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<br />u U I.l ,) '1 't <br /> <br />32 <br /> <br />liTo limit the period to five years would seriously bog down <br />the public works program with delays for review of authorized <br />projects and consequent delays in planning for new projects. <br /> <br />liThe Society, therefore, recommends that the 'Principles <br />and Standards' not be applied to already authorized projects <br />unless actual construction has not commenced within ten years <br />after authorization. <br /> <br />". . . The Society notes that the 'Activities Covered' do not <br />include those Federally assisted programs of the Environmental <br />Protection Agency and of the Department of Health, Education, <br />and Welfare. Perhaps others are not included. <br /> <br />liThe Society recommends that the 'Principles and Standards' <br />be applied to Federal participation in all comprehensive regional <br />or river basin planning of water and land resource development <br />and to all Federally assisted programs including grant programs <br />to states, interstate or intrastate entities. <br /> <br />"In addition to the modifications outlined above, the Society <br />considers that an intensive training program is es sential to <br />effective and expeditious application of the 'Principles and <br />Standards. '. . . II <br /> <br />:::~***~::: <br /> <br />". . . [Recommended] That there be carefully drafted a <br />clear-cut, readily understood, plain English summary of the <br />'Principles and Standards' and made a part thereof, and. . . that <br />special care be taken in the drafting of the 'Procedures I to clarify <br />and simplify the application of the 'Principles and Standards. "' <br /> <br />[. <br /> <br />Dr. Paul E. Roberts, Professor of Economics, University of <br />Florida, on behalf of the Environmental Defense Fund <br /> <br />liThe most favorable aspect of the proposed principles is the <br />discussion about the appropriate discount rate to be used to <br />discount future benefits and costs. Most of the evidence reported <br />in the proposed principles and elsewhere point to an appropriate <br />discount rate of at least 10 percent. <br /> <br />"I find no disagreement with this interest rate <br />that it would be appropriate for the next five years. <br /> <br />and agree <br />But rather <br />