemination of  information. For example,  I received a
1500 page Generic Environmental Impact Statement
on nuclear waste disposal (and other technologies don't
have nearly the far-reaching environmental implications
as does rad-waste)  three days before the  hearings in
Atlanta last week. So I can verify that neither adequate
time nor resources were allocated for public participation.
    Are there members of the press in the audience?
Would you raise  your hand?
    (No response)
    MR. PATE: I think this demonstration  also proves
that  point. Just  for the record, could  I receive  the
Federal Register for   the  Solar  Energy Coalition-
Alabama's Library? Since I was told at the public hearing
on  Management of Commercially Generated Radio-
active Waste that notice of that hearing and the subse-
quent 1500 page GEIS was  announced in April. The
address is Solar  Energy Coalition-Alabama, P.O. Box
163, Coaling, Alabama, 35449.
    Just to remind us  of what we are here for, I will
quote, "the adequacy of attention to energy conserva-
tion methods and environmental protection ... and the
environmental consequences  of  the application  of
energy technologies."
    In terms of conservation, let's examine the Indus-
trial  Recycling and Conservation  hearings that DOE
held. In those hearings it was brought out that DOE had
no  mandate  on energy  conservation  for  industrial
groups, all they have is targets. Unless financial incen-
tives or economics are there,  I doubt if industry is going
to take it on their own to meet those targets.  It should be
mandated conservation efforts.
    Let me take this opportunity to castrate DOE and
EPA at the same time for their open-ended approach to
urban waste utiteation, promoting combustion, rather
than  source  separation, and  more environmentally
benign  energy  production   technologies,  such  as
methane generation (etc.).
    Include  here endorsement by  the Department of
Energy and the Department  of Agriculture and EPA's
lifting  of  environmental considerations for  alcohol
production.
     In terms of alcohol production,  I  would  like to
address a  couple of issues. Just what is the net energy
picture for alcohol? We  know that a bushel of corn meal
will produce 220,000 Btus of alcohol, but how much
energy does it take to  produce that alcohol? Distillers
use 280,000 Btus, but that is for double-distilled drink-
ing alcohol. The engineers  at the  National Gasahol
meeting in November,  1978, said that they could do it
for 80,000 Btus, but they haven't done it yet. How
many Btus of gasoline and other fuels does it take to
grow a bushel of corn. And if it does take a total of, for
example, 200,000 Btus to grow, harvest, mill, and pro-
duce 220,000 Btus of corn-derived alcohol, is it worth
it? Or are we better off perhaps to use our oil reserves,
until a direct solar economy is achieved?
     I would like to note here that in 1972, (if I am not
mistaken, we have somebody here from the Petroleum
Council)  the  Department of Interior stated that the
reserves of petroleums in  the United States was at 500
billion barrels in 1972. A short year later, after the Arab
oil embargo,  this reserve was reduced to fifty billion
barrels of  oil  in  our reserves. One year dropped our
domestic reserves a hundred-fold. Why is that?
     Since it takes much less invested energy to grow
high cellulose crops, for example trees, than it does to
grown grains, perhaps we should concentrate on wood
alcohol, (methanol) instead of grain alcohol, (ethanol).
What are the net energy  figures  for alcohol produced
from high cellulose crops such as wood chips, bagasse,
and corn stalks? Grain is fairly plentiful today, but much
less plentiful than it was in the 1950's when we filled
ships with our surpluses and then towed them out to sea
and sank them.
     Food shortages are looming for the 21st century.
Soil is eroding from our corn fields at over a ton per acre
per year average. Is it wise to get deeply involved with a
resource which would allow us to prolong our love affair
with the automobile, continue the destruction of our
soils, and then have to go "cold turkey" at a point where
we are even more dependent on liquid fuels. Perhaps a
better solution would be  conservation,  1500 pound
cars, and more careful land use.
     Alcohol is a more powerful fuel than the blend of
hydrocarbons  we call  gasoline. When added to  gaso-
line, it raises the octane level the same way additives
such as tetraethyl lead do.  On the  surface, this would
seem to be a good thing. By adding  alcohol to gasoline,
we can abolish leaded gas and save the catalytic con-
verter, thus making it possible  to continue building
engines the same old way. Alcohol may be arriving just
in time  to  preserve  current American  automobile
technology for a few more years at a time when we
should be changing as rapidly as possible.
     When gasoline  was selling for  about 65 cents per
gallon, 10 percent alcohol-gasohol was selling for about
70 cents per gallon, presumably because the alcohol
costs 50 cents per gallon more than gasoline to produce
and sell; that is, about $1.15 per gallon. Although there
have been claims that alcohol can be produced and sold
for 60 to 70 cents per gallon, most commercial sales
have been in the $1.10 to $1.60 range.
     In Brazil,  where both 100 percent alcohol and  10
percent gasohol are in rather extensive use, the alcohol-
based fuels are far more expensive than gasoline, even
though gasoline costs significantly more than it does in
the United States. Are there any  good solid studies
                                                  39

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Hearing of October 3, 1979
which would lead us to believe that alcohol will ever
compete economically with gasoline, or are we  just
luxuriating in wishful thinking?

    Also, we must remember that since it takes energy
to produce alcohol, the cost of alcohol will always be
pegged  to  the price  of other  energy,  whether that
energy is a ton of coal, a pound of uranium, a barrel of
oil, or a cord of wood.

    This shortsighted approach is indicative  of  the
irrelevance of the PPMS. At this point, it becomes diffi-
cult to reflect upon the relevance of environmental con-
siderations in current DOE research, development, and
demonstration decisionmaking processes since at best
those considerations are  wholly inadequate at this time.
    To quote Public  Law  93-577, Section 2(a),  the
"nation is suffering from a shortage of environmentally
acceptable forms of energy,  (b) ... This failure is partially
because the unconventional energy technologies have not
been judged to be  economically competitive with tradi-
tional energy technologies." Who made that judgment?
    Perhaps it would  be wise to ask why we have the
"conventional" energy sources we use, and then see if
there is any correlation between those accepted energy
sources and those which the Department of Energy, in
its shortsightedness  and total lack of public interest or
benefit, are advocating.
    Our energy needs today are met by supplies derived
by men who in their "infinite" wisdom learned how to
forge the earth's beauty into power for a profit. Prior to
this development, all energy needs were derived from
renewable,  environmentally  benign  energy sources,
notably, solar, wind, biomass, and hydro, and were all
income sources of energy.
    My  perception of environmentally   acceptable
energy technologies calls for appropriate technology in
the area of  renewable energy resource RD&D which
inherently call for decentralization, public  benefit  and
control,  and  distinct  advantages  for our  progeny.
Instead, we have tower power so that someone can sell
the sun.
    In regards to tower power, the tower  power con-
sists of a very large array, perhaps 1 to 10 square miles,
of mirrors on double axis mounting so they can con-
stantly reflect and focus sunlight near the top of a tall
tower.  The  tower  contains high technology metallo-
ceramic  surfaces which can receive the  energy at
temperatures from  a  few hundred  degrees to a  few
thousand degrees and use  this heat to boil water  and
then run a turbine on superheated steam.
    The boiler turbine uses large amounts of cooling
water just like the  ones in nuclear coal-fired power
plants. The advantages of the tower power are that the
fuel is free and the plant is  free from the various pollu-
tions: air, water, mining,  radioactivity, and dangers
associated with conventional power plants.
    However,  there  are  many problems  associated
with tower power. Not only does it continue the tradi-
tion  of  centralized  high  temperature  corporate-
distributed power, but the fact that these plants would
have  to be  located in low rainfall  areas means that
cooling water would be scarce and expensive.
    In addition, these semi-arid areas are the last areas
where we should be heating up the water. Desert areas
are low population density  areas and so  the plants
located  large distances from the  load centers would
require a larger scale transmission line and facilities than
conventional power plants.
    The initial costs are high, about $10 per watt, and
show  little promise for future cost reductions.  By con-
trast, many wind electric systems are already operating
at less than $3 per watt and the cost of photovoltaic cells
is now below $4 a watt with  costs on  the order of  $1
watt promised in a couple of years.
    In addition, the tower power is a "fragile" power
plant. Parts must be  replaced frequently, not  only
because of the  very high temperatures and rapid flow
rates,  but also because the mirrors must remain bright
and the axis free-turning in  a rather hostile, blowing-
sand environment.
    Another problem with centralized terrestrial  solar
system is  the difficulty of providing storage  backup.
Either you fire up a fossil fire  boiler every  night or you
must store the daily-generated solar energy during the
day so that it can be released at night.
    So far, the only feasible way to do this is to pump
water up to a high lake pump storage and then let the
water run  back   down  through  turbines at night.
Although this is the best option available for centralized
power plants, it is not very efficient and it is particularly
inappropriate for  power tower application because of
the lack of water at the desert sites and because of high
evaporation  rates.
    Small-scale storage is much more appropriate. A
household can  store  its  solar electricity  in batteries,
flywheels,  or other technologies which cannot operate
on that large a scale.
    It is disgusting and disappointing to me to see  short
term profit oriented energy technology promoted by a
government agency when that government was estab-
lished by the people and for the people and not by the
multi-nationals  and for the  multi-nationals and  their
respective  stockholders.
    The only folks I see advocating coal gasification, et
cetera, are politicians representing coal-producing states
and oil  companies which in  turn own the coal com-
panies. Instead  of research, development, and demon-
stration  to  increase  supply  of internal combustion
engine fuels, alternative transportation methods utilizing
more  efficient technology should be the priority of the
day. According to my calculations, approximately  60
percent of DOE's funding goes to nuclear energy and of
that going to nonnuclear sources,  about 95 percent
goes to oil companies or other large multi-nationals.
                                                   40

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                                                                                    Statement of Mr. Pate
    The most sensible program currently offered by the
Department of Energy is the Appropriate Technology
Small Grants Program and we will be lucky if we can
squeeze $16 million out  of the big business funding for
this year.
    The Appropriate Technology Program  exhibits a
characteristic I would tend  to  advocate. Let's simply
give all the Department  of Energy funds to  the public
and let the public through free enterprise select appro-
priate energy conservation or supply technologies. At
least they couldn't screw things up any worse  than DOE
has done with their Department of Entropy approach.
    I  fully realize that when big business has squeezed
the last dollar of profit  from its oil,  natural  gas, coal,
nuclear, shale, and tar sands investments and have suf-
ficiently monopolized the renewable energy field that
they will allow DOE to proceed with actual efforts to
develop those energy resources.
    There are by now several  million Americans who
are pissed about nuclear power, as  evidenced by the
almost daily rallies, marches,  and  protests (brought
about by their education on the subject) and believe me,
this public criticism of energy policy will spill over to
other  adverse profit-oriented energy  technologies.
    What I am calling for is sensitivity to public benefit
and long term solutions  rather than short term pitfalls.
For example, the synfuel—and I would like to note here
the misnomer of synthetics, there is nothing synthetic
about converting from a solid form to a liquid form with
a very high net energy loss—program would  only solve
our petroleum shortages in the near future, wreaking
havoc on the environment in the process.
    The billions proposed to develop this  extremely
low,  net-energy-benefit technology could  be  much
more  productively spent developing long term solutions
such  as renewable technologies, conservation, and
educating the public.
    The Department of Energy has failed  to set an
appropriate  example  in  procurement   efforts  with
respect to photovoltaics, and research, demonstration,
and development has been disproportionately directed
toward  NASA-scaled  energy  systems   rather than
community-scaled  peoples energy.  Not only have
smaller, environmentally benign technologies been sur-
named DOE's "stepchild" in energy research, develop-
ment, and demonstration, but those  solar technologies
being promoted by DOE, also by NASA, Boeing, West-
inghouse, will have adverse and irreversible environ-
mental damage as well  as serious resource  depletion,
i.e., SSPS and tower power.
    From the  outcry  of  solar  advocates  and anti-
nuclear proponents, I feel that the American public is
unwilling to sacrifice a  clean  environment, even for
energy. What is needed  is active  rapport not only
between the Department of Energy and big business, but
between small business and the public as well. A per-
sonal point of aggravation is  my understanding that
about 75 percent of the Small Business Administration's
solar loans went to big business subsidiaries for synfuel
projects, coal gasification, what-have-you.
    One thing strikes me for certain, if nuclear power
development had been assigned to solar advocates or
appropriate  technology folks  in  the fashion  which
nuclear advocates have been assigned the development
and commercialization of solar, we would still be waiting
for  our first commercial reactor  just like we are  still
waiting  for commercialization of solar technology to
begin. Unbelievable!
    President Carter has been quoted as saying that if
he and  Congress  can't  deliver to the public a sensible
energy plan, then they should all resign and go  home.
Second that recommendation.  And if the Department
of Energy can't  begin to reassign priorities in its energy
research, development, and demonstration, then they
can all forget it and go home also.
    If the Department of Energy expects its new effort
at public candor to be accepted, it has got to stop its
determination to  keep vested interests  above  public
interests and to  begin to take long and serious looks at
environmental impacts.
    As guardians of the earth's resources during  our
time here, we have a moral obligation to ourselves and
to our progeny to conserve all resources that we  are
technically and not necessarily economically feasible of
doing so, meanwhile devoting all energies and resources
to renewable energies.
    I'll  close with my  tee-shirt of the month  which
states, "We don't  care. We don't have to care. We're
Exxon. At Exxon, we're part of the problem." Thank^you.
    DR. REZNEK: Thank you.  Are there questions?
    (No response)
    DR. REZNEK: I have just received a note that our
next witness, Dr. Schlesinger, has been delayed. He is
scheduled for the last witness for the day. We would like
to open up and ask if any of the audience would like to
testify.
    MR.  STEVENS: My name is Ken Stevens.  My
comment is really  quite brief. This morning a couple of
the people made comments with respect to the role the
engineering  profession  should play.  As a Registered
Professional Engineer, I have noted that over the past
ten years or so there has been a change in the attitude of
engineering students. Most notably that environmental
matters are no longer out of the question for considera-
tion, they are part of the decisionmaking, they are  just
as much a part of  it as physics or chemistry or electrical
matters. I think  that is very desirable.
    We are seeing this in  the Department of Energy,
especially with the younger people coming into DOE.
Since I work on  the outside,  I  can watch this from
somewhat of an objective distance. They are integrating
environmental thinking  into their  technical  decisions
without even giving it a second thought.
    An example is when I visited someone in Energy
Technology a few days ago, the ET group within DOE,
and asked what he saw as the basic needs for additional
                                                   41

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Hearing of October 3, 1979
 R&D funding, he listed three items. Two of them were
 for specific technology development and one of them
 was for an environmental study that was actually being
 funded by ET. It was obvious to me that he had done a
 lot of cross thinking with EV, Mrs. Clusen's operation,
 and said they have work going and we would  like to
 parallel it with some work that enables us to integrate
 this thinking with our technical decisionmaking at the
 front end.
     So 1 think this is a very positive thing that is going
 on. I  think there is a  long term trend. I think it  is
 accelerating. I think it is very desirable.
     DR.  REZNEK: Mr. Stevens, I  think we missed
 your affiliation.
     MR. STEVENS: My name is Ken Stevens, I work
 for the Aerospace Corporation, which is a consultant
 to DOE.
     DR.  REZNEK: 1 would like to address a question
 or two to Mr. Pate. Mr. Pate, your comments imply that
 any centralized power distribution system is in reality so
 expensive as to not be deserving of federal support and
 any decentralized one, based on renewable resources,
 is  competitive and  therefore  advantageous to any
 centralized one. Is there a formalism for  making this
 calculation?
     For example, you  implied that in the long term,
 renewables  are our only solution. However, I believe
 that most people think that we have quite a number of
 years left on a synthetic fuel based on coal technology
 and that  the cost of foregoing that  transition  bridge
 would in fact be quite high.
     MR. PATE: You are right, I stated the costs would
 be very high. It would deserve a commitment which
 President Carter called the "moral equivalent  of war," I
 believe. At any rate, the 400 or so years that we have
 left of coal at current energy consumption rates would
 be knocked down to around  125 years if we used the
 synthetic  fuels program primarily because you  take a
 ton of high  grade coal and convert it to approximately
 90 or so gallons of gasoline.
     I  didn't really mean to imply that  all centralized
 generating facilities were necessarily demons. I realize
 that in a lot of urban areas that will be the way we have
 to  go and,  therefore, I have  no  difficulties with that.
 What I am saying in terms of how the selection process
 should be made would be to take a look at net energy
 benefits, that was a  part of my comment, that in the
 PPMS evaluations, there were no comparisons made
 between competing energy technologies and it is also
 important to note that PPMS's are not even required for
 I think technologies  in  which  less than  $50  million  is
 spent  in a year or less  than $200 million is  budgeted
 over the life of the project.
     At any rate, with respect to what  I feel is one very
 good  Department of Energy program going on right
 now is the Appropriate Technology Small Grants Pro-
 gram. I would challenge anybody within the Depart-
 ment of Energy to take a look at the net energy benefit
per dollar invested in that Appropriate Technology Pro-
gram and compare that to dollars invested on any other
energy technology program that is being developed,
with the possible  exception of conservation. Also,  in
respect to synfuels, President Carter's plan purports to
invest $88 billion through the Energy Security Fund to
develop a synthetic fuels capacity to provide 2.5 million
barrels per day in  1985. The figures that I see from the
Harvard  Business School,  Energy  Futures  Report
would tend to indicate that about a ninth of that invest-
ment  spent  on  conservation  technologies  would
generate  that same 2.5 million per day saved, which
would be saved from that point on and not have to be
resupplied daily.
    DR. REZNEK: So you believe that it is possible to
have a  reasonably forma! calculation of net energy
return per investment, particularly Federal R&D invest-
ment, which could be used as a consistent criteria across
the investment choices.
    MR. PATE: Yes, I do.
    DR. REZNEK: Another question that I would like
to return to is that you felt that the substitution of energy
conservation methods for fuel consumption required an
activity above and beyond the market allocation required
of federal mandate to conserve energy. Do you believe
that the federal establishment has got the wisdom to do
that effectively?
    MR. PATE: That's a  very incriminating question. I
am not sure that there is that capability—
    DR. REZNEK: We are only people.
    MR. PATE:  Right. I am not sure there is that
capability.  I can  note, however, that  the  American
public  is indeed  willing  to adhere  to  conservation
methods. I think the figures that are coming in are like
85 percent  response participation in the thermostat set-
ting and what have you. I think that indicates  that the
American public as a whole is willing to go along with it.
I think it is  important to note that in terms of industrial
(or commercial, or what have you) energy consumption
(for one industry in particular}, the aluminum industry
has decreased because it is very economical for them to
recycle and to conserve energy putting out aluminum
products, and that they have gone to those technologies.
    What is needed is to take away the federal incen-
tives—in  terms of taking  raw materials,  rather than
recycling products,  there  are also tax incentives for
industry to ship raw materials rather than to ship recycled
materials. There are resource depletion allowances that
should be gradually if not drastically done away with.
And several other areas of institutional barriers there. I
just don't feel  that setting targets without providing
some sort of financial incentive or else mandating those
targets is going to be very effective in energy conservation.
    DR. PATTON: You mentioned several things that
gets close to economics and I thought I would take a
moment to see if I clearly understood your point. You
called for  the equivalent of net energy analysis  as
                                                   42

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                                                                                    Statement of Mr. Pate
evaluating various alternatives and the same thing was
said today, earlier, before noon. Allow me a flight of
whimsy for a moment.
    I could see the Labor Department doing a net labor
analysis and then you could see the Treasury doing a
net capital analysis and when these three reports would
be brought to the Office of the President, he would turn
to his council of economic advisors and say "what shall i
do?" and they would say, "Look at the market price for
the three commodities and choose the one that is most
effective in terms of price." They might say that. It is
very likely they would  say that. But I wonder if that
would satisfy your understanding of the issue as well.
    What 1 am really saying is you cannot look simply
at net energy, you must recognize that we need land,
natural resources, labor, and capital and all those things
are captured in  the price system if, one,  you don't
unduly  subsidize  one thing to  the  disadvantage  of
others; and two, you avoid the use of mandates. I would
appreciate your response to that.
    MR. PATE: What I would address first is the state-
ment  of unduly providing  incentives for  one  energy
technology over the other. I think it is fairly common
knowledge that the non-renewable  energy resources
are heavily subsidized by the government and there are
very few  incentives, except for personal income tax
credits and very small industrial  income tax credits, for
development of renewable energy technologies.
    In terms of the three part analysis of the net energy
analysis or the net labor analysis or the net  capital
analysis of the energy technologies,  I think  that by
examining and if there were some structured method for
preparing an accurate report in those three areas in
comparison of non-renewables versus renewables, that
the renewables in  most cases would probably give a
slight advantage at this time due to the high and rising
cost of non-renewables energy sources.
    But I think also that somewhere in  that analysis
there has got to be what this hearing is for, an envi-
ronmental consideration.  It really bothers  me that we
are depleting the earth's  resources, which have taken
millions and millions of years to  store here, in a period
of roughly 100 years for our own personal, self-seeking
interests, so that we can fly around in our  automobiles
and we can live in a 70 degree heated house and a lot of
other things that really shouldn't be and that as  inhabi-
tants of this sphere and of the  earth for  a very short
period of time, it is our responsibility to make sure that
the future generations  and our progeny  in particular
have resources for the necessities of life, not only purely
physical comforts.
    So I  would advocate a four part analysis. I am
about as fair-minded a person as 1 know  and if there
were distinct economic or capital or land considerations
that  would  preclude development  of a renewable
technology and that is what the  people wanted, then )
would be all for it.
    DR. REZNEK: When  you pursue  that line  of
argument in its usual direction, you finally corne to the
point where someone has to put a discount rate on cur-
rent costs and future discount of increasing costs and
values of remaining resources to future generations. Do
you have a discount rate that ought to be used? Should
we plan for 100 years or 50 years?
    MR. PATE:  Steve, 1 have really  given a lot  of
thought to  that subject.  If we continue  our nuclear
madness, we might should only use 100 years, but
assuming that the physicists' calculations are correct, the
sun is going to keep shining for something  on the order
of four billion years.  So what I would advocate in terms
of replacement costs would be  to average the number of
people that are going to be here for four billion years
and then see what  it amounts to  environmentally for
energy development.
    DR. REZNEK: I think  if we use a billion year
discount rate, you will end up in renewables.
    MR. PATE:  The transition to  renewable-based
society is inevitable, and this is a comprehensive change
in lifestyle in terms  of recycling, conservation, and  all
the things that people quibble about being good and fine
but  that the  economics are just not there.  The fact
remains that that transition is going to be made, because
at our rate of consumption, we are going to deplete the
earth's fossil  fuels  within a  very  short  (geologically
speaking) period of time.  1 would even allow 500  or
1,000 years if that is what you want to hear, but the
transition is inevitable. So why delay that transition?
Why not devote our interests and our energies and our
resources to developing those technologies so that we
have petroleums to make plastics and to make drugs
and to make fertilizers for future generations.
    Once you  do that,  the  environmental  concerns
really begin to take shape.
    DR. PATTON: If we run out of time, please stop
me. Your view of economics is a  little different than
mine and I guess I seek to better understand yours. For
one thing, you know, as we transition through the next
100,200,500,1,000 years, it isn't that you abruptly run
out of any one commodity such as petroleum as feed-
stock. It is just that its marginal price slowly rises relative
to other things of which we are not running out.
    There is another aspect to it and, of course, that is
the  population. If  prices grow higher and  the public in
the  future does not want to have large families, there
could be a reduction in the total number of people living
on earth over the next few billion  years, taking your
model there, and so it isn't that somehow you have to
axiomatically assume that the population  stays in this
country at 220 or several billion for the world, the society
of the future has a way to accommodate the changing
circumstances. You  seem to have ruled  out totally that
there  might be  finds of energy that we haven't con-
sidered  til now, some rumbles include such things  as
geothermal beneath the domes under the ocean floor. If
                                                  43

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Hearing of October 3, 1979
you put yourself back 50 years, go back 100 years, go
back 200 years, people then did not forecast the things
we take for granted now.
    I think it is appropriate that society continue to use
a discount rate. OMB would say 10 percent. And I think
that discount rate can even be used in the case of the
non-renewables, that is a personal opinion, but I at least
share that view with you.
    The other thing I would  mention  is  that the
renewables cause you and require you to live in a much
lower level of industrial  activity than we  now take for
granted. For example,  you talked to alcohol.  If you
wanted to add 10 percent alcohol to all of the gasoline
used in this country and produce the alcohol from grain,
you would have to totally commit all of our farmlands to
the production of the grain to provide the alcohol. 1
thought I addressed that I would only point out to you
then that the rate of power that renewables can supply is
considerably less than that which we take for granted now.
    The other thing you seem to  be very upset about
was the fact that  the EXXON Corporation does  exist
and it is large and it represents centralized  industrial
power in your eyes. The only thing 1 would observe is it
was  the use of  concentrated capital  in the form  of
private sector-forming corporations that found domestic
oil that we now take for granted, found the oil in most of
the world, in foreign countries  throughout the world
that so recently we took for granted. It was the national-
ization of that foreign oil by those foreign countries that
suddenly raised the price. So I wonder if you  aren't for
some reason kind of biting an institution—and  I don't
mean any one firm, I mean the concept of the corpora-
tion which provides jobs and puts capital together to go
out and find energy—I wonder if you aren't biting that
goose that laid the golden egg.
    MR. PATE: It is a real good point. It is extremely
well-taken. In regards to population growth, I personally
would advocate negative population growth so that we
don't have as much consumption because we wouldn't
have as many people here.
    Also,  you mentioned appropriate at some point in
some context and what I would like to address is appro-
priate  lifestyle,   appropriate  energy  consumption,
appropriate energy resource development.
    The point here in consideration  with the "goose
that laid the golden  egg" or what have  you, I ride a
motorcycle and I personally am not paid in any fashion
to be an advocate for  solar energy or public interest
advocate  or what  have  you,  so,  obviously, my
economics and  yours are probably in a  good deal  of
disparity. Once you get down to where you are driving
a very fuel-efficient car or on a motorcycle or riding a
bicycle, I will probably be on a horse. My interpretation
of the way that we are supposed to live as individuals
and in terms of why we do necessarily need an indus-
trial society really is another subject for discussion.
    At any rate, the utilization of energy resources
which are non-renewable, and I think you will accept
the fact that the earth is a finite sphere, will subside as
the marginal cost. Along that line, I would like to state
for the record that there is not enough copper to  put
enough solar collectors on everybody's house to heat
the water for the people that we have got. So there are
going to have to be decisions made and you seem to
indicate that the world population level would somehow
control itself and probably regress back to a previous'
level of population—
    DR. PATTON: I was not trying to be a clairvoyant.
I merely said the society can accommodate the chang-
ing economic conditions over a period of time and as
prices grow higher,  you can expect that people might
have fewer children which individually is the family unit,
but collectively reflects what the size of the total population
will be.
    MR. PATE: Exactly. The last thing that  I would
like to say in regards to that is that we do have limited
resources and we do have an environment to be con-
cerned with. Because, number one, the people who are
promoting  synfuels are older (which I think  most
everybody would admit does have serious environmen-
tal impacts, negative impacts), and I am going to be
around for 20, or 30, or 40 years longer than you all so
I have got to live with decisions that  DOE and  the
Federal Government are making now—
    DR. PATTON: Not on that motorcycle, you aren't.
    MR. PATE: Maybe not.  But at any rate, we do
have the environment to be concerned with and I don't
really  feel  that  environmental  considerations   are
given—it is my interpretation that they are not given any
consideration but what consideration they may have is
not significant enough for me.
    DR. REZNEK: If we can proceed. Mr. Schlesinger?
    DR.  SCHLESINGER: Thank you. Ladies and
gentlemen. Let me first say that AGA, which represents
the natural gas in this  country,  some 85 percent of
them, appreciates this opportunity to appear again  this
year at Section  11 hearings being conducted by  the
Environmental Protection Agency.
    This past year  has been a real turning point for
energy, gas energy in particular. It is significant to point
out that the National Energy Plan issued by this Admin-
istration  depicted  gas  energy  as  a  declining  and
ultimately  disappearing component  of the  nation's
energy policy, to disappear altogether by the year 2030,
I believe, if you project it onward.
    Two years later, the second National Energy Plan
depicts the exact opposite trajectory for gas, gas energy
in various forms and shows a five-quad increase at the
up end by the year 2000 in natural gas supply potential.
    These kinds of discussions are likely to continue.
We see no end to  the kinds  of considerations and I
simply want to raise with you six  issues that I think are
germane as you consider environment and conservation
in connection with energy.
                                                  44

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                                                                               Statement of Dr. Schlesinger
    First, the issue of synthetic gas from coal. Critics of
synthetic fuel programs often make the mistake of com-
paring synthetic gas with natural gas.  I have no argu-
ment that synthetic gas from coal would have to fall on
the short end of the stick environmentally speaking,
because natural gas is the cleanest major fuel we have.
But this country has  to use more and more of its vast
coal resources in some way to help reduce oil imports.
Today, 70 to 75 percent of our nation's coal is burned
to make electricity and this trend is likely to continue.
    In effect, what I  am suggesting to members of the
Panel is that we really have three choices  as a country
about what we can do with  all that coal we have, the
400 year coal supply. We can  either leave it in  the
ground, which I would submit is irresponsible. We  can
burn all  of  it, which I  think  is not  environmentally
desirable. Or we can turn some of it into usable fuel,
namely clean oil or clean gas.
    I  think  that  choice really comes down  to one
between  coal gas, coal  liquids,  and  coal electricity—
some  secondary fuel, one of those  three, produced
from coal.
    From an environmental standpoint, 1 would submit
that the superior answer is synthetic gas from coal on
every count, from every parameter one wishes to go into. I
will submit a copy of my testimony from a year ago that
I think demonstrates this point.
    In particular, I want to raise the carbon dioxide
issue because I think this is one that has not been well
understood.
    Carbon dioxide emissions from the coal gasification
cycle—considering the pile of coal through to the end-
use point as gas, versus carbon dioxide emissions from
coal electrification considering combustion  of coal, ship-
ment of electricity and that use—would produce 20 per-
cent less carbon dioxide than the equivalent level of coal
electrification. I believe that  Dr.  Gordon MacDonald's
figures fully support this  point.
    I think the question with carbon  dioxide and coal
gasification should really be one of what do we do with
the predominant source of all the carbon dioxide, even
though it is only 80 percent of the carbon  dioxide from
electrification.
    It  is interesting to note that coal gas plant, a stan-
dard size commercial scale 250 million cubic foot a day
coal gasification plant, would produce about 300,000
cubic feet per day of pure carbon dioxide,  nearly pure.
This accounts for most of carbon dioxide in that 80 per-
cent, and it  is coming out as nearly 100 percent pure
carbon dioxide,  what would be considered industrial
grade.
    At least one proposed commercial-scale coal  gas
plant has been in active discussions with  a nearby oil
producer to  sell  its carbon dioxide by-product for the
purpose of enhanced oil recovery. So that my sugges-
tion in connection with  the carbon dioxide issue is to
expand environmental research into productive uses of
this pure grade  carbon  dioxide that will be emitted,
(either vented  or  frozen  or  in  a shipped form) for
enhanced oil recovery. What environmentally compat-
ible uses can be made for this? What kind of dissipation
can be seen if this is, in fact, injected for purposes of
enhanced oil and gas recovery, primarily enhanced oil
recovery in this case?
    There is also an active CO2 chemical market. It is
the 27th largest chemical in the country. Perhaps there
are research areas that would be relevant in terms of
expanding kinds of uses for CO2  as well.
    We  also  want  to raise the issue of gas  from
unconventional and  new  technologies. Recently, the
American Gas Association published a brochure which
you may have seen entitled "New Technologies for Gas
Energy Supply and Efficient Use." It describes each of a
large variety of unconventional gas resources, each of
which could produce significant additional  amounts of
conventional and unconventional gas, natural or syn-
thetic methane, from a variety of resources way beyond
what we consider to be our domestic gas resource base,
which ranges from  700 to  1200 Tcf.
    In particular, several of these potential resources
have been associated with potential environmental dif-
ficulties. I would strongly recommend that the EPA and
Department of Energy's research  programs be strongly
enhanced in these areas;  in  particular, what are the
specific  brine   disposal issues  in  connection  with
geopressured gas that need to be  resolved? What kinds
of solutions are there? Is this also  a reinjection potential
or what?
    Right now, the Department of Energy is sponsoring
four test wells  in a resource whose total quantity may
ultimately lie somewhere  from 3,000 to 50,000 Tcf
of gas.
    Most of DOE's  effort in the past several years
(through ERDA) for this geopressured resource has had
little to do with gas. It has been attempting to make use
of the heat for geothermal electricity production. We
would submit that' the methane content of what comes
up is far more  interesting.
    Third, total energy systems. While I am aware that
EPA's research programs are very significant in the area
of production of energy from wastes in connection with
RCRA programs, I think there ought to be far greater
emphasis on total energy systems such as the produc-
tion of gas from perhaps sewage treatment plant wastes,
production of gas energy from solid waste sites (Class I
disposal sites). Inactive Class  I disposal sites alone are
estimated to contain substantial amounts of methane
that  could be used without significant  technology
breakthroughs.
    And following on that, where ought total energy
systems be emphasized? We at AGA have  recently
completed two studies that would help respond to this
particular question. I think it may come right home to
the Clean Air Act. Gas has a very significant advantage,
perhaps,  in helping  site  coal-fired boilers  or  other
facilities and helping  to abate air  quality problems and
                                                   45

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Hearing of October 3, 1979
help address the non-attainment problem that lingers
throughout the nation,  not only for particulates  and
sulfur-oxides, but for other criteria substances as well.
    Two potential solutions ought to be investigated by
the Environmental Protection Agency. For one, we
notice that in an effort to control  non-attainment  in
some urban areas, there has actually been discussion  of
shutting  down parking lots in some in-city areas. We
would submit that this is unnecessary if one were to take
a harder look at a methane automobile. By every com-
parison that one can make, even with coal gas in the
cars, there is no cheaper way to  run a car today in the
United States. Natural gas  costs about 50 cents a gallon
equivalent. A conversion for automobiles is not expen-
sive compared to the kinds of capital costs we are seeing
with the electric  car.  Total emissions—the gas auto-
mobile again  is very favorable. So rather than shutting
down parking lots, maybe  we ought  to be talking about
reconfiguring our automotive fleet, at least urban  fleet
uses in the initial stages. We note with dismay that there
is not a single research project that we are aware of that
is federally sponsored in this  area despite these advantages.
    The other area where non-attainment problems could
be addressed and additional research is required is the use
of gas in  new facilities designed to bum other fuels such  as
coal or solid wastes.
    The select use of gas in these facilities could be accom-
plished on a seasonal basis, or on an  intermittent basis, if
possible,  under the Clean Air Act, or even under situations
where part of the facility is burning the coal or solid waste
fuel and  part is burning gas, in an effort to help meet the
National  Ambient Air Quality Standards.
     Significant meteorological study is needed to prove
this concept out, and 1 think this  is an area where addi-
tional environmental research is  required.
    Another issue that we would urge upon EPA and
its R&D  programs is the acceleration of end-use device
research. This is really connected with the total energy
concept. It may  very well be that  small-scale electric
generation using gas, which produces far less pollution
and is far less socially objectionable  than either coal  or
nuclear power for electricity, may really hold significant
promise  for helping meet the future needs for electricity
in this country.
     We  suggest and recommend that additional work
be  accomplished in the area of  cogeneration systems:
small-scale,  home-size cogeneration systems perhaps
using known engine devices there are already on the
market,  we note, but have very limited deployment,
perhaps sterling cycle engines in small scale for producing
electricity and, as a by-product,  home heat.
     I  would point out to the  Panel  that of the  78
quadrillion Btu's of primary energy (quads) this country
used last year for all of its fuel use, some 17 quads were
never used, but were rejected from  the nation's power
plants as waste heat into the air and  the water. There is
a  good  reason,  unfortunately,  for  that. Most  of the
power plants that we emphasize are objectionable.
    If we could locate power plants much closer to the
people, we could begin to take advantage of their waste
heat and improve  the overall  efficiency of  electric
generation.
    Our final recommendation comes in  the area of
review and permitting processes throughout the agen-
cies. It is primarily directed towards the Department of
Energy and we will make this same suggestion in other
forums. The licensing process for new energy facilities is
woefully  long. I don't necessarily wish to comment on
whether substantive and procedural requirements of exist-
ing law be overturned. Frankly, 1 think in the case of a
number of energy facilities, neither is required. This is
my own opinion. I think that our industry would concur
strongly that an expedited process which puts important
facilities on what  you would call a "fast track" alone
would accomplish significant gain in helping to alleviate
the problems of regulatory delays, without  any change
in the law, as an appropriate first step.
    We  note that in her speech yesterday before the
Gas Men's Roundtable, Deputy Administrator Barbara
Blum emphasized that EPA has already taken steps to
put energy facility  considerations on a fast track, and we
applaud  that. We think that this approach,  perhaps,
could set a model for the Department of Energy.
    In conclusion, I think that we are going to continue
to see a reemphasis on new forms of energy supply as a
significant point in all kinds of discussions on energy
policy. Synthetic fuels is only one  area where we can
increase  our energy supply. We think that  coal gas,
among the synthetic fuels, is the obvious and preferable
synthetic fuel and almost every government report that I
have ever seen or private study bears this out.
    The capital efficiency advantages of various alter-
native gas options should definitely be explored. With
that, I  thank the  Panel for inviting AGA, again, and
would  entertain questions from anybody.
    MR. PIERCE:  I just might respond  to your last
point,  and I appreciate the specific and  constructive
presentation you made. An earlier speaker mentioned a
study in EPA's Region VIII where on the delay issue  in
permitting one of the key ingredients there  was the fact
that many times  the applicant didn't provide all the
background information and material. I feel  this is a very
productive area that maybe the government and indus-
try can work closely together on. I just wanted to get
some of  your reactions to that  point.
    DR. SCHLESINGER: I have two reactions on
that point. One, the groundrules are continually chang-
ing. Often applicants are confused as to exactly what
they are supposed to provide. This may  or may not
account  for some insufficient  applications. But more
importantly, I guess it occurs to me that it  is important
for the agencies to drive  home on  that process, make
them provide all that you think needs to be provided.
This helps separate the wheat from the  shaft. More
often than not, the serious projects for which substantial
sponsor funds have been expended have done all kinds
                                                    46

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                                                                             Statement of Dr. Schlesinger
of environmental work, baseline monitoring and signifi-
cant analysis of all sorts, and it would surprise me if
these kinds  of projects would be insufficient  in their
applications. Other kinds of projects  that are  kind of
"spur of the moment" are unable to provide this kind of
information. This helps EPA. I guess that is how I would
respond.
     MR. PIERCE: On that point, it is my understand-
ing  that the latest version of the  Energy Mobilization
Board states that before the expedited schedule com-
mences that the  applicant  must provide all of the
background  information required, so that this gain is
going to be an issue that we are going to have to both
work on very closely.
     DR. SCHLESINGER: This would be helpful as
long as all the background information that is required is
well-defined.
     MR. PIERCE:  Right.
     DR. SCHLESINGER: One  last point on that.  I
am  sorry, I don't mean to filibuster that question. It is
interesting to note that, in connection with the five coal
gas plants that have been proposed by members of our
industry  (who are in effect small guys in the energy
business}, have spent cumulatively $100 million prepar-
ing  materials and engineering designs and so forth for
five coal gas plants.  I would imagine these guys would
win the race in any filing materials context.
     MR.  SIEK:  I  am interested in  your comment
because  I am from  Colorado and we are faced  with
some synthetic fuel development out  there,  as  you
know.  We recognized that our permitting process was
really a confused process for industry to deal with, for
environmentalists to deal with, and for state and local
agencies to deal with. We have attempted to put a pro-
cess together that addresses that problem, that brings in
all levels of government early on to meet together with
the  proponent  and to try to understand from each
perspective what is required of the applicant.
     To date, we have run a pilot project on the AMAX,
Mt. Emons, project which some of you may have heard
about. It has worked out very well. I think AMAX as  a
proponent is really pushing this project as a model pro-
cess to be utilized in their projects throughout the coun-
try and the world. Certainly local government has been
very receptive to it. The state agencies, I think to an
agency, are very supportive and the federal agencies to
date have cooperated and feel that it is a step in the right
direction to coordinating environmental permit reviews.
     We  will have that project out. I mentioned this
morning it is being funded by DOE. I think DOE sees  it
as a possible model for energy and  mineral resource
development throughout the country.  We will have that
finished sometime in December or January in Colorado
and implemented.
     So I think working with the oil shale industry there
and the other mineral development industries there get-
ting their support, it seems like this  is a process that
probably has a lot of possibility throughout the country
and may address some of the problems that you are
concerned with.
    DR. SCHLESINGER: I would like to find out
more about that project. We at AGA are now studying
the institutional barriers to solid waste methane recovery
projects and we  are finding there that no one  knows
who ought to be "the applicant" let alone, when an
applicant has been decided upon, what he has got to
come up with. There are so many parties to it: there are
the utility,  the  state  and  local government,  the
municipality, the Federal Government, various Federal
Government programs, DOE, EPA, public utility com-
missions. There is just a real need for a series of model
methane projects.
    MR. SIEK: I think an oil shale project in Colorado,
a demonstration project, that is now being constructed,
went through  over 70 permits to start operation and
over a period of about two or three years to obtain those
permits. That is not unusual, 1 don't think. I think what
is required of oil shale industry certainly is going to be
required of coal gasification development. All of these
things need to be coordinated. It is costing millions of
dollars for duplication and  confusion and delays and
that is the intent of this process which will be available,
again, in December in manual form with all the permits
laid out, how you can jointly hold public hearings, and
how the timeframe for each permit can be coordinated.
    DR. SCHLESINGER: I would really like to see that.
    DR. REZNEK: I  would like to return to some of
your comments. You imply very strongly that research,
Federal supports R&D,  in  the gas  area  is  under-
represented in the current program and this year rather
than deal with what is underrepresented and what is
overrepresented, I would  like to concentrate a little bit
on the process.
    You indicated that the  underrepresentation in the
Federal slate of R&D support is basically not in the pro-
duction end of R&D but in the R&D that  would be
necessary to find new end-uses and substitute  gas,
methane presumably  generated out of coal,  as the
substitute use. You mentioned methane-powered cars
and a few others.
    Why does the system, or would you care to com-
ment on why the system of deciding how to allocate the
Federal research dollar overlooked these resources and
are there ways of modifying the allocation of research
monies to make a better balance in your opinion rather
than support the program you advocate?
    DR. SCHLESINGER: I appreciate your  asking
that because we have  done considerable study  on this
point. First of all, Steve,  I really think that the  under-
representation of gas energy and the gas option is com-
plete across the board. It is not particularly confined to
end-uses.
                                                   47

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Hearing of October 3, 1979
    In the supply programs alone of the Department of
Energy, gas-related R&D accounts for some eight per-
cent  of  the 1980  budget.  Electricity-related  R&D
accounts for 78 percent of the budget. That is in the
energy  supply  budget. Some figures  on  that are
available and I can provide our studies on it.
    In the total R&D budget of the  Department  of
Energy—that brings some $2 billion dollars up to about
$3 billion including supply and end-use  (which is not
very much to add to the whole other demand side of the
equation)—the ratio  is about 8% to 78%,  about the
same  ratio. So I think there is particular bias against gas
in both the supply and demand areas.
    By the way, in the entire DOE budget, it may inter-
est you to know, gas-related work altogether accounts
for some three percent of DOE's  budget in FY 80,
whereas electricity is about 50 percent.  We understand
others have attempted the same thing roughly and got
quite  similar kinds of answers.
    As to why this has happened, I think it is pretty
obvious.  Gas was kind of considered to be a  dying
issue. I can recall when I joined the American Gas
Association, my first question was: is there going to be
an AGA in a couple of years? What are  we bothering
with an AGA for?
    The very opposite is the case. With all of the prob-
lems other fuels are having—nuclear, coal combustion,
and others—I don't think there is any question that gas
is going  to be here  for a long time,  including in  its
renewable forms. So that I think is why this underrepre-
sentation occurred—no one  really  cared about a gas
automobile, the job was to get out an electric automobile.
    I have had  discussions on this  point  with the
Department of Energy, and I think the only way  to
change them is to create an awareness of the oppor-
tunities for gas supplies beyond just the  conventional
resources, including renewable sources of methane  as
part of a solar/renewable-resource future, and then we
can begin to talk in terms of gas-related R&D, and other
primary fuels as well.  Oil,  interestingly enough,  is
similarly underrepresented in the RD&D budgets.
    DR. REZNEK: Let me pursue the question  of
whether  the  only way to do that is to arouse the
awareness of certain of my fellow bureaucrats although
in a different agency. The question of inter-fuel com-
petition and displacement of conventional markets that
one fuel had, displacement of that fuel out of that
market and by another, has been a difficult subject for
the government for a long time, since World War 11, and
various administrations have adopted various policies
some of which border on the simplistic of being unaware
or trying  to shut off certain issues.
    Is there an approach, an analytical  and objective
approach to examining that question of trying to set a
policy of where we think various fuels may move forward
and various fuels may contract?
    DR. SCHLESINGER: I would recommend to the
Panel that a recently published report by the Mellon
Institute, entitled, "The Least Cost Energy Strategy," be
studied thoroughly.
    The Mellon Institute's Energy Productivity Center,
directed by Roger Sant, formerly the Assistant Adminis-
trator of FEA  for Environment and Conservation,  is
undertaking a  $4 million study funded jointly by the
Department of Energy and a number of private indus-
tries including, I am happy to say, the American Gas
Association and the Gas Research Institute.
    This study is  aimed at investigating a completely
new way of looking at the interfuel competition issue;
namely, the approach called  "energy  service."  The
premise is that an energy service is what people require.
For example, people want a warm house; they are,  in
effect, neutral as to whether this heat comes from gas,
oil heat, electricity, and so forth. The same holds true
for industrial energy services.
    Thus, separating energy use into its service sectors,
the Mellon Institute people have taken another look  at
the 78-quad economy that the U.S.  had last year and
have concluded in their preliminary study that this could
have been a 59-quad economy if the least-cost use  of
energy  had  been  made,  at  some  huge savings  to
consumers.
    Interfuel competition was only part  of the study;
conservation approaches were examined as if they were
a fuel as well.  Naturally, since many of them are not
very expensive,  conservation gained  a  substantial
portion of traditional energy markets.
    Oil use would have decreased by 30 percent in this
country  and electricity use would have been only about
half of what it actually  was,  if the  least-cost energy
strategy  had  been  followed.  Gas  use  would  have
increased slightly,  or would have  been higher than
it was.
    EPRI, the Electric Power Research Institute, is a
major funder of the Mellon Institute study. I don't think
that AGA's involvement had anything to do with the
rather surprising  conclusion that Sant's preliminary
study came up with. But that is the best analytic exam-
ination I have seen yet to the interfuel competition
question because it really breaks apart the whole fuel
question into its components. What  are the demands
for energy?
    AGA has also done  a study looking just at the gas
side  as  to  what the actual demand, the  economic
demand, for gas is in industry, homes, and so forth,
based on present  usage systems. We found that the
actual economic demand for gas is high and rising, and
will increase some 25 to 28 Tcf nationwide by the year
1990. Incidentally, that excludes power plant demand;
we just assume that declines.
    DR. REZNEK: Although I realize you  weren't
here, we heard some tantalizing testimony this morning
that said that in fundamental resource allocation process
                                                  48

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                                                                                  Statement of Ms. Jones
inside of DOE that it should be structured on issues,
issues quite similar to how do you heat houses and
where  do you  find  the substitute  to  heat  houses.  1
assume the  Carnegie study that you referenced takes
that kind of look and approaches  it across fuels and
across conservation.
     DR. SCHLESINGER: That is correct. Fuels per
se don't enter into their initial investigation. The investi-
gation  simply examines the energy uses in buildings
considering  some, I  think,  9 or 12 different kinds of
energy use in buildings  (homes,  factories, and some
industrial uses).  So  they break apart the traditional
energy sectors,  and industries. One  portion of the
study, is devoted to buildings and another is devoted to
industries. There are some  23 kinds of energy use in
industries that were considered.
     In terms of the resource allocation process being
devoted toward fuel issues,  I think there needs to be a
more structured  approach to resource allocation than
simply an examination of specific problems as they arise.
    DR. REZNEK:  The issues are how do you heat
homes  and then you begin to pull that  one apart.
     DR. SCHLESINGER: We are saying the same
thing: energy services, energy uses.
     DR. REZNEK: Your energy services and the sug-
gestion this morning have some notes in common. Any
other questions?
     (No response)
     DR. REZNEK: We have one  remaining witness,
Jo Jones.
     MR. PATE: Could 1 ask one question?
     DR. REZNEK: Certainly.
     MR. PATE: I understood in the prehearing docu-
ment that there was supposed to be a public interest
representative on the Panel. I don't  see that person
listed here.
     DR. REZNEK: We have tomorrow, Zack Willey,
and we have on Friday Tom Kimball.
     MR. PATE: Oh, there just wasn't anybody — that
was the question.
     DR. REZNEK: Ms. Jones?
     MS. JONES: I am Jo Jones and I am representing
the Georgia Clean Water Coalition. 1 often have prob-
lems with my Southern  accent being heard or under-
stood sometimes especially  so with  a little competition
from this noise on the side.
     I want to thank EPA for inviting me here today to
express our views. As an active volunteer environmen-
talist, I have for the past 10 years watched the citizen-
agency relationships evolve from one  of being locked
out of local, State, and Federal agency decisionmaking
to various levels of involvement and participation.
     Some agencies, such as EPA, have made commit-
ments  at  top management levels to institutionalize
public participation in the earliest stages of planning and
development of projects realizing  that it offers major
benefits to agencies in  expediting  valid projects and
working out "bugs" and if carried out honestly can lead
to public acceptance and support of projects. If not, the
public will often fight to delay or stop projects.
    Even so, public participation  in agency decision-
making is still in its infancy. Basically, DOE is an agency
which  is very  young and does  not  seem  to  have
matured in its understanding of the public needs and
reactions as EPA has.
    It was a great disappointment to learn  that DOE's
attitude seems to be similar to that  of DOT,  except that
at least DOT is now paying lip service to  public par-
ticipation but with as yet no honest commitment to it.
    In such agencies we find that the general attitude is
that the public is a bunch of naive amateurs and that the
agency  professionals  are  the  only ones with the
knowledge and ability to deal with the issues.
    This attitude, which seems to have manifest itself in
DOE, is a  grave error and is unacceptable. If it con-
tinues,  DOE will find  its programs stymied and its
credibility destroyed.
    DOE'S research and developement work is of major
importance to America's future. The public cannot be
fooled and will not accept lip service or sham public par-
ticipation programs.  There must be a commitment from
the top and a commitment at all levels to  involve the
public at the earliest stages in its processes.
    The public does have  important contributions to
make and  can  play an important role in  helping to
shape DOE's programs in a publicly acceptable manner.
    DOE's national advisory committees  which are
heavily dominated by industry are  unacceptable.  DOE
must establish mechanisms to  effectively inform  and
meaningfully involve the public in its decisionmaking
processes.
    We recommend that they look to EPA for leader-
ship  in  this area—specifically,  the 208 water quality
planning process and the transportation-air quality plan-
ning process—to improve on the effectiveness of these
procedures, undertake citizen participation demonstra-
tions immediately, and prepare a plan of action. All of
this can, if DOE wants to, be completed within the next
year. Their success in this undertaking will be a measure
of DOE's commitment to the public's interest.
    I would like to digress for a few moments from my
prepared statement and go to the subject of the hearing,
the official subject of the hearing, which was "adequacy
of attention to  environmental protection and energy
conservation, use of technical  and scientific  informa-
tion, decisionmaking, communication of rationale for
technology development,  integration  of technology
development and environmental research planning."
    Without adequate  public participation, it is very
difficult for the public to be able to  understand these
processes upon which we are supposed to be commenting.
Apparently it has been very difficult  for the public to get
documents, to be able to understand the documents, to get
them before decisions were made, and I feel that it is very
                                                  49

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Hearing of October 3, 1979
difficult to comment on the more technical aspects when
you have not had the kind of ongoing information all during
the process in which  the public  could have affected the
process and which would have given the public a lot more
information than they  were able to understand.
    The other comment that I would like to make is that it
was a great disappointment to many of us that solar was not
included in this evaluation because ! think that it needs that
visibility and  it is important that the Congress know that
DOE is evaluating solar in the same way that it is evaluating
the other technologies  which  are   being  considered,
evaluated, and so on.
    DR. REZNEK: Thank you. Are there questions?
    (No response)
    DR. REZNEK:  I would like to ask a few questions.
How  do you measure  the  effectiveness  of the public
participation?
    MS. JONES: It is difficult,  and, as I said, it is in its
infancy and I have certainly participated in building public
participation and I have personally been locked out of agen-
cies before we had public participation. I find  many more
doors opening. I feel that one way of evaluating public par-
ticipation is by asking the public if they  are satisfied with it.
    There are many people,  many of us who  are
grouped into the category of being environmentalists of
public interest groups who  have a  lot  of  knowledge
about the specific issues and who are, as I said in my
statement, not included in the decisionmaking process
but yet who can often shape or guide projects in a direc-
tion that may be somewhat different than that that
would be taken by the technical people but which are
still valid and which  will make  a project more publicly
acceptable.
    I think it is a matter of asking the public whether or
not they feel that the public participation opportunities
have  been adequate. If they say they haven't, then I
think that that offers your evaluation. That could be
done by sending out questionnaires to the publics that
you have on your list or various ways of asking the
public if they feel  in general that the participation has
been adequate.
    DR. REZNEK: We heard a little earlier from Mr.
Moss who has had a long history in terms  of advisory
groups and external  input into  public agency decision-
making processes and he expressed a feeling that even
when very successful that the members of the advisory
groups feel  a certain sense of frustration in terms of
knowing that their ability to impact the process, and you
seem to believe that  the active  public participation and
the translation of the ideas and the understanding that
the decision-making was  done in an open forum, is
important in  itself.
     MS. JONES:  Yes,  I  do because  I  have been
involved with agencies that officially and formally had
public participation but which did not believe in public
participation and which lived up to the letter of the
regulation but yet have walked all over the citizens who
were  supposed to be participating  and stymied their
efforts to the best of their ability. It is extremely frustrat-
ing and it defeats the entire purpose because the agency
then does not have the value of the  input that they are
requiring so that this same frustrated public is not going
to shoot down their projects when the time comes to
build them or to implement whatever the agency wants.
    I think that if the public were sure that the agency
had listened to and carefully considered their input and
could give rational reasons  if they did not follow the
recommendations, I think the public would be far more
satisfied, but I think it is very important to answer and to
give rational reasons in writing if you  do not accept what
is recommended by the public.
    DR. REZNEK: You mentioned our 208 program.
One of the concerns that I have in public participation is
a question of what is the integrated  federal role versus
project-by-project and local public  participation on a
single project.
    Do you feel that "beat levels of government or local
organizations such as 208 agencies have an inherent
advantage in  the public participation  process over
Washington-based organizations?
    MS. JONES: I am on and have been, I have been
vice  chairman of the  208 Advisory Committee for a
couple of years on a regional planning commission and
I have served on a technical task force, 208 technical
task  force as Chairman of  the Georgia  Clean Water
Coalition, I have representatives on  each of the State's
technical task forces,  208 technical task forces. So  I
have  had a lot of experience with this. I feel that it
depends on the  commitment of the State  and local
agencies. As I said, it has a long way to go.  EPA has
attempted to set up regulations but until there  is a
commitment from the local government, then there are
going to be efforts to get around it, to live up to the letter
of the regulations—to do what is required in the regula-
tions  but yet to totally  defeat the  purpose of public
participation.  It is a battle that is being fought all over
the country.
    I feel that they {public participation regulations)
offer hope if EPA is willing to stand  behind its commit-
ment to  public participation. I feel in a sense that the
input into local levels is very important and that it should
be required but yet I feel that EPA should be stronger in
standing behind the citizens when the  intent  of the
public participation is abused by local agencies.
    I think that it has to be looked at on a case-by-case
basis. I think in some areas people are very satisfied with
their public participation. It is a matter of convincing the
agencies that it is to their best interest. DOE is a lot fur-
ther behind than EPA, and EPA is still learning and will
continue  to  learn for  a while  because the public
participation, formalized public participation is so new.
                                                    50

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                                                                             Statement of Ms. Jones
    DR. REZNEK: Thank you. If there are no other
questions, we will adjourn to 9:00 o'clock tomorrow
morning.
    (Whereupon,  at  4:30  p.m.,  on  Wednesday,
October 3, 1979, the hearing adjourned to reconvene
at 9:00 a.m. on the following day.)
                                               51

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October 4,  1979
Panel:

DR. STEVEN REZNEK, Deputy Assistant Administrator
    for Environmental Engineering and Technology, Environmental Protection Agency

ROY GAMSE, Deputy Assistant Administrator
    Planning and Management, for Environmental Protection Agency

ALAN MERSON, University of Denver

DR. JAMES MacKENZIE, Council on Environmental Quality

ED GRISHAM, New Mexico Energy and Minerals Department

DR. ZACK WILLEY, Environmental Defense Fund

DERRY ALLEN, Policy Planning Division, Environmental Protection Agency
                                      53

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Contents
MORNING SESSION
  PAGE
PAGE
    57  Opening remarks, DR. REZNEK

    57  Statement of DR. CHESTER RICHMOND
           Oak Ridge National Laboratory
           Questions and remarks
              60 DR. REZNEK
              60 MR. MERSON
              61 MR. MERSON
              61 DR. MacKENZIE
              62 DR. REZNEK
              62 DR. WILLEY

    62  Statement of DR. KENNETH BRIDBORD
           National Institute for Occupational Safety
             and Health
           Questions and remarks
              64 MR. GAMSE
              64 MR. MERSON
              65 MR. MERSON
              65 DR. RICHMOND
              65 DR. WILLEY
              65 DR. REZNEK
              66 DR. REZNEK
   67  Statement of DR. RALPH PERHAC
          Electric Power Research Institute
          Questions and remarks
             69 MR. GRISHAM
             70 MR. GRISHAM
             70 DR. MacKENZIE
             70 DR. WILLEY
             71 DR. WILLEY
             71 MR. GAMSE
             71 MR. GRISHAM
             72 DR. WILLEY
             72 DR. REZNEK
             73 DR. REZNEK
   73  Statement of MR. MICHAEL PAPARIAN
         California Sierra Club
         Questions and remarks
             76  DR. MacKENZIE
             76  DR. WILLEY
             77  MR. MERSON
             77  MR. GRISHAM
             77  DR. REZNEK
             78  DR. REZNEK
                                      54

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Contents  (Continued)
AFTERNOON SESSION
  PAGE
PAGE
    79  Statement of MR. BOB REYNOLDS
           Lake County Air Pollution Control District in
            California
           Questions and remarks
              80 MR. MERSON
              81 MR. MERSON
              81 DR. REZNEK
              81 MR. GRISHAM
              82 DR. WILLEY
              82 DR. REZNEK
              83 DR. MacKENZlE
              83 DR. REZNEK
              83 DR. WILLEY
              84 DR. WILLEY

    84  Statement of MS. JANE MacGREGOR
           Atlanta League of Women Voters
           Questions and remarks
              85 MR. GRISHAM
              85 DR. REZNEK

    86  Statement of MR. RICHARD PRATT
           Pennsylvania Sierra Club
           Questions and remarks
              87 DR. WILLEY
              87 DR. REZNEK
              88 DR. REZNEK
              88 DR. WILLEY
              88 MR. MERSON
              89 MR. MERSON
              89 DR. REZNEK
              89 MS. MacGREGOR
  89  Statement of MR. SCOTT CRYTSER
         Pennsylvania Gasohol Commission
         Questions and remarks
            91 DR. REZNEK
            92 DR. REZNEK
            92 DR. WILLEY
            93 DR. REZNEK

  93  Statement of MS. PATRICIA PELKOFER
         Group Against Smog and Pollution
         Questions and remarks
            95 MR. MERSON
            96 MR. MERSON
            96 DR. REZNEK
            96 MR. GRISHAM
         Adjournment
                                     55

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Proceedings
                                                                              Statement of Dr. Richmond
9:08 a.m.
    DR. REZNEK: Good morning. My name is Steve
Reznek. I'd like to welcome you to the second day of the
hearing under Section  11 of the Nonnuclear  Energy
Research and Development Act on the relative empha-
sis  given  to environmental protection  and  energy
conservation.
    Yesterday we heard from a very interesting slate of
witnesses. Kevin Markey  testified on an approach  to
decisionmaking to take account of questions of  energy
conservation/environmental  protection  which  would
examine the energy problems  on a source utilization
basis; that is, as in home heating—and look at trade-offs
between environmental impacts of various approaches,
including conservation,  liquid fuels, gaseous fuels  or
electricity.
    Doctor Gordon McDonald talked  about ways of
quantifying the  environmental  problems of alternative
approaches to using a coal resource, for example, and to
doing comparisons, formal comparisons between alter-
native  technologies. He also testified  at some length
about global energy problems and comparisons of fuel
cycles  in terms of their  impact on  global problems.
    This morning we are  pleased to have a new panel
with us. Sitting at the end of the table is Doctor James
MacKenzie of the Council on Environmental Quality. Sit-
ting next to him is Doctor Zack Willey of the Environ-
mental Defense Fund from California. Next to him will be
Ed  Grisham (who hasn't sat down yet)  of New  Mexico
Energy and  Minerals Department; next to  him  is Alan
Merson from the  University of  Denver, formerly from
EPA, I might add. Next to me is Doctor Roy Gamse of
the Planning and Management in EPA.
    As you know, this year we tried to approach Section
11  responsibility in a slightly different manner than has
happened before.  Rather than examine the DOE budget
in terms of its allocations between energy technologies or
between the different fuels,  we  examined the decision-
making processes that have been used inside the  Depart-
ment of Energy which generated those allocations. We
are encouraging the witnesses during these three days to
comment specifically on the decisionmaking process and
how that process might improve—be changed to im-
prove  the relative emphasis given to these two con-
cerns— energy  conservation  and   environmental
protection.
    The first witness this morning is  Doctor  Chester
Richmond of the Oak Ridge National Laboratory.
    Ches?

