is a much clearer demarcation of authority of the Federal Government vis-a-vis the authority of the States in reviewing decisionmaking on nonradiological and environmental considerations.

As I say, I make this statement in the context of my knowledge of the contents of the study that has been under way for the last 6 or 8 months and which will culminate in a report to the Commission at the end of May, and in the context of my own familiarity with the licensing process and the amount of duplication that does exist between data generation and review of data of nonradiological and environmental

matters.

Mr. DAVIS. Is there any sort of formal method of cooperating with the States in these matters now? Is there sort of a board that has representatives of both State and Federal officials that try to get together to work some of these matters out in advance, or is this done informally?

Mr. ROWDEN. We do have mechanisms. Some of these mechanisms are formal. Some have entered into State compacts. The Southeastern Nuclear Board is a compact of the Southeastern States. The Western Interstate Nuclear Board is another regional compact of the Western and Northwestern States. To that extent there is a formality to the communication.

We have set up an Office of State Programs. That is an action which the Nuclear Regulatory Commission has taken. The primary function of that office is to interface with the various States. It is that office which has been responsible for the sponsorship of the study which I mentioned.

We are also considering establishing what we would call State liasion officers at the regional offices which we have in 5 different regions around the country and which presently concern themselves only with inspection and enforcement actions. This will be a further mechanism for communication with the States.

We have quite extensive dialog with the National Governors' Conference which has a permanent staff. As a matter of fact, they have been working with us on the State-Federal siting study.

I might mention one other thing. I am ex officio member of the National Association of Utility Regulatory Commissioners, which is a useful mechanism for communication with the State regulatory bodies.

We have attempted to utilize all the institutional mechanisms available to us. There are limits in that regard. I think some basic structural changes will have to be made before we can do the sorts of things that I believe should be done.

Mr. DAVIS. At several points in your testimony today you have indicated that you have in the past recommended certain basic legislative changes. Do you anticipate that you will be sending up a legislative package again this year reflecting some of the changes that you think will be necessary in your legislation?

Mr. ROWDEN. It has been our contemplation that after the completion of the Federal-State study that I mentioned we would be putting together a legislative package to deal with needed changes in the licensing process. I firmly believe that not only does that need to take

place in other words, the completion of the Federal-State study, which is imminent-but that to present to the Congress the most constructive legislative package that we can it will be necessary for us to have some additional dialog with the administration so that we can integrate our planning and our thoughts with theirs.

I assume the Congress would desire it to be done that way. I would expect that there will be a legislative package submitted to the Congress this year.

Mr. DAVIS. One final question. The Japanese have frequently been held out as being one of the best countries in getting nuclear power generating plants from the planning stage to operational stage. Generally, how does their procedure differ from ours and what makes them faster in this process?

Mr. ROWDEN. Speaking in general terms, although in terms of the legal procedures and some other aspects of the review they are somewhat different from us, basically they do the same sort of things we do. They have an environmental review, and consider the design and site of the facility. They have a construction period and have a period of preoperational review.

The mechanisms of conducting their reviews is somewhat different from ours, but essentially they go through the same process. Their experience has been markedly the same as ours in terms of the increasing amounts of time that they have encountered in what I characterize as the nuclear plant cycle. At one time not so many years ago the so-called nuclear plant cycle in Japan was in the range of 5 or so years. Our latest figures, and I am not speaking with any degree of precision, based on present Japanese experience, would put that nuclear plant cycle in the range of 8 to 9 years, which is not too different from our own experience in this country and for some of the same reasons that we are encountering here.

The scope of the environmental review process has expanded considerably. The public's concern about nuclear issues, safety and environmental, has also expanded considerably, leading to more extended public inquiries in that regard. And the construction period time, which is the main differential between their nuclear plant cycle and ours, although it is much better than ours, has also begun to expand.

This is an experience which we see around the world. As these countries become I use the term advisedly-more sophisticated in their nuclear review process, because sophistication seems to correspond with the amount of time taken to complete the process, and as public attention on nuclear issues becomes more sharply focused, the nuclear plant cycle expands. This is true not only in Japan but in Western Europe.

Mr. DAVIS. Thank you, Mr. Chairman.

Mr. DINGELL. The Chair thanks counsel. The Chair recognizes Mrs. Lavigne.

Mrs. LAVIGNE. I have before me what I think was purported to be your submittal to OMB. It differs from what was presented to Congress on January 17. I would like to know how the budget as submitted to Congress in your view is detrimental to your operation?

In other words, you have been cut quite a few dollars from the budget request submitted to OMB.

Mr. ROWDEN. There have been budget revisions. We believe that the budgetary figure which we have presented to the Congress, and which we are supporting, with the modifications which I contemplate may have to be made in certain areas as a result of the President's energy policy statements is one that would give us resources adequate to carry out our program effectively.

There have been differences of opinions as to amounts that might best be committed to particular programmatic areas. I don't think that the incremental differences are that large that it impacts in any significant way on our regulatory capabilities.

As a matter of fact, some of the additional resources which we believe desirable, say in the inspection and enforcement area, I think are resources which the administration is going to support our getting. What we will ultimately have is a budget that we can support as being adequate to give us the funds and personnel to discharge our regulatory responsibilities.

Now we can deal with individual items if you like and I assume your staff members can respond to it, but that is my overall assessment. In making that assessment I think that I would be less than honest if I didn't recognize that when we are dealing with a budget we are dealing with a national budget, not just an agency budget, and choices have to be made in terms of allocation of resources.

This, of course, is the reason why we have a Presidential budget submitted rather than simply individual agency budget requests. I have no real ground for complaints as to how we came out of the budgetary process. I will make that statement not only about this year's review process but about the budgets we have gotten since NRC has come into existence.

I think the administrations involved have been very forthcoming in that regard, and I think it is necessary.

Mrs. LAVIGNE. In the budget to OMB there was no money for the pay raise supplemental for 1977. Is that correct?

Mr. BARRY. We have not received, of course, the supplemental yet but OMB did permit us to put in our 1977 budget the amount that we need.

Mrs. LAVIGNE. That was the budget to Congress, not the budget to OMB, is that correct?

Mr. BARRY. Yes; that was added at a later time.

Mrs. LAVIGNE. The budget cut from your request to OMB then amounts to about $10 million, is that correct?

Mr. BARRY. $11 million; the difference between our budget as submitted to OMB and the budget to Congress was $11 million. If you put the pay raise back in there you will see how we get back up to $292 million. We went in with $298 million. We were cut back to $287 million. We were permitted to put the $5 million in for pay raise which takes us back up to $292 million.

Mrs. LAVIGNE. What areas were significantly cut?

Mr. BARRY. About $6.5 million in research as a net change.
Mrs. LAVIGNE. For what kind of research?

Mr. BARRY. It was safety research.

Mrs. LAVIGNE. Safety research?

Mr. BARRY. Yes. If you want the specifics, Mr. Levine can tell you. Mrs. LAVIGNE. We would be interested in what kind of safety issues were going to be cut out of your research budget.

Mr. LEVINE. We were actually cut $6.7 million in research. Of that amount $6.2 million was in program money, and $0.5 million in associated equipment.

Mrs. LAVIGNE. Associated with what?

Mr. LEVINE. There was a half million dollars worth of equipment which was associated with the $6.2 million of program money. Time has overtaken one of the items we asked for which was for part of our LOFT program. The LOFT program schedule slipped and there was no need for that money. That accounted for about one-third of the funds. The others are really very small items and not of great significance to our research. Our total research budget as approved by OMB was $132.8 million.

Mrs. LAVIGNE. Could you provide a listing of those projects that were cut?

Mr. LEVINE. Yes.

