91- 059 0 -89-8 (Pt. 12) 15630 EXTENSIONS OF REMARKS June 11, 1987 gen on this wonderful opportunity to continue and private schools. And high school attend to assure that residential rates will not in his contributions to the education of the deaf. ance was frequently poor, Adams said. crease more than 10 percent as a result of But now, Adams said, a more structured school day and a continually updated and acid rain control technologies. Most residential MILTON HIGH PICKED AS ONE enriched curriculum have helped reduce ratepayers will face less than a 1 percent rate OF NATION'S BEST transfer to private schools from one-third to increase. 25 percent. Attendance "has improved dra I urge my colleagues to signal their support matically," too, he said. for control of acid rain by cosponsoring this HON. BRIAN J. DONNELLY Milton High School is one of 271 schools vital legislation. OF MASSACHUSETTS in 46 states to receive the Excellence in Edu IN THE HOUSE OF REPRESENTATIVES cation award. The two other Massachusetts Thursday, June 11, 1987 schools honored: the private Northfield ACID DEPOSITION CONTROL Mount Hermon School in Northfield and ACT OF 1987 Mr. DONNELLY. Mr. Speaker, I wish to the public Wayland High School. share with my colleagues an article from the The high school is the third Milton school May 28, 1987 Patriot Ledger reporting on the to receive a federal award within two years. HON. GERRY SIKORSKI selection of Milton High School as one of the Last year, the Tucker Elementary School OF MINNESOTA was named one of 270 outstanding public IN THE HOUSE OF REPRESENTATIVES best in the Nation. It is the third school in and private schools in the country. In 1985, Milton to receive a Federal award in the last 2 the Pierce Middle School was named one of Thursday, June 11, 1987 years. the best secondary schools in the country by Mr. SIKORSKI. Mr. Speaker, John F. Ken The Excellence in Education award is a the U.S. Education Department. nedy said, "We must use time as a tool, not a well-deserved recognition of the hard work Schools nominated for this year's award couch. We must carve our own destiny." and endless dedication of the school adminis nationwide were judged by a panel of 71 re Today I am introducing legislation to carve tration, faculty, and students of Milton High viewers-two-thirds of them from outside our destiny by controlling the threat of acid School. The Milton High School parents de the field of education-on a wide range of attributes, from test scores to dropout rates. rain. With this bill, we can forge a cleaner en serve special recognition for their contribution They checked attendance rates for both stu vironment, a sounder economy, and a health in promoting a positive student attitude toward dents and faculty and the school's civil ier world for ourselves and our children. the school. rights record. SILVIO CONTE, TOM TAUKE, HENRY I wish to add my name to the list of those Schools got points for being drug-free. WAXMAN, and others join me in sponsoring who have joined in congratulating Milton They also were judged on how well they public schools and all the residents of the taught citizenship and the U.S. Constitution this new bill, H.R. 2666, which is nearly identi town of Milton on this proud occasion. in the bicentennial year of its signing. cal to last year's acid rain legislation, H.R. The winning school principals and super 4567. With over 170 cosponsors from every MILTON HIGH PICKED AS ONE OF NATION'S intendents will be invited to Washington at region of the United States, H.R. 4567 was BEST their own expense this fall for a ceremony State-developed strategies are required children and their families as they passed make the organization available to all Farm to reduce sulfur and nitrogen oxide emis through the school doors. Sandy has that Credit Stockholders, rather than only Fed sions. A two phase program is mandated quality of making school an enjoyable experi eral Land Bank members. I feel compelled giving States until 1993 to reduce sulfur ence. to tell you that our organization in 1980 ·e.nissions by five million tons from electric Sandy always enjoyed teaching history, vis sent 4 members of its executive committee, utilities, and until 1997 to reduce sulfur iting classes from time to time. His excitement of which I was one, to discuss with then emissions by an additional five million tons and enthusiasm for the subject is so conta Governor of the Farm Credit Administra from major stationary sources. States are gious that the students truly looked forward to tion, Donald Wilkinson, what we thought given until 1997 to reduce nitrogen oxide were severe problems developing in the emissions by about two million tons from his classes. This tireless enthusiasm and excitement Farm Credit