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C\J M 00 ,,.,, ~:';1 James 110naghan January 17, 1977 Page 2 Finally, let me say briefly what I should have said to the PCC. Perhaps it will be helpful for future policy considerations. 1. Much of the Savery-Pothook decision was based upon the Administration's policy of favoring agriculture. That is perfectly legitimate, but I didn't see the kind of clarity I would hope for in such a policy. What is meant by favoring agriculture? Reserv- ing water for irrigation, subsidizing irrigation, and shifting land into agricultural use are means of carrying out such a policy, but they can only be evaluated as such if we are clear about what we are trying to accomplish. Are we seeking to maintain agricultural incomes? De we wish to .preserve opportunities for rural people to remain on the land? Unless we can specify those objectives clearly we will be unable to evaluate alternatives, such as Savery-Pothook, with respect to their agricultural impacts. Discussion then deteri- orates to the level of "any agricultural project is a good project." I fear that there was too much of that in the PCC review. Much of agriculture is experiencing economic hard times, due to overproduction. We must ask ouselves how to deal with this situation effectively. If we do, it will be obvious that subsidizing further irrigation development may be counterproductive. 2. Quite clearly a substantial part of the conce1n for agri- culture in the review process was really not motivated by any objective to favor agriculture. Rather, negative objectives, such as precluding industrial development, were basic and favoring agri- culture was a way of attaining .these objectives; Again, such an objective may be appropriate (although I suspect that the real concerns lie still deeper). However, it can't be effective unless it is more clearly stated. 3. The cumulative EIS issue was not treated clearly, in my view. There was almost no recognition that the Bureau of Recla- mation's policy of cumulative impact review is totally inappropriate. What good does it do for a cigarette smoker to have a medical Check-up after each cigarette? Eventually, and too late, he will be told that he has detectable lung cancer. What is needed is progr<lllllllall.c, not cunmliltive, review which will tell us where we arc hC<ldcd a9 well as where we have been. 4. Economics were deemed irrelevant to state level review of federal projects. I agree that no state can be allowed to make federal policy in this or any other respect. However, a state may well ask whether its .own aims broadly or narrowly conceived, are well served by its own participation in any federal program or project.. ......1.. ,-I: