country during World War II by the U.S. Army as an alternate means of crossing the isthmus, the road was opened to the public after the war, and now one sees no forest anywhere (not even on the far slopes), except where the road passes through a short stretch of the Canal Zone.

Panama's population continues to grow rapidly, and the people must go somewhere. What better place than into newly opened country? There is still a considerable amount of virtually untouched forested land away from the roads, though this area is obviously being chipped away. But surely controls can be applied to this process of colonization of newly accessible areas. Especially on the steep slopes, where permanent agriculture is almost impossible, rapid erosion certain, and the danger of flooding great, forests should be retained. Failure to preserve such forests has already resulted in a lack of water in some areas during the dry season. Much of the soil in the lowlands is poorly suited for conventional agriculture anyway-a large proportion of the available nutrients are tied up in the naturally occurring vegetation, and are lost when that vegetation is removed. In most areas the soil is so thin that it will produce crops for only a season or two and then must be abandoned. Because of this, the highest economic use for many areas would probably be retention in forest, perhaps with periodic selective cutting or marketable trees, or with growing of certain crops, such as cocoa and coffee, in which most forest canopy trees are retained.

Most of the Canal Zone presents a striking contrast to the picture so far presented. As part of its Canal defense policy, the U.S. government has for years carefully restricted the number of private individuals allowed to farm or settle. within Zone limits; there are minor exceptions, but essentially all land is owned and controlled by the government. Because of this exclusionary policy, much of the Zone remained in or reverted to woodland or forest, and now is a vital island of forest in the midst of generally cleared countryside. The contrast is especially impressive on the road that winds through Madden Forest in the Canal Zone and then suddenly emerges into Panama province. As a result, the Canal Zone now has probably the most extensive, readily accessible lowland forests in Middle America. A great variety of birds, and even many of the larger mammals, can be easily seen, the latter especially on Barro Colorado Island, where protection from hunters is provided. Hunting is allowed generally, and, as the Zone is adjacent to heavily populated areas, some of the larger fauna have been locally extirpated. A newly enacted (1973) hunting law, totally protecting all bird species other than the Blue-winged Teal, Gray-headed Chachalaca, Common Snipe, and doves and pigeons, may, if enforced, greatly aid some species. At present, native waterfowl, the larger eagles, curassows, macaws, as well as such mammals as the jaguar, tapir, and manatee are either gone from the Canal Zone or are very scarce and local. Virtually everything else remains, however, and the Zone continues to be a naturalist's paradise.

Political considerations may soon drastically alter this situation, however. The Republic of Panama understandably resents the large American presence and its obvious affluence. A major change in the status of the Zone has been anticipated for years and is bound to come sooner or later. This surely will mean an end to the Canal Zone as it is presently known, and (unless the Panamanian government takes protective measures) will probably also mean an end to most of its forest. Certain areas, among them Madden Forest and Barro Colorado Island, will, it is hoped, continue to be preserved in their natural state. It is not out of place to make a plea here for preservation of a few additional areas, most notably Fort Sherman and San Lorenzo, the Achiote Road area, and particularly the Pipeline Road area near Gamboa. Even a brief perusal of the main body of this book will reveal how often Pipeline Road is mentioned. For variety of birdlife, it is without question the outstanding, easily accessible forest area in Panama. As such it would make a wonderful wildlife reserve, and if properly protected could become a fine tourist attraction for Panama. For the present, it remains in the hands of the U.S. military, and the forests are intact (though hunting is allowed); its future, like the future of the rest of the Canal Zone, is decidedly uncertain. Latin America lags considerably behind the rest of the world in setting aside suitable areas as national parks and biological reserves, though some countries are making commendable strides in the right direction, despite severe budgetary restrictions (a fine example is Panama's neighbor, Costa Rica). Panama, unfortunately, trails even most of its sister republics. To date only one national park has been established (in 1968), a small but interesting tract of cloud forest on Cerro Campana, about thirty miles west of Panama city. Regrettably, even

this area is inadequately protected and has been invaded by squatters. It is much to be hoped that Panama establish a system of parks, both for its own people and as part of an effort to attract more tourists from abroad.

Probably top priority should go to the area in western Chiriqui around Volcán Barú (the Volcán de Chiriqui of much zoological literature), a long extinct volcano that reaches above timberline and is Panama's highest mountain at 11,410 feet. Actual establishment of this long discussed park would protect what remains of a fine highland forest (rapidly being destroyed by squatters), and the faunas that are dependent upon it, including the Resplendent Quetzal (perhaps the most beautiful bird in the New World, and still probably easier to see here than anywhere else) and numerous species endemic to the highlands of western Panama and adjacent Costa Rica. Adequate samples of other forest habitats should also be set aside before they are totally destroyed; the situation in the lowlands of western Chiriqui is the most critical in this respect. Reservation is relatively easy today because much of the land involved is still owned by the government.

Areas should be set aside as forest reserves along the Pan-American Highway as it is extended east through the so-called "Darién Gap," and also along the several trans-isthmian highways now under construction or projected. Government plans for the reservation of sizable areas surrounding the body of water that will be impounded behind the dam on the Bayano River above El Llano are commendable. Protection of the as yet remote Darién highlands, which also contain endemic birds and other animals, and of the many seabird colonies in the Gulf of Panama, is also needed.

A number of bird species have decreased drastically in Panama, especially in recent decades; several have already been mentioned. The Resplendent Quetzal depends upon the highland forests of western Panama, which are rapidly being cleared for new agricultural land. Although it is illegal, males are still shot as trophies, both sexes still find their way into the pot, and young still are removed from nests to be caged, where most promptly die. This bird's potential as a tourist attraction is being realized only slowly. Despite hunting laws regulating the season and bag limits for most game-birds, a number of species have been overshot, and the laws remain virtually unenforced. The relatively unsuspicious Great Curassow is probably the most endangered, and has been extirpated over wide areas, though it apparently remains fairly numerous in remote inaccessible forests.

The somewhat warier and more arboreal Crested Guan seems better able to withstand hunting pressure, and remains in reduced numbers wherever the forest cover it depends on is retained. The Black Guan, endemic to the highland forests of the western highlands and Costa Rica, has become decidedly scarce in western Chiriqui, and probably has declined to at least an equal degree in other parts of its Panama range, though there are no recent data. Tinamous and woodquall are also hunted assiduously, but their overall decline is probably more due to forest destruction than to direct hunting pressure. Woodquall are considerably less furtive, however, and consequently are more vulnerable; the Marbled Wood-Quall has for example declined considerably even in the forested Canal Zone. Populations of the resident species of waterfowl have been decimated in many areas by unrestricted year-round shooting. The once abundant Band-tailed Pigeon of the western highlands has also decreased dramatically due to heavy hunting, though it is still reasonably common at least locally. Many diurnal birds of prey remain fairly numerous in Panama, though again all species dependent on forest have seen their potential ranges shrink drastically. However, the larger species, in particular the huge Happy Eagle, have become very rare in recent years, and the Happy appears to have decreased even in remote areas despite its official protection.

The group whose status gives greatest cause for alarm is the macaws. Though at one time widespread in Panama, today they are restricted entirely to remote forested areas. One species, the Scarlet Macaw, once ranged over the Pacific slope east to the Canal Zone, but is now found regularly only on Coiba Island off the cost of Veraguas, and if that island's status as a penal institute should be altered and the area opened to settlement, the macaws would undoubtedly be swiftly eliminated. The other Panamanian members of the genus are not yet in such a precarious situation, but all species have been greatly reduced in overall numbers. Macaws are sometimes shot for food, but the primary cause of their

rapid decreases (other than the usual forest destruction) has been the taking of young from nests to be kept as pets or sold into the cagebird traffic. If there are to be any macaws at all in Panama a few decades hence, measures prohibiting their exportation from the country will have to be implemented.

The picture is not entirely bleak, though. In recent years a number of persons residing in Panama have become aware of the conservation problem, and are organizing ever more effectively to do something about it. The Comisión Nacional de Proteccion de la Fauna Silvestre (National Commission for Wildlife Protection) was formed in 1967 under the Ministry of Agriculture and was instrumental in obtaining presidential decrees protecting various animals, including the Quetzal and the Happy Eagle. In 1967 Panama organized a national section of the International Council for Bir Preservation (ICBP). The Panama Audubon Society has striven to interest more people in the country's birdlife and the need for its protection. An increasing number of persons visit Panama each year for the express purpose of seeing its birds and other wildlife. But any such program will inevitably be short-lived if the present rapid rate of population increase (over 3 percent annually) continues for any length of time. In the long run, curbing this increase will not only be of great benefit to Panama's marvelously rich avifauna, it will also be much in the interest of the Panamanian people, for only then will real social and economic progress for all the people become possible.

EXCERPTS FROM "THE TOUCAN"

(Panama Audubon Society, March 1977)

ON CONSERVATION

The members of the Panama Audubon Society, with valuable assistance from visiting birders, have just completed a historical Christmas Bird Count, which our president, Dr. James Pujals, has described in vivid detail in recent issues of the Toucan newsletter. It was a feat for which all those who contributed their time, energy and talents can feel justifiably proud. But as we bask in the glow of our recent achievement, perhaps we should ask ourselves this: How many bird counts comparable to that of 1977 will be possible in Panama in years to come? Unfortunately, the answer is probably very few, unless our concern about the steadily increasing threats to our local wildlife communities is transformed into action to meet and diminish those threats.

Two areas in the Canal Zone demand particular and urgent attention:

(1) In the forest habitats along the Gamboa Pipeline Road, the mounting pressure on wildlife populations from uncontrolled hunting is shockingly evident to anyone spending as much as an hour in the area any day of the week, and could be painfully evident to the unwary visitor who happens to step into the path of a stray bullet.

On a recent Sunday morning, several Society members birding along the Pipeline Road encountered at least a dozen hunters, came upon the empty parked cars of many more and were frequently distracted from identifying bird calls by the sudden, ominous crack of gunfire, signaling the probable violent end of another member of the local wildlife community. All of this led up to an almost finale to the morning's outing. As the group walked from the main road along the small trail leading to the Rio Frijoles, three hunters were encountered coming out of the forest, one armed with a shotgun, another with a rifle, a weapon prohibited by law from use in the Canal Zone; in the hand of one of the hunters was the material evidence of their shooting foray: a Rufous Motmot with holes in the chest and back where a rifle bullet had passed through its body. The hunters' car license number was reported since they had broken the law in the use of the rifle. Unfortunately, they had broken no law in killing the Motmot because no such law exists. A law that would protect this and almost all other bird species, as well as many animal species, in the Canal Zone by imposing strict, but reasonable, regulations on hunting has been in the works since 1973 but to date has not been put into effect. If adopted and enforced, it would go a long way toward preventing such needless destruction of our local fauna.

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In his book, "A Guide to the Birds of Panama," Robert Ridgely makes a plea for the preservation of several valuable forested areas in the Canal Zone, particularly the Pipeline Road area . . (which for variety of wildlife, is without question the outstanding, easily accessible forest area in Panama. As such it would make a wonderful wildlife. . . ."

(2) The other area of immediate concern is the Madden Forest Preserve, where the evidence of forest destruction is increasingly apparent. An especially blatant example of this unlawful gutting of large sections of forest was very succinctly described in the February 7 Toucan by our scientific chairman, Dr. Nate Gale. Several PAS members have gone to this area, near the Las Cruces trail, for a first-hand look, and an appalling sight it is an ugly wasteland of huge felled trees and rotting vegetation. An area that only a short time ago was teeming with life is now essentially dead-unless you count the torn patches that are springing up around the edges. And this is only one example of a phenomenon that is occurring in other places throughout the Forest Preserve, a term that begins to take on a mocking ring. If these damaging inroads are allowed to continue, Ridgely's description of the Canal Zone as having ". probably the most extensive, readily accessible lowland forests in Middle America" will eventually be rendered meaningless, and one of the world's most valuable forest habitats for tropical bird and animal species will have been lost to mankind. Biologist David W. Ehrenfeld, in his moving articulate book, "Conserving Life on Earth," could be speaking of the situation here when he says that "... the widespread and often preventable destruction of natural communities and subsequent general loss of species foreshadows and is often accompanied by severe environmental problems for the human inhabitants of the region regardless of their technology. If the other motives and objectives for maintaining the diversity of the environment fall on deaf ears, this ominous correlation at least should provoke concern."

It is hoped that members of the Panama Audubon Society and others in the community interested in preserving this richly endowed tropical forest environment will express their concern whenever and wherever possible, and their support for measures to relieve hunting pressures on local wildlife populations and to stop the cutting of trees in the Forest Preserve. You can do this by writing a letter to the governor, by calling the Executive Planning staff "Hot Line" (523412) or the Environmental Coordinating officer (52-7961), or by contacting members of the Pacific and Atlantic Civic Councils. No one should feel that his or her voice is too small to be heard-the more persons who are heard, the greater the chance that those in positions to make decisions will make the right ones from a conservation standpoint.

