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1. Without knowing the nature and frequency of monitoring 

 activities which might be prescribed by the Administrator, it is 

 not possible for me to estimate the costs of this program. I am 

 sure Congress will prudently review the potential for costs 

 before moving forward with this legislation. 



2. I can only address the issue of privately and federally owned 

 beaches as they would be impacted in Texas. The public in Texas 

 has a traditional easement over all beaches which are accessible. 

 This means that state and local governments have long exercised 

 responsibilities on these privately owned beaches and would 

 comply with the monitoring requirements without burdening the 

 private owners . 



In the case of Federally owned beaches, which are extensive in 

 Texas, I would expect the relevant Federal agencies to conduct 

 the monitoring program as a part of their recreation management 

 program. It is possible that Federal agencies would utilize 

 water quality standards and monitoring frequencies promulgated by 

 the Administrator, if the standards adopted by the State were 

 more stringent. This matter should be clarified if it is the 

 intent of this legislation to present the piiblic with clear and 

 consistent information. 



3. I have requested our Texas Water Commission to comment on 

 this question. I am advised that the issue is complicated by the 

 cost and duration of the tests available as well as their 

 relevance to human health protection. The Water Commission's 

 responses will be forwarded to you as quickly as I receive them. 



4. Again I have called on the Texas Water Commission and the 

 Texas Department of Health for a response. Let me observe that 

 in Texas our shellfish harvesting is almost exclusively in the 

 bays whereas our water contact recreation is very largely on the 

 Gulf beaches. Therefore we expect no significant cost saving 

 from adopting a single standard. This legislation would require 

 substantial new monitoring. 



5. If monitoring in Texas were limited to beaches where a 

 significant niimber of people really get in the water and are 

 exposed to its potential risk, I don't think the cost would prove 

 to be so great since we are already out there monitoring water 

 around oyster beds, for instance. 



Suppose on the other hand that I am wrong and the cost is great - 

 - seemingly prohibitive, then it is a question of trade offs, 

 pulling money from other activities. That is where we would be 

 at a loss as policy makers. At this point there is simply no 

 scheme of public priorities for the Gulf. That is why the 

 efforts of EPA's Gulf of Mexico Program to create a Gulf plan 

 were so welcome to those of us who have to make trade offs on 

 what is important. That is why I believe that there is a need to 

 have a multi- jurisdictional Gulf Commission to set policies and 

 priorities that can guide us. 



Primed on recycled paper 



