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militate against unilateral action with respect to mining. Unilateral action would lead to international friction,

no doubt with unfortunate and costly consequences in many aspects of our relations with foreign governments. It is even possible that some foreign governments, who are aware of the most active proponent or proponents of this legislation, might respond by taking hostile actions against various subsidiary interests, and this could, of course, embroil the United States in international discord. The Executive, in its testimony, has questioned the royalty fee the industry has set for itself; we wonder whether the taxpayer, under the fee structure, will benefit adequately from this new activity. We doubt that it is reasonable for the Federal government to subsidize mining companies by reimbursing them for losses or additional expenses caused by rules implimenting a future international regime.

Finally, on the other side of the scale, there is no evidence of pressing need for additional supplies of nickel, copper, manganese, and cobalt, the minerals that result from deep seabed mining, and if the U.S. proposal for a provisional regime is adopted, mining activities could begin within a couple of years in any event. The potential balance of payments benefits from mining, while desirable, are quite insignificant when compared with the liabilities of unilateral action. Indeed, the primary

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reason for passing this legislation at this time would appear to be to enhance the financial well-being of various mining companies and to assist the inter-corporate relationship of one mining subsidiary with its parent.

The above views are based on the assumption that mining will not take place until. American corporations do have national legislation or an international regime providing some security for their investments. If signifi

cant exploitation were to start soon without a regime, including environmental safeguards, we would want to reconsider our position and may well favor the passage of legislation on this issue, perhaps legislation prescribing a temporary moratorium.

In sum, while the introduction of S.1134 has played the useful role of airing this issue before the public, we believe environmental considerations buttressed by other national interest factors compel the conclusion that this legislation should not be passed. Since deep seabed mining may well be a desirable activity in the future, and since negotiations for an international regime may be completed within the next year or two, we believe the Executive branch should fulfill its obligation promptly to analyze the environmental impact of this activity and the safeguards which should accompany it, and we ask this subcommittee to encourage the Executive branch to do so and to see that the public participates in a timely, proper fashion.

Thank you.

Senator METCALF. I understand that Dr. Wade is not going to be with us, so we will proceed at this point with Dr. Donald J. Zinn, Professor of Zoology, University of Rhode Island.

We are delighted to have you here.

Mr. ZINN. Thank you, Senator.

STATEMENT OF DONALD J. ZINN, PROFESSOR OF ZOOLOGY, UNIVERSITY OF RHODE ISLAND, FOR THE NATIONAL WILDLIFE FEDERATION

Mr. ZINN. Mr. Chairman and Senator Hansen, my name is Donald J. Zinn. I am a Professor of Zoology specializing in marine biology and a research associate of the Graduate School of Oceanography, formerly the Narragansett Marine Laboratory at the University of Rhode Island. I am also the past president of the National Wildlife Federation.

I am a graduate of Harvard College with a degree in Zoology and I hold a Ph. D. in zoology from Yale University.

In addition to several other professional organizations, I am a member of the Marine Biological Association of the United Kingdom. I am co-editor of the bulletin "Psammonalia," which deals with the microscopic fauna of the marine sediment. I have devoted some time and research to the problem of the ecology of the microfauna of the marine environment.

The National Wildlife Federation is a private organization which seeks to attain conservation goals through education; its national headquarters are at 1412 16th Street NW., Washington, D.C. The federation is composed of affiliates in all States, Guam, Puerto Rico, and the Virgin Islands. These affiliates, in turn, are made up of local groups and individuals who, when combined with associate members and other supporters of the National Wildlife Federation number an estimated 3.5 million persons.

The National Wildlife Federation welcomes the invitation to comment on S. 1134, the "Deep Seabed Hard Mineral Resources Act."

Mr. Chairman, while the National Wildlife Federation includes in its membership many sportsmen, as well as birdwatchers and other admirers of wildlife and nature, and especially conservation-minded environmentalists, the prime concern for our organization always has been for the overall welfare of natural resources everywhere on this planet.

We do not think that a wasteful, careless, haphazard, possibly pollution laden, potentially faunally destructive approach to exploiting the mineral resources of the seabed wil contribute to the welfare of the bottom dwelling finfish and shellfish or to the conservation of the products of their valuable environment. We are certainly not opposed to the development of this resource, and because we favor a positive, reasoned, circumspect approach, we endorse, in general, the conservation principles in natural resources in S. 1134, within the stipulations noted below.

Despite the fact that benthic animals have been collected from the deep sea for about a century, the bottom or benthic invertebrate fauna

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was not evaluated quantitatively until 1950, when a Danish expedition collected 13 samples off the west coast of Africa in depths from 800 to 3,660 meters. Since then, the results of a great deal of this kind of work have been published from investigations in the Atlantic, Pacific, Indian, and Antarctic Oceans and the Mediterranean Sea. The sediments sampled ranged from fine sands of terrigenous origin to a variety of oozes to silty clays and clays.

In summarizing the results of these various studies it can be said that each region sampled supports a characteristic number of animals per square meter in a general trend of decreasing density with increasing depth and distance from the continent, and independent of latitude.

For example, in one investigation in which the benthic fauna of the North Atlantic was studied, the outer continental shelf to about 200 meters average 6,000 to 13,000 individuals per square meter; upper continental slope to about 1,000 meters, 6,000 to 23,000 individuals per square meter; the lower continental slope, which goes to about 2,000 meters in depth, 1,500 to 3,000 individuals per square meter; the abyssal rise, which goes to about 4,000 meters, 500 to 1,200 individuals per square meter; and the abyss, which is below 4,000 meters in depth, 50 to 300 individuals per square meter. This work also revealed that over 85 per cent of the fauna was composed of worms, crustaceans and bivalves, the remaining 15 per cent being divided among at least six other invertebrate groups.

Although the environment for minerals on and in marine deep sea bottoms is scarcely known, major programs for inventory of these kinds of resources on a worldwide basis have been proposed by a number of interested professional and government groups.

One of the most serious problems facing marine mining operations is waste disposal. Unlike land operations where mine tailings can be retained in specially prepared areas, or returned back to the original excavation, waste disposal in the ocean is much less controllable and will also have a greater effect on the surrounding environment.

Not only can these wastes contaminate the new ore, but it may have a major effect on the ecology of the area, especially when toxicants are utilized in the ore benefication process. Past studies on the effect of mining on marine biological life have been retrospective in nature, being initiated after the damage was done. Future studies will involve the measurement of the ecosystem before any activity is commenced, so that causal effects may be continually monitored as mining progresses.*

It is of the utmost importance, it seems to us, that exploitation of one natural resource does not involve the destruction of another.

The problems associated with water turbidity and waste disposal may also have their positive side. Informed opinions have been expressed that sea floor activity may release large amounts of nutrients previously unavailable to plant and animal life in these areas, so that mining the sea floor may have the same beneficial effect as plowing land.

Mining companies apparently have always lived with the threat and consequences of polluting the environment hanging over their

heads; sometimes they have not faced these problems at all, sometimes they have attacked these problems grudgingly and ineptly, and sometimes no expense has been spared to solve the problem to everyone's satisfaction. From now on, counter measures to avoid pollution should take a place of primacy in mining of evaluating of studies in the ocean deeps.

Public opinion is at the point where the very suggestion of possible disturbance of the environment will lead first to voluable criticism and then just possibly to expensive constraints. In cases where the proximity of dredging operations to beds of living shellfish has already caused justifiable concern among interested environmentalists, it is obvious that the need for intensive study and analysis of the total picture of such operations had not yet been met.

Painful and time consuming as such studies often are, they are essential if the resource is to prosper and the interests of all citizens are to be satisfied. The concept of multiple use of our environment will require us to give thought not only to maintaining the integrity of the ocean and sea bottoms, but in many cases to making it mandatory to avoid utilizing them to avoid catastrophic disturbance of alternative resource areas of land.

For this reason, adequate and reasonable fundamental research must be done on the total environment of virtually everp deep sea station to be mined before informed decisions can be made on whether the area is to be exploited. Hopefully impetus will be given to this country's so far meager efforts in the development of environmental and technical standards on which such decisions may properly be based.

Mr. Chairman, thank you again for the opportunity of making these remarks.

Senator METCALF. Thank you very much indeed for being here.
[The prepared statement of Mr. Zinn follows:]

STATEMENT OF DONALD J. ZINN, PROFESSOR OF ZOOLOGY, UNIVERSITY OF
RHODE ISLAND, FOR THE NATIONAL WILDLIFE FEDERATION

Mr. Chairman, my name is Donald J. Zinn. I am a Professor of Zoology specializing in Marine Ecology and a Research Associate of the Graduate School of Oceanography, formerly the Narragansett Marine Laboratory at the University of Rhode Island. I am also the past-president of the National Wildlife Federation.

I am a graduate of Harvard College with a degree in Zoology, and I hold a Ph.D. in Zoology from Yale University.

In addition to several other professional organizations, I am a member of the Marine Biological Association of the United Kingdom. I am co-editor of the bulletin Psammonalia, which deals with the microscopic fauna of the marine sediment. I have devoted some time and research to the problem of the ecology of the microfauna of the marine environment. My most recent publications in this area are, "Recommendations for Research on Deep-Ocean Fouling" published by the U.S. Naval Ordnance Systems Command (Tech. Report 4004-1, April 1970), and "The Impacts of Oil on the East Coast" published by the Wildlife Management Institute, in 1970.

The National Wildlife Federation is a private organization which seeks to attain conservation goals through education; its national headquarters are at 1412 Sixteenth St., N.W., here in Washington, D.C. The Federation is composed of Affiliates in all States. Guam, Puerto Rico, and the Virgin Islands. These Affiliates, in turn, are made up of local groups and individuals who, when combined with associate members and other supporters of the National Wildlife Federation number an estimated 31⁄2 million persons.

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