Copyright 1999 Federal Document Clearing House, Inc.
Federal Document Clearing House Congressional Testimony
March 10, 1999
SECTION: CAPITOL HILL HEARING TESTIMONY
LENGTH: 2535 words
HEADLINE:
TESTIMONY March 10, 1999 SARAH CHASIS SENIOR ATTORNEY NATURAL RESOURCES DEFENSE
COUNCIL HOUSE RESOURCES CONSERVATION AND REINVESTMENT
BODY:
TESTIMONY OF THE NATURAL RESOURCES DEFENSE
COUNCIL on H.R.701, "THE CONSERVATION AND REINVESTMENT ACT" AND
H.R. 798, "THE RESOURCES 2000 ACT" Before the HOUSE RESOURCES COMMITTEE March
10, 1999 Presented by S arah Chasis Senior Attorney and Director of Water and
Coastal Program Natural Resources Defense Council: 40 West 20th Street New York,
NY 10011 (212) 727-4424 MY NAME IS SARAH CHASIS AND I AM A SENIOR ATTORNEY WITH
THE NATURAL RESOURCES DEFENSE COUNCIL (NRDC) AND DIRECTOR OF ITS WATER AND
COASTAL PROGRAM. I APPRECIATE THIS OPPORTUNITY TO TESTIFY TODAY BEFORE THE HOUSE
RESOURCES COMMITTEE ON H.R. 701, THE CONSERVATION AND REINVESTMENT
ACT ("CARA"), A BILL INTRODUCED BY CHAIRMAN YOUNG, AND H.R. 798, THE
RESOURCES 2000 ACT, A BILL INTRODUCED BY CONGRESSMAN GEORGE MILLER. MY TESTIMONY
ON BEHALF OF NRDC FOCUSES ON THE OUTER CONTINENTAL SHELF (OCS) IMPACT ASSISTANCE
TITLE OF H.R. 701, THE LIVING MARINE RESOURCES TITLE OF H.R. 798, AND THE OCS
REVENUES USED TO FUND ALL TITLES OF BOTH BILLS. NRDC IS A NATIONAL ENVIRONMENTAL
ORGANIZATION, WITH OVER 400,000 MEMBERS, DEDICATED TO PROTECTING NATURAL
RESOURCES AND ENSURING A SAFE AND HEALTHY ENVIRONMENT. NRDC HAS A LONG HISTORY
OF INVOLVEMENT WITH THE PROTECTION OF OCEAN AND COASTAL RESOURCES AND HAS WORKED
ON A NUMBER OF COASTAL AND OCEAN ISSUES, INCLUDING OFFSHORE OIL AND GAS
DRILLING, COASTAL ZONE MANAGEMENT AND MARINE FISH CONSERVATION. IN OUR VIEW, THE
OVERARCHING GOAL FOR THE COAST AND OCEAN TITLE OF THESE BILLS SHOULD BE
PROTECTION AND RESTORATION OF OUR NATION'S FRAGILE, BUT EXTREMELY VALUABLE
COASTAL AND MARINE RESOURCES WHICH ARE INCREASINGLY UNDER PRESSURE FROM A
VARIETY OF FORCES. IN ACHIEVING THAT GOAL, 5 PRINCIPLES SHOULD BE CLOSELY
ADHERED TO: *THE LEGISLATION SHOULD PROVIDE NO FINANCIAL BENEFIT TO STATES FROM
THE LIFTING OF CURRENT MORATORIUM OR FROM NEW LEASING OR NEW DRILLING. THIS
SHOULD APPLY TO ALL TITLES OF THE LEGISLATION, NOT JUST THE COASTAL OR OCS
IMPACT ASSISTANCE TITLE. *THE STATE OR LOCAL SHARE OF MONEY SHOULD NOT BE TIED
TO THE ACCEPTANCE OF NEW OR CLOSER LEASING OR DRILLING. *MONEY THAT GOES TO THE
STATES AND LOCAL GOVERNMENTS MUST BE SPENT ON ENVIRONMENTALLY BENEFICIAL
PROJECTS. *THERE SHOULD BE FEDERAL AGENCY OVERSIGHT OF HOW MONEY IS SPENT TO
ENSURE COMPLIANCE WITH FEDERAL ENVIRONMENTAL LAWS. *ANY OFFSETS SHOULD NOT COME
FROM EXISTING ENVIRONMENTAL PROGRAMS. THESE SAME BASIC PRINCIPLES ARE SET OUT IN
THE FEBRUARY 2,1999 LETTER TO CHAIRMAN YOUNG AND OTHER REPRESENTATIVES FROM
NINETEEN OF THE NATION'S MAJOR NATIONAL CONSERVATION ORGANIZATIONS THAT IS
ATTACHED TO OUR TESTIMONY. THIS LETTER STATES THAT: "OUR ORGANIZATIONS ARE
STRONGLY OPPOSED TO ANY FINANCIAL INCENTIVES THAT PROMOTE OFFSHORE OIL AND GAS
DEVELOPMENT," IDENTIFIES INCENTIVES INCLUDED IN EARLIER VERSIONS OF THE
LEGISLATION AND RECOMMENDS WAYS OF REMOVING THEM. H.R. 701, WHILE CONTAINING
IMPROVEMENTS OVER LAST YEAR'S BILL (H.R. 4717), STILL FALLS SERIOUSLY SHORT WHEN
MEASURED AGAINST THE ABOVE PRINCIPLES. IN CONTRAST, H.R. 798 ADHERES TO THESE
PRINCIPLES VERY CLOSELY. AS A RESULT, WE SUPPORT H.R. 798, BUT MUST CONTINUE TO
OPPOSE H.R. 701 UNLESS AND UNTIL THE CONCERNS WE HAVE RAISED ARE SATISFACTORILY
RESOLVED. WE STAND READY TO WORK WITH THE MEMBERS OF THE COMMITTEE AND THEIR
STAFF TO DO THIS. FOLLOWING IS OUR ANALYSIS OF THE TWO BILLS WITH RESPECT TO THE
PRINCIPLES ENUNCIATED ABOVE. H.R. 701, THE CONSERVATION AND REINVESTMENT
ACT REVENUE SOURCE H.R. 701 INCLUDES REVENUES FROM NEW LEASING AND NEW
DRILLING AS A FUNDING SOURCE FOR ALL TITLES OF THE BILL, WITH ONE EXCEPTION.
EXCLUDED FROM REVENUES FOR TITLE I ("IMPACT ASSISTANCE FORMULA AND PAYMENTS")
ARE REVENUES FROM LEASED TRACTS IN AREAS UNDER MORATORIUM ON JANUARY 1. 1999
(UNLESS THE LEASE WAS ISSUED PRIOR TO THE ESTABLISHMENT OF THE MORATORIUM AND
WAS IN PRODUCTION ON JANUARY 1, 1999). WHILE THIS LATTER LANGUAGE REPRESENTS A
DEFINITE IMPROVEMENT IN THE BILL, IT ONLY AFFECTS TITLE 1. IN ADDITION, IT DOES
NOT EXCLUDE REVENUES FROM NEW LEASING AND DRILLING IN SENSITIVE FRONTIER AREAS
NOT COVERED BY THE MORATORIUM. THE BILL THUS STILL FALLS SHORT OF MEETING THE
FIRST PRINCIPLE. THE OBVIOUS CONCERN IS THAT IF THE MANY AND VARIED
BENEFICIARIES OF THIS LEGISLATION SEE THAT IT IS IN THEIR FINANCIAL INTEREST FOR
NEW LEASING AND DRILLING TO OCCUR-IN ORDER TO PROVIDE MORE FUNDING FOR THE
LEGISLATION OVERALL AND FOR THEM IN PARTICULAR-IT WILL ERODE SUPPORT FOR THE
EXISTING OFFSHORE OIL AND GAS MORATORIUM, WHICH CURRENTLY PROTECTS THE EAST
COAST (WITH THE EXCEPTION OF EXISTING LEASES OFF CAPE HATTERAS), THE COAST OF
FLORIDA (WITH THE EXCEPTION OF EXISTING LEASES OFF THE FLORIDA PANHANDLE), THE
CENTRAL AND NORTHERN CALIFORNIA COAST (WITH THE EXCEPTION OF EXISTING LEASES OFF
THE CENTRAL CALIFORNIA COAST), OREGON, WASHINGTON AND BRISTOL BAY IN ALASKA. IT
