118 



Senator Stevens. As I listened to your answer, I could only think 

 of the sign that used to say "Plan Ahead," and the "d" and everything 

 was down at the bottom because they ran out of space. 



I think if we are trying to help the States plan ahead, there has 

 got to be some way to prevent them from running head-on into a 

 problem which was not raised by anybody at the planning stage. To 

 me, that would be an environmental problem. 



It does not seem to me that we have done enough to require the 

 advanced coordination of the land use planning with the advance 

 concepts of NEPA. The 102 statement is a good example. I recently 

 received Mr. Kuckelshaus' monthly report, the 102 report. I think 

 the unemployment situation in the country today would be more 

 easily understood if we considered the delay factors of NEPA, which 

 are not presently understood by the Congress, in my opinion. I 

 would hope that your department, in particular the model cities con- 

 cepts and communities, would have the ability to forestall the en- 

 vironmental problems that might result in the future. 



Consider, for instance, constructing a new city around Fairbanks in 

 my State. You could proceed with a nice plan and a State land use plan 

 and everything else. However, if the concept of water pollution that we 

 have in the wintertime with ice fog were not taken into account, it 

 would result in the final approval basis being stalled completely by 

 virtue of not having an environmental aspect properly included in 

 State land use planning from the very first. 



Therefore, I would hope that this would be one of your goals, Mr. 

 Jackson. I thank you for your comments and I assume you agree with 

 Mr. Train, in that you would rather have the "whole loaf" rather than 

 the "half a loaf" concept. 



Mr. Jackson. Absolutely, Senator. We think that S. 992 is the 

 proper approach for the Senate to take. 



Senator Stevens. May I ask one more question. I asked Mr. Train 

 this. Do you believe that a Federal activity under section 106 would 

 include insurance activities under Federal housing or grants to States 

 under the various housing programs? In other words, are we really 

 covering all Federal activities or are we just covering the activities of 

 the Federal Government ? 



Mr. Jackson. Senator, as you know, the section you referred to refers 

 back to section 204 of the Demonstration Cities Act of 1966. This is 

 what I was referring to when I indicated that the Office of Management 

 and Budget has implemented that through one of its issuances called 

 A-95. That procedure defines what is Federal program activity for the 

 purposes of section 204. 



Now, as it relates to the housing programs, it applies to projects of 50 

 or more contiguous lots — projects of 50 single family homes or multiple 

 family housing of 100 units or more. We have determined that that is 

 the proper size for ascertaining that its impact is significant enough to 

 require the use of the A-95 procedure. 



For each of our programs we made an assessment of when the impact 

 is substantial. Whenever the impact is substantial, then the type of 

 predevelopment coordination that you speak of is required. 



Senator Steatrns. Unless there are 50 homes, for instance, under that 

 concept, then, a small subdivision of 25 homes would not come within 

 your definition of significant Federal activity. Is that right ? 