Presentation by Doctor Chester Richmond
Oak Ridge National Laboratory

    DR. RICHMOND: Thank you. Mr. Chairman,
panel members,  ladies and gentlemen. My name is
Chester  R.  Richmond. I'm  Associate  Director for
Biomedical  and  Environmental  Sciences at the Oak
Ridge National Laboratory.
    During the past several years I have participated in
the planning, organizing, and implementing aspects of an
integrated multidisciplinary life sciences program in sup-
port of synthetic fossil fuels. My view this morning will be
from a research management position with emphasis on
synthetic fuels.
    I welcome the opportunity to testify at these  hear-
ings.  The  timing, I believe,  is extremely important
because Secretary Duncan is in the process of restructur-
ing the Department of Energy. His predecessor organized
DOE according to technical readiness and these hearings
are addressing the linkage of environmental issues and
research to a technology as it  progresses from  early
research to  commercialization.
    The evolving DOE organizational structure now ap-
pears to be a hybrid of the Schlesinger DOE and the
Energy  Research  and Development  Administration.
Therefore, the questions being asked via the Section 11
review may provide useful input to DOE on a subject of
environmental evaluation.
    I'll  now discuss the issues that have been raised as
part of  this Section  11 review. The background docu-
ment for these hearings clearly states that the develop-
ment of an energy technology as it progresses from its
early research stages through commercialization requires
that associated environmental concerns be addressed at
three  levels. Specifically, there are site-specific concerns,
regional or  cumulative impacts, and national concerns.
    These  are all valid and very important, but in my
opinion, need to be broadened even more to  include
global aspects. I recently discussed this situation relative
to the carbon dioxide as a global concern as  part of
testimony presented to the House Committee on Science
and Technology  hearings on synthetic fuels.
    I would argue that environmental and health con-
siderations cover a span from site-specific to those that
                                                  57

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Hearing of October 4, 1979
are truly global in nature. One might also look to the acid
rain problem as another indication of growing interest in
regional concerns.
    1 strongly endorse President Carter's recent directive
that a ten-year comprehensive acid rain assessment pro-
gram be undertaken and managed by a standing Acid
Rain  Coordinating Committee.  The  comprehensive
research plan is scheduled to be completed by the end of
this year.
    The above discussion points out the complexity of
the situation. It is clear that there is a requirement for
much  coordination and integration of  our nation's
resources as we attempt to develop  energy-generating
systems to supply our needs with minimum stress on our
environment and the health of our citizens.
    We must also include the internal environment of an
energy-generating facility which brings us into the impor-
tant area of worker protection, health and safety. This re-
quires the input of  still other State and Federal agencies
as  well  as 'additional  research   and  development
components.
    I am, however, generally optimistic that we can, at
least in the R&D area that addresses health, safety, and
environmental concerns, combine the resources and
talent of various Federal agencies, such as EPA, DOE,
and others, and private organizations, such as EPRI and
the private  community, business community, to  max-
imize the chances that we can indeed produce systems
that wilt provide more benefit than stress to society.
    Obviously, this demands a great deal of planning
and coordination. It is difficult and requires much atten-
tion. However,  I  believe we are  learning in the life
sciences to work more efficiently in  this mode.
    I think an  excellent example is the current activity of
the University  of  Minnesota-Duluth low  Btu gasifier
which is part of the Department of Energy's Gasifier in In-
dustry  Program. Figure 1 in my submitted  testimony
shows  the many contributors to  this particular activity
where an existing gasifier and heating plant is being con-
verted to burn low-Btu gas produced by coal gasification.
The  three ton-per-hour demonstration  plant  is jointly
funded by DOE and the University of Minnesota.
    An environmental advisory committee, comprised
of DOE, EPA and NfOSH, provides important guidance
to this program.  It involves both the environmental and
the technological side  of the Department of Energy,
many components of the Oak Ridge National Laboratory
and other organizations, but more importantly, the local
departments and the physical plants and health and
safety components  of the University.
    Another point is  we must appreciate that many of
the individuals  involved in  the health,  safety,  and
environmental studies related to energy are in much de-
mand because of concerns related to the use of industrial
chemicals, foods, drugs, and other  materials by society.
    Federal legislation such as TOSCA, RCRA, and
others place strong demands on the life sciences research
community. I understand there are now about two dozen
laws on toxic substances alone.
     Cost should not be the only factor that determines
whether a project is reviewed by the DOE Program and
Project  Management  System.  Other  factors  such as
uniqueness of an environmental or health consideration
in kind, location or time, need to be  considered. The
potentiality of a system also needs to be addressed.
     For example, small systems that may be duplicated
many times as part of a larger commercialization effort
may demand specific attention. One might also need to
pay attention to the review of small projects at sites where
the availability of certain resources may be limiting.
     I think perhaps the DOE Gasifier in Industry Pro-
gram I mentioned earlier is an example of how effective
management systems can be designed to incorporate the
health,  safety  and  environmental  considerations into
small demonstration projects.
     Environmental  research planning even  for  small
projects such as the gasifier I mentioned is  difficult. Com-
mitments must be made to many organizations and they
span three or more years. This planning has been difficult
to implement; however, I believe progress is being made
by the Department  of Energy's Office of Environment
which conducts the research and development related to
such demonstration facilities.
     Greater efficiencies would be realized,  however, if
multiyear commitments could be made by both the tech-
nology office in question and the Office of Environment.
     The DOE Office of Environment funds both generic
environmental, health, and site-specific research at many
locations, including laboratories and universities around
the country. This core program should not be allowed to
erode  as  the  requirements   for site-specific  studies
increase.
     The Department of Energy, I believe, should coor-
dinate its funding sources so that both site-specific, which
are extremely important, and generic work can both be
pursued. We must remember that answers to the regional
and global concerns most probably will arise from the
generic research conducted as part of the core programs
at various laboratories.
     These core programs provide  the bridge between
the identification and planning, the EDP's and the PEP's,
and the assessment functions, such as the  environmental
readiness  documents, the environmental assessments,
and the  impact statements;  however,  the  generic
research provides for continuity, institutional balance and
strong scientific input. It bridges the planning and  the
assessment functions. It  must not be allowed to be
transformed solely into site-specific activity.
     As pointed out in the background document pro-
vided for  this  hearing, the Department of  Energy has
relied  heavily  on  several   criteria when  evaluating
environmental concerns—reviews, excuse me.
     Although the criteria could be made more explicit it
may be important,  in the final analysis, to  make them
                                                   58

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                                                                                Statement of Dr. Richmond
broader. For example, more information must be ob-
tained on the kinds and quantities of potentially harmful
mutagenic and carcinogenic chemicals in various process
and product streams.
    At the same time, control technologies designed to
remove or ameliorate these chemical classes,  such as
basic  nitrogen-containing polycyclic hydrocarbons pro-
duced by some coal conversion processes, need to be
developed.
    Attention must be directed towards classes of com-
pounds and materials for which environmental or work
place standards have not yet been developed.
    President Carter called for the  Department  of
Energy  and the Environmental  Protection  Agency to
develop  procedures  for  establishing  environmental
protection  standards  for   all   new  energy—coal—
technologies.
    I don't believe that any new standards have been
developed  to date; however,  I  understand  a  draft
memorandum of understanding between  DOE and EPA
on  Coordinating Procedures for Establishing Environ-
mental Protection Standards for  Emerging Nonnuclear
Energy Technologies now exists.
    Whatever criteria for evaluation develop, it is most
important that the entire fuel cycle be considered. Atten-
tion to the integrated cycle rather than  any one compo-
nent provides a broader perspective on potential regional
or global considerations  in addition to  those  that are
more site-specific.
    Also, we will  need such broad-based information
when comparing the benefit or detriment  to society from
competing processes. We must ultimately face squarely
the issue of competing and the minimum risk for energy-
producing processes.
    There are many questions about the proper role of
the DOE and the Federal Government  in determining
environmental protection standards and policies. The
trend  is toward more active participation by  State and
local  governments. The Resource Conservation and
Recovery Act of 1976 is an example of a Federal initia-
tive in this regard.
    I believe that many—excuse me—I believe that non-
Federal levels of government will become the foci of deci-
sions  on environmental trade-offs among energy policy
alternatives. Harmony between energy development and
regional concerns will be  largely defined  at the  regional
level with the Federal Government defining the bound-
aries of acceptability, offering incentives for actions and
decisions that are in the national interest and in helping to
resolve conflicts that arise between States and regions
whose actions and  decisions affect one another.
    The extent to  which the DOE's Office of Environ-
ment affects policy development is not clear. It would ap-
pear that the input to policy development is relatively
minor as compared with input of a supporting or ad-
visory nature.
     I believe there must be a strong input to technology
development from the life sciences disciplines. Further-
more,  this interaction must begin early in the develop-
ment of the technology  and continue throughout the
pilot and demonstration stages. There should be equal
authority and responsibility.
     Two major kinds of research and development must
be supported by the Office of Environment in collabora-
tion, wherever possible,  with other agencies. These are
generic and site-specific studies.
     This problem raises still  another question. That is,
which  Federal agencies  should provide support to the
generic studies  which  include analytical  chemistry,
biology,  environmental  sciences,  physics, and  instru-
mentation development  as well as activities in the  soft
sciences, such as sociology and economics?
     A possible solution to this problem would involve a
transfer of financial support from the DOE technology of-
fices to the environmental area for site-specific  related
work. I am very pleased that EPA and other agencies are
contributing to valuable program funding through pass-
through funds and other mechanisms to assist in support-
ing these important health and environmental studies, in-
cluding site-specific work.
     This action will ultimately conserve the ASEV fund-
ing for support of generic research which is not, for all
practical purposes, supported by other agencies.
     DOE can pursue two major paths towards the dem-
onstration of technologies that  are economically prac-
tical, technically feasible,  and environmentally accepta-
ble. I believe DOE can demonstrate on  a small-scale that
it is feasible for a technology to operate before commer-
cial development.
     In addition, I believe it would be useful to build ex-
perimental facilities to use as working laboratories to
refine the technology, to characterize  the process and
product streams,  to  establish the  health and environ-
mental impacts and  to develop environmental control
technologies.
     The hearing background materials provided us sug-
gest  that this would not be the case and that the inte-
grated approach would result in a design of experimental
facilities.
     Furthermore, I suspect that the integrated approach
may  be the most efficient way to ensure that the resultant
facility  is  acceptable environmentally. Hopefully, this
integrated approach  would  allow for  important feed-
back between the development engineers and the  life
scientists.
     In conclusion, I would like to touch on a subject of
assessment studies.  Basically these are important and
serve many useful purposes. However, we should not
get into the position where an assessment study is simply
a mechanism to avoid making a decision or taking an
action.
                                                    59

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Hearing of October 4, 1979
    Very often one assessment leads to one or more
assessments. I  am reminded of the Sorcerer's Appren-
tice. We have learned how to do something but it is not
clear that we know how to turn the system off.
    We must be careful that the shift from doing science
to doing paper studies is not done to the extent where it
adversely impacts the science.
    Thank you.
    DR. REZNEK: Thank you, Doctor Richmond.
    Are there  any  questions?
    (No response.)
    DR. REZNEK: I  have—maybe I'll start with some
questions. I have a couple of areas that I want to ask
about. Do you feel that the state of the art is such that you
could do a comparative risk in a particular area, say, car-
cinogenicity between competing technologies; for exam-
ple, two competing low Btu gasification technologies? Do
you feel that that is practical and possible? And if fairly
standard  protocols  could be adopted and implemented
for doing those evaluations and allowing an environmen-
tal  impact or in this case, a carcinogenic  risk  impact
analysis between the two?
    DR. RICHMOND:  That's a very involved ques-
tion, but I think the short answer is that any such assess-
ment  conducted today would not be precise enough, I
think, to be of great use. We need more experience. For
example, if we return to the example I used of low-Btu
gasifier program, we need to accumulate more informa-
tion on several [gasifiers] to get important base-line data.
    The kinds of information we have been able to ob-
tain throughout national programs suggests, however,
that there are  classes of  compounds associated with—
generically, with coal conversion, whether it's gasification
or liquefaction.
    We can make broad statements such as the nitrogen-
containing  polycyclic  hydrocarbons appear to  be the
compounds that are most hazardous to man. There are
ways of altering the process to eliminate these materials,
but the mix of these materials will  vary  among the
processes.
    So to do  what you're suggesting will take  much
more characterization and much more knowledge. But
ultimately,  I believe  we  must  do these comparative
studies.
    DR. REZNEK: At any level, for example, emission
of criteria pollutants, sulphur dioxide or sulphur com-
pounds,  are there any  methods  available that  would
allow a comparative environmental impact of competing
technology?
    DR. RICHMOND: I think in terms of the available
information, it's relatively easier to look at the emissions
of—for example, particulates; the relative amount of coal
required for a given process to produce, say, a unit of oil
or  whatever; the amount of emissions CO for example,
or sulphur—1 think that kind of a comparison is relatively
easier than the one you mentioned earlier, looking at the
carcinogenicity.
    In the latter case, we're talking about  identifying
classes of chemicals from among tens of thousands of
chemicals that are related to the process.
    DR. REZNEK: Would you recommend the. stan-
dard protocol for collecting this information, as I say in a
standard protocol fashion for submissions to the deci-
sionmaking process on whether or not to go with a par-
ticular  technology  or  to  compare  alternative
technologies?
    DR. RICHMOND: Yes, I think that's critically im-
portant. Perhaps I can give you an example. There has
been established, again through DOE and EPA funding,
a  repository  for  chemicals  for  use by investigators
throughout the country.
    I guess the most recent example I can point to is the
use of oil produced from shale from the western part of
the country. The samples that are made available are well
characterized so that everyone is using the same material.
By "everyone" I mean the environmental scientists and
the biological  scientists.
    It's also widespread in that there are many universi-
ties and, in fact, contractors for several agencies who are
using these materials.  So it's important to have  a com-
mon base line,  well characterized materials everyone is
using so that it will help minimize  the introduction of
error and perhaps confusion. Because we must remem-
ber that one talks glibly about producing oil from shale,
but you produce a  crude product  and then many things
can be done  to that product through further treatment
and  you end up with many classes of material which
must be studied.
    DR. REZNEK: You've also commented on experi-
mental facilities  to  make available to explore in  a fairly
rigorous way the environmental problems in performing
environmental assessment. Do you feel those facilities
exist now and there's a systematic approach to looking at
the environmental  problems, particularly in a compara-
tive manner from one  facility to another?
    DR.  RICHMOND: I think that's  evolving very
rapidly. I again will return to the one example, either the
low-Btu gasifier at  the University  of Minnesota-Duluth.
There's a similar project within the same program at Pike
County which involves a municipality, actually.  So that
information will  be gained at two low-Btu gasifiers. There
are also activities related to H-coal process and several
other developing processes. SRC, for example.
     So in time, there will be an opportunity to have data
collected during the development of various processes
which hopefully will allow some intercomparison and
cost comparisons to be made.
     MR.MERSON: Mr. Chairman?
     DR. REZNEK: Mr. Merson?
    MR.  MERSON:  Doctor Richmond, at the outset
you  suggested  that perhaps global considerations or
global concerns were overlooked or at least not given the
emphasis  that  local,  regional  and  national concerns
receive. I am very much intrigued by that idea and I'd like
                                                    60

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                                                                                Statement of Dr. Richmond
to get some of your  thinking about the institutional
framework that you think might evolve in representing
those global or international concerns. I think we do have
some devices. I think you suggested in the health and
safety area the kind of intergovernmental cooperation
that can take place.
    What do you see as a way for having DOE include
some of these broader  global concerns in the decision-
making process?
    DR. RICHMOND: That's a very important ques-
tion. Much of what will happen as we continue, not just
industrialization-commercialization of energy related ac-
tivities, but more broadly, other activities in the country
that will add to materials which can be exported in a true
sense.
There is, as you know—some of you know—a program
set up for several years within the Department of Energy
to study the effect  of climate and specifically CO2. But
how one implements this on the international level is still,
to me, not clear.
    My own view is that the—well, let me mention a few
details first. Currently the U.S. and Canada  produce
much of the COZ that's generated and released to the at-
mosphere. Roughly half is produced  from terrestrial
sources—oxidation, rotting of trees, etcetera; massive
deforestation.
    But  around the turn of the century or thereabouts,
the contributors will change and the developing third
world countries and Northern Europe will be producing
much more CO2 than the U.S. and Canada.
    So we will probably be in a position of lecturing to
the rest of the world not to produce CO2 from fossil fuels,
assuming they can get them somewhere.
    Now that kind of involvement on an international
scale, 1 think, will make the question of nuclear weapons
material proliferation look minor.
    There are attempts to grapple with this problem on
an international level, but I think the magnitude of the
potential problem just requires a more concerted effort
somewhere within the Federal system. I would not like to
see another  bureaucratic entity develop and  I'm  sure
most people share  that view. But it's just not clear to me
how one should go about perhaps a more efficient means
of facing these issues on a truly international basis.
    The first step, obviously, would be to do it in our
own country on a  national basis.
    MR. MERSON: I guess I raise the question based
on some experience I've had. I attended a conference in
Berlin this spring on sulphur dioxide and how we deal
with  sulphur dioxide across national boundaries  and
came away with the feeling that we don't deal with it. In
fact, we have no framework. You have a European Eco-
nomic  Community in Western Europe that is there to
promote  trade  and,  1 guess, some  type of economic
unity, but the environmental impacts are simply not being
dealt with.
    My concern is that we don't seem to have within this
decisionmaking process at DOE any way for having those
global concerns brought into the equation. At EPA, for
example, we have dealings with the State Department
when we're concerned with some impacts in  Canada or
vice-versa.
    But I don't see right now—and perhaps someone
else would like to answer this (Steve or someone else on
the Panel) —I don't see a mechanism right now for hav-
ing these considerations brought to the floor. That's why I
was asking you, since you raised it, if you could suggest
some way right now that we  could begin to get those
issues represented in a forceful way.
    DR. RICHMOND: That's again—I have no con-
crete recommendation to make. I think, obviously, one
place to  start is to have some  organization  look
hard—and  I'm not usually  one who recommends gap
studies—but first of all find out who's  doing what. My
perception   is—and  this  is  purely  perception—that
although the various groups in different agencies who are
addressing the problem, they are doing very probably a
job, but I think the potential impact and magnitude of this
problem demands much more effort.
    Let me give you one  concrete solution. The facts
that  we have are related  to the increase  in  the at-
mospheric level of carbon  dioxide.  Beyond  that, there
are many models. So the current interest is for people to
use the models and make predictions of the  increase in
temperature in the future  and what will happen. But
what is clearly needed is  more understanding of the
phenomena  that are  involved.   We  heed  more
measurements.
    To do this requires atmospheric  chemistry; it in-
volves ocean chemistry; the interface of the atmosphere
and the water; the deep sea, since that's where some of
the carbon  is ultimately bound as carbonate. What we
need is greater attention on the R&D effort.
    I think we all agree that there has been—and we can
document factually—an increase and if the increase con-
tinues, then there will very probably be some serious
changes in the global environment. But what we need is
to have a better understanding of the phenomena in-
volved so that we can fine tune and build better reliability
into the models.
    There's too much slop right now.
    DR. MacKENZIE:! was going to ask a very related
question which perhaps you've answered sufficiently,
which is how, in the face of all this uncertainty on carbon
dioxide  and sulfates and perhaps long-term wastes of
radioactivity and so forth, how do you incorporate those
into policies that are being made to move the country in
one  direction  or  another? I guess that's very closely
related to institutions, but in the face of such uncertainty,
how do you incorporate the risks into decisions? And the
decisionmaking process.
    DR. RICHMOND: Again, that's  a very, very dif-
ficult question. I would guess that would be the topic of a
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Hearing of October 4, 1979
very interesting seminar. There are no easy answers to
that question.
    DR. MacKENZIE: Okay, fine.
    DR. REZNEK: 1  would like to return for a few
moments to your last comment which is related. The
energy crisis is with us. It is time for some decisions.
There are certainly decisions which can be postponed a
few years and COZ may be one of them, but there are
other decisions which have to be made now. Saying we
need more knowledge is certainly true, but it seems that
there needs to be some guidelines for  prioritizing  the
types of knowledge that we are going after.
    Can you comment on how you would suggest the
research be divided between applied research whose job
it  is to generate  numbers in  a fairly consistent and
straightforward way on facilities we have now versus
more basic  research in  looking at the fundamental
phenomena such as the CO2  balances?
     DR. RICHMOND: That's again—a key question. I
think—1 hate to put a numerical value on this,  but one
needs to have in running a modern research organization
an appropriate mix of the two kinds of research. If you
become all oriented  solely toward the current questions
and short-term answers, you won't survive because you
won't have  the knowledge  base in the future.
     On the other hand, if you do only long-range re-
search, you won't survive because you won't be funded
continuously.
     I think as a rule of thumb, it's important  to have
somewhere around a quarter of the program where you
can depend on sort  of non-targeted—
    DR. REZNEK: Are you  speaking for your own
organization or for DOE?
     DR. RICHMOND:  I'm  speaking for my own
organization.
     DR. REZNEK: Would  you like to comment on
DOE's allocation in the  process?
     DR. RICHMOND: No,  I guess I can't because I
don't have a broad enough view of all their requirements
and needs.
    I guess the basic question is—the important question
is that the availability of—I guess I should use specifically
the words  "basic research money," but for research
related to core programs [on] understanding how you
measure  the potential carcinogenicity and mutagenicity
of materials from  coal conversion units  as opposed to
site-specific work where the money is obviously  tied into
a given process at a given location.
    The core programs are the ones that we have to be
careful not to endanger.  Again, they are the ones that will
be generating knowledge that will be useful  somewhere
along the system. One example I'll return to; I think there
is good evidence emerging that we probably can, indeed,
identify classes of chemicals that when input back to the
technologist, will allow the technologies to alter a system.
In this case, it appears  to be a hydrotreatment process
which will reduce drastically and perhaps eliminate the
whole class of compounds, the nitrogen containing poly-
cyclic hydrocarbons. So that's the kind of thing that you
won't learn necessarily from any one site. It's the in-
tegrated knowledge that you derive from the core type
programs.
     DR. REZNEK: Thank you.
     DR. WILLEY: Doctor Richmond, you mentioned
in your  talk a  great  number  of  criteria applied  in
evaluating any technology. You mentioned  cost and
environmental consequences and also the ability  of the
technology to be replicated on a large scale. Do you have
any thoughts as to how those criteria would be reconciled
with one another, not only  for a particular technology,
but also across technologies? In some cases, they will be
conflicting. Is there some kind of methodology or the
beginning of a methodology you would suggest to try to
take all of those things into  consideration in making
decisions?
     DR.  RICHMOND:  I  think that's  related  to the
question that Dr. Reznek asked earlier. I mentioned look-
ing carefully at the general  classes of chemicals and prod-
ucts and process strains. So that hopefully enough infor-
mation is gained and  we can make the proper  cross-
comparisons, on a more specific level of comparison, I
think, than is used currently.
     Currently, the kinds  of criteria, as you know, are
rather broad.  They were listed  in the background  docu-
ment, There are comparisons of pollutant emissions and
energy  efficiencies and  comparing  dollar  costs for
meeting environmental standards and looking at prob-
able adverse impacts that may rule out  commercializa-
tion. They are the show-stopper sort of things.
     So again, my feeling is we have  to look at a finer cut
of criteria and one point  I made specifically is that we
shouldn't overlook some of these relatively small projects
that  are on the order of several million dollars because
they may be replicated many times. So that if we study
several of those very  intensely, later on when they
multiply  and if they  multiply and  are widespread
throughout the  country,  we  will  not  have sort  of
miscalculated on the  potential environmental impact,
i.e., if they slip through a detail and review process solely
because they were not above a certain dollar level.
     DR. REZNEK: Thank you, Doctor Richmond.
     Our next witness is Doctor Kenneth Bridbord from
the  National Institute  for  Occupational Safety and
Health.
Presentation by Doctor Kenneth Bridbord
National Institute for Occupational
Safety and Health
     DR.  BRIDBORD:  Distinguished Hearing  Panel
Members, ladies and gentlemen. It is a pleasure for me to
be here today to present  the views of the National In-
stitute for Occupational Safety  and Health, NIOSH, on
the important issues of environmental protection and
energy conservation.
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                                                                                  Statement of Dr. Bridbord
     NIOSH, located within the Center for Disease Con-
trol  of the  Department of  Health,  Education,  and
Welfare, is  the  principal Federal  agency involved  in
research and standards recommendations to protect the
health and well-being of American workers.
     In this regard, NIOSH works closely with the Occu-
pational Safety and Health Administration, OSHA, and
the Mine Safety  and Health Administration, MSHA, in
the Department of Labor, which are responsible for the
setting and enforcement of  standards within general in-
dustries and mining industries, respectively.
     During the past five years, NIOSH has been coop-
erating with the Environmental Protection Agency, with
the Department of Energy, and with the National Institute
of Environmental Health Sciences, also within HEW, in a
coordinated Federal research program to identify and to
prevent potential health problems in energy industries.
     One of our major concerns in all energy technol-
ogies,  both  nuclear and nonnuclear, is the health and
safety of those workers who must construct, operate, and
maintain these facilities including workers in pilot and
demonstration, as well as commercial facilities.
     Unfortunately,  it has been our experience that the
issue of occupational safety and health  has generally
been given  relatively low priority  and visibility in the
development of new energy technologies.
     It is clear to  us that failure to consider occupational
safety and health adequately during technology develop-
ment will result in needless injury and/or disease, as well
as jeopardize the basic success of that technology in the
long-term  by requiring costly retrofit controls later that
could more easily have been incorporated during initial
construction.
     Occupational safety and health considerations must
be one of the earliest issues to be discussed, studied, and
resolved before  large-scale  commitment to any  energy
technology is made. Because occupational safety and
health issues are largely independent of siting, occupa-
tional  safety  and  health  assessments should  really
precede overall environmental assessments.
     Consideration and solution of occupational safety
and health problems early  in the technology develop-
ment phase may actually contribute in a  major way to
resolution  of potential general environmental problems.
     This is because workers are best protected by control
of harmful emissions at the source before they ever can
enter the general environment, thus, also, protecting the
general population and the  ecology.
     Potential  occupational  and environmental  health
problems must be identified early in technology develop-
ment to give adequate opportunities to solve such prob-
lems. Considering occupational safety and health at the
design stage before technologies leave the drawing board
can do much to  prevent future problems.
     Relying upon  Environmental Impact Statements as
the primary means to resolve these issues may already be
too late in the technology development process to do
much good.
     Specifically, NIOSH recommends that, one, occu-
pational safety and health should become a major com-
ponent of DOE Environmental Readiness Documents
and DOE Environment Assessments to assure that these
issues  will be considered as early in  the technology
development phase as possible.
     In making this recommendation, NIOSH recognizes
that there may be engineering scale-up  problems in ex-
trapolating from pilot and demonstration to commercial
scale facilities. In this regard, control technology research
to prevent harmful emissions in the workplace and the
general environment must be coordinated to help assure
that  efforts to protect the environment  do  not inadver-
tently harm workers, nor efforts to protect workers harm
the general environment.
     Workers must be  adequately  protected  from the
onset of technology development. We cannot afford to
wait 20 or 30 years or more, the latent period  for many
chronic diseases, before identifying  potential problems.
    To better accomplish the goal of protecting workers,
NIOSH recommends that, two, a separate Occupational
Safety and Health Impact Statement should be required
for all developing energy,  and for that matter, other
technologies. This impact statement should be  prepared
before the development of Environmental Impact State-
ments  and should  consider  not only  information on
health effects, but  also  whether adequate  control
technology is available.
    NIOSH's experience in the review of Environmental
Impact Statements is that occupational safety and health
considerations are  rarely, if ever, mentioned,  let alone
adequately dealt with.
    In reviewing the type of health  and  related research
that is necessary to assess developing energy technol-
ogies,  it  is  extremely  important  that multidisciplin-
ary teams of biological  and engineering scientists work
closely together in the identification and solution  of
potential problems.
    NIOSH recommends that, three, research be orga-
nized more along  technologies than along biomedical
science disciplines. Health researchers must understand
the technologies before being able to focus  research
questions upon the most important potential problems.
    Health research questions should also be asked in a
way to assist the engineers in the design and  develop-
ment of adequate control technology.
    At this point, it would be unrealistic to expect bio-
medical researchers to define exact dose-response rela-
tionships early in the technology development process.
However, if researchers could, at least, identify the most
likely toxic components in process and product streams,
the engineers could further focus their efforts on process
modification and control technology development.
    Here, I might add,  I believe both Doctor Richmond
and I are very closely in agreement.
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Hearing of October 4, 1979
    In this regard, engineers require better training to
more fully appreciate the need to consider health and
safety in process design.
    I might just dwell on this point for a moment. Before
entering the area of the  biomedical sciences I was a
chemical engineer. I do not recall at one time in my
education process at both  an  undergraduate and gradu-
ate level,  any mention of general  environmental,  let
alone the occupational health issues.
    I think part of the longer-term solution is to sensitize
the scientists in the engineering community to begin to
ask a basic set of questions very early on in their thinking
process about the potential health and safety implications
of that developing technology.
    I think if we don't get the engineers to ask that set of
questions routinely and develop sensitivity to that issue,
then we will always be in a catch-up situation. That obvi-
ously isn't going to resolve all of our current problems.
but I think in  the  long-term that can do a great deal to
help.
    A case in point is in coal liquefaction and gasification
where the severe operating conditions, temperature and
pressure,  and the erosive/corrosive  nature of many
process streams require extensive efforts to develop im-
proved containment systems.
    A fourth NIOSH recommendation is that occupa-
tional  safety and  health considerations should not be
ignored in our overall efforts to conserve energy. Manu-
facture of insulation materials, especially  with pressures
to push production to meet increasing  demand, may
result in harm to workers.
     Efforts to conserve energy by exhaust gas recircula-
tion may also result in buildup of contaminants, possibly
to harmful concentrations.
     Recycling and resource  recovery may also expose
workers to hazardous substances. Even solar energy may
have  associated  occupational   safety  and  health
problems.
    The final NIOSH recommendation is that, five,
worker representatives, must be given  an adequate op-
portunity to participate in the public debate relating to
developing energy technologies.
     One reason why workers have not been more vocal
in that debate is that there is a common  misconception
that environmental goals can  only be achieved at the ex-
pense of job  opportunities. This, of course,  is not the
case.
    One of the advantages of a  separate occupational
safety  and health impact statement  is that this will
encourage workers  to  express opinions about energy
technologies,  particularly on  matters affecting their own
safety  and health. The current  environmental impact
process does  not  encourage  participation from workers
in this national policy debate.
     In this regard,  1 was most pleased  that represen-
tatives from organized labor were  present at the regional
workshops preceding this hearing, and that occupational
health and safety was identified as an explicit criteria that
requires further discussion.
    This concludes my formal remarks. I shall now be
pleased to answer any questions.
    Thank you.
    DR.  REZNEK: Thank  you.  Are there  any
questions?
    MR. GAMSE: Doctor Bridbord, Doctor Richmond
in his comments made reference to the Memorandum of
Understanding that EPA has been developing with the
Energy Department which we expect to be finalized very
soon. It attempts to  map out a process by which first
guidance and then standards for environmental protec-
tion  would be developed along with emerging tech-
nologies, which the  Energy Department is involved in
development on.
    I'm wondering if there is a similar activity going on
with regard to occupational exposures or if you see a
need for a more formalized process for incorporating
concerns about occupational exposures and developing
standards  in  the  process   of  developing  these
technologies?
    DR. BRIDBORD: I would certainly support the
concept very strongly, both as an organizational repre-
sentative and because of my strong personal views on this
matter.  I think one  has to approach the developing
technologies looking at both the occupational and the
environmental standards together. I have to, from this
perspective, express  a little disappointment that to my
knowledge the Department of Labor, including the Oc-
cupational Safety and Health  Administration as well as
the Mine Safety and Health Administration, and  the in-
stitute that I represent, NIOSH,  have not been involved
in the basic discussions between EPA and DOE about the
overall concept as to where  we're going in terms of
environmental standards and making appropriate recom-
mendations with  respect to technology development.
    I think one has to look at the standards across-the-
board in terms of new standards that might be necessary
to protect workers as well as  standards for the general
population. I think they are very complementary.
    MR. MERSON: I'm a little concerned about your
second recommendation, namely, preparing a separate
occupational safety and health impact statement before
moving ahead to other environmental concerns.
    I'd appreciate it if you could just expand a little on
why you think it's necessary to interject another  step in
this decisionmaking process to deal exclusively with oc-
cupational health  and safety considerations; why it can't
be, as you suggested in your first recommendation, just
part of the process that  looks at overall  environmental
concerns?
    DR. BRIDBORD: I would feel more comfortable
in relying upon the current process or something close to
it if those processes  were adequately asking questions
about how best to protect workers.  What I've seen hap-
pen is that there is so much, and I think very appropriate
                                                    64

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                                                                                Statement of Dr. Bridbord
concern for the general environment, that the questions
and public debate does not give adequate opportunity to
discuss the occupational safety and health issues. Also,
considering the fact that at times in a very simplistic view,
concern for the environment may appear to be at odds
with concerns about workers' protection. I think that that
question just never gets asked by the "Environmental
Concerned Groups,"
    That's really the reason why I feel so strongly that we
need  to take a closer look and  perhaps modify that
process. I certainly don't mean that recommendation in
any way to diminish the importance of the general envi-
ronmental concerns.  But 1  haven't  seen  one environ-
mental impact statement that I've been comfortable  as
having really looked at the occupational safety and health
aspects.
    If we look at the occupational aspects carefully, 1
would argue that we will also help a great deal to protect
the general environment. If we have  solved a lot of the
fugitive emissions questions, with process modification
steps to reduce,  at least, certain classes of compounds
from forming, I see in the long-term the occupational and
environmental concerns being very,  very complemen-
tary; not antagonistic.
    But I have to state  again that  up until now, that
question has been ignored. And I feel very uneasy about
just saying, oh, yes, leave it to the environmental impact
process because it just hasn't worked, in my opinion.
    MR. MERSON: Steve, 1 think  Doctor Richmond
has a  question.
    DR. RICHMOND: If I may, I'd  like to reinforce
not the recommendation, but the  importance of the
worker aspect of the problem. Many people don't appre-
ciate the environment fs inside, indoors, as well as out-
side. It's a working environment, and the model which I
put forth in my testimony of the gasifier at Minnesota, we
have the opportunity in the research world to see the
whole problem without worrying too much about how
it's divided in terms of bureaucracies.
    I mention there is an advisory committee that's com-
prised of both EPA, DOE and NIOSH. That's very im-
portant because some of the early-on problems that have
been identified are those such as releases  of carbon
monoxide and mercury vapors which obviously impact
the people on-site, the worker population.
    DR. BRIDBORD:  Please don't  misinterpret my
remarks as opposing sticking with  the basic environ-
mental impact process, if one could be assured that that
process can  be modified and  expanded to include an
adequate look at occupational safety and health. At least
up until now, it has not been modified  and that's why I
have chosen to  separate this out  as a very specific
recommendation.
    DR.  WILLEY:  Your  fourth  recommendation,
Doctor,  is   a  special   concern  for  conservation
technologies. I'm just wondering why special concern for
the emerging conservation technologies as opposed to
any emerging energy technologies?
    DR. BRIDBORD: I think my feeling here—and I'll
be glad to give some examples—is that while certainly
conservation has a great deal of merit, it's very important
and I strongly endorse it, but we shouldn't leap into any
situation without fully understanding what we're doing.
    Perhaps two illustrations would be helpful.  Let us
look at the whole area  of home insulation and energy
conservation in the home itself. Here, one has not really
focused upon the whole question of indoor air pollution
as opposed to outdoor pollution. Here, indoor pollution
can primarily be the result of indoor sources of emis-
sions—a couple of examples come to mind. Cooking
with gas, for  example,  may have  associated problems
with exposure to nitrogen oxides.
    In a very  simplistic first approximation as a model
system, any time you cut down the air turnover within a
confined space to less  than two  times per hour, any
pollutant emitted in that space really builds up in an ex-
ponential fashion and there are many, many sources of
potentially harmful chemicals in the home. Solvents used
in cleaning, for example. •
    1  mentioned cooking. Any combustion products in
the home.  These are all sources—smoking can  be  a
source of sidestream smoke. I certainly don't endorse
smoking. I strongly support the position of HEW.
    But I think we should keep in the back of our minds
that all exposure isn't just what's coming from the outside
and that we shouldn't push so far on the home insulation
area that we have closed up that box too tight without
thinking about some of those sources.
    In addition, in the insulation area, there's the whole
question of the safety and integrity of the basic materials
that are used in insulation and some of the off-gas prod-
ucts that may result.  Also, the question of fibers, particu-
larly in certain sizes, which may cause potential problems
somewhat along the line that asbestos has caused.
    That's  one set  of examples. In  the area of  solar
energy, which has so much appeal, and I think many,
many strong points,  let us not forget to ask a basic set of
questions in terms of looking at the basic materials that
may be used to construct certain units, looking at the
question of perhaps heat transfer fluids and the potential
toxicities there and being aware of the  workers who have
to put  these materials together and install them as well.
So that we've identified the problems before and we've
solved those problems before. That's the point I'm trying
to get at.
    DR. REZNEK: I'd like to ask just one question—it
seems  to be  my continuous  question. I find  your
testimony very good in terms of adding a  set of new
dimensions to the concerns on a particular evolving
technology, the conservation of our supply.  However,
do you feel that there are acceptable standardized proto-
cols which will allow you to do intertechnology compari-
sons?  Can you evaluate in a meaningful and acceptable
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Hearing of October 4, 1979
way the relative worker health and safety risks of one
gasification process versus another or between gasifica-
tion and electrification?
     DR. BRIDBORD: Okay. Here I have to agree very
much  with  the comments of Doctor  Richmond and
perhaps expand a little bit here, too-.  That  the health
science community has not really had an opportunity to
ask the full set of questions that might be asked. Are we
going to make the health comparison, let's say, looking
only at the problem of chronic respiratory diseases, for
example? Perhaps we may not have asked the basic set of
quesions not only about the  potential carcinogenic,
although that will probably be asked because of the im-
portance of that, but what about the effects of various
materials on  other target organs  in the  body,  either the
nervous system, the liver, the reproductive process, etc.
In general, we have not asked the full set of health ques-
tions, but I find it very difficult to say we have all the infor-
mation we need to make that kind of comparison.
     What I do feel we can do at this point in time is to in-
tegrate much more strongly the technology, control tech-
nology and process modification with what we suspect to
be harmful classes of materials and to start to ask the sets
of questions in a way. What are the break points in terms
of that technology development that allow us to control
at increasingly stringent levels of control so that we buy
the greatest margin of future protection and to try to force
the engineering community working with the biomedical
community to work together  to really develop the engi-
neering know-how and the systems analysis to control
many, many emissions, even if we don't fully understand
the  health  implications,  to  the  lowest  possible level
without getting to the point where you break the possibili-
ty of having that technology at all.
     In the EPA area, for example, there's a lot of discus-
sion about the criteria pollutants and a lot of focusing on
those pollutants. But those are  still just one set of con-
cerns. Just thinking that you've made your comparison,
just looking at the criteria pollutants, really leaves a whole
number of other questions unanswered.
     In terms of the future perspective on this, there are
likely to be continued discoveries as the health scientists
ask questions  that  identify heretofore  unrecognized
problems.
     So I really feel very much that you need to continue
to ask the health questions, but ask the engineering ques-
tions in an entirely different way that I don't believe has
yet been asked.
     DR. REZNEK: During—this is perhaps repeating
my same question in a slightly different way—during the
workshops that were preparatory for this hearing where
we  went out to the lay public or people not as profes-
sional as some of us, there was a lot of stress on the DOE
management system and its ability to use environmental
information to actually make judgments about the alloca-
tion of resources. The fact  that the balance between
development versus—development for energy produc-
tion or energy conservation—versus resources allocated
to solve environmental problems  or health and safety
problems,  that  that point was  well addressed by  the
system, not necessarily any individual cases. This cer-
tainly incorporates that.
    But the information for comparisons and for allow-
ing one technology to go ahead seemed to favor very
definitely the economic aspects of the energy production
rather  than the comparison  of the environmental or
health and  safety aspects. So the question is  really
staightforward—can you conceive of a standardized in-
formation risk assessment protocol which would help in
the betweerj-technology allocation  process?
    DR. BRIDBORD:  I wish I  could give a  simple
answer "yes" to that, but unfortunately my response is
going to be in the negative. One major reason is that it
would be very difficult to identify and translate into dollar
terms the true health impact, let alone ecological impact
of any technology because, as far as I'm concerned, all of
the basic sets of health questions  have  not been asked
yet.

    So we have, if you—there is perhaps a three-dimen-
sional matrix involved in this. On one axis might be the
technology; another axis might be the set of pollutants
that are associated with that technology, both inside the
plant and in the general environment; and the third set is
a whole host of effects, not only just environmental and
health,  but  in the health area  for example  you have
literally every target organ and system in the body that
could potentially be affected.
    Now the probabilities are that they're not all in-
volved, of course, but until one has at least tried to ask
some general questions to define the magnitude of risk,
recognizing you can never ever prove anything com-
pletely safe, but at least to ask some intelligent questions.
    I'm very comfortable as to how our damage func-
tions are in terms of current knowledge, with respect to
what the true situation would be. I don't think there's any
simple answer to simple protocol from my perspective
that you can plug in.
     DR. REZNEK: Thank you very much. We seem to
have run a little over time. Why don't  we take a break
now?
     First, let me say, though, is there anyone from the
audience who would like to address a question to the first
two witnesses?
     (No response.)
     DR. REZNEK: If not, we'll break for 15 minutes or
maybe 12 minutes, by my watch,  and reconvene at half
past.
     (Whereupon, a break was taken at 10:14 A.M.)
     DR. REZNEK: Our next witness  is Doctor Ralph
Perhac of the Electric  Power Research Institute.
                                                     66

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                                                                                   Statement of Dr. Pcrhac
Presentation by Doctor Ralph Perhac
Electric Power Research Institute

     DR. PERHAC: Are you ready?
     DR. REZNEK: Sure.
     DR. PERHAC: Okay. Mr. Chairman, Panel, ladies
and gentlemen. I am Doctor Ralph M. Perhac, Acting
Director of the Environmental Assessment Department of
the Electric Power Research Institute.
     Mr. Chairman, I welcome this opportunity to testify
and express some of the views of EPR1  with regard to
research planning.
     The specific question I plan to address is what is the
basis by which EPRI decides which technologies it will
support? Hopefully by discussing this question, it will give
you and the Panel some insight into our approach to
research planning and also help in your evaluation of the
overall DOE planning process.
     Let me start first by saying a few words about EPRI in
general and, secondly, get into the specific issue of  how
EPRI decides which technologies it will support.
     First, a word about the Electric Power Research In-
stitute. EPRI was founded approximately six years ago to
serve as the research arm of the electric industry in the
United States. It is a non-profit educational institution. In
essence, it is a research funding institution. We do prac-
tically no research at EPRI at all. We fund research. Our
support comes from the utility companies in the United
States, which means ultimately from the  consumers
themselves.
     Approximately half of the  American  utility com-
panies,  both  private  and  public,  are  contributing
members  to the  Electric Power  Research  Institute.
Although we only have  about half the total number of
utility companies, our support represents about 75 to 80
percent of the total electric capacity in this country.
     Membership in EPRI is entirely voluntary on the part
of the individual utility company.
     Our charge is  to fund research that relates to the
generation and transmission of electrical energy. That
research ranges anywhere from developing more effi-
cient burners to studying pulmonary dysfunction related
to  atmospheric particles.  We cover the full range of
technological as well as environmental research.
     We focus on two principle types of research in the
broadest sense. Number  one, research that is generic or
relative to the industry as a whole. Obviously, we get our
support from the industry throughout the United States.
Our main interest is in doing research that benefits the
broad base of industry rather than one specific utility
company.
    A prime example of that would be development of
improved  precipitators  for  collecting  atmospheric
particles.
    The second type of research we fund is research that
may relate to just a few specific industries in a specific part
of the nation, but is so expensive that no small combina-
tion of companies could afford to do it.

    An example of that would be visibility studies in the
Southwest. This is extremely costly research. It may relate
only to a few specific  utility companies, but because  of
the  high cost, this group  of  utilities in the Southwest
could not afford to undertake it; therefore,  we will sup-
port that type of research.

    Let me make one or two other comments about
EPRI before I move on to the research planning mode.
Number one, we do not support research that relates to
advocating policy. Number  two,  the  results  of EPRI
research are the property of the researcher, not of EPRI,
which  means that  we exercise  no control over the
research that we support. What the researcher wishes to
do with that research is his business. He may publish  it;
he may not publish it. We do not exercise control over it.
    We obviously have the right to publish it if we wish,
inasmuch  as we pay  for  it,  but we  do not own the
research results. As a result of this twofold approach  to
research, that is, the absence of doing advocacy research
plus  the fact that we do  not own the  results of our
research, have given us a high degree of credibility. I
think we're justly proud of the credibility that our research
has gained throughout the research community and the
governmental community.
    Let me now move on to the more specific question:
how does EPRI decide what research it wilf support  or
what technologies—into what technologies it will put  its
money?
    Rather than sit down and just make a list of criteria
on which we will do our planning, we use a threefold ap-
proach. Number one, we  examine first the specific re-
quirement of the Electric Utility Industry. Number two,
we  then generate a  series  of assumptions  or basic
premises that we must consider.  By putting these two
together—that is, the special requirements and the basic
assumptions—we find that the research planning ap-
proach falls out very nicely and very conveniently.
    Let  me, therefore,  discuss  first  the special re-
quirements and secondly, the assumptions that we use in
deciding how we will move ahead.
    The Electric Industry  does have some special re-
quirements.  Obviously EPRI  has one overall  general
special requirement and that is to do research related  to
the electric industry in general. But within that broad re-
quirement, there are some very specific things—and I will
list four. Number one, the electric industry does have the
special  requirement of  providing  electricity  to  the
customer. This is its charge, of course. The electric in-
dustry is in a very special position. It more or less func-
tions as a Government-approved monopoly within a free
enterprise system.  But in having that monopoly,  its
charge is to provide electricity to the customer.
                                                    67

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Hearing of October 4, 1979
     It means, therefore, the electric industry must antici-
pate the demand; it must go out and operate and con-
struct and transmit electricity to society. So that's require-
ment number one—the providing of electricity.
     Requirement number two is that it must provide
electricity  reliably and at minimum cost. This reliability
aspect is an important special requirement of the electric
industry.
     The third special requirement is that  the industry
must secure access to resources. That is, to land for raw
materials and things of that sort.
     The fourth  and final special requirement that I'll
mention is that the electric industry must protect the en-
vironment and public health. This is an important con-
sideration in  its  providing of electricity  and providing
electricity reliably and at minimum cost.
     I think if you think for just a minute about these
special  requirements,  you will  see that  certain  ap-
proaches to research  fall out almost automatically. I'll get
into that in more detail later.
     Let me move on to the second step in  this research
planning process, and that is the assumptions or the ma-
jor premises under which the electric utility  industry and
EPRI specifically operate. I will list six of them.
     Number one assumption is that electricity demand in
the United States will grow. We do not see this as a static
situation. We see the demand continuing to grow. How
much it grows, of course, is a matter of debate—whether
it's two percent, three percent, four percent, I don't think
is material in our overall planning.  What is important is
that electricity-demand will grow. This is an assumption.
     Incidentally, let  me  emphasize right  now that  in
specifying these assumptions,  I  am  listing a series  of
working hypotheses.  I am not specifying a policy that is
followed by EPRI. These are simply assumptions that we
follow in planning our research. We are not advocating
any of these assumptions one way or the other. We ac-
cept them as a working hypothesis.
     Assumption number two: over the future decades
with regard to electricity demand, we assume that capital
costs to the industry will be high. This is a very important
consideration that bears on the type of research that will
be undertaken.
     Assumption  number  three: long  lead  times are
needed if  we're going to change the present energy mix.
We have a general mix now of nuclear, oil, natural gas
and coal.  For all practical purposes, this  covers most of
the electricity production in the United States.
     If we want to  make  significant changes in  that
mix—and  I  emphasize  the  word "significant"—we
assume that long lead times are going to be needed. We
can't make these changes in one decade.
     Assumption number four: for at least  the next few
decades, we  assume that the existing technologies will
continue to provide the major source of electricity.
     Assumption number five, we assume that the United
States should not establish a strong dependence on
foreign supplies of fuel. That means,  in turn then, that
the United States must concentrate its electricity produc-
tion  on domestic fuels as much as possible, which of
course, means basically on coal and uranium if the other
assumptions above are correct, these assumptions being
that  long lead times needed;  that existing technologies
are needed.
     The final assumption we make is that environmental
consideration will continue to become increasingly im-
portant, even more so than they are now.
     I have  listed a series of  research criteria—excuse
me—a series of special requirements for the electric utility
industry. I'v.e listed a series of major premises or assump-
tions. Putting these two together, I think you'll see that
the requirements for our research planning fall out rather
simply.
     I suggest, Mr.  Chairman,  that any governmental
agency or any research funding group can take this ap-
proach—that is, establish certain criteria, establish certain
assumptions or premises, and then use these to decide
how it will support a research program; what technol-
ogies will need to be developed; how the money should
be distributed.
     Let me now move on to the final part of my testi-
mony and that is the specific research criteria that EPRI
uses in deciding which technologies to support or how it
will spend its research money.
     Our overall planning is based on five basic points
and  I will list these in order. Number  one, our research
planning or our decision  on which technologies to sup-
port is based  on, first of all, the extent to which the
technology can provide the needed energy. Now you
may recall that I mentioned previously (under the specific
requirements of the electric utility industry) that we are
required to provide electricity.  Obviously, we have got to
put money into supporting those technologies which can
provide the needed energy and in the time-frame  in
which  it's needed.
     Let me give you an example. We have the tech-
nology now to provide electricity from fuel cells. But the
amount that comes from that is minimal, compared  to
what is needed.
     On the other side of the coin, we see fusion as a
possible means of providing  tremendous quantities  of
electricity, but that is decades away. So it's quite obvious
when we look at things like fuel cells and fusion, we will
relegate them to a minor position compared to other
technologies.
     I  must  emphasize   "compared  to  other
technologies."
     So the first criteria is the extent to which the tech-
nology can provide the needed energy in the necessary
time-frame.
     The second criteria:  financial considerations, and
these include two things. Number one, the financial con-
sideration to the industry in terms of capital outlay. This
obviously is going to have a bearing on the technology
                                                    68

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                                                                                  Statement of Dr. Perhac
that we will support. Secondly, is the cost to the con-
sumer. Now, again, we have the technology to devise a
number of means of  providing electricity—and large
amounts of electricity.  But the cost is so great, either in
terms of capital outlay by the industry or more important-
ly, cost to the consumer, that there's no point in putting a
tremendous amount of money  into those technologies
right now in order to supply the demand that we see for
the next ten to twenty to thirty years.
    Number three criteria:  the EPRI research budget.
We have a finite amount of money, as does any organi-
zation, and  we  have  to  judge the emphasis  in our
research funding on the amount of money that is avail-
able. We have to have somewhat of a balanced program
and that, of course,  depends to a large extent on how
much money is available.
    The fourth criteria is the extent of research which is
being done by others. Now, to a large extent this means
the Federal Government, but not exclusively. Let  me
give you an example of that.
    In my own department, the Environmental Assess-
ment Department, we are putting very little money into
research related to environmental problems of nuclear
energy. This doesn't mean we don't see that as an impor-
tant issue; it doesn't mean that we have no interest in
nuclear energy. What it means, instead, is that we see the
Federal Government putting quite a bit of money into
nuclear energy. The amount that we could allocate is
very small and we could hardly dent the program which
is  going on and  which  has gone  on by the Federal
Government. Therefore, those  projects which  we sup-
port in nuclear energy are very few and are aimed at fill-
ing a gap within existing Federal programs.
    Again, I emphasize it's not because of  any lack of
concern over the environmental effects; it's because we
see that the impact we can make is so small compared to
other research  which is going on that we can profitably
put our money into other technologies and produce a
greater effect for the overall welfare of society.
    The fifth,  and final, concern is  the environmental
concern, and this includes a full gamut of environmental
problems from the physical chemical aspects of the  en-
vironment to  health  effects.  For  example,  material
damage; visibility degradation;  human health, ecology
and socioeconomic aspects.
    Now, I don't pretend that the environmental consid-
erations will necessarily rule out a technology. I must
make this  point.  Let me give you an example. We  are
considering, for example, many technologies of gasifica-
tion. The prime  consideration is not environmental.
There are other things that go into which technology we
will support with regard  to gasification.  This doesn't
mean we're not interested in the environmental aspects.
It just means that it's not the prime consideration because
our feeling is that we can take care of the environmental
aspects of the particular technology. We don't see that as
the deciding factor on which gasification technology the
nation will use.
    Our concern is to go ahead, develop the technology
at the same time that we are examining the environmen-
tal concerns of the different gasification technologies and,
at the same time, developing the technology to take care
of whatever environmental problems will arise.
    But the environmental concern is very definitely an
important aspect in our overall research planning.
    Mr. Chairman, I  think I have covered the basic
thinking that goes into  the EPRI research format or into
the  EPRI research planning.  Again, I thank you for this
opportunity to address the panel and the audience.
    DR. REZNEK: Thank you.
    MR. GRISHAM: Doctor Perhac, could I ask you a
question regarding  your working relationship with the
Department of Energy?
    DR. PERHAC: My relationship  with the Depart-
ment of Energy?
    MR. GRISHAM: Right. Do you-
    DR. PERHAC: We have just recently  signed a
working agreement with the Department,  all within the
last two, three, or four months,  and this agreement
basically outlines the areas  of interest of the Electric
Power Research Institute and the Department of Energy,
the  extent  to which we may be cooperating  and the
mechanism by which we will be cooperating. How, for
example, we would operate a jointly funded project and
things of this sort.
    MR. GRISHAM: Do you have projects  now that
are  jointly funded with EPRI and DOE?
    DR. PERHAC: Yes, we do. And we  look forward
to more, but we do have some projects now that were
jointly funded.
    MR.  GRISHAM:  Okay.  One  other  question.
Could you  give us  an idea of what kind of projects are
underway now through this joint funding?
    DR. PERHAC: We have none in the environmen-
tal area just yet, none in the specific environmental area.
The projects are in the fossil fuels division which relate
more  or less to technological development. Pilot plant
type operations and test facilities, precipitator type equip-
ment. It's   in that  area  where the joint  funding has
gone on.
    We are  now  pursuing  with  the Department  of
Energy  the possibility of funding some  specific en-
vironmental studies.  For example, I'll give  you  one
specific example on animal toxicology studies; inhalation
toxicology.
    MR. GRISHAM: Steve, one other  question, if !
might. The question regarding  your  statement about
research in the area of policy. Could  you define what
you mean by "policy"? I don't understand how you can
avoid policy in your research.
    DR. PERHAC: Oh, we do some policy research.
There's no  question about that. We will look, for exam-
ple, into the effects of the Resource Conservation Recov-
ery  Act on the electric utility industry as a means of judg-
ing  what sort of research we will support in regard to solid
waste disposal.
                                                   69

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Hearing of October 4, 1979
    What we do not  do,  however, is research that
would result in our  advocating a policy. For example,
under—again under the Resource Conservation Recov-
ery Act, there is a proposed provision  whereby utility
solid waste will be subjected to a chemical test to see
whether or not the solid waste is a hazard.
    We may study that test with regard to its reproduci-
bility,  the cost of doing it; things of this sort. But we will
not say or recommend that this is a good  or bad test. We
don't feel that's our position.
    We may do research, for example,  with  regard to
studying the emissions from different types of coal plants.
But again, our position is not to recommend one type of
coal plant over another with regard to national policy.
We will present the data and let whoever makes decisions
make  their own judgment.
    MR. GRISHAM: Thank you, sir.
    DR. MacKENZIE: From your assumptions, it is
clear that you are worried about the—you are assuming
that existing technologies  will  provide  the energy
resources for the next few decades. That was one of the
assumptions. And yet, environmental considerations will
loom very important.
    Given the slowness with which new energy technol-
ogies can make an impact, I'm a little puzzled why you
really  don't take a very long-term point of view and see
whether or not environmental  considerations, such as
carbon dioxide, might,  in  fact, have significant implica-
tions for the  utility industry today. If it takes four or five
decades to switch energy sources—I'm just wondering
whether or not global concerns,  for example, CO2 or
acid rain or what have you—might not really have signifi-
cant implications  for what you should  be supporting
now.  It might be a very important part  of your whole
program.
    DR. PERHAC: I almost have to say yes to your
question because I'm not quite sure exactly what you're
asking. I hear a lot of things and I agree with most of what
you're saying, but may 1 ask that you be more specific in
the question. Then perhaps I can answer it.
    DR. MacKENZIE:  Okay. Does EPRI do much
work on renewable resources—wind, for example?
    DR. PERHAC: We do research, yes, on the more
unusual technologies, but a limited amount. Again, we
have to decide on which time-frame we're going to—
    DR. MacKENZIE: That's my question.
    DR. PERHAC: —we're going to focus our efforts.
Whether it's in the next,  say, zero to 5 years or 5 to 30 or
40 years or beyond 40  years.
    For all practical purposes, most of our emphasis is
going into what one might consider the mid-range; say,
research problems that  will arise over the next 5 to 30
years  or so, something to that extent. That's basically
where we're  putting  most of our emphasis.
    That being the case, we focus most of our emphasis
on existing technologies and the  problems relating to
those, both technological and environmental.
    Now, this doesn't preclude looking, for example, at
the environmental effects of fusion. We do have a small
effort into that. We are also looking, for example, at the
COZ problem to  a  limited  extent. That's an existing
technology, of course, or a problem related to an existing
technology, but the problem may be longer range than
30 years, but we are looking at it, to see what we might
be able to contribute as far as supporting research.
    Does that answer, in part, your question?
    DR. MacKENZIE: 1 think-
    DR. PERHAC: I think the time-frame on which we
focus our efforts, the so-called midterm, has a profound
effect on what research we will support and  what con-
siderations go into that research.
    DR. MacKENZIE: Do you have an idea of the
fraction of your budget that goes into, say, fossil fuel sup-
port as opposed  to  longer  term, such  as  renewable
resources?
    DR. PERHAC: Yes. In round figures—and these
are very  round—approximately 45 percent of  our
research budget which this year in 1979, calendar '79, is
a bit over $200 million, goes into our fossil fuels and ad-
vanced systems  program, or rather, division.
    About 20 to 25 percent goes into nuclear and the
rest is split between the electrical transmission division
and the energy analysis and environment division.
    So the fossil fuels division is getting about half the
budget.
    Now, I want to caution or emphasize one point.
Although the energy analysis and environment division
may only get between 10 and 15 percent of the budget,
the actual amount of money spent on environmental
concerns at the Electric Power Research Institute is about
50 percent of the total budget. We have a separate envi-
ronmental assessment department,  which gets its own
budget, but there's environmental work going on in all
the divisions.
    So,  actually, with regard to environmental  con-
cerns, close to 50 percent is a fairly accurate figure as far
as what we're supporting.
    DR. WILLEY:  I'm curious about the  process of
specifying assumptions because obviously that's going to
be very important to DOE in establishing their research
agenda.  In particular, I assume when EPRI talks about
long lead time, this is referring to long lead times that are
required in the development of coal or nuclear proj-
ects—8 to 10 years? Is that what you're referring to
when you assume long lead times?
    DR. PERHAC: No. When I said long lead times, I
was referring to—specifically to the fact that long periods
of time would be needed if we're going to make a major
change in the mix of energy technologies that we now
use.
    DR. WILLEY: I see.
    DR. PERHAC: If we're going to bring in, for exam-
ple, extensive liquefaction or extensive gasification to a
                                                   70

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                                                                                  Statement of Dr. Perhac
 large extent, or extensive use of solar energy, we don't
 see this happening in the next couple of decades. We see
 this requiring quite a few decades.
     DR. WILLEY: As far as the Department of Energy
 goes, in trying to establish assumptions under which they
 should work, do you have suggestions as to how the
 Department ought to go about establishing assumptions?
 In your case, it's much easier. I assume that you poll the
 industry  on some kind of criteria for what they assume
 and then determine your research agenda.
     For the Department of Energy, since its constituency
 is much broader, would you have any suggestions as to
 how it would establish a set of assumptions from which a
 research agenda could flow?
     DR. PERHAC: I'm going to have to say no, I don't
 because  it's an  area in which  I  don't specifically deal
 myself. At EPRI, to some extent, we poll the industry in-
 formally, but we have a separate planning department
 that devotes most of its energy to the question of research
 planning. I don't deal much with that aspect of it. I'd bet-
 ter not answer.  I'd be guessing and  that's all. So let me
 avoid that one.
     MR. GAMSE: As you talked about the criteria that
 EPRI uses  itself, I was trying to  translate those to what
 recommendations there might be for the Energy Depart-
 ment's decisionmaking.  Particularly the environmental
 criterion  that you use.  Do you have any suggestions on
 how  environmental concerns should be factored  into
 DOE R&D planning?  Specifically,  you  said that  you
 moved the research along on all of the technologies
 simultaneously and did the environmental research side-
 by-side.  Is that  the path  you would recommend for
 DOE? When should environmental considerations or the
 results of environmental research affect the priorities with
 which projects are funded or whether they go on to the
 next stage or not?
     DR. PERHAC: I think you've asked probably one
 of the most difficult questions that a person could ask. It
 would be almost a truism for me to say that the decision
 to abandon a project, for example, would be when the
 environmental concerns are insuperable. That's an easy
 answer, but I'm not sure how one decides that.
    I can't give you an easy answer to that, I just don't
 know. Could you try phrasing the question differently?
    MR. GAMSE: Well, for instance, at the early
 stages, I gather that EPRI does not adjust its funding
 priorities on the technology development side based on
 the environmental  considerations? Your assumption
 seems to be that you do the environmental research and
 assume that that will lead to the solution of the environ-
 mental problems that you identify.
    I hope I'm fair in characterizing this.
    DR. PERHAC: Only in part. Let me give you a
specific example where it works  the other way. No, I'll
give you  two examples. Let me go back to the gasifica-
tion case.
     We don't really know enough yet about the envi-
ronmental consequences of extensive use of gasification
technology. Therefore, we are supporting a fair bit of
work on gasification technology and at the same time
we're developing  an  environmental program to go
along with  that.
     That's one example where the two are going hand-
in-hand,  where the environmental concern is not yet
affecting our research funding on the technology.
     Now, on the other side of the coin is, for example,
conventional coal-burning. From our  environmental
work, we're discovering more and more that a major
cause of pulmonary dysfunction may be some very fine
respirable particles  which are in the atmosphere.
     This is some information that we're just discover-
ing,  and other groups are discovering it as well. We are
supplying  this information to our fossil fuels division
which then uses it in its design to minimize the amount
of fine particles which get into the atmosphere.
     So there the environmental work is preceding the
technology development. So I don't think I can give you
a simple answer. There are just individual cases where
one  precedes the other and vice-versa.
     MR. GRISHAM: Doctor Perhac, are you satisfied
now with  the  way R&D  is developed  in the Electric
Power Industry on  a national level? If you're not, what
could be done to change it to improve the system? •
     DR. PERHAC: You ask a question that I'm really
not qualified to answer. You said the "Electric Power
Industry." I can't speak for the Electric Power Industry
as a whole because the  Electric Power Industry has
many different research segments. TVA, for example,
has a very extensive research group.  We're not  in a
position really to judge the  overall research effort of the
industry. All I can do is pass judgment on the EPRI ef-
fort and we are just one segment of the research effort
of the industry.
     My own personal opinion is yes,  I am presently
satisfied with the EPRI research approach. Any changes
I would make would probably be minor.
     DR. WILLEY: You've raised the  main criteria of
EPRI being supply over liability and of course, that has
got to be a  main criterion for any research group. Cer-
tainly DOE's research program  will have to be con-
cerned with supply over liability. The question that's
been raised in these hearings and elsewhere has been
whether or not one should consider increasing the effi-
ciency of use of energy as  an aspect of supply; that is,
the technologies that use the existing supply of energy
more efficiently essentially increase supply. Does EPRI
consider increased  efficiency technologies to be supply
of viable technologies, and  therefore,  eligible  under
those criterion  for research funding?
     DR. PERHAC: Is your question does EPRI con-
sider efficiency of supply—
     DR. WILLEY: Increased efficiency.
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Hearing of October 4, 1979
    DR. PERHAC: Yes, very definitely. Incidentally,
let me correct one thing you said. You said that I listed
the providing  of electricity  and providing electricity
reliably as the two most important special requirements.
No, they're not the two  most important. They're just
two of four that I listed.
    DR. WILLEY: They were the first two, then.
    DR. PERHAC: These were not in  priority order
necessarily. But they are—they are two important con-
siderations, but certainly not the most important.
    Yes, we're  certainly interested in more  efficient
supply for more efficient production. There's no ques-
tion about this, A major effort is devoted to more effi-
cient  production. I might add also that  we're moving
very extensively into the conservation area. So those
are two considerations.
    DR. WILLEY: My question was mainly consumer
efficiency in-use, more than efficiency of  production.
    DR. PERHAC: Oh, of in-use?
    DR. WILLEY: Yes. In other words,  does EPRI do
research on in-use efficiency?
    DR. PERHAC: Right now, very little; very little.
Again, it's because we have a finite budget and we see
enough problems to support just within the production
and transmission of electricity without getting  into the
in-use of it.
    We do consider it to some extent. As I mentioned,
we're looking into conservation within the homes which
has to do with energy use. We do have some small ef-
fort, for example, into electric cars, which is a use of
electricity. But the efforts are small compared to others.
    DR. WILLEY: Given the information that pres-
ently  exists and is being talked about nationally now
about the cost and financial advantages of increasing in-
use efficiency, wouldn't that  indicate or give you con-
cern with capital requirements for the industry that that
would be a top priority item?
    DR.  PERHAC:  Again,  I'll  give  my  personal
opinion. No. I don't think it is a top priority item.
    DR. WILLEY: Given your criterion,  shouldn't it
be?
    DR. PERHAC: Not if we consider the availability
of the money we have and the time-frame in which
we're thinking.
    DR. REZNEK: Doctor Perhac, I have some ques-
tions, one of which I'd like to explore a little bit, a sub-
ject you raised—maybe it's a little  unfair—the gasifier
question.
    1 personally have some feelings about  the dif-
ference in gasifier technologies which, to make a long
story  short, are the high temperature pressurized proc-
esses, burn out the polycyclics that are maybe car-
cinogenetic; they slag the ash, thereby binding heavy
metals;  and that low temperature ones have a number
of environmental disadvantages, which  we normally
associate with things like coke oven 6perations. 1 see
that those  environmental questions  should be fairly
important in the selection of the technologies that finally
get used.
    Your statement was that the primary view of which
technology should be used are not related to the envi-
ronmental  criteria,  but once it's  decided  on  their
economic or performance criteria or other engineering
characteristics,  then you  certainly  do  worry about
improving their environmental performance.
    This is a problem,  but it's a problem that many of
our witnesses have talked about;  namely, that you
define the -area in  which  you want  to develop. For
example, LURGY (phonetic) or so-called TEXACO or
Gallushia (phonetic) and then you  pursue a develop-
ment  area, development in those three or four  areas
and then sort of as an afterthought or as part of the proj-
ect itself, worry about the environmental controls, but
never ask the fundamental question: should I drop one
of the three or one of the four because it can't compete
environmentally with the others?
    Is that estimation reasonably accurate  of your
position?
    DR. PERHAC: Let me restate  the position and
see if that,  in part, answers your question.
    Our knowledge now of the adverse environmental
effects that may result from gasification technologies is
very  incomplete.  Doctor Richmond,  for  example,
pointed out some of the deficiencies in our knowledge.
    We do not feel that we are in a position to pass
judgment  environmentally on  any  of  the  specific
gasification technologies, that is, which one is better or
worse than the other in the long-run.
    As a result of that, we are not using the environ-
mental consideration yet in deciding which technologies
we will support as far as funding research. Again, it's
mainly because of our  ignorance of knowing what the
effects are. Therefore, we  are considering putting
money into a number of different technologies all  at the
same time, and at the same time, doing extensive envi-
ronmental work along with it.
    If at some point, we find that the  environmental con-
sequences of a particular technology are so adverse that
they cannot be corrected in any sort of economical or
reasonable way, then I think obviously, this would affect
considerably the extent to which we  would support a
technology.
    DR. REZNEK: Thank you. The second question,
you also touched on, which is a problem in designing
any research program;  a relationship between those of
us who are trained as engineers and those of us who are
trained as health specialists. You mentioned that within
EPRI you seemed to have worked out pretty well the
transfer of information on the health effects of fine par-
ticulates into the engineering program to develop con-
trols for fine particulates.
    Do you within EPRI have a separate environmental
engineering capability that would examine such  ques-
tions as the environmental benefits of using product gas
                                                   72

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                                                                                Statement of Mr. Paparian
of a gasifier to generate the process steam, versus using
the feed stock  which would be coal, to generate the
process steam? Do you have a separate environmental
engineering  division and does that division, if it exists,
help  close this  gap between  the engineer  and  the
biologist?
     DR. PERHAC: In answer to your question,  no,
we do not have a separate environmental engineering
division, as  such.  But we  have engineers within  the
fossil fuels division who work fairly closely  with  the
health effects and ecological people in the  environ-
mental assessment department.
     DR. REZNEK: And do you feel that that linkage is
working fairly well?
     DR. PERHAC:  Yes,  in  general.  Again,  you're
touching on an area that's very difficult. This is a ques-
tion of transfer of information between divisions,  be-
tween departments, between agencies.
     We  attempt to do as well as we can. How well
we're doing is open to question. Anybody might say we
could do better or we could do worse.
     DR. REZNEK: You've also  mentioned  that
throughout your budget about 50 percent is allocated to
environmental questions. 1 applaud that from my point
of view.
     Two questions: one, do you  feel it's important to
be able to keep your resource allocation  records and
your resource allocation procedures in such a way that
you can easily identify that percentage—reasonably ac-
curately and  reasonably easily  identify it; and second,
would you care to comment about whether or not you
feel the 50 percent average may be in the general ball
park of where you would like to see  DOE's split?
     DR. PERHAC: Let me answer the first question.
No,  it's not easy to identify the exact percentage that
goes  into environmental studies. For  example,  let's
assume that we're supporting research on a new elec-
trostatic precipitator.  Does one consider that  research
on environmental questions?
     DR. REZNEK: Yes.
     DR. PERHAC: Some people would  say no, that
isn't. That is  more technology. Or what if one is, for
example, doing research on an improved type of burner
that would say increase the temperature, thereby break-
ing down polycyclic aeromatic hydrocarbons. Is that an
environmental research effort?
    Some would consider it yes; others would say no.
So there are areas like that where it's hard to decide
whether or not it's purely an environmental subject or
an engineering, technological subject. The 50 percent is
an estimate and I don't think there's an easy way to pin
that down to a fine percentage.
    That takes care of the first question. As far as the
second question, the overall effort of the Department of
Energy—what's my opinion on that?
    Again, I think before I could answer that, I'd have
to know specifically under what time-frame the Depart-
ment of Energy is operating; what it considers its most
important time-frame?  Should its research effort be
focused on the near term, mid term or long term? If I
know the distribution of that, then I think I'd be in a bet-
ter position to answer how much I think ought to go in
environmental work.  Because I think it will differ de-
pending on the specific time-frame.
    DR. REZNEK:  Finally, I think my  last question
may be a trifle unfair, but let me return to your selection
of time-frames for EPRI research.
    The basic assumption that things change slowly,
isn't that perhaps a little self-fulfilling? In fact,  if you
don't  go after new and radically different technologies,
then,  in fact, it'll take a long time to get there?
    DR. PERHAC: Again, I'll answer that from a per-
sonal  opinion, not from the position of EPRI or the Elec-
tric  Utility Industry. In one word, no. I don't think it's
self-fulfilling. I think it's based on very careful analysis of
the  capabilities of society.
    DR. REZNEK: I'd like to compliment you on your
testimony. I thought  it was extremely well presented
and very well thought out. I'd just like to express my
appreciation for your testimony.
    DR. PERHAC: Thank you for this opportunity.
    DR. REZNEK:  Our  next  witness is  Michael
Paparian of the California Sierra Club.