WILL ALSO LEAD TO SUPPORT FOR NEW LEASING AND DRILLING ON EXISTING LEASES OFF
NORTH CAROLINA, THE FLORIDA PANHANDLE AND CENTRAL CALIFORNIA, AS WELL AS IN
SENSITIVE AREAS OFF ALASKA-NONE OF WHICH ARE CURRENTLY PROTECTED BY MORATORIA
AND MANY OF WHICH, IF NOT ALL, ARE EXTREMELY CONTROVERSIAL. IT IS CRUCIAL TO
REMEMBER THAT THE MORATORIUM ONLY EXIST BECAUSE CONGRESS EACH YEAR REENACTS IT
AS PART OF THE INTERIOR APPROPRIATIONS LEGISLATION. PRESENTLY, A ONE-YEAR
CONGRESSIONAL OUTER CONTINENTAL SHELF MORATORIUM CONTAINED IN THE FY 1999
DEPARTMENT OF INTERIOR APPROPRIATIONS BILL PRECLUDES THE EXPENDITURE OF FUNDS
FOR NEW FEDERAL OFFSHORE OIL AND GAS LEASING IN SPECIFIC COASTAL AREAS UNTIL
OCTOBER 1, OF THIS YEAR (1999). THIS CONGRESSIONAL OCS MORATORIUM PREVENTS NEW
LEASES FOR OFFSHORE DRILLING ON ANY UNLEASED TRACT ALONG THE ENTIRE U.S. WEST
COAST, THE EAST COAST, PORTIONS OF FLORIDA, AND BRISTOL BAY IN ALASKA. NOW IN
ITS SEVENTEENTH YEAR, THE MORATORIUM MUST BE RENEWED EACH YEAR. AS RECENTLY AS
THE 104TH CONGRESS, THE MORATORIUM WAS REMOVED IN THE HOUSE SUBCOMMITTEE ON
INTERIOR APPROPRIATIONS, AND WAS ONLY NARROWLY REINSTATED AFTER A BIG FIGHT IN
THE FULL HOUSE APPROPRIATIONS COMMITTEE, IN SPITE OF STRONG OPPOSITION TO THE
MEASURE BY THEN-CHAIRMAN REP. BOB LIVINGSTON. THERE HAVE BEEN PREVIOUS YEARS IN
WHICH THE OCS MORATORIUM HAS SURVIVED IN THE HOUSE APPROPRIATIONS COMMITTEE BY A
NARROW SINGLE-VOTE MARGIN. RELATED ACTIONS HAVE BEEN TAKEN BY TWO SUCCESSIVE
PRESIDENTS, WHICH SUPPLEMENT, BUT DO NOT REPLACE, THE PROTECTION GRANTED BY THE
CONGRESSIONAL MORATORIUM. THESE "PRESIDENTIAL DEFERRALS" ARE POLITICAL IN NATURE
AND ARE NOT CONSIDERED TO BE AS DEPENDABLE IN PROVIDING ASSURED PROTECTION OVER
TIME. IN 1991, FORMER PRESIDENT GEORGE BUSH ANNOUNCED THAT HE WAS DIRECTING THAT
ANY FURTHER OCS LEASING WITHIN THE AREAS PROTECTED BY CONGRESSIONAL MORATORIUM,
EXCEPT IN ALASKA, BE DEFERRED UNTIL AFTER THE YEAR 2002. NO FORMAL EXECUTIVE
ORDER WAS ISSUED BY MR. BUSH, AND IT IS CONSIDERED THAT ANY SUBSEQUENT PRESIDENT
COULD REVERSE THIS DECISION. DURING THE 1999 "YEAR OF THE OCEAN CONFERENCE" IN
MONTEREY, CALIFORNIA, PRESIDENT CLINTON, ACCOMPANIED BY VICE-PRESIDENT AL GORE
AND FOUR CABINET SECRETARIES, ANNOUNCED THAT THEY WERE DIRECTING THE MINERALS
MANAGEMENT SERVICE OF THE DEPARTMENT OF INTERIOR TO EXTEND THE PREVIOUS BUSH OCS
DEFERRALS UNTIL THE YEAR 2012. NO FORMAL EXECUTIVE ORDER HAS BEEN ISSUED BY THE
CLINTON ADMINISTRATION SINCE THIS ANNOUNCEMENT, AND IT IS CONSIDERED VULNERABLE
TO POSSIBLE POLICY REVERSALS BY SUBSEQUENT ADMINISTRATIONS. EVEN FOR TITLE I,
