harvest the fish and market it interstate-say during a 2- or 3-month period-would that afford much relief to the industry? Mr. VER DUIN. Well, it would not in the case of coho salmon because they are restricted for sports fishing only and cannot be taken commercially. I am sure that your statement about them having lower DDT levels when they are smaller and having less fat is true. But that is a time when they are out on the lake. They seem to be widely scattered. The sportsmen cannot find them and commercial fishermen are not permitted to take them. So we are talking about a rather impossible situation. Mr. MESERVE. Thank you. Senator HART. Thank you, Mr. Ver Duin. Thanks very much. Our next witness is Dr. John Kitchel of the Michigan United Conservation Clubs, MUCC. STATEMENT OF JOHN H. KITCHEL, FOR MICHIGAN UNITED CONSERVATION CLUBS Dr. KITCHEL. Thank you, Senator Hart. I am privileged to appear here to represent MUCC this morning. I have been a member of this organization for some 20 years and occupied various offices. I just completed 2 years as president of the organization. During this 20-year period, I served as, chairman of the committee for MUCC to study pesticides and their effects. And I have recently been appointed to the water resources commission by Governor Milliken. Michigan United Conservation Clubs Senator HART. Doctor, may I interrupt to say that is a good appointment. Dr. KITCHEL. Thank you, Senator. MUCC is a statewide, nonprofit, nongovernmental, nonpartisan organization of Michigan citizens interested in the wise management of this State's natural resources, the conservation of its soils, waters, forests, wildlife, and minerals, and the promotion of healthful outdoor recreation for all. Founded in 1937, MUCC is now composed of about 350 affiliate local conservation and sportsmen's clubs and has a total membership of 115,000 people. MUCC has long been interested in the fisheries of the Great Lakes. Beginning about 15 years ago, we have contended that the sport and commercial harvest from these waters was not nearly approaching or reaching the potential it should with good management. And we have not departed from this stand. The reasons for this sorry state of affairs, we can summarize rather briefly: Fish stocks were first of all degraded by commercial exploitation over a period of several decades. The coup de grace was administered to the high value, deep water stocks by the marine lamprey. Meanwhile, the waters have been "enriched" by the addition of partially processed sewage, industrial wastes, and other contaminants for many years until the quality of the habitat for some of the high value species is not so good as formerly. Now, another exotic, namely the alewife, introduced as a result of man's hope to exploit the waters of the Great Lakes for another purpose, transportation, has erupted and the population explosion as you know left our beaches stocked with zillions or some other big number of dead fish in 1966 and 1967. To control this thing, the Pacific salmon were introduced, and it appears the effort will be a success. The high value commercial species, the basis for the commercial fishery in past years, have always been the deep water species which are rather high in oils. These are the lake trout, whitefish, the various chubs, Menominee whitefish, and related species. The shallow water fish by and large are not very high in oils or fats and do not retain much of the pesticides that reach the water. Now we have the effect of pesticides. This has been the latest damaging blow to the commercial fishery. Certainly these persistent_chlorinated hydrocarbon insecticides have been reaching the Great Lakes waters, probably mostly through tributary streams, but nevertheless getting in there for many years, and the monitoring of the levels of these in fishes which began 5 to 6 years ago indicates they are there in sufficient concentration to produce damaging effects. Concentrations in the chubs and related species have not been sufficient to prevent their marketing, but as you all know the concentrations accumulated by salmon last year went so high that the Food and Drug Administration felt called upon to step in and set a tolerance or action level for DDT and dieldrin. MUCC has asked repeatedly since 1963 that the use of these things (persistent chlorinated hydrocarbon insecticides) be prohibited or be limited under the law to those rather few uses for which we had no satisfactory substitute. We have been repeatedly told that these are agricultural chemicals, that agriculture is not using them, that the residues in the water come from the cities. While this may be a tremendous exercise in semantics, it does not seem to me it solves any problems. Recently, our Michigan Agricultural Commission did move to restrict these uses, but the steps under the law are rather time consuming, so we as yet do not have practical limitation or elimination of these persistent pesticides in Michigan. We have been told that sales of these materials in Michigan have declined considerably, but I think this is not due to action by the agency and is probably more due to an awareness on the part of the consuming public that the materials are damaging and they are refusing to purchase