Presentation by Michael Paparian
California Sierra Club

MR. PAPARIAN: Thank you. I am Michael Paparian,
Assistant Energy  Coordinator for the Sierra Club  in
California. I wish to thank the Environmental Protection
Agency and its staff for inviting me here to testify today.
    I'd like to start out with two quotes that'll put some
perspective on the nature of my comments today. The
first one is from  Alexis de Tocqueville  in his book,
Democracy in America: "The health of  a democratic
society may be measured by  the quality  of functions
performed by private citizens." Secondly, from Energy
Secretary Charles W. Duncan, Jr.: "I plan to maintain
an active and an open  dialogue with all  elements  of
American society  that have an interest in  energy mat-
ters, with public interest groups, consumer groups, en-
vironmental  groups,  labor  groups, industry  and
business groups, all interested  publics."
    I've come here not to assess the details of how the
Department of Energy operates—there are plenty  of
other  people in this room who have much greater ex-
perience than I in dealing directly with the Department.
Instead, I have come to offer a solution to many of the
criticisms that have been raised regarding DOE.
    A fundamental problem with the Department, as
well as many other government offices, is inadequate
attention to citizen involvement and  inadequate atten-
tion  given  to information dissemination. The new
Secretary  has shown  his eagerness to  invite  dia-
logue  with the public. I  hope  to  see this  come about
effectively.
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Hearing of October 4, 1979
    The purpose of today's hearing is to assess how
well the Department of Energy  takes  into account
energy conservation and environmental protection in its
programs.  Specifically,  the  Program  and  Policy
Management System is being looked at.
    The PPMS  was  designed  as  a  management
strategy to assist in ongoing evaluation of large projects.
It is intended to allow for review,  at specific stages, of
the technical, economic, and environmental factors of
each technology.
    Further, the PPMS is intended to ensure environ-
mentally responsible decisionmaking.
    These goals are admirable and proper for a well:
functioning process. However, there is one factor that is
ignored in the process—public review and scrutiny.
    The PPMS process has no formal mechanism for
involving the public other than at the  end when it is
mandated to meet the procedural requirements of the
National Environmental Policy Act. Because of this, the
process as a whole adversely affects environmental
considerations.
    At various stages in the PPMS process, documents
are produced to plan for further research  and develop-
ment or define and evaluate environmental factors. The
work that leads to the preparation of these documents is
important as it helps to determine where the project will
go and how it will be implemented.
    The Environmental Development  Plan is used to
review the major documents  and the provisions for
public review of them. This plan defines major environ-
mental  concerns  associated with  a particular energy
technology and  general environmental  research  re-
quirements for addressing those concerns. The docu-
ment is produced by the Environmental  Coordination
Subcommittee composed of Department  staff.
    It  is an internal document, with public access only
by request after it is produced.
    The Environmental System Acquisition Project En-
vironmental   Plan is used to  plan  environmental
research and development for a specific project. Again,
it is an internal document, with public access only by re-
quest after it is produced.
    Environmental Readiness  Documents review  en-
vironmental  status of the technology and serve as  for-
mal Office of Environment input  to DOE technology
development decisions.  They are  internal documents,
once again, with public access only by request after they
are produced.
    Environmental Assessments  and Environmental
Impact Statements are  produced to decide  if  NEPA
applies and  if it does, to produce further documents.
Public  review is required by NEPA, and therefore, hap-
pens, following the drafts of these documents.
    In all the planning, research, and development of a
project, the  public has no  access to the process  until
documents come out, and even then, there have been
many  complaints about the lack  of availability of the
reports.
    At the Pittsburgh Section  11  workshop held last
July, there was general agreement that mechanisms for
public participation and information dissemination are
inadequate.
    There was an expressed desire for a more open
process. However, a question was raised, "Does DOE
really want  public  participation?"  According to the
report on the workshops, "Some participants expressed
skepticism about this  and  said  that if information
dissemination and public participation do not appear in
DOE's budget, then DOE doesn't perceive them as a
priority."
    Similar comments were aired at all the workshops.
From Atlanta:  "Work group reports indicated general
consensus that public involvement  in the Program and
Project Management System was inadequate. . . . Many
participants felt that the public should be brought into
the process  earlier—by  the time  the public has an
opportunity to participate, primarily through review of
Environmental Assessments and Environmental Impact
Statements,  it is too late for their opinions to  affect
many important decisions."
    From Denver: "There was general agreement that
public participation in the project was inadequate . .  .
One group suggested that a set proportion of each proj-
ect's budget be set aside to support public participation
activities.  . . .  Several participants reported that they
had not been able to obtain documents through regular
channels."
    From San Francisco: "Most of the groups agreed
that better information dissemination was needed and
documents should be made more readily available for
public re view. . . . There is no systematic method for in-
volving local officials and citizens after siting decisions
are made."
    From Pittsburgh; "One work group summed up the
feeling of many participants in the statement that 'public
input seems to  get  lost  in  the maze  of  a  vast
bureaucracy.' It seems to go into a 'black box' and there
is no accountability to the public."
    It is this "black box" that shrouds DOE programs in
the eyes of many. It is very difficult for anybody outside
the organization to penetrate such a large and diverse
Department.
    Further, it is difficult for a Department employee,
who has primary responsibility for something other than
public participation, to be adequately sensitive  to the
needs of the public.
    In California, our Energy Commission has solved
many of  the  public participation  problems through
establishment of an Office of Public Advisor.
    The  Public Advisor is intended to,  (a) insure full
and adequate participation by all interested groups and
the public-at-large;  (b)  insure timely and complete
notice of all meetings and hearings is distributed to the
public; (c) advise groups and the public as to effective
ways of participating in commission proceedings; and
                                                   74

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                                                                                Statement of Mr. Paparian
(d) recommend additional measures to assure open
consideration and public participation.
    The Department of Energy has not shown much
effort to insure the type of public participation as is man-
dated by the California Energy Commission. Perhaps
the Department would do well to study the California
case and adapt such a program to its own needs.
    Such a program would help instill the public con-
fidence that the Department so desperately needs at this
time and would meet the needs expressed by members
of the various publics interested in DOE programs.
    The need for the DOE to expand  its efforts to in-
form the public and encourage their participation has
been shown by  the comments at the regional hearings.
The need is manifest in expressions of confusion of how
to enter the "black box" of decision making or how  to
extract information from the box.
    By providing a mechanism for public involvement
in all aspects of Department operations,  DOE can
realize the following benefits:
    One, issues and facts will be brought out early. By
involving  a   diverse  group  of  non-Department
employees early in any process, key issues can be
brought  out that may otherwise be overlooked until late
in the process. In many cases, these issues may be ones
that could cause long delays if left unchecked during the
program development.
    Two,  conflicts can  be  resolved.  Ongoing com-
munication with interested  parties throughout any pro-
cess can help to resolve conflicts  that would otherwise
have 'cast doubt on the validity of the  decisions made
within the Department.
    The opportunity for face-to-face  communication
can help to insure that conflicts  are  looked  at in a
rational manner with a common goal in mind instead of
being arbitrated in an adversary relationship later on.
    Three, there will be greater support for Department
actions.  By encouraging full public participation in deci-
sion processes,  DOE would have a basis of support for
the decisions. The  people  who helped to form a deci-
sion would understand the reasons for it and would help
to validate the outcome.
    There has been much cynicism expressed about
how decisions are arrived at in all government agencies.
Opening the decisions up to public scrutiny early would
insure that those interested  would understand how deci-
sions are arrived at and would help decisionmakers to
understand the  concerns of the public.
    Four, the public's demand for an increased rote in
government decisionmaking  will  be met. Much if not
most, of the present distrust in government stems from
the belief that the government is meddling in the lives of
our citizens without taking into consideration the conse-
quences of government action. Full public participation
can alleviate the concerns that government is regulating
without concern for the outcome  of the regulation.
     Five, there will be expedited process.  Through
dialogue,  concerns  will  be raised early and  in many
cases these concerns will result in modification in pro-
gram development.  Costly and time-consuming delays
will be avoided when the concerns of all are under-
stood and taken into account in the development of
programs.
     A public advisor for  the  Department of Energy
would serve the need of interested parties to participate
in decisions that affect them. A public advisor's office,
under whatever name, would serve as watchdog for the
public interest.
     It would both bring in the public to participate in
Department  processes and insure the activities of the
Department are made known to interested parties.
     The function of a public advisor's office  is a vital
one and as such, it  should not be treated  lightly in the
organization  of  the   Department.   It  should  be
autonomous from  all other departments and should
report  directly  to  the  Secretary  to   insure  its
independence and credibility.
    The budget of the office should be adequate to in-
sure that the office doesn't become a showplace with no
substance. In California, the public  advisor receives
roughly one percent of  the Energy Commission's
budget  and  has  roughly  one   percent  of   the
Commission's staff.
    Why  spend tax dollars on such  an effort? Many
would argue that those without financial resources have
just as much opportunity to participate as those who do,
and that an agency  should not spend funds to bring in
people to participate.
     It should be clear that without some expenditure of
funds, there is no way the Department is going to insure
public understanding and awareness of decisions.
    Further, those  who participate  from outside  the
Department as part of their jobs, are in most cases par-
ticipating on tax-deductible dollars. As such,  it makes
perfect sense to afford others similar opportunities with
tax dollars from the  government.
    A public advisor's  office  at  the  Department of
Energy would have  the following functions:
    One,  to be  a clearinghouse of information. The of-
fice would serve as a clearinghouse for information on
Department activities, programs, policies, publications,
etcetera.   The  office  would  be  a  place  for   the
public—here, I  define the public broadly to include all
interested  parties—be a place for the public to turn for
information on  what the Department is doing, how to
obtain information on specific programs and policies,
and what opportunities there are for participation in the
Department processes.
    The office would be easily accessible to the public,
with toll-free phone lines  and adequate staff to deal with
public inquiries. The office would also help the public
extract information  from divisions within  the Depart-
ment when necessary to do so.
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Hearing of October 4, 1979
    Two, to be an advisor to the Department on public
participation. The office would advise the Department
and its divisions as to the best ways to solicit and obtain
public input. The office would be the one to bring in the
public where opportunities arise to do so.
    The office would be aggressive in searching out
programs in need of public input and by insuring that
the public is brought in to participate.
    Three, to give advice to the public on how to par-
ticipate. In recognition of the fact that many people do
not have extensive experience in  dealing with the
Department, as others do, the  Department—the office
would  serve to coach the public on how best to  par-
ticipate in Department activities.
    This will help the public participants to effectively
convey their ideas and help to avoid unnecessary waste
of departmental staff time.
    Four,  to give  notice of hearings,  workshops,
etcetera. The advisor should be responsible for insuring
that adequate notice is given to all interested parties of
the date, time, and location of hearings of interest to
them. It is important that the public be given adequate
notice of activities and the advisor should be the watch-
dog to insure this happens.
    Five, to advise the Secretary on methods to insure
full public participation. The advisor should advise the
Secretary on how to  further facilitate and encourage
public  involvement. In areas where the Advisor does
not have the power to effect a change in procedure, the
Advisor should provide the Secretary with the informa-
tion necessary to make a rational decision on the issue.
    Six, to solicit input from interested parties. The Ad-
visor should identify those individuals or groups who
may have an interest in an issue and may not otherwise
be participating. These groups should be encouraged to
become involved in  appropriate areas.
    In many areas,  the California Energy Commission
has set up an advisory committee  structure to en-
courage early airing of issues and problems. These ad-
visory  committees have  ranged  from committees  to
assess  and recommend changes in specific  program
directions,  including  wind,  cogeneration,  and load
management programs, to committees that assess the
overall performance and direction of the  Commission
itself.
    By establishing  a formal participation and informa-
tion  dissemination  process as I have described, the
Department of Energy will better serve the need of the
public to be involved in the energy decisions that will be
important in the  next few years.
    The Department has a choice at this time—either
having business as usual with the probability that most
decisions will be  assailed or bringing in the public and
having a validation  of decisions that meet the public
need.
    Thank you.
    DR. REZNEK: Thank you. Jim?
    DR. MacKENZIE: As you know, the Department
of Energy has an Assistant Secretary for Environment
who produces  many  of  the  documents  you  have
referenced. I have two  questions relative to this office.
First,  has  the  Office  of  Assistant Secretary failed
somehow to carry out the responsibilities assigned to it
by law; and secondly,  in the various documents that
you've  referred  to—Environmental  Development
Plans,  Environmental  Readiness  Documents—have
you, in fact, reviewed them and found them to be in-
adequate or is it that there simply was no review by your
own group and others? Have you, in fact, found them
factually inadequate so that there really are grounds,
beyond public participation, for getting input into them?
    MR. PAPARIAN: I think the question becomes
whether or not the public should be involved in  these
processes and not one  of  whether the Secretary—the
Assistant Secretary for  the Environment has failed or
whether the documents have been inadequate.
    The Assistant Secretary  for the Environment has
done an admirable job, but  that person's job is limited in
that being within the structure of the Department,  it's
very difficult to fully understand what the concerns are
of the different publics.
    As to the specific documents that have been com-
ing out, I reviewed a few of  them and without going into
specifics, here, in  many cases with additional public in-
put from, say, a group such as my own, I feel that some
of their premises could have been different, some of the
things they emphasize  could have been different and
perhaps  some  additional  factors  could have  been
brought in.                                  •
    DR. WILLEY: I know at various points in history
over the last  5 years the  California Commission has
thought about and even several times  actually  done
funding of intervenor groups in specific proceedings.  1
haven't  watched that enough to know  how it turned
out. I'd just like to know whether you think the  Depart-
ment of Energy ought to consider funding of intervenor
groups on specific issues or specific proceedings?
    MR. PAPARIAN: Absolutely. It's interesting, a
study by the EPA several  years ago indicated  that 50
percent of  citizen environmental groups have annual
budgets of under $2,000.
    In cases where somebody wants to bring in an ex-
pert witness, say, an expert witness fee can range up to
about $1,000 or half the annual budget  of half the en-
vironmental groups in the country.
    As a minimum, in committees or hearings where
expert witnesses would benefit the process, the public
should be  reimbursed  to  bring them in. The public
should also be reimbursed for participation in  DOE
activities.
    DR. WILLEY: Just a follow-up.  Is the California
Commission continuing to fund particular interventions
by  outside  groups? When  I  say "outside,"  non-
governmental, non-industry groups?
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                                                                                Statement of Mr. Paparian
    MR. PAPARIAN: It has funded—in many cases,
the travel time  of  the  outside  participants.  The
intervenor funding issue has been open to debate within
the California legislature  and  a formal program  of
intervenor funding has not happened.
    What has happened, in many cases, though, is
where someone from the public has wanted an expert
witness brought in who would definitely benefit a pro-
ceeding,   the  Commission  staff  has   taken  it  on
themselves to fund,  as a staff witness, that expert.
    MR. MERSON: If we are permitted to look at the
political climate right now, I'd like to ask a question
about the California  Public Advisor.  With respect to the
length  of  time  the  permitting process now takes  in
California  compared  with the  process  prior to the
existence of that office, and keeping in mind the discus-
sions that  are taking place right  now about an Energy
Mobilization Board, there is some concern over delay in
the permitting of energy facilities: Do you, from your
own experience, have any comments on the process
being extended significantly by either intervenor groups
or the public advisor in California. It is a consideration
that we have to keep in mind with respect to the Federal
process.
    MR. PAPARIAN: I think  it's  an important con-
sideration  and I think it's my feeling that intervention
and early bringing in of the public has actually served to
expedite processes rather than delay them.
    In  many cases where lawsuits have been brought,
on projects, I think they could well have been avoided if
the public  was brought in  early,  their concerns
understood, and some of their objections met.
    MR. MERSON:  Do you have any data to either
confirm or refute that? I'd like to think that, too. I'd like
to feel that just as with the new CEQ regulations, where
we have a scoping process that tries to get everybody
who has a concern about a major Federal action in-
volved  early, that perhaps  we can avoid  some last
minute confrontations that tend to extend the process.
    Would the experience in California tend to either
support or refute that?
    MR. PAPARIAN: There was a mostly qualitative
study done by the Public Advisor which I don't have
with me, which compares the things the Commission
has done,  with some of the things that were  done
without some public input. I could probably get ahold of
that for you, if that's what you are looking for.
    MR.  GRISHAM: 1 have  one question,  Steve.
You've talked about  establishing  an office of public
advisor near the Secretary in the Department of Energy.
I've a question on relationship of other factors in this
process. It seems like DOE  is highly centralized in  its
operation. The regional offices have very little responsi-
bility or authority to operate or make decisions and,
therefore,  the States aren't involved as much as they
might be in the decisionmaking process.
    What benefit do you see in establishing these of-
fices of public advisors at a closer level to the people and
the groups that are interested in these problems?
    MR. PAPARIAN: 1 think it's very important and I
think—what I meant by establishing  it close  to  the
Secretary was to have the person in charge of the pro-
gram  not  associated with any other programs in  the
Department. The person's sole charge would be to bring
the public into the process.
    I would envision a decentralized operation. It's very
difficult working from Washington, D.C. to understand
what's happening in the various regions of the country.
In that sense, I would hope to see much of the activity of
the office  occurring at the local level and working di-
rectly with local participants in developing relationships
with them at the local level.
    DR. REZNEK: I'd like to expand on that a little
bit. I also wrote down questions of State and local rela-
tionships in the  public  information dissemination and
public review process.
    There have been  some experiments where  we
heard testimony on the cost of the workshops, which
endorsed them quite highly. I'd tike you to comment, if
you would—if you'd care to, on the question of a third
party  organization, either  coalition  of States or a
regional coalition or some  body, be  it composed of
other organizations at lower  levels of government or in-
dependently  established, to handle  this process  for
DOE, reporting back through the central authority the
public awareness office? Do you feel there would be ad-
vantages to that kind of, if you will, joint venture or
independent organization?
    MR.  PAPARIAN: Are you talking about such
third party groups advocating positions from the public
or bringing the public into the process?
    DR. REZNEK: Both disseminating the two points
that  you  made—disseminating  information  and
soliciting public opinion.
    MR.  PAPARIAN:  So  essentially the office  I
described would be a contract organization; is that what
you're getting at?
    DR. REZNEK: It would have that capability.
    MR. PAPARIAN: I mean in a sense, instead of an
office within the Department, it would be an office out-
side the Department; in a sense a  contracted office?
    DR.  REZNEK:  Weil, we  saw, for example,
several instances: one where the permit review author-
ity  was delegated by the Federal Government into a
single authority and that authority was, in this case, a
State  organization, namely,  Colorado.
    Colorado would take the lead in carrying through
the process for all permits; Federal as well as State, as
well as local. And through an interagency agreement,
between the  Federal   organization   and the  State
organization, the permitting authority was, for lead pur-
poses, vested in .a non-Federal entity.
                                                   77

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Hearing of October 4, 1979
    We saw another planning group which was com-
posed of a coalition of counties in one area supported
with DOE funds that carried on the public participation
and public planning function for geothermal.
    In many cases, we heard testimony that these were
quite  effective.  There was a case where there was a
Federal involvement, but the Federal involvement was
through a third  party.
    MR. PAPARIAN: Yes. I think it's vital to separate
public involvement activities from any research activities
or advocacy or permitting procedures. I think the office
or  whoever does it  should be  independent  of  the
substantive actions involved.
    You spoke of the geothermal case. In that case it's
the Gripps Commission in California, which essentially
is a planning agency which does geothermal research
and development, and works more directly with local
and State agencies than it does with the public. Their
work  is admirable, but they are more an extension of
the local governments than a public representative.
    I think it's important that an impartial person within
an  impartial office,  without any  preset  notions as to
what conclusions they are arriving at—that that type of
office be involved in what I'm talking about.
    DR. REZNEK: Would you compare that question
of impartiality for perhaps third party organizations ver-
sus actual members of  this field office  of the public
awareness office? Do you feel there might be  a  dif-
ference there? I'm not sure I'm making myself terribly
clear.
    MR. PAPARIAN: Yes. Could  you say that again?
    DR. REZNEK: There are  two  ways to pursue the
type of activity: one, to have this public awareness office
and have  Federal  employees in  the  regions and
associated within—with individual products or with in-
dividual regional processes or at the national level. The
other  way to do it would be to  operate it through third
parties; grants from the central authority to local groups.
Do you feel that  there's a difference in terms of  the
impartiality of operating either of those two modes? I'm
not saying that you should have only one mode—that is
do  everything through a third  party or do everything
through a Federal  employee, but at least you would like
to see a mix of modes and whether or not there'd be an
advantage of using one of the two in certain instances in
terms of impartiality.
    MR. PAPARIAN: If the third party group came in
without a really preset  accountability to a group such as
a local government  or a State government or an in-
dustry group or anything else like that, then I think it
would be fine.
    But if you bring in, say,—say you contracted with
our State  Energy Commission to do this. Then you
would  be contracting with  someone with more  of a
State perspective than a local perspective and would
open yourself up to criticism that you  are taking the
State concern more loudly than you are the local  con-
cern for the public concerns.
     I think it's vital that the office be independent of any
of those.
     DR. REZNEK: Thank you very much. I enjoyed
your testimony.
     I think we'll break now and we'll reconvene—let
me check  my schedule—at about  1:00 p.m. 1  was
tempted to ask whether or not your organization is one
of the under $2,000, but I'm not going  to.
     Oh,  yes. We have one more question from the
audience. It says there is a view that effective conduct of
government's business is effectively throttled by com-
peting activities of public interest groups. What does the
continued call for greater public participation mean with
respect to the system of elective representatives? I think
this is maybe two questions, if you'll allow me to inter-
pret: one is how do you see the relative roles of the
executive and the legislative in making  some of these
energy decisions, perhaps some of the larger decisions;
and second is a subject that we touched a little bit, that
there are competing public interest groups—industry is
certainly  one of them and  the  Sierra  Club may be
another—and does not the competition of these groups
necessarily  slow down decisionmaking?
     MR. PAPARIAN: Let me turn that around. It's my
strong view that bringing all of the interested groups in
on a particular project of issue, such as coal gasification
or such as air quality—by  bringing all  the interested
people in, you are letting their concerns be known early
so maybe they don't have to seek other remedies fur-
ther  on if the concerns aren't looked at early in the
process.
     As to  the—1 sense the  other half of the ques-
tion—to be looking at  our elective and appointed form
of government and  asking whether or not I think that
that meets some of the needs that I'm talking about. It is
very difficult for a public official to have a full under-
standing of each of the issues that are important to our
society, but by delegating some  of our governmental
responsibilities to our citizens, I think we are meeting the
needs of  the citizens more directly. That we're meeting
the needs of our citizens more directly. And we're  able
to address their concerns more directly than through a
structure  that insulates the public from the decision-
making.
     DR. REZNEK: Thank you.
     We'll reconvene at 1:00 p.m.
     (Whereupon, at 11:49 a.m., a lunch recess was
taken.)
                                                   78

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Afternoon  Session
                                                                            Statement of Mr. Reynolds
1:05 p.m.
    DR. REZNEK: We have a new member of the
panel.  Derry Allen will  be replacing Roy  Gamse this
afternoon.
    Our first witness is  Bob Reynolds from the Lake
County Air Pollution Control District in California.

Presentation by Bob Reynolds
Lake County Air Pollution Control District
in California

    MR. REYNOLDS: Members of the Panel, I want
to thank you for this opportunity to appear before you.
My name is Bob Reynolds. I'm the Director of the Lake
County Air Pollution Control District which includes
two-thirds of the California Geysers-Calistoga Known
Geothermal Resources. This area receives  a major im-
pact from air pollution as a result of twelve production
power  plants and associated development activities.
    Several additional  power plants are  in various
phases of construction and planning. Hydrogen sulfide
air quality standards continue  to be violated and viable
inexpensive technologies to mitigate this impact still do
not exist.
    As such, I am deeply concerned with the question
which these hearings'are being held to address. Has the
DOE RD&D  program  given  adequate attention  to
energy  conservation  methods  and  environmental
protection?
    From my standpoint as a public servant, charged
with enforcing  air  pollution control laws  in  an  area
where violations are common and ensuring acceptable
air quality in Lake County where it is not acceptable, the
answer must be an  explicit,  No!
    We  have  received  and continue  to need  the
assistance of both the DOE and the EPA, as well as our
State Air Resources Board and Energy Commission.
    Efforts of DOE, worthy of mentioning, include the
Lawrence Livermore Laboratories' activities in prepar-
ing an  overview document  and the resulting ASCOT
program. These programs were supported by the DOE
Assistant Secretary for the Environment.
    Also,  one  technology,  the  EIC   Upstream
Hydrogen sulfide steam abatement technology research
co-funded with  PG&E  should  be  noted.  However,
these programs lack complete  and swift followthrough.
They are not sufficient by any measure to provide timely
and  comprehensive  environmental  information  for
regulatory decision makers or the geothermal industry.
    We cannot assure adequate environmental protec-
tion if geothermal resources utilization is to expand as it
is presently anticipated.
    Several  relevant documents, in  addition to  the
previously mentioned overview, published by the EPA,
DOE, and its predecessor ERDA, etcetera, clearly in-
dicates air quality degradation as both  the most serious
environmental impact and most limiting factor to future
geothermal  development, especially  in the  Geysers
KGRA.
    Why then hasn't DOE  become  more aggressive
and put into place a comprehensive RD&D program to
develop control technologies to mitigate such impacts?
I certainly don't know the answer, but I suspect it may
be related to a lack  of awareness or sensitivity to  en-
vironmental issues at the top management level within
DOE. Perhaps it is a simple case of conflicting objectives
when top-level management is obligated to promote an
industry while admitting and addressing the constrain-
ing factors of detrimental environmental impacts.
    Because of this  latter factor,  I would recommend
that somebody within DOE's or EPA's  RD&D manage-
ment process be clearly identified as the advocate for
environmental concerns in  DOE projects and that they
be buffered  from  both  budgetary and subtle pressure
from within DOE.
    During our regional workshop the DOE program
and  Project  Management  System   was  discussed.
Though somewhat confusing, the system did appear to
address  environmental concerns. However,  several
participants as well as myself wondered if the system
really worked and if the Office of the Environment really
played a strong advocate role within the PPMS system.
    Many participants as  well as myself were con-
cerned about what criteria were used to make decisions,
why  was the  system apparently  secluded within  big
government,  and who or  what assures adequate
followthrough  once  decisions are  made and  the
necessary programs initiated?
    It is likely that  parties with vested  interest and
know-how to track and influence systems like the PPMS
are the only parties  outside DOE  who have  the
resources to  become involved in  and influence such
decisions.
                                                 79

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Hearing of October 4, 1979
    After considerable discussion, the consensus of our
workshop, after much muddling, was that the PPMS
simply did not apply to our problems, since our prob-
lems were not requiring $200 million to address.
    The DOE needs a very active program of catch-up
environmental programs enabling a full assessment of
problems and development of mitigating technologies.
They should not cost below amounts such as the type
PPMS covers.
     I also agree with the points summed up in the
prehearing document that DOE internal documents are
not readily available; that often even published informa-
tion doesn't find its way into needed hands; that a public
outreach program involving DOE staff is needed; that
public advisory groups for specific technologies should
be  established; that  DOE  should  sponsor energy-
environmental conferences at  the local  and regional
level—and I don't mean in Oakland, I mean in the areas
that are being impacted;  and  most importantly,  that
greater use of local expertise and DOE technical staff be
incorporated into selection and planning DOE research
and development studies.
     I mentioned earlier the DOE's Lawrence Livermore
Laboratories' overview project for the Geysers-Calistoga
KGRA. It recognized the needs mentioned above and
identified  H2S abatement  technology  RD&D  and
several additional priority research items.
     Has DOE completely followed through on this pro-
gram? In my opinion, no. DOE has initiated  the At-
mospheric Studies  of Complex Terrain—the ASCOT
Program—which is relevant to the nation and the
Geysers. The program promises to provide relevant and
useful information. We will interact (the LCAPCD), and
maintain our interest and hopefully play a role in seeing
this project to completion and trust DOE will continue to
support  this   program.  However,   in  the Geysers-
Calistoga KGRA, PG&E, who's the primary utility, has
selected,  financed and  generally  failed to achieve
needed H2S abatement technology. They are now pro-
ceeding with the EIC  process which initially  had limited
DOE support.
     Why is the DOE now pulling  out  of  this RD&D
and leaving PG&E to fulfill DOE's mandate, especially
when they have been so unsuccessful thus far? Why is
PG&E expected to develop  abatement technology for
its competitors? What will happen if the EIC process
fails? Why isn't an H2S abatement technology applicable
to all geothermal steam, which is clearly of national in-
terest, being  RD&D'd  by DOE? What  management
system made  these proceeding decisions? If there was a
conscious decision, why weren't the public, local or
state air regulatory agencies involved in these decisions?
     We should not wait until a developer-regulatory
controversy  occurs prior to  pursuing  technological
answers. Yet that is exactly how matters are occurring at
the Geysers.
    If any of the Panel members doubt this is the case,
they need only put themselves in an Air Pollution Con-
trol Officer's position where one must deal with an irate
applicant or public  simply  because viable mitigation
technologies are not available.
    Until  such  support  and  action  for mitigation
technologies are aggressively pursued on a timely basis
by DOE, my position necessitates the response that the
attention to environmental protection is not adequate.
    I certainly hope the DOE will be more conscien-
tious and aggressively  involved in conservation and
environmental matters as other alternative technologies
are realized beyond geothermal development  in the
Geysers-Calistoga KGRA.
    Another topic which disturbs me is industry's claim
that regulatory  bureaucrats are causing unnecessary
and unfair  delays. However, these delays have their
origin in the absence of environmental information and
lack of mitigating technologies.
    We are not necessarily delaying; we simply want
responsible development of the resources. Thus, DOE
misses  on the mandate of Public Law 93-477.
    Another concern of mine relative to these hearings
is that the Federal agencies commonly fail to realize that
a balance between national goals and local  environ-
mental effects must be reached.  I feel this can only be
accomplished by local involvements of Federal agencies
in the impacted geographical areas allowing decisions to
be made in concert.
    Once again, I wish to recommend that workshops
be held to address DOE regional RD&D programs of a
lesser and greater magnitude; identify procedures which
are utilized to  make decisions  on conservation and
environmental protection as part of these programs and
that DOE also be more actively involved in funding and
promoting H2S  abatement technologies for geothermal
energy. Finally,  DOE should identify resource people
or groups to advise local government.
    In short, DOE  should  let their technical staff  in-
teract more extensively with the environmental agen-
cies. A major  effort should be directed towards identify-
ing how the public,  local and State agencies  can
influence DOE processes.
    I thank Doctor Reznek and his staff for the excellent
job I believe they performed during the San Francisco
workshop,  and  especially for his willingness to redirect
the workshop when the attendees  made  it clear that
they were not as  interested in the PPMS system as in
simpler and less costly solutions and projects.
    Thank you.
    DR. REZNEK: Are there questions?
    MR. MERSON: I don't  want to take too much
time, but I don't have any real background on the pro-
ject that you  were discussing, the geothermal project
that you were referring  to.
    MR. REYNOLDS: The overview project?
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                                                                               Statement of Mr. Reynolds
     MR. MERSON: Pardon?
     MR. REYNOLDS: The overview project?
     MR. MERSON: Yes. I was interested in hearinc;
that in your view  DOE,  in  essence, pulled out or
delegated responsibility to a private utility for further
research on pollution abatement technologies. Is that—
     MR. REYNOLDS: That's correct.
     MR. MERSON: I'd like just a little more informa-
tion on that because I am concerned about that mode of
conduct and whether or not that—
     MR. REYNOLDS: Let  me regress just a second.
Maybe I can explain the complete background. An Air
Pollution Control Officer gets involved in many things
and just last Tuesday, in fact, I was over in Santa Rosa
where we were having a hearing. There were several
promising technologies discussed.  The EIC process is
clearly one of the more promising technologies at the
present time. It  was funded  to the tune of about a
million dollars by DOE. The  EIG corporation  itself put
some of the money into this project.
    Well, as soon as that technology looked a  little
more promising,  DOE, for many reasons—and some of
them may  be the fact that they didn't want to get in-
volved in a program where royalties may go to some
people or there may be some patent rights or there may
be  a  lot of complications—simply  lost interest or
whatever. I don't know how the decision was made.
    But now it's going forward with PG&E and EIC. As
the funding parties. As a result, the first thing that—
    DR. REZNEK: Excuse me. Is DOE removing the
money that they  originally put in the project or—
    MR. REYNOLDS: No,  it's essentially a pilot proj-
ect which is now at the next step, which is to demon-
strate  or initiate  and actualize  the  entire system.
There're a  few additional tasks to be done in the  pilot
project phase before they can go on to  finalizing the
power plant system.
    Apparently  as part  of  this process,  DOE  has
withdrawn and the EIC process— future development
will be funded essentially through PG&E and the EIC
Corporation.
    One of the subsequent things that happened  as a
result is that PG&E had to go back and get another
variance. I  heard that Joel Robinson mentioned there
were  no problems  in  the Geysers-geothermal area.
Those power plants have operated under variance after
variance. The Air Quality Standards are violated com-
monly. It's not like it happens once or twice a year, but
is violated by factors of two.
    This area that they're impacting, by the way, is an
area where there are resorts; church sanctuaries  and
childrens' summer camps. I mean it's not like they are
out in the desert. So you must have a better feeling for
the entire situation.
    PG&E has essentially, during this variance process,
as mentioned earlier, claimed that they could not get
the technology on line until 1985, at the earliest. I don't
 know whether DOE's going to be involved or is going to
 track that progress further. I seriously doubt if they will. I
 don't even know that I'll be able to track the progress as
 the EIC process has actually demonstrated.
     But the past H2S control technology history in the
 Geysers has  amounted to failure after failure. There
 have been four or five technologies that they've tried to
 apply and they simply haven't worked.  It is not possible
 to take an abatement  technology from one  industry,
 such as sour gas treatment in a refinery,  and stick it onto
 a geothermal power plant.
     These problems are not unsolvable, it simply takes
 time and effort. In fact,  if you look closely at the record
 you'll find that DOE's  Dr. Olehe Weres of Lawrence
 Livermore Laboratories warned that the surface con-
 denser, which is an integral part of the Stretford process
 they chose to use on several new  power plants, was
 unlikely to work if there is significant ammonia in the
 steam.
     However, people  concerned over the  develop-
 ment didn't really pay attention to him. But it turns out
 he was right.  They don't work. They're about 66 per-
 cent efficient, while everyone was  counting  on  them
 being 95 percent efficient.
     MR.  MERSON: What you're saying is  that this
 PPMS process, then, is not working as advertised in
 terms of—
     MR. REYNOLDS: No. The PPMS process, as  I
 understand it, only addresses  these $50  million and
 $200 million projects. Fifty million a year, $200 million
 in total; is that right, Steve?
     DR.  REZNEK: That's  right.  It  is addressing a
 major demonstration of the geothermal  technology, but
 it is not addressing the clean-up.
     MR.  REYNOLDS: Right. It's building  a power
 plant and everything else, but it's—well, I don't know.  I
 don't really want to get off the issue to what's happening
 in New Mexico, but that would be a good example of
 what the DOE is supporting. They're building a power
 plant—where they have identified right away  that one
 of the  environmental  constraining factors is  found
 to be that  New Mexico has an extremely low hydrogen
 sulfide standard—about one tenth that of the state of
 California.
     So the way they're  going to resolve this problem,  I
 understand at least, is by trying to  have the standard
 changed. Whereas they really ought to seek  different
technology on that line.
     Now,  that's something I'm not really that aware of
and do not care to put  forward to this Panel as a fact,
okay. But  that's the way I understand the situation.
     I have talked to Ron Conrad from New Mexico and
he is concerned  with efforts to relax their state H2S
standard.
     MR.  GRISHAM:  Just to set the record straight
 on that, it's  about a $100 million project,  between
 Union Oil Company, the Public Service Company, and
                                                  81

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Hearing of October 4, 1979
New Mexico. And it seems like DOE has a great deal of
trouble with geothermal projects. In the EIS work, they
didn't involve the Indian tribes in the area, and where
the well was going to be sunk was right in the middle of
a sacred area, a very sacred area for them.
    The hydrogen sulfide is a problem. It looks like the
agency will not give a variance there, and so the indica-
tions I had Monday before I left to come  up here was
that  DOE will probably pull out of  the project. So
they've left that one fairly well where it is right now, too.
    DR. WILLEY: This is not so much a question as a
comment. It seems to me that what you're saying is that
at least with respect to geothermal and the kind of
geothermal in the Geysers area, that DOE, for whatever
reasons, hasn't come to a point  where it's put enough
money into abatement to make a meaningful abatement
program to go alongside the development program.
    I guess what I'm  wondering is if this is an example
of a lack  of coordination of DOE  with  the National
Energy Plan? If we look at the overall national needs,
and we look at some of the information on the availabil-
ity of geothermal potential in the western U.S.—not just
in California, but in  New Mexico and Colorado  and
Utah and other areas—we'll see tremendous potential.
Maybe what we're saying is  that at the highest level,
which is the National Energy Act and National Energy
Plan, that DOE has not, for whatever reasons, looked at
the overall potential of  geothermal and funded abate-
ment accordingly.
    MR.  REYNOLDS:  I definitely  agree  with  that
statement. That was my point. If you go back to DOE's
own documents and those produced by the Lawrence
Livermore Lab that  was supported by the Assistant
Secretary for the  Environment of DOE. The facts are
there. The priorities are there. DOE just isn't pursuing
them.
    I don't think we need to demonstrate, for instance,
in the Geysers areas, how to build a power plant. PG&E
has done a fine  job of that. They've built plenty of
power plants up  there.  The problem is to demonstrate
how to mitigate the impact of those power plants.
    The ASCOT program, which is one of the resulting
programs of the overview and scoping out of the KGRA
problem is a study of the complex terrain. It turns out
things  are never  simple whenever  you go out to do
something new. This study should provide the first com-
plex terrain model.
    One problem is the fact that we really don't know
where the air emittants are going. There are several air
pollutants that are of concern in geothermal develop-
ment, especially in the  KGRA. One of the worst ones,
of course, is hydrogen sulfide because every person up
there has their own monitor and often feels like com-
plaining. Lake County, rather than accept complaints,
just simply mails out a monthly survey where people
can circle the day and the month on which they have  a
complaint and mail it back.
    There's also Radon 222 coming from geothermal
development. We really don't know how extensive a
problem that is  yet.  The ASCOT project will, in part,
help address that problem. They'll begin to develop a
model that we can use to help find out where the air
pollutants are likely to be going and what receptors are
likely to be impacted. I would certainly hope that we
continue that program in a rational fashion. I  would
hope that DOE will also get into mitigating technologies.
     DR.  REZNEK: One—several  witnesses  have
commented  on the  relationship  between  the en-
vironmental interests who are normally represented by
people trained in biology or atmospheric processes or
that type of discipline as opposed to developers, who
are  usually  engineering-oriented. We've  had  some
discussion yesterday on institutionalizing the engineer-
ing interest in finding mitigation solutions.
     It's my understanding that the EIC process is, in
fact, funded out of the organization in DOE that is
responsible for energy development, and not the Office
of the Environment.
     Would you care to comment  on  the—on any
observations you might have on institutionalizing the
engineering expertise in mitigation programs? Would
you prefer to see it separate, combined  with?
     MR. REYNOLDS: You know, I really have got to
be  honest  with you.  Programs  aren't  what  make
things—it's the intent; it's the spirit of the people carry-
ing them out.
     So if institutionalization quiets that spirit, lowers the
enthusiasm and makes a situation where you have com-
peting  objectives and  one of  those  objectives  is
competing with environmental concerns, then I  would
say don't institutionalize it. But if, in fact,  they can coex-
ist  with the management process by  themselves,  I
wouldn't have a preference, just as long as the problem
is addressed.
     DR. REZNEK: One of the—another question I'd
like to ask is the same type of question. Geothermal, in
particular, is at least presently allocated to certain very
specific areas of the U.S.  and yet,  decisions on the
geothermal program are being made in Washington, to
some extent.  Do you feel  the regionalization of deci-
sionmaking authority within DOE would be helpful in
dealing with problems such as yours?
     MR. REYNOLDS: I definitely do. You know,  I
have contact with Cal Jackson, for instance, and those
people sound like they are interested, and I believe that
they would do as much as they can, I think that would
help an awful lot if you're talking about a local agency.
     You've  got to  understand  the  contraints  we
operate under. Just the cost of coming back here to
Washington would  wipe out 80 percent of our travel
budget. We can't even go to Oakland on a regular basis
and it's just unreal to think that we can be involved, et-
cetera, with some agency back in Washington. We can't
                                                  82

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                                                                              Statement of Mr. Reynolds
even afford to call you. So my response to that would
be yes
    DR. MacKENZIE: You indicate quite forcefully
the lack of resources for the abatement technology. Do
you have any idea  how much money DOE put into
developing, the power plant itself?
    MR. REYNOLDS: In this particular instance, they
put none.
    DR. MacKENZIE: So if they put none in, then
PG&E developed the  hardware for the  plant, whv
shouldn't PG&E develop the  hardware for the scrub-
bing?  I mean, I'm just curious  as to why—
    MR. REYNOLDS: Why I feel they shouldn't?
    DR. MacKENZIE: Yes.  I mean-
    MR. REYNOLDS: Well, part of the Energy Plan
for the nation, as I understand it, is to utilize geothermal
energy quite extensively. Okay, PG&E is just going to
solve their problem, and they're going to try to get their
investment back. Their problem is one with regulators
right now. It's not one with solving the national energy
problem.
    A good example  is that if they had  an upstream
abatement process  which could  be applied to  flash
steam, Geyser steam, etcetera, it  would be very much
in the national interest since a lot of problems that are
intertied, such as the  abatement  technologies, would
remove such  things as CO2 or at least give you an op-
portunity to remove those things. That's probably going
to be essential if you're going to use hot water resources
and flash steam as a method of producing electricity.
    I  don't think PG&E should be'put in  a position
where they have to decide whether to proceed to abate
a plant or to shut it down. It may turn out that abate-
ment  technology is  too expensive and PG&E would
choose to just not build or to decommission a  plant.
That puts pressure on people like me when technology
might have solved the problem.
    I'm in the position of letting  them go ahead and
operate the power plant at some lower level or essen-
tially be the  one that's responsible for shutting down
what a great number of people generally conceive of as
being a very useful alternative energy—one that's going
to be on-line soon.
    So my response to you would be that PG&E is in
the business of producing power.  They shouldn't be in
the business of developing abatement technologies. I
think that clearly falls on some Federal level like DOE,
when  it's in the total nation's interest.
    I think it's kind of a limited view when you feel that
the DOE also has to build a power plant before they can
research mitigating technologies.
    The way  I understood the law that we're discussing
here today is  that it is to  bring on nonnuclear energy
forms that are environmentally acceptable. Now, if you
can  accomplish that  by   developing   mitigating
technologies   and PG&E and Union  76  are  smart
enough to figure out how to get the steam  out of the
ground and plug it into a turbine, maybe all DOE has to
do is learn how to mitigate those environmental impacts
and you've got your clean alternative energy.
    DR. REZNEK: On the same line, would you like
to see DOE budgeting procedures  clearly  delineate
where  they  are  spending  engineering  efforts on
mitigating technologies  and  where they're spending it
on development technologies?
    MR. REYNOLDS: Yes. I think that from the last
question, I clearly would. I think there're two types of
projects that we're talking about here, at least that I'm
talking about. I understand DOE's position where they
must look at the whole project every time  they fund a
project, but what I'm saying is you need both kinds of
projects and they don't necessarily have to  occur at the
same geographical site.
    So, yes, I would.
    DR. WILLEY:  I have a question which is kind of
related to what Doctor MacKenzie was  talking about.
Isn't part of the problem in California or any State that
the State—in this case, the State Air Board, which I
think is the umbrella organization for the Lake County
Pollution District—
    MR. REYNOLDS: That's right.
    DR. WILLEY: —sets its own standards. In this
case, hydrogen sulfide.  It raises kind of a paradox in a
sense for DOE which is that if a State or a locality wants
to set  environmental   quality  standards that   are
somehow stricter than, say, the national  average,  then
what should DOE's responsibility be in funding abate-
ment technologies to meet those stricter standards?
    In other words,  if a locality wants to pursue higher
environmental quality, then in some sense, part of the
burden will have to rest on them. Now, how that works
its way out—whether it means DOE has a process of
giving localities money to fund research on their own, to
pursue higher environmental quality, I'm not sure,  but it
is a paradox that's unresolved in my mind.
    MR. REYNOLDS: There are two things I would
say, okay. One is that probably what will  happen if you
take  that approach, is that they only have  to get some
mitigating technology that cuts off at Point A, which is a
Federal level, not Point B, which is a State level or  Point
C, which is a county level. Each of these agencies can,
as you know, make rules that are more restrictive.  They
can't make rules that are less restrictive.
    Well, my response would be that DOE, if their real
mandate is to put energy, clean energy on line, should
be to address the mitigating measures—what is at-
tainable technologically? In  other words, they should
provide technological answers. I think the local agencies
and  the  State agencies can try to compromise and
understand actual needs. At times, Air Quality degrada-
tion will have to be allowed. I think it's occurring right
now.
    But there's no way you can expect organizations
like the Lake County Air Pollution Control District to
                                                  83

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Hearing of October 4, 1979
develop some mitigating technology other than those
required of the industry, and the State. The State Air
Resources Board budget, the whole research budget, as
I understand It, is about $3 million. It's nowhere near
the $20 billion you're talking about in this bill.
    Therefore, they cannot develop those mitigating
technologies and as such, their response will commonly
be—I don't know if you're that familiar with processes in
California  with the California Energy Commission and
the Air Resources Board—not  to allow irresponsible
development. If that conflicts with the Federal Energy
Plan, I guess they'll have to be resolved in the best way
possible.
    I think there are technological answers and that's
what I'm here today trying to say. 1 believe there are
technological  answers to technological problems and  I
really think if DOE gets aggressive and puts a lot of at-
tention towards  environmental  impacts  then those
problems will be resolved.

    DR. WILLEY: I take it that you don't think it's
feasible, then, to have,  in this case, PG&E, pursue the
particular  type  of   abatement  that's  necessary to
Geysers—
    MR. REYNOLDS: They are doing it. I'm afraid
that if it's not feasible, it's  not going to be done. That
would be my comment.
    PG&E will pursue it. They're committed, hopeful-
ly! Geothermal energy, as I understand it, and I think it's
correct, is quite economically  attractive.  But  PG&E,
you ought to understand, also has competitors who are
up there—the Department  of Water Resources and the
Northern  California Power  Association. PG&E  is
developing the technologies for them as well and PG&E
isn't in a hurry.
    I think that mandate clearly lies at  the  Federal
levels.  My understanding of the law  is that if  nothing
else, DOE should be involved in that process. If you
don't fund it, you should at least be assured that they're
doing it for you. Right now I don't know if that's hap-
pening. Maybe it is.
    EPRI is  currently  funding the  Courey  process.
There're people involved.  I'm not trying to say that no
one's paying attention.  I'm here to say that DOE could
put a lot  more attention  into geothermal energy and
H2S abatement in particular. This sentiment is shared by
the other Air Pollution  Control Officer in the area. He
also believes that DOE could have found an answer two
to three years ago or at least have started a program that
was aimed at finding an answer.
     If you look at the Geysers KGRA  overview,  it
clearly recommends that H2S abatement technology be
pursued as the overwhelming priority.
     My considered  judgment is that  it's just a lack of
followthrough at this point. 1 think that eventually the
mitigating technologies will be there but meanwhile we'll
have these undesirable environmental impacts. We'll
have unnecessary delays as far as some people are con-
cerned and very necessary delays as far as other people
are concerned. 1 think if you really want to go forward
with a lot of these alternative technologies—and I don't
think the Geysers KGRA is going to be any less difficult
than other technologies as they come on  line,  like
gasohol—then you've got to start programs before the
conflicts occur.
    In general DOE has an excellent technical staff.
The university and national lab research centers are also
quite excellent and it's a crying shame that they're not
being directed at those problems.
    DR. REZNEK: Thank you very much.
    Our next witness is Jane MacGregor  from the
Atlanta League of Women Voters.

Presentation by Jane MacGregor
Atlanta League of Women Voters

    MS. MacGREGOR:  Thank you for this oppor-
tunity to address the hearing today.
    The League  of  Women Voters  believes that
government policy, programs and performance must
include coordination among the various agencies and
levels of government.  It must also include  well-defined
channels for citizen input and review.
    It  is from this viewpoint I will address the Depart-
ment of Energy's decisionmaking process.  The League
of Women Voters  of  Atlanta-Fulton County, Georgia
recommends specific avenues for public participation.
    Citizen  input  is  limited  by  the  public's lack of
knowledge of what DOE is doing, what research and
development is  funded,  and in  what  stage  is the
research and development.
    What are the choices that need deciding, their
costs—financial,  environmental and human—and their
limitations in solving energy needs? The public should
also be informed on contracts awarded and the criteria
for those awards.
    Public information should not be just for a general
audience; it should also focus on those most interested
and affected. It should address other Federal agencies,
political officials on the State and local level, public in-
terest and civic groups, industry, labor and academia.
     In terms appropriate for the particular  audience,
DOE could utilize news  releases,  public service an-
nouncements, and a periodic newsletter and magazine.
    The informed public must have a mechanism for
voicing their opinions  and concerns. Technologies that
have reached a  point for decision could appropriately
be discussed in a workshop format, possibly followed by
formal hearings.  DOE must then respond to these opin-
ions by considering them in their decisions.
    The Energy Systems Acquisition Advisory Board,
ESAAB, which  authorizes each  successive phase of
technology development, is the logical place to utilize
public  opinion.
                                                   84

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                                                                             Statement of Ms. MacGregor
    First, the League of Women Voters of Atlanta-
Fulton County believes that ESAAB, which includes the
DOE Under Secretary, several Assistant Secretaries, the
Controller and Director of Procurement and Contracts
Management, could better consider the  various social
and environmental factors contingent on an  energy
system if the board was broadened to include other cofi-
cerned agencies such as EPA, HEW, the Department lof
Labor and Commerce.                           j
    This involvement of other departments not oijily
helps consider all the factors of energy decisions, it a|so
helps  coordination among the various agencies to ex-
pedite the chosen technology developments.
    This broadened ESAAB should hear a pro and con
presentation  which should include the opinions from
the workshops and previous  public  hearings.  Direct
testimony could be given by national  industrial, labor,
environmental and public interest organizations.
    The  League understands that  an Environmental
Impact Statement is not always considered necessary.
We believe that such a statement would be beneficial
under all circumstances, and the EIS should incorporate
the Environmental Readiness  Document prepared by
DOE's Office of the Environment.
    It appears to the  League of Women  Voters  of
Atlanta-Fulton County that DOE's decisions are based
on information from  internal sources and there is no
channel for the interested public or agencies to affect the
decisions or participate in the choices. Yet, what is the
purpose  of  the  energy  development?  The  energy
development  is ultimately for the promotion of social
well-being, the benefit of our  nations's populace as a
whole.            •'
    Therefore, it is inappropriate for DOE to be  making
unilateral decisions.  All the impacts of a particular
energy source should be investigated  and considered,
and the input of all affected parties should be included
as early in the development as feasible.
    In conclusion, let me reiterate the League's basic
stand for coordination among government agencies and
the levels and well-defined channels  for citizen input
and review. It has been said that democracy is govern-
ment by discussion and that public policy does not rise
above the level  the  public understands, tolerates  or
demands. If we are to move in  new directions, we must
have information and discussion.
    Thank you.
    DR. REZNEK: Thank you.
    Are there questions?
    MR. GRISHAM: I interpret your remarks as sug-
gesting, then, that ESAAB become to some extent an
interagency board—
    MS. MacGREGOR: Right.
    MR. GRISHAM: —rather than strictly a function
of DOE. I'd be interested in your reaction to the com-
ments from a gentleman this morning if you were here
when  the gentleman  from  the Sierra  Club spoke. He
suggested—I think he called it a public advisor—to the
Energy  Department basically to  sort of represent  a
broader array of interests,  parallel really to your con-
cern. Somehow in the process, in an early stage, there
be raised a number of issues that might not otherwise be
factored into the process that early.
    Do you  see a  need for some  external force
somehow  in addition  to other bureaucrats, other—I
mean, after all, EPA is another Federal agency and you
were suggesting, I  think, that you broaden it by in-
cluding  agencies that might have somewhat different
perspectives.
    Would you favor broadening  it even further to the
extent of perhaps introducing an institutionalized voice
of the public?
    MS. MacGREGOR:  We discussed that among
ourselves and  could  not decide  how such a person
should be selected.  So, therefore,  we limited ourselves
to the bureaucrats in the broadened participation on the
ESAAB board; however, the public voice in the pro and
con presentation would, in  effect,  give the direct public
input.
    MR. GRISHAM: You'd open up, in essence, the
deliberations of that body so that there was participation
generally by the public in its—
    MS. MacGREGOR: We want to make sure that
the ESAAB board hears not only  the good things, but
the bad  things about our energy system.
    MR. GRISHAM: Thank you.
    DR. REZNEK: There  was some testimony yester-
day that indicated that rather than structure along the
lines of major energy acquisition that the review of pro-
grams and projects fall within a structure that looked at
in-use  demands—for  example,  home heating—and
looked at  all possible ways of fulfilling that demand,
including conservation,  gaseous fuels, liquid fuels or
electricity,  than to lay out  a program to  evaluate the
relative competition of those in the future and then the
relative  usefulness of Federal investments in each of
those alternatives.
    That proposal  yesterday seemed to  have  certain
attractive features and I assume would be quite com-
patible with your view, that there should be a represen-
tation of a wider participation in the review, rather than
a wider  participation in just the question of whether or
not to continue to invest in  a larger—in a purchase of a
larger scale technology.
    Would you care to comment on if the ESAAB were
reviewing the relative importance of supply, demand
and various types of supplies for  a particular fuel use
rather than the question of  actually purchasing a larger
version of a gasification technology; would you find that
more  attractive and a more meaningful  decision for
public involvement?
    MS. MacGREGOR: It certainly seems logical that
you look at needs before you decide the systems. Public
involvement could  be in either by just reviewing the
                                                  85

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Hearing of October 4, 1979
system to be acquired or by looking at the demands. I
don't see that public involvement should be limited, in
either.
     DR. REZNEK: Okay. Our next witness is Dick
Pratt of the Pennsylvania Sierra Club. I've got to make a
phone  call. Alan, could you chair for me, please?
     Thank you.