THE IMPROVEMENT IS INCOMPLETE BECAUSE REVENUES FROM NEW LEASING AND DRILLING IN
SENSITIVE FRONTIER AREAS NOT COVERED BY THE MORATORIUM WOULD STILL FUND THE
TITLE. IN ADDITION, IT IS NOT CLEAR FROM THE LANGUAGE WHETHER REVENUES FROM
DRILLING ON EXISTING LEASES OFF NORTH CAROLINA, THE FLORIDA PANHANDLE AND
CENTRAL CALIFORNIA WOULD BE USED TO FUND TITLE I. THESE LEASES ARE IN MORATORIA
AREAS BUT ARE NOT COVERED BY LEASING MORATORIA. DRILLING ON THESE LEASES IS AN
EXTREMELY CONTROVERSIAL ISSUE IN EACH OF THOSE STATES. TO ADDRESS THE PROBLEM,
THE LEGISLATION SHOULD DEFINE THE TERM "QUALIFIED OUTER CONTINENTAL SHELF
REVENUES" IN THE DEFINITIONS SECTION (SECTION 102) TO EXCLUDE REVENUES FROM NEW
LEASING AND NEW DRILLING AFTER THE DATE OF ENACTMENT OF THE LEGISLATION, AS THE
RESOURCES 2000 LEGISLATION DOES. THIS WOULD REMOVE THE FINANCIAL INCENTIVE TO
SUPPORT NEW LEASING OR DRILLING IN MORATORIA AND OTHER SENSITIVE COASTAL AREAS.
ALLOCATION OF STATE AND LOCAL SHARES THE LEGISLATION TIES A STATE'S SHARE OF
FUNDING UNDER TITLE I DIRECTLY TO THE AMOUNT AND PROXIMITY OF OCS LEASING AND
PRODUCTION OFF ITS COAST. THIS PROVIDES A CLEAR FINANCIAL INCENTIVE TO STATES TO
ACCEPT NEW LEASING AND DRILLING. FIFTY PERCENT OF A STATE'S ALLOCABLE SHARE IS
DEPENDENT ON ITS BEING WITHIN 200 MILES OF A LEASED OCS TRACT. THE MORE
PRODUCTION ON SUCH TRACTS AND THE CLOSER IN TO SHORE THESE TRACTS ARE, THE MORE
MONEY THE STATE GETS. SEE SECTION 103 (c)(1) AND (2). AN IMPROVEMENT IN THIS
SECTION OF THE BILL IS THE EXCLUSION-OF MORATORIA TRACTS FROM THIS CALCULATION.
THUS, EVEN IF MORATORIA TRACTS ARE LEASED OR DRILLED, A STATE WOULD NOT GET MORE
MONEY. HOWEVER, THE LANGUAGE IS AMBIGUOUS WITH RESPECT TO EXISTING
LEASES/PRODUCTION ON TRACTS IN MORATORIA AREAS. THESE TRACTS ALSO SHOULD BE
EXCLUDED. MOREOVER, NEW LEASING AND DRILLING OUTSIDE MORATORIUM AREAS, INCLUDING
SENSITIVE FRONTIER AREAS OFF ALASKA. WOULD STILL BE FACTORED INTO THE ALLOCATION
FORMULA, THUS PROVIDING A SIGNIFICANT INCENTIVE FOR ALLOWING SUCH ACTIVITIES TO
PROCEED. WE BELIEVE THAT THE FORMULA FOR ALLOCATING FUNDS UNDER TITLE I SHOULD
NOT BE TIED TO OCS LEASING AND PRODUCTION, BUT INSTEAD SHOULD REST ON SHORELINE
MILES AND POPULATION ALONE. ALTERNATIVELY, IF OCS ACTIVITY HAS TO BE A FACTOR,
IT SHOULD BE BASED ON A FIXED, FLAT PERCENTAGE BASED ON HISTORIC OCS ACTIVITY,
NOT NEW ACTIVITY THAT OCCURS AFTER PASSAGE OF THE LEGISLATION. THIS WOULD
ACKNOWLEDGE STATES THAT HAVE SUFFERED OCS IMPACTS TO DATE, WITHOUT PROVIDING AN
INCENTIVE FOR NEW LEASING, EXPLORATION OR PRODUCTION. ANOTHER MAJOR CONCERN WITH