System. At that time, we told electric utilities and industrial boilers. Each him collateral values were being set too state would have the flexibility to pursue extend to all he does. For the past 20 years, high and that nothing was being done to any control strategy within the source cate he has supervised over 150 sixth-grade stu pay the extra cost of high priced bonds. Our gory to achieve the required reductions. dents on a 3-day trip to the Nation's Capital. ideas were totally rejected. Perhaps they Failure of a state to submit an approvable Sandy inspires them with his love of country, shouldn't have been. By examining the suc plan would result in congressionally im the pride he has in his profession, and a show posed emission limitations. Western smelt cesses and failures of past policies, we can ers would have to be in compliance with the of sincere concern that they learn all he has develop a better future. Clean Air Act by 1988. to offer. While never losing sight of the "3 The Congress is now debating whether to <2> Congressional midcourse correction is A's", Sandy looks to the future unafraid of in use public funds to save the Farm Credit possible before phase II. EPA is required to stituting new programs to improve the quality System from possible collapse. If the plans submit a study to Congress in 1993 to deter serve the best interest of the national econ of education. omy, then we think they are necessary. mine the reduction in acid rain achieved Sandy is a veteran of the Korean conflict, under phase I and the feasibility of meeting However, the request made by the System 1950-53, serving as a quartermaster aboard seems to indicate to stockholders that most phase II requirements. If Congress fails to the U.S.S. Roanoke, U.S.S. Missouri, and the act to adjust the program by January 1994, of the funds would be directed toward the Phase II requirements go into effect. U.S.S. Raymond. His love for country shows, System's bureaucratic form. In other words, (3) A Federal subsidy program to keep resi as he tells the children stories about this it would open the vault and let them con dential rates from increasing more than period. A loving husband and father, he still duct business as usual. The System was 10%. A Governor can receive Federal assist finds time to become involved in community built like a pyramid and now in the last ance if residential rates exceed 10% as a projects. decade that pyramid has been inverted. We result of the sulfur dioxide control program. His love, his concern, and his respect for all are opposed to any assistance that would To be eligible for the subsidy, the Governor allow Farm Credit System to conduct busi the children are deep roots that we can all ness-as-usual. The Farm Credit Service must take steps to substantially equalize build on. I take great pride in sharing his ac and levelize residential rate hikes attributa Center or Association is the most important ble to the program. A Federal trust fund is complishments with my colleagues. entity in the Farm Credit System. Manage created by levying fee on electricity generat ment must be able to directly manage its own loan portfolio and also be held respon ed not to exceed lf2 mill per Kwh (about 25 REVIVING THE FARM CREDIT to 50 cents per month on a typical electric sible for that portfolio. bill). The fund would be available to pay for SYSTEM There are certain fundamental principles program control costs to maintain residen which need to be followed if there is going tial electric rates below 10%. HON. ARLAN STANGELAND to be financial assistance to the Farm <4> Allowance/or Innovative Technologies. OF MINNESOTA System. These principles are: A Federal program can be established at the IN THE HOUSE OF REPRESENTATIVES 1. Farm Credit Service Centers or Associa option of interested states to promote the tions should be the primary lenders. Agency use of innovative technologies as control Thursday, June 11, 1987 Centers with centralized capital stimulates methods for sulfur dioxide and nitrogen Mr. STANGELAND. Mr. Speaker, I rise unresponsive management. oxides. today for the purpose of focusing on the Farm 2. There should be a central entity which would be responsible for the orderly sale of <5> Tougher standards for new power Credit System. There has been much discus plants. The new source performance stand bonds. The central entity should be respon ards would be tightened for nitrogen oxide sion in recent weeks about what needs to be sible for examinations of service centers or emissions from new power plants. This done to revive this System. Before any associations with the authority to take ap tightening would reduce nitrogen oxide changes are made, we must thoughtfully and propriate action if they are not operated ac emissions