Presentation by Richard Pratt
Pennsylvania Sierra Club

     MR. PRATT: Thank you very much. My name is
Richard Pratt. I chair the Pennsylvania Chapter of the
Sierra Club and professionally I'm a physicist. In both
capacities, I'm concerned with many of the issues that
are being addressed here.
     As a participant in the Pittsburgh hearings, I'm also
here to reiterate the concerns which  we expressed
there. I believe that those workshops, at least the ones
we attended, were  educational. It would have been
helpful, I believe, if after those  workshops had had a
chance to formulate  questions and think about the sub-
ject, we could have heard some  DOE response, as well
as to have some idea of the  extent to which  DOE ac-
cepts EPA's characterization of the DOE Environmental
Program.
     However, I think this simply underlines  the main
issue or the main point, namely, that we as a public
have no independent knowledge of DOE activities.  We
can see that DOE is not involving a wider public in the
decision making process and it's our view they should be
doing so and doing so very early.
     Early participation outside the agency, we believe,
is necessary for the effective  management of any pro-
gram which is  ultimately going to impact the public.
Now, later, the public has its say and, often, that is inef-
ficient  and leads to  many delays, which could have
been prevented if this much  broader public  input had
begun  early.
     Now,  I  should also  say, turning then to  the
substance of what we covered in Pittsburgh and what is
to be discussed here, that I believe the EPA summary
document  prepared  for  these hearings  quite  well
describes most of the concerns that were brought up in
Pittsburgh, both the general concerns and those related
to specific technologies discussed there.
     Although the focus this year in these hearings is on
the management of specific technologies, it seems in-
evitable that one, to some extent, has to begin with a
prior question of how environmental concerns are being
addressed in energy policy planning.
     I understand this to some extent was explored last
year. Certainly one needs to talk about the strategies of
conservation and the decisions among technologies, the
priorities for use of renewable resources, the  impact of
large-scale versus small-scale technology and the like.
One can't totally forget about that even if one wants to
concentrate  on  the  management  of  specific
technologies.
    But for our purpose today, in this regard, it seems
to me the question is: How are such more general con-
cerns identified in the course of the management pro-
cess and then fed back  into the  policy process.  I
presume  both of these processes are going on, and one
would hope that what is learned about environmental
concerns in  a particular technology  doesn't just stay
within the  confines  of the  development of  that
technology,, but gets fed back into the more general
policy issues of which technology should be developed
and pushed and at what rates, with what resources and
the  like.
    My second area of concern is what I understand
the  main  question here to be, namely, the general DOE
process  for  including environmental concerns in its
management techniques. 1 believe it is really difficult to
judge or  answer that question fairly from the outside
and without hearing some DOE response to the analysis
which the EPA has provided the public.
    It seems clear that that process is systematically
structured. What  is not clear is  whether the process
functions or simply exists  on paper. It is not  clear
whether that process suffices to protect environmental
concerns. We  saw no guarantee that an identified en-
vironmental problem must be dealt with, that a mitiga-
tion strategy must be adopted, and so forth.
    It was not clear to us that the process identifies
necessarily the needed  environmental research related
to a given technology or, if it does identify it, that it pro-
ceeds to  accomplish it  or, if it accomplishes it, that it
proceeds to  integrate the results into actions in future
decisions. Nothing in the structure indicates that this is
necessarily happening.
    It is also not clear whether this process doesn't, in
fact, create incentives for the managers of technologies
to proceed with the development of those technologies
rather than hesitate in view of possible environmental
consequences  as they come to light. It's not clear that
there is any real incentive for a manager whose future
depends  probably on his success in developing one of
these projects in saying  no, I think those matters are so
serious we'd better slow down what I'm doing.
    A related  issue which did not seem to have been
addressed at all concerns the Office of Environment
within DOE. What is its structure? How does it function?
It certainly doesn't  seem to be remarkably visible to the
public. We have  no real sense  of its  resources, the
caliber and strength and numbers of the staff. Those
issues we did not get any feel for, and it seems to me
that one  cannot discuss the  process without knowing a
bit more about the office that is so intimately involved in
that process.
    My third point, which I believe a number of other
speakers  have touched on, is the issue of public par-
ticipation in  the process or even the participation of
                                                   86

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                                                                                   Statement of Mr. Pratt
other agencies and technical resources. It seems clear
from the description, at least, that such participations at
present are minimal and that they should include ad-
visory groups, not just for the environmental section,
but for other offices within  DOE.
    It seems clear that such participation should include
opportunities to review studies, recommendations, op-
portunities to comment, if not participate, and we think
there should be many forums for participation. I don't
want to assert that there should not be DOE decision-
making points that are DOE responsibility.
    We do  think,   though—if  there  are  such
points—there should also  be explanations and  view-
points on-the-record related to ultimate decisions which
DOE chooses to make.
    In discussing participation, so  far what I've said
could apply  nationally. It is clear that  DOE should
devote  more attention also  to  the  regions  and  to
localities and to more systematic involvement, hopefully
in a  non-bureaucratic way,  of  the  many involved
publics.
    The last of these general questions that we raised in
Pittsburgh, and I don't believe it's been resolved yet, is
where are we about to go?  To what extent will the new
proposals, now being considered in the Congress to ex-
pedite  energy development,  at the same time protect
and assert and assess the legitimate environmental con-
cerns? That is, to what extent are these new proposals
aimed at bureaucracy, red  tape and the like, or at the
substance of our environmental concerns?
    Here we could, I suppose, ask what lead  is DOE
and its Office of the Environment taking in making sure
that expediting is done in the first sense. That is, cutting
bureaucracy red tape,  rather than the second—that is,
short-cutting the environment.
    Finally,  I should say a word about the particular
concerns of  our own area and our own workshop  in
Pittsburgh, in the field  of coal liquefaction and gasifica-
tion, which of course,  is of great interest to us.
    We have a sense, which was not dissipated in the
workshop, that the technology is being rushed at the ex-
pense of economic and environmental  costs. We have a
feeling that scale-up is proceeding too rapidly before
considering  impacts   in  terms  of  waste  disposal,
transportation,  byproducts,  air  and  water  quality,
community infrastructure—in  other words, premature
commercialization.
    We would like to  hear more of the implications  of
the earlier DOE finding, that there was a 50 percent
chance  that this technology will violate environmental
regulations. If there's a 50 percent chance, it suggests
one should maybe go a little more slowly than we seem
to be.
    Once  again,  with regard  to  these particular
technologies, we feel a great lack of public participation,
a great lack of any discussion with the various publics  of
our region, of our area, of any of these issues.
    Thank you.
    DR. REZNEK: Thank you.
    Are there any questions?
    DR. WILLEY: I was interested in your comment
on perceived lack of incentive of project managers to do
anything other than pursue full-scale development. At
least in theory, isn't the project managers's incentive to
comply with environmental standards the fact that en-
vironmental standards exist and that he has to assume
that his  technology will, if it's going to be operational
and pursued, comply with standards?
    MR. PRATT: I don't know that it's an incentive. It
is certainly a requirement or duty. But the incentive of
the manager is to push on, I would think, and hope that
things will work out. If there's no incentive to wait or to
go slow, you push along with the technology and you.
hope  along the  way that you will either change the
regulations  or find a way to meet them.
    DR. WILLEY: I  see. So your perception is that
environmental regulations aren't a constraint as far as
managers go?
    MR. PRATT: They are constraints; they are not
incentives. I was speaking of incentives to a manager.
    DR. WILLEY: I  suppose what we  observe now
with  the  overriding environmental regulations would
support your  hypothesis?
    MR. PRATT: Yes. I should think so.
    DR. REZNEK: I'd like to follow that a little bit. It's
a nice idea to say  that when  an energy technology is
developed and introduced that it should be optimized or
reach maximum performance, both environmentally
and in the economic or energy yield or energy produc-
tion area.
    Yet, if you try to  explore that concept very far, it
becomes quite difficult to expect a single manager to in-
terpret what it means to optimize environmental per-
formance as  well  as  economic performance  of the
energy technology.
    Do  you  have  any suggestions for how  to incor-
porate an  ethic that  says  the number  of particular
energy facilities you're going to put in a particular area is
as limited by  environmental constraints as they are by
availability of pipes and steel,  and  that, therefore, an
important  role is  to  assure  that  the environmental
aspects  are   minimized—environmental  detriment
aspects  are  minimized  as well  as  maximizing the
economic performance? Is there a way of doing that
better than  is currently done?
    MR. PRATT: Let me  comment in two ways on
your remarks. First, more as  an aside, of course, the
requirement in putting  a technology on-line  is not
necessarily  to optimize its handling of environmental
matters,  but  simply  to  meet  some   "minimum
standards." Regulations don't say what we would like so
much as what is the least that we can deal with. Natur-
ally, one would hope in the long run to go beyond those
standards, especially as our experience usually teaches
                                                  87

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Hearing of October 4, 1979
us that we discover further problems  which require
tighter standards.
    Commenting  in  a second way,  more to  the
substance of your question, 1 think that  you must pro-
ceed in parallel, back at the policies stage, with the deci-
sion to develop a technology and to look at the alter-
natives, at the  same time. You cannot,  as you say,
expect that the same person who is pushing the utiliza-
tion of a given technology or the building of a given
plant  is going to be the one who is going to have the
greatest concerns with whether this power could have
been provided some other way or through some other
technology or was it needed in the first place.
    So what you need presumably is a system which is
a little more balanced in its branches, between branches
that are building things and branches that are consider-
ing alternatives, rather than having a whole agency, let's
say, whose mission it is to build and secondarily to do
the best it can with the consequences. It seems to me
you need a more balanced situation, where at the same
time you are setting your energy priorities and energy
goals  and  your  environmental priorities, your  en-
vironmental goals, and then you look at those on the
same footing and try to ask, well, how can we optimize
both  of these,  rather than look for  the  best energy
technologies and then  later worry about  how to handle
the environment.
    DR. REZNEK: If I understand  you  right, you'd
recommend an environmental control or mitigating
measured technology that would do things like develop
H2S stripping, sulfur dioxide stripping, for these emerg-
ing technologies and that those programs would be well
identified, particularly in their budgeting, if not in their
organic function within the agency?
    MR. PRATT: I was actually talking,  ! think, one
level higher in the  hierarchy you're discussing, back at
the policy stage.  You're talking  now   within  the
framework of given technology and—it seems to me
that the kind of environmental  priorities we're talking
about don't reside within the technology, but outside it.
So it seems to me once you have an  office concerned
with a specific technology, that it's inevitable that the
priorities of that office are going to be with the  develop-
ment  of that technology.
    So I think what I'm saying is at another level, you
need  an office that is concerned with the environmental
implications  of that  technology  and  other  tech-
nologies—and the future course and fate of  a given
technology depends not only on how well the one office
develops it as a technology, but how  well the other
office  succeeds in making  sure the  environmental
problems are handled.
    DR. WILLEY: If I understand you correctly, isn't
the closest process that exists now to try to deal with that
question of balance the application  of the  National
Environmental Protection  Act to the  National Energy
Act; that is, in determining a mix of energy supply and
demand for the country over a 20-year time horizon
and evaluating that from the environmental perspec-
tive, that that is where the analysis ought to be done
before offices and individual technology programs are
launched?
    MR. PRATT: That would be an example  of an
overall balanced look of the type I'm talking. His ques-
tion, of course, is directed, then,  towards how is that
carried out by an agency? How should one structure an
agency to  ensure  that something like that,  in  fact,
happens?
    MR. MERSON: Yes, I guess that's my concern. In
looking at it institutionally,  how do we represent these
interests in  some coherent way? You commented that
you have a question about the Office of the Environ-
ment  within the agency and how effective it  is in really
representing these  perspectives forcefully in decision-
making processes. We've heard some suggestions—Ms.
MacGregor  suggested  perhaps that we broaden the
ESAAB, the review board. We also heard a suggestion
earlier today about the public advisor or some other
intervenor in the process.
    I'd be interested in any reaction that you have to
those  kinds of institutional changes. You talked about
perhaps setting up another office that would do a more
effective job of representing these interests. How do you
react  to  some  of  these  suggestions  for institutional
change?
    MR. PRATT: The questions I raised about the Of-
fice of the  Environment were exactly that,  namely, I
have no real sense of what it's doing or what weight it
carries in the actions of DOE. I'm not sure that what you
want to do is create a new office outside DOE. I think
you have great dangers in that route, that it is maybe in-
effective.
    What I would  like to see is that an office charged
with those concerns is of equal priority within DOE to
some  of the .other  offices.  I didn't particularly get that
flavor in the documents, but 1 don't know that much
about it.
    Regarding the question of public involvement in
participation, one  can distinguish  that from public
involvement in decisionmaking. It is possible, that if we
are charging DOE with making,  in the end, various
decisions subject to the pleasure of the President and
the Congress and  the review of  other agencies of a
statutory nature, that they should do so.
    However, one would like to believe that they are
doing so after a full and open process and with a full and
open  and deliberate consideration of the evidence that
has been developed.
    What I was urging more was early involvement of
the many publics, by which I don't just mean a group
like the Sierra Club or other Government agencies, but
technical societies and  many other groups. You name
it. So that  all of the concerns get  fed into the process
early and people can begin to decide what to do about
                                                   88

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                                                                                Statement of Mr. Crytser
these concerns when it's not yet such a costly matter or
when early decisions have rigidified or hardened posi-
tions to the point that  an agency just won't change its
mind.
     It seems to me that's what's most important—to get
in there early and proceed in a way that encourages
some sense of confidence and trust, namely, that when
people make suggestions, they are taken seriously.
     I don't know whether putting people on boards as
voting members or not is the way it's going to help.
     MR. MERSON: Looking at this chart on page 10
of the background document, I think it's striking when
you look down the column marked "Public Access" that
you really don't have any significant public access until
you  get to the environmental assessment or EIS.  I
gather that you're saying it would be awfully helpful  if
starting with the environmental development plan  you
had the ability to comment.
    MR.  PRATT:  Sure. As  chair  of  a statewide
organization, I get notices all the time from EPA, from
the Forest Service, from various groups—almost never
from DOE. Yet, DOE is doing an awful lot of things that
impact on our State.
    DR. REZNEK: I'd like  to go over a subject that
was covered a little bit earlier in the testimony.  There
have been several suggestions for increasing just the in-
formation dissemination aspect and one of the sugges-
tions—maybe mine—was to inquire about the utility of
having DOE use a third party organization for its infor-
mation dissemination and comment collection activities
of a  particular State or local government.  I'd like to
address  that both to Ms. MacGregor and  Mr.  Pratt.
When using an  association of  counties or regional
associations or State  associations—do you feel that
there will  be cases,  where  that  kind of arrangement
may,  in fact,  expedite the process of information
dissemination?
    MS. MacGREGOR: I noticed that there was an
energy  information  administration  within DOE and
although it seems to be getting information in, it didn't
seem to be putting it out.
    So  I  thought it  could be  broadened  to also
disseminate information. Through what channels—I'm
not sure I have been very impressed with EPA Regional
IV's  magazine  on  environmental  concerns  in  the
Southeast, and is what I had in mind when I made the
reference to DOE publishing a magazine. They do  not
have  regional—well,  they do have regional offices,
don't they? And possibly each regional office could  put
out at least a paper on  what is going on, in that region.
    To use an outside agency on a contractual basis—is
that what you had in mind?
    DR. REZNEK: Or a grant basis, if it's a public
body like a State?
    MS. MacGREGOR: I really feel that DOE should
have dissemination under its own roof. I think they'd
have more feel for the  public if they did.
     MR. PRATT: I would agree with that viewpoint. I
would tend not to be too enthusiastic about a third party
arrangement. I'm not that impressed  with other ex-
amples that one sees from time to time of it.
     Furthermore,  I  think  that  DOE  needs  to  be
strengthening its involvement in the communities in the
regions and, therefore, it ought to be taking these kinds
of activities more seriously. So that it's the sort of thing
DOE should be doing and giving higher  priority or
higher weight; just as I was arguing they should be giv-
ing environmental considerations greater weight; they
should be giving educational information considerations
a greater weight. That will help them to establish this
participation also with their many  different  publics,
which they're just not doing.
     There are some DOE offices in the regions, which
one of their spokesmen characterized to me as a "win-
dow dressing."
     DR. REZNEK: I have one more question for Mr.
Pratt. In your testimony, you said that in the liquefica-
tion  area,  it's  premature  to  commercialize  or
demonstrate the facilities  and that that statement on
prematurity was based on  the lack of knowledge of en-
vironmental effects of the technology.
     I assume that in your evaluation of prematurity,
you also take into account the world situation  in terms
of demand and supplies of liquid fuel?
     MR. PRATT: Yes. Certainly we  know that the
general view of most industrial spokesmen  is that this
route is premature also for the same types of reasons.
There is no point to freeze a technology at this point or
go up to full-scale until we're far enough along that we,
(a) know its consequences, and (b) know that we're go-
ing to use it.
     DR. REZNEK: Any other questions?
     (No response.)
     DR. REZNEK: We'll take a break until about half
past and I  believe we  have two more witnesses for
today.
     (Whereupon, a break was taken at 2:13 p.m.).
     DR.  REZNEK:  Our first  witness  is  Patricia
Pelkofer from the—
     MS. PELKOFER: We switched.
     DR. REZNEK: You switched. Okay Scott Crytser
from Pennsylvania Gasohol Commission.

Presentation by Scott Crytser
Pennsylvania Gasohol Commission
     MR. CRYTSER: Thank you. Doctor Reznek.
     I'd  like to  say  good afternoon  to the  Panel
members, the audience.
     Like most of you, I've read and re-read these Sec-
tion  11 documents that have been sent to me. I like to
think I've actually studied  it and I've tried to—I've re-
written all the passages forward and  backward just  to
make sure  that  I'm  completely aware  of  what that
Section 11 means.
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Hearing of October 4, 1979
    I'd like to read to you  and to the audience what
Section 11 (a) states. "The EPA is supposed to check
out the effects of new energy ideas, to make sure that
conservation was given enough attention; and to see if
the environment was considered and to what extent it
would be hurt by using these new ideas."
    Doctor Reznek, would I be close in that translation?
That's Section 11 (a)?
    DR. REZNEK: Yes.
    (Laughter.)
    MR. CRYTSER: Then Section 11 goes on to ex-
plain how the EPA can get this information and what it
can do with it.
    What we are talking about today is energy and the
environment. How the consequences of research and
development of a new  and old energy system  may
pollute or otherwise threaten the world. Air pollution,
water  pollution,  noise  pollution,  land-waste  and
desecration, and even the social and economic disrup-
tions—all these have to be considered.
    . I think it's important for us to recognize how natural
it is to pollute. To exist is to pollute. Going for a walk
endangers some  of the  earth's species.  Eating and
breathing  will foul the air and the earth to an extent.
And certainly, this nation's  more  advanced  and
sophisticated projects have a greater and greater impact
on the world we live in.
    We can scour and treat the air and the water; and
we can dampen or isolate the noise and location. But all
we have is an ability to move the pollution or change it
and not quite to eliminate it.
    So what we do is look at the level and the form of
the pollution produced by a particular energy activity
and to determine if its tolerable or if it can be modified to
be so. We look at the good that comes from it—the fact
that we have lights when we hit the switch;  we have
heat when we need it—and decide if it's worthwhile to
disrupt our lives and our world and our children's world
to go this  or that particular route.
    Section 11 initiates  such a judgment and assess-
ment process. The Council on Environmental Quality
may report on the trends in the energy applications and
their consequences but does not have the simple power
to invoke  any mandates of  reason on the weighing of
the gain versus the loss.
    Even the esteemed Program and Project  Manage-
ment System (PPMS), does not make comparisons be-
tween technologies, according to the documents that I
have received.
    There is no criteria that the DOE is required to
employ consistently in its decisionmaking process. The
DOE is not required to judge a  system by its efficiency.
They are  not required to judge a system according to
the power it produces in view of the pollution it creates.
    The energy RD&D policy in this country has no in-«
violable principled criteria. This is the most glaring lack
in our  evaluation  process of energy research. There is
no policy established that accords the importance of cer-
tain basic principles; there's  no criteria whatsoever.
Benjamin Franklin once remarked, "When the Govern-
ment passes a law or employs a law in violation of basic
principle, it must soon pass other laws to cover up the
mistake."
    Our RD&D policy is in violation of such a principle.
    The most basic principle of energy,  and one that
should be imposed and mandated upon the DOE deci-
sionmaking process, is simply to recognize the two
sources of energy: renewable and non-renewable.
    The non-renewable fuels such as oil-shale,  coal,
natural gas, uranium, petroleum—these  are immense
storehouses of power that the geological process has
handed to  mankind. They are best  viewed as usable
potential, as stored reserves.
    The reserves are to be treated the way a family or
business or industry might use their cash savings. To
carry this analogy, they are used to help when they're
needed, to maintain one on one's feet.
    We've been abusing nature's helping hand by over-
using  these reserves. Such energy reserves are to be
used as a buffer to avoid being rushed  or faced with a
shortage of power. They are to be used only to the ex-
tent that they help create productive,  renewable energy
systems.
    The continued harvest and mining of our natural
bountiful fossil heritage  is the pollution danger that the
Section 11, the DOE, the EPA never deal with. We are
aware of the finite nature of these reserves and we are
aware that technologies that deal with these reserves are
simply delaying the inevitable transition we must make
to renewable and benign resources.
    According to the background document, there are
no criteria that the DOE is routinely or formally required
to include in the PPMS. Let us start here.
    The number one environmental criterion and one
that respects a basic natural principle of the irreversible
limits  of this planet, is to simply  limit the use of these
ancient reserves. To do otherwise  is very dangerous
and this clearly  falls into the realm  of environmental
protection. This  is one clearcut criterion that may be
uniformly imposed across the entire energy industry
and research.
    A second basic-principle would be  to include  in
Energy Research,  Development, and Demonstration
Policy the  beginning of a transition in economic and
political advantage from the fossil and nuclear programs
to the  more benign renewable fuel forms.
    The purpose of this Hearing is to establish a docu-
ment  for Congressional and  Executive  review and  I
think it has to be established here that the people have
gone on record as being concerned about a future that is
dominated by deadends and disappointments.
    A self-sustaining renewable fuel should be priced
below  the  use of our rapidly  depleting reserves by
                                                   90

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                                                                                 Statement of Mr. Crytser
policy. To give the petroleum or synthetic fuels pro-
grams artificial supports and financial benefits is-to work
counter to basic principle and it is to succumb to political
irrelevance and cowardice, to oppose the inevitable, to
delay the day until we must face our cold and hungry
children  in the  darkness of our  own  selfish  short-
sightedness because we waited too long.
    The quality of life in the not too distant future is in
grave jeopardy. Would this not be an enlightened inter-
pretation of environmental quality laws? We must judge
these technologies by realistic criteria; to  allow old and
new programs to strip and scar this planet while dump-
ing toxic wastes into our oceans, rivers,  air and coun-
tryside is one thing; but to do so in pursuit of an energy
form that is by its very nature only postponing the day
when we must make the transition to another source, is
purely ridiculous and irresponsible.
    There is one more big problem with proceeding on
a course of action that neglects these basics. By delaying
the transition, we will not always have the  somewhat
comfortable buffer of our  stored energy reserves to
assist us in making the change that we must do anyway.
    In an article release by the Friends of the Earth this
idea is addressed. I'm not a member or  sufficiently in-
formed  to  be an official spokesman  of theirs,  but I
believe that their organization has somewhat the same
philosophy as the Environmental Protection  Agency.
    The article by Mark Reis and Enid Goldman com-
ments on  Washington's  role.  I  quote, "Long-term
(energy) planning in contrast to the fragmented Federal
program of the last year must be explicitly based on
renewable resources. The .National  Energy  Plan only
tinkers  with  Solar  (and  renewable)   energy.   This
haphazard  promotion  cannot hide the major subsidies
given to the other  depleting energy resources.  Like
other technological revolutions, the fate of  renewable
energy use in the United States  is directly  linked to
consciously  instituted  incentives and  the removal
of barriers."
    What are the incentives and what are the barriers?
One of the purposes of these hearings is to evaluate the
DOE  management system and the environmental con-
sequences of an energy RD&D program.
    This role can bring tremendous potential to bear in
the challenge of the future. The definition  and  inter-
pretation of the Environmental Protection statutes with
a  commitment to the basic  principles  of  renewable
versus non-renewable sources can begin the incentive
process that is so important.
    For starters, the DOE can begin to remove the in-
ternal staffing obstacles to this principled program. In
the DOE, there are almost  2,000  personnel in  the
Nuclear  Development Programs and fewer than 50 for
all the renewable fields of  wind,  solar,  thermal, and
photovoltaic.
    Every day there are fantastic gains being made in
every one  of these fields and  also  in many  other
renewable energy fields.
    That is the type of obstacle the government can
remove once our policy aligns itself with principle.
    On the incentive side, there's tremendous potential
for action on the part of the DOE and the EPA from the
standpoint of Section 11. The DOE and the EPA could
begin to identify every Federal, State, local and city
ordinance that  might  discourage  renewable energy
sources, and simply declare it environmentally unsound
or illegal.
    The EPA could impose national building codes en-
forcing proper insulation, encouraging passive solar
design. Further, the DOE/EPA should make available
free estimates on conservation methods and on the per-
formance and expense of renewable home systems.
    The Public  Affairs Division  could  circulate the
displays and exhibits of the various applications of these
new  clean  alternatives  to the  nonrenewable
resources—at shopping centers, city halls, county fairs,
and throughout the media.
    Let's not fight the renewable resources. The EPA
has a responsibility for assessing the DOE's programs in
light of energy conservation and  their environmental
consequences. What could be more relevant to that
mandate than merging assessment policy to principles
of depletability? We don't  have to stir  the imagination
too far to visualize a society that has failed to develop
alternatives for its  vanishing reserves. Is  that not an
environmental consequence?
    With the greatest respect for the work  of the EPA
and the DOE, I say that this message has to go to Con-
gress and the President. If the DOE and the EPA are
going to finally have a concrete  point of analysis,  a
critical  point,  and if that point is going to  include the
principles of renewable versus nonrenewable, let's not
waste any more time.  Let's make the future a place
where there are not massive threats to our health and
our homes  due to  an unprincipled  and haphazard
energy policy.
    DR. REZNEK: Thank you.
    Are there questions?
    (No response.)
    DR. REZNEK: Let me start with a  few.  There
have been a number of attempts to calculate the energy
yield of various systems, for example, solar satellites or
coal-fired power plants or the nuclear system. One
trend that  seems  to be  developing  is  not only  to
calculate the energy yield per unit of energy investment
in the capital equipment or other aspects of the system,
but  to  separate that accounting into  renewable and
nonrenewable and calculate the  renewable energy
source—the  renewable   energy   yield   versus the
nonrenewable investment to make that yield.
    I assume that you believe that that should be done
sort of  universally in evaluating any project?
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Hearing of October 4, 1979
     MR.  CRYTSER:  Yes,  Doctor Reznek. I think  it
should be an established criteria that cannot be violated.
To violate that would be to violate a basic principle that
we would be using our stored reserves when there are
ample alternatives available.
     If the use of the stored  reserves was shown to be
clearly advancing pursuit of a renewable resource, then
I think it would be making a net gain toward a sound
future.
     But to use a stored reserve without any respect to
advancing a renewable  resource—then  it's just the
wrong direction.
     DR.  REZNEK: There are large reserves of both
nuclear and coal energy exhaustibles  in the  United
States and  the  criticality of transition from the ex-
haustibles to totally renewables depends, in part, on the
size  of those reserves.  There are people who believe
that  it's  not important to begin the transition—not only
not important; it's not economically wise to forego the
benefits of using those resources now.
     Would you  like to comment on that and perhaps
give  us some idea of your timeframe for which it will be
critical to forego the remaining supply of  fossil and
uranium fuels?
     MR.  CRYTSER:  I have heard and read varying
studies  that report that we have 800 years to  1,000
years of varying  fossil  reserves and uranium.  Doctor
Teller's  studies   indicate  that  inexpensive  uranium
energy will be available for 600-800 years, if not longer.
     I don't feel that the point is when, if we are making
no attempt to have a concrete  criteria that  requires  a
transition  to renewable benign  energy sources. 1 feel
that  no time is too soon to begin if, in saying that we're
not beginning now because we don't absolutely have to,
and  we'll start some other time. That's not making the
commitment that I think we need to make.
     So I think yesterday  was a good time to begin.
     DR. WILLEY: Could you  say a few words about
your perception of  the environmental problems with
energy crops as we understand  agricultural technology
now and what you see as the necessary adjustments in
agricultural  production to   alleviate some   of  those
impacts?
     MR.  CRYTSER: I was invited here because of my
association with the Pennsylvania Gasohol Commission
and  the National Gasohol  Commission, which pro-
motes conversion of agricultural products  into liquid
fuels.
     The environmental problems associated with the
production of distilled  ethanol by Environmental Pro-
tection  Standards are usually  well in line with the
standards.
     I've been granted a  permit to operate  a distillery
and  the  environmental  concerns were so  negligible
when I indicated that  the byproducts would be used
either as a feed source or for  composting purposes. The
water is not spoiled; the air is spoiled only with nontoxic
carbon dioxide. So with methanol, that's something I'm
not well enough versed in to inform you on, but with the
production of  ethanol, which is  used today to make
gasohol, there are no environmental restrictions upon
its production.
    DR. WILLEY:  More than the conversion process,
was the production process in the field any problems—
    MR. CRYTSER: Well,  there're tractors that  pro-
duce carbon  monoxide.  The cars  and tractors  have
been, for some time  now, securing Environmental  Pro-
tection Agency approval and been in production. That's
not a concern of the  production process.  But yes, in the
production process,  you will have electricity produced
by the public or  private sector; you'll have—if you're
going completely to the  basics,  you'll  have gasoline
used to run the tractors that are out in the field and the
harvesting equipment.
    To that extent,  everything is negligible. There are
no exotic techniques; no  heavy  metals or gases; no
radioactivity and no toxicants released into the environ-
ment. What we are talking about  is simple farming and
moonshine technology.
    I wasn't here to boost any particular benign source
of alternative  energy over another.  Gasohol is  one
answer and even as a member of several boosting agen-
cies of gasohol, I won't say that  it is  the answer. It is
ONE of the solutions that we have.
    DR. WILLEY:  The reason I  raised the question is
in order for DOE and EPA to follow out their mandate,
at some point—not just for gasohol, but for any sources,
environmental assessments will have  to occur. In the
case of gasohol,if we visualize in a National Energy  Plan
a large-scale plan for production  of gasohol, then the
other part of that, in analysis of the  environmental im-
pacts would be the  consequences in  pesticide use,  in
soil erosion, and some of the other problems that are
associated with agricultural production.  I don't  think
anyone has a handle on the magnitude of that en-
vironmental problem.
    I'm just  wondering  what your  reaction  to  that
would be.
    MR.  CRYTSER:  I recently gave a speech  at a
university in Pennsylvania and afterwards the professor
that invited me said well, hey you  didn't mention any of
the negative points about gasohol production. I told him
I searched for two weeks to find some. So there're not a
whole  lot of  negative—there're  economic considera-
tions with every project that  should be considered. At
some point they  have to be addressed.  The economic
considerations with a domestic energy source, I'm sure
you can just imagine—the last year I have a study on
('78),  we spent  some  $42   billion  for overseas
petroleum. If you're visualizing a liquid  energy source
that   could  completely  terminate  our  overseas
dependency,  there's an economic gain right there.
    We  pay  farmers—in the  same year that the
previous  report came out, we paid farmers $22 billion
                                                   92

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                                                                                Statement of Ms. Pelkofer
 not to grow crops. So by going into something that
 would  be  agriculturally based,  there're  two  great
 economic considerations.
     Environmental concerns are  just as important.
 There are tremendous environmental advantages to a
 nonpolluting, unleaded agricultural liquid fuel.
     Finally,  I think 1 would  rather have  American
 farmers in the driver's seat, as far as being our energy
 suppliers, than the Arabs.
     DR. REZNEK: Do you feel that DOE, through its
 allocation process, has not allocated enough money to
 development of renewable  or  do you feel that  the
 Federal  Government's  role in  something—in  the
 renewable  development is probably  just about right
 now,  but  what  is   wrong  is  that  the  Federal
 Government's role is too strong  in the competing ex-
 haustible fuels?
     MR.  CRYTSER: I  think  you're  approach-
 ing—some serious related concerns—in answer to your
 first question, yes, I do feel that there is insufficient sup-
 port. To the second point, yes, there are artificial sup-
 ports and  even  OPEC's  prices for  oil,  in view of
 depletabtlity, I think they're far too low.
     Right now the alcohol that is going in to blend with
 gasoline is economically not competitive with gasoline.
 But this is not in view of stepped-up production with
 massive  regional  distilleries and some  equivalent
 Federal promotion of the idea;  of the lack of the envi-
 ronmental  hazards  that would  waylay a  lot of  the
 dangers attributed to petroleum; as far as the sludge on
 the surface of our nation;  the disgusting air  quality. It
 can completely wipe out the use of lead as an additive
 that has been blamed for mental retardation and drop-
 ping l.Q. scores across the nation.
     There are a lot of things that would have to be con-
 sidered and I think the price could become competitive
 with a combination of the things that  I've mentioned
 and you've mentioned, Doctor Reznek.
     DR. REZNEK: Questions?
     (No response.)
     DR. REZNEK: Thank you very much.
     Our last witness today is Patricia  Pelkofer of the
 Group Against Smog and Pollution from Pittsburgh.

                                             i
 Presentation by Patricia Pelkofer
 Group Against Smog and Pollution

     MS. PELKOFER: Thank you.
     I am vice-president of GASP, Group Against Smog
 and Pollution. These comments are presented on behalf
 of GASP, which is a  nonprofit,  all volunteer citizens'
 organization founded in October  1969  to work for en-
 vironmental protection and improvement in Pittsburgh,
Allegheny County and the  State of Pennsylvania.
     GASP's efforts have been  directed towards im-
plementation and enforcement of Federal, State and
local  air and  water  quality  regulations and towards
educating the  public  on the  health-related aspects of
environmental pollution.
    Because energy is an environmental phenomenon,
the GASP Board of Directors set up an energy commit-
tee in 1971 to begin a process to inform our members
and the public on energy resources, pollution problems
and aspects of energy conservation.
    In September  1973, GASP directors  adopted an
overall energy policy to guide the group's actions in this
important area of concern.  This guideline  included
maintaining  an impartial attitude toward  all energy
resources—coal,  oil,  gas  and  nuclear—currently
available in our region.
    We  look  at all energy  resources  in  the light of
GASP's objective to reduce and prevent to the fullest
extent possible, within the existing state of technology,
all forms of ecological degradation.
    GASP was represented at the Section  11 Regional
Meeting held in Pittsburgh July 31, and members have
reviewed the background documents available for this
hearing.
    We  are in agreement with  the prehearing docu-
ment's assessment of the strengths of the Department of
Energy's Program  and Project Management  System,
setting levels, phases, decision  points and identifying
technological and environmental concerns.
    We are not, however, so certain that the DOE pro-
cess is actually prepared to deal with the environmental
problems which have  been identified, as a new process
moves up the scale-of-size.
    The most difficult problem in commenting on the
DOE Management Program and Process, and how ade-
quately environmental concerns have been considered,
have been the  number of unanswered questions and
concerns that continue to come up.
    For instance: what is the place of synfuels in the
nation's overall and  long  term energy development
plan?
    It is GASP's belief that both  nuclear and fossil fuel
processes use up our globe's  limited energy resources.
Synfuels should be  considered an interim step—a tran-
sitional  energy  source  for  several  decades—to  a
relatively unlimited  energy source such as solar, winds,
hydroelectric, ocean currents, and fusion.
    One senses a capacity commitment to these syn-
fuels projects and developments, which may not be the
best investment, of either capital or intense, expensive
technology.
    A second question is: where and how has energy
conservation been  factored into DOE's planning pro-
cess—either in weighing one process against another,
or one source against another,  in light of net energy
use, or whether projected capacity of potential commer-
cialized plants include a conservation factor?
    Energy conservation, in GASP's view, must be an
inherent part of our national energy policy, and must be
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Hearing of October 4, 1979
 viewed as  complementary to energy  research  and
 development and not as an alternative to it.
     To cite one example on a more regional or local
 level; in reviewing locations for pilot or demonstration
 plants for synfuel technologies, is the environmental im-
 pact of any new process thoroughly related to the total
 potential environmental and  socioeconomic  problems
 of an area? Are  current  and longstanding existing
 problems well-reviewed?
     For example, the background material indicates
 Morgantown, West Virginia as a site selection for a sol-
 vent  refining  demonstration plant.  This  location,
 therefore,  involves the Monongahela River basin.  The
 Pennsylvania Department of Environmental Resources
 in March  1978 published a report on Water Quality
 Issues  for  Pennsylvania  indicating  that  the
 Monongahela River faces one of the most serious water
 supply problems in the Commonwealth.
     It is intensively used to meet  the water needs of
 steel  mills  and other  industries  in  the  Pittsburgh
 area—17  public  water suppliers  and  three electric
 generating facilities.
    The Monongahela River is simultaneously the na-
 tion's most heavily used inland waterway, with com-
 mercial navigation carrying approximately 38  million
 tons of raw materials, goods and fuels annually.
    The Monongahela basin is subject to flash floods
 immediately following storms and extremely low flows
 during the dry  periods. Although  most  Pennsylvania
 streams have a continuous base flow which is supplied
 from  ground water  aquifers, the  base  flow  of  the
 Monongahela is almost nonexistent. As a result, during
 dry periods, almost all of the flow in the Pennsylvania
 portion of the  river  above  the  Youghiogheny River
 Confluence  comes from  Tygart  Reservoir in  West
 Virginia, which provides a maximum release of  220
 million gallons per day.
    Tygart Reservoir was authorized by Congress  and
 developed by the Army Corps of Engineers to support
 navigation. (The 38  million tons a year.) The United
 States claims a Federal navigation servitude over the
 waters released from  Tygart and the natural flow of the
 river, in an amount necessary to operate the locks  and
 dams—a minimum of 220-340 million gallons per day.
    This means that the Federal  Government may
 under low flow conditions prohibit any diversion of river
 water which may reduce or interfere with flows required
 for navigation.
    Current and projected interbasin transfers and con-
 sumptive uses for public  water  supply, which  is 37
 million gallons a day, power plants,  17 million, and in-
 dustry,  117 million gallons a day,  would substantially
 conflict with navigation during low flows.
    But putting  it  bluntly,  in  the next  significant
 drought, Pennsylvania will face the difficult choice of
 shutting  down  or  curtailing  navigation,   industrial
production,  power generation,  and municipal water
supply.
    Already,  the  Department  of  Environmental
Resources has been forced to deny any additional water
allocation requests to public water suppliers in the basin,
and advise current and prospective users to seek alter-
nate locations and sources. The timing of a major water
crisis is solely dependent on the weather. What might be
the added burden of an intensely water-using liquefica-
tion plant in this area?
    Obviously,  water quality in such  an overworked
river leaves much to be desired. In the Level B study of
the Monongahela Basin conducted by the Ohio River
Basin Commission in 1975, water quality problems are
derived from four major sources: domestic sewage, in-
dustrial  wastes,  acid  mine  drainage,  and  nonpoint
sources.
    One hundred and four  communities require new
construction or upgrading of sewage facilities, and there
are 48 major point sources of industrial pollution in the
basin. Noncoal mining related industrial discharges are
concentrated in the Allegheny County-Pittsburgh area
and also near Morgantown, West Virginia.
    Acid mine drainage is the single most serious water
quality problem in the area, affecting over 2400 stream
miles or nearly 25 percent of the total stream mileage in
the basin.
    While active coal  mines  and industrial sources are
now slowly  coming under more strict regulations, the
extent of  the inactive  mine problem  includes nearly
50,000 unreclaimed strips, 150 strip sites of 10 acres or
more, and 1550 acres with evidence of subsidence due
to collapse of underground mines, and mine refuse sites
of five acres or more  at 68 sites.
    There are a total of 668 inactive mines discharging
389 tons per day of acid. About 70 percent of this pollu-
tion comes from deep mines.
    Along with water quality and quantity  problems,
the Monongahela Valley is a  noncompliance area, fail-
ing to meet air quality standards  to  protect human
health for  any of the major pollutants.
    How  are such area-wide  existing  problems in-
cluded in  environmental evaluation, or is a proposed
facility considered in a vacuum type situation?
    Other questions: How much State, regional, and
local input has gone into'research, development, and
demonstration decision processes?
    Should  not potential for serious environmental im-
pact as well  as development cost be a factor in rating a
project major or minor, and thus, subject to top  level
review? We  are reminded of relatively small operations
in Hopewell, Virginia and Buffalo, New York, produc-
ing or storing chemicals which have resulted in serious
environmental impacts and health problems.
    How  many serious environmental problems  with
no immediate "solutions" or with tough and expensive
technological requirements, may become obvious in a
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                                                                                Statement of Ms. Pelkofer
 50,000-ton commercial plant which may not appear in
 a 50-ton pilot or a 5,000-ton demonstration operation?
 If a great deal of money has been invested through pilot
 and demonstration  stages, is  rejection at  the commer-
 cialization stage likely?
     Is there a  line  item in the Department of Energy
 Research, Development, and Demonstration budget for
 citizen participation  and public education? Has a citizen
 participation guideline  been  developed  as a basic
 criterion for all citizen involvement into energy develop-
 ment and planning? Many such guidelines are in place
 involving the  Department  of  Housing  and Urban
 Development,  Department  of  Transportation   and
 EPA's Clean Water, Safe Drinking Water, and RECRA
 Programs. These are just a few of the major recurring
 concerns expressed by members who  reviewed  the
 background material for this Hearing.
     Many of these concerns were expressed across the
 country at the prehearing meetings. We hope that the
 Energy Department will have the opportunity to  re-
 spond to the people on some of these points.
     There  is a  strong agreement with public sentiment
 voiced at the prehearing workshops that explicit  en-
 vironmental criteria should be developed and applied to
 all major decisions in the technology development pro-
 cess and that criteria should be known to the public;  that
 State and local agencies and organizations should be
 given a greater part in planning and reviewing projects
 that directly affect their jurisdiction.
     Without some of these types of inputs, we will have
 nothing but a series of political decisions instead of a
 policy based upon scientific information.
     The underlying reason  for all the questions asked
 at the national workshops and by those reviewing hear-
 ing documents  is the late entry of citizen input into the
 decisionmaking process.
     In  recent  years,  the American  public has  en-
 countered the  environmental  revolution,  the  energy
 crunch, the world food shortage and the economic con-
 fusion. The United States, with its high standard of liv-
 ing and the most educated people in the world's history
 has also become the most confused about its future.
     There is a general recognition about the  serious
 problems ahead. There are many classic calls for action,
 but before we can have action, we must have a plan.
     The typical American approach to such problems is
 the participatory process. The  issue of energy develop-
 ment is perhaps the best vehicle to explore new avenues
 of policy  development, because  energy  is  so  all-
pervasive. Public  participation and public  education is
crucial and it must be strengthened.
     Our political and  national boundaries have  not
been drawn with an  eye toward air basins, watersheds,
energy regions.  Topographic features many miles away
often act to concentrate allowable effluent  levels which
are far above acceptable standards.
    Such effects can be found in public health threats
or environmental impacts thousands of miles from the
source, or many years after the emission, often in a dif-
ferent region or country or in a different era.
    Citizens must be aware of these aspects and costs
for prevention of these effects must be factored into the
development.
    Possibly the regional level is optimum for a public
participation process in energy development because
various interests may be brought together to discuss and
interact through a common concern for the welfare of
the region.
    GASP, along with many citizens of this country,
are both  amazed and frustrated at the lack of mean-
ingful citizen participation in the development of energy
programs and policy. We will continue to work for more
public participation in  all energy/environmental inter-
related decisions affecting our region, the state of Penn-
sylvania and the Nation.
    We  thank both  the  Environmental  Protection
Agency and the Department of Energy for the oppor-
tunity to  comment at this meeting.
    DR. REZNEK: Thank you.
    Are  there  questions?
    MR. MERSON: I guess I'll ask my usual question.
Based on your reading of the background  materials,
which obviously you've read with some care, do you
have any specific institutional changes that you  would
want to see incorporated into the PPMS process cur-
rently employed by DOE? You've called, I think, very
eloquently for  much greater public participation, for a
careful consideration of environmental impacts. Would
you suggest any structural changes?
    MS.  PELKOFER:  I  think  definitely that  the
regional   level  should  be  strengthened.  GASP
thinks—(this is not just my opinion)—that people are
best able  to have input about things with which they are
familiar, and from that basis, they learn of the greater
problems.
    If there would be more effort to communicate with
the public—even the meetings that EPA held, if DOE
would  hold a number  of  these  across  the  coun-
try—something like that, it  would be helpful to get
people to come together and look at some of these
problems. Although nobody wants a coal gasification
plant in their backyard, if they go  through the  whole
process and see what might be—what's the need behind
it, then there's  a chance of compromise or possibly get-
ting new  ideas to set off on something entirely better for
the area.
    MR. MERSON: Perhaps getting some of the plan-
ning documents that are  mentioned here, assessment
documents, for discussion early on at a local or regional
level.
    MS. PELKOFER: A very early stage, so residents
know what's being planned and  how many of those
                                                   95

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Hearing of October 4, 1979
things might impact your area. In addition, documents
regarding all energy "R&D" should be available. While
geothermal energy may not be of interest in the coal
region, you still should know a little bit about it...What
all the development ideas are.
     Plus, I still feel, as several people have mentioned
today, that the public  must have a feeling of overall
planning that everything is relating to in the energy field.
I think any message to  Congress—that's one thing that
GASP has been trying to get through every chance
possible—to our local  Congressional representatives,
that this plan is needed.
     Somebody has to  bite the bullet and since they're
the ones who are elected, I guess it's their job, before
EPA or DOE or anyone else can really feel any sense of
direction. You have to have an overall plan which in
spite of the reports that have come out, it just isn't there.
There isn't that feeling that there's a  goal some place
where we're  really going  in considering the  whole
problem.
     MR. MERSON:  Strategic planning in the sense
that, I think, as Mr. Markey suggested yesterday, look-
ing at what our needs  are going to be in terms of the
end-use for various fuels. Working backwards from that
to some extent.
     MS. PELKOFER: That's the thing, and also work-
ing  in the conservation factor,  because too many
things—possibly  what  people think they need, they
really may not. How valid conservation figures are,  has
to be factored in,  before you  start  thinking about
capacities or anything else.
     MR. MERSON: Thank you.
     DR. REZNEK: One—there have been several
suggestions or parts of  suggestions for allocating levels
of development; that is, numbers of  power plants or
coal production or what have you,  ethanol or methanol
production facilities, on a regional State-by-State basis
and asking the States to move rather aggressively on
presiting  hearing process  so  that we  can  transfer
whatever range of quad future we want to talk about
into a regional and then  local impact; and asking a
thorough process for the States, the production States
to establish goals for themselves to get agreement on
what those goals might be and where the development
might be occurring and where we're going to prestudy
the siting of individual facilities.
     Would you like to see such a process developed? I
might also want to ask Ed Grisham whether or not New
Mexico has been examining the question of where, in
fact, its load of the supply, future supply  may, if fact,
occur?
     MS. PELKOFER: Would you please restate your
question? I did not understand it entirely.
     DR. REZNEK:  No, I'm just saying you  take
whatever National Energy Plan with the mix of conser-
vation, coal supply, biomass supply and translate that
into a State-by-state allocation and ask the States, not
necessarily on a one-for-one, but in a range of values,
and ask the States to go ahead with preplanning and
presiting of the facilities that the plan calls for.
    Would you like to see that—
    MS. PELKOFER: That might be a good idea, but
again only if there's public participation, because, what
happens on so many of these things—everybody's plan-
ning,  independently.  There may be  something else
being planned for that land, too, and somehow or other
they meet in collision at some future date. One group
has a park in mind and  somebody else  a high-rise.  I
think  that probably it would help to plan on a State
level, but there still is a great deal of communication
needed among agencies and  also  with the general
public so that residents have an idea of what's happen-
ing in their area when it's going to affect the quality of
their lives.
    Also, you don't  have a few people on  the inside
able to acquire land and such and make big profits out
of it when it's not in the best interest of the whole State
or country.
    DR. REZNEK:  Ed, would you like to—
    DR.  REZNEK:  —would  you  like  to  comment
on New   Mexico's ability to  plan or specify  future
development?
    MR. GRISHAM: Just make a comment, Steve.
We feel sort of that it's going to be an obvious choice
where the development is going to go in New Mexico,
like it is in the country. You're going to have your coal
gasification plants where your coal is; you'll have your
uranium mines and mills where  your uranium is;  and in
New Mexico, it's in a very small area of the State up in
the Northwest corner.
    We're not attempting to do any plant siting at all
because industry is doing that as they  develop the
resources. The only thing we've  done is develop  a
Community Assistance Council  to help plan for the im-
pacts  and  we intend not to see growth occur at a rate
that's  going to be detrimental to the environment or to
the economic and social well-being of those people liv-
ing in that area.
    So that's about the only position we've taken at this
point. But we do have an Industrial Planning Council
made up of major industry in the State that works with
us monthly  in reviewing  applications for Community
Assistance and long-range plans for plant siting.
    MS. PELKOFER: Could  I add something? I've
been working for three years on the 208 Water Quality
Management Plan for our area. There have  been
volumes of material gathered on all of these types of en-
vironmental  development and  economic problems.  It
makes you wonder where all this material goes and why
some  of these various agencies can't share this informa-
tion back and forth instead of starting from scratch. Also
in  public  meetings and hearings on these plans every
township and county want a growth projection. "You
can't say that our population is going down."  You can't
                                                   96

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                                                                              Statement of Ms. Pelkofer
estimate that in the plan because "we're" going to be
greater. "We're" going to have a new coal mine in our
township and we have to have a sewage treatment plant
all of our own. "We" don't want to go in with somebody
else.
    One thing you would have to be careful about is to
have a very strict criteria that everybody doing any kind
of evaluation  and projection use the same basis—the
same kind of population projections; so that when it
comes back up for a whole picture at the national level,
you're going to have it all on the same basis.
    DR. REZNEK: Are there any more questions?
    (No response.)
    DR. REZNEK: I'd like to thank the witnesses to-
day. I feel we've solicited and received some very good
testimony.
    We'll reconvene tomorrow at 9:00 o'clock for our
third and final day.
    Thank you very much.
    (Whereupon, at 3:25 P.M., the hearing was ad-
journed, to reconvene the following day at 9:00 A.M.)
                                                 97

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October 5, 1979
Panel:

DR. STEVEN REZNEK, Deputy Assistant Administrator
    for Environmental Engineering and Technology, Environmental Protection Agency

REBECCA HANMER, Deputy Regional Administrator,
    Environmental Protection Agency

DR. PAUL STOLPMAN, Office of Air, Noise, and Radiation Programs,
    Environmental Protection Agency

DR. A. BRUCE BISHOP, New York State Energy Research
    and Development Authority

DR. SAMI ATALLAH, Gas Research Institute

DR. SHELDON KINSEL, Director, Congressional Relations
    National Wildlife Federation

CLAUDE BARFJELD, Government Operations Committee of the Senate

GREG ONDICH, Section 11 Coordinator
                                       99

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Contents
MORNING SESSION
  PAGE
PAGE
    103  Opening remarks, DR. REZNEK
    103  Statement of DR. SAMUEL MORRIS
          for DR. LEONARD HAMILTON
            (of the Brookhaven National Laboratory)
            Questions and remarks
               105 MS. HANMER
               105 DR. ATALLAH
               105 DR. KINSEL
               106 MR. BARFIELD
               106 DR. REZNEK
               107 DR. REZNEK
               107 DR. KINSEL

    107  Statement of MR. WILLIAM ROGERS
            Gulf Mineral Resources Co.
            Questions and remarks
               108 MS. HANMER
               108 DR. ATALLAH
               109 DR. REZNEK
               109 DR. ATALLAH
               109 DR. STOLPMAN
               110 DR. STOLPMAN
               110 DR. KINSEL
               110 DR. ATALLAH

    111  Statement of MS. SUSAN TACHAU
            National Center for Appropriate Technology
            Questions and remarks
               112 MR. BARFIELD
               112 DR. BISHOP
               112 DR. STOLPMAN
               113 DR. STOLPMAN
               113 DR. REZNEK
               113 DR. ATALLAH
               113 MS. HANMER
               114 DR. KINSEL
               114 DR. REZNEK
  114  Statement of DR. NEIL SELDMAN
          Institute for Local Self-reliance
          Questions and remarks
             117 DR. ATALLAH
             118 DR. REZNEK
             118 MS. HANMER
             119 DR. BISHOP
             119 MR. BARFIELD

  120  Statement of MS. MARY JADIKER
          Lake County Planner, Lake County, Califor
          Questions and remarks
             121 MR. BARFIELD
             121 DR. KINSEL
             122 DR. REZNEK

  122  Statement of DR. ALLAN HIRSCH
          Fish and Wildlife Service,
           Department of the Interior
          Questions and remarks
             124 DR. ATALLAH
             125 DR. ATALLAH
             125 DR. REZNEK
             125 DR. KINSEL
             126 DR. KINSEL
             126 MS. HANMER

  126  Statement of MR. ROBERT THOMASON
          Occidental Oil Shale
                                       100

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Contents  (Continued)
AFTERNOON SESSION
  PAGE
PAGE
    129  Opening remarks, MR. GREGORY ONDICH

    129  Statement of MR. DAVID ANTHONY
           University of Florida
           Questions and remarks
               133 MR. ONDICH
               134 MR. ONDICH
               134 MS. HANMER
               134 DR. BISHOP

    135  Statement of MR. MARK McCLELLAN
           Pennsylvania Citizens Advisory Council
           Questions and remarks
               138 DR. BISHOP
               138 DR. KINSEL
               139 DR. ANTHONY
               139 DR. KINSEL
               139 MR. ONDICH

    140  Statement of MR. ALBERT SLAP
           Pennsylvania Public Interest Law Center
           Questions and remarks
               142 MR. ONDICH

    142  Statement of DR. MICHAEL DEVINE
           University of Oklahoma
           Questions and remarks
               144 DR. ATALLAH
               144 DR. BISHOP
               145 DR. ATALLAH
               145 DR. KINSEL
  146  Statement of MS. LORE KEFFER
          Group for Recycling in Pennsylvania
          Questions and remarks
             148 MR. ONDICH

  148  Statement of MS. EDITH CHASE
          League of Women Voters of the United States
          Questions and remarks
             150 DR. BISHOP
             151 DR. BISHOP
             151 MS. HANMER

  151  Statement of DR. CARL NORBECK
          Thome Ecological Institute
          Questions and remarks
             153 DR. BISHOP
             154 DR. BISHOP
             154 MS. ONDICH
             154 MR. SEAMAN

  154  Statement of MR. MICHAEL SEAMAN
          California Solid Waste Management Board
          Questions and remarks
             157 DR. KINSEL
          Adjournment
                                       101

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Proceedings
                                                                               Statement of Dr. Morris
9:05 a.m.
    DR. REZNEK: Good morning. My name is Steve
Reznek  and I'm with the Environmental  Protection
Agency, and I'd like to open the third day of the hearing
under Section  11 of the Nonnuclear Energy Research
and Development Act.
    The purpose  of  the  hearing is to examine  the
relative emphasis given to energy conservation and en-
vironmental  protection in  the  research and develop-
ment programs of the Department of Energy.
    The hearing panel this morning includes—who's
sitting at the end of the table?—Claude Barfield, who is
with the Government Operations Committee of  the
Senate. Next to him is Dr. Sami Atallah from the Gas
Research Institute.  Next to him is Dr. Bruce  Bishop
from the New  York State  Research and Development
Authority.
    Next to  him is Paul Stolpman of the Office of Air,
Noise, and Radiation Programs in the Environmental
Protection Agency. Next to him is Sheldon Kinsel of the
Wildlife Federation. And next to me is Rebecca Hanmer
of EPA's Regional Office in Boston.
    The first witness this morning is Samuel Morris of
Brookhaven  National, Laboratory.
Dr. Morris?

Statement of Dr.  Samuel Morris for
Dr. Leonard Hamilton of the Brookhaven
National Laboratory
    DR. MORRIS: Thank you.
    I'm here this morning on behalf of Dr. Leonard
Hamilton of Brookhaven  National Laboratory. He's
asked me to convey his apologies to you for not being
able to be here  today, since he's in Luxemburg address-
ing a seminar  of  the Commission of the European
Communities.
    A primary mission of the Department of Energy is
to develop and commercialize new energy technologies
that are economically practicable and technically feasi-
ble, together with being environmentally  acceptable.
DOE's technology  development  and environmental
research areas  need to press forward in a coordinated
way in order to assure that this goal is achieved in an
efficient and timely manner.
    How can one go about this? First, it's necessary to
have  some  idea  of  how  the technology  can  be
developed. Then the environmental impacts must be
assessed, along with the information available to deter-
mine these impacts.
    This originally gave rise to what was  called the
Environmental Development Plan, or EDP. The EDP
initially   examined  the   technology  development
schedule, went through the technology  schedule and
process and identified areas of potential environmental
problems. To reduce the  uncertainty associated with
these  environmental concerns,  it  established
environmental research needs and provided compatible
schedules for  this  environmental research   and
technology development.
    Subsequently, the Environmental Readiness Docu-
ment, or ERD, took  over the responsibility of defining
areas  of environmental concern and research needs.
The role of the  EDP was  then confined to providing
compatible schedules for environmental and technology
research and development, as well as scheduling future
ERDs and Environmental Impact Statements (EISs).
    Thus, DOE, in accomplishing its goal of developing
technology in an environmentally compatible way, has
evolved two planning documents, ERDs and EDPs.
    What are the criteria for effective ERDs and EDPs?
An ERD should be an  analysis of environmental con-
cerns relevant to the technology based on critical review
of research results. Each ERD should address five areas:
    One, the current  state of knowledge  about the
health, safety, and environmental impacts that would
be created by deployment of the technology.
    Two, available  control technologies—capabilities
and costs.
    Three, the current and proposed regulations which
will affect commercialization.
    Four, the areas of  environmental  concern  for
which information is inadequate and further research is
required.
    And five, the  likelihood of significant delay  in
attaining program objectives because of environmental
concerns.
    The Environmental Development Plan, or EDP is a
management planning document, scheduling activities
needed  for  determination of environmental accept-
ability, including environmental research, future ERDs
and EISs.
    EDPs were initiated several years ago to provide a
common basis for planning by the Assistant Secretary
for  Environment and  those  responsible for energy
                                                103

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Hearing of October 5, 1979
technology development. EDPs include, in addition to
brief descriptions of the technology and plans for its
development,  the identification  and description of
environmental issues. In addition, each describes and
schedules actions required to allow development to pro-
ceed in an environmentally acceptable way. EDPs, as
documented agreements between principals  with dif-
ferent  responsibilities   for  managing environmental
issues, serve  as  a vital component of DOE's overall
planning process. They have also  been used as support
for judgements regarding the environmental accept-
ability  of evolving energy technologies  presented in
Environmental Readiness Documents (ERDs). It is im-
portant, however, to understand what EDPs are not.
While they provide an essential common base for pro-
gram planning, they are not program plans.
    The EDP should draw on the ERD for identification
of  environmental  concerns,  analysis  of   specific
environmental concerns and impacts, research recom-
mendations, and prioritization.
    The  success of both EDPs and ERDs requires an
environmental assessment program.  One  of  Ruth
Clusen's  first  acts as Assistant Secretary for  Environ-
ment  was  to  establish a  Health and Environmental
Effects Assessment Program (HEEAP). This  program
will operate at a level of approximately a million dollars
in 1980. The program  will provide analytical, quan-
titative, and  documented assessments  of  what  is
known, unknown, and uncertain regarding  potential
health and environmental impacts of energy technology
being developed by DOE.
    The  assessments  will be structured to provide
descriptions of health  and environmental effects in
terms  of  total  energy  technology   fuel   cycles.
Assessments will be continuously updated to provide
new information  and improvements in the methods of
analysis.
    Health and  environmental  assessment  will  take
research  data from  DOE's  research program,  and
others, in this country  and abroad, on source terms,
atmospheric   transport,  environmental  transport,
metabolic  models,  dose-effect  relationships,   and
ecosystem  models. The  health  and environmental
assessment activity will then  produce  quantitative
assessment of occupational,  accidents, public health,
and ecosystem  effects associated  with  the energy
technology, along with  analysis of the sensitivity of the
results to  factors  such as geographic   location,
demography, and control levels.
    We have assessed these technologies, determining
their interrelationships,  and included assessments that
are specific to individual technologies,  while cross-
cutting general assessments that are common to several
technologies.
    This program should eventually provide the  infor-
mation on which ERDs and EDPs are based. Since the
program  is starting  only with  a  few  technologies,
however, it will be several years before many ERDs and
EDPs can derive information from these assessments.
    How do current ERDs and EDPs shape up to the
objectives we have described?
    Since  EDPs  already existed when  ERDs  were
begun, and since ERDs were funded at a lower level of
effort than EDPs, the ERDs have tended to contain less
environmental assessment than the EDPs and much
less than our objectives.  Where there is an extensive
assessment to draw on, the ERD can be rather complete
and include detailed analysis.
    Where'a major assessment has not been done, the
ERD should strive to be comprehensive, but cannot be
expected to cover the subject in much depth.
    Our brief analysis of some of the September 1978
ERDs  suggests  that these  fifteen  to  thirty  page
documents deal with most environmental issues  in
insufficient depth, however. The ERDs tend to present
data unsystematically and  to  emphasize  qualitative,
rather than quantitative analysis.
    The  guidelines  suggest that analyses in ERDs
should include a review of emissions, control  tech-
nologies, dose-response data, and ultimately, impacts,
but to date ERDs usually deal with only one or two of
these requirements.
    With respect to the five specific areas  I mentioned
earlier to be reviewed in  ERDs, the  first is the assess-
ment  of current state of knowledge  about  environ-
mental concerns. Most  ERDs  treat this  area insuffi-
ciently. They omit definitions of the  origin and size of
environmental  concerns. ERDs list concerns, but fail to
list underlying reasons for  the concerns.  ERDs give
mostly qualitative data and make minimal  effort  to
measure  the  relative  importance   of identified
environmental  issues.
    The second  area is the analysis of  the control
capabilities and costs. Some effort is made to assess
expected emissions from individual  technologies and
the capabilities of feasible  controls. ERDs also give cost
estimates of control, but do not document these costs
very well.  (Total cost analysis is usually several pages.)
Since there is usually  no  explicit statement of the per-
cent  reduction  in  various residuals available in the
documentation, one cannot determine what is being
"bought."
    Third is the current and proposed regulations.  In
ERDs, current and proposed regulations are listed in a
reasonable tabular fashion. These tables could be im-
proved by listing, where possible, the actual standards,
rather than merely stating what residual will need to be
controlled. This could provide some feeling about the
difficulty of reaching goals.
    The fourth is the additional research required.
ERDs now merely list a potpourri of research needs and
their dollar costs. They  should make  some  effort  to
prioritize these needs.
                                                  104

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                                                                                 Statement of Dr. Morris
    Finally are the potential  "show-stoppers." ERDs
identify these potential show-stoppers, together with a
probability estimate of delay in the attainment of the
program goals because of environmental concerns. One
is not given the assumptions used in defining this prob-
ability, and, as a result, one cannot understand how the
table derives from the text.
    ERDs could be improved significantly  by  limiting
the task  requirements  and systematically  identifying
issues to be assessed. Environmental issues are now
identified haphazardly. A more logical approach, used
in  many of the analyses  at  Brookhaven,  would  go
through the entire fuel cycles of each of the technologies
and identify possible environmental conflicts.
    After this review, judgment should screen out less
important issues. The  remaining environmental issues
should be assessed as quantitatively as  possible, with
particular  attention  to   source  terms,  transport
mechanisms, receptors, and responses.
    Environmental issues should be fully referenced;
such a presentation would  delete much  of the present
qualitative speculation in ERDs. ERDs should explicitly
state when  environmental data are not available. And
finally, ERDs should be updated every two or three
years.
    To turn to EDPs, because the EDPs were the first
ERDA, and subsequently DOE, planning document to
combine technology development and consideration of
possible environmental impacts, they now include data
far in excess of the needs for  a document intended to
serve primarily as a guide for program management
planning. As DOE has recognized, much of the scien-
tific assessment should be shifted to  the future  ERDs,
and EDPs should confine their coverage of these areas
to summaries of the analyses contained in the ERDs. To
implement  this change in the emphasis of the two
documents, it is necessary to shift the bulk of the effort
to the ERD.
    From an administrative perspective, a  single sub-
contractor should be given full responsibility  for the
preparation of the individual ERD or EDP. Since the
ERD  is  principally   a  scientific  review, National
Laboratories—which  has  the necessary  talent and
capabilities—should  be responsible  for  their prepara-
tion. Furthermore, the same group should  have con-
tinuing responsibility for revising ERDs when revisions
are required.
    EDPs, on the other hand, which are management
planning  documents,  could  more  appropriately  be
prepared by management  consultants in cooperation
with DOE staff.
    Figure 4 in the prepared testimony  diagrams how
information will flow from the health and environmental
assessment to the ERDs  and EDPs.  It shows how
resulting  research is incorporated in Health and En-
vironmental  Effects  Assessment  Documents
(HEEADS}, ERDs and EDPs,  and how  HEEADS and
EDPs will guide the course of research by delineating
uncertainties that need reducing and gaps in knowledge
that need filling.
    The health and environmental assessment area is a
scholarly, objective  assessment  of health  and  en-
vironmental  impacts of energy technologies. This is a
very large task, and it's an obvious area where DOE and
EPA should combine efforts. EPA has a definite interest
in health and environmental assessment, and has  in-
place  assessment  activities   for  many   energy
technologies.
    Cooperative  efforts  in  this area  would avoid
duplication and  could have intellectually synergistic,
beneficial effects. An immediate advantage to EPA
would  be  closer  awareness  of details   of  the
technological processes that they would  need in any
confirmatory evaluation. Such an  active cooperative
program  would not  preclude an ultimate  secondary
confirmatory evaluation by EPA.
    Thank you.
    DR. REZNEK: Thank you.
    Are there questions from the panel?
    MS. HANMER:  Dr. Morris, I'd be  interested in
your  assessment  of  the  extent  to  which these
documents have  had  an impact on priorities and plan-
ning—substantive impact.
    DR. MORRIS: That's a question I'm really not in a
good  position to answer. I really don't know to what
extent these documents have  actually been used in
framing and  planning the DOE research plans.
    DR. ATALLAH: Yes, Dr. Morris, you mentioned
that ERDs treat the assessment insufficiently from the
quantitative standpoint. I think there's one problem that
whoever does the assessment has, especially with new
technologies—-I know  about biomass ones,  as the im-
pact of marine plants, or the recovery  of  gas from
geopressure  brines—the data are not there  to do a
quantitative analysis. There aren't enough wells sunk to
measure  subsidence, for instance, potential subsidence
effects, environmentally.
    So it's very difficult to do an assessment when you
don't have the data. You guess. And so the nearest you
can do is do a qualitative analysis of it; identify the
potential problems.
    DR. MORRIS:  I agree. You  can't do a quan-
titative analysis unless there are data. But one of the
things that the ERDs have to do is identify where there
are no data  and systematically evaluate what the data
needs actually are.
    DR.  KINSEL:  You mentioned that—or you
recommend, I guess, that the ERD, since it's principally
a scientific review,  should perhaps go to  the National
Laboratories, but as I'm sure you know,  there's been
some  criticism of the  National Laboratory system over
the years, and a suggestion that perhaps  too much
research is sent to the  labs where there may be a certain
amount of inbreeding or at least not the range of new
                                                  105

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Hearing of October 5, 1979
ideas present that you might find if the research was
sent to schools not necessarily associated with the Na-
tional Labs, or perhaps to other research institutions.
     Why is it you think that the National Labs are par-
ticularly well-suited to do this type of research, as com-
pared to outside groups?
     DR. MORRIS:  Well,  I  think  the  National
Laboratories have several advantages. They provide a
continuing organization to do this over a long period of
time. Also, since in  a sense they're owned by DOE,
they're immediately available for this kind of work.
     I don't think there's anything that would necessarily
preclude continuing responsibility for the preparation of
an environmental readiness document being given to a
research center at a university.
     Most of the labs have extensive interactions with
universities, and in fact in many  cases have cooperated
closely with universities in preparing and conducting this
kind of effort.
     I think that the National Labs are a logical place to
put this responsibility, but my main point is that this is a
scientific effort and should go to  a scientifically oriented
group, be it at a National Lab or a university.
     The other important point, I think, is that it should
be a continuing effort. I think there have been too many
times, even in the short life of these kinds of documents,
where it's given to one group to do and then the follow-
ing year it's taken away from that group and given to an
entirely different group unfamiliar with the process.
There should be some kind of continuing responsibility
in a single group over a long period of time for the
development of these documents.
     MR. BARFIELD: Wouldn't the document also be
better informed if there was some provision for public
comment, at least from the scientific and technological
community, in addition to whether it's from the labs or
the university group,  whatever?
     That someone knew that the DOE was preparing
these documents, that the time had come for this, and
had a chance to make comments one way or the other,
purely technical, or even scientific?
     DR. MORRIS:  Well, I think the document should
be a continuing thing. It can be reissued. The EDPs are
almost necessarily reissued annually in order to match
the budget planning.
     The current schedule for ERDs is not for a regular
reissuance, but we think that the ERDs should be issued
on  a regular basis—perhaps not annually, but at least
every two or three years.
     MR. BARFIELD: But that doesn't get really to the
point. I mean let's say—I presume you're  saying that
somebody could take a look at the first cut at it and
comment, but should there not be some built-in—would
it not be helpful to have some built-in process for public
comment?
     DR. MORRIS:  Well, I think a built-in process for
public comment in the process of developing the  ERD
could be useful. I'm not sure how easily it could be done
administratively.
    MR. BARFIELD: Couldn't the  DOE announce,
or the Assistant Secretary for the Environment, just
announce that she was in the process of preparing or
having prepared an ERD, and anyone who wanted to
submit information on this particular technology should
do  so,  give  the name in the  Federal Register, or
wherever. It's not a difficult, complicated procedure.
    DR. MORRIS: I don't see any reason not  to do
that.
    DR. REZNEK: I have some questions along the
same lines. _
    This EDP and ERD process is an internal process,
and seems to go on before the  decision to enter the
NEPA  Environmental Impact Statement formulation.
One suggestion is to, in fact, make the  environmental
research planning and the documentation  assessment
of the results  part of the NEPA process, and therefore
requiring a public review.
    Do you feel that this internal planning and evalua-
tion process should precede the NEPA process and the
public review  that that requires? Or that the two should
be integrated?
    DR. MORRIS: Well, I think they  have to be in-
tegrated in the sense that one feeds into the other. At
some point in the development of a technology, one or
maybe a series  of Environmental Impact  Statements
have to be prepared.
    It's not clear that early in the research part or early
in the research stage there's a sufficient base to actually
begin a formal preparation of an environmental impact
statement, though, I don't think.
    DR. REZNEK: In your testimony and in the proc-
ess  itself there's an assumption that it is necessary to go
ahead  on  a  particular technology and the  environ-
mental evaluation follows that assumption, and  there
are no explicit criteria for when a particular technology
should be  stopped on environmental  grounds, and
there is no cross-technology comparison on either the
performance grounds or environmental grounds to say
that this  competing technology looks better than the
other one and therefore let's stop the first one.
    Do  you—your  testimony  seems  strongly to
endorse that environmental evaluation does not have a
very effective role to play in deciding the scheduling of
the development. Do you feel that—is that a correct
interpretation of your position?
    DR. MORRIS: No.  I think that the comparative
assessments across technology can be very important
and very useful.
    They're actually done at a slightly different level
than the Environmental Readiness Document  and the
EDPs. Those documents  clearly  are associated with a
single  technology,  and  evaluate  potential  environ-
mental problems with that technology.
                                                   106

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                                                                                Statement of Mr. Rogers
    That process has not really incorporated the notion
of setting criteria for a point at which a technology
becomes unacceptable.
    I think  what  is incorporated  is  the weight  of
evidence environmentally against a technology which
might, from the outside, determine unacceptability,  so
that the technology development people will be aware
of the  potential for future development  of a  given
technology running into trouble on those grounds.
    And so while  I don't  think in this stage there is
necessarily an  internal  criteria  for  stopping the
technology, I think that it partly is recognizing outside
forces that may  stop the technology.
    Now somewhat independently, there is a  con-
siderable effort at doing integrative, comparative assess-
ment of technologies across different fuel cycles. We're
deeply   involved in this effort.  The  environmental
readiness documents really provide a base—right now a
limited base—for that, but potentially a substantial base
for doing such a comparative assessment.
    DR. REZNEK: You  would like to see a com-
parative assessment have both a formalized and a high
level role in the  Department of Energy?
    DR. MORRIS: Yes.
    DR. KINSEL: You say that you are preparing to
make such a kind  of comparative analysis of various
technologies.  You're doing the work right now? Did I
understand that correctly?
     DR.  MORRIS: That's right.  We've been  doing
comparative assessments. We have carried out a com-
parative assessment a few  years ago across the major
electric  power sources. We have  been continuing to
provide  the basis  for  a comparative  assessment  by
building  up  necessary  information  on the different
technologies  that  can   be fed into  a  comparative
assessment.
     DR. KINSEL: Where does that information go in
the DOE decisionmaking process?  Vou have the infor-
mation. How is  it transferred to the people who have to
make the recommendations for  budget purposes or
others?
     DR. MORRIS: Well, the work that we've done on
comparative assessment goes into DOE through the Of-
fice of the Assistant Secretary for Environment.
     DR. REZNEK: I have one more question. Within
any  particular technology  or  range  of  tech-
nologies—and by particular technology I would say
Lurgi  gasification   and  range all  the  gasification
processes. One question that you  raise is are those
technologies  being configured  in an environmentally
optimal  sense?
    An earlier witness raised the question of whether or
not you generate the steam for the process out of the
feedstock out of coal,  or  whether you generate the
steam out of the product which is much cleaner,-the
synthetic natural gas.
    Where are questions of environmental engineering
performance to be addressed in the scheme that you've
put forward?
    DR. MORRIS: Weil, I think that those kinds of
questions are addressed at a couple of levels. For one,
they're addressed in the environmental effort that goes
on  closely associated with the technology, and there
have been some efforts, for example, in the gasification
area, to look at engineering tradeoffs within the system
that will lessen the environmental impact,  and  those
efforts  have  gone on in the technology development
side of DOE, as opposed to the environmental side of
DOE.
    Such considerations are or also can be easily part
of the environmental readiness  documents  in their
examination  of the potential environmental concerns of
the technology.
    DR. REZNEK: Thank you very much.
    Our  next  witness is William Rogers of Gulf  Oil
Corporation.


Statement  of William L. Rogers, Manager,
Environmental Affairs,
Gulf Mineral Resources Co.

MR. ROGERS: Mr. Chairman, members of the panel,
ladies and gentlemen, the opportunity to  discuss  en-
vironmental protection measures within the Department
of  Energy's  RD&D management process is appre-
ciated. My comments will be limited  to the perspec-
tive I have  gained through participation in the coal
liquefaction  program The  Pittsburg & Midway Coal
Mining is  performing for the Department of Energy,
SRC-II.
    I appeared before you in March 1978, a couple of
months before our contract for preliminary work leading
to a demonstration plant for SRC-II was signed. 1 em-
phasized  at that appearance the  desirability of setting
standards for emerging technologies as soon as the facts
are known, to encourage and speed the application of
new fuels.
    This year I appear before you a couple of months
after we delivered results of "Phase Zero"  of our con-
tract with DOE on SRC-II. Approval has now been
granted for us to proceed into Phase One, engineering
design for the SRC-II demonstration plant.
    Since last year's  Section  11 hearing,  we have
gained considerable exposure to the DOE planning proc-
ess and have had the opportunity to  define projected
environmental  problems with SRC-II and lay plans to
solve these problems in timely fashion.
    A comprehensive baseline data-gathering program
was instituted in July 1978, specific to the Morgantown,
West Virginia site  for the SRC-II demonstration plant.
                                                  107

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Hearing of October 5, 1979
    Baseline studies which have now been conducted
for a full year, have identified no environmental con-
cerns  which would prevent  construction  of the pro-
posed SRC-II demonstration plant at this site. No critical
habitats and no rare or endangered species were en-
countered from the organisms collected at the site, and
literature searches indicated that none have existed  in
the area in recent historic time.
    Air quality measurements for background concen-
trations of  sulfur dioxide,  nitrogen  oxide,  carbon
monoxide, ozone,  lead, and total  suspended par-
ticulates are within National Ambient Air  Standards,
although ozone levels  have approached the standard.
The "guideline" for nonmethane  hydrocarbons has
been greatly exceeded on occasion.  It appears the
relatively high hydrocarbon concentrations are primarily
due to natural sources—for example,  plant emana-
tions—and possible outgassing from old coal mines.
    The water quality  of surface streams in the vicinity
of the site is highly variable. Many streams offsite tend  to
be  polluted by  acid  mine  drainage.  Other  offsite
streams, such as the Monongahela River, have better
water quality with a near-neutral pH and generally low
concentrations of  trace  elements.  The  two  onsite
streams appear to have better water quality than other
streams in the vicinity.
    Coal-derived liquids  have long  been known  to
have some  carcinogenic  potential. Nonetheless, ex-
perience  has  demonstrated  that proper  industrial
hygiene procedures can  adequately  protect persons
who come in contact with  the materials. DOE has com-
prehensive  research  and animal testing  programs
underway to more precisely  assess the carcinogenic
potential of process streams and products in the SRC-I
and SRC-H processes.
    A  research study is underway at the Battelle Pacific
Northwest Laboratories in Richland, Washington; and
Gulf has been asked to initiate and direct a comprehen-
sive toxicology program. These studies will provide in-
formation  to insure that  carcinogenic effects  can  be
avoided in the operation  of the SRC-II demonstration
plant.
    Until  these data are  available, the present health
protection program at the Fort Lewis facility will serve  as
the basis for a program to protect workers and nearby
residents from potential hazards.  Based on data ob-
tained from the Fort Lewis Pilot Plant, we are confident
that larger plants  can be operated without adverse
health  effects on  workers  or residents in the vicinity.
    From my vantage  point, the Department of Energy
procedures  and  their   implementation   are  quite
thorough  in insuring environmental protection in the
performance of DOE programs.
    The Environmental Impact Statement is a keystone
in  DOE planning.  The  influence of  the Assistant
Secretary for Health and  Environment and her staff is
felt throughout the DOE energy development program.
Input from the public is sought in early phases of proj-
ects. During our Phase Zero program we assisted DOE
with a public scoping meeting held in  Morgantown,
West Virginia on  June 26, 1979, on which  occasion
those people who will be most affected by the SRC-II
demonstration   plant  had the  opportunity  to hear
preliminary plans for the project and to comment. Addi-
tional public  meetings have been scheduled by DOE for
Morgantown, West Virginia on October 22nd, 1979,
and Pittsburgh,  Pennsylvania on October 23rd, 1979.
    I had the privilege of working with the DOE Assis-
tant  Secretary for Energy Technology  and  Assistant
Secretary for   Environment  representatives  in  the
development of the Project  Environmental  Plan  for
SRC-II. This plan is quite comprehensive, addresses
potential  environmental  concerns,  and   certainly
underscores  the  strong influence that  the  Assistant
Secretary for Environment has on DOE  projects.
    The environmental laws we now  have on the
books are, in my  opinion, indeed adequate to control
the environmental consequences of DOE energy proj-
ects. Regulations  now in force and being prepared for
promulgation by EPA will insure that emissions of all
conventional pollutants  meet  standards.  What  is
needed is close cooperation among DOE, EPA, and in-
dustry so that if the need arises to  control additional
pollutants, beyond those now covered by regulations,
standards can  be established  and  regulations pro-
mulgated in  a timely fashion so as not to delay critical
projects such as the SRC-II demonstration plant.
    In point of fact, there is widespread concern that
we have gone  too far and that environmental laws,
rules, and regulations are unnecessarily delaying energy
projects which are critically needed by the nation. The
President has recommended, and the Congress is con-
sidering,  an Energy Mobilization Board as an answer to
this, among  other problems.
    I believe the  present DOE research and develop-
ment management system and the process within that
system for addressing environmental issues already pro-
vide more than adequate attention  to  environmental
questions,  and   that  concerns  expressed   in  the
workshops can be satisfied within that system.
    Thank you  very much.
    DR. REZNEK: Thank you.
    Any questions?
    MS. HANMER: Have you found in this particular
project—since you cited a "widespread" Concern that
we have gone too  far—the environmental requirements
that  have been placed  upon your project  and the
evaluations you have had to make  to  be either un-
necessary or irrelevant to the project?
    MR. ROGERS: No, we  have not at this point in
time. Any concern is prospective.
   . DR. ATALLAH: Mr. Rogers, in your environmental
impact assessment, did you consider abnormal events
and the releases that could result on  a one-time basis,
                                                  108

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                                                                                Statement of Mr. Rogers
an  accident resulting in the release of some of the
fluids—gases or liquids—into the streams or the air?
    MR. ROGERS: That  work is underway at this
time. It has not been completed. The environmental im-
pact statement for this project is in preparation, and we
are assisting the DOE by  preparing an environmental
report. We will consider such releases.
    DR. REZNEK:  I'd like to  ask some questions
about carcinogenicity testing.
    In your own mind, do you feel that at the end of
your test there will be sufficient data available from your
tests—and  more importantly,  perhaps, from  other
sources—to  do comparisons of the carcinogen  risks
from  synthetic  liquids  from coal  versus petroleum
products, or direct liquids such as yours compared to in-
direct liquids such as the ones generated in the South
African process?
    MR. ROGERS: Of  the efforts  of which  I am
aware, the program that we are embarking upon for the
DOE  will  focus on SRC-I  and SRC-II process in-
termediates, and materials, so from that program itself
we will not have comparative data on other materials.
    However, the Department of Energy has quite a
comprehensive  program  underway at the  Battelle
Northwest   Laboratories,  which is  working to
characterize SRC-I and SRC-II and other materials, and
working to obtain toxicology results on them.
    I believe substantial information of the kind that
you're talking about will be available upon completion
of the Battelle Northwest Laboratories effort.
    DR. REZNEK: Do you believe that the EIS pro-
cess and the environmental review has substantially or
even in any way slowed  down the development of your
project at Morgantown?
    MR. ROGERS: Not to this point in time.
    DR. REZNEK: Are you  familiar with the new
CEQ guidelines on EIS preparation and do you feel that
those are a substantial improvement in the process?
    MR. ROGERS: I do indeed. 1 believe that the em-
phasis on alternatives, the emphasis on seeking advice
and input from all sources at the outset of the prepara-
tion of an EIS is most constructive.
    DR. REZNEK: Do you believe that the internal
Environmental Development Plans and Environmental
Readiness Document could or should be incorporated
in the new EIS process?
    MR. ROGERS: I think that they could be, and it
might well make some sense.
    Actually, the thing from my own experience that I
think we need to put more emphasis on is not so much
the formal  system  of preparing  documents and cir-
culating documents, but to provide opportunities for
various segments of the public who are concerned with
these projects—like government agencies, the industry,
environmental community—to meet in forums where
questions can be discussed  and interchange of  views
can be had and mutual respect can be generated.
    I was privileged to be appointed the chairman of
the Oil Shale Environmental Advisory Panel when I was
with  the  Department of the  Interior some years ago
when the prototype oil shale program was just begin-
ning.  This  panel included representatives from  the
Federal Government, the State governments, and the
environmental community, and I believe has proven to
be effective in bringing out, on the one hand, the con-
cerns of  the environmentalists  about  that particular
development; and on the other hand the thinking of the
industry and the government as they planned  the
program.
    The  National Coal Policy Project  is another  ex-
ample of this type, and I believe that attention should be
focused on trying to provide similar types of forums with
respect to other elements of  the energy development
program.
    DR.  REZNEK:  Yesterday we  heard  several
witnesses also comment on this, and I raised the ques-
tion then about in  certain  instances having third  par-
ties—be they State governments or federations of coun-
ties or any other third party—as a management agency
for such forums. Do you feel that a third party involve-
ment can, in certain instances, improve that process?
    MR. ROGERS:  In certain instances I'm  sure it
could, but  it is so  sensitive to the qualifications and
characteristics of the individual who is placed in charge
that I would be reluctant to establish that as a policy.
    I think in general it might be best to have an official
from  the Department of the government, which is
responsible for the project, chair the operation to insure
that it moves along, has continuity, and so forth, but on
occasion  there might  be  an  individual from a "third
party" group which could be effective in that role.
    DR. AT ALLAH: In the hearing that you  had in
West Virginia, I was wondering whether the public was
prepared educationally and technically to respond to
some of the problems that the environmental impact
assessment did consider. Is the public really capable of
taking an adverse position, if they wanted to? Do they
have the funds to hire  consultants to do that for them?
    MR. ROGERS: Generally not. I believe, though,
that this meeting—which was a scoping meeting at the
outset of  the environmental impact statement pro-
cess—perhaps should  not be expected to provide  the
kind  of input that you're speaking of. I think that  the
objective there is to be sure that areas of concern on the
part  of the public have not  been overlooked in  the
preparation of the impact statement. I would expect that
the kind of analysis and criticism that you're  seeking
might well  come out in the hearing on the draft  en-
vironmental impact  statement.
    DR. STOLPMAN: I've got a couple of questions.
    On  page  2  you  indicate   that  air  quality
measurements on concentrations of—and I think you're
going through all the criteria pollutants, but you indicate
                                                 109

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Hearing of October 5, 1979
carbon dioxide. Did you mean carbon monoxide there
for the measurements you took? Or were those—
    MR. ROGERS: Yes, that's right. I'm sorry about
that.
    DR. STOLPMAN: And later on you indicate that
the nonmethane hydrocarbon guidelines are greatly ex-
ceeded. Do you remember or do you recall what those
levels are that you're talking about there?
    MR.  ROGERS:  I  don't  recall the  levels.  I
remember that it was around five  percent of the total
time or the total number of measurements that were
taken and were—
    DR. STOLPMAN: Does "greatly" imply double?
Triple?
    MR. ROGERS: As I recall Jt was within double.
    DR. STOLPMAN: Okay. Then you go on to say
that it appears that those concentrations  are primarily
due to natural sources. What technique did you use to
determine that or come to the conclusion that they were
natural sources and not transport or manmade sources
or something like that?
    MR. ROGERS: That was an analytical conclusion
of the experts that we had working on the program. It's
really not supported by any  body of data.
    DR. STOLPMAN: Okay, thank you.
    DR. KINSEL: I'd like to follow up on a question
that was asked a little earlier. On  your page five you
say, "In point of fact, there is widespread concern that
we  have gone too far and that environmental laws,
rules, and regulations are unnecessarily delaying energy
projects which are critically needed by the nation."
    I'd ask you to expand on that, whether the stand-
ards are such that you feel plants cannot meet them, or
whether the permitting process is so slow that it's caus-
ing delay.
    MR. ROGERS: ! believe that the main area of
concern, at least so far as I'm concerned,  is in the per-
mitting process, and in the total governmental legislative
and regulatory scene, which can on occasion result in
unnecessary delay.
    DR.  KINSEL: So you were  not  objecting—I
assume Gulf Oil is not objecting to the level of the stand-
ards that the laws and regulations imply.
    MR. ROGERS: That is correct. Not at all.
    DR. KINSEL: What, in your experience from the
other side of the permitting process, is the problem with
delay? Is it too few people in government agencies to
process the permits in a timely manner, do you feel?
    MR. ROGERS: Yes, in some cases. In some cases
that is responsible, and in some cases it's the profusion
of permits required at various governmental levels and
conflicts between the governmental levels as to the ap-
proach. In some cases it is ambiguous language in the
law. It—there's a number of sources.
    DR. KINSEL: Okay, I have one additional ques-
tion. I don't want to take too much time, Steve, but it's
my understanding that the product of the SRC-II pro-
cess is very similar to conventional residual oil? Is that
correct?
    MR. ROGERS: That's right. It's used for the same
purpose.
    DR. KINSEL:  Yes. I also have heard criticism of
this process that there is now and will be in the future a
surplus or an expected surplus of resid. Is that correct?
Since it is a by-product of cracking of petroleum and we
have certain fixed demands for some of the other prod-
ucts of the product,  that we may not be in such short
supply on residua] oil as some of the other products,
such as gasoline.
    MR. ROGERS: I  really am not in a position to
answer your question. I  believe that SRC-H provides an
opportunity to produce  a product that is now supplied
from petroleum sources, and that through its develop-
ment we help lead the nation to the position where we
do  not require so much petroleum for satisfying our
energy needs.
    Now, I  grant it  may not be that simple and there
may be other things required as well in order to truly
remove totally the  requirement  for  offshore petro-
leum, but this is one step which can  help us in  that
direction.
    DR. ATALLAH: Going back to the same question
about the profusion of  requirements for permits, are
there superfluous permits required, that  shouldn't be
there?
    MR. ROGERS: In some cases there are.
    DR. ATALLAH: Or is it just the number that you
have to go through? Could they be combined in,any way?
    MR. ROGERS: In  some cases there are. I'm strug-
gling with a situation right now in the nuclear licensing
area, the uranium mill and mine that we have projected
in New Mexico, in which the Congress passed a law
called the Uranium Mill Tailings Act that is a fine law
and has  proper provisions—nothing wrong with the
standards—but unfortunately, because of a defect in the
language, it  appeared that in agreement states, where
there was agreement for the state to license the facility,
that the Nuclear Regulatory Commission  was directed
by  the Congress to assume licensing  authority over
byproduct materials  in  those agreement states imme-
diately for a  three-year period, and the  State could not
assume that until three years after the date of the law.
    And whereas we had been working with the State
and the State  had been  employing  the  Nuclear
Regulatory Commission as a consultant in their licens-
ing  action, so  there  was no substantive technical con-
cern, we found ourselves required to obtain, in addition
to the license from the State, a license from the Nuclear
Regulatory Commission, which—since  of course that's
a Federal action—required an environmental impact
statement, and we were unfortunately saddled with a
delay  in  the  licensing action,   under those  cir-
cumstances—which  really does not address substantive
characteristics of the project. It is just a procedural mat-
ter that causes delay. That's just one specific example
that I know about.
    DR. STEVEN REZNEK: Thank you very much,
Mr. Rogers.
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                                                                                Statement of Ms. Tachau
    Our next witness is Susan Tachau of the National
Center for Appropriate Technology.
    Could you see—perhaps we're not getting out to
the audience—
    MS. SUSAN TACHAU: No, it's not on.
    DR.  STEVEN REZNEK:  One of them is the
recording mike, and one is the public address system.
    MS. SUSAN TACHAU: Okay.

Statement of Susan Tachau,  Assistant Director
Washington, D.C. Office of the
National Center for Appropriate Technology

    MS. SUSAN TACHAU: I am pleased to have the
opportunity to testify before you today regarding Sec-
tion 11 of the Federal Nonnuclear Energy Research and
Development Act.
    The National Center for Appropriate Technology,
NCAT, is a nonprofit corporation with its headquarters
in Butte, Montana.  NCAT was  established two years
ago through a grant from the Community Services Ad-
ministration  to develop  and   apply  appropriate
community-based technology to meet the specific needs
of low-income  people and to  promote  locally-based
programs that develop individual-based and community-
based self-reliance.
    At our Montana location, our staff of seventy-five is
developing a number  of  environmentally sound and
energy conserving technologies which all have  a great
potential  for  producing  or conserving  significant
amounts of energy for our country. However, in order
for these technologies to make a significant national im-
pact, the Federal government must make the effort to
spread them as fast and furiously as possible.
    Mr.  Chairman, the comments I  wish to make re-
garding the Program and Project Management  System
followed by the Department of Energy are based on a
single guiding principle. The principle is that the end-
use for which the energy is required should determine,
as much as possible, the source and form of the energy
to be employed for that use. The choice  should  be
based on considerations of conservation or, in other
words, of energy economy. This means that preference
should always be shown for forms of energy that, while
remaining compatible with the end-use to which they
are put, are as direct as possible, involve as little  capital-
intensive technology as possible, and come, as much as
possible, from renewable sources. There are some end-
uses,  for example, for which electricity is the  only
suitable form of energy, but  heating homes with  elec-
tricity supplied by oil-fired or nuclear-powered plants is
not such an end-use. There are less costly and more
efficient forms of energy for  heating homes than such
plants offer.
    Many  appropriate technologies are very  large
energy  savers  and  do not  have the adverse envi-
ronmental effects associated with conventional  large
scale technologies.  Many of these  technologies are
being developed at NCAT today. Allow me to list them:
passive solar heating and cooling, weatherization train-
ing and technology development, microhydropower,
solar  reliant greenhouses,  alcohol fuels,  organic
agriculture  and  community  gardens,  low-cost  solar
water heating, and biogas production.  Development
and application of these technologies need to be made a
part  of  our national  energy program. All of these
technologies conserve or displace petroleum and all
have  very  small detrimental effects, if any, on the
environment.
    The major review process for R&D projects by high
level DOE  officials is called the Program and Project
Management System, PPMS. The PPMS only reviews
major system technologies. These are systems that are
generally of high technical complexity and of very high
cost. Appropriate technologies, on the other hand, are
by definition low-cost and uncomplicated, and, as such,
are very unlikely to be included in the  PPMS review
system.
    Also, the PPMS review process does not take into
consideration alternative small-scale technologies when
it evaluates a particular major system technology. !n
other words, it does not consider other ways to obtain
the energy which  is proposed for production by the
technology under  consideration. The PPMS is  con-
cerned with determining if the technology is sound, the
cost  acceptable,  and  the  environmental  effects
manageable; but it is not concerned  with matching
technologies to end-uses for energy in order to achieve
maximum conservation.
    If technological alternatives are not reviewed, then
energy conservation possibilities will not  be  addressed,
nor will appropriate technologies or  other alternatives
be addressed which might produce more economically
the  same  amount  of  energy as  the   large-scale
technologies being  considered.
    There  are also some problems with the assessment
of environmental impact of major system technologies
in the PPMS review process.  Most of the assessment of
the environmental impact is generally  done on the
national level. Most of the serious environmental effects
of the new large-scale technologies will be felt  most
severely  at the  regional and local  levels  where the
energy facilities are actually located. These effects must
be examined closely. Coincidentally, it is at the regional
and local level where appropriate technology's environ-
mental soundness  will be most obvious. Thus, small-
scale  appropriate technologies could be implemented
much more rapidly and  economically  than  complex
mega-scale projects.
    Mr. Chairman, we understand that DOE faces a
very great challenge, and a bias in favor of large-scale,
expensive technologies is, perhaps.to be expected. But
we would urge  DOE to consult with NCAT and  other
advocates of appropriate technologies more freely and
more frequently than they appear to be doing. We at
NCAT also recommend the  following changes in the
DOE PPMS review system:  First, change  the PPMS
review process so that it includes consideration of small-
scale  technologies capable  of  producing  equivalent
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Hearing of October 5, 1979
amounts of energy, either by generation or conserva-
tion, thereby reducing adverse environmental effects,
and; second, make sure that the environmental analysis
done under the PPMS review process includes regional
and local impacts of technologies under consideration.
    Mr. Chairman, members of the panel, that con-
cludes my testimony. I appreciate the opportunity to
appear before you and will try to answer any questions
you have.
    DR. STEVEN REZNEK: Thank you very much.
    Are there questions?
    MR. CLAUDE BARFIELD: How does the DOE
evaluate the list—let's take the list that you gave of
appropriate technologies now.  Is it just done by  the
Assistant Secretaries—relevant Assistant Secretaries—
    MS. SUSAN TACHAU: There is one Assistant
Secretary  who  should  be   evaluating  appropriate
technology—that's the Assistant Secretary for Conser-
vation and Solar Applications. Under that section is the
Office of Small-Scale Technology, which has been very
helpful to us. In addition, the Office of Consumer  Af-
fairs has been involved to some extent in promoting ap-
propriate technologies. Other  than that, though, I don't
really believe appropriate technologies and energy con-
servation are seriously considered in DOE.
    MR. CLAUDE BARFIELD: I think-it occurs to
me that it might make sense not to try to integrate
yourself in the PPMS,  which may be asking sets of ques-
tions and have the kind  of analysis that might not be
even relevant to the kinds of things you're after. But, it
might make sense to beef up  a second process for, so-
called, appropriate technologies and small, more cost-
effective technologies.
    MS. SUSAN TACHAU: That is a good idea.  But
we are  still  interested in having  some input in  the
analysis  of the large-scale technologies.
    MR. CLAUDE BARFIELD: But that's a different
set of questions,  I think. It doesn't preclude having a
separate kind of system for the kind of technologies
you're interested in. Do you see what I'm saying? You
could still try to have some input into the other analysis.
    MS. SUSAN TACHAU: I think you're right.
    We're trying to have as much input as possible, and
we seem to  have very little contact in other organiza-
tions like ours, so we have very little input.
    DR. BISHOP:  You emphasize in  a number of
places that there is a need  to examine  technologies
based on their overall energy efficiency or economy,
and looking  at smaller appropriate technologies which
could supply the same equivalent energy as large-scale
technologies.
    Have you attempted to actually do that in any
of—with any of the appropriate technologies and deter-
mine if  sufficient capacity  of small  dispersed nature
could actually displace—
    MS. TACHAU:  Yes.
    DR. BISHOP: —certain large-scale technologies?
And could you comment on that?
    MS. TACHAU:  Yes, I am fairly  new  to  the
organization, but our R&D staff in Burte has  indeed
done this, and I don't have the exact figures,  but for
instance  with various  passive solar  and active solar
systems you can heat a home more efficiently and more
economically than with many other energy sources, like
centrally-generated  electricity or oil.
    DR. BISHOP: Have you been able to examine
the environmental effects of small technology explicitly,
or are these statements of a kind of general sense and if
it's small  it!s not—
    MS. TACHAU: No, in fact we-
    DR. BISHOP:  —going to  have  as  large an
impact?
    MS.  TACHAU:  No. In fact, we have been
monitoring committees which go out to study the envi-
ronmental effects of our projects.  We  have one right
now that is monitoring small-scale alcohol stills. We feel
this is very  important.
    DR. BISHOP: And does that analysis take into
consideration an aggregation of such facilities—
    MS. TACHAU: Yes it does.
    DR. BISHOP: —in terms of their total impact,
even though dispersed, and further, does it look at the
total  materials  cycle  involved  in producing  these
technologies?
    MS. TACHAU: Yes it does. That's one of the
things  that we're  very  concerned with, is that  we
try—we are monitoring  the entire system,  the entire
process. We do want to have the technologies dispersed
and while we're looking at the local, community impact
of those technologies, we're also not forgetting to look
at the  aggregate, nationwide  effects of these  things.
    DR. STOLPMAN:  You indicate that the PPMS
review process  doesn't take into consideration alter-
native small-scale technologies when it evaluates par-
ticular major system technologies. What do you have in
mind as the—as what you would like to see that proc-
ess—I mean would you like to see an evaluation of
small-scale  energy  alternatives that could be funded
at equivalent levels, or exactly what are you looking
for there?
    MS. TACHAU: They wouldn't need to be funded
at  equivalent  levels,  but when  you  evaluat^ a
technology with every step, see if that is the end use that
you want, see if that is the type of technology that  can
best produce the amount of energy that you want, and
protect the environment at the same time.
    DR. STOLPMAN: But if you determine that—
    MS. TACHAU: Then you would stop—
    DR. STOLPMAN:  —passive solar is the bet-
ter, more cost effective,  less—more environmentally
sound—
    MS. TACHAU: Then you would be promoting
passive solar instead of the others.
                                                 112

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                                                                                Statement of Ms. Tachau
     DR. STOLPMAN: Then you'd stop funding the
major—are you basically saying that that then should go
into the  budget considerations  and you would stop
funding the major utilities?
     MS. TACHAU: Well, I'm not sure  I would stop
funding all of them. It would depend on what the other
technology was and what it was capable of producing.
I would certainly not rule out stopping funding of par-
ticularly objectional technologies and generating  the
energy they were to produce by various appropriate
technologies.
     DR. REZNEK: One other witness on the first day
of testimony commented very similarly to you that the
major management decision now is whether or not to
move on in-scale in a particular technology, and he sug-
gested  that the major management  review be in the
in-use  sector—for example,  home heating—and  it
include—that  major management review include  a
comparison  of  all  alternatives  to  provide  home
heating—conservation,   appropriate  solar,  gaseous
fuels, liquid fuels, and electricity—and in each of those
reviews to lay  down the research problems associated
with each one of those,  what the return on  Federal
investment in R&D would be, and then to select a pro-
gram not on a single technology, but on a total program
designed  around home  heating, for example.
     Would you endorse that concept?
     MS. TACHAU: Yes I would.
     DR. AT ALLAH: Some of these programs that you
list, the eight programs, appear nice on paper, but when
you  think about them—I'm not qualified  to talk about
solar energy, but you look at the weatherization, alcohol
fuels, and biogas production. There may be more risks
involved to the individual farmer who might build a little
still in  the backyard1 or a biogas production  facility,
where you're now exposing a person who's not trained
technically to a new technology, whereas in the other
case, where you concentrate your environmental prob-
lems under the control and assessment of technical peo-
ple,  it might be less risky for that farmer.
     MS. TACHAU: I  agree with you.  That  is why
when we have these grants and we promote these pro-
jects, we also  have a training manual and we send
people out to help them.
     It  is  very important that people  know  how  to
operate  these  technologies..   Of  course,  much
appropriate technology, like weatherization,  isn't  so
difficult.
     DR. ATALLAH: Right, but you could accumulate
toxic gases in the house.
     MS. TACHAU: Well yes, but that's not really a
problem.  We're not talking about airtight houses, here.
Previously there may have been some problems with in-
sulating, but our studies have now shown that  even in
very well-insulated houses, there is enough leakage that
there's  always  enough fresh air ventilation to prevent
buildup of noxious gases. I don't know the details here.
If you want, I can get back to you on this.
    Of course, there can be risks, like with alcohol stills,
simply because more people are getting involved in the
energy-producing process.  But that's  why  we think
training is so important, that's why we produce so many
detailed manuals that tell people exactly what to do. Let
me add one thing. There may  be direct threats to
people's safety with some appropriate technologies, but
there are also many fewer indirect threats, like air pollu-
tion from coal burning, radiation  release from nuclear
accident, or water shortage caused  by high water use
from synthetic fuel plants. So, things more than balance
out. In fact,  I'm sure you're not surprised to hear that I
think  that  greater safety  will definitely  come  with
appropriate technology.
    DR. ATALLAH: We also have seat belts, but-
    MS. TACHAU:  —but  it's  very important that
 people are in control of their energy resources.
    MS. HANMER:  I thought  your statement was
very good. I wonder,  what acceptance are you finding
at  the State and local level,  both for the concepts of
appropriate technology and for specific projects?
    MS. TACHAU:  Really very  good acceptance. In
Montana, for instance, we have a  great deal of support
from the Senators, the Congressmen, and the people in
Butte,  and  we're  showing  that these technologies
actually work. Our—it's very hard to convince people
appropriate technologies work when you don't see any
examples.
    We've been in existence  for two years. People are
finally  hearing   about  us.   They  know  about  our
greenhouses. They  know  about our  solar panels.
Weatherization  is  showing  significant  conservation
effects. So now it's getting much easier. It's much easier
to  work with the people and to show them that it works
now.
    We have a project in Portland, Oregon, or Eugene,
Oregon,  where  all  the technologies  are being  in-
tegrated, and the whole community  is working on this.
    DR. STOLPMAN: In your development of these
appropriate technologies, what kind of environmental
monitoring are you doing?
    Let me give you an example.  In the weatherization
I think the point that was being  made  down here is
when you lower the turnover of the exchange rate of air
in  your home you can get build-up of perhaps—
    MS. TACHAU: Right.
    DR. STOLPMAN:  —radon  or some  other—
maybe NO2 or some other  noxious pollutants.
    Do you,  as—in  developing or pushing  these
technologies, do you have a monitoring program going
that would indicate whether indeed  you're creating
environmental problems with these technologies?
    MS. TACHAU: We are constantly evaluating the
environmental effects  of our programs.  If you want
                                                  113

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Hearing of October 5,  1979
specifics, though, for example, on the radon-toxic gas
issue, as I said before, ! will have to get back with you.
    DR. KINSEL: I'd like to ask a question about the
analysis you alluded to that you're doing.
    One of the things we find in Washington that gets
the attention of members of Congress or policymakers is
some analysis of the cost of a barrel of oil equivalent
saved. We have discussed already this morning and
apparently  previous  witnesses have  gone into con-
siderable detail about the need for some type of cross-
fuel comparison.'
    That's  very difficult based on perhaps straight en-
vironmental  assessments,  but  one  thing  which  is
relatively simple to use as  a  cross-comparison  are the
dollars invested versus the energy which is saved or the
cost of energy produced.
    When  that type of analysis is applied, all kinds of
interesting things happen from the perspective of those
concerned about the environment. Conservation takes
on a much more impressive  role in the future energy
policies of  the country, and some other  things—like,
synthetic fuels—are put into  what my organization, at
least,  and others feel is a more proper perspective in
terms of the role that they should play.
    Are you doing any of that type of analysis, even
taking  into  account the labor costs  of building  passive
solar devices or greenhouses to assist in heating? Are
you coming up with any kinds of numbers on this?
    MS. TACHAU: Yes.
    DR. KINSEL: —what the cost of oil equivalent
saved is?
    MS. TACHAU: Yes.  Our research and develop-
ment organization  in Butte is doing that, and  I know
some  round figures, but not  specifics,  but I could get
back in touch with  you on those.
    DR. REZNEK: In your second recommendation
you stress the inclusion of local and regional impacts in
the entire process of review within  the Department of
Energy, and this is a subject that several people have
commented on, obviously a difficult question.
    Do you—have you thought of ways in which you
can accomplish both local and State review without pro-
longing that review process indefinitely?
    MS. TACHAU: It would  prolong it, but I would
think it is important to still have those inputs,  and it's
important that the  local people and the whole region
has some input into those technologies which would af-
fect them directly.
    Right now it's  my understanding that when we for
instance are developing a  coal gasification .plant, you
are trying to determine on the national level how many
BTUs it will produce, rather than how that plant will
affect that community. Consideration is not placed into
what will need to be done for that community, what
Federal programs will be affected,  what new schools,
what new highways, what the people actually  want in
that community, whether they—you know, how much
energy that community will receive from that plant.
    So it's important that they have the  input and I
think  it is important  that the process continue,  even
though it will prolong it perhaps a little bit.
    DR. REZNEK: There has been a suggestion that
at the national level certain concerns—for example, im-
pacts  on CO2 and temperature of the global environ-
ment; general health assessments of the pollutants that
are emitted—that the national assessment deal with
those  kinds of questions and that both the authority and
the responsibility for the review of the individual site im-
pacts be delegated to a more  decentralized authority, a
regional authority  of  the Department of Energy, or
some  other responsible individuals, that that delegation
process take place and that these reviews be done con-
currently.
    Would you favor such, or—
    MS. TACHAU:  I think I would. I'd  have to know
more.
    DR. REZNEK: If there are no other questions, I'd
like to thank the witnesses very much.  I feel that the
testimony  this morning has been very good,  and ex-
tremely helpful to  us.
    We will reconvene at 10:45.
    (Whereupon, a recess was taken.)
    DR. REZNEK: Our next witness is Neil Seldman
from the Institute for Local Self-Reliance.
    DR. SELDMAN: Thanks, Steven.
Statement of Neil Seldman
Director of Waste Utilization
Institute for Local Self-reliance
    DR.  SELDMAN:  It's  good  to be  here.  I am
presenting testimony that was developed by myself and
Richard Anthony, Solid Waste Coordinator for Fresno
County, California. We understand that EPA's involve-
ment  in evaluating the adequacy of DOE programs is
certainly appropriate, especially since DOE and EPA,
along with the Department of Commerce, are jointly
responsible  for   resource   recovery planning   and
implementation.
    Earlier this year  in Atlanta—Section  11 hearings
identified  very specific questions and concerns with
DOE's urban waste programs. In brief, these are:
  • The extent to  which actual project implementation
    concurs with legislative policy mandates.
  • The  lack of  involvement of  a  broad  range of
    alternative  energy and  conservation public ad-
    vocates in  Program Development  and  Program
    Management.
  • The failure  of DOE to encourage funding of re-
    cycling—that  is source separation recycling—and
    community scale  waste utilization development.
  • Source  separation  programs have  proven to be
    viable. They can  and have increased the efficiency
    of combustion of remaining fractions  of solid waste.
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                                                                                Statement of Dr. Seldman
  • Criteria for establishing priorities for funding which
    determine  that  only  projects  which  cost  $50
    million, minimum, are considered.
  • The lack of emphasis on the development of lower
    cost technologies and processes which have proven
    viable and are based on the development of long-
    term conservation and recycling habits by citizens.
    Let me give you a rather graphic example of how
DOE  programs are intended to discourage recycling.
Currently, DOE's urban waste technology program is
contemplating an  entitlements benefit  for  producing
BTUs from burning garbage, based on $2.07 per barrel
of oil  equivalent, or 5.7 million BTUs. Well, I've done
calculations which are included in an attachment to this
testimony, which you can look at, which indicate that if
D.C.  was to burn its 2000 tons of garbage per day, it
would generate about 20 billion BTUs per day which
would entitle  it to about $7000 a day in entitlements.
However, if it were to recycle its material, it would save
about 21 billion BTUs of energy, and that calculation is
based on the energy cost of producing  materials  from
secondary raw  materials, as opposed to  virgin. And,
yet,  D.C.  or  any  other  city would get no  entitle-
ment  benefits  from "producing"  that energy through
recycling.
    I  think another thing that came  out of the Atlanta
session  was  the  utter frustration  that  professional
recyclers, private enterprise recyclers, and  municipal
recyclers  have in trying  to communicate with the
Department of Energy. The reporting on waste utiliza-
tion in Atlanta did not have full data. It did not identify
the   limits  and   risks   of  large-scale  combustion
technologies,  and  it certainly did  not  report on the
progress  and  breakthroughs  by  community-based,
municipal, and private enterprise recyclers.
    The Federal government's urban waste technology
program  as is  currently  established is  bypassing the
approach for conservation  through  recycling and for
implementing community-based recycling, in favor  of
centralized, large-scale,  so called  "black  box" ap-
proaches. Despite about a half a billion dollars worth of
public and  private investments, over the  last decade,
these  large  systems have  a rather mediocre track
record. I should point out that currently seven percent
of this country's solid waste stream is recycled through
source  separation  recycling  by  businesses  and
households. One percent is recycled through combus-
tion and  energy recovery. And yet, virtually the  total
program of DOE, EPA, and the Department of Com-
merce has been to invest monies in the latter approach,
providing no funds for the former, although the former
is currently recycling seven times as  much materials as
the latter.
    I  should also point out that the costs for recycling
are much smaller than for centralized treatment, and of
course you should remember that the  investment  in
recycling is an investment in long term socialization and
habits of consumers and industry.
    The  national  network   containing  technical
assistance,  information  dissemination,  technology
developments using input from a decentralized network
of  professional  recyclers,  and a national  advisory
research board  for resource recovery programs would
aid in the fast implementation of such an energy conser-
vation  effort. Federal policy implementation activities
can  be   maximized  through  joint  private sector,
community-based  enterprises  which  would  create
permanent local  markets for solid  waste  materials,
reducing the  need for government regulatory action.
    A  specific  case  which  demonstrates  problems
caused by the present method of priorities is the situa-
tion in Memphis, Tennessee. There, EPA and DOE are
actively promoting a co-disposal plant which would pur-
port to burn mixed waste and sewage sludge for energy
recovery,  despite the opposition of local government,
local private sector, and local public interest individuals.
This situation is extremely urgent, and I suggest that this
panel,  or another panel,  take a very close look at the
planning process and public participation process going
on  in  Memphis,  right now,  around those  proposed
series of plants  around that city. In a note, which you
can refer to here, there are extensive and professional
critiques of  the EPA/DOE plan, and they must  be
addressed.
    Based on the preceding information, we make the
following  specific recommendations:  One—DOE and
EPA present development of technical  and scientific
information is insufficient as it does not consider ad-
vancement of such technologies as cryogenic rubber
processing, glass plastic extruding technologies, com-
posting,  vermicomposting  technologies,  small-scale
recycling  industries  for  paper,  glass,   and  metals
recovered from waste. Similarly, DOE's Urban Waste
Technology   Program has   ignored  these  needed
technical  developments.  Investment  in  participatory
systems should  be preferred over investment in expen-
sive hardware so that resource and energy conservation
can be maximized.
    Two—Each  agency  should  rethink the  steps
necessary to  maximize conservation.  Involvement of
community in recycling will raise the efficiency of any
ultimate  disposal  system by  incineration  effort  by
removing noncombustibles from the waste stream. In
some respects,  land burial where recovery could  be
made when necessary may be  more practical than a
capital  intensive system which would destroy resources
for a rather ephemeral BTU value.
    Three—Development of a Technical Assistance
Network tapping  local recycling expertise to provide
help to local jurisdictions.  Local agencies that now exist
can provide professional assistance to Federal agencies.
EPA, DOE,  and  the  Department of Commerce can
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Hearing of October 5, 1979
revamp their programs to include maximum involve-
ment of such professionally competent organizations as
the  four  state recycling  associations  in  California,
Washington, Oregon, Colorado, the one in New York
City, and the West Michigan Environmental Action
Council in Michigan. These people have been investing
the better part of a  decade in developing professional
competence, track records, and run very  successful,
economically viable  programs. At this point, they have
virtually no input  to EPA, DOE, Department of Com-
merce  planning for resource recovery. They've been
specifically excluded.
     Four—Development of a nationwide  education
and  information  program, modeled  after the  best
aspects of state  programs in Washington,  Oregon,
California and  Maine  to produce  and  disseminate
literature, reports, films, slide shows, technical forums
and  computerized reporting. For an example, the In-
stitute  for Local  Self-Reliance  for Fresno  County
developed and distributed  materials regarding  grant
information  and  technology  developments to  local
officials, and community representatives in Fresno. The
local  government  there  has   no  capability  for
disseminating this information. An EPA survey dated
1972 revealed that 90% of housewives surveyed would
be willing to  source separate their household waste for
recycling. (Whether most of that 90% would pay a
higher  monthly fee in order to support recycling is vir-
tually unknown.) A Fremont, Seattle  report on a typical
neighborhood of mixed income and racial composition,
a neighborhood program now getting 68% participation
for voluntary curbside recycling and  a California State
Solid Waste  Management report indicating breakeven
levels—tonnage  breakeven levels—for economically
viable recycling programs—none of  these reports are
made available to the public.
     I want to point out that recycling  is usually criticized
for not being able to support itself economically.  Well,
no waste system supports itself economically. However,
recycling is the one system  that comes closest to  sup-
porting itself in direct costs, and in terms of indirect costs
benefits the community in terms of employment, educa-
tional spinoffs,  and community  effects. Those non-
quantifiable benefits are  not included when I say that
recycling comes closest to paying for  itself in a sector of
the economy which is completely subsidized and tradi-
tionally has been completely subsidized.
     Another major source of information is the "650"
grant proposals in California. Recyclers in that  state,
along with industry, presented a program now in effect,
which is funneling $5 million a year for infrastructure in-
vestment in  recycling.  There are  about  forty  very
technically competent proposals submitted to the Solid
Waste  Management Board which would make wonder-
ful reading,  and excellent training for  recyclers, com-
munity groups, and cities across the country. This infor-
mation must be disseminated.
     Five—DOE must establish new criteria for projects
based  on net  energy  benefits,  maximum  payoff  in
energy  returns per  dollar  invested, and establish a
small grants program  for  urban  waste technology
development.
     Six—A national citizen's advisory board should be
formed to review and recommend to DOE, EPA and
DOC policy for a resource recovery program. It could
also suggest impacts of proposed projects in regard to
conservation,  environmental  protection,  economic
development,  and  citizen  participation. The  board
could  be  chosen  from  among  community-based,
municipal and private enterprise process or manufac-
turing  recyclers,  energy  recovery combustion unit
manufacturers,  environmentalists,  educators  and
equipment  manufacturers.  Subcommittees  for each
region could be established to evaluate programs and
identify and prioritize research needs, hear or publish
reports  on new and developing technologies and par-
ticipation processes. They would serve to channel infor-
mation to DOE, EPA and DOC, as well as to State and
local  levels. This program  could  be  integrated into
existing Section 11 processes.
     Seven—DOE should develop a waste  utilization
research  and  development  program  to   stimulate
economy-of-scale  analysis  and  demonstration   of
manufacturing technologies which could, at little or no
increase in  per  unit  cost  of production,  produce
products for local markets using the solid waste stream
as materials in  the solid waste stream as the primary
feedstock to the industry.  The RCRA  mandate  to
develop markets for recycled  materials and  DOE's
primary responsibility for development and commer-
cialization of projects for funding could  create funding
for these types of programs which would create a local,
steady demand for raw  materials coming from the solid
waste stream. I point out that in the City of Seattle, right
now, 19% of the solid  waste stream is  being recycled
through private enterprise buy-back centers—with no
involvement of the Federal or local governments.
    Local governments and the Federal Government
could reduce regulatory activity by utilizing private sec-
tor and community-based mechanisms  as a  positive
price  incentive  which  would  replace  the  need for
Federal  Government intrusion in local government and
the  private  sector.  Such   a  program  could also
encourage  joint private/public ventures and  could
integrate positive  private  enterprise and community-
based organizations.
    We believe that these steps will allow DOE, EPA
and DOC to better achieve their mission to develop and
commercialize   technologies  that  are   economically
practical, technically feasible, and environmentally ac-
ceptable, while at the same time increase public partic-
ipation in planning, implementation and evaluation.
    Right now, the country is making an investment in
solid waste technology. Roughly, a half billion dollars of
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                                                                                Statement of Dr. Seldman
Federal money will be used over the next three or four
years to develop technologies. I would say that virtually
no thought  has gone  into  the  opportunity  costs
associated  with investment  in  high  technology  cen-
tralized development. That is, the cost of not making
those  funds  available  to  decentralized  recycling  ap-
proaches. The opportunity costs can be tremendous. I'll
give you one very quick example in the City of New
Orleans. Since 1973, the City of New Orleans has been
working  under  a contract  with  a  private  resource
recovery firm. The City has to deliver 650 tons per day
of solid waste to that facility. The City can undertake no
activity to change the amount in the City's solid waste,
or the composition of the City's solid waste. If they do,
they have to pay financial penalties. I've just come back
from New Orleans where there is a strong coalition of
community  groups  that  want to start  implementing
cryogenic processing of rubber tires, alcohol derived
from organic waste,  small-scale paper manufacturing,
small-scale smelting  and product manufacturing, along
with a host of other technologies, which have been
demonstrated or are about to be demonstrated. They've
gone to their City for assistance, but  their City cannot
give them that assistance. They would be in violation of
their contract with the resource recovery firm. That is a
major  opportunity cost for those community  develop-
ment  corporations  in  those cities  which  have  the
resources if they could have access to Federal,  local and
state money for implementation of these technologies
which provide employment, orientation toward conser-
vation, and as I said  before,  community effect.
    It would be a great tragedy if citizen's groups, and
community development corporations in the City of
New Orleans, and in other cities, could not pursue that
alternative path toward resource recovery because of
"up front" biases on the part of Federal administrators
who simply do not want to consider recycling. This bias
is pervasive, not only in the government, it's in private
industry  and it  appears in the  highest  levels  of
academia.
    I'll give you another example.  Last week, people
participated in an AAAS Research Agenda Conference,
for resource recovery. New technologies and  develop-
ing technologies were  not considered. Reports were
given in which people outwardly stated they have a bias
against recycling, therefore, they didn't consider  it.
These  attitudes  have to change,  and recyclers  and
citizen's groups and environmentalists have formed the
Committee for a National Recycling Policy to make sure
that they do change, and that the public becomes aware
of the  choices now available in the resource  recovery
investment.
    This Committee  was formed earlier this year, and
it's based on the following five principles: 1. That com-
prehensive  recycling  of solid waste is essential for  the
preservation of the nation's natural resources. 2. That
comprehensive recycling of solid waste is essential for
the stability of economic growth  which is  currently
threatened by the scarcity and high costs of energy and
raw materials. 3. That comprehensive recycling of solid
waste is essential for the education of  citizens  to less
wasteful consumption and disposal habits. 4. That com-
prehensive recycling and  utilization of solid waste is
essential  for the  community  and economic  develop-
ment of the nation's declining inner-city and rural areas.
5. That comprehensive recycling of solid waste is com-
patible with energy systems planned to burn wastes after
recyclables are extracted from the solid waste stream.
    Committee members  include 100  of the leading
private  sector,   university,  community-based  en-
vironmental groups, researchers and practitioners from
around the country. The resources and  cumulative ex-
periences  and professional skills of the Committee are
available  to this Panel, and/or  any other forums you
might recommend to  help develop  management and
technical programs to implement comprehensive recycl-
ing in the economy. The Committee represents those
individuals who have invested ten years to the realiza-
tion of environmentally sound and economically viable
solid waste management. They  would now like to see
these accomplishments broaden through participation
in Federal policy forums, and thereby help prepare our
country for the future  decades  which will be charac-
terized by energy  and  material resource shortages.
    DR. REZNEK: Thank you.
    Are there questions?
    DR. AT ALLAH: Yes, I was wondering if you have
in mind any research and development programs that
ought to be done in the urban waste area, because ! feel
that   we're past the  demonstration stage.  The
technology is there, the problem is local acceptance and
economics.
    DR.  SELDMAN: Can I ask you to clarify what
you mean by resource recovery  technology?
    DR. AT ALLAH: Well, you said 1% of the current
waste is recycled and recovered—recovering the BTUs
out of it.
    DR.  SELDMAN: One  percent  is recovered
through  centralized,  capital  intensive  combustion
systems. I think, and industry agrees with me, bankers
agree with me, manufacturers agree with me, that fur-
ther  subsidization  of  centralized  technologies  is  no
longer necessary.  That is,  those technologies that are
proven, the private sector will move into and develop
because the money is there and  the technology works.
If you're talking about recycling, there is a wide range of
research, implementation and evaluation of programs
that is required. In fact, the National Science  Founda-
tion has recently  funded the  Institute for Local Self-
Reliance, where I work, to conduct a research agenda
conference for recycling. This conference is in the pro-
cess of being formed, the first orientation meeting is in
San Francisco on November 9th. The followup meeting
is a month later in D.C., and the research agenda will be
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Hearing of October 5, 1979
presented to the National Science Foundation. I would
say  over 60  professional recyclers, university re-
searchers, manufacturers,  materials  purchasers  and
government  scientists  and policy officials will be in-
volved in the formation of that recycling agenda. It will
be completed by January 1980, and I will be happy to
present it to you. The agenda will identify the research
needs and implementation  needs in the area of source
separation recycling and  small unit  combustion for
energy recovery.
    I want to  stress one thing when  I say small unit
combustion.  The economy of scale of energy recovery
plants is 250 tons per day. That means it's going to cost
you the same amount,  on a per ton daily capacity basis,
to build a 250-ton plant as it is to build a 1,000 ton
plant.  By going  to  a 1,000 tons,  you  realize no
economy of scale. And yet, most of government spend-
ing and research  has been in the area of large  scale
1,000 ton-per-day facilities, in pyrolisis and wall-to-wall
incineration and RDF. And, for this reason, there has to
be a change in Federal programming—it's just backing
the wrong horse,  and it's putting virtually all of its
resources on  the  wrong  horse.  And, this research
agenda will articulate the areas that you asked about.
    DR. REZNEK: I'd like to ask a few questions. Do
you feel that a methodology exists for evaluating the net
energy benefits of a technology transfer program, that
is, the dissemination of information program on the pro-
grams that currently exist?  That is, you could evaluate
what the net energy benefit would be  of such an infor-
mation transfer program itself.
    DR. SELDMAN: Yes, I  think you could, if you
can give some  kind of formula on how much technical
assistance will  lead to how many tons of materials
recycled. And, 1—for instance,  earlier draft  of this
testimony, I  pointed out that a proposal that was set
forth to EPA two years ago to set up a  decentralized in-
formation system   and  technical  assistance  network,
meaning professional recyclers in California would give
assistance to cities  in California, same thing for Oregon,
Colorado, and so forth.  If that plan had  been im-
plemented, that 7% per year could have been raised to
8% per  year.  I could work out  the energy savings
numbers and the  economic value of  that  1%  of 150
million tons per year. So, those things can be worked
up, given some assumptions.  I think  that the current
technical assistance panel's program of EPA and the
peer  matching program   in  EPA,  if  properly  ad-
ministered could increase the  level of recycling above
7% if it would  involve  the people who have the actual
experiential knowledge, and those who have been do-
ing it for ten years. At this  point, these people are not
involved in those programs.
    DR. REZNEK: My second question, you partially
answered. Do you feel that it is possible to do today a
calculation of net  energy benefit—say in doubling the
7 to 14%?
    DR. SELDMAN: Oh, those are very simple ex-
trapolations. They could be made.  We could use the
chart  that I  have for D.C., in  the testimony I gave
you—my testimony to the DOE target hearings, and
simply extrapolate from that—that would be a relatively
simple task.  I should point out that although DOE you
might think  would perform a net energy balance and
would do these comparisons, whether you should burn
or recycle. DOE has been asked to do  that, they have
yet to do that. It's relatively simple to do, I don't know
why it hasn't been done.
    DR. REZNEK: Given a perception  that DOE is
preoccupied  with  energy  supply,   and  that  the
Environmental Protection Agency is preoccupied with
enforcement against industry, do you feel that any of
these  agencies are  likely to convert and pursue, ac-
tively, a recycling  program?
    DR. SELDMAN: I think, yes. I  think the three
agencies that have primary responsibility for this, can
work  together and develop a good memorandum of
understanding. I think I  differ with you a bit in that I
think  if  you read the legislative mandate for DOE's
Urban Waste Technology Program they're not told to
produce energy through garbage. They're in the Office
of Conservation, and considering that by recycling-you
conserve more energy than you would—with lower cost
than you get if you burn it at much higher cost—I don't
think it's at all amiss to ask those people to consider con-
servation as  part of  their existing mandate. Now, they
have not interpreted it that way, but 1 don't think it's a
problem with their  mandate to develop urban waste
technologies.
    MS. HANMER: This is a little bit aside from the
Department  of Energy, but it seems to me that many of
the things you said are indeed addressed to EPA policy
and practice.
    I'd be interested to  know what kind  of response
you have had from the Office of Solid Waste and EPA
to the same  concepts you have put into this testimony.
    DR. SELDMAN: The Institute and Institute staff,
and members of the Committee for National Recycling
Policy have been addressing their needs and concerns
to EPA for the better part of five years.
    Some   modifications  in EPA  programs   have
resulted directly, as a result of this dialogue. The most
significant has been the model scope of  work under the
Urban Grants Program through the combined work of
the Institute, the  Department of Natural Resources in
Michigan, and the county of Kent in Michigan, and the
West  Michigan Environmental  Action Council  and
Recycle  Unlimited,  community-based  recycling
operation.
    It was pointed out to EPA that their model scope of
work  again  fit into  the  traditional pattern of putting
source separation  planning and implementation as an
asterisk to comprehensive planning on solid waste.
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                                                                               Statement of Dr. Seldman
    This has been changed. EPA has also agreed to in-
volve more community-based recyclers in their peer
match program. That has not been implemented, based
on my best information.
    EPA has also been asked to change their technical
assistance panels, because there's  an inherent bias in
the contractors who get that  contract. Is everyone
familiar with how those panels work? Okay. Those con-
tractors don't like recycling. They don't have experience
in it. They don't make money out of it. They should not
be responsible  for providing technical  assistance  on
recycling.
    EPA has not moved on that.
    I would say that the dialog with EPA is open. We
talk to them. However,  their record  in following our
advice to move toward integrating recycling professions
into their programs, I feel, could be improved.
    DR. BISHOP: I'd like to clarify one point. Maybe I
missed it, because 1 don't see—have a copy of your
written testimony. You made your references primarily
to recycling as being a more efficient approach than
direct combustion.  Does that hold true in terms of the
economic value of the end-product uses of the—of solid
waste materials?
    That is, is the energy value greater than the recycl-
ing value, even though the net energy may be less? See
what I'm saying?
    DR.  SELDMAN: No,  1  don't  understand  the
question.
    DR. BISHOP: In other words, if you burned the
solid waste, and used that energy in whatever form, or if
you used the  solid waste to produce methane or—
    DR. SELDMAN: I see what you mean.
    DR. BISHOP: —or some  other end product, is
the economic value- of that greater  than if you had
recycled that material in as a primary—
    DR. SELDMAN: To answer that I would have to
break it down into the components of the solid waste
stream. In the area of paper there's a raging controversy
now between  reports from various agencies. Some say
you get more energy from recycling paper a number of
times than you do from burning it.  I happen to  believe
that's true, but it's controversial at this time.
    In terms of organics, wet  organics primarily, it
doesn't make much sense to burn them at all. Forty to
sixty percent is water anyway; the transportation costs
are a major problem. The economic benefit and energy
savings  benefit of producing organic  matter, com-
posted,  vermicomposted organic matter from organic
waste, has recently been documented in an NSF report
by Roger Blobaum. ! don't know the full title. It was
done  a  few months ago. They did  a model  on the
Omaha/Council Bluffs metropolitan area and the value
of organics in  that solid waste stream to the agricultural
area immediately surrounding that area.
    When you get to other materials, such as metal and
glass, you have the problem that  centralized systems
 destroy those materials and they are no longer available
 for recycling. The technology of extracting glass and
 aluminum from mixed solid waste has not been proven.
 It's still in its developing stages.
     The technology for  pulling out  metals in some
 cases works, but  in other cases the metal is too con-
 taminated to be marketable in the secondary industry.
 Therefore, the metal and glass is completely lost, so the
 energy  values—and  economic   values—of  those
 materials are forfeited.
     So you have to take a calculation based on the
 specific parts of the waste stream. Because centralized
 waste recovery does not deal  with the metal or the
 glass, and because it gets a very, very ephemeral value
 out of wet garbage in terms of BTU, I would say that
 we'd be much better off  keeping those materials and
 feeding them back into the secondary materials stream.
     I can give you references on energy evaluations,
 comparing  recycling  to centralized  recovery. I could
 give you those references later.
     DR. REZNEK: One more question.
     MR. BARFIELD: I take it the—your contact with
 the Department of Energy is largely through the Assis-
 tant Secretary  for  Energy Conservation  and Solar
 Energy. Is  that correct? Is that where this urban re-
 cycling is—
     DR. SELDMAN: Yes.  In the  Conservation  and
 Solar Applications Division.
     MR. BARFIELD: That—the programs collected
 in that  area, and that Assistant Secretaryship, per-
 sonalities aside, is certainly counted outside as one of
 the weaker elements of the Department of Energy.
     Have you had—do  you have any sense of—in
 terms of the people you deal with—of the programs you
 deal with—of what their  problems  are and why they
 seem to be ineffective or maybe even—
     DR. SELDMAN: Yes, I think they're  profes-
 sionally competent. I think they're managing a program
 for investment in one form of resource recovery. I don't
 mean to question  that.
     However, they made a decision, and that decision
 is  a  rather limited one in terms of  the availability for
 investment in the total area of resource recovery.
     MR. BARFIELD: When  you say  "they,"  you
 mean the people, the program people  who are par-
 ticularly involved in your area. Have you tried to kick
 that  upstairs, say  to the deputy level or the assistant
 secretary level?
     DR. SELDMAN: I talked to a whole lot of people
 at DOE, and I've  been told to try to get the message
 from the Congressional energy committees to them,
 rather than to try  to change the policy program from
 within.
     MR. BARFIELD: And has it been successful?
    DR. SELDMAN: We're talking to a lot of people.
And I notice, for instance, that   in a  very  recent
 solid waste report  that came out, Representative Florio
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Hearing of October 5,  1979
who is the Chairperson  of the House Transportation
and Commerce Subcommittee, is calling for a new ad-
visory committee. I have the statement. It's something
that's pushing  in the right direction, and we've been
feeding them a lot of information.  When 1 say "we" I
mean the Committee for National Recycling Policy have
been feeding a lot of information to his staff, to Senator
Durkin's  staff,  and  to Senator Bradley's staff—they
serve on the Senate Energy Committee.
    DR. REZNEK: Thank you very much.
    Our  next witness  is Mary  Jadiker  from Lake
County in California.

Statement of Mary Jadiker
Lake County Planner
Lake County, California

    MS. JADIKER: Good morning and thank you for
the opportunity to present a microcosmic perspective of
DOE effectiveness in geothermal energy development
in the Geysers area of California—and, by reference,
other areas in the West.
    My  name  is  Mary Jadiker, and  although  it
sometimes has been my role in the past, I trust I'm not
your token environmentalist today.
    I'm here to  represent what I consider a truly  lost
minority in the DOE project management system, and
that's local government,  and the residents of areas of
energy resources in the process of being developed.
    I'm a Planning Commissioner of the  County of
Lake,  a  member  of  the   California  Geothermal
Resources  Board  Technical  Advisory  Committee,
Geothermal Advisory Council member to the California
Energy Commission, and Advisory Committee member
of GRIPS, which is a four-county joint powers geother-
mal agency, and I served by gubernatorial appointment
on the State Kapiloff Geothermal Task Force. That's
relevant only as a sort of flash of credentials and to show
that I have actively participated for the last five years in
the cause for appropriate and sensible development of
geothermal energy.  And in the process I've become a
member  of  the  new elite, the Informed  Public, that
people always worry about.
     There's another side to all of those organizations in
which I participate,  and that  is none of  us—none of
them—have ever been  able to establish an effective
means of communication with DOE in terms  of their
role in geothermal energy development.
     What I consider appropriate and sensible develop-
ment of any resource is that which occurs as the result of
decisions made by responsible people after the probable
consequences  of those decisions are revealed through
predevelopment assessment and periodic  reassessment
of the entire spectrum of economic, environmental, and
social short- and long-term impacts on the area being
developed.
     This assessment must include more  than looking
for rare  and endangered species, because so far we
humans and our habitat are not on the endangered
species list.
    The Department of Energy has a role to play here.
Geothermal electrical generation  is a realized fossil fuel
alternative. It is an interim source of a few hundred or
thousand megawatts. We have 605 megawatts at pre-
sent  from fourteen  operating plants  in the  Geyers.
National policy should  encourage alternative genera-
tion facilities, as well as conservation and increased
efficiency.
    That, however, should not  foreclose the need to
realistically accept the environmental impacts of alter-
native forms of energy.
    Somehow, at least  in the geothermal energy field,
the Federal role has been misdirected. Once someone
decided that The Geysers should be able to produce X
megawatts in X years, DOE funded a  cottage industry
producing scenarios which inevitably showed that it can
be done with only benign or beneficial side effects in the
timetable set out, and then when real life doesn't match
the scenarios, it somehow determined that real life—not
the scenarios—are in error.
    Local government, the folks who must actually
make the ultimate go/no-go regulatory decisions, are
the ones who have to live with the immediate results of
those decisions. We're the ones who see and hear and
smell, pay for, or benefit from our  "go"  decisions.
Obviously we  feel those ultimate decisions must  be
made at the local level.
    And just as apparent is the  fact that local govern-
ment does not have the resources to develop the infor-
mation base necessary to make wise decisions.
    We have a lot of questions.  We do not appreciate
the outside political and economic pressures put on us
when we make a "no-go" or "go-slow" decision.
    Lake County is a small, poor, rural county which
has the mixed fortune of containing a projected three to
four  thousand megawatts  of geothermal energy. We
have  about 35,000 people, but the population has
doubled in the last five years. We're entering a period of
intense population growth and development. We don't
want our  decisions on geothermal development today
to preclude other growth options tomorrow.
    We have  a  lot  of questions, and those questions
could be answered by adequately funded and  defined
data base acquisition programs and pollution control
strategies.
     DOE has spent millions  studying The Geysers.
We're practically an  annuity for the National Labs. But
local government still doesn't  have the basic environ-
mental and economic information it needs in the form it
can use.
    We tend to think it might be because no one ever
came to us and asked us.
     Local government is too often treated as the object
of some  anthropological  field  trip.  Our geographic
jurisdiction  seems  to  be  considered  as  some
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                                                                                Statement of Ms. Jadiker
underdeveloped  colonial possession,  just  right  for
exploitation.
    There's no one geothermal location that will ever
be likely to produce thousands of megawatts, or that
heat energy equivalent.  Geothermal energy is simply
not best suited for large, central distribution use. It's a
much more Jeffersonian energy source.
    Unfortunately, that  means that  most  geothermal
projects are the wrong scale for DOE's present manage-
ment system.
    If I could give DOE just one direction for geother-
mal program assistance,  it would be "Think small." If I
could add another, it would be, "Stop the scenarios and
go ask the  locals what they need to plan  appropriate
and sensible energy development in the area of their
jurisdiction."
    Some  specific suggestions which would improve
the local interface between the Department of Energy
and everyone else is to establish more regional contact,
give more autonomy to the DOE regional offices, set up
means for more  DOE participation with local govern-
ment and the public, more public access to the DOE en-
vironmental review processes, and expand  the concept
of an environment to  include the total socioeconomic
and  human   elements.  Change  the  basic  project
management system so the same people stay with the
same energy source and its development scenarios.
And establish a method of periodic review of the project
by others in the agency and the public so that the public
does not come into the process late, late, with only the
opportunity to comment on a draft EIS.
    Many projects never have an EIS.
    Establish regional information centers with a public
advisor-type ombudsman, live person. The California
Energy Commission has established such an agency. It
seems to be always at war with the rest of the Commis-
sion and everyone else, but local government and the
public appreciate and use the facilities of the Public Ad-
visor's Office whose function is to assist members of the
public—and that turns out to  be anyone who is not the
Energy Commission and a project proponent—to assist
members of the  public to participate in the regulatory
decisions that the Energy Commission must make.
    And last,  again, think small.
    Thank you.
     DR. REZNEK: Thank you for your very eloquent
testimony.
    Are there questions?
     Claude?
    MR. BARFIELD: I just have a comment. Your
testimony on  another—relates to another  subject. I
hope while you're here you'll go to  whoever  the
representative is  for your—in the House to lobby him
against the House making the same mistakes that we've
been  making for the last two days in the Senate, to
create an energy mobilization board that will sweep right
over you, whether  you're talking about  geothermal
energy or whatever kind of energy.
    So if you've got an hour today while you're here,
you might stop by over there.
    MS. JADIKER:  I happen to know he's a pro-
ponent of the idea.
    MR. BARFIELD: Well that's too bad.
    MS. JADIKER: Yes.
    MR. BARFIELD: Have you had any—where is
your contact in  terms  of Department  of Energy, nor-
mally,  for State and local concerns?  Is it-has it been
through the  now-abolished Assistant Secretary for—I
forget  what  the combination  is—Congressional, In-
tergovernmental, and Public Relations?
    MS. JADIKER: No, it has not.
    MR. BARFIELD: Or has it been with the program
people? Or do you see any—is there much interconnec-
tion between what the Assistant Secretary for Inter-
governmental Relations, as far as you know,  does,
or—I forget  what the  title is—and the local program
people who are handling say geothermal and  local
government concerns?
    MS. JADIKER: DOE seems to be constantly in a
very fluid state,  as they say. One of the problems we
have had is maintaining a constant contact source.
    Most of our contacts come from  the project pro-
ponent, and most of that has come from the regional of-
fice, the San Francisco office.
    We have not effectively established—on the state
level or particularly the local level—any ability to deal
on  a small government to large government agency
basis. It has been entirely on specific programs, whether
it's pollution  control abatement assistance, or whether
it's deep-hole drilling, or whatever it is, or whether it's
trying  to seek  funds  for  a  particular environmental
research project.
    We are very often cut off at the regional level, with
the kinds of words such as, "Well, it won't do you any
good to go any  further because we make the decisions
anyway, and so don't bother." And  we have found
when we go around the regional office and do go di-
rectly to the Washington headquarters and speak to
people, and  obtain assurances of  cooperation, that
while the regional office has existed in the manner that it
does, the funding is not able to get through the regional
office to us.
    We have been extremely distressed, but since the
management aspects of DOE seem forever changing,
we are not able to know if it's hopeless, or if it's just a
product of change.
    DR. KINSEL: I  also enjoyed your testimony. I
found it very informative.
    One of the  criticisms that has led to the popularity
of the Energy Mobilization Board is that local and State
governments, as well as the Federal Government, are
unresponsive to the big picture perspective and the
need to reduce dependence on foreign imports, and
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Hearing of October 5,  1979
they take too long to make decisions,  which is why
Claude mentioned there is interest in the ability to run
over them.
    Would you comment on that, from the perspective
of someone at the other end? You alluded to the fact
that you don't have the kind of information you need,
even  though the Department of Energy has spent
millions of  dollars studying geothermal power. Could
you give some specific examples of the kinds of things
that might be beneficial to you, to speed the process
from your perspective, that's not now being done?
    MS. JADIKER: Yes I could, and it's an involved
answer, and one of the problems with that myth, which
has led to  such  schemes  as the Energy Mobilization
Board and projected ideas that the whole Geysers area
should be declared a national energy resource and con-
demned—you know, that kind of thing goes on too—is
that I don't know where the idea that State and local
governments are the  reason  for  slow  development,
occurred. But 1 think it is not true in terms of the time it
takes  to issue a permit from the time an application is
received until the developer has his permit to drill a well,
build a power plant—power plant permitting takes two
years now. California's made all kinds of expediting
laws. Well drilling permits take less than a year because
we also have a twelve-month you've-got-to-make-up-
your-mind law in California, and I tend to think that it is
the economic problem of the resource that has been the
real delaying factor, rather than local foot-dragging on
the terms of local government.
    There  has been a tremendous  amount  of  foot-
dragging at the  Federal level  in issuing leases for
development,  but  there is  not   a tremendous
amount—there isn't any  foot-dragging at the  local
county level. We issue land-use permits without which
no one can drill a well. Unless you drill a lot of wells and
find some steam there's no point in applying for a power
plant permit, which is issued by the State.
    And those  processes do  go  ahead  with a
reasonable expedition.
    In Lake County we have  I guess it's about 120
geothermal wells  permitted and drilled, most of which
are good. There has been one denial out of all of that in
all this time. The average time it takes to get a permit to
drill a well is probably nine months, and considering the
amount of environmental assessment—we  operate, of
course, under CEQA (California Environmental Quality
Act)—that doesn't seem at all unreasonable.
    It's—one of the problems we find in the geothermal
business particularly is that since you—since it looks as
though you're drilling for oil and gas, and you have the
same  equipment  and the same derrick and the same
crews, and the same technology, and you can get a per-
mit to drill  an oil well in ten  days in California, that
people thought perhaps it should take ten days to get a
permit to drill a geothermat well and establish a geother-
mal field.
    I tend to think that a lot of that myth of local
government foot-dragging has come about as a result of
industry's dismay that they're simply operating under a
different system and it's a different resource.
    But there is very little truth to that. If you want to
run out of time lines, there are a hell of a lot of permits
that have to be obtained.
    CEQA  (California  Environmental  Quality Act)
came into the process about the same time as the push
for geothermal energy began seriously  in  California.
The Public Utilities Commission ceased being the giver
of power plant permits at about  the same time. The
California  Energy  Commission came into being—all of
this was in 1973 through '75, really. It took a very long
time for everyone to learn how to do those dance steps,
figure out the new regulatory system, and I feel because
of that, plus the fact that there has not—economics of
geothermal electrical  energy  development  is  now
proven, but was not,  and I think perhaps adding all
those things together led to some over-reactive industry
statements and some over-reactive legislation.
    That's certainly true  in California, where by the
time the lobbying  has gone through, the bill has gone
through, it's finally passed, the problem for which it was
passed to correct has already corrected itself.
    DR. REZNEK: Any other questions?
    (No response.)
    DR. REZNEK: We  heard some other testimony
on an office similar to that established in California. You
would—I assume  you  have envisioned the  local body
who is a real person, but a management structure within
the Department of Energy that would assess the viability
of the program and report on the progress and actually
translate to the local authority and the local situations
the assessment process plus the dissemination of infor-
mation and the evaluation.
    MS. JADIKER: That's true.
    We'd  like to think of State and local agencies and
governments being able to be partners with the Depart-
ment of Energy, rather than having the Department of
Energy be our patrons.
    DR. REZNEK: Thank you very much.
    Our next witness is Allan Hirsch from the Fish and
Wildlife Service of the Department of the Interior.

Statement of Allan Hirsch
Fish and Wildlife Service
Department of the Interior

    DR. HIRSCH: Mr.  Chairman, let me begin by
very briefly describing  the role  of the Fish  and Wild-
life Service in the energy research and development
process.
    One of the missions of the Fish and Wildlife Service
has been to gather, analyze and present ecological in-
formation that would aid in resolution of environmental
problems associated with major resource changes in the
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                                                                                   Statement of Dr. Hirsch
country, and as a consequence, the Service has been
heavily  involved  in  energy-related  issues.  It  has
been—as you know—a participant in  the Interagency
Energy Environment Research and Development Pro-
gram,  administered by EPA,  and in a  number of
Department of Interior energy  development activities
such as coal development, geothermal development,
oil shale, and outer continental shelf oil and gas leasinc
activities, where we have an  opportunity to bring the
results of our information gathering and research and
development to bear on these programs.
    My comments this morning are not going to try to
critique the Department of Energy's Program and Proj-
ect Management System. We  haven't been involved in
that system and 1 don't feel equipped to critique it. In-
stead I'd like to comment more generally on some ways
in which ecological considerations can enter into the
process of research, development, and commercializa-
tion of emerging energy technologies.
    Further,  I will focus  specifically here on  the
ecological impacts, as distinct from direct human health
effects or other effects.
    The Prehearing  Documents that you  prepared
identified the  need for more explicit environmental
criteria for application  to major Department of  Energy
decisions  relating  to  the  development  of  energy
technologies,  and among  those  would  be  criteria
relating  to  ecological  impacts.  One of the  questions
raised was how this  process could  more  effectively
assess the ecological impacts.
    It is possible to  formulate a number  of  explicit
ecological criteria that would guide the decision process.
Some examples are bioaccurnulation of toxic materials,
evidence of food chain'magnification, irreversible effects
on significant populations or  species of organisms, or
modification of important environmental processes such
as geochemical cycling. I think there would  be general
concurrence that any impacts  falling into the categories
like these would be serious and possibly unacceptable.
    But for such criteria to be used effectively in deci-
sions relating to energy technology, we have to relate
those to the magnitude, the scale, and the cumulative
effect. We can really state very few absolutes. At what
point along a continuum, for example, would the con-
tribution of a new energy technology to acid rain or to
the CO2 problem become so unacceptable as to in-
dicate that  no further investment should be made in
research and development on that technology?
    A great deal remains to  be learned  if we are to
strengthen the input of ecological criteria into the risk
assessments that have to address questions like that,
and the effectiveness of these risk assessments is often
limited by our ability to accurately predict ecological im-
pacts, particularly second and third order effects. The
difficulties of predicting the response of ecosystems to
stress from development are  well known, and in  this
area these difficulties would be compounded by the fact
we're often dealing with new and as yet unexperienced
technologies.
    Therefore, from the standpoint of taking account of
ecological  considerations in  the  energy research,
development,  and commercialization process, it's im-
portant  that  we  try  to  think  in  terms of  adaptive
mechanisms and adaptive management techniques.
Such  techniques should include provision for monitor-
ing and tracking  impacts through each stage in the
energy  research  and development  process.  They
should include highly focused research studies to fill im-
portant gaps, as well as retrospective studies to evaluate
the actual impact  of past  practices, and the findings of
these efforts have to be fed back in a systematic way into
the process of developing and commercializing energy
technologies.
    In this regard, I strongly support some of the pro-
posals that were identified in the Prehearing Document,
such as assuring the inclusion of integrated and parallel
environmental research, development, and monitoring,
along with the  technology  development,  as  the
technologies move from the basic research stage to the
pilot plant, the demonstration plant, and ultimately to
commercialization.
    The need has to be  stressed for  experimental
facilities  which test not only the technological capability,
but also the environmental issues. There's also a need
to emphasize decisionmaking systems  which focus  on
incremental and   adaptive  decisionmaking  to  the
greatest  extent possible,  rather than .go/no-go deci-
sions, so that we  can  reflect, as we move through the
various steps,  the findings of environmental research,
assessment, or monitoring.
    Thus far, what I've been emphasizing is the need to
improve our understanding of ecosystem response to
energy technologies and to integrate that with the deci-
sion  process.  Perhaps  that  sounds  like,   "more
research," or,  "we don't  know enough to provide ad-
vice." I  would like, however, to focus on one of the
ways in which we could do a great deal more today to
apply  our existing understandings. That involves the
development and use of ecological criteria early in the
planning process  of facility siting.  What I have to say
here applies  more  when we  get to  the  stage  of a
demonstration facility or  commercialization of a proc-
ess, than it does to the fundamental bench research at
the beginning of the chain.
    This  basically  involves  developing  and  using
ecological criteria  prior to siting decisions. Today these
considerations usually enter in after individual sites have
been selected  and are being evaluated,  and after the
battle  lines have been drawn.  If we use these criteria
early  in  the process of identifying candidate sites for
demonstration  projects  or  for   full-scale  projects,
we could ease—if not avoid—many of the last-minute
confrontations.
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Hearing of October 5, 1979
    I'll describe how I think this can be done in three
basic steps. The first step is to describe the ecological
characteristics  of  regions  in which  the technology is
likely to be applied. If it is a given form  of coal gasifica-
tion or liquefaction for example, and we know generally
the regions  in which that technology is likely to be
brought  to  bear,  we  can  describe  the  ecological
characteristics  of these regions. This can range from a
simple inventory  of vulnerable components—such as
endangered species—to a more complete characteriza-
tion of  the structure  and  the function of the major
ecosystems within that  region. I would advocate  the
latter.
    Such a characterization, based on the  use, syn-
thesis, and interpretation  of existing data, can  be  ac-
complished within a one- to two-year  period. Thus it
can be scheduled in a way that cannot be said to unduly
delay the developmental process. And  yet the absence
of a meaningful framework of such ecological data ha;
often been a major obstacle. It has resulted in delays ii
the development process and it has  resulted in very in-
effective environmental assessments. So it seems to me
that in thinking about the further development of energy
technologies, one  important step is to  make provision
somewhere in the governmental structure for planning
and conducting appropriate regional ecological surveys
or characterizations well in advance  of siting decisions.
By and large,  provision  for that does not exist today.
    I'll give one example of this. In  response to  the re-
cent controversies  concerning  refinery siting on  the
Atlantic Coast—and you may have read in the paper
this morning that the  Department of Army has essen-
tially decided to go ahead with its approval of a refinery
site at Portsmouth—the Fish and Wildlife Service  has
just  initiated  a  survey  to  identify  the  ecological
characteristics  of  individual  segments of  the entire
Atlantic Coast. This study  is not oriented towards  the
detailed site-specific analysis that is  needed after a  site
has been selected, but  rather towards the  kinds  of
regional  analysis that  could support advance planning
well prior to the selection of individual sites. The survey
will  provide  a  framework  of  information  about
ecological characteristics of the Atlantic Coast.
    The second step would be the  development of
siting criteria, and the application of those criteria within
the region concerned to designate in advance areas that
are particularly unsuitable for various kinds  of energy
facilities or development.
    The way this would be approached for any emerg-
ing technology is to identify the  physical and chemical
effects of the component processes as  well as we can,
and  then,   taking  into  account  the  ecological
characteristics  of  the  region   concerned,   to
describe—again,  to the  extent that  we can  within
existing  knowledge—the  likely impacts  on  various
ecosystem components  or ecosystem functions. To do
this, one can use impact matrices or models or other
existing techniques of environmental assessment.
    To a relatively straightforward or simple example of
the application  of regional siting criteria has been the
Department of  Interior's recently adopted  coal leasing
program,  in which criteria for designating lands un-
suitable for mining have been developed. These criteria
include such things as areas containing valuable habitat
for threatened and endangered species, areas important
for the maintenance of migratory bird  populations,
flood  plains,  and  other sensitive ecosystem com-
ponents. Now the coal  resource regions subject to leas-
ing by the Department of Interior are being inventoried,
and these kinds of criteria applied to  exclude areas from
leasing early in  the planning process.
    A third step, in addition  to providing for regional
ecological characterizations and for identifying impact
categories and  criteria, is to try to develop an applied
planning mechanism through which  these environmen-
tal or ecological criteria can be weighed in  concert with
other siting criteria on a regional scale.
    For example,  we  can use multiple objective pro-
gramming  models  which  balance   economic,
technological, and environmental  objectives to address
regional siting issues, once we have developed the ap-
propriate data base for ecological criteria. In this way
we're  not talking about ecological  criteria which are
presented or considered as absolutes, but rather criteria
that can  be appropriately weighed  and balanced in a
systematic way  with the other kinds of concerns that go
into siting  decisions. By and  large, that  is not  done
today.
    In summary, then, for that aspect of the energy
research and development program that involves the
location of large-scale or full-scale facilities, if we con-
duct, in advance, rapid characterizations of the regions
where  these facilities are likely to be located, if we iden-
tify siting criteria appropriate  to the various classes of
impact, and if we pursue the application of those criteria
through various kinds of planning mechanisms, we can
make  an  important improvement  in  the location of
energy facilities.
    Thank you.
     DR. REZNEK: Thank you.
    Any questions?
     DR. ATALLAH: As a point, to site an LNG facility
at the location—or a refinery—I can estimate the risk to
the public and society and get a number for that, or at
least a feel for it. I can compare it with other risks.
    If  I were to-transfer or transpose a kelp  species from
Newport Beach, California to the  Atlantic, how can
I—what criteria would  I use for risk  acceptability to the
ecology—not to the public?
     DR. HIRSCH: Well, acceptability, of course, is a
social or political determination. For example, in outer
continental shelf leasing we can project the trajectory of
oil  spills  that might occur if a given tract were to be
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                                                                                  Statement of Dr. Hirsch
leased and the probability that those spills would occur
at a certain time of the year, and we can give an assess-
ment that  those  spills would  have such-and-such a
probability  of eliminating a large population of marine
birds. That we can do.
     Now,  as to the consequences to  society of
eliminating that population of  marine birds,  unless it
happens to be a species that is commercially of impor-
tance or a  species in which the secondary  impacts on
the ecosystem can be determined, that becomes very
much a matter of social and political determination. But
at least we can reveal for trade-offs what the significance
of that action is, not necessarily what the public accept-
ability of it  would  be.
     DR.  AT ALL AH: Somebody  has to  make  a
decision whether  this  new  technology is going to go
or no-go.
     DR. HIRSCH: Right.
     DR. ATALLAH: And so they must have a set
standard of criteria for accepting that risk to ecology.
     DR. HIRSCH: Well, as I tried to indicate, it's quite
difficult to  come up with very finite criteria,  because
most of these things tend to operate along a continuum.
It's hard to answer, for  a criterion which involves certain
kinds of food chain impacts. On what scale and with
what degree of irreversibility does it  become  unac-
ceptable? 1  think we can do more and should do more
to try to document these classes of criteria, but I'd argue
that there's no one answer—-it  becomes very much a
matter of risk assessment. What I'm saying is that the
ecological component  of risk assessment can be quan-
tified much  better than it has been in the past, and in ad-
dition we need to  do a lot more to improve that quan-
tification through integrated research at every step in the
energy process.
     DR. REZNEK: Allan, if  you can call me "Mr.
Chairman," I can  call you, "Dr.  Hirsch."
     Dr. Hirsch, from your comments you seem to be
saying that in terms of where to do a  particular thing
there are systematic approaches, there  are quantifiable
approaches that  will  lead  to  very much improved
decisionmaking.
     DR. HIRSCH: Yes.
     DR. REZNEK: But in terms of  either  what to
do—that is, should we  build a high-temperature gasifier
or a low-temperature gasifier, the status of ecological
assessment has not yet progressed to the point where it
is stable enough or intellectually compelling enough to
make a solid argument that will  allow you to design the
engineering.
    Is that  correct?
     DR. HIRSCH: I  think in application that's prob-
ably correct, but that in potential, it's not correct. One of
the paradoxes of  NEPA is that NEPA was set up in
policy to take into account the effects  of man on the
ecosystem and its consequences. I think that's been one
of the weakest components of the NEPA EIS process,
and there are various reasons for this that are fairly com-
plicated, in my judgment.
    One is that ecosystems are very complex, subject
to all kinds of variables and extraneous events, although
I'm not sure they're any  more  complex  than  the
economy is. Frankly I think that the ecologists can prob-
ably have about as good a batting average of prediction
as economists can do these days, and yet, you know,
the economic aspects—
    DR. REZNEK: The economists work for a lot
more.
    DR. HIRSCH: Yes, but there are a whole host of
reasons why we aren't bringing ecological assessment to
bear as effectively as it can be, Steve. I would argue that
we can do a lot better job of it. There are techniques.
    We, in our program, are trying to explore some of
these. I was interested in  some of the comments  that
were just made here. Some of those techniques involve
a number of fundamental principles, one of which is
that ecosystems are dynamic, that you have to operate
on a risk basis, and it's not a black and white snapshot
approach.
    I think that the EIS process in a way has almost
hindered that, because of the pressure to get an en-
vironmental impact statement. The  new procedures
under NEPA do allow or encourage more use of a flexi-
ble, adaptive response to ecological assessment  that
would build in incremental decisionmaking, that would
build in monitoring, and that would build in some sense
that we're dealing with a  dynamic process and not a
one-shot deal.
    I'm not stating this very clearly, but my answer is I
think we can do a lot better within the  state-of-the-art
than  we have been doing.
    DR. KINSEL: 1 am  very  interested in your out-
lining of the steps  that could be used.
    One of the  problems—and you cited one of them
which frequently arises, once a plan is announced to
build a refinery in  a specific place—occurs for what we
think is somewhat  the opposite of the reasons you were
talking about, that the process goes backward.
    Instead of  looking  for  good  places  to build
refineries, a company decides it can get land cheaply—
    DR. HIRSCH: Yes
    DR. KINSEL:  —and then starts through the per-
mit process and runs into  objections for often very
legitimate reasons.
    You refer to the Portsmouth situation specifically.
As I understand it, an analysis was done of East Coast
refinery sites and Portsmouth came in last, as I recall.
    DR. HIRSCH: That's right.
    DR. KINSEL: Is that assessment the kind of thing
that you're talking about doing ahead of time?
    DR. HIRSCH: Yes,  well that's certainly true. An
analysis was done of 37 alternate sites. Perhaps that is
an example of a failure to capitalize on the analysis.
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Hearing of October 5, 1979
    But I'm arguing for something on an even larger
scale than that.  We are talking about looking at the
Atlantic Coast, and—instead of coming in and trying to
attack the tail end of the process—indicating what the
relative vulnerabilities are. I don't think this has been
done well ecologically anywhere. I'm not arguing that if
it  is done well  that the  development  interests will
necessarily take  cognizance .of it, but I  can think of
power plants where there has been long litigation going
on, where, if they had  stopped to think about it, they
would have seen that the plant is located at the absolute
place   where  they  would maximize  the  ecological
problems.
    So I think  it's that kind of thing—rather than
engineering in solutions after you locate the plant, try to
put that up in the siting criteria at the front end.
    Now I'll admit that the case you're giving is an ex-
ample where—at least in my judgment—attempts to do
that didn't work very well.
    DR. KINSEL: One other very quick question.
    You talk about integrating the environmental con-
cerns with some of the others. Obviously the weight
that's applied to various of those factors in your model is
going to be critical.
    What agency could do that, giver1! that we have a
number of single-mission agencies all of which think that
their mission is more important than anyone else's?
    DR. HIRSCH: There is an institutional barrier
there. Some states  do  have siting commissions. The
State of Maryland, for example, has a facility siting act. I
believe New York does.
    We're experimenting  right now with the Electric
Power Research Institute on something  called  a
multiple-objective  programming  model   for  the
Delaware, New Jersey, Pennsylvania area, trying to
show a configuration of sites in relation to demand that
would optimize these various features!.
    Until we came  along they were looking at things
like distance from load  centers, distance from  popula-
tion centers, adequacy of water  supply. We're now
cranking  in various environmental criteria.
    How the results of  that kind of approach get taken
into account in "real world" decisionmaking  within the
kinds of regulatory or planning institutions we  have, is
quite variable, but there are places where it certainly can
be done.
    I would think a utility, in its own interests, would be
interested in that kind of  analysis  in doing  its own
planning.
    MS. HAMMER: Allan, I'm interested in how the
information  and research that the  Fish and Wildlife
Service is developing is factored  into the assessment
and evaluation process for energy technologies in the
Department of Energy.
    Do you have any kind of cooperative arrangement
or memoranda of understanding or anything like that?
    DR. HIRSCH: In that regard I feel a little bit like
the previous speaker. We have had various ad hoc
dealings with the Department iof Energy. Of course we
get to review their  Environmental Impact  Statements
just as everyone else does, which is at the tail of the
process.
    We don't have a systematic relationship with the
Department of Energy that allows our views to come to
bear in the most meaningful way. There are probably all
kinds  of reasons  for  that—changing  organizational
structures in the Department of Energy, the fact that we
are operating in an area where our  mandates are not
that specific, and so on. If it comes to consultation on an
endangered species, there's  a specific legal mandate,
and that functions. But if it comes to cranking in what
might be called a broader ecological viewpoint into the
assessment, there's  no real mandate for that, that I'm
aware of.
    So the answer  is, we don't have as systematic in-
volvement,  by  any means,  as  we should  have. Our
Assistant Secretary has recently corresponded with the
Department of Energy suggesting that  we try to find
ways  of strengthening that relationship.
    DR. REZNEK: Any other  question?
    (No response.)
    DR. REZNEK: I'd like  to call one more witness,
Robert E. Thomason of the Occidental  Oil Shale Pro-
jects,  or Occidental  Oil Company,
    In the  history of hearings before me, it's a surprise
witness.
Statement of Robert Thomason
Occidental Oil Shale
    MR. THOMASON: Thank you, Mr.  Chairman,
distinguished panel  members, ladies  and gentlemen. I
want to thank you for the opportunity to speak to you
for a few minutes.
    Again,  my name  is   Robert  Thomason.  I'm
representing Occidental Oil Shale. As a representative
of the oil shale industry, I feel fairly comfortable in sitting
in the spotlight as oil shale does with 360 degree high
intensity and talking to an EPA panel. I would like  to
represent this particular case from Oxx's position that oil
shale  would be dealt with in-depth in  this particular
hearing. As a result, we did not feel disposed to making
a formal testimony. However, having been conditioned
to—in oil shale, to monitoring everything, we decided
to come forward and sit in on the hearings and if we felt
it was useful, to be responsive to some of the remarks
that were made, essentially to be responsive  to support-
ing some of the activities that DOE and EPA are under-
taking in an effort to further this ground of cooperation.
We think this cooperation is very important to the suc-
cess of the synthetic fuel energy development industry.
    We've  been listening for the better part of three
days to testimony which is intended to focus the ade-
quacy of attention  to environmental protection, and
                                                  126

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                                                                              Statement of Mr. Thomason
energy conservation measures within DOE's RD&D and
demonstration process.
    It  seems to me,  after listening to much of the
testimony—much of what has been suggested is being
done or has been done. Much of the remarks have been
1 think productive. However there are some ideas that
came across in particular with regard to the preparation
of multiple environmental  impact statements, as sug-
gested by Mr. Markey that occur to me as not being par-
ticularly productive or directed towards conservation or
timely energy development.
    The oil shale program as a whole, and in particular
the prototype oil shale program, serves  as a  rather
classic  example, I think, of what can be done,  and it
started indeed with one very adequate—and well done
dynamically environmental impact statement. That of
course moved  dynamically through very exhaustive
review by what Bill Rogers mentioned to you as the Oil
Shale Environmental Advisory Panel. Subsequently the
concerns put forward in this  EIS and public comment
were integrated into the detailed development plans for
the prototype program.
    The  detailed  development  program has been
exhaustively reviewed  by the Oil  Shale Environmental
Advisory Panel, which is made up of a very multidisci-
plined group of folks. This has been a very excellent ele-
ment of public exposure and a very excellent element in
providing communication between the various agencies
that are concerned, public and  private,  and  special
interest folks as well.
    I  think that  this particular program has been
extremely successful-
    As a directly involved  shale oil developer  and
cooperator with DOE and EPA, I'd just like to speak out
in behalf of DOE's effort to use technical and scientific
information in decisionmaking and the communication
of rationale for technology development decisions, and
the integration  of DOE's Energy Technology Section
and DOE's Environmental Section in research planning.
    The  DOE/ET cooperative agreement with  Oc-
cidental provides for environmental research and plan-
ning work with the Office of the Assistant Secretary for
Environment, Ruth Clusen, and an environmental task
force  has been formed to carry out environmental
research and  planning, combining the forces of DOE,
EPA,  National  Labs of the State of Colorado, the
Department of Interior's Area Oil.Shale Supervisor's Of-
fice, and project developers into a unified teamwork ex-
ercise,  in  particular directed towards gathering  and
analyzing environmental data.
    This particular interagency cooperative task force
effort being led by DOE involves the workshop process
for data analysis and problem solving, and it does in-
deed provide public exposure through a broad-based
advisory committee. That committee includes one of
the other folk's agency that was testifying here a day or
two ago, and N1OSH sits in on the committee. As is I
suppose characteristic with governmental agencies that
are complex, they have difficulty communicating what's
going on. However, indeed the EIS that was involved
and the programs that are planned therefrom and the
development  plans, do  consider occupational health
and safety in great detail, and the working environment
and the working folks in  a very, very sensitive way.
    This particular task force has also a very high level
of technical capability, and it is working to build a com-
mon element of trust and credibility. It's working to
provide data  to constructively answer environmental
questions. And  it's working towards the  sharing of
research data  and plans to  help  prevent  costly  and
wasteful duplication of effort.
    Indeed, dynamic changes in the DOE organization
are frustrating at times, and the organization could be
streamlined. However, we really see progress taking
place, particularly by this specific DOE effort, and we
want to give it a chance to mature. We feel that such in-
teragency cooperation is a very positive effort that's vital
to the success  of orderly  phased energy  resource
development.
    I think we want to guard against the initial pitting of
technologies against one another. We need to address
the total energy problem, which includes conservation,
the use  of nonrenewable  and  renewable  sources.
They'll all have a place and they're all required.
    At this point, however, we've got to concentrate ef-
forts in the direction of making early and large impact in
the short term in order to span to the long term. I think
that may be one of the explanations why DOE attends
to certain major impact areas insofar as energy produc-
tion technology is concerned, and has perhaps set less
emphasis on some of the other areas. But they're all im-
portant, and we don't want to lose track of that fact. We
support the development of all those areas in a  par-
ticularly thoughtful priority sequence that reaches the
end result.
    DR. REZNEK: Thank you.
    Are there any questions?
    (No response.)
    DR. REZNEK: Is everyone hungry?
    1 might make an observation that in addition to all
those interagency committees, there is a body, there is a
person to talk to out there.
    Thank  you very much. We'll reconvene at 1:30.
    (Whereupon, a luncheon recess was taken.)
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Afternoon Session
                                                                             Statement of Dr. Anthony
1:32 p.m.
    MR. ONDICH: First I'd like to introduce myself.
I'm Gregory Ondich. I'm the Section 11 coordinator.
Dr. Reznek will not be able to be here this afternoon, so
I'll act as the moderator.
    Some of the witnesses asked if I could reintroduce
some of the panelists, and so I'll do that, and after I do
that we'll start with Dr.  Anthony from the University of
Florida as our first witness.
    To my extreme left is Dr. Sami Atallah, from the
Gas Research Institute.  I believe your agenda shows Dr.
Robert Rosenberg. Dr. Atallah is  filling  in for Dr.
Rosenberg.
    Next to Dr. Atallah is Dr. Bishop from the New
York State Energy Research and Development Author-
ity, and we are expecting Paul Stolpman, and 1 believe
he'll probably be back. He's with our  Office  of Air,
Noise,  and Radiation Programs.
    Next we have Dr. Sheldon Kinsel from the Na-
tional Wildlife Federation. Dr. Kinsel is sitting in place of
Dr. Kimball who had a previous engagement today.
    And to my immediate left is Rebecca Hanmer, the
Deputy Regional Administrator from the EPA Boston
Region. I'd like to  particularly welcome Ms. Hanmer
because she participated last year in our hearings and
we're happy to have her again.
    MS. HANMER: They gave me a Purple Heart.
    (Laughter.)
    MR. ONDICH: So with that, I'd like to start with
our first witness, Dr.  David Anthony, University of
Florida.

Statement of David Anthony
University of Florida

    DR. ANTHONY: I am David Anthony from the
University of Florida, although I am not representing the
University. That's for identification only.
    I also—well, just again as one of the witnesses this
morning commented, just to flash credentials, I have
been involved as  essentially  an environmental  com-
municator for now some seventeen years in Florida and
the Southeast.
    As I approached this hearing, I've been somewhat
puzzled as to how you, the panel, the EPA, the DOE,
and Congress in particular, might view  this process. I
can see the possibility  that you—that it might be  re-
garded by some or all of you as sort  of  a standard
bureaucratic process, that you're required by law to do
this and therefore, do it, I could see DOE people being a
bit resentful of getting any recommendations from EPA
as to how to run their ship—the turf problems. I can see
that  there are—in fact, reading this morning's paper
there's abundant evidence that there are heavy political
pressures to—"Let's just get on with  making lots of
energy, and to heck with all sorts of other considera-
tions." Particularly. "To heck with the environment."
Witness the probable choice of Portsmouth, environ-
mentally the worst place on the East Coast they could
put the oil refinery.
     But 1 bring you a very strong countermessage from
the people that I've been talking to.  They are  your
employers, and indeed they're—in the case of  Con-
gress—your electorate.
     As I was talking to many different stations of people
in Florida there was one almost universal reaction,
when I outlined briefly what this hearing was about.
Curiously, almost to a person they said, "Give 'em hell!"
     As a matter of fact,  I started to write out a—the
reason I don't have a presentation to give you all, nicely
typed up, was that I heeded a little too well their advice
and I felt on reading it over that it was a little bit stronger
than I liked to leave with you, so in  more reflective
moments, when I get back home, I will eliminate a few
of the cuss words and send you something that's a little
less outspoken.
     But 1 think it would be worthwhile to look at why
did these people say that? I asked them, "Why do you
say—what do you want me to give them hell about?
How do you want me to give them hell?" This sort of
thing. Not that I would necessarily—they knew perfectly
well that I would go ahead and do what I planned to do
anyhow, but at least I would be influenced by what they
said.
     They felt that the energy decisions being made now
may well determine the social, economic, political, and
environmental future of this  country, yet these people
felt they 'often don't even know what decisions are being
made, and feel those they do know about are made in
some—well, clearly to them a process which defies logic
and reason. In other words, they  felt they were being
made in a thoughtless manner, perhaps in a—oh, sort
of divide-up-the-turf manner, the standard way you
might decide where to run a particular highway, for ex-
ample : that you comply with the letter of the law only;
                                                 129

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Hearing of October 5, 1979
that you keep the big special interests happy; that you
don't rock the boat; (business as usual); that you—well,
I'll censor that about what you do  with members of
Congress.
    What does the public seem to want in the energy
area? The public that I was able to contact is admittedly
a very small slice of the public. However, I have a suspi-
cion it more accurately reflects the public point of view
than perhaps you and your superiors do, isolated this
far from the public.
    First and foremost—by the way, I'm knocking quite
a bit here, and I want to stop and pause for a moment
and suggest  that you pay a lot of  attention to this
background document. It seems to  me  it  was very
thoughtfully prepared. This is counter to what I've just
said about some of the other things. I think it's very
thoughtfully prepared, and indeed with reference to the
Atlanta regional hearing, which I attended, 1 think it's an
amazingly accurate condensation of the points of view
of a very large number of people and their ideas going
everywhere. I think  it was a beautiful job and I would
commend your reading it. I  think it carries  much the
same message that I'm going to give you. I may empha-
size it a little differently in various places, but I would
commend it to your reading. I think it's a fine job.
    It seemed to me first and foremost,  that people
wanted to have ready access to reliable current informa-
tion, pro and con, on energy alternatives. You pick up
the popular  press and you find all sorts of energy
miracles suggested, and the people I know, at least, are
sophisticated enough not to believe all this stuff.
    Before coming to these hearings, I read, of course,
the reports of all  the other regional hearings, and in
every blessed one of them this was one of the foremost
considerations, the need  for more  information about
what is going on—not so much about the process of
review, but about what's going on and indeed what are
the pros and  cons of various alternatives.
    And again, it's not original with me, but it appears 1
think at least twice in the abstracts of the regional  hear-
ings that there ought to be—this is a concrete suggestion
I hope you might carry forward—that there ought to be
a well-publicized 800-number "hotline" to some real
person at DOE Regional Headquarters, at the least.
    Now on this I can  speak with some considerable
feeling,  because  in  trying  to do  some of the
homework—which I like to do before 1 appear in any
such thing as this—I was frustrated in trying to find out
things. I—indeed, it's going to  come 'home to  roost
when my boss sees the phone bill.
    1 called  all over the country to find out certain
things, and got snippets here and snippets there, and
yet I'm supposed to be, I guess, in the language of Mary
Jadiker, one of the, quote, "informed public," and I was
going up the wall trying to find out things which seemed
to be reasonable for a citizen to be asking.
    And I would suggest this "hotline" as a start. A per-
son on such a "hotline" could at least have pointed me
in the right direction, given me the phone numbers and
the people, and so on, and I could have been away
from—I still would have had a big phone bill, but my
task would have been made much easier.
    Now, I am going to make  a suggestion that is
original  with me.  It  does not appear in any of the
resource documents.  I'm suggesting that there ought to
be published on an annual basis a document whose title
might well be "Assessment of Energy Alternatives," and
it should be put out by an independent agency— not by
EPA, not by DOE—God Forbid! In my mind I had been
searching  around  as to what agency  might be the
reasonable one to do this, and happily—in an other-
wise unhappy  transportation adventure,  since it took
me nine hours to get from Florida to Washington yester-
day, many of them in  the air circling Atlanta, and so
on—my seat mates happened to be two people from
the GAO, and suddenly the light turned on. Why not
the GAO?
    They're not beholden to anybody—or supposedly
are not. And why not have the GAO or—what?—Office
of Management and Budget? You know the shops bet-
ter than I do, but I was trying to fish for one that would
seem to be neutral, and yet is used to looking at long-
term things, at weighing costs and benefits and this sort
of thing, and has a substantial staff and expertise.
    This document I would feel, this assessment of
energy alternatives, put out on an annual basis, should
include  short  descriptions  in  layman's terms—now
there's where I had an advantage.  I'm a biochemist, so I
know something of the physical sciences and something
of the biological sciences.  I was getting stuff which
would 'have been gobbledygook, except  I just had
enough—I just knew enough to ask the right questions,
and I knew where I  didn't know, and these  kinds of
things, so 1 was able  to dig out substantial amounts of
information—but you should  have  heard the gobble-
dygook I got some of the times.               :
    So I think the assessment document should be in
layman's terms. The descriptions of various alternatives
should  include  indications  and contraindications  for
their use.
    For example, say in discussing windmills, the cur-
rent thought is there has to be a certain number of miles-
per-hour average wind  velocity which is fairly high  for
them to even have a chance of being very useful. Okay,
there might well be a map published with this alternative
indicating in what regions of the country one might find
such wind velocities.
    Estimates—there ought to be current estimates of
fossil-fuel-in versus energy-out type of efficiency. And if
they can do so,  there should be some estimation of the
rate of development. I'm thinking here of photovoltaic
cells where the rate  of progress has been enormous,
and so  that a mere  statement of what it is  today is
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                                                                                 Statement of Dr. Anthony
misleading, unless one looks at the rate of progress and
what would appear to be likely very soon.
     I think there ought to be—in other words, some
sort of estimate as to how this is going to go over time,
plus there ought to be some sort of estimates of the
dollar per kilowatt hour produced, per unit of thermal
energy, or whatever it is that they produce. In other
words, the dollar efficiency. And again, versus time.
     For example, the solar buffs are constantly talking
to me about dollars per peak watt produced. Okay,
there's a number you can play with and have its rate of
movement over time portrayed, perhaps in a graph.
     This annual document I would think ought to also
have some estimate of the time it would take to reach X
percent of the national energy demand utilizing this pro-
cedure, with some  probable limits suggested, a lower
and upper  limit.  In  other words,  is this likely  to
be—ever—a  very important thing  nationally  in  the
energy picture, or is it not? In the case of photovoltaics it
might well be so. In the case of windmills, locally, but
perhaps not generally. This kind of assessment. And
then, some  kind of comments on  the  environmental
pluses and minuses.
     For example, one of these photoelectrochemical
things I have learned about required at one point in the
process, hydrolysis of hydrogen bromide to,  among
other  things—to bromine.  Well I'm  enough of  a
chemist, as soon as the guy said, "You're going to have
bromine on your rooftop,"  my enthusiasm turned to
caution. This is a potential hazard that would  require
very well-thought-out control strategies.
     I would think that this annual energy  alternatives
assessment document must also include names,  ad-
dresses, and phone numbers of where to go for more
information on each of these alternatives. It should also
include  the dollar value of Federal support to each. I
think that would be highly revealing in some cases.
     This obviously comes under the heading of access
to reliable current information. That was a motif that just
appeared over and over again. The people! talked with
felt in the dark,  and they felt in the dark about extraor-
dinarily important things.
     I'd like here to deliberately lift a comment that Ms.
Jadiker made this morning. This is  again  a recurring
thing that you find here. And, the people that I talked
to,  over and over again,  said that  they felt that  the
Department of Energy just was unable to think small,
THINK SMALL. If  it isn't megabucks, to hell with it,
seems to be the attitude.
     What the people were  saying was  they felt that
there needed to be a reordering of DOE emphasis. I've
forgotten which one of the speakers this morning spoke
about their seeming penchant for backing the  wrong
horses. I constantly was receiving this comment, "Look,
they're  pushing  very  hard for an  energy  alternative
which  involves—"  and it's  not a  very great  over-
simplification—"grinding up  and frying  the  Rocky
Mountains,  dumping out a volume larger than that
which you fried, utilizing a process which requires a lot
of water in a region that doesn't have a lot of water, to
produce synthetic fuels at great cost of both energy and
dollars, a thousand to two thousand miles  from their
major demand centers."  I'm referring to shale oil. My
contacts gave it a large vote of "no confidence."
     From our review of DOE,  it  seemed  there was
heavy emphasis on these megabucks, centralized, very
high  technology, so-called hard energy alternatives,
and there seemed to be a very great lack of emphasis on
the soft, the decentralized, the not  very expensive in
terms of capital-cost-to-the-government-type of energy
alternatives. I would include here such things as energy
conservation.  I would include a whole  spectrum of
things related to solar—passive, active, even some of
moderate technology.
     This again is not original with me. You will find it
shot through this review document.  And, incidentally,
the public that 1 talked to, at least, just were reflecting
very accurately what this  document said.
     I also constantly heard this wish to have much
greater public participation in the energy decisions. Of
course immediately the question is, how?
     By the way, this expressed need to have much
greater public  participation, arose out of  some of the
considerations we've already talked about. They felt, A,
that they  hadn't  been involved  and hadn't been in-
formed; and B, what decisions had been made hadn't
been too smart. And so actually they felt that  they knew
better.
     They also  were reacting to what they felt was an at-
titude of arrogance. Of course  I had long contact with
the old  Atomic Energy Commission, and so I'm well-
schooled in arrogance. In fact, I was at one time an
employee of the  Atomic  Energy  Commission,  and
again am  well schooled from the inside. But anyhow,
it's sort of a "Papa knows best." Ms. Jadiker was point-
ing out this over and over and over again this morning,
with reference  to the gcothermal  business. "Go away,
little boy, don't bother me. Papa knows best.  You don't
get the big picture."
     I believe,  Dr. Kinsel, you were asking  about the
"big picture" this morning. I think it's precisely the big
picture that's being missed. Here we go putting this
heavy reliance on—again—our  nonrenewable  fossil
fuels, a heavy reliance on high technology, a very great
centralization, as opposed to other alternatives. We're
in a new ballgame, and yet we're applying the same old
fossil-fuel-dependent-society notions. In many cases,
the people in the DOE and elsewhere in government
that are pushing this came right out of the very fossil fuel
industry that they're trying to force us to be dependent
on for the foreseeable future.
     The people felt that there's a need for some fresh
new thinking, that we're in a new energy world, not in
the old one.
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Hearing of October 5, 1979
    Now, the suggestions  about how there  can be
greater  public participation had  to do  with fund-
ing—that's a repeating concern here. One specific  sug-
gestion  which would require  very  little funding is to
demand public representation on the ESAAB—and  I
use DOE's  gobbledygook  here. Translated to  (just
barely) understandable English, you will find ESAAB is
the Energy Systems Acquisitions Advisory Board. If you
look at  DOE flow charts you  will see that the Energy
Systems Acquisitions Advisory Board is the one which
determines whether it's time for a particular program to
move from  laboratory to  pilot to  demonstration to
commercialization.
  ,- The public feels that they ought to be represented
on the—this is now an in-house organization. It's in-
cestuous. It's the same revolving door  arrangement of
people  from the  very industries that they're talking
about being branches of deciding whether it's time to go
ahead or not, and the public be damned. And the public
is not very happy about that.
    So public representation  on at least the ESAAB,
and there was a suggestion this morning which I picked
up as well from the people 1 talked to—that there  be a
national citizens advisory board, advisory to the DOE
and  EPA on energy matters.  And I would simply
underscore comments which you've already heard two
or three times—this morning—that there be prepared
information for all sorts of media dissemination about
the energy program alternatives, that there perhaps be
regional or State public information meetings. This has
to do with public participation. That would be informa-
tion the public could use to participate much more often
and in a much more informed manner.
    And finally, I would emphasize and re-emphasize
the notion of much earlier more effective consideration
of environmental concerns. I wish Dr. Hirsch were here,
I would ask his permission to condense  his presentation
into two words, and I would then mimic Ms. Jadiker for
the two words. She would say, "Think small," and  then
I .would underscore that. I think Dr. Hirsch—if I could
find him, we might drink to it shortly—"Think early," in
matters of environmental concern.
    He alluded to, for example, a power plant—the
siting  of power plants, and commented that too often
some corporate body said,  "Find a piece of  land
cheap," and they bought it, and said, "Now we're going
to put a power plant here. Give us the permits." And he
alluded to a  couple of power plants that he knew about
that are in absolutely the worst possible locations.
    !'m virtually certain that I  know the same two, and
they're in Florida. You couldn't have picked two loca-
tions  on the coast of Florida that were worse than the
two that were picked by these companies in just the
manner described. It got to be so terrible, and was get-
ting to litigation and all this sort of thing, that I'm—well,
I'll speak for a moment, if you will allow me, from per-
sonal experience.  I got called  in at the last moment as
sort of a neutral third party. There was about to be a
lawsuit and all that kind of thing. So I had to see if there
wasn't some way, now that they've made this terrible
decision about the power plant and they'd started to
build it, was there any way that we could ameliorate it a
little bit.
    And the answer turned out to be yes, and in the
process,  save  the company  in  excess  of a million
dollars.
    So the—that particular power company's  ex-
ecutives are rather ambivalent when they see me come
into  the room  where  they  are.  They don't know
whether I'm a kook or not,  since I actually saved them
some money and got some environmentalists off their
backs, and—so anyhow,  the point of this story is that
this got such very bad press in Florida, and very bad
repercussions in state government, that both power
companies involved  independently set up their own
site-selection criteria, and it was really a very responsive
sort of thing. It was a very thoughtful thing; it took into
account all sorts of environmental considerations, and
they voluntarily came up with lists of—a very small list
of possibly acceptable  locations,  acceptable  environ-
mentally, and they simply outright rejected a number of
other sites in Florida.
    Ultimately Florida did pass a power plant siting bill
which essentially said—formalized into law this kind
of matrix preparation and so on, very—rather sophisti-
cated selection of sites.
    It would seem to me  that sort of thing needs to be
done with reference to some of these energy park sites
that we're talking about. The NEPA level is too late. By
then the sides  have been  chosen,  real estate has been
bought and camps have been set up, and "'tis so, 'tain't
so" has been going back  and forth, and it's much too
late.
    We were supposed, by the way, to talk about the
DOE decisionmaking process, which incidentally kind
of bothered me. That sounded very bureaucratic, to talk
about process.  I mean I  didn't care so terribly much
about the process. 1 cared  about the results. By the way,
I was not alone  in that—you'll find that in your docu-
ment as well.
    Although, in looking at the process, it seemed to
have  a lot of holes in it.  The results have been pretty
sorry too, to start with.
    You heard a litany of objections to the way it's ac-
tually been working out,  and so I  would  suggest that
maybe the process needs some surgery,  but  I would
also suggest that the decisions that have been made so
far, the very basic decisions to go to this high energy,
centralized high technology, almost to the exclusion of
the other things, just isn't the way the public is thinking.
     One last little example of that, some rather forward
thinking individual in the Department of Energy pushed
for and got as part of their appropriation, some money
for small grants  to little people for innovative  ideas of
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                                                                               Statement of Dr. Anthony
this appropriate technology type of thing. To the region
that I know best, which is the Southeast, there was $1
million in the kitty, and it wasn't at all well publicized
that this kitty was there, but—you're familiar with this
sort of thing, 1 think, Ms, Hanmer.
    Anyhow,  word somehow leaked out that indeed
there was this money available, and in the Southeastern
eight-State  region, Region IV in the  EPA, although
there was a $1 million kitty, the last time I heard the
numbers they had received over 1500 applications for
this. The aggregate value  of the proposals submitted
was in excess of $70 million. These numbers are out-of-
date by about two months. It's much worse now.
    Now I  admit that a fair number of those would be
for  perpetual  motion machines, or  whatever.  You
know,  a fair  number of  them  you  would have to
eliminate out-of-hand. But it suggests very probably the
real need for this kind of money  for the small-scale ap-'
propriate technology little fellow type investigation or
research,  in  many  cases,  was   badly,   badly
underestimated by the DOE, that very probably in the
Southeast they could have spent profitably thirty, forty,
or even fifty million dollars to support such proposals,
and they had quite a time getting a one million dollar
appropriation!
    This suggests to me again a gross miscalculation of
what the state—of what the situation  really is, and  I
would  think  there  ought to be just a  painstaking
reassessment of where we're  going in energy, for a
number of reasons.
    Think small. Think early. And think differently.
    Okay? That's it.
    MR. ONDICH: Thank you, Dr.  Anthony.
    Do we have any questions from the panel?
     (No response.}
    MR. ONDICH: I'd like to  make an observation,
and then a question or two.
    You reflected certainly on  some of  the people,
some of the witnesses we had today, but I'd like to add
that we have heard from other witnesses, some people
who actually were concerned with the national coal pro-
ject, and some larger projects, larger than what may be
considered  small-scale appropriate technologies, about
the  need for more information, more information before
you get to the NEPA process, more public participation,
so I would add that as you hopefully look at some of the
other testimony of the last few days you  be reassured
that those comments were carried out.
     DR. ANTHONY: Well I certainly hope so, and if I
may make a comment on your comment, I did not want
to leave the impression that I thought one should, say,
junk the notion of looking at shale oil or coal gasifica-
tion, and the like. No, I didn't mean that at all.
    I simply meant that I  wanted some reordering of
the  priorities, where these other things seem to be rather
poor relations. I  simply wanted to elevate them to
legitimacy—not that I wanted to, say, dump shale oil, or
dump one of the others, although I would suggest that
this panic pressure to get them on-line and to hell with
environmental or any other considerations,  doesn't
make much sense either.
    I'm simply saying that 1 think there should be some
greater balance of approach than there is now. I did not
want to leave the impression that I thought these were
forever and totally and always bad ideas. I'm just saying
to go at them as the top priority item hell-bent, forget
the environmental and social and economic impulses,
was also a dumb idea.
    I'm very reassured that there  was this  expression
from these other areas.
    MR. ONDICH: The question—I really have two.
The first one has to do with  NEPA. You talked about
NEPA requirements and how it may be too late in the
process. 1 wondered if you have any feeling about the
regulations, the CEQ regulations, which became effec-
tive several months ago, where they're talking about
records of decisionmaking,  where environmental fac-
tors are brought in to that process.
    Do you think this would in any way help in making
the NEPA requirements more responsive to—

