ML19329F879
| ML19329F879 | |
| Person / Time | |
|---|---|
| Issue date: | 07/08/1980 |
| From: | Ahearne J NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML19329F857 | List: |
| References | |
| NUDOCS 8007110297 | |
| Download: ML19329F879 (8) | |
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Statement of John F.
Ahearne, Chairman U.S. Nuclear Regulatory Commission P.r. Chairman, members of the Committee, the Commission appreciates this opportunity to express its views on the President's Reorgan-ization Plan No. 1 of 1980.*
Following delivery of the Commission's statement, individual Commissioners have statements which' they would like to deliver at that time.
I disagree with the following positions taken by the Commission.
The Commission's fundamental evaluation of the Reorganization Plan is this:
The Plan will worsen, rather than improve, the Commission's organization and structure.
It will not lead to better nuclear regulation or safer nuclear power plants.
It will, however, lead to friction and distrust within the Comnission and may well direct the Commission's attention away from nuclear safety and enmesh the Commission in time consuming debates about the prerogatives of the Chairman and the full Commission, and the right of individual members to have access to information to which the Chairman has access.
We strongly believe that the Commission format is worth retaining because of the benefits associated with the diversity of views of its members in the formulation of nuclear safety policy.
Yet, the real price 'for this Plan that you have been asked to approve, and the unstated conse'quence of concentrating power in the Chairman, is a severe curtailment of the Commission process.
Commissioner Hendrie was unavailable and did not participate in the preparation of the Commission's statement.
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.T" It is desirable for the Chairman of this or any Commission to
..g have a larger administrative role than the other members of the Commission.
However, the Chairman's larger role should be built, and should depend for its continued existence, on the understand-ing and acceptance of the other members.
Chis relationship between the Chairman and the other Com=issioners can serve as a '
mechanism for accountability and can make the Chairman's larger role a positive feature of the agency's discharge of its responsi-bilities.
However, it is precisely this relationship between the Chairman and the other members which the Reorganization Plan would curtail.
The Plan's provisions on appointment of Staff, staff reporting requirements, and access of Commissioners to information can only exacerbate any divisive environment within the Commission.
Under the Plan, the Chairman's role will no longer depend on the acceptance of the other members; his preeminent powers will often enable him to act without regard to their wishes.
The Chairman will appoint all but two of the key NRC Staff personnel.
Staf f appointments are important because the Staff provides basic support functions for the full Commission in safety policy development and enforcement.
The Commission would continue to appoint only the Directors of Nuclear Reactor Regulation and Nuclear y.aterials safety and Safeguards.
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There is no rational explanation for this division of Staff appoint powers in the Plan.
This illogical appointment system could well become a source of con-flict within the Staff.
The two officials appointed by the Commission will report to and be supervised by the Chairman or his appointee, the E::ecutive Director for Operations; both directors will be surrounded in the Staff by officials whom the Chairman alone appoints.
The Chairman has a veto over all other key appointments, including the General Counsel, the Director of Policy Evaluation, the heads and members of the adjudicatory panels, and the members of the Advisory Committee on Reactor Safeguards.
In the case of the Advisory Committee, whose function it is to advise the Commission on nuclear safety issues and whose members sit for four-year fixed terms, the potential influence on nuclear safety of the Chairman's veto is graphically illustrated by the fact that the Chairman will be able to prevent the reappointment of a membe'r, without cause.
The Chairman will be the sole supervisory and reporting authority for the Staff, unless he chooses to delegate that authority.
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4 This authority opens a broad avenue for the Chairman to exercise substantial control in nuclear safety policy, in addition to his role as a voting member of the Commission.
The Chairman's control will be most evident early in the critical stage of policy development by the Staff, and late at the equally critical stage of' policy enforcement.
This role for the Chairman will hinder, rather than foster, increased Commission involve-ment in nuclear safety policy.
Ccncentration of power over Staff in the Chairman is not an academic or hypothetical matter.
It creates the real possibility of a minority Chairman who can frustrate the will of the Commission majority through his power to appoint and supervise the Staff.
A majority Chairman does not need such a battery of authority because he can expect to win Commission acceptance of his appoint-ments and actions.
Thus, the dangers associated with a minority Chairman under the Plan are not only serious but unnecessary.
At the same time that.the Plan would strip the Chairman's sthength-ened role from its connection to Commission acceptance, it would reduce the role of the Commission to make it very much dependent upon the Chairman.