by about 1 million tons by 1997. carefully examine the successes and failures cording to law. 15632 EXTENSIONS OF REMARKS June 11, 1987 The Farm Credit System has lost sight of and the inspirational choir and acts as adviser tee made a difference. The people of our its fundamental goal of delivering dependa for the young adult choir. Nation were well served by his talent and de ble credit to farmers and ranchers at the Married in 1939, Mr. Glover has two sons, votion. lowest possible cost. The stockholders of the Farm Credit Marvin and Kenneth; a daughter, Melissa; and System have experienced tremendous four grandchildren. He was educated and has changes over the last decade. The unbeliev resided in Passaic for most of his life, serving MEDICARE HMO/CMP able increases in the cost of operation cou God and his community. IMPROVEMENT ACT OF 1987 pled with the loss of markets has created an Mr. Speaker, it is individuals such as Arthur impossible situation. There are many stock Glover which truly represent what is best in HON. DAN MICA holders paying their bills on time. They are public service. Helping the less fortunate to OF FLORIDA also paying a premium on the interest rate fulfill a basic need and performing that duty in because of the inflation of the late 1970's IN THE HOUSE OF REPRESENTATIVES and the decisions that were made during a kind and admirable fashion is a difficult task, that time. and yet it is one which Mr. Glover has done Thursday, June 11, 1987 The National Association of Farm Credit for 34 years. Mr. Glover attributes his success Mr. MICA. Mr. Speaker, today I am pleased Stockholders is willing to work with Con and perserverance to cooperation and team to introduce the Medicare Health Maintenance gress to insure that assistance to the Farm work. Important words which are often Organization Quality Improvement Act, a col Credit System be directed toward improving spoken, then neglected in practice. It is obvi lection of reforms which was partially enacted the delivery of competitive funds, rather ous that Arthur Glover did not neglect them, than enhancing the bureaucratic system. in 1986. and both he and all who serve the public in Today I will testify before an Aging Commit terest can certainly be proud of what he has tee hearing which was convened to review CONGRESSIONAL SALUTE TO achieved. Federal HMO operations. This hearing was ARTHUR GLOVER, 34 YEARS Mr. Speaker, this man is not only an inspira also convened in response to a dire situation OF SERVICE TO HOUSING AU tion to those serving the needs of the people in south Florida, wherein the Federal Medicare THORITY OF THE CITY OF but indeed for the people themselves. He has contract of International Medical Centers, one PASSAIC, NJ worked his way up the ladder in the strongest of the Nation's largest HMO's, was terminated tradition of hard work and honest effort which by the Health Care Financing Administration. HON. ROBERT A. ROE has allowed so many of our citizens to im IMC served 130,000 Medicare beneficiaries at prove their lives. Doing this, as Mr. Glover has the time of the contract termination. Currently, OF NEW JERSEY done, in the service of his fellow man serves IMC is in receivership with the office of Flor IN THE HOUSE OF REPRESENTATIVES to emphasize the importance of his contribu ida's Insurance Commissioner. The president Thursday, June 11, 1987 tion to society. I am sure, Mr. Speaker, that of IMC has been criminally indicted. my colleagues in Congress join me honoring I am sure that this is not a situation which Mr. ROE. Mr. Speaker, today I rise to pay this fine individual. tribute to a man who has spent his life aiding we would like to have repeated in the future. others in the pursuit of one of the most funda The provisions of this bill would enhance Fed mental necessities of life, clean adequate THE RETIREMENT OF MR. eral oversight of HMO's and specifically ad shelter. Mr. Arthur Glover has spent the past JAMES CREGAN dress the financial solvency of these organiza 34 years in the service of the housing author tions. It would require the Federal Govern ity of the city of Passaic, NJ, and on June 16 HON. WILLIAM D. FORD ment to make a greater effort to monitor the he will be honored for his work by his col fiscal health of an HMO's affiliates; it would OF MICHIGAN make it illegal for health care service provid leagues at a retirement reception. Mr. Speak IN THE HOUSE OF REPRESENTATIVES er, I know you and our fellow Members of ers to dun HMO members for services; it Congress will want to join me in extending our Thursday, June 11, 1987 would require the Secretary of Health and best wishes on an outstanding job well done. Mr. FORD of Michigan. Mr. Speaker, the Human Services to study the quality of care Arthur Glover has performed