    DR. ANTHONY: I think it's a step in the right
direction. 1 think it remains to be seen how well it works
out.
    I'm concerned about the NEPA process being so
late—being after the acquisition of real estate, and these
sorts of things, where you end up in—you're being
asked to pass on is this particular thing proposed at this
location—what  are the environmental  consequences?
    You know, it's—well, I get back to wondering, sup-
pose even back within the DOE, suppose their environ-
mental branch says  the impact statement prepared by
their program office stinks. I have a strong suspicion that
the program office may well say, "Go away, boy, don't
bother me. We're going to build the plant."
    1 want to see some sort of regulation or legal bar
against  that  kind of thing,  and  in the case   of the
NEPA—I mean bless NEPA. It helped  very much to
stop a misbegotten project in the State of Florida called
the Cross-Florida Barge Canal, and I'll drink to that this
evening. NEPA is necessary and useful, but I'm saying
that that shouldn't be the only thing. There should be a
whole lot stronger  earlier things, when there's much
greater chance of success in— really, what I'm asking is
to adapt the energy developments to the needs of the
environment on occasion, instead  of always the other
way, always saying well, we'll only destroy nineteen
percent of the mangroves in order to put the plant here.
    1 think the suggestion ought to be well now, sup-
pose the plant is ten percent less efficient if you took it
away from the mangroves altogether. That's adapting
the energy program to the  needs of the mangroves,
rather than vice versa.  And I think this approach needs
to come in very early.
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Hearing of October 5, 1979
    MR. ONDICH: My—okay, just one more short
question.
    In our prehearing document we were concerned
about the appropriate level of government, the Federal
level,  the  State level, County  level, for dealing with
some  of the environmental problems. We talked about
familiarity  with the Southeast,  the eight-State region
view.  Do  you have any  reaction to that? Because I
would hate to think that  all this information  should
come  from the Federal level.
    DR. ANTHONY: I have some information, too.
I'm ambivalent here. I recognize the—and I reacted very
strongly to—in a positive sense—to the  testimony of
Ms. Jadiker about the—just wanting to stomp down the
individual—the local level of government, this pater-
nalistic, you know, "Don't bother me, boy," you know,
"it won't do you any good," and so on. That attitude, I
deplore.
    But I  don't want to go all the way and put it way
down  in the  control  of little individual governmental
units.  I am painfully aware that in certain counties in
certain States which obviously  shall  be nameless that
one could subvert  the county  commission for about
$1.98 ahead-
    daughter.)
    DR. ANTHONY: —and this kind of worries me.
And  there are  political  pressures  within  a State,
sometimes, or within a county that would be irresistible.
They  may be totally illogical, but they would be irre-
sistible, whereas someone up here,  you know, could
care less about whose brother-in-law is Department of
Natural Resources head, or whatever, you know. These
things end up being important at the local level.
    So I  think there needs to  be  some balance. I
wouldn't opt for total local control, and I certainly don't
opt for an arrogant paternalistic attitude on the part of
the Federal Government.
    In Florida we've been developing a kind of a model
of governmental partnership in an effort to preserve
some  parts of the Suwanee River, the one  fabled in
song,  and so on, from unwise development and ex-
ploitation.  First, some years ago the Federal govern-
ment  proposed  to make it a national wild and scenic
river.  But,  it was an arrogant proposal. It paid no atten-
tion to local requirements, or anything else, and got a
fury of local opposition.
    And it just fed these $1.98 subversive-type groups.
So, what happened? The Suwannee, for ten years, was
developed badly and with total  lack of synchronization
of taws and that sort of thing, but finally it became ob-
vious  that indeed local  control  wasn't  working.  It
became obvious even to the local people, and now
there's a movement afoot in a sort of a multipartite ap-
proach of partners, partners of the county commissions,
the regional  planning  boards,   the  environmental
organizations of the State, our Congressmen, and the
appropriate federal agencies, that are now trying to,
together, draw up legislation that will accomplish and
accommodate as much as possible with several points of
view, but it's a cooperative thing, deliberately and con-
sciously attempting to be pretty much equal partners.
    And this is the kind of thing that I think I would
prefer to see,  rather than the present almost wholly
Federal, paternalistic arrogant sort of thing, which I've
seen too much of.  But  I also worried about—now
maybe you don't have that kind of county commissions
in your State, but we have some in our State, that are all
too easily pressured locally to be on the side of non-
logic, and they need to be balanced.
    MR. ONDICH:  Thank you.
    MS. HANMER: You opened your statement by a
description of the efforts you had made calling around
talking with people.
    DR. ANTHONY: Yes.
    MS. HANMER: Would you say that there is a
consensus among the people you talked to or the
people you know of on your recommendations about
thinking small or thinking early, or about the direction in
which our energy policy has  taken? Do you think that
represents an upsweli of public opinion?
    DR. ANTHONY: Yes I do, very strongly so.
    MS. HANMER: Thank  you.
    DR. BISHOP: Greg?
    MR. ONDICH:  Yes.
    DR. BISHOP: I'd like to pose one questiomthat
you might respond to out of your experience.
    You emphasize strongly the need for more public
participation, and one of the things that  I guess I've
wondered about in this called-for public participation is
to what extent that itself is also an elitist process, to a
certain extent? That is, those people who in fact do  re-
spond to opportunities to make input to these kinds of
processes come from a certain level of education,  in-
volvement in" decisionmaking activities that are carried
out in private industry and government, and so forth,
and  even in the  call for public participation there's
still—you're  still really missing some large group of
people that  are not particularly informed  on these
issues, and may not be.
    Are you concerned  that they should be? Should
there be an effort to attempt to inform these people and
draw them into the process? Or to what extent do you
think it is balanced or elitist, as I characterize it?
    DR. ANTHONY: As Mr. Ondich would confirm, I
believe, a rather substantial part of the Atlanta Regional
meeting that occurred in July revolved around just such
questions  as you  talked about.  We  were  talking
with—yes, there was this need for public participation, a
strongly felt need. Yes, I and  most of the people at that
Atlanta hearing, and I suppose here, would fall in this
elitist group. I'm a college professor. I've been involved
in environmental—I've been an environmental com-
municator, I've been involved in environmental hassles,
I've had some relationship to State government, and so
                                                 134

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                                                                              Statement of Mr. McClellan
on. So I'm not—and this is not meant in any way to be
derogatory or pejorative. I'm not Joe Six-Pack.
    But some—but these decisions are going to greatly
affect Joe Six-Pack, and in a democracy he should have
a voice, and the kind of thing we were arguing—we just
could not resolve how this could be accomplished.
    In the first place, to inform Joe Six-Pack in this very
complicated and often technical arena  would seem to
be an almost insurmountable thing. And secondly, is
sheer numbers. How can  you  have any sizable cross
section of the population, you know,  including—and
you name whatever comes to mind when you think of
other than  elitist professions—to have  them  repre-
sented, and so on.
    We never—we simply couldn't come to grips with
it. I don't know how this can be accomplished. I see it as
a very major problem, that there is a certain almost
built-in elitism in the hearings and in the so-called
"public participation programs," close quotes. There's a
certain elitism. It's pretty hard to get around, but  I think
that  very real efforts need to  be made to try  to get
around the  elitist characteristic.
    I'd agree that there are problems in that area, and I
frankly haven't got very much in the way of suggestions.
I've been involved a few times in public participation
efforts and have not been very successful. I'm trying to
reach—for example, in our State, we try to reach—we
have a little contact with organized labor, but not very
much.  Very little contact  with the black community.
We've tried and failed. I don't have suggestions in that
area.
    DR. BISHOP: Thank you.
    MR. ONDICH: Again, I would like to thank you,
Dr. Anthony.
    And I'd  like to move to our next witness, Mark
McClellan,  from  the Citizens Advisory  Council  of
Pennsylvania.
    DR. ANTHONY:  I  will  send you  expurgated
copies.

Statement of Nark McClellan
Executive Director
Pennsylvania Citizens Advisory Council
     MR. McCLELLAN: My name is Mark McClellan. I
am the Executive Director of the Citizens Advisory
Council to  the  Pennsylvania Department of Environ-
mental Resources.
     The Citizens Advisory Council was established in
1970 by an act of the Pennsylvania Legislature, and is
mandated  to  advise  the Governor, the  General
Assembly,  and  the  Department  of  Environmental
Resources on environmental affairs.
    The overall mission of the Council is to promote an
environmentally sensitive point of view in the work of
the Department, and other agencies,  and to inject a
nonagency citizen-oriented perspective into the public
decisionmaking process.
    It is from this perspective that I've reviewed the
Department of Energy's Environmental Planning and
Assessment Process, as well as its role within the overall
Department of Energy's Program Project Management
System (PPMS) as it was outlined to us at the July 30th,
1970 workshop in Pittsburgh, Pennsylvania.
    I must state at the beginning that it is somewhat dif-
ficult as well as uncomfortable to review a process which
is so deficient in terms of opportunities for public  in-
volvement, as well as interagency coordination, that
most participants in the workshop, as well as the EPA
personnel, were not even sure that  the system is opera-
tional, let alone whether the actual decisionmaking pro-
cess follows a formal  design.
    In my testimony today I will address my comments
to the major deficiencies, which seem to exist and which
in my opinion must be improved  if the program and
project management system is to result in environmen-
tally acceptable decisions  on major energy technology
projects.
    The intent  of  the  Federal  Nonnuclear  Energy
Research and Development Act which mandates these
hearings is clear. It is  to develop on an urgent basis the
technological capabilities to support a  broad range of
energy options which are both socially and environmen-
tally acceptable. This  indicates that  for an  energy
technology to be acceptable  it must  meet the dual
criteria of technological feasibility  and environmental
acceptability.
    It is therefore essential that any technology project
which proceeds to the  commercialization through the
Department of Energy's Research, Development, and
Demonstration Program (RD&D) must give equal atten-
tion  to  resolving environmental problems  associated
with the  technology,  as is  given  to   eliminating
technological problems.
    In  the  materials which  were  provided  to  the
workshop participants, it  indicated that in April 1979
the  President's Second National Energy Plan expressed
this same intention by  stating, "Satisfactory develop-
ment of all these energy technologies depends on solv-
ing  environmental and worker safety issues in  parallel
with economic and technical issues."
    To  insure that research and environmental issues
are  synchronized with the development phase  of the
technology,  I believe it is essential that environmental
considerations be  integrated  into all stages  of  the
decision   process,   from basic  research through
commercialization.
    The purpose of the Section 11 review, as you are
aware, is to review the Department of Energy's Environ-
mental Planning and  Assessment Process to determine
whether DOE has actually given adequate attention to
environmental protection  in the PPMS decisions. Due
to  a  lack  of public access  to  the  DOE planning
documents, such as  the Project Environmental Plans
(PEP) and the  Environmental Readiness Documents
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Hearing of October 5, 1979
(ERD), I am frankly unable to determine to what extent
and at what stages environmental considerations are
considered.
    Consequently, I believe that the major decisions in
the PPMS can be a good barometer to  determine  to
what extent, and at what stage environmental concerns
have been considered by the Energy System Acquisi-
tion  Advisory   Board  (ESAAB)  and   the   Under
Secretary, in their decisions to move a technology to the
next development phase.
    As a measure  of  the  success of the process, I
believe a  case can be made that the review process and
the preparation  of  the Environmental Development
Plan   (EDP)   and  the  Environmental  Readiness
Documents (ERD) are only useful and are only accomp-
lishing  their objectives if the processes as applied can
result in a negative decision.
    1 believe this is the  critical test of the success of the
environmental planning and assessment  process.  The
obvious purpose of this assessment process is to insure
that the PPMS system results in an environmentally ac-
ceptable  decision.  In  other words, if the process  is
operational, and if the  EDP and ERD are given ade-
quate consideration by the Board and Under Secretary,
then one would expect to see at least some projects
being temporarily halted or permanently canceled, if the
environmental impacts are determined to be unaccept-
able, or if some problems remain to be resolved which
require  additional  research  prior   to   moving  a
technology to a subsequent phase of the  development
process.
    In my judgment, this does not appear to  be the
case within the Department of Energy today. Once a
project enters the funding pipeline for basic research, it
appears to be a foregone conclusion that the project will
proceed unmolested through the key decision points in
the PPMS to commercialization.
    For example, to date, over twenty ERDs have been
prepared on energy technologies involved  in geother-
mal, coal liquefaction,  coal gasification,  and oil shale
projects,  yet not one has been held  up  or canceled,
despite the fact  that each has serious environmental
drawbacks which remain to be solved and in some cases
problems which are yet to be completely  understood.
    All indications  are that the  necessary environ-
mental research identified in earlier EDPs, is moving at
a pace considerably behind the technological develop-
ment. In addition, coal liquefaction and gasification pro-
jects, where there is serious potential for adverse health
effects, have moved at least partially to  the commer-
cialization phase with  minimum effort to resolve the
environmental problems at a similar speed.
    The  ERDs prepared on these projects and pro-
grams  have not been readily available to  the public.
Therefore, if one assumes that the major environmental
problems and research  needs have been  addressed by
the Office of Environment in the ERD, then either the
PPMS system is not being used, or the Office of Envir-
onment's  planning  documents  have not been given
adequate  consideration  by  the  Board  or  the
Under Secretary of DOE.
     I must emphasize again, that it is extremely difficult
to verify this information  because the Board's activities
are shrouded in mystery.  Their meetings are not widely
publicized, there is no public or outside agency involve-
ment in their decisions, and there's no evidence that
there are any formal criteria or performance standards
upon which their  decisions are based.
     Consequently, the public as well as other Federal
agencies have no  way to determine the rationale for the
Board's recommendations to the Under Secretary.
     For example, in the past week the Board has met
and has approved the moving of two solvent refined
coal projects to the next development phase. An ERD
on  the  technologies was available for Board review.
However,  it is impossible to determine whether  the
document's findings have had any effect on their deci-
sion to  recommend proceeding into the  development
phase.
     In  summary, I believe  there are three principal
problems which seriously reduce the ability of the PPMS
system  to  result  in  environmentally  responsive
decisions.
    The first is the lack of formal criteria or standards
upon which the Board and Under Secretary base their
evaluations of individual technologies.
    The second is the insufficient authority to mandate
the synchronizing of environmental research with the
technological development.
    The third is the existence of major barriers to public
review of  DOE planning  and review documents, and
the lack of opportunity for public involvement in the
decisionmaking process.
     The first problem, the absence of explicit criteria,
gives the appearance if not the reality, that decisions are
arbitrary. If such criteria or standards were applied to all
technologies,  it would insure that pertinent environ-
mental issues are  given considerations at all key deci-
sion points in the  PPMS process.
     In addition, the consistent application of the criteria
to all technologies, large and small, will provide a sound
basis to compare  the relative superiority  of alternative
energy technologies and options at each  development
phase.
     It  is  my  recommendation  that specific criteria
should  be developed and formally  applied to all
technologies at each key decision point. In addition, the
Board's recommendations  should be based  on the
satisfactory meeting of these criteria. Accompanying all
Board recommendations should be justifying documen-
tation. This information should be widely distributed for
a specific  time period for public review and comment
prior to the Under Secretary's decision.
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                                                                              Statement of Mr. McClellan
    The second major problem stems from the absence
of any formal requirement that would stipulate that no
energy  acquisition project can proceed to the next
development phase until  environmental concerns and
research needs have been satisfactorily resolved.
    A combination of the EDP and the ERD are the
essential basis upon which this evaluation should be
made. The EDP defines the major environmental con-
cerns associated with a particular technology and the
environmental research requirements for  addressing
these concerns through each subsequent phase of the
development process.
    The ERD is the independent judgment of the Office
of Environment as to whether it is suitable for an energy
technology to move to the next phase. This is actually
an evaluation of how adequately DOE has addressed
the concerns and resolved the problems identified in the
EDP, and  more specifically the PEP.
    Presently, the Office of  Environment's planning
and assessment documents are only advisory and are
used as guidance  to the Board, the Program Offices,
and the  Under Secretary. It is my recommendation that
the progress of all  energy acquisition projects be condi-
tioned on  the satisfactory completion of the research
and resolution of major environmental problems iden-
tified in  the EDP.
    The  EDP  should  be   modified  to  identify
"thresholds" which should outline the environmental
conditions which must be met and the extent of the
research which  must be  completed during  each
development phase. Any deficiencies or unacceptable
environmental problems, identified in an ERD, should
be a condition for temporarily halting and in  severe
cases canceling a project. In the case of a project that
does not meet the  threshold, the Department of Energy
Under Secretary should have the discretion to allow the
project to  proceed. But only to the next phase, and
under conditional  approval which would stipulate that
specified environmental concerns must be resolved in a
specified time period, or the project will be placed on
permanent hold at that phase.
    No technology should be ever approved for com-
mercialization unless all thresholds are satisfactorily met.
It is essential that these conditions be made compulsory.
Otherwise, environmental research will continue to lag
far behind  the development of energy technologies,
making it increasingly difficult to discourage the use of a
technology until the environmental problems have been
resolved, if at all possible. One only has to look at the
history of nuclear power in this country to recognize that
once the genie is out of the bottle, pressures  come to
bear which make it difficult to put it back. For example,
if nuclear power had proceeded through a process of
development with  the additional conditions I've men-
tioned, commercialization could not have been possible
until the question of  permanent  waste disposal  had
been satisfactorily  resolved.
    Finally,  if the  public is to be able to adequately
review and comment on the DOE energy technology
decisions, DOE planning and assessment documents
must  have   wider distribution.  More  importantly,
however, DOE must provide for greater opportunity for
the public to participate in the decisions themselves, and
not just to react to the DOE decisions. The increasing
lack of confidence in government can be clearly traced
to the public's mounting frustration over its inability to
participate in the public decisionmaking process.  The
Energy  System Acquisition  Advisory Board,  which
reviews the Environmental Readiness Documents, and
authorizes each of the successful phases of the develop-
ment, has Yio public representation and no system for
widespread review of their decision outside of DOE. It is
my recommendation that the  Board's membership be
expanded to include members of  the public,  and
representatives of other Federal agencies.
    In addition, all Board recommendations accom-
panied  by justifying documentation  should be made
public and open to  formal public review and comment.
Presently, the major opportunity for public review and
comment on DOE decisions is within  the EIS process. I
recommend  that this review be expanded to provide
formal public review of the Office  of Environment's
Planning and Assessment Document, the  EDP, the
PEP, and the ERD. In this manner, the public can in-
sure that all  relevant environmental factors have been
considered,  the appropriate research  has  been pro-
posed,  and  all major environmental problems have
been resolved prior to commercialization of any energy
technology.
    In closing, it is disheartening to realize that as we sit
here attempting to  improve this management system,
Congress is considering the establishment of an Energy
Mobilization Board, with the authority to waive environ-
mental  laws, to preempt state  and local  land  use
authority, to reduce  opportunities for judicial review
and public participation, as well as to eliminate the pro-
cedures which are the essential elements of the process
we're  discussing today.  These procedures must not be
viewed  as hindrances to meeting  the Nation's energy
needs. Procedural duplication and  unnecessary admin-
istrative practices, which prolong the siting instruction of
essential energy supply projects, should be eliminated.
However, substantive  laws  and  review procedures
established to protect public health and safety should
not be waived. These procedures were meant, through
their required review procedures, to insure better deci-
sions  and to eliminate decisions  which will result in
severe costs, in terms of environmental and  public
health damage, and social disruption.
    The DOE, in its RD&D program, must provide for
a formal process to insure  that the critical questions of
need and the environmental and social acceptability are
adequately  debated, with  sufficient  opportunity  for
public  participation.  Increasingly,  evidence indicates
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Hearing of October 5, 1979
that the types of projects which the DOE is presently
funding, such as synthetic fuel facilities, are not needed
on the scale proposed, and cannot make substantial
contributions to our near-term energy problems. As a
result, the waiving of any review requirements will result
in the continued expenditure of vast sums of Federal
funds for energy supply projects which are unnecessary
and which pose serious environmental problems.
    if I can add one thing to my formal comments, I
may have a different opinion from  a lot of these people
coming here in the last three days  and from comments
made earlier in the sense that I believe that the process
is all important. Even maybe more important than want-
ing the right decisions. Because if we don't have a good
process in place, then the decision will be made at the
whim of those people who are in the position of making
these decisions at that time. We can have a solar advo-
cate, if he's in DOE now, supporting solar. Once he
leaves, we'll have the kind of synthetic fuel processes
we're having now.  If you have a good process  with
specific criteria on which a  decision should be based,
and it's in place, decisions cannot be made arbitrarily by
people due to individual bias or outside pressures. The
explicit criteria which 1 recommended will make it clear
what the right decisions are, and  I'm sure, then,  that
under this process soft technologies will fare very well.
    Again, 1 want to thank you for this opportunity,
and ! will welcome any of your questions at this time.
    MR. ONDICH: Thank you,  Mr. McClellan.
    Are  there any questions from the panel?
    DR. BISHOP: Yes. You've  referred to the need
for criteria to determine what— whether a technology is
environmentally acceptable, and you make a decision
at some point based on acceptability as to whether you
continue. And you've  referred  to the  concept  of
thresholds as one way of establishing perhaps a 'no-go'
or a 'go' decision point.
    Many of those criteria that you might set up of
course—range on a continuum of values, of impacts or
emissions or  whatever, and I guess I'm interested in
what your comments are on—as you look at a  con-
tinuum or a range, if there isn't a clear threshold per se.
How do you  establish those levels that will  tell  you
whether  it's acceptable or not acceptable, and make
those judgments?
    MR. McCLELLAN: I think it's a combination of
things. You're very right. I don't think all of the impacts
can be quantified, and many of them just can only be
balanced against other  risks that other technologies
impose.
    However, I think there's a combination of things
that can insure that a reasonable evaluation can be
done.
    My main concern in establishing criteria is basically
to insure that decisions are made on the basis  of a
careful evaluation of all important  factors.
    Presently, the Board is now operating in the dark.
We don't know how they're making the decisions. They
appear arbitrary. They may not be, but they never give
any justification for their decisions.
    For  example,  the  Environmental  Readiness
Documents  on coal gasification, the one  in  1978,
according to the data that I was given, came out and
said there was a .5 or fifty percent chance that adverse
environmental impacts would take place, meaning im-
pacts—in their definition—which would go beyond and
exceed present or planned environmental standards.
    The decision was still made to go ahead through
commercialization with  those technologies. There was
no justification of why, whether they felt that was ac-
ceptable or  unacceptable  adverse  environmental
impacts.
    For example, one criteria which I would suggest be
used, is to establish a level of risk of unacceptable envir-
onmental impact whether it be  .5 or .6; this should be
debated, and use this as a threshold which must be met
prior to  moving a project to  the next  development
stage.
    In addition, I believe that  even  if a criteria is not
quantifiable it is important, even if it just requires you to
look at certain environmental factors before the decision
is made to move it to the next development phase. If
this is done in conjunction with  public review  of the
planning and assessment documents that DOE prepares
we can, for example, look at the EDP and see if all rele-
vant environmental factors have been considered. If the
answer is yes then we can then look and see if the ap-
propriate research is being done; and then when the
Board  and the Under  Secretary make their decision
on  the  environmental  acceptability of  the   tech-
nology—we'll have some basis for determining whether
their justification is a lot of hot air or it's based on an
adequate evaluation  of the information and research
that's been completed.
    But you're quite right. I think there is difficulty in
determining  what is unacceptable environmental risk or
impacts. I would argue, however, that the inability to
quantify a factor or criteria such as environmental risk
does not preclude us from making  an intelligent and
reasonable choice. I think the public can make good
decisions and can determine what's better, the risk of
nuclear accident or the risk of the health hazards from
sulfur dioxide problems with coal burning, if given suffi-
cient information,
    MR. ONDICH: Anything else?
    DR. KINSEL:  I'd like  to make one comment,
which really encompasses both your  statement and the
previous one.
    As a representative of an organization which seeks
to have an impact on the policy process, I can certainly
underscore from our experience the kinds of things you
suggest as being important to improve the process.
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                                                                              Statement of Mr. McClellan
    I suggest, though—and  I would like to get your
reactions to it—that perhaps one of the participants in
the policy process which has not been used to the fullest
potential and perhaps is not  really meeting its obliga-
tions is Congress. The kinds of documents or the kinds
of information which  you recommend be put together
by the Department and made publicly available should
perhaps—and I'd be curious to get your comments on
this—go to the Congress and lay out in a fairly simple
form for them what the alternatives are and the risks.
    It's very difficult to insure, even based  on the pro-
cess, that people are going to  make decisions which are
really responsible, and it frequently seems to be impor-
tant that you have a check and balance system, at least
from the perspective from which we deal with the policy
process.
    DR. ANTHONY: Are you really speaking to both
of us, or—
    DR. KINSEL: Yes, I am.
    MR. McCLELLAN: I think that is important and
you're right.  1 think you saw the Congress in the recent
gasoline  crisis trying to do  anything,  regardless of
whether it was right or not with the  synthetic fuel bills.
Slowly however they've pulled back and slowed it down
as proper information has been fed to them by people
who know some of the problems related to synthetic
fuels.
    Information is a key there, and I think—and that's
why I believe the process  is so important, because I
think the facts are there, and I think we can put it out
and have the information an open and comprehensive
debate—both in Congress as well as nationally and at
the state level—which lays out the options and lays out
the risks, and then approaches a decision  by asking:
"What are the least cost energy options with the least
probability of adverse environmental and social impacts
which meet our reasonable future energy needs?"
    I think that's the  way it should be handled. I don't
think  we should be supporting specific decisions, but
supporting a proper process in which to make the decision.
    DR. ANTHONY: If I may respond briefly, when  I
was suggesting that publication of an annual assessment
of energy alternatives, I finally fished around for some
independent agency  to—who might well put this out
and I suggested GAO. I had in the back of my mind as a
second suggestion the Congressional Research Service
as the agency that—and that might well  have more
impact on Congress.
    I was a little concerned about the possible—that
they might possibly be directed for political motives, and
that's why I  rejected  them  in favor of the GAO, but  I
certainly did think that of this very important thing you
suggest, that you need to feed to Congress information
which they can believe and act on.
    I don't relish—I wouldn't relish their responsibility
in trying to deal with this  synthetic fuel business, for
example, as Mr. McClellan  has said, on the basis of the
welter of—for the lack of information or misinformation
that they probably have.
    I don't  know whether the Congressional Research
Service would be a reasonable one to do this, or not,
but again I  would bow to you  bureaucrats who—not
you. I know you're not a bureaucrat, Dr. Kinsel—
    DR. KINSEL: I |Was going to point that out—
    DR. ANTHONY: Yes, well I know Tom Kimball
very well, and so I know exactly where you come from.
    DR. KINSEL: As far as bureaucracies go, ypu've
made a very, good selection.
    DR. ANTHONY: Well I just happily had a plane
seatmate who was GAO, and the light bulb went on.
    DR. KINSEL: There is an agency of the Congress
that might—I might just mention—do the job called the
Office of Technology Assessment, which while they see
their mission as somewhat more long range, would  be
one of the  obvious groups to take a look at this. If I
could make one other very quick comment for the
record, I  think what the two of you have  underscored
and  which—as was pointed out—runs as a  thread
through many of theiother public comments, if nothing
else, shows the inadequacy of  the Department  of
Energy in fulfilling the responsibility given to it by Con-
gress to report back periodically on  its assessment of
where the Nation should be going.
    If you've ever looked at one of those reports back
to the  Congress,  they're absolutely  inadequate and
don't begin  to deal with most of the issues which you've
raised. It seems to me that that's one specific recom-
mendation  which ought to go back to the Department,
that they need to take  a fresh look at the mandate, the
responsibility given to  them by  Congress in the act of
setting up the Department, look at the criticism which
has been leveled  at the information available to the
public, and  try to adjust the discrepancies in that docu-
ment with the mission they should have been undertaking
all along.
    DR. ANTHONY: It does  seem to be something
that needs to be updated, because the rate of change is
very rapid in these areas, and 1 wouldn't want it to be
cast in concrete or coal, or whatever, but I would plead
for it to be  frequently updated.
    MR. ONDICH: I would just like to comment  on
Mr. McClellan's remarks, and reflect on something that
perhaps he knows.
    In our first day of testimony Mrs. Klusen, the Assis-
tant  Secretary for Environment from DOE, indicated
that there is a project management study that's currently
going on within the Department, and—so I think your
comments are timely, and we will insure that these are
at least brought to the attention of the people who are
conducting  that.
    Again, I'd like to thank you, and I'd like to ask that
the panel and perhaps the audience and some of the
witnesses bear with  us. I have  a note that one  of our
later witnesses, Dr.  Devine, has asked that he  follow
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Hearing of October 5, 1979
Mr. Slap because of a plane he has to catch, so what I'd
like to do now is move to Albert Slap from Pennsylvania
Public Interest Law Center, and then following that we'll
have Dr. Devine.
    Mr. Slap?
Statement of Albert Slap
Pennsylvania Public Interest Law Center

    MR. SLAP: Thank you very much.
    My talk is entitled "Synfuels: Will it be the Nuclear
Power of the 1980's?" And with the Senate passing the
Energy Mobilization Board, I intend to send this to all
those who voted in favor of the Energy Mobilization Board.
    The energy crisis of the 1970's was no surprise to
most  conservationists who had advocated  for many
years  the wise use of nonrenewable fossil resources.
The writings of John Muir, Aldo Leopold, and others
attest  to this fact. America did not heed these admoni-
tions and in fact continues to ignore the energy problem
as the troubled waters rise around us.
    This trouble  takes  many forms:  environmental,
political, social, and economic. Directly or indirectly the
degradation  of the environment with toxic chemicals,
the near meltdown at Three Mile Island, or fourteen
percent inflation rate, high unemployment, and social
disharmony  can  be associated with  our misguided
energy policy.
    Even the widening  rift between blacks  and Jews
has its roots  in the failure  of Americans  to conserve
energy.
    Theoretically, in our society it is the job of Congress
and the President to set policy in the energy area. It is
the job of  the Executive  Branch  agencies, like  the
Federal Energy Administration and  the Environmental
Protection Agency, to carry out that policy.
    In actuality,  the  Federal agencies charged with
implementation have much more  control over policy
than is commonly thought.
    Take, for example, nuclear power. When Con-
gress  passed,  and President  Eisenhower  signed,  the
Atomic Energy Act in 1953, it established the Atomic
Energy Commission to facilitate nuclear power develop-
ment and to protect the public welfare and health. In the
energy  leadership  vacuum  that  followed  for  two
decades, the Atomic Energy Commission—and later
the Nuclear  Regulatory Commission—fostered   the
growth of commercial nuclear power. When the acci-
dent at Three Mile  Island directed  the  spotlight of
national and international attention  on nuclear power,
the picture that emerged was not pleasant. The public
saw that, in  truth, not all  of the  harmful aspects of
nuclear power had been fully examined by the agencies
charged with  guarding public health.
    As incredible as  it  seems now, the Nuclear
Regulatory  Commission  had accepted the  nuclear
industry's assertions on the improbability of  a  Class 9
accident occurring, and never required the evaluation
of Class 9 accidents in individual plant licensing and
environmental impact statements.
    Three Mile Island was a Class 9 accident.
    All of this relates in a very  direct  way  to  the
development  of  synfuels  and  the Department  of
Energy's decisionmaking process. Just  as the Atomic
Energy Commission/Nuclear Regulatory Commission
ushered Americans into the nuclear age  with incom-
plete   knowledge   of  the  true  cost  of   nuclear
power—[i.e.,  problems with  uranium tailings,  fuel
reprocessing, low-level radiation hazards,  evacuation
and  medical  response,  and  radioactive  waste
disposal]—the Department of Energy may be on  the
verge of fast-tracking synfuels with the help of a Con-
gress facing reelection and constituents still smoldering
from gas lines in the summer of 1979.
    A quick look at the major energy systems being
developed at the Department of Energy by the Office of
Energy Technology clearly illustrates this point. Of the
ten nonnuclear projects on OET's drawing board, a full
six  are synfuel projects based  on coal; only two  are
solar projects.
    The   Environmental Protection Agency has  the
responsibility under  Section  11 of the  Nonnuclear
Energy Research  and  Development Act of 1974, to
"assess the adequacy of attention to energy conserva-
tion methods  and  environmental protection, and  the
environmental  consequences  of the  application  of
energy technologies."
    In  1979,  EPA examined  the Department  of
Energy's program and project management system for
determining research and development demonstration
and commercialization  investments. No matter how
good DOE's management system is, and no matter how
well EPA  fulfills its responsibility to point  out flaws in
it—and I  point out that EPA's Pittsburgh workshop,
which I attended, was one of the most superbly orches-
trated and high-powered sessions I've ever attended—
the sometimes creative  agency-to-agency tension can-
not  produce  a   positive  result   unless  Congress
understands the very nature of the energy crisis itself.
    There is no indication that Congress does under-
stand  the energy  crisis.  The  fast-tracking  Energy
Mobilization Board  will undoubtedly accelerate syn-
fuels—including oil shale development in  a desperate
attempt to achieve energy independence without really
understanding the ties that bind us to  our  present
dilemma.
    In Barry Commoner's 1976 treatise on  energy,
The Poverty of Power,  he gives an excellent overview
on  the energy crisis and coal's  place in the solution to
the crisis.  Coal is abundant, he says. We have enough
in the United States to:  "last about four to six hundred
years at the present rate of use."
    But how does coal fit into the energy picture?
Should it  be used to fire hundreds of synfuel plants
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                                                                                    Statement of Mr. Slap
across the country? Or should it be used to generate
electricity for electric cars and trucks?
    Commoner would  argue that synfuel is  a  very
inefficient use of coal, that enough is known now about
synfuels and oil shale to rule them out of our  energy
future, and that society's limited resources, government
tax revenues and private capital should not be directed
there.
    Because of its  nature, coal is not  well-suited for
internal  combustion engines that move our  private
vehicles and consume  one-quarter of the  country's
energy.  Nor is it suited  to  directly heat or cool the
Nation's buildings.  The  question is presented  then
whether we try to change coal to meet the needs of our
oil-and-gas-dependent society, or whether we try to
change the utilization of oil and gas.
    Commoner argues that:
"The existing U.S. reserves of natural petroleum could
readily take care of  our total needs for such fuels  for a
period of fifty years or more,  a time in which they could
be replaced by renewable energy sources. There would
then be no need to develop coal conversion or shale oil
production.  Nevertheless, in the absence of  such  a
rational  energy program,  the production of synthetic
fuels from coal and shale is often put forward as a viable
substitute for imported oil."
    Commoner argues that, with existing knowledge,
wise policymakers would rule out coal conversion and
oil shale development on three grounds:  (1) thermal
inefficiency;  (2) environmental  and health impacts;
and, (3) economics.
    Thermodynamically, coal is a high quality energy
source and  should  be  matched  to the tasks needing
such sources, namely, generation of electricity, heat for
industrial processes, and industrial steam.
    Commoner writes:
"The  notion of converting coal  to  liquid fuel to run
vehicles flies in the face of thermodynamics. By the time
the fuel has been  produced, about a  third of coal's
original  energy content  has  been used up to run the
liquefaction process. Then, when the fuel is used to run
cars and trucks most  of it  is wasted  because these
vehicles operate with an efficiency of about ten percent.
The waste heat that their engines produce is spewed
into the environment and cannot possibly be applied to
any practical tasks."
    The environmental effects of synfuels include those
traditionally associated with coal mining—harm to land
from  spoil  banks  and  strip  mining,  black lung in
underground  miners,  acid  mine drainage, etcetera.
Water usage in oil shale and coal conversion is also a
serious  problem.  Synfuels can consume thirty to two
hundred gallons of water per million BTUs while strip
mining  alone  uses  only  .7  to 1.6 gallons per million
BTUs.
    The possible widespread development of coal con-
version  in oil shale  in the dry Western States threatens
to  destroy  an important  renewable  resource, the
agricultural land base.
    Another well-known environmental health effect of
coal conversion, and one which is of particular concern
to my organization, is cancer. Coal hydrogenization
byproducts, polycyclic hydrocarbons, have been shown
to produce cancer in humans since 1775 when Percival
Potts discovered scrotal cancer in chimney sweeps. Skin
cancers among workers were associated with  a coal
conversion operation  in West Virginia between 1952
and 1959. Shale oil has been a recognized carcinogen
since  1876.
    Apart from these very serious environmental prob-
lems,  the capital costs of producing synthetic oil and gas
from coal is very much higher than the cost of produc-
ing coal itself. For example, Commoner writes:

"In 1970 a  typical  strip mine produced per year per
dollar of capital-invested coal two million BTUs  of heat
energy. In contrast,  if that coal were then liquefied, the
amount of fuel  produced  per dollar of invested capital
would represent only about  245,000 BTUs of heat
energy, a reduction  of more than 87 percent in capital
productivity. Similarly, coal gasification involves a 92
percent reduction in capital productivity. Shale oil pro-
duction yields about 420,000 BTUs of fuel per dollar
capital invested."
    The  Congressional  Budget Office  has recently
estimated that the cost to the taxpayer to meet a House
established goal of  500,000  barrels a day of  synfuel
could be  18 to 22  billion dollars.  A recent article in
Science magazine—volume  205, page 168—restated
the position of some  energy analysts that, "develop-
ment  of synfuels should be left almost entirely to the
private sector. The government's most useful contribu-
tion  would  be  to  stop  interfering  with  market
mechanisms."
    Commoner's assertions have also been supported
by  a  new study  produced at the Harvard Business
School entitled Energy Future. The study argues that
the most advantageous future scenario would be to
emphasize conservation. According to Dr. Stovall, one
of the Harvard study's authors, conservation can: "save
five million barrels a day by the late 1980's, faster than
you can get even one billion barrels a day from synthetic
fuels."
    Having reviewed the problems associated with syn-
fuels development, it is perhaps best to conclude by urg-
ing EPA to call to the  attention of Congress through its
Section 11 review that a major national commitment to
synfuels and oil shale brought into commercial develop-
ment  by the Department of Energy would be a potential
disaster, environmentally,  economically,  and  would
drain  needed-public and  private resources away from
energy conservation.
    In this regard, I am submitting for the record a copy
of the Energy Summary  Table from the Sierra Club's
alternative energy plan. This table compares, strategy-
by-strategy, the Sierra Club's plan to President Carter's
plan.  It shows  that  conservation can reduce 1990 oil
imports by 2.46 million barrels per day more than the
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Hearing of October 5, 1979
Administration's plan, and reduce 12,449 billion more
total barrels by 1990 than the President's plan.
    The additional ten-year costs of this conservation
program would only be 2.5 billion dollars.
    Whether one is pro- or  anti-nuclear,  there is
general agreement that commitments to commercializa-
tion  of nuclear power were made without adequate
study of the full costs. As a result, the nuclear industry
is  a  sick institution teetering on collapse. If it does
collapse, the pieces will have to be picked up by all of ui
at great expense.
    With what we know about synf uels, we could easily
find ourselves in 1990 with an  industry similar to the
nuclear power industry, having cost billions more than
initially anticipated, having crowded out other investments
that were needed for industrial productivity and controlling
inflation, and having very serious health impacts.
    Thank you very much for permitting me to make
these remarks.
    MR. ONDICH: Thank you.
    Are there any questions from the panel?
     (No response.)
    MR. ONDICH: I have a  very—perhaps  not so
general, but a question about your remarks or your
comments on a project  that has just  recently been
announced, the solvent-refined  coal  project,  which
would certainly affect Pennsylvania, to some extent.
    What do you think the Federal Government should
do about that? I mean there has been a commitment
made, the projects are scheduled for development and
construction. What can be done at this point in time?
    MR. SLAP: Well, there's always the problem of,
do you throw good money after bad, and my position
would be that if one  looks at the energy crisis and the
solutions to it—if we, were going to use coal, we would
be putting it into creating more electricity and using it as
coal in power plants, and not reducing its thermal effi-
ciency and increasing the capital cost by building syn-
fuel plants.
    One of the problems that I see in  going forward
with  these solvent-refined  coal plants, at this point, is
that it may stimulate—falsely stimulate or give signals to
private investors and to the energy companies that the
government is going to back this program, that they're
going to continue to provide subsidies in various forms
and bail them out if there's any problem.
    This has happened in the area of nuclear power.
You  know, we have  many half-built plants, and in the
wake of all of the problems that Three Mile Island raised,
do we continue to build those plants, or do we stop?
    Another example is the Tellico Dam. We have a
new cost-benefit study that says it's not going to be cost-
beneficial to  let the gates close and to flood  the
farmland, but because of special interests we go ahead
and do it anyway.
    So I would say synfuels at this point in time should
probably be scrapped.
    MR. ONDICH: Does that reflect the—1 wouldn't
know if I should call  it a constituency, but of the
individuals you represent, particularly from Pennsylvania
or States with resources which have economic value
and are currently being used?
    MR. SLAP: Well I'm testifying on my own behalf,
as director of the environmental  project of the Public
Interest Law Center; of Philadelphia, but 1 also sit on
several committees of the Sierra Club. Sierra Club has
about 5,000 members in Pennsylvania, and I would say
that this position  pretty much accurately reflects the
position in this Energy  Summary Table, which is  pro-
duced by the National Sierra Club,  so I  would say that
this is a view—while it  is my own personal view, that
it's shared by  many people  such as Commoner, the
authors of the Harvard Study, conservationists  who
believe that we make a commitment to energy conser-
vation, mass transit,  automobile  efficiency,  retrofit  of
residences for thermal  efficiency, solar research  and
funding, cogeneration, industrial conservation, and that
through these that we will achieve much more than we
would achieve by commercialization of synfuels.
    I'm not an economist,  but  one of the scariest
prospects of the heavy DOE emphasis on synfuels and
fast-tracking is the attraction of capital in the wrong
direction, that if there's a limited amount  of government
tax resources and if there's a limited amount of private
capital (with the prime interest rate at such a high level,
private capital is not going to  be readily invested)  to
foster development in  one area, it almost inevitably
means that it's not going to be put into another area,
such as solar research or conservation.
    MR. ONDICH: Anything else?
    (No response.)
    MR. ONDICH: Again,  I'd like to thank you, Mr.
Slap,  and ask if Dr. Devine is here, and we can move to
his testimony.
    I'd like to mention that we have scheduled three
more witnesses today—Edith Chase from the League of
Women Voters, Dr.  Carl Norbreck from the Thome
Ecological Institute, and Mike Seaman, California Solid
Waste Management Board.
    Following Dr. Devine's testimony, I  think we'll take
just a short break, perhaps as short as five minutes, to
stand up and stretch, and then  we'll proceed into Edith
Chase's testimony.                       ,

Statement of Michael D. Devine
Director, Science and Public  Policy Program
University of Oklahoma

    DR. DEVINE: Thank you.  I'm Mike Devine. I'm
Director of the Science and Public Policy Program at the
University of Oklahoma, which  is a multidisciplinary
research group.
     I'd like to note that my testimony is based to a  large
extent on a major study of energy RD&D funded by the
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                                                                                  Statement of Dr. Devine
National Science Foundation, which my colleagues in
the Science and Public Policy Program and 1 completed
about two-and-a-half years ago, and the results of this
study have been published in a book titled "Our Energy
Future."
    To begin with,  I  believe we  must  give  explicit
recognition to the  fact that many of the decisions to
be made on  future energy sources  and  conservation
options will be highly politicized. Therefore, energy/
environmental research must be viewed broadly, to pro-
vide information not only to a small research group, bui
also to energy policymakers and the public at large. In
order to be most  useful,  the research must be both
reliable  and credible. Let  me briefly define these two
terms and their differences.
    Reliability, as I will use it, indicates the scientifically
estimated range of error included  in any set of  data or
body of information; that is, reliability is a measure of
confidence a scientist or engineer has in the data or
information.
    In contrast, credibility is defined as the measure of
the confidence interested parties have  in the informa-
tion. Credibility is  a synonym for believability. If the
range of parties interested in  a decision includes only
scientists and engineers, reliability  may be synonymous
with credibility. When parties are introduced who have
broader social or environment concerns, then credibility
requires more than a technical judgment of reliability.
    In  the background document provided prior to
these hearings, five major issues were identified, and i
will assume that people are generally familiar with those.
    I believe that  although credibility is  not explicitly
mentioned in the discussions of these five issues, it is an
underlying concern in several of them, and I think that's
been brought out in much of the testimony that I've
heard today. Although again that term itself wasn't really
used very much.
    For example,  issues of state versus national
impacts, environmental criteria used, and the role of non-
DOE interests all reflect a lack of confidence on the part
of at least some interests that environmental impacts
have been adequately addressed. Whether this is fac-
tually true or  not is irrelevant and, in fact,  impossible to
prove one way or the other.
    In raising the issue of credibility, I am, of course, in
no way questioning the competence, motives,  or inte-
grity of DOE personnel, but the simple fact is that DOE's
primary mission is to  promote energy development,
and therefore many persons are naturally skeptical of
DOE-sponsored  and  DOE-approved studies  dealing
with   the  environmental  consequences  of  energy
development.
    Environmental RD&D appears to  require four
characteristics if it is to have maximum credibility.
    One, it must involve a diversity of interests in the
planning and  the conduct of the research to prevent the
study from being limited to just those impacts of interest
to a specialized research community.
    Second, the data and  impact assessments must
include site-specific components so as to inform those
likely  to be directly affected by energy development.
    Third, the research should be produced by persons
or institutions who are viewed as being professionally
competent.
    And fourth, the studies must be funded and carried
out by parties who do not have a vested interest in the
outcome of the decisions which will be informed by
the RD&D.
    Now there are a wide variety of actions that DOE
might take to enhance the credibility of the environmen-
tal research it carries out or funds. However, I would
like to recommend a series of rather broad changes.
    First, for every step in the development phase of an
energy technology, there should be a parallel environ-
mental assessment by a group without a vested institu-
tional interest in the technology.
    The purposes of such assessments, are:  One,  to
provide an early alert regarding impacts on a regional or
site-specific basis that may either enhance or constrain
utilization; and  two, to assist in the creation of profes-
sionals who have expertise about the technology and its
potential impacts, but who do not have a vested interest
in its promotion or demise—that is, a professional group
with credibility to a broad range of interested parties.
    A second related recommendation is that an inde-
pendent  agency should  be established  to fund and
monitor the environmental assessments.
    This new Federal agency should have neither a pro-
motional nor a  regulatory role in  energy policy. The
agency would be  analogous to the National Science
Foundation in its relation to other parts of the  Federal
Government.
    The agency would identify needs for assessments,
select the groups to do the studies and assure that each
study is conducted so that the results are reliable and
credible.  Reliability  and  credibility  require that the
research  group not only  be professionally competent,
but they also require that representatives of the range of
interested  parties be  involved as  consultants  and
reviewers,  including representatives of  the industry,
local government, and consumer interests.
    Participation by a range of potentially affected par-
ties prepares the way for disseminating the information
from the assessment, because it alerts interested parties
to the fact that the data will be forthcoming and it gives
them  confidence that the  work is comprehensive and
unbiased.
    In order to carry out these research programs, my
third recommendation is that new research institutions
be  created  that  have the  capability for conducting
reliable and credible energy/environmental research.
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Hearing of October 5, 1979
    Most existing research organizations are viewed, at
least by some of the parties interested in energy deci-
sions, as having bias because of their ties with funding
sources that have promotional or regulatory interests.
    For example, the National Laboratories are charged
by DOE with carrying out much of its environmental
research, but there  is a perception among some that
research findings that run counter to agency policy are
unlikely from these captive institutions.
    The credibility  of  various  profit  and nonprofit
private research organizations is also regularly questioned
because it is believed that the continuing need for new
research contracts imbues them  with a sense of cau-
tion—that is, in practice, they become the kept orga-
nizations of those who fund them.
    University research groups are often more credible
because their job security is somewhat more removed
from continuing success in generating contracts, but
they are hampered  by  organizational traditions.  For
example, the types of studies called for, fit poorly with
reward  systems  based  on  academic disciplines and
traditional basic academic research.
    A model for the type of institutional support being
recommended is the U.S. Air Force relationship with
the RAND Corporation. A fixed yearly support  level
allows the building and maintenance of a research staff,
and based on that  support  level the organization is
obligated to do research in problem areas identified by
the funding agency, but the research staff is also
expected to carry out  independent research  of their
own choosing.
    I would like to  emphasize that credibility  requires
openness. Publication of research results should not be
constrained by contractual arrangements which require
prior agency approval.
    My final recommendation has to do with the data
base upon which all of these environmental studies will
be based.  At the present time, data on  developing
energy technologies is difficult to access, and compar-
ability among alternatives is lacking. And we heard that
point emphasized by some of the previous speakers.
    What is needed is some  sort of "national energy
data center" to act  as a central  repository for energy
resource  data  and performance  data  for energy
technologies and processes.
    The primary function of such an organization
would be: One, to collect and verify basic data on the
input-output  characteristics of energy technologies;
two, to facilitate access to energy data for all interested
parties;  and three, to conduct data analyses useful to a
range of participants. Such an organization should have
complete access to environmentally related data gener-
ated by federally funded research or demonstration projects.
    In  summary, I just want to emphasize  that the
primary theme of my statement is the need to enhance
information credibility.  The  utility  of environmental
research on new energy technologies is as dependent
on the manner in which the information is generated as
it is on the technical content of the information.
    I'll quit here and try to respond to any questions.
    MR. ONDICH: Thank you, Dr. Devine.
    Do we  have  any  questions from the  panel?
Dr. Atallah.
    DR. ATALLAH: I have something on the last item
that you mentioned, on the national repository for data,
that many of the data that are developed today are on
small pilot plants, PDUs,  and the use of these data for
large-scale predictions, future predictions, may not be
appropriate without proper scaling and without quality
assurance of the data and how it was derived.
    So before you get to that stage you want to be sure
of the quality of the data, and eventually scale it up
properly. And that may be a problem.
    DR. DEVINE: As you know, a lot of  that data
floats  around now, talking about emissions from syn-
thetic fuel plants, and so on, but we really don't have a
very good idea of what emissions really will be from
such facilities, because they all are based on very small
bench-scale or pilot-scale units. So that information is
available now and people use it. But the purpose of this
organization would be to gather that  data in  a  central
place.  1  think  it  ties  very  closely  to  some  earlier
testimony  about the need for  some kind of  annual
report  which   summarizes  information  on  energy
resources and describes energy technologies.
    When I  mentioned  that it shouldn't  just collect
data, the agency should also analyze and publish reports
that would utilize  this data; to try  to make publicly
available what this data  means; what we know about
various energy technologies; and, depending on  their
state of  development, how reliable the data  is. These
sorts of tasks would be  the purpose  of this  group  or
this agency.
    DR. ATALLAH: Thank you.
    DR. BISHOP: We've heard some earlier sugges-
tions,  Dr.  Devine, about agencies that might possibly
undertake the types of activities that you describe here
as requiring a new Federal agency.
    Being one concerned with expanding government
agencies and bureaucracies, can you comment on your
feeling of the possibility of some existing entities taking
on those responsibilities, and  with credibility,  as you
put it?
    DR. DEVINE: Yes, there're two different agen-
cies or organizations. One was the agency which would
merely supply the funds, and then there was a  recom-
mendation having to do  with the creation of research
organizations which would carry out the research.
    In terms of the agency, I would think you probably
could do it  with something like the National Science
Foundation  now,  without creating  a  new agency.
However, they would be given a certain lump  sum of
money to spend in supporting energy/environmental
research.
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                                                                                Statement of Dr. Devine
    DR. BISHOP: Thank you.
    DR. ATALLAH: Coming from an agency which
derives its funds from the hidden surcharge on your gas
bills, that's not very much unlike a tax, really. We are
being pressured into using consumers on  our advisory
board. And one of the biggest problems that we have is
finding knowledgeable consumer representatives and
representatives  who can  truly  represent the  total
American public.
    Can you suggest where we can get people to serve
on our committees  and advisory boards?
    DR. DEVINE: 1 think that question's been brought
up several times today. You agree, we should get the
public participants involved, and yet we don't—a lot of
these end up being a pretty small circle of people. And it
requires some expertise on the part of the participants.
    We in  our study did make recommendations on
this point. I know this is a whole other issue, this idea of
how do you get public participation. Do  you provide
funding for public participation groups, and so on? I
think  that  it  probably  is necessary to  find  some
mechanism to provide financial support to "public par-
ticipants." I think that might take the form of providing
funds to groups where they can buy their own professional
expertise.
    DR. ATALLAH: But I look at the  list  of public
representatives who appear here. Which one should
I select?
    DR. DEVINE: Oh, you mean which group should
you select?
    DR. ATALLAH: Which group should I go to?
    DR. DEVINE: Oh, I don't know.
    DR. ATALLAH: There're at least a hundred.
    DR. DEVINE: Well you have to try to select a
representative  sample, I think, representing environ-
mental groups, consumer groups, local governments,
and so on, and I know it can get out of hand, but I-think
more important  than that is  just how these  groups
actually get involved. I think a lot of points have been
brought out here today that they get involved too late in
the process. One of the points made throughout my
statement was that  these groups should  be involved
early in the process.
    DR. KINSEL: Let me make just two comments.
One is that there is a certain belief that there is a con-
sumer movement or an environmental movement, as
such, and yet  those  of us who are in some of these
segments of the public interest movements understand
that there are  differences of opinion even within the
organizations or the, quote, "community," unquote.
    So part of the problem might be that you want to
convene a spectrum of views within the community and
begin to get some feeling for what the overall viewpoint
is. That might be one way to get around the problem.
    In fact, that's one of the things which the Depart-
ment doesn't do, and many  Federal  agencies don't.
They  select one or two  groups and  assume that
therefore they have a full range of views, when in fact
there may be a wide divergence  of views, admittedly
within  a  narrower  spectrum or  narrower  range,
perhaps, than in the public at large, but in terms of the
information which might be  helpful to policymakers,
they may not be getting the diversity of views  from
within the environmental community  that they might
really benefit from.
    I  would like to ask you one specific question. I
discussed with an earlier witness the problem which
some see with the National Laboratories, and you referred
to that.
    From your perspective  as one  clearly  who has
looked at this problem from  the policy as well as the
scientific point of view—how would  you classify the
peer review in the scientific community of the environ-
mental assessment work  done by the National Labora-
tories?  Can you  make any generalizations  about
whether  that  work  is  seen  as being competent,
pedestrian, what?

    DR. DEVINE: I'm  not really sure I can. I  guess I
haven't really seen any comprehensive public reviews of
the environmental work by the National Laboratories. I
am familiar with  some of the work directly.  1 haven't
seen other people's views of it.
    From what I've seen of it, it looks technically com-
petent;  you  know,  I'm really  not  challenging  its
technical content; I'm really not saying that it's not good
competent work, but it's  a question of the credibility of
it. The question is, will the range of interests who see
the results of this work that  may, for example, be in
favor of synthetic fuels, will they believe that? Will they
believe it as much if it came from some other organiza-
tion which they see as having  less of a vested interest or
less of a direct tie to the  Department of Energy?
    And that's  the real issue.  It's  not  whether it's
technically competent work. I think from what I've seen
that the research  that comes out of the Laboratories is
technically competent.
    MR. ONDICH: Again,  thank  you,  Dr. Devine,
and at this point I'd like to suggest a five-minute break
and we will reconvene at 3:35 and our first witness will be
Edith Chase, followed by  Dr. Norbeck and Mr. Seaman.
    (Whereupon, a short recess was taken.)
    MR. ONDICH: I'd like to resume the  hearings,
and I'd first like to apologize to Lore Keffer. I realize
you've been  here all day—
    MS. KEFFER: That's all right.
    MR.  ONDICH:  —and it was  completely my
mistake in not calling you to the witness table.
    First I'd  like to have  Edith Chase of the League of
Women Voters, and then we'll follow with Lore Keffer?
    MS. CHASE: No, she was ahead of me.
    MR. ONDICH: Oh, okay.
    MS. KEFFER: Do we wait for Rebecca?
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Hearing of October 5, 1979
    MR. ONDICH: No, I think we should proceed.
    MS. KEFFER: Okay.