them when told what is in the material offered for sale. You, Senator Hart, I believe have sponsored an amendment to the Water Pollution Control Act which would require the Secretary of the Interior to set water quality levels for pesticides. MUCC at the time of the water quality hearings in 1967 took much the same position-we wanted our waters monitored for these things but we have since had an opportunity to review, not only all the old information, but some new information. And we are skeptical of the practicality of such a program. DDT, for instance, may occur in water in 1 part per trillion, but through the action of plankton, then concentrating in the forage fishes, then in turn to be picked up by the predators at the top of the chain, this is reconcentrated and multiplied 10,000-fold or 100,000fold so that we wind up with some multiple of the values for DDT that we are now finding in chubs. As we recall, this is 3 to 5 parts per million in Lake Michigan Multiples of the concentrations in chubs are found in salmon and lake trout after they have been in the lake for 3 to 4 years, I mentioned before, and we all know the concentrations in salmon have prevented their interstate sale. The concentrations in lake trout are apparently of an order that would make them unfit for sale in interstate commerce when they have reached appreciable size and maturity. The values in whitefish, I do not happen to recall, but the values in lake trout are high enough that they will probably prevent reproduction and negate the effort to reestablish lake trout as the principal deepwater predator in the upper lakes, especially in Lake Michigan. Our position now is that it might be possible to determine a level in water that would be so low that no fish could accumulate more than a safe level. Safe for consumption, that is. Where do we go when this level is exceeded? Where do we go to apprehend the culprit? We cannot go out and arrest all the farmers in the State of Michigan or all the residents in the State of Michigan who may have been fogging for mosquitoes or using this for some other purpose. It seems to us that we can pose a simpler problem and arrive at more effective controls by imposing limitations on the manufacture formulation, transportation, sale, and application of these chemicals. In summary, I think we might say that the persistent chlorinated hydrocarbons have proved damaging to many elements of our environment as Senator Hart recited here at the opening of the hearing and that they are creating serious problems for the commercial fishery in the Great Lakes. We believe the only practical method is to eliminate as nearly as we can the manufacture, sale, and use of these materials-DDT, dieldrin, aldrin, lindane, heptachlor, toxaphene, et cetera. Thank you. Senator HART. Thank you, Doctor. Yesterday, at the hearing in Lansing, your successor, the current president of MUCC, Frederick Brown, very briefly stated the position of the United Conservation Clubs. I should not indicate this early, I suppose, what I suspect my own conclusion will be, and I certainly could not speak for the subcommittee, but your very brief paper, nonetheless, seems to trace with clarity where we logically should wind up. It suggests that the one feasible way to deal with this problem with a minimum of disruption and a maximum of safety is simply to identify the pesticide for which we have a scientific basis for finding it to be a serious threat to the whole environment and then outlaw it. Simply say, "Do not manufacture it." This makes the policing relatively simple. But if we are ever going to get to that point, we are going to have to be in a position to say that there are available effective, nonpersistent, pesticides that can be substituted for the banned pesticide if the value of that pesticide in agriculture or in insect elimination for public health reasons is of a high order. In your opinion, are there effective, nonpersistent, pesticides available that could be substituted for the major uses of DDT and other chlorinated hydrocarbons? Dr. KITCHEL. I think my answer would have to be double barreled there. First for the use of many of these things in the open such as control of mosquitoes or elm bark beetles, there are effective substitutes that are not as persistent, substitutes that have a half life of weeks or months rather than a long period of years. The other part of it is that I believe we can permit the use of some of these items in situations where they will not escape to our waters and be distributed generally in our environment such as the use of, I think it is, chlordane that is put in around the foundations of buildings to control and prevent the damage from those wood-eating antlike things I can't think of the name of them. Senator HART. Termites. Dr. KITCHEL. I do not have that detailed information at hand, but I am certain that we have these things. Senator HART. What we would have to be sure of is that the substitute chemical does not have characteristics that might make it just as dangerous to either man or wildlife. I have a question here that we intended to ask. You have already answered it in part, but let me ask it explicitly. You might develop the thought which is contained in your prepared testimony. What action would you recommend that government, both Federal and State, take to minimize ecological disruption from pesticides-without sacrificing agricultural production or disease control programs; or do you really think that the two things are bound to have a head-on collision? Do you think there is an inevitable conflict? Dr. KITCHEL. No, I do not believe there is an inevitable conflict. The people who promote the use of these things and who so bitterly oppose elimination of their use or strict limitation on their use seem to me to be mostly the manufacturers, the people who make a profit from this. And I have talked to some of these people and heard them testify. And frankly, I am a little bit skeptical that they are talking more from their pocketbook than they are from their concern for the common weal. Senator HART. Thank you very much, Doctor. Mr. Meserve. Mr. MESERVE. You mention in your statement that there are a few uses for persistent pesticides for which we have no satisfactory substitutes. Could you elaborate on what some of those uses might be? Dr. KITCHEL. I think we ran over that briefly. The only one that I am certain about is that we do need some kind of persistent material to protect buildings from termites. I do not know of any other use that we cannot eliminate. But there possibly are others. I have heard testimony from people involved in the Public Health Service that they must have DDT, for instance, in case of an epidemic of Equine encephalitis to control mosquitoes. But I do not quite buy this because I know there are good materials available which will eliminate mosquitoes or control them without the use of DDT. And I think we could very well apply these. They might be a little more expensive than controlling mosquitoes with DDT when we are faced with an epidemic of some of these things, but I do not think that is an essential use. Mr. MESERVE. Do you know anything about research work being done on biological controls as a substitute for chemical controls-how actively research is being conducted and what type of progress is being made? Dr. KITCHEL. I cannot answer that specifically. I know that there are a number of areas where such research is being conducted and that they have had a measure of success in some fields. One example is the use of a tiny wasp imported from, I believe, Italy, to control the cereal leaf beetle. They found that the chemical pesticides, whether they were short lived or long lived were not satisfactory, did not do a job in controlling the cereal leaf beetle. And MSU has turned to this parasite to control the cereal leaf beetle. I have not had any reports of whether this is going to be a real satisfactory control or not. Mr. MESERVE. Do you have any indication that when the State of Michigan, through one of its agencies, launches a pest control program, that it consults ecologists beforehand and tries to ascertain just what the long-term or short-term effects on fish and wildlife might be before they determine what chemical is actually going to be used? Dr. KITCHEL. I was, I guess I am still, a member of this advisory committee to the Department of Agriculture, and they are responsible for the public programs. And I cannot recall an instance in which they turned to us first with the problem and said, "What do you suggest?" They called us to a meeting to review the problem and then said, "This is what we propose to do about it." Our objections and suggestions, I do not believe, got very much consideration. Perhaps they got more than I realize. Mr. MESERVE. Was there ever a case where your advisory group, by a majority vote or some sort of majority expression of opinion, suggested that a particular pesticide should not be applied and a substitute should be found, and the Department overrode that objection? Dr. KITCHEL. I can recall one instance where the Department had discovered an infestation of gypsy moth, I believe it was, down in Calhoun County or some part of the State near a lake. And they proposed not to treat it with the persistent pesticides as they had in he past and I think they had used principally DDT-but to use one of the organophosphates or carbamates. I do not recall now which. But one suggestion they seemed to accept was that this is going to, in case you are unlucky and get a little wind, drift so that it gets in the lake, and might cause a fish kill. So we suggest that you warn people in the area there is a possibility of a fish kill in particularly the shallow waters of this lake from this material. And it was not a persistent material, but it is one that is highly toxic to fish in the brief life that it has. So I think they acted on that suggestion. They did tell the people that this might kill some fish, too. on. Mr. MESERVE. But generally, they did not act on the suggestions? Mr. MESERVE. Was the creation of this panel then basically a little bit of window dressing to satisfy people that ecologists were being consulted, when in fact they were not being listened to at all? Dr. KITCHEL. The appointment of this advisory committee which was not a statutory group followed an effort by a number of our State conservation organizations to get a bill through the legislature which 30-831 0 69-pt. 2- 14 |