in an exemplary Committee on Post Office and Civil Service, provided to HMO members as compared to fashion and we applaud his endeavors in the which I have the honor of chairing, has lost the kind of care offered by other health care vanguard of service to his community. one of its most valuable staff members. provider structures. Mr. Glover is truly an example of the Ameri I refer to Mr. James Cregan, who for the I have long been an advocate of the HMO can work ethic. Born in Cordele, GA, on past several years has been the committee's concept of health care, and I would encour March 20, 1918, he migrated to Passaic in deputy general counsel specializing in postal age efforts to increase the enrollment of Medi December 1929 and began work for the hous matters. Mr. Cregan has entered the private care beneficiaries in HMO's. However, we ing authority on December 15, 1953. From his practice of law in Washington with David must make strenuous efforts to safeguard not start as a building maintenance worker, Mr. Minton, another former lawyer with the com only the significant Federal monetary invest Glover rose through the ranks as a grounds mittee esteemed by his colleagues. ment in these organizations, but, most impor worker; foreman of the building maintenance Mr. Speaker, to say that Mr. Cregan will be tantly, we must be vigilant in our oversight of workers; and supervisor of the grounds, equip missed is an understatement. I seriously doubt the kind of care HMO's provide our Nation's ment, and maintenance repairmen. that there is another lawyer in this country seniors. On November 9, 1969, the PHA Board of who knows any more about postal law than Commissioners, then chaired by Maurice J. Mr. Cregan. Moreover, Mr. Cregan has proven A TRIBUTE TO DR. PAUL Miller and the executive director of the PHA himself a shrewed and capable negotiator. VOCHKO Edward Rabb, elevated Mr. Glover to the post I certainly do not envy the adversaries he of assistant executive director, a position he will encounter in the private practice of law. held for nearly 18 years. He currently holds They do indeed have their work cut out for HON. JOE KOLTER the title of public housing manager and was them. OF PENNSYLVANIA recognized with 25 year and 30 year service Mr. Cregan is another poignant example of IN THE HOUSE OF REPRESENTATIVES awards. just how difficult it is to keep our very best Mr. Glover is active in his community not people in Government. For many years, out of Thursday, June 11, 1987 only as part of his employment, but he has dedication, Mr. Cregan rejected opportunities Mr. KOL TEA. Mr. Speaker, today I rise to been and continues to be a vital part of the in the private sector with substantial sacrifice. pay tribute to a constituent of my Fourth Dis Union Baptist Church in Passaic. A member There comes a time, however, when the trict of Pennsylvania, Dr. Paul R. Vochko. for some 50 years, Mr. Glover holds the dis pressing needs of one's family must take An educator for 40 years and superintend tinct honor of being a church deacon. In addi precedence. ent of the Ambridge Area School District for tion to also serving on the church's advisory I, personally, want to thank Mr. Cregan for 20 years, Dr. Vochko of Ambridge, PA, has youth committee, he is blessed with a fine his outstanding service. There is no question contributed greatly to his community as a civic bass baritone and sings with the male chorus in my mind that his presence on the commit- leader and a humanitarian. June 11, 1987 EXTENSIONS OF REMARKS 15633 Dr. Vochko was graduated from Geneva Mr. Nardone was born on June 24, 1917, in duction Workers Union, Local 148, to repre College and did graduate and doctoral work at Boston's North End. He was married on Feb sent thousands of workers in scores of busi the University of Pittsburgh and Slippery Rock ruary 7, 1953 to former Sylvia DeCicco and nesses. State University. He attained certification in they have one son, Joseph Nardone, Jr. The Joe Nardone believed it is the function for secondary school studies, history, physical best man at their wedding, the Honorable every union to develop the philosophy indicat science, and guidance. Edward F. Zampella, is now Hudson County's ing that the interests of labor are one without He served as Senator ARLEN SPECTER'S of central judicial processing judge. distinction by race or nationality, religion, pro ficial representative for the service academies Joseph Nardone described by his son as a fession, or creed. Every individual deserves a for Beaver County, and on the board of direc self-made, self-educated man who speaks fair day's pay for a fair day's work. He has tors of the Ambridge Chamber of Commerce, very few words. Denied a formal education earned the respect of the laboring