Mr. BARRY. The remainder of the cut was as a result of the cut in personnel. It was in the price cut of people. A good many of the people were in inspection, and it now appears that we will be getting an increase in inspectors as a result of the Presidential announcement the other night where he wants to put inspectors onsite.

We have to go back to OMB with a budget amendment, and depending on the Commissioners' decision will be requesting an additional amount for inspection.

Mrs. LAVIGNE. When can we expect that you will be coming forward with this budget?

Mr. BARRY. In to OMB within 10 days. I cannot quite forecast when OMB will have the President's budget amendment to the Congress because, of course, it won't be only NRC. It will also include ERDA and anyone else that will be affected as a result of the President's energy policy.

Mrs. LAVIGNE. We will be interested in what you will need when we consider this as a package if you could provide that.

Mr. ROWDEN. Yes; you will be advised of that.

Mrs. LAVIGNE. Thank you.

Mr. HUNT. Mr. Rowden, in comments to Mr. Davis, you indicated or at least I sense you indicated that the Japanese process relative to licensing and construction was becoming more sophisticated at the present time, and indeed the 3-year construction period for which they were lauded may be extended in the future.

Have you or your staff gone through any comparative analysis relative to their safety requirements or their environmental analyses and compared those with the ones utilized in this country?

Mr. ROWDEN. Mr. Case might address himself to that.

Mr. CASE. Not specifically, sir. We are quite familiar with their requirement, and to a large degree they are copied after ours, as a matter of fact. We have not made a 1-to-1 comparison on the safety side. I would doubt, however, absent that specific comparison, that there is any significant difference.

Mr. HUNT. Thank you very much.

Mr. CASE. Mr. Minogue in the standards development area confirms my feeling.

Mr. HUNT. Thank you very much.

Mr. DINGELL. The Chair observes there are a series of questions. which were conveyed to NRC and ERDA, which will be inserted in the appropriate place, together with the answers.

Mr. Rowden, we want to commend you and thank you for your assistance in responding promptly to requests of the committee. It has been most helpful. Do you or your associates have any further

comments?

Mr. ROWDEN. No, Mr. Chairman. I appreciate the degree of your familiarity with our program and the constructive questions that have been put to us. I stated at the outset that we welcome this opportunity for a chance to have what I consider to be, even more than a budgetary presentation, an opening dialog with you. We do look forward to a very close and constructive relationship with you.

I know, sir, of your interest in nuclear matters and your even broader interest in energy matters. I can assure you that you will find not only myself but my colleagues and the whole organization willing to work with you on as positive a basis as we possibly can.

Mr. DINGELL. Mr. Rowden, we are appreciative of your assistance and kindness to the committee this morning. We thank you for your presence. We do look forward to a strong, constructive relationship where we can be helpful to you. We thank you and your associates for being present this morning.

The committee will stand in recess until 2 o'clock.

[Whereupon, at 1:05 p.m., the subcommittee recessed, to reconvene at 2 p.m. the same day.]

AFTER RECESS

[The subcommittee reconvened at 2 p.m., Hon. John D. Dingell, chairman, presiding.]

Mr. DINGELL. The subcommittee will come to order. The committee is very pleased to have with us an old friend, Mr. Anthony Roisman, staff attorney, National Resources Defense Council, and Ms. Claudine Schneider. Ms. Schneider, we are aware of some of your work and have a warm and friendly interest in your concern and are particularly pleased that you will be with us. We will receive your testimony as a panel and we will recognize you in such order as you wish to recognize yourselves. If you will, each, for the assistance of the committee identify yourself, we will be pleased to receive your statement. STATEMENT OF ANTHONY Z. ROISMAN, STAFF ATTORNEY, NATURAL RESOURCES DEFENSE COUNCIL, INC.

Mr. ROISMAN. Thank you. My name is Anthony Z. Roisman. I am an attorney with the Washington office of the Natural Resources Defense Council. I have a prepared statement which I would request be put in the record and I will summarize it.

Mr. DINGELL. Without objection, all your statement will appear in the record.