Mr. LINDSEY GRANT,

W. M. WHITMAN CONSULTING SERVICES.
Kensington, Md., September 28, 1977.

Deputy Assistant Secretary for Environmental and Population Affairs Department of State.

DEAR MR. GRANT: This is in response to the notice in the Federal Register for August 29, 1977 (42 FR 43466) inviting comments on the draft environmental impact statement for the Panama Canal Treaty dated August 1977, hereinafter referred to as the "EIS." These views are strictly my own and have not been coordinated with any government agency, official, or individual.

A reading of the EIS as a whole suggests a number of questions as to the sufficiency of the document under the National Environmental Policy Act of 1969 and implementing regulations and judicial decisions, particularly in reference to the requirement for consideration of the environmental impact of the proposed action at all stages of the decision making process, but these comments are limited to consideration of the environmental effect of increases in rates of tolls required by the proposed new treaty, discussed at pages 25 and 26 of the EIS.

In effect, the EIS concludes that assessment of the economic impact of the treaty is presently impossible because of lack of data as to costs of operation of the Panama Canal after the treaty goes into effect. The EIS then assumes increases in tolls of 25 percent to 35 percent and concludes that the environmental effect of such increases would be no greater than the impact of the tolls increases of 19.7 percent and 19.5 percent that went into effect in 1974 and 1976, respectively.

In my view, none of these assumptions and conclusions can be supported. In 1978, costs of operation of the Panama Canal based on the 1978 budget program adjusted for annual treaty payments to Panama ($73 million) and other changes in revenues and expense resulting from the treaty will approximate $392 million, and revenues from tolls and other sources are estimated at $311 million. Under the statutory formula enacted by Congress, tolls for use of the canal are required to be established at rates sufficient to recover costs of operation so that an increase in tolls rates sufficient to increase tolls revenues by $81 million, or approximately 46 percent, will be required.

Assuming for purposes of his calculation that an increase in rates of tolls of 46 percent will produce an increase of that amount in total tolls revenues, the tolls increase required by the treaty would be as follows:

The assessment of the environmental impact of the 1976 increase in tolls was based on traffic projections and estimates of sensitivity of Panama Canal traffic to tolls increases that concluded that over a period of ten years, increases of 50 percent, 75 percent, 100 percent, and 150 percent in the rates in effect prior to July 1974 would result in reduction of cargo movements through the canal by 11.5 million, 28.8 million, 49.1 million, and 80.1 million cargo tons, respectively. In comparison to rates in effect prior to July 1974, the 1976 tolls increase resulted in a cumulative increase of 49.5 percent, so that the environmental effect of the increase was analyzed from the standpoint of loss or diversion of 11.5 million cargo tons of canal traffic. However, the increase of 46 percent over 1977 rates required by the treaty would represent a cumulative increase of 119 percent over the rates in effect prior to July 1974, so that on the basis used in the Environmental Assessment of the 1976 proposal to increase tolls, it would be necessary to consider the environmental effect of loss or diversion of about 50 million cargo tons-a far more serious loss than the 11.5 million tons used in the 1976 Assessment.

Accordingly, the conclusion that the rate increases required by the treaty would not have a more significant impact on the environment is not supported by the analysis in the 1976 Assessment cited on page 26 of the EIS and attached to the EIS at Tab F. The proceedings on the 1976 tolls increase point toward the contrary conclusion.

Finally, it seems apparent that neither the amount of the tolls increase required by the treaty nor the environmental impact thereof can be determined with any degree of confidence without an updated ten-year projection of traffic and tolls with estimates of the sensitivity of Panama Canal traffic to tolls increases of up to 150 percent. Changes in economic conditions affecting canal traffic since the last ten-year projection as well as the impact on traffic of the proposed treaty suggest that on the basis of data presently available, no reliable conclusions can be drawn as to the future volume of traffic, tolls revenues, or the environmental effect of increased rates of tolls.

The basis for the various conclusions reflected in the preceding paragraphs are discussed in the attachment in as much detail as possible within the time constraints imposed by the notice.

Very truly yours,

Enclosure

COMMENTS OF W. M. WHITMAN

W. M. WHITMAN.

This is in response to the notice in the Federal Register for August 29, 1977 (42 FR 43466) inviting comments on the draft environmental impact statement for the Panama Canal Treaty dated August 1977, hereinafter referred to as the “EIS.” These views are strictly my own and have not been coordinated with any government agency, official, or individual.

A reading of the EIS as a whole suggests a number of questions as to the sufficiency of the document under the National Environmental Policy Act of