man and the Laughlin Memorial Library, the Beaver because of the depression, he had to go to County Federated Library Association, Har work to assist his mother in raising a brother the employers he has dealt with. monie Associates, and the Geneva College and sister. Doing so was quite difficult, but When learning of Joe Nardone's retirement Alumni. indeed he assisted. this year, one corporate vice president wrote, Dr. Vochko developed and administered a According to those who know Mr. Nardone, I sincerely doubt if any man has contrib licensed practical nursing school program in he always possessed a thirst for knowledge uted more to the progress of relations be the Ambridge area as well as administering a which he instilled in his son, assuring him tween a local and their corporate associates successful preschool program. He organized every educational opportunity possible. Nar than you have. I am certain too that no and administered a standard evening high done's doctrine was to avoid easy money, to man has ever left behind him a more grati school program for adults and developed a work hard every day, building and investing in fying record of loyalty and devotion to the highest ideals of union and management. community relations newsletter. solid things. Dr. Vochko was appointed to the State Joseph Nardone is described as a man While another colleague wrote, board of education for a 5-year term sched from the old school. He often did business I do remember some trying times, but uled to end in 1989. with a handshake. He would often say, to his always, the thoughts that crystallize are of His professional associations include mem business associates that formal agreement or a friend, an advisor, a worthy adversary, and bership of the National and Pennsylvania not, his handshake guaranteed what he a fair negotiator * * * Part of our growth School Board Associations. He served as a agreed to live up to. derives from the working relationship that member of the advisory board of the Universi The periods of history during which Joseph we have had with this union. We have ty of Pittsburgh Tri-State Study Council, and has lived were indeed trying ones. His year of always found that those, representt:d by Jue on the Intermediate Unit Task Force for Spe birth saw America's entry into the war against Nardone, have kept the interest of the em ployer in mind, as well as those of the mem cial Education. He served on committees for Germany, World War I on April 6, 1917, caus bers they represent. Joe's philosophy has the United Fund, the Heart Fund, Muscular ing many difficult days for families seeking to always been that without employers there Dystrophy, St. Mary's Church Committee, the survive. would be no jobs, and he must keep them Inter-Faith Clergy Advisory Committee and the After the war ended, Joe Nardone's early alive and profitable for his members to pros Greek Catholic Union. years, during the 1920's, welcomed Winnie per. I am proud to be counted as one of Dr. Vochko served in the Air Force for 2% Winkle, George White's Scandals, Babe Joe's friends. years and later became a member of numer Ruth's career, 14 years with the New York Joe Nardone is known in Hudson County as ous armed service organizations. He is also a Yankees, and the Black Sox Scandal, and a low-key, honest, hard-working respectful in Phi Delta Kappa and a Delta Pi Epsilon. with the first Miss America being crowned at Because of Dr. Vochko's outstanding com Atlantic City in 1920. dividual. Only recently has he gotten due rec munity activities, he has been awarded with In 1921, the U.S. sweat shop operators re ognition for helping thousands of working honors such as "Man of the Year in 1972" by sisted efforts by union men to organize gar people and their families when the city of the Ambridge Chamber of Commerce, and the ment workers in big city loft factories with Jersey City gave the building, which houses St. Nicholas Award in 1977, the highest honor signs that read: "If you do not come in his union headquarters, the address of One bestowed by the Archbishop of Pittsburgh Dio Sunday, do not come in Monday." Nardone Place. cese, Byzantine Catholic Rite. He has been On July 2 that year, Jack Dempsey knocked Joseph Nardone has done an excellent job honored with numerous other local, church, out George Carpentier at Boyle's 30 Acres in for his family, maintaining a beautiful resi civic and ethnic awards. Jersey City at boxing's first $1 million gate. dence in Bayonne. He has served as a role The dedicated service of Dr. Paul R. It was in 1929 when the Nardone family, model to Joseph, Jr., and has inculcated Vochko has been a valuable asset to the Am with Joseph nearing his teen years, felt the many of his own attributes and ambitions. He bridge community