508 



of critical size of the elements. Thus the idea of NOAA is attractive. However, I 

 see several problems that need to he considered in determining the final form of 

 the organization. 



The Commission report discussion of the proposed incorporation of the Coast 

 Guard in NOAA refers to, but does not deal adequately with, the question of its 

 continuation as a specifically identified armed force of the United States, to func- 

 tion as a component of the Department of the Navy in a national security role 

 in time of war. Maintenance of this identity would somewhat detract from the 

 advantages of consolidation of the Coast Guard with the other fleet operating 

 entities (ESSA and BOF) to be joined with it in NOAA. The Commission report 

 also does not take sufficient account of the large proportion of the Coast Guard's 

 work occupied with search and rescue, and with marine safety matters not 

 closely allied to the other functions assigned to NOAA, and the effect of this 

 rather separate work on its participation In the main stream purposes of the 

 agency. 



It also seems clear that the large number of functions assigned to NOAA will 

 require more resources than will be brought to it by the organizations that will 

 come together to form it initially. The matter of additional staff strengthening 

 is not addressed adequately in the Commission report. It is probable that a 

 natural recruiting ground for initial staff augmentation might be from the Navy 

 program, particularly in the area of ocean engineering and technology. Some such 

 assistance to founding the civilian program in this field might well be wise, but 

 unless carefully thought out and accomplished, the result might really be to 

 cripple a Navy program that the Commission wants preserved, rather than to in- 

 crease the national program and capability. This point should be examined care- 

 fully in the light of our earlier comments on the usefulness of Navy technological 

 programs and the need for Navy research programs in this field, and the necessary 

 detailed planning to avoid unnecessary difficulties accomplished before proceeding 

 with NOAA. 



The relationships between the DOD program and that of NOAA would need 

 to be carefully coordinated both to prevent unnecessary duplication and to insure 

 that the existence of either program could not be used as an excuse to cut the 

 other unwisely. 



The form in which NACO is proposed seems to us to be unwise on several 

 counts. The mechanism suggested would appear to put one operating agency 

 (NOAA) and what amounts to its advisory group (NACO) in an effectively con- 

 trolling position over other opei*ating agencies with their own special mission 

 requirements. This nearly guarantees petty conflict arising from the natural 

 tendency of NACO to regard NOAA jobs as more important than those of other 

 agencies. It would seem preferable to use a management body composed of suit- 

 able representatives from the concerned organizations at, say, the Assistant 

 Secretary level, with a group of outside advisors working with them. These 

 groups might work throughout the year, but report to a more senior policy group 

 like the present council, meeting annually to review the subject and report to the 

 President. An alternative to a special senior policy group for annual review would 

 be an annual review by the Federal Council on Science and Technology. 



None of these organizational schemes is perfect, and all seem somewhat cum- 

 bersome, but the organization of a field that is principally defined by an environ- 

 mental subject and area (although it does include some specific missions in it) 

 in a government that otherwise tends to be principally functional and mission 

 oriented cannot be easy. It might also be noted that establishment of another 

 independent agency reporting to the President may not be entirely wise. However, 

 there are legitimate objections to the subordination of NOAA to any of the 

 existing departments. 



At least until the establishment of the new organization proposed by the Com- 

 mission, or such other new organization, I support the continuation of the Na- 

 tional Council on Marine Resources and Engineering Development. As indicated in 

 a previous paragraph, some alternative organizational schemes would also benefit 

 by continued existence of this Council in some form. 



The proposed University/National Laboratory System and the National Proj- 

 ects would form a comprehensive set of organizations and programs which could 

 serve to stimulate the whole field. Establishment of the University/National 

 Laboratories, however, should not be used to prevent or to make impossible for- 

 ever the entry of major new organizations to the field, since the formation of new 

 groups is frequently a powerful stimulus to progress. The consideration implies 

 the necessity for and importance of the availability of support to research and 

 development entities other than University /National Laboratories. 