Statement of Lore Keffer
Group for Recycling in Pennsylvania

    MS. KEFFER: Group  for  Recycling  in Penn-
sylvania is a public interest group whose purpose is to
promote  conservation of energy and  materials. The
group was founded in 1971  on the premise that it is
unconscionable to  uncover new  sources of materials
and energy—ever  more remote, less accessible, and
therefore ever more costly—if these  supplies are to
be wasted.
    Conservation has been  our  only  source of new
supplies in the recent past and will be our only source in
the near term. Conservation, along with the use of
renewable sources  should be our major source in the
long term.
    In view of our stated interest, the prior question
immediately comes to mind, even  before trying to
evaluate the adequacy of attention paid to environmental
protection and consequences  of the RD&D program for
energy development, underway at DOE.
    Where does a given RD&D project intended to
develop a new source of energy fit into overall energy
procurement policy?
    How is a  stated  RD&D program offset  with  a
similar RD&D program in conservation or in the use of
renewable sources of fuel?
    There appears to be no mechanism for the public's
participation in such policy planning. Yet, any comment
on  environmental  impacts of new  fuels  is absurd,
indeed,  an imposition on the public, without proper
knowledge, as well as input, into overall energy pro-
curement planning. We cannot return to  eighteenth
century living. We need energy to exist, but we are also
aware that any technological commands—any  tech-
nology, excuse me, commands a trade-off between a
steady supply of energy and usually adverse environ-
mental, social, and economic impacts. The  question is
one of scale:
    Are  the dislocations necessary? Do we need this
given technology at all? If we do, on what scale? Is the
price worth it? Can the energy be supplied in some other
way,  everywhere  or,  perhaps, in a specific location?
    According to the Council  on Environmental Quality,
DOE's total fiscal year 1979 budget for conservation is
less than one-third  of its budget for energy production.
Furthermore, conservation research, per se, is only a
relatively small part of the conservation budget, and
most of it is directed to the near term rather than the
long term efforts. A large fraction of the projects  DOE
terms  "research"  are   actually  projects  which  are
demonstrating existing technology.
    This is a quote, this prior paragraph.
     Another quote. "Even though there has not been a
.detailed  review of DOE's conservation RD&D  pro-
 grams, several recent studies suggest that large addi-
 tional energy savings are achievable through a sharply
 expanded program of basic and applied research of an
 advanced technical nature. These  studies suggest  a
 number of rather major changes in DOE's conservation
 RD&D effort:  What—develop a substantial program of
 basic and  applied  research  aimed  at  the better
 understanding of fundamental processes and properties
 of  inherent interest in  conservation. Restructure the
 RD&D  program explicitly to encourage  unsolicited
 proposals directed toward new ways of doing things,
 rather than incremental improvements. Three—Provide
 increased emphasis on energy transformation and con-
 version at the point of "end use." Develop more effi-
 cient small-scale conversion systems. Expand nonhard-
 ware research to improve understanding of the relation-
 ships among energy, its substitutes, and the economy.
 This research includes an examination of existing public
 policies, such as, real estate taxation, direct and indirect
 transportation subsidies, and corporate tax policy with
 respect to RD&D and capital investment. And finally,
 public education aimed at the aggregate of small savings
 by  many of the efforts of countless individuals."
     And that is the end of the CEQ quote.
     To sum up, until the public knows the scenario of
 our energy future, it cannot make judgments regarding
 the adequacy of environmental protection. If the aim is
 to be satisfied with some 85 quads of energy supply by
 the year 2000, then the synfuel program, for instance,
 is very expensive indeed—both in terms of actual capital
 investment and  in terms of its costs  in  environmental
 degradation.
     If we, as a  nation insist on burning 120 quads of
 energy by the year 2000, then  environmental protec-
 tion must be traded against the extra BTUs, and the
 environmental provisions are probably  adequate and
 realistic.  We  will  just have to  be  prepared to pay
 the price.
     The general decision process of going ahead or
 not going ahead with a given RD&D project appears
 rational and orderly. Decision gates are set up at each
 step of the way, on paper. Whether the process actually
 works, is less clear.
     We have a  few comments about this process.
     The  Systems  Acquisition  Advisory  Boards,
 ESAAB, are all internal boards, made up of senior DOE
 officials and do not include the Assistant Secretary—oh,
 I'm sorry, and do include the Assistant Secretary for
 Environment. But we wonder whether this Board ought
 not to be opened up to  include a few who bring along
 other points of view.
     It is—we almost had the impression that there was
 a secret cell passing on a given project.
     It is good that the Assistant Secretary for Environ-
 ment is a member of ESAAB, but we wonder whether
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                                                                                  Statement of Ms. Keffer
he is not outnumbered and also outvoiced from the very
outset. He being only one person, as opposed to the
number of project officers.
    If the dollars  spent on 70 nonmajor  quote,
unquote, major systems constitute 50% of the  RD&D
budget, why are these not reviewed for environmental
impact as well? It seems to us that in the aggregate,
these   nonmajor  systems could  do  quite enough
environmental damage to warrant this attention.
    As a corollary, are the positive effects of  certain
smaller conservation projects factored into acquisition
decisions?  And in  this respect  we  overlap with
almost—with  every  other  testimony  I  have  heard
this morning.
    Along the same lines we wonder whether members
of environmental coordinating subcommittees are out-
numbered and outvoiced by project officers.
    Are projects funded to be  truly research and
development projects or is th'e agency tacitly expected
to bring the projects under consideration on-line? Or to
put it  in another way, how do you halt a project which
is, say, in the demonstration stage?
    The structure of decisionmaking in any DOE pro-
gram  requires investigation into possible environmental
impacts, but  does not  appear  to  require that these
impacts must actually be dealt with. By the time a proj-
ect has progressed through the various decision gates,
that is ERD and then EA and then EIS, and does arrive
at the point where an EIS is called for, it seems rather
late. We feel the structure tends to propel a project to
completion, rather than making the managers hesitate
or even halt. We found it difficult to visualize a decision-
maker actually scrapping an RD&D project on environ-
mental grounds.
    The provisions for public participation during  the
development of a given project seem sincere and well-
intentioned. Yet, it is not clear that it all works.
    Many of us have been very vocal about not being
able to obtain sufficient information in order to make
judgments. Others receive no notice of developments at
all. True, the  public may obtain an Environmental
Readiness Plan and later an Environmental Assessment
and Environmental Impact  Statement documents  but
the public has  to be truly in the  know to be  able to
find the right person from whom documents are to be
obtained. Further, the public must monitor a  project
continually to know when to obtain information.  It is not
clear  that either DOE or its agent in  environmental
matters, EPA,  is prepared and equipped  to  furnish
necessary information.
    We do appreciate the fact that you  are  always
going to act on incomplete information, we don't  want to
be nags and want more and more and more information.
    We are talking about a reasonable minimum.
    The burden to find out seems to be on the public.
There are some advantages inherent in such a burden-
some process. When information is handed out,  it tends
to be presented in the best possible light. Still, given the
extremely slim resources of public interest groups, it
does seem reasonable.
    I would like to make a little footnote.
    Since we are a conservation organization, and
have quite a lot of expertise on the subject of garbage,
we would much rather have gone to Atlanta. We would
have had a lot to say about recycling and garbage. But
we couldn't afford to go there. Enough said about that.
    I'm sorry—we'll  just very briefly touch on envi-
ronmental concerns  in  the  field  of liquefaction and
gasification of coal.
    We, who attended  the Pittsburgh workshop, had
persistent questions about whether the synfuel projects
were being rushed, no matter what the economic and
environmental costs. As long as the public is not privy to
information regarding energy development in general,
there was no answer to that question really.
    Another question nagged at us: what is the nature
of research  into  the  scale-up of a given technology?
Techniques  do  not always proceed  linearly from
laboratory to pilot plant to demonstration plant to com-
mercialization. Yet, we found that no research on this
subject was in progress. Scale-up on a linear progression
is simply assumed.
    That seems to us, to be living dangerously.
     Finally, DOE finds that there is a 50% chance that
synfuel technology will  violate  environmental regula-
tions. Are we, in the Pittsburgh area, made to realize
this? Is there any funding in the synfuel program public
education on this subject?
     We feel that there should be a line item specifically
for this public education purpose.
     Finally, recommendations for improvements in the
provisions for public participation. The resources of any
public interest group,   particularly  a  local  one, are
externely slim, as we have already mentioned. It would
be a good idea to give public interest groups some help
in doing their job and DOE's job better. We have mixed
feelings  about funding  private citizens groups from
public money altogether. But DOE or its monitor, EPA,
could help in other ways.
     One of them might  be when—that when attending
hearings  or conferences,  duplicating  and postage
money would be welcomed, so that those attending can
share with others what they, themselves have learned.
You must remember that a—to a public interest group,
$20 is money. And it  would cost us at least that  to
duplicate the handouts and send them out to say our
Board members. That  would be very helpful if our
Board—each one of our Board members could learn
what the representative who was sent to a given hearing
or conference learned.
     And I might also add that the public interest group
is your best bargain  in  the world. You are getting a
wealth of expertise and free labor, a lot of labor.
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Hearing of October 5,  1979
    DOE and/or EPA might develop a good representative
 mailing list.
    Then—airfare and per diem to participate in out-
 of-town hearings are most welcome.
    We  thank you for this opportunity.
    We  also think  that any serious  regard for  envi-
 ronmental  effects  must provide for  enforcement of
 regulations. It is in this context that we deem it vital to
 provide funds to  educate the public  as to what they
 must  know  in order to monitor the enforcement of
 regulations when a project does come on-line.
    MR. ONDICH: Are there questions from the panel?
    You mentioned that some of your testimony had
 overlapped or covered some of the  other testimony
 presented today,  as well as some other days of the
 Hearing.
    I would like  to just ask a question about energy
 conservation in use which you talked about, particularly
 since  your organization is local, I presume, in the Pitts-
 burgh area. Do you have some statistics or information
 on the impact in your area—in Pittsburgh?
    MS. KEFFER: —No I don't have numbers, I will say.
    But  it does seem to us that a synfuel program is
 akin to killing a gnat with  an elephant gun in many
 respects. The capital investment  is enormous. The jobs
 created are minimal. And certainly they are not created
 in the sector where they're most needed.
    On  the other hand, there  are many jobs to be
 created in the conservation of  materials. And it just
 seems to us unconscionable  to try  to fix  whatever
 energy problems we have by simply digging a deeper
 hole and going after more of where the previous stuff
 had come from.
    And this is what we are essentially doing.
    No,  we  do not have  hard numbers—say if  we
 recycled the 640 tons of newspaper that we generate in
 Allegheny County—that  would  produce more BTUs
 than X barrels of liquefied coal.
    But  I wonder if anybody else has those numbers.
    And, at the same time, I think that would be RD&D
 money well employed.
    MR. ONDICH: Again, I thank you.
    And may we have Ms. Chase now?

 Statement of Edith Chase
 Environmental Quality Committee
 League of Women Voters of the United States

    MS. CHASE: 1 am Edith Chase,  a member of the
 Environmental Quality  Committee of the League of
 Women  Voters of the United States. The  League of
 Women  Voters of the United  States is a volunteer
 citizens group organized in over  1300 local Leagues in
 all 50 states, the District of Columbia, the U.S. Virgin
 Islands and Puerto Rico. The League has been involved
 in water resources management,  water  quality,  air
 quality and solid and  hazardous waste issues for a
number of years. These, of course, are the key envi-
ronmental factors  that must be  considered  in  any
evaluation of new energy technologies.
    League  work  in  the  energy  field,  a  natural
outgrowth of our  longtime  environmental  interests,
dates back to the early '70s and resulted in adoption of
an energy position in 1978.
    Briefly,  the League supports policies that: One,
bring about a significant and progressive reduction in
the U.S. energy growth rate.  Two, give priority to con-
servation, renewable resources and the environmentally
sound  use of coal  in the United States  energy  mix
between now and the year 2000. Three, effect a shift to
predominant reliance on renewable resources beyond
the year 2000. We also believe that public understand-
ing and cooperation are essential to the success of any
national energy strategy. We are equally convinced that
citizen participation in decisionmaking must be assured
at every governmental level.
    Thus, we especially  appreciate  the  fact that  a
number of League members have had the opportunity
to participate in the Section 11 regional workshops this
year and, of course,  in the Hearing this week in
Washington. I attended the Pittsburgh workshop  and
was impressed  by  the excellent job  done  by  the
workshop leaders. The agenda was carefully designed
and the purpose was clearly stated. Carefully prepared
materials were sent in advance of the meeting.  The
visual aids were well-designed, ample opportunity  was
allowed for  both  discussion  and  questions, and the
participants came from a wide variety of backgrounds
and interests.
    This afternoon, I would like to speak to two prin-
cipal issues.  First, the consideration given to environ-
mental and conservation factors in DOE decisions on
nonnuclear technology RD&D projects and  second,
opportunities for effective  public participation in  the
decisionmaking process.
    First, to what extent are environmental and energy
conservation factors included in DOE decisions on non-
nuclear energy technology and RD&D projects? Judg-
ing from the  charts that outline the DOE planning  and
decisionmaking process vis-a-vis RD&D, or presumably
in budget allocations, little emphasis has been placed on
conservation and  renewable energy sources.  The
Energy Systems Acquisition Advisory Board apparently
meets in closed session and the criteria on which their
decisions are based are not  made public. It appears
doubtful therefore that the DOE technology develop-
ment  planning  process integrates all environmental
concerns at the program or energy systems level.
    Additionally, the Environmental Protection Agency
has no role in  DOE's decisionmaking  process. It
seems to us that EPA's environmental expertise should
be utilized and that EPA should have, at the very least,
an advisory role on the key decision points. Under the
present  system,  EPA is consulted only after the  fact,
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                                                                                  Statement of Ms. Chase
which may be too late to influence the consideration of
environmental factors that are of critical importance to
the decision  to proceed with  a technology.  Further,
DOE's formal decislonmaking process seems to concen-
trate on large, high-cost, high-technology programs to
the exclusion of smaller systems. There appears to be
no mechanism for  consideration  of  decentralized
systems and appropriate technology. Neither the chart
nor the process indicates, for example, any considera-
tion  of energy conservation,  reuse and recycling,
renewable  energy  sources,  waste  heat utilization, or
nonquantifiable benefits such as clean air and water.
Thus, the environmental review process may not be as
comprehensive as called for by the Program and Project
Management  System,  and potentially  cost-effective
approaches may well be overlooked. In addition, some
smaller scale projects could pose serious environmental
impacts that would not be adequately evaluated.
    We also question whether the DOE process ade-
quately addresses the following areas of League concern:
    Criteria for decisions which  include  net energy
analysis, long-term energy productivity, health effects,
both acute  and chronic, and the interrelationships with
water, air and land use. Is consideration given to the
delivery of energy  to the user,  including transmission
losses and social, economic and environmental impacts?
    Also, mechanisms for conflict resolution.
    Provisions for independent review at key decision
points.
    Provision for coordination with other agencies.
    Cost/benefit analyses that identify hidden subsidies
such as  Federal  RD&D  dollars  for certain  energy
technologies, the discount rate  used and spelling out
what costs are included and excluded.
    Another, consideration of potential capital costs in
relation  to  alternative  uses  for those funds and  the
sources of capital and operating funds.
    Changes in institutional arrangements needed to
protect public health and safety for future generations.
    The role of State and local governments and the
private sector in construction and operation of various
energy systems.
    We would also like to  know whether the chart
outlining DOE's decision making process represents how
decisions are really made and the consideration actually
given to environmental factors and alternative means of
meeting energy needs before a go-ahead decision is made.
    Although we have a number of questions concern-
ing what happens during the PPMS process, we do sup-
port  a systematic  approach to decisionmaking and
documentation  requirements.   While environmental
concerns resulting  from the development of specific
technologies may have been identified, they do  not
appear to have been dealt with adequately.  PPMS is
project-oriented and the Office of Environment's role is
largely limited to one of influencing project develop-
ment rather than affecting policy development. In addi-
tion, we question why Environmental Assessments and
Environmental Impact Statements are prepared by the
Technology Program Office rather than the Office of
Environment. Close coordination between DOE, EPA
and other agencies at all steps in the process is, from the
League's perspective,  essential in light of the environ-
mental impacts of the various energy technologies.
    The  list  of  criteria   for  evaluating  individual
technologies on  page 15  of the "Background Docu-
ment" is an excellent point of departure. However, we
believe major  emphasis should be focused  on  waste
management,  a  key national issue. Serious problems
today result from focusing attention on the front end of
energy cycles and neglecting the back end of the cycle.
We believe a major research effort is needed on ways to
reduce, not just treat wastes, and to deal with existing
problems, such as fly ash, sulfur emissions, carbon diox-
ide, mine tailings and stripped lands, before proceeding
at full throttle to create more wastes. The environment
is not an infinite sink.
    Some  of our recommendations: We recommend
that the Office of Environment play a greater role in
policy  development,  especially with respect to com-
parison between various technologies. Funding should
reflect those added responsibilities. Environmental con-
cerns should  be  considered  from  a  whole-system
management perspective,  including long-term impacts
and human as well as  natural factors. The ESAAB
should review a larger  portion of DOE RD&D pro-
grams, both major systems and smaller projects, using a
defined set of criteria,  including waste  management.
Appropriate technologies,   energy  conservation, and
solar programs could be aggregated as a major system,
with formal high-level review.
    The second issue I wish to address is: How can the
Federal research management process be modified to
include  opportunities  for  the  public to  effectively
participate in the decision process?
    The League is concerned about the limited oppor-
tunities for public involvement in  the decisionmaking
process. Government and industry have clear environ-
mental responsibilities, of course. The purpose of effec-
tive citizen action is not to subvert those responsibilities
but to make sure they are  honored. Government and
industry have  experts,  but citizen organizations often
have their own expertise to contribute to environmental
decisionmaking.  Moreover, while environmental deci-
sionmaking must be based on the best available scien-
tific and  technological  information, value judgments
and social decisions are ultimately required. And these
social decisions must reflect the public will, for the envi-
ronment belongs to the public, not just the experts in a
government agency or industry immediately involved in
a particular decision. When risks must  be  measured
against benefits or when economic and environmental
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Hearing of October 5, 1979
values must be weighed and balanced, the public has
the right and the obligation to  make its views known.
Mediating differences between citizens and government
early in the planning process can avoid confrontation
at a later  date and also subsequent  citizen distrust
of government.
    Opportunities for public involvement, according to
the DOE chart, are limited to  comments on the draft
EIS. Public comment might well be invited on  basic
assumptions such as determination of need, population
projections, per capita energy usage and price elasticity.
Further, no role is defined for State and local officials
and agencies. They might participate in a review and
comment  procedure on general issues;  their  input
would certainly be essential on site-specific issues.
    In order to participate, citizens need to be  informed.
For example, while 1 receive the  DOE Weekly Announce-
ments, Energy Insider,  and Consumer  Briefings  and
appreciate these, I am not aware of any efforts to inform
the public of the availability of important materials such
as the Environmental Readiness Documents.
    For effective citizen participation, we believe there
should be 1) a clearly defined mechanism or process.
2) Commitment to the mechanism or process by all par-
ties directly concerned. 3) Direct access by citizen par-
ticipants to  the decisionmaking process or body  and
access to materials or documents on which decisions are
to be  based. 4) Broad geographical and interest  group
representation. 5) A clear definition of the participating
citizen's role.  6)  Adequate  preparation  and briefing
available for citizen participants. 7) In-depth information
and staff help available in order for participants to carry
out assigned  responsibilities.  8) Well-defined proce-
dures as to whom and how  citizen participants are
accountable. 9) Procedures for reporting back disposi-
tion of citizen recommendations.  10)  Provision for
periodic public meetings for direct citizen input  and
review as plans or programs  develop. 11) Adequate
notification  of meetings and  where  information  is
available for public inspection.
    There are, of course, many ways to broaden'citizen
participation in this process.  We would like to suggest
the following possibilities: setting up a working group of
citizens and elected officials to draft a proposed  public
participation program, including information  outreach;
establishment  of an  interdisciplinary advisory board;
installation of a toll-free number; funding an ombudsman
and finally, providing funds for some research, travel
and per diem expenses for representatives of the public
so that they may attend key meetings or hearings.
    And then some recommendations: Public partici-
pation in the planning process  should begin at an early
date.  Citizens should be involved in developing the
criteria to be used for evaluation, setting priorities and
reviewing internal documents including the Environ-
mental  Development  Plan  and the  Environmental
Readiness  Documents.  Environmental  Assessments
and Environmental Impact Statements should be based
on these documents and serious consideration should
be given to environmental concerns identified during
the PPMS review before further development takes
place. The public should also be involved in developing
the criteria for  siting energy and waste management
facilities. Following the review and comment period of
public hearings, a summary report that includes the
answers to the questions raised by the public should be
prepared  and distributed.  The  DOE budget  should
include  adequate  funds  to  underwrite  increased
information dissemination and public participation.
    Recent discussion of fast-tracking energy decisions
raises questions about the possible exemption of energy
facilities from complying with new laws and regulations
designed to protect the public against problems such as
toxic chemicals or drinking water contamination.  We
are concerned  that environmental considerations are
proceeding at a snail's pace while energy development
is moving ahead like a jackrabbit. The League believes
that  expedited  review of  energy facilities could be
appropriate, but not if citizen involvement,  information
gathering and environmental protection are sacrificed in
the process.
    Thank you for the opportunity to express  our
views.
    MR. ONDICH: Thank you  Ms. Chase.
    Do we have any questions from the panel?
    1 might mention—I understand that you have  a
plane very shortly, so we'll try  to keep it just  to  a
question or two.
    Dr. Bishop?
    DR. BISHOP: Just one question that relates to, I
guess an observation between the two of you as we've
heard your testimonies this afternoon. Both calling for a
greater role of citizen involvement as we've  heard quite
a bit today.
    You represent an organization that is nationally
based,  and has, of course, perhaps a broader base of
support because  of that  organization  to  participate.
And 1 understand that your organization is essentially a
local one.
    MS. KEFFER: Yes, it is a local one.
    DR.  BISHOP: Both of you have indicated the
need for more resources to be provided so that public
interest  groups, however you  define those, and  who
represents the public interest, can be involved in  this
kind of a process, and I  agree that that's important.
    The question I have  is  how—if you  have  any
thoughts on how you distribute what I would expect to
be very limited and constrained resources that might be
available for  this  kind of participation?  How do  you
decide who gets it? And which ones are going to receive
some of these funds to participate and represent all of
the diversity of public interest that's out there?
    MS. KEFFER: Could I ask you a question by way
of answer?
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                                                                               Statement of Dr. Norbeck
    Your total  RD&D budget is what, a  million—a
billion and a half?
    DR. BISHOP: Mine?
    MR. ONDICH: DOE's-I believe in the fiscal year
1979 the nonnuclear energy RD&D budget was 1.8 biion.
    MS. KEFFER: Okay. I  understand  you spend
$20,000 on this, these hearings, once a year, $20,000.
    MR.  ONDICH:   I  don't  have the  numbers
available.
    MS. KEFFER: Okay, well let's assume that.  That
doesn't seem to me a great deal of money in terms of
one and a half thousand million dollars. I just don't see
why, with the will to do it, why you talk so terribly much
about limited funds. It's a  question of where do you
apply your funds first. It's a question of putting priorities
on things.
    DR. BISHOP: I  think that's  exactly  it, and the
question  is how do you do that? I think if you  took
the local—
    MS. KEFFER: Yes, okay, that's the more difficult
problem.
    DR. BISHOP: —level of interest on up to national
organizations and groups, there are literally hundreds of
thousands of such public interest groups.
    MS. KEFFER: Yes.
    DR. BISHOP: I  just don't think the funds—no
matter how large—whatever percentage you take of a
billion dollars is going to really be sufficient to fund  all of
those organizations.
    DR. BISHOP: No, okay. I grant you.
    MS. CHASE: My comment might be that it might
be on the basis of applications, and I know that DOE
already sends out requests for proposals, because I've
seen a few go by my  desk, and in general these are
requests for specific projects and demonstration of cer-
tain solar—including solar projects,  but in general I
haven't seen anything  requesting—requests for policy
development.
    And I feel that this is where we need more attention
than anything else, that on the policy issues I have not
seen any funding go by. Now that doesn't mean it hasn't
been, but I'm just not aware of it.
    So I—to turn the sentence around, I'm suggesting,
as in agreement with Ms. Keffer, that there could be
certainly a sum  of money, whatever the size, set aside
in requests for proposals,  and we would be happy to
submit them.
    I've  carried out some under contract with other
agencies. I don't have any with DOE.
    MS.  HANMER:   With  the League's extensive
experience in public involvement and decisionmaking,
I'm wondering if you have any agencies or projects that
you might suggest  to us as models to which DOE or
EPA might turn.
    MS. CHASE: My experience has really been with
EPA, and I've  done several projects on  208 Water
Quality Management and Coastal  Zone Management
and Air Quality and Coal Use, and you know, I've done
half a dozen, and we worked with the agency to design
a project. So working with them, so it would meet both
our needs and the agency needs is important. I don't
know that—right off the top  of my head—I could be
more specific than that.
    MR. ONDICH: Again,  I'd like to thank both of
you and call for our next witness.
    MS. CHASE: Thank you very much.
    MR. ONDICH:  Our next  witness is Dr.  Carl
Norbeck from the Thorne Ecological Institute.

Statement of Carl Norbeck
Thorne Ecological Institute
    DR. NORBECK: Thank you, Greg. I don't know
about the rest of you, but I'm pleased to  be  heading
down the homestretch on this Hearing. I would like to
assure  all  of  you  that  I  respect  the  rights  of
listeners—especially late on Friday afternoons—so I'll
keep my remarks brief.
    Of  the  five issues that were identified in  the
background document for this Hearing, the ones that I
would like to focus on  relate to what I would call an
outreach dimension, that is, the opening up of the plan-
ning process. The  issues that I am focusing  on are:
Number one, involving appropriate governmental levels
for treating environmental issues. Number two, involv-
ing  nonDOE interests  in  evaluating  environmental
issues.  Number three  relates to  the criteria  used in
evaluating individual technologies, and here I'm think-
ing of these criteria from the point of view of grassroots
concerns. For example, socioeconomic considerations.
    At the outset I would like to dwell just for a moment
on some of the things that I think have been lost in tran-
sition between the regional workshops and the National
Hearing, and then I would like to move on to some very
specific recommendations regarding the issues.
    For starters, I want to  dissect the term "issues." I
think that's a bloodless term.  At the Denver workshop
"issues" were identified as failures on the  part of the
Department of Energy:  a failure to involve appropriate
government  levels, a  failure  to  involve nonDOE
interests, and a failure to  develop  explicit grassroots
criteria.
    Greg, you'll recall from having been in  Denver
yourself, that there  was a tremendous feeling of frustra-
tion on the part of many of  the  people there, and a
poignant sense of voices in the wilderness in terms of
wanting to have access to the decisionmaking process
and feeling like  we were very,  very removed  from it.
There was a good deal of passion at the  Denver
workshop, and I'm sure at many of the others also. I
think that's something that does get lost in terms of the
translation to a background document for the National
Hearing,  and it really should be kept in mind.
    In terms of specific recommendations, criticism of
DOE on the three issues that I am zeroing in on reflects
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Hearing of October 5, 1979
the Machiavellian  maxim that the absent are always
wrong. People out west feel that DOE is an extremely
remote presence,  and in the case of  oil shale in
Colorado or coal  in Wyoming and  Montana, this is
particularly irksome.
     Let me talk for just a moment about oil shale. The
list of unanswered oil shale environmental issues related
to water, land, air, and people is extremely lengthy. In
reviewing DOE's Environmental Readiness Document
related to oil shale, 1 am of the opinion that it does not
effectively depict the magnitude and significance of the
environmental concerns,  that it  does  not effectively
depict the lag times involved in developing adequate
mitigation measures, and that  it  does not effectively
depict the possibility of actual failure of these control
measures.
     One  example would be  the euphemistic term,
"embankment spoil piles," which  sounds like a small-
scale phenomenon where you push a little spent shale
over the edge of the hillside, throw some grass seed on
it, and everything is restored. In actual fact, the volume
of materials that would be generated is so huge that it
would fill canyons, and the attendant problems related
to  stability, to erosion  and  sedimentation,  to  the
possibility   of ineffective  revegetation—they-  are
absolutely staggering. Those of us who live in Colorado
have a very intimate sense of the scale of these prob-
lems and I don't think that comes across in the Environ-
mental Readiness Document.
     If the three issues related to outreach concerns
were grouped together, the goal  statement related to
them would read something like this: To formally involve
local, State, and national levels,  as well as the public, in
the planning, assessment, and problem resolution process.
     Such a program would, of course,  give DOE a
more  intimate and accurate perspective  of environ-
mental problems related to a particular technology.
     In Colorado there is a lot of publicity being given to
a process which seeks to accomplish just these goals, of
involving people,  and  this is called the Joint Review
Process. At a time  when the Energy Mobilization Board
is being viewed as The Answer in trying  to get things
together, I think that it's worthwhile for me to talk a little
bit about the Colorado Joint Review Process, because it
is  designed to streamline the  process  of  review  and
approval of projects;  and it is certainly  a lot more
democratic than an Energy Mobilization Board.
     The Colorado Joint Review Process, as it  was
originally conceived, was designed to coordinate inter-
jurisdictional review and approval  of  major winter
recreation developments. More to the point, it is now
being  used  on  an  experimental  basis   for  the
AMAX/Crested Butte molybdenum mine, which is an
absolutely huge undertaking.
     What it does, it provides a "one window" coor-
dinating   forum  regarding regulations,  evaluation
criteria, and public involvement; and in addition, it is a
handy vehicle for eliminating a lot of duplication.
    At Crested Butte, the parties involved in the Joint
Review Process are AM AX as the proponent, the U.S.
Forest Service, the  Colorado  Department of Natural
Resources, and Gunnison County. Gunnison County is
the lead agency in coordinating the reviews.
    Another  interesting aspect of this is  the fact that
each of the four agencies that are represented serves as
the coordinating agency for its sister Federal, State, or
local agencies. In other words, when the Forest Service
comes to  a session, they have done their homework
and represent BLM, the Fish and Wildlife Service, the
National Park Service, and  whatever  Federal agencies
are concerned with that particular project.
    In similar fashion, the State agency that is the coordi-
nating agency represents all the other State agencies, and
Gunnison County brings together the local jurisdictions.
    As part of the Joint Review Process there is the
option to develop a strong public participation program
to complement it.
    The suggestion, the recommendation that I have is
that DOE consider using such a process in the Program
and Project Management System, commencing at the
pilot plant  phase. I  think many of the  earlier generic
phases could  be handled with newsletters and regional
workshops. However, with the actual siting of facilities,
an outreach program that goes down to the grassroots
level becomes quite  important.
    What I would like to do now, very briefly, is  just
walk you through some of the steps of the Joint Review
Process.
   • Step one in the Joint Review Process is the initial
proposal. In this case DOE or a contractor or an indus-
try would be the proponent. They would give the pro-
posal to a  selected agency and that would trigger the
process. BLM would  most likely  be  the  key Federal
agency related to oil shale.
    Step two would be an interjurisdicripnal alert by the
contacted agency—BLM—to  all the  affected jurisdic-
tions and municipalities,  and this includes everyone, all
the Federal and  State jurisdictions, and  the different
counties and  towns involved—a comprehensive list.
    Step three is a meeting of all of the parties to iden-
tify their concerns, to address the data requirements, to
hammer   out the evaluation criteria,  and  also  to
designate  the appropriate coordinating agencies. With
oil shale, for example, BLM would be the coordinating
Federal  agency,  the Colorado Department  of Local
Affairs would  probably be the coordinating State agency,
Rio Blanco County and the Town of  Meeker would
represent  the local jurisdictions. So here would be a
small body that could bring together the state of the art
in terms of regulations and evaluation criteria in a "one
window" context, and really streamline the process.
    Already  at step three and we have addressed one
of the issues that we're concerned with, that is, how do
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                                                                                 Statement of Dr. Norbeck
we involve different levels of government in terms of
their responsibility related to environmental matters.
    Step four would be a summary statement of that
meeting, and this would provide the grassroots input
that DOE would need for an  Environmental Develop-
ment Plan and for a Project Environmental Plan.
    Step five  is really the official kickoff,  the official
notification of  intent related  to a project. This is  the
optimum time to initiate an Environmental Assessment,
and also to notify all of the citizen groups.
    Step six relates to the preparation for common
public hearings. I think it's useful to be able to have
common public hearings, hearings that bring together
not only local concerns, but concerns of State and
national level as well.
    Step seven is the public hearings themselves.
    At this point in time, in terms of the Joint Review
Process,  we have involved the different jurisdictional
levels, we have had grassroots input in terms of  the
evaluation criteria, and we have had public input. All
three of the outreach issues that I was concerned with
are addressed.
    Step eight would be the  submission of a detailed
plan by the proponent incorporating many of the con-
cerns that have been expressed by the different jurisdic-
tions, and also, this would be the time of the possible
formation of an ad hoc citizens committee.
    Step nine, the Joint Review Team scopes out the
Environmental Impact Statement. The citizen commit-
tee can certainly be involved. The agencies and the pro-
ponent assign  money and manpower to get the  job
done. A cooperative agreement is signed, laying out the
role and expectations of everyone. The proponent then
applies for all of the permits.
    Step ten is the draft Environmental Impact State-
ment which would provide input to the Environmental
Readiness Document,
    Step eleven is the public hearings on the draft EIS.
An interesting aspect  of this is  the fact that each
level—the Federal, State, and local—issues a unified
statement in terms of their position on the project. The
final EIS is part of this step.
    Step twelve relates to the issuance of permits con-
taining stipulations relating to environmental protection,
and implementation is underway.
    Those are the formal steps of the Joint Review Pro-
cess, and it seems to me that it is a fairly easy task to
integrate the DOE decision  process into the  Joint
Review Process.
    I've  listed basic references  related  to  the  Joint
Review Process. Colorado has a Manual for the Colorado
Review Process. The Forest Service has become very
interested in the process and they have a document called
The Joint Review Process. And also there has been
considerable local coverage related to how the process
is working in the Crested Butte area.
    In view of the fact that there is a precedent in terms
of a process  by which many of these issues can be
adroitly handled, those of us in the West have a feeling
that to plunge ahead without something like this smacks
of the old scraping and raping game that has given so
many areas in the country lots of problems.
    If there's a bottom line on all of this I think it is the
fact that people in the West—and I don't want to be
totally aligned with the West; I  think people are con-
cerned everywhere. I  think that people want to have
standing in the decisionmaking process. They want to
have some ownership  in the decisionmaking process.
    The Joint Review Process is one mechanism, one
precedent that says this can be done. Time and again,
where people have not been given the opportunity to be
involved on the front-end of these things, they have
come in on the tail-end as the spoilers.
    MR. ONDICH: Thank you, Dr. Norbeck.
    Do we have any questions from the panel?
    Dr. Bishop.
    DR. BISHOP: I think you've outlined. Dr. Norbeck,
a very interesting program that you're engaged  in.
    I'd  like to ask just a couple of questions.  Is
the—does the program have—has it been institution-
alized in some way through law or otherwise to have
some actual legal standing?
    DR. NORBECK: Yes it has. It was established
by Executive Order of the Government of Colorado.
    DR. BISHOP: How's the outcome of the process,
then,  incorporated into  decisions about going  ahead
with certain developments?
    DR. NORBECK: It's a voluntary process. AMAX,
the Forest  Service, the State, and Gunnison County
have all entered into a cooperative agreement.
    Once  this  is  done, the process is fairly  well
legitimatized in terms of peer pressure. However, that is
also one of the weaknesses of the process, the fact that
it is voluntary and some of the parties can delay on it.
    DR. BISHOP: So  it's a morally binding process
and—
    DR. NORBECK: Yes it is, and we've found out
that there is lots of peer pressure to really do a good job
on it.  We're very encouraged by it.
    DR. BISHOP: Okay,  can  you just comment on
one more thing? The nature of the cooperative agree-
ment, that is between the—well, who are the signatories
to that and what does  it in effect accomplish?
    DR.   NORBECK:  Well,  the  signatories  are
whichever  corporate representative  needs to  sign as
well as the Federal agency  administrator, the County
Commissioners for the County,  and the Governor for
the State. And there is enough pressure in terms of liv-
ing up to the terms of those agreements that I think just
that pressure is an accomplishment that makes it work.
     Your're probably going to have to re-ask  that
question. We're not tracking.
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Hearing of October 5,  1979
    DR. BISHOP: Well I think maybe the answer is
longer than we have time to hear, but I guess it's really
more in the nature of what's contained  in that agree-
ment, the  key elements of it. Does it  outline  the
program, the study to be followed, the—
    DR. NORBECK: Oh, yes.  There  are,  in  the
documents that I mentioned, extensive criteria related
to all of the resources, the entire program in terms of
what's of specific concern to the area, the evaluation
criteria,  the  time frames involved, who's going to be
doing what, who's going to be paying for what. It's very
specifically laid out.
    DR. BISHOP: Thank you.
    MR. ONDICH: Dr. Kinsel?
    DR. KINSEL: I'd just like to ask a question also on
the process, which I find very interesting.
    I  wonder,  though,  whether  it  would  be  more
successful with a project which is site-specific by virtue
of the resource being only in  one place, such as a
molybdenum deposit, as opposed to—as we talked
about earlier today—there being possibly twelve or fifteen
potential sites for an oil refinery on the East Coast.
    It would seem  to me to be very complicated to
enter into this process in all of these sites, yet it's essential
to get local participation.
    Do  you feel—that this would be fairly  narrowly
applicable only to where you have  a particular high
quality oil shale deposit and the decision is basically
either it  goes there or nowhere.  You have a relatively
narrow range of choices, whereas on some decisions,
there may be a much broader geographic distribution, a
much larger range of possible choices.
    DR. NORBECK: That's true.  It is an  excellent
process, an excellent model in terms of something like
oil shale. If you're looking up and down the east coast at
fifteen   different alternatives,  that's quite   another
problem, but once something happens on the ground, a
process like this can be put into place and all the pieces
come together very fast.
    So it's just one of many tools.
    MR. ONDICH: Just two quick questions.
    One is, is this process similar to the one that's used
by—I  believe  it's   the  Northern  California  Powei
Authority, in siting a geothermal—
    MR. SEAMAN: No, I don't think so.
    DR. NORBECK: I'm not familiar with that project. I
know that the Joint Review Process  has been used in
Wyoming in terms of coal development.
    MR. ONDICH: My second question  is is it appli-
cable to  cases where you're using federally-owned land
for some purpose, a resource development, where they
have to be  crossed  to have some  development, or
whatever?
    DR.  NORBECK:  Yes,  1  think  it  certainly is,
because as  the scale of these projects increase, the
impacts  are  going to spill over from  the Federal lands
themselves into the communities and the counties that
are involved,  and I think that is one of the powerful
aspects of this process.  It enables you to deal in a
cohesive way with the impacts that are spilling out from
Federal lands.
    MR. ONDICH: Thank you very much.
    We'll move to our next witness, Mike Seaman.

Statement of Michael J. Seaman
California Solid Waste Management Board
Testifying In His Own Behalf
MR. SEAMAN: Good afternoon. I'm Michael Seaman.
I live in Sacramento, California and I'm here on my own
behalf to discuss the decisionmaking process as it per-
tains to implementation of the Act. The major points I
would like to make are that:
    The Program and Project Management System—
PPMS—as it is being applied to the Act, is an inappro-
priate decisionmaking process because it is not keyed to
the  resolution  of  conflicts between  technological
development and  environmental protection.
    The PPMS does not provide for adequate public
involvement.  This problem  is compounded by  the
apparent misunderstanding by DOE of the role of the
public in decisionmaking.
    The PPMS isolates contributions from those not con-
nected with DOE, especially those of State governments.
    The PPMS does not adequately address the spec-
trum  of  environmental  concerns, especially  waste
management..
    It is my feeling that if the  PPMS continues to be
used to implement the Act in the present manner, it will be
difficult to accelerate the development of vitally needed
energy alternatives. The outcome of the current process
will be solutions  with  diminished  effectiveness and
weakened popular support. My specific concerns are
as follows.
    The  decisionmaking process.  The Program and
Project Management System guides the commitment of
expenditures  for  technologies through  the various
development phases.  It is a useful tool for controlling a
sequence of work such that the product can occur on
schedule.  I have  used  such a  tool as a construction
manager designing and building public works projects
and as a local government planner for administering
planning grants. As noted in the Section 11 background
document, the PPMS is not a policy planning system,
however.
    The fundamental flaw of the use of the PPMS as
the mechanism to address both technological develop-
ment and environmental management is its lack of sen-
sitivity to the balancing of diverse values between those
two broad subject areas. Conflict resolution  is fun-
damental  to  public  policy and decisionmaking. The
PPMS  is  incapable  of  achieving  consensus  among
conflicting values.
    Traditional decisionmaking  processes  may be
characterized as shown in Figure 1. Component factors
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                                                                                Statement of Mr. Seaman
of policy, supply, demand, environment, technology,
or whatever, are exogenous inputs to a "green box" that
eventually yields an outcome. The PPMS represents an
orderly description of what happens inside the "green
box"; it provides for a systematic way of receiving the
inputs and directing a flow of work towards the output.
    Notice  that the diagram does not show a relation-
ship between any two  input  factors.  Supply  and
demand do not constrain each other, for example.
    In recent years the notion of scarcity has suggested
a reevaluation of the traditional decisionmaking paths;
this is particularly necessary in the energy field. Perhaps
policy should be related to supply and demand.  Per-
haps technology and the environment are connected.
The latter concept appears to be what Congress had in
mind in passing Section  11 of the Act.
    The PPMS is a linear scheduling tool with very little
tolerance for feedback  and reevaluation, and limited
criteria to evaluate progress along the way. The criteria
are not used routinely and are not formally required in
the management process. This is consistent with the
system's flow charts. There are no paths to preceding
steps in the event a mistake or problem might come
to light.
    Construction or production  scheduling demands
this sort of steady flow. It allows for time to catch up, but
not for time to redesign the program. In contrast to the
guarantee of performance by  a bond, public decision-
making is normally characterized by incremental change
that follows from competition among differing values.
The results  cannot be guaranteed. Without an  iterative
process, some values run the risk of being shunned  or
shoved around in the rush to demonstrate project success.
    Environmental factors  are  especially  affected
adversely by  the PPMS. The system pretends to inte-
grate environmental factors with technology develop-
ment factors. However, no opportunities exist for the
steady exchange of information between the two. It is
only at~ a  few decision  points that  such potentially
diverse values confront each other.
    Since these decision points occur towards the end
of a series of steps, there is scant room for the flexibility
necessary to achieve a  compromise. At  a minimum,
there should be  a mechanism for the early and  con-
tinuous flow of ideas from one set of values to the other.
     Figure  2 portrays  another systematic decision-
making process,  one which  I  have used to gain a
perspective on a wide variety of complex environmental
management  projects.  The  factors  within the box
representing  the energy  management system are the
biophysical subsystem, the energy use subsystem, and
the energy  decisionmaker.
     Each factor is interrelated within the system. The
system inputs are the  definition of the problem and
statement of goals—a law, for example—a budget, and
the lobbying or monitoring efforts of watchdogs.
    The outcome of the system is the maintenance of
an internal state of equilibrium, or change to a different
evolutionary stage, as expressed by a redefinition of the
only controllable  inputs—the problem statement and
the budget.
    The biophysical subsystem is defined by the envi-
ronment's ability to give and take. The land may yield
valuable coal, for instance, but there is an equal and
opposite measure of environmental damage from pollution,
land devastation, and waste generation.
    The energy  use  subsystem  may  be  similarly
described. It represents societal  interactions such  as
supply and demand relationships, price versus elasticity,
and so on. Besides internal constraints, these two sub-
systems constrain  and benefit each other.
    Energy  decisionmakers  must  understand   the
nature of their interactions to perceive how technology
and the environment  complement  or  conflict  with
each other.
    The energy decisionmaker has the important role
of achieving  and maintaining the steady state or recom-
mending program redefinition. In the PPMS there is no
such obligation to create a balance. There is, instead,
a duty  to  move a  project along from research  to
commercialization.
    Public involvement. The PPMS, being of private
sector and defense origins, is ill-equipped to integrate
public concerns  with  those of  management.  This
weakness is compounded by its application to energy—
a topic of recent crisis proportions that has traditionally
been controlled by scientists and engineers. The Section
11  background documents and the remarks of other
speakers have addressed the shortcomings of the DOE
management process in some detail. I shall not belabor
the point.
    Besides the inherent limitations of  the PPMS, I
believe that the flaws in  the DOE approach stem from a
fundamental misunderstanding of the role of the public
in the decisionmaking process. This misunderstanding
may have to do with the notion that public involvement
is a legal, possibly moral, requirement which must inevit-
ably yield to the sacred cows of  profit, technology,
and expediency.
    Like an Environmental Impact Statement, public
participation is done to diffuse challenges to manage-
ment, rather than  to improve the results of the decision-
making process. In other words, it is seen as a nuisance
or,  at best, a nice to have but not very practical item.
    Another view is that public participation is an inte-
gral component of a decisionmaking process. The three
inputs in Figure 2  define the limits of  the decision-
maker's ability to  understand and maintain the system
equilibrium.  As can be seen, the decisionmaker has little
or no interactive relations with the watchdogs. This is
because people watching the process normally have
their  minds  made up ahead of time, and they have
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Hearing of October 5, 1979
shifted their attention to promoting their own points of
view in a competitive setting.
    It is essential to comprehend this point  if public
involvement is to be useful in the decisionmaking process.
    A successful decisionmaking process is one which
addresses and  reconciles the full  range of values in
society. Too often, a shotgun approach is used to solicit
public views, however.  Public participation  activities
take the form of formal hearings that are too late or too
structured to be  useful. The audience is not defined
ahead of time to insure that the spectrum of values will
be represented.
    The result is reactive, rather than proactive involve-
ment.  The watchdogs are indeed watching, though. If
they cannot find something they can relate to in the
decisionmaking process, they will carry their causes to
the political arena and perhaps the budget. This hap-
pened in California  last  year with the  overwhelming
passage of  the Proposition 13 tax  revolt initiative.
Decisionmakers weren't listening, so the voters pulled
the rug out from under the traditional pillar of local
government—property taxes. Local  government in
California is muddling through after its slap in the face,
but! wonder if national energy needs can risk the same
kind of reaction and  subsequent slow readjustment.
    Short of overtly imposing an energy project on a
State  or area that does not want it, it may be very dif-
ficult  to deliver  an  energy  system  that  has  been
developed using the DOE approach. Nuclear power's
failure to win widespread public  support  is  a good
example. There is something very wrong with a proposed
solution to  the Nation's  energy  dilemma if it makes
growing numbers of people march  in protest of it,
assault power plants, and even go to jail to  stop it.
    The nonnuclear  alternatives cannot afford the lux-
ury of casual indifference to public attitudes  that has
characterized nuclear power development.  Early  and
continuous involvement of the range  of public values
is essential  if the softer  alternatives are to gain  and
hold support.
Cooperation with others. It is customary for the Federal
government to implement a program and expect a State
or local government to comply with it after it has been
developed. The PPMS is consistent with this tradition,
but  in so doing it isolates the  vital contributions of these
other  levels of government.  It would be better for the
Federal level to first consult State and local policies
and needs.  Without wishing to open  a debate about
autonomy or decentralized responsibility, I submit that
DOE can gain knowledge, credibility,  and support by
establishing better relations. The other  levels can make
positive contributions that can simplify and expedite
program progress.
    At the  State level,  for example, California has
made progress in advancing geothermal development
and in conserving or recovering energy through waste
management. I participate in monthly policy and program
development meetings of a committee of California's State
agencies interested in geothermal energy resources.
     My impression  of DOE's relationship  with  that
interagency body is that while DOE staff has been cor-
dial and helpful, the most that has come out of DOE's
participation has been an awareness of DOE's complex
organizational  structure,  its  apparently  continuous
reorganizations,  and the resulting  confusion for State
program funding. Instead, DOE and the State agencies
ought to be sharing information about how to accelerate
environmentally sound geothermal energy development.
     As for waste management, I think it is significant
that  the West  Coast  was  effectively excluded  from
access to the Section  11 process  when it addressed
the issue.
     Having worked in waste management in Washing-
ton,  Oregon, and California, 1 can assure you that DOE
can learn a lot from the experiences of those States in
achieving energy savings through recycling and waste
reduction, or in seeking to derive energy from wastes.
     California's program is particularly significant.  The
State Solid Waste Management Board supports a $6
million  annual grant program  for local level resource
recovery and recycling activities. Within this, the Board
is funding certain preconstruction activities for resource
recovery facilities. Through the President's Urban Policy
Program,   DOE and EPA are  promoting  a similar
facilities development  program in California.  Unfor-
tunately, the two programs were not well-coordinated
from the start. Most of the bugs have been worked out
by now,  but  the initial conflicts might  have been
alleviated had the Federal government begun by seeking
the advice  of California.
    One further note, California is actively pursuing the
recovery  of energy  from  rural agricultural   and
silvicultural wastes. There is no linkage between DOE's
agricultural and urban waste activities, because separate
program offices are involved.
    This has—at least in California's case—led to fund-
ing difficulties for our rural waste to energy projects. A
total waste-to-energy package  should consider both
rural and urban sources and needs.
    The Section 11  background document addressed
the need to involve State and local  entities, stating that
involvement should begin when initial siting decisions
are made.  My feeling is that DOE should get together
with  the other governments well before that stage, the
better to make sure of State and local initiatives. Return-
ing to  my  remarks about the decisionmaking process
and public participation, there  should be an  early  and
continuous cooperative exchange  between DOE  and
the other levels.  This could be achieved by systematically
involving the State and local governments as publics
that, like the other publics, have information  vital to
developing  the  policy  equilibrium  so  essential to
program success.
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                                                                                Statement of Mr. Seaman
    Environmental concerns. Finally,  with respect to
the attention to environmental factors, my impression is
that the PPMS is not sensitive to the range of environ-
mental concerns. I base this impression on the fact that
waste management continues to be left out.
    At the regional hearing in San Francisco the issue
was identified as a concern, but it was not noted in the
Section 11 background document. Rather than dwell
on this point, I shall just say that if wastes are not ade-
quately addressed, then there is a chance that other envi-
ronmental factors are having difficulty gaining attention.
    Again, energy decisionmakers should be cognizant
of the whole biophysical subsystem and its interactions
with the other components and subsystems of a com-
prehensive energy management system.
    In summary, I have  stated that DOE's decision-
making process is deficient so long as the headstrong
Program and Project Management System is the means
for achieving results. There appear to be few systematic
ways to understand the complex relationships between
the environment and society's use of energy.  There are
too many opportunities within the PPMS to ignore or
belittle public, State, and local values.
    The underlying problem is that there seems to have
been a failure to recognize that energy development is a
matter of policy as well as of project dimensions.
    Thank you for your attention. I would be glad to
answer any questions you may have.
    MR. ONDICH: Thank you.
    Are there any questions from the panel?
    DR. KINSEL: Yes,  I'd like to explore a  couple
things—you have some very interesting insights, 1 think,
in your statement, and I agree with you that from  our
own  experience,  dealing with policymakers  at  the
national level, many of them do see public participation
as a nuisance or something which they have to do, rather
than as a tool to  help them perhaps achieve the best
policy decisions.
    I think, though,  that  it might be important to  dif-
ferentiate between public participation as an  insurance
that  ideas  which might not otherwise come  to  the
policymaker's attention are brought to that individual's
attention, as opposed to putting on the policymaker the
burden  of  deciding whether,  say,  occupation  at
Seabrook signals a  greater sense  of opposition  to
nuclear power than public polls which show that  the
majority of the public still favors  nuclear power as a
source, so long as it's done in a safe manner.
    It seems to me that there may be a problem with
putting that type of burden on  a  policymaker, and it
may be—if I understood your statement correctly—may
be that that type of a decision is more properly placed
with  elected representatives. There may be a break-
down there in communication between those people
who  institutionally should be reflecting the conflict, if
there is such, between points of view on a controversial
issue, as opposed to the  policymaker  who should be
executing  the  decisions of,  say,  a legislative body,
something more representative of the people.
    I'd just be curious on your comments on that.
    MR. SEAMAN: If you refer to the diagram of the
interactive decisionmaking process, you can see that 1
feel that policy is something that is probably better left to
the elected decisionmakers. It is the role of an agency
such as DOE to insure that the equilibrium is maintained.
If there  are signs that the equilibrium is not going to
be maintained, that is, if they hear the drums beating, or
something, they should inform the elected officials.
    The Section 11 process is a good example of that,
because a report will be made to Congress. Everybody
has come in here and complained for three days in  a
row that they feel isolated from what's been going on;
the report is the  way of requesting a  redefinition of
the program.
    Of course, the ultimate way to deal with the policy-
makers is to vote them out of office, which is often done.
    DR. KINSEL: If I could follow up on that—I think
that, with that type of general  approach, part of the
problem eliciting the response of a number of witnesses
here today on, for example, the synfuels program is that
people in policymaking roles are  taking upon them-
selves to make decisions that really are not  in their
province—that for whatever reason the decisions points
have been skewed so that Congress, which  should be
making these kinds of evaluations, is not doing it, and is
too often leaving it to  people who  are making them
based on an insufficient feel for what the concerns of the
public are.
    So  we have  a very vicious circle here  where we
have  people being  forced to fill  a  role  that they
shouldn't, under our system of government, perhaps,
be filling. At the same time, they don't have the benefit
or they're not availing themselves of the public input
which would allow them, if they are going to be making
that type of decision, to make the best decision.
    MR. SEAMAN: Well, I think that's why we have
three branches of government and ballot boxes, to deal
with that very thing. If Congress is derelict, then the
executive branch can point the finger, and that happens
quite frequently. If the legislative branch and executive
branch are too busy pointing the finger at each other,
then sooner or later someone will sue and the courts will
get involved. These things do have  a way of working
themselves out.
    Unfortunately, the process is extremely tedious,
and very expensive, but it does seem to have met the
test of time.
    MR. ONDICH: I'd just like to second Dr.  Kinsel's
remark in that I think you've provided some very useful
and thoughtful remarks.
    I would like to now ask if there are any comments
from the floor.
    (No response.)
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Hearing of October 5, 1979
    MR. ONDICH: Again, I'd like to thank both of
you gentlemen. This concludes the hearings.
    I'd like to mention what Dr.  Reznek did the first
day, that the Hearing record will be open for.two weeks
following the conclusion of this Hearing, and any com-
ments, or  if people would  like  to add, you can send
them in to the Environmental Protection Agency in care
of the Section 11 coordinator.
    {Whereupon, at  4:48 p.m. the  hearing  was
adjourned.)
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Addendum

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Written Statement Submitted by
Kirk Cunningham, Chairman,
Conservation Committee
Sierra Club, Rocky Mountain Chapter
Denver, Colorado
    I would like to submit the following remarks for the
Hearing record of the October 3-5 National Hearing on
Section  11 of the Nonnuclear Energy Research and
Development Act of 1974. They are made on behalf of
the Rocky Mountain Chapter of the Sierra  Club and
arise from my participation  at the Denver Section  11
workshops  this summer, from my understanding of
relevant Sierra  Club policy, and  from  my personal
experience as a layman who has tried to comprehend
and respond to numerous Federal management planning
and rulemaking documents.
    There are no doubt ways in  which  DOE RD&D
management could be improved to better consider envi-
ronmental issues and public participation, but I believe
that  it could bejimproved in the  following  important
ways:
     (1)  Criteria  to  determine which  projects  receive
"major  management attention."  In addition  to the
customary factors such as cost and immediate environ-
mental impacts, DOE should also  consider,  as a crite-
rion, how much long-term irreversible damage may be
Intrinsic  to the technology. It is my experience that too
many impact discussions in EISs tend to focus on miti-
gation by technical means during the life of the project,
but fail to address the consequences of eventual shut-
down and abandonment. In Colorado, a good example
of this problem is oil shale technology. I understand that
one such project came in under the cost threshold and
so was not considered a "major project." Yet all types of
oil shale production have intrinsic, probably insoluble,
long term impacts on ground and surface water quality
which will not be apparent until after mine closure. In
contrast, a power plant emits pollution only while in
operation  (neglecting the coal  mining  problems, of
course), and even very large and costly solar or conser-
vation projects will have negligible impacts during and
after operation. Therefore,  technologies  like oil shale
deserve close and continuous environmental scrutiny
even for projects below the  cost threshhold.
     (2)  Evaluation criteria used at decision points. The
same emphases on cost and long term impacts as listed
above should be used in decisionmaking,  in addition to
the usual environmental impacts. But direct and indirect
impacts of the advent of heavy industry into presently
sparsely populated areas should also be  considered.  I
can  use oil shale again as an example: increments in
Colorado River salinity 50-100 years hence regardless
of present mitigation attempts,  and  decrements in
wildlife  habitat  and numbers  due  to  residential
developments and increased hunting pressure. Oil shale
and other energy operations are projected to increase
northwest Colorado's populations by a factor of three.
Social and economic impacts on present rural towns are
too obvious to mention.
    (3) Public participation processes. It may  well be
that public participation should occur prior to the E1S in
the planning scheme; however, I am not certain that
new structures or bodies need to be created. The follow-
ing suggestions are essential: (a) The interested public
must be informed actively, not passively, of the progress
of a major project through the decision points.  For ex-
ample,  a  short,  clearly-written blurb or  press release
might be sent around to an appropriate mailing list.
(b) EDPs, PEPs,  and ERDs must be more easily avail-
able to the interested public, and must be written in a
clear way  with  the  issues outlined so  that we can
understand them. (I assume that this would also help
DOE  personnel  understand their  own  documents!)
Many people now complain that such documents have
not been easily available. If they were readily available,
and if we knew  of their existence, then we  could use
them to prepare ourselves for EIS input later  on and
perhaps thus obviate the need for much more public
input before the EIS. As a volunteer environmentalist, I
have limited time to devote to public input exercises, but
I  would like to have  more time to prepare myself for
those that do occur—90-day comment periods for com-
plex topics when approached cold are simply inade-
quate,  (c) Hearings and workshops to facilitate public
input are useful,  but must get to the point and should
not be held during the day. For example, the Section 11
workshop in Denver could probably have been com-
pressed into one-half day. (d) Finally, those  people or
local governments  whose interests are most immedi-
ately and severely affected by a proposed project must
be convinced that the project will not be jammed down
their throats no matter what, i.e., that the alternative of
not building the project at all will be given serious con-
sideration by DOE if major problems arise. Other inter-
ested people must also be convinced that their input at
the  EIS  level  is  given serious  consideration  by
DOE—otherwise there will be  strident demands  for
more rigidly defined public input mechanisms earlier on
(i.e., more bureaucracy!).
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    In summary, impacts analyses and the criteria for
new energy projects must be conceptually and tem-
porally broader. Public input must be made easy for the
public, and mustv have  impact on  decisionmaking.
Thanks for your consideration of these remarks.

Written Statement Submitted by
A.H. Rosenfeld, Professor of Physics,
University of California, Berkeley, and
Principal Investigator, Energy Efficient
 Buildings Program, LBL, and
Paul P. Craig, Professor of Applied Science,
University of California, Davis.
     We  are submitting this  note to emphasize a few
well-known problems.
    First we would like to point out that many of DOE's
failings in managing a basic research program  have
been succinctly and convincingly described in the 1978
OSTP Working Group report known within the Depart-
ment as the Buchsbaum Report. At high levels within
DOE the Buchsbaum report is said to have been extremely
influential,  but we,  at the receiving  end of research
budgets and controls must say ruefully that we have yet
to see much effect.
    The Buchsbaum Report seems so convincing to us,
that we are starting this commentary by reproducing the
Executive Summary, their comments on the dangers of
setting rigid timetables and overmanaging, and  the
importance of stability of funding and the support of
graduate students.

The Buchsbaum Report
Executive Summary
     There is a lack of balance  in the DOE programs
between research on the  one hand and development,
engineering, and demonstration programs on the other.
This stems in large measure from a preoccupation with
certain near-term programs and neglect of longer term
fundamental work that is vital to the DOE mission. The
dearth of research is especially evident in the solar and
fossil fuel programs.
     A strong component of basic research within each
technical program is essential if  the DOE is to fulfill its
mission. Each Assistant Secretary should include a basic
research  category within his budget and should acquire
staff with expertise in the management of basic research.
     The management and  conduct of basic research
within the technical areas should be under the guidance
and budgetary control  of  a Research  Coordinating
Committee (RCC) consisting of the Technical Assistant
Secretaries with the Director  of OER as chairman. The
functions of the RCC should  be assigned to the existing
R&D Coordinating Council.
     The Office of Energy Research must be expert in
the fields of research under its coordination. The OER
should conduct research in the sciences, technologies
and  other  areas  (such as environment, health  and
policy studies) which apply broadly to many .programs.
    The overall basic research program of the DOE
should be of a  size and scope sufficient to assure the
health  of disciplines of importance  to the long term
development of energy technologies. Stability of fund-
ing is a  key element  in the development and main-
tenance of  a research program of the highest quality.
Excellence  of research should be a  principal concern
when judgments are made on the support of specific
proposals.
    The existing research program is not well balanced
among the  DOE laboratories, industry and universities.
The budget for basic energy research in the universities
should be  increased.  If  necessary,  funds should be
diverted for this purpose from the development activities
or even from other parts of the basic research program.
    Several DOE Laboratories with  applied roles and
missions require a redefinition of those missions in order
to maintain their effectiveness. Within a  well-defined
mission,  conduct of basic  research is vital to the health
and vitality of a laboratory. Laboratory  management
should have flexibility in the conduct of basic research.
    Because of the dominant importance of fossil fuels,
the DOE should establish  a National Program for Fossil
Fuels Research. Effective  implementation of this pro-
gram may require the creation of a new organizational
structure to provide a focus and  a mechanism for the
conduct of needed research.
    A key element in the development and mainte-nance
of a basic research program of the highest quality is the
stability of funding. High quality basic research is a long
term endeavor and sharp fluctuations in support  level
are particularly damaging. Redirection  of  resources
should, therefore,  be  accomplished  at a rate that will
enhance the overall effort, but not so rapidly that it
unduly impairs  the work of outstanding performers.
    The issue of stable funding is particularly critical for
universities. Since  they must make long term commit-
ments to significant research programs and to graduate
students, who typically spend three to six years on spon-
sored research leading to  a PhD degree, research proj-
ects at universities should be funded for at least two or
three years (as DOE  is authorized by law to do) or,
preferably,  be  supported by step-funding. Under a
system of step-funding, a research project is allocated
support for several years  ahead but  in declining steps.
Annual reviews then determine the merit of the project
and,  if the assessment is favorable, funds are  aug-
mented to maintain the long-term financial assurance
initially  established.  The  stability  that  this  provides
promotes effective research.
     A particular problem of university-based research
programs is that of graduate student support. University
research programs play a  major role in graduate educa-
tion. We perceive that the support of first-year graduate
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students who have not yet chosen their research topics
has become a problem in some universities. At present
the DOE Trainee Program is trivially small. An expanded
Trainee Program would increase the effectiveness of uni-
versity participation in DOE basic research programs.
    We are now going to give three examples of how
long it takes {a  year or so of tedious urging) to obtain
funding for long-range or innovative projects.
    The  first example  concerns the "Watt-Watchers
Tables" (LBL Report 5926). We did this work in 1976
and 1977, and came up with some remarkable conclu-
sions on the size and cost-effectiveness of the potential
for more efficient use of energy in California. It became
clear to us that we should expand this work to the entire
U.S.,  and produce  "supply curves  of conserved
energy."  We  have  since received funds  from  the
California Policy Seminar for extending  the California
work, and have received urgent requests from  DOE to
generalize the results, but still no stable funding. We'll
return to this  after we mention cases two and three.
    Case two concerns research on radon in homes —
monitoring it, uncovering its pathways into homes, and
the effectiveness of air-to-air heat exchangers in flushing
it  out. We first became convinced that this  was  an
important problem in the early spring of 1978, and have
been  working on the problem "by moonlight" for  18
months. Only now are we beginning to receive funding
... from DOE, and nothing yet from EPA. We are send-
ing you a copy of LBL 7809 (Rev  Aug. '79),  a paper
whose first draft  was actually written in the spring of 1978.
    Case three is a report entitled "Building Energy Use
Compilation and  Analysis (BECA) -  An International
Comparison  and  Critical Review" authored by   12
distinguished  experts in  the field. It has been clear for
some time that the U.S.  and the world need a Building
Energy Use  Data Center which would issue regular
critical reviews. But this is another long-range project
which is so far  unfunded, and operating on volunteer
labor. We are sending you a draft of its first report: LBL
8912, which will soon be submitted to the international
journal, Energy and Building.
    Our general comment on these three cases is that
DOE's Office of Conservation and Solar Applications
has been very good about funding us to study building
envelopes,  ventilation and computer modelling, provided
that we satisfy  many short term deliverables.  We  are
proud of this program; its reputation is excellent, and
we have produced books, special issues of journals,
hundreds of papers in refereed journals,  and hundreds
of reports. We are grateful to DOE for funding us, and
the results have been in the national interest of learning
how to use  energy efficiently. But we  are no longer
unknown  quantities, and we feel that  we should be
encouraged to put some fraction of our effort, perhaps
one quarter, into long-range research, with no deliver-
able except high-quality publications in archival journals
and review articles.
    In particular, in most of the scientific fields funded
by DOE or NSF, it is understood that up to 5 percent of
the  research funds must be set aside for data centers
which compile results and issue regular critical reviews,
tables,  and references.  These centers are funded on a
continuing basis. The best example is the National Stan-
dard Data Reference System, ably administered by the
National Bureau of Standards, in collaboration  with
DOE and other concerned agencies. Both cases one
and three should be fundable under the analog of such
a program, but no program exists.
    If  a data center is continuously funded, or at least
step-funded,  then  it  can produce important timely
reports as it foresees the need. Back to example one. It
was clear last summer,  when OPEC suddenly doubled
oil prices,  that there was going to be a sudden increase
in retrofitting  existing  homes (to  make  them more
energy-efficient) particularly New England, with heating
oil prices going through $l/gallon this coming winter.
    As previously  mentioned, we were already in the
process of producing the two figures for California.
    Figure one is called a "decay curve." It shows what
we  know about  reducing energy  use as we invest in
improvements in various parts of the home  — space
heating,  water  heating,  cooling,  appliances,  and
lighting. We have found that it is convincing to the
homeowner, although it does not tell him exactly what
to do first, or his return on investment.
    Figure two is the same data, replorted as a "supply
curve" of the cost of conserved energy vs. annual sav-
ings.   It  is   more  satisfactory  to economists  and
policymakers. It shows clearly that more of a homes
resource energy can be saved for a total investment of
about  $1500, and that the cost of conserved energy for
these retrofits is less than the cost  of new supply.
    We point out again that we are still having difficulty
finding the right combination of offices within DOE to
support this sort of information system for the U.S. as
a whole.
    We thank you for  your time and attention.
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