and I am proud to introduce impact of the stock market price crashing in heads the Top Cat Sound Recording Studio in him and his achievements to my colleagues in Wall Street. For the next several years the New York City, which has many Hollywood the full House of Representatives. Nardone family saw lean days. and Broadway entertainers as clients. No doubt in an effort to correct some I am sure we will hear a lot from Joseph JOSEPH NARDONE, LABOR wrongs that he witnessed, Joe Nardone Nardone, Jr., in the labor and business world began his love affair with organized labor. LEADER FROM BAYONNE, HON because, the apple does not fall far from the There is no question that Joe Nardone was ORED ON HIS RETIREMENT tree. motivated by the philosophy of Samuel Gom pers who led the American Federation of When this tribute to Joseph Nardone is HON. FRANK J. GUARINI Labor until his death in 1924. given to him, he will be surrounded by hun OF NEW JERSEY Gompers said, dreds of his friends at his surprise retirement IN THE HOUSE OF REPRESENTATIVES • * * to recognize that first things must dinner being held at the Casino in the Park. It Thursday, June 11, 1987 come first. The primary essential in our mis has been my pleasure to salute a man who sion has been the protection of the wage came into this world at the height of World Mr. GUARINI. Mr. Speaker, on June 18, worker, how to increase his wages, to cut War I, helped his family survive the depres 1987, a testimonial dinner marking the retire hours off the long work-day, which was kill sion, stood with America during World War II, ment of one of my constituents is being held. ing him, to improve the safety and the sani The function, which will be attended by sever tary conditions of the workshop, to free him in Korea and Vietnam conflicts, witnessed al hundred friends, coworkers, and business from the tyrannies, petty or otherwise, several recessions and contributed to many affiliates of Joseph Nardone of Bayonne, NJ, which serve to make his existence a slavery. worthwhile charitable causes while represent will be held at the Casino in the Park, Lincoln While the ranks of labor were growing it ing the working class. Park, Jersey City. was most specialized and crafts and laboring I am certain that my colleagues here in the Joseph Nardone is retiring as president and people who were organized. Joe Nardone saw House of Representatives wish to join me in chief financial officer of the labor organization a need for the little people working in small wishing Joe Nardone and his wife Sylvia, and he founded, Production Worker's Union, Local establishments to have the benefit of a pro his family good health and peace during his 148, the unit is affiliated with AFL-CIO. ductive union. His concern has led to the Pro- retirement years. 15634 EXTENSIONS OF REMARKS June 11, 1987 EXCLUDING EDUCATIONAL these areas, we have begun to treat scholar its proposal to allow oil exploration within the GRANTS AND SCHOLARSHIP ships and grants like just another payment. Arctic National Wildlife Refuge. The effect of taxing a portion of grants and I would, in particular, emphasize two lines HON. PAUL B. HENRY scholarships is to either reduce the value for from the comments: OF MICHIGAN recipients or force grantors to increase the "Although additional discussion has been IN THE HOUSE OF REPRESENTATIVES size of the grant in order to maintain the same provided in response to many of our com "buying power." Thus the National Science Thursday, June 11, 1987 ments, the majority of EPA's concerns have Foundation, recently increased the size of not been adequately addressed in the final Mr. HENRY. Mr. Speaker, I am pleased to graduate student stipends by $1,200 per year, LEIS. In several important instances, EPA's join today with my colleagues Congressman to prevent the tax law from reducing the value level of concern has been increased by the WILLIAM FORD and Congressman FRED of the fellowship. revisions to the document." GRANDY in introducing legislation to revise The change in the Tax Reform Act also U.S. ENVIRONMENTAL one aspect of the Tax Reform Act of 1986- works unfairly against many low income stu PROTECTION AGENCY, the provision by which grants and scholar dents. The following example illustrates this REGION 10, ships awarded to college and university stu problem. Seattle, WA, June 1, 1987. dents may be subject to Federal tax. Student A, who is from a low-income family Re: Arctic National Wildlife Refuge Report The Tax Reform Act provides that grants and has tuition and books paid for by private Final Legislative Environmental Impact and scholarships-which include everything Statement. scholarships, has $4,1 00 in earnings from em Hon. WILLIAM P. HoRN, from Federal Pell grants to NSF research ployment and receives a $2,000 Pell grant grants to State and privately funded scholar Assistant Secretary for Fish and Wildlife award for a total of $6,1 00 in taxable income. and Parks, U.S. Department of the Inte ships-are taxable except to the extent that This student must pay $165 in tax-15 per rior, Washington, DC. they are used by degree candidates to pay for cent of $1,100. DEAR MR. HoRN: The Environmental Pro tuition and "course related" fees, books, sup Student B, who is from a middle-income tection Agency . could be greater. data from the Central Arctic Herd in Identify potential regulatory conflicts Mitigation: The effectiveness of proposed the vicinity of Prudhoe Bay. For example, which may involve interagency coordina measures is not evaluated. Discussions the text notes that although the CAH no tion. We are concerned about potential reg about rehabilitation are incomplete. longer calves where development occurs ulatory conflicts if, for example, leasing Regulatory processes: There is no discus around Prudhoe Bay, it has nonetheless in were proposed in environmentally sensitive sion of how the new authorities requested creased in size. This is used as a basis to con areas for which the granting of other neces by the Secretary in his recommendations clude that development in the 1002 area sary permits would be inconsistent with ex would relate to existing environmental laws, should simi isting laws and policies. other than that a leasing program 'might' larly not affect the PCH. However, the text These and other concerns are discussed require compliance with NEPA, the Clean notes a variety of important differences be further in the enclosure which represents a Water Act, and the Clean Air Act. tween these two herds which include: summary of our more detailed technical Noise impacts: There is no quantitative <1) the CAH has a much lower population review comments. evaluation of noise levels which makes it density; Based upon the inadequacy of the infor difficult to reliably assess the disturbance (2) the majority of the CAH's important mation presented in the final LEIS, EPA effects on sensitive wildlife species. calving grounds have not experienced devel would normally recommend that a revised Cumulative effects: The final LEIS ac opment activities; document be prepared. The final LEIS re knowledges cumulative effects by providing <3> the CAH's calving grounds have not mains in need of corrective measures that a list of projects which might occur but does become overcrowded ; and order for it to be an adequate basis for any sion of the off-ANWR effects on distant <4> predation by wolves and brown bears Congressional action. Since Congressional inland native settlements has been provided. on the CAH has been minimized. hearings have already begun, EPA recom The impacts to the exchange network from These differences strongly suggest that mends that the Secretary of the Interior's the recommended action have not been eval the LEIS predictions, based on data for the final recommendation to Congress be modi uated. CAH, are likely to underestimate impacts to fied to better reflect the available scientific These issues remain important even from the PCH. information. a programmatic perspective. Their signifi Placing such emphasis on CAH data is not Thank you for the opportunity to review cance is increased by the Secretary's pro necessary. A large body of data on the PCH the final LEIS. If the Department of the In posed recommendation that the final LEIS (summarized in the 1002 Area Final Base terior has questions about EPA's comments, be statutorily adopted as the EIS for the line Report> has been gathered by FWS in please feel free to contact me directly or Mr. leasing program itself. We disagree that this the last few years. The Final Baseline Alvin L. Ewing, EPA's Assistant Regional document is adequate for that purpose. Spe Report contains additional PCH data that Administrator in Anchorage. We look for cifically the leasing program inferred from appear to not be adequately reflected in this ward to answering your questions and help the final LEIS might not provide the oppor final LEIS. The final LEIS conclusions are ing you prepare the final recommendation tunity to consider alternatives for individual apparently not based on all the available in to Congress. lease block deletions. Such deletions could formation. be aimed at locally reducing risk to environ Sincerely, Mitigation ROBIE G. RUSSELL, mentally sensitive tracts. A greater degree of site-specific information (e.g. a tiered The mitigation discussions throughout Regional Administrator. the final LEIS raise several concerns. The Enclosure. EIS> is necessary to evaluate such a pro gram. entire 1002 area has been designated Re EPA REVIEW COMMENTS, ARCTIC NATIONAL