THE BILL CONCERNS THE METHOD OF ALLOCATING FUNDS TO LOCAL JURISDICTIONS. FIFTY
PERCENT OF A STATE'S SHARE GOES DIRECTLY TO ELIGIBLE LOCAL POLITICAL
SUBDIVISIONS. SECTION 103(e). ELIGIBLE POLITICAL SUBDIVISIONS ARE DEFINED TO BE
THOSE THAT LIE WITHIN 200 MILES OF ANY LEASED TRACT (INCLUDING TRACTS IN
MORATORIA AREAS). SECTION 102(6). AS A CONSEQUENCE, A LOCALITY WITH OCS LEASING
OFF ITS COAST IS ENTITLED TO SHARE IN 50% OF THE STATE'S ALLOCABLE SHARE, WITH
ITS SHARE INCREASING THE CLOSER THE LEASED TRACT(S) ARE, LOCALITIES WITH NO
LEASING ARE NOT ENTITLED TO ANY PART OF THE STATE'S ALLOCABLE SHARE. OBVIOUSLY,
THIS CREATES A MAJOR INCENTIVE FOR LOCALITIES TO ACCEPT NEW OCS LEASING. TO
ADDRESS THIS PROBLEM THE DEFINITION OF ELIGIBLE POLITICAL SUBDIVISION SHOULD
EXCLUDE TRACTS LEASED AFTER ENACTMENT. SUCH TRACTS SHOULD ALSO BE OMITTED FROM
THE CALCULATION OF HOW MUCH AN ELIGIBLE POLITICAL SUBDIVISION RECEIVES. USES OF
THE MONEY IT IS EXTREMELY IMPORTANT THAT FUNDS DISTRIBUTED TO STATE AND LOCAL
GOVERNMENTS BE USED TO RESTORE AND ENHANCE COASTAL AND OCEAN RESOURCES AND NOT
TO CAUSE FURTHER ENVIRONMENTAL DEGRADATION. FOR THIS REASON, WE STRONGLY
RECOMMEND THAT USES BE RESTRICTED TO: AMELIORATION OF ADVERSE ENVIRONMENTAL
IMPACTS RESULTING FROM THE SITING, CONSTRUCTION, EXPANSION, OR OPERATION OF OCS
FACILITIES, ABOVE AND BEYOND WHAT IS REQUIRED OF PERMITTED UNDER CURRENT LAW;
PROJECTS AND ACTIVITIES, INCLUDING HABITAT ACQUISITION, THAT PROJECT OR ENHANCE
AIR QUALITY, WATER QUALITY, FISH AND WILDLIFE, OR WETLANDS IN THE COASTAL ZONE;
ADMINISTRATIVE COSTS THE STATE OR LOCAL GOVERNMENT INCURS IN APPROVING OR
DISAPPROVING OR PERMITTING OCS DEVELOPMENT/PRODUCTION ACTIVITIES UNDER ANY
APPLICABLE LAW INCLUDING CZMA OR OCLSA; AND/OR REPURCHASE OF OCS LEASES. THE
USES OF THE MONEY AUTHORIZED IN SECTION 104 OF H.R. 701 DO NOT ENSURE THAT
FURTHER ENVIRONMENTAL DEGRADATION DO NOT TAKE PLACE. THEIR FOCUS IS NOT ON
RESTORING THE ENVIRONMENT OR ENSURING ACTIVITIES DO NOT FURTHER DEGRADE THE
ENVIRONMENT. WHILE STATES MAY USE FUNDS FOR SUCH PURPOSES, THERE IS NO
REQUIREMENT THAT THEY DO SO. MOREOVER, STATES AND LOCALITIES WOULD BE FREE TO
USE THE MONEY FOR A HUGE ARRAY OF PURPOSES, INCLUDING PROMOTING MORE OFFSHORE
DRILLING, HIGHWAY CONSTRUCTION AND THE LIKE. WE URGE THAT OUR PROPOSED LANGUAGE
BE SUBSTITUTED FOR THAT IN THE BILL, OR THAT THE APPROACH TAKEN IN H.R. 798,
DISCUSSED BELOW, BE UTILIZED. OVERSIGHT TO ENSURE THAT THE FEDERAL DOLLARS ARE
SPENT RESPONSIBLY, IN AN ENVIRONMENTALLY SENSITIVE MANNER THAT COMPLIES WITH
FEDERAL LAW, IT IS IMPORTANT THAT THERE BE FEDERAL OVERSIGHT AND APPROVAL OF
