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emissions than previously thought, and very different from the way EPA is formulating its regulations.

Would you agree there is much more research yet to be done to understand the effects of PM 2.5 and ozone and how they interrelate?

Mr. BAKER. Mr. Chairman, we've been concerned about particulate matter issues, and that's, of course, one of the reasons that we have proposed an increase in our Health of the Atmosphere Initiative, because we think it is very important to have accurate science. This is our role. It's something that we look at carefully, and we've been concerned about better understanding of both natural and human influence factors that affect particulate matter; that is, what part is due to natural causes and not controllable; what part is due to human causes, and then how does that vary region by region and State and State? We think it's very important that this information gets into the policy process. As I said, the policy process is not our business, but it is our business to provide accurate science and make sure that science is in there, so that there is a good scientific footing for the several-year implementation of these new standards that would occur if these rules will be adopted in some form.

I mean, we know that these lower standards mean that air quality targets are much closer to natural background levels than is currently the case. And this means all the more reason that we have to have good science and why our Boulder laboratories have been working very hard on this problem.

Chairman CALVERT. Would you agree that EPA at the present time doesn't know enough about the sourcing of especially particulates, the chemical makeup, just a general range of information regarding, as I mention again, particularly particulates of the 2.5 and below, to enforce them, to enforce new regulatory standards?

Mr. BAKER. Mr. Chairman, I can't really comment on the EPA and the way in which they make their rules. All I can say is I think there is more science to be done and we're trying to feed that into the process.

Chairman CALVERT. With that, I don't believe there is any additional questions. Again, I want to thank you for coming today and answering our questions, and your testimony was very enlightening.

With that, this Committee is adjourned.

[Whereupon, at 11:11 a.m., the hearing was adjourned.]

APPENDIX 1: Additional Statements for the Record

Statement of

Captain Fred R. Becker, Jr.

Director, Navy Affairs

Reserve Officers Association of the United States

for the

Subcommittee on Energy and Environment

House Committee on Science

March 4, 1998

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Reserve Officers Association of the United States
"PRESERVING THe Nation's Defense for 75 YEARS"

private,

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It receives no

The Reserve Officers Association is a supported, congressionally chartered association. federal or other public funds.

Army Navy Air Force Marine Corps

Coast Guard

Public Health Service ⋆ NOAA

One Constitution Avenue, N.E., Washington, DC 20002-5655
Telephone: (202) 479-2200 FAX: (202) 479-0416 800-809-9448

My name is Fred R. Becker, Jr. I am the Director, Naval Affairs of the Reserve Officers Association of the United States. I would like to limit my testimony to the cost studies that have been conducted with regard to the administration's proposal to dissolve the Commissioned Corps of the National Oceanic and Atmospheric Administration (NOAA).

Much has been made of the purported cost savings to be achieved by dissolution. A full and complete review of all the cost studies, however, clearly reflects that no real savings will achieved. In this respect, the dissolution plan forwarded to the Congress by the administration reflects cost savings that are, simply stated, non-existent. In fact, the cost of dissolution, as will be discussed in detail, will exceed $26M over 5 years. More importantly, there will no real cost savings even in the outyears, as dissolution of the NOAA Corps will increase the operating costs of NOAAs' ships and aircraft by over $2M annually as a result of civilianization.

The 1990 Commerce Department Inspector General report, that first asserted that there would be savings through dissolution of the NOAA Corps, has been largely discredited by three more recent cost studies that I shall later discuss in detail. As to the former Inspector General's report, the fault lies in the fact that his report focuses on the civilianization of only a portion of the shore side positions and ignores the clearly more expensive civilianization of the sea-side and aviation positions, where significant overtime costs are routinely incurred. In addition, the former Inspector General report does not attempt to grade each position by its responsibilities. For example, the report equates all captain positions to GS-14s, although many captain positions in the NOAA Corps have

supervisory responsibilities equal to that of GS-15s or senior executive service positions. The former Inspector General report further incorrectly incorporates, as a cost of current operations, the annual payment of retired pay to formerly retired NOAA Corps officers, as opposed to the annual retired pay liability for those officers currently on active duty. In addition, there are a number of other irregularities in the former Inspector General's report. The later studies by Arthur Andersen and Company, the General Accounting Office (GAO), and Hay Huggins correct all these deficiencies.

In January 1996, at the time the NOAA administrator announced his intention to eliminate the NOAA Corps, the only cost study available, conducted by Arthur Andersen and Company, showed that the NOAA Corps was actually less costly than an equivalent civilian work force. Specifically, the Arthur Andersen study, commissioned by the Department of Commerce, found that the NOAA Corps was about $500,000 less expensive annually than its civilian counterpart.

Subsequently, the GAO released its report

(GAO-GGD-97-10, "Federal Personnel Issues: Issues on the Need for NOAA's Commissioned Corps") that stated: "...that using civilian employees to carry out the Corps' current functions would result in limited saving" (emphasis added). Referring to the Arthur Andersen study, the GAO report asserts that, when the estimated federal income tax benefits of Commissioned Corps officers are considered, the government would realize net savings of an estimated $661,000 by employing civilians. The GAO report also states:

"If the Corps were to be converted to civilian employment, the actual net cost
reduction could vary depending on various factors.... It must also be
recognized that, because the Corps is now smaller than it was in the period

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