TECHNICAL/ SCIENTIFIC ISSUES source Category 2. However, several discus WILDLIFE REFUGE FINAL LEGISLATIVE ENVI· sions in the text make a distinction in habi RONMENTAL IMPACT STATEMENT In a variety of instances, the final LEIS tat value. The overall "2" designation is not The primary issues and concerns identi conclusions and the Secretary's Recommen supported by the information in the final fied during EPA's review of the ANWR final dations do not appear to be well substantiat LEIS. The final LEIS indicates that site-spe LEIS are outlined below. Comments are ed by the information provided in the draft cific habitat designations will be conducted broadly organized under three major head and final LEIS. during the site-specific development/pro ings: Responsiveness to Comments, Techni Definitions of impact significance duction phase. Characterization of habitat cal/Scientific Issues, and Alternatives Anal Definitions of significance of impacts are after leasing and exploration has occurred ysis. inappropriate in many cases. For example, could result in habitat being upgraded to RESPONSIVENESS TO COMMENTS impacts are not considered "major" in the Resource Category 1. The impacts may not The final LEIS has acknowledged most of final LEIS unless they exceed 30 years or be mitigatable. more duration. For many fish and wildlife Mitigation discussions in the final LEIS EPA's concerns expressed in our comments are incomplete. The final LEIS assumes on the draft document. However, an ade species, several generations could be ad quate analysis of the impacts associated versely affected within this time, leading to that mitigation measures will be both con with these issues is not apparent. Detailed severe population- and community-level im sistently implemented and completely suc analysis of the following issues, as refer pacts. cessful. No analysis or references are provid enced from our previous correspondence, re The final FEIS is inconsistent in its appli ed to support these assumptions. Rather, mains a prerequisite to rational decision cation of impact definitions. Often discus the final LEIS states that the experience at making. sions in the text describe a "moderate" Prudhoe Bay provides a basis for minimiz effect, but it is labeled in the conclusions as ing or eliminating adverse effects through Air quality: Available knowledge of Prud the careful application of mitigation meas hoe Bay development effects was not uti "minor." lized, evaluation is deferred to future analy Also, impacts are in many cases down ures tested in that area. As the Corps of En graded from the draft LEIS without any ex gineers noted in its comments on the draft ses. planation or justification. The final LEIS LEIS, industry has been reluctant to apply Water and gravel supply needs: Signifi compensatory mitigation and restoration cant shortages are acknowledged, but the has numerous examples of impact conclu final LEIS has not presented an adequate sions that are minimized in this manner. It techniques on the North Slope, except in analysis to show whether water quantity I is not clear on what basis these changes very limited experimental circumstances. were made in the preparation of the final EPA's own extensive experience with the gravel quantity are sufficient to support the major operators at Prudhoe Bay supports recommended action. The final LEIS as LEIS. As one example, modification of 12,650 acres of wetlands was evaluated in this conclusion; rehabilitation technology sumes that major adverse effects can be for the North Slope is particularly lacking. handled in a manner which will not result both the draft and final LEIS. The draft la in adverse impacts to water quality or habi beled this as a "moderate" effect, but in the Cumulative effects tat. final it was down-graded to "minor" with no Cumulative effects are not adequately Marine transportation facilities: Existing explanation. Considering the potential for evaluated in the final LEIS. The final LEIS significant impacts due to causeways around hydrologic disruption and habitat fragmen provides a list of criteria for determining Prudhoe Bay are not reflected. tation, the impact could be "major". which actions should be included in the cu Wetlands: Only a very limited evaluation Underestimation of impacts mulative effects analysis. The criteria of large-scale hydrologic impacts and habi Potential underestimation of impacts appear to be unduly restrictive and narrow tat fragmentation has been conducted. If occurs throughout the LEIS. This is par the focus of the analysis. By using these cri the hydrologic impacts are greater than the ticularly true of impacts predicted for the teria, a list of projects that constitute the brief discussions imply, the large amount of Porcupine Caribou Herd