STATE PLANS FOR UTILIZATION OF THE FUNDS. WHILE THE LEGISLATION REQUIRES THE
STATES TO DEVELOP PLANS FOR USE OF THE MONEY AND TO CERTIFY THE PLANS TO THE
SECRETARY OF INTERIOR, THE SECRETARY IS GIVEN NO AUTHORITY TO REVIEW AND APPROVE
THESE PLANS. IN ADDITION, IT IS THE STATE THAT DETERMINES CONSISTENCY OF LOCAL
PLANS WITH FEDERAL LAW, NOT THE FEDERAL GOVERNMENT! SECTION 105(c). THE LACK OF
FEDERAL OVERSIGHT COMBINED WITH THE BROAD USES TO WHICH THE FUNDS MAY BE PUT AND
THE LARGE FEDERAL DOLLARS INVOLVED MEAN THAT ENVIRONMENTALLY DAMAGING PROJECTS
COULD WELL BE FUNDED UNDER THIS LEGISLATION. OFFSETS IT IS ESSENTIAL THAT OCS
IMPACT ASSISTANCE NOT BE FUNDED AT THE EXPENSE OF EXISTING ENVIRONMENTAL
PROGRAMS. H.R. 798, THE RESOURCES 2000 ACT WE STRONGLY SUPPORT H.R. 798 BECAUSE
IT ADHERES TO THE PRINCIPLES WE SUPPORT. IT DOES NOT PROVIDE INCENTIVES FOR NEW
OFFSHORE LEASING OR DRILLING. THE BILL SPECIFICALLY EXCLUDES REVENUES FROM NEW
LEASING AND PRODUCTION AS A FUNDING SOURCE FOR THE ENTIRE BILL. SEE SECTION 4(4)
DEFINITION OF QUALIFIED OCS REVENUES. THE BILL ALSO DOES NOT ALLOCATE REVENUES
AMONG STATES (OR LOCAL JURISDICTIONS) BASED ON PROXIMITY TO LEASED TRACTS OR
PRODUCTION. TITLE VI ("LIVING MARINE RESOURCES CONSERVATION, RESTORATION, AND
MANAGEMENT ASSISTANCE") MAKES FINANCIAL ASSISTANCE AVAILABLE TO COASTAL STATES
BASED ON COASTAL POPULATION AND SHORELINE MILES. SECTION 602(B)(1). FINALLY, THE
BILL REQUIRES THAT TITLE VI MONEY BE SPENT ON THE CONSERVATION OF LIVING MARINE
RESOURCES, NOT ON ACTIVITIES THAT COULD CONTRIBUTE TO FURTHER ENVIRONMENTAL
DEGRADATION. IT PROVIDES SIGNIFICANT NEW FUNDING ($300 MILLION) SPECIFICALLY FOR
MARINE CONSERVATION. WE RECOMMEND THAT CONSIDERATION BE GIVEN TO HAVING SOME
PORTION OF THE MONEY UNDER TITLE VI GO TO HELP FUND EXISTING UNDERFUNDED MARINE
ANC COASTAL CONSERVATION PROGRAMS, SUCH AS COASTAL ZONE MANAGEMENT, MARINE
SANCTUARIES, AND ESSENTIAL FISH HABITAT PROTECTION. A PORTION OF THE FUNDING
UNDER THIS TITLE COULD BE USED TO ASSIST IN ACHIEVING THE GOALS OF AT LEAST SOME
OF THESE PROGRAMS; HOWEVER, IT WOULD NOT APPEAR TO DIRECTLY FUND THEM.
SIMILARLY, WE WOULD LIKE THE OPPORTUNITY OF WORKING WITH CONGRESSMAN MILLER AND
THE COMMITTEE ON THE STANDARDS THAT APPLY TO THE STATE CONSERVATION PLANS TO
ENSURE THAT THESE PLANS ARE EFFECTIVE AS POSSIBLE AND ON WAYS TO ENCOURAGE
STATES TO MOVE FROM THE PLANNING PHASE TO THE IMPLEMENTATION PHASE
EXPEDITIOUSLY. WE APPRECIATE THIS OPPORTUNITY TO TESTIFY AND LOOK FORWARD TO
WORKING WITH THE COMMITTEE ON THIS IMPORTANT LEGISLATION.
LOAD-DATE: April 13, 1999 