By and large, Commissioners will be permitted to be informed about agency operations only to the extent the Chairman wants them to be informed.
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5 The Chairman could withhold information relating to the administration and management of the agency. This means, for example, that the Commission will likely not know the true nature or extent of the Chairman's control over Staff policy papers which are forwarded to the Commission.
The Plan also provides an arguable basis for withholding other information.
A Chairman might attempt to withhold significant material, such as inspection information, on that basis.
The Chairman will largely control the extent to which individual Commissioners may receive answers to their-questions from the Staf f.
Many of these questions can be expected to raise, or relate to nuclear safety issues.
No matter how often it is said that ultimate authority will continue to res,ide in the full Commission under the Plan, this is simply not so.
The Plan provides no means for the Commission to hold the Chairman acco.untable with respect to a large number 'of his actions.
Nor does the Plan give the Commission any means of requiring the Staff to comply with the Commission's policies.
The authority of the Commission extends to rulemaking, adjudication and policymaking, but not to any other matter of agency business even though it may bear upon nuclear safety.
The Commission is not free to take up 9
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6 a particular matter outside this sphere of activity even though a majority believes the Chairman has abused his power.
While the Chairman is to be governed by the general policies and decisions of the Commission in his actions, he will have the power to restrict access to information and leave the Commission in the dark about what he is doing, or whether it is consistent with Commission safety policy.
In sum, the Plan will adversely alter the structure by which nuclear safety is regulated.
Moreover, a very real practical consequence of a strong Chairman and a weak Commission will be increased Executive Branch control over nuclear regulation.
The President's power to appoint and remove the Chairman makes the Chairman's accountability to the President very clear.
Under the Plan, a Chairman with allegiances to the Executive Branch would have extensive powers over NRC organization and considerable control over the shape
- of nuclear regulation.
Because of the limitation on access to information, individual Commissioners will not be informed or able to exercise a meaningful check on the Chairman's actions which have substantive import for nuclear safety.
Thus, the Plan contains the worst features of the single administrator and collegial agency proposals.
Because the Executive 3 ranch influence will be in secret, there will be no accountability,
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u but at the same time, the independence, openness and diversity that justify a Commission may be undermined.
The public's scepticism about the adequacy of nuclear safety regulation is hardly likely to be dispelled by this effort to reduce the inde-pendence and effectiveness of the regulators.
If public confidence is to be restored in the government's determination to place the public health and safety first, that will come through strengthen-ing, not weakening, regulatory independence and through insistence on strict, tough nuclear regulation.
Changes in the Plan are necessary if effective regulation of nuclear safety is to continue under an independent Commission.
The right and power of the Commission, by majority vote, to take up any matter of agency business must be explicitly recognized if the Commission is.to act as a useful check on the powers of the Chairman.
This change would leave the Chairman free to act unless a majority voted otherwise in a particular situation.
Of course, the Chairman would remain able to deal with emergencies as necessary.
The principle of full access to information for each Commissioner, which has been a part of nuclear regulation since 1955, should not be curtailed.
The list of Staff officers appointed by the Commission should be enlarged to include the Executive Director
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8 for Operations, the Executive Legal Director, and the Directors of Research, Standards Development and Inspection and Enforcement.
The role of the Executive Director for Operations should be defined in the Plan as the Chief Staf f Officer, to whom the Staff reports, who acts as the Commission's agent, under the general supervision of the Chairman on behalf of the Commission, in managing the day-to-day operations of the agency.
The Chairman should not have the power to veto appoint-ments to the ACRS and adjudicatory boards.
No review of the causes of management difficulties of the NRC should overlook the urgent need for the agency to be housed at a single location.
The Administration has been supportive of that goal.
Mr. Chairman, this completes the Commission's statement on the Reorgani=ation Plan.
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UNITED STATES
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January 7,1980
. _ CHAIRMAN The Honorable James T. McIntyre, Jr.
Director, Office of Management and Budget Room 255 Old Executive Office Building Washington, D.C.
29593
Dear Mr. McIntyre:
In his December 7,1979 statement, the president said he would shortly submit to the Congress a reorganization plan for NRC. He further stated that the plan would (1) strengthen the role of the Chairman as the chief executive officer, (2) empower the Chairman to select key personnel, and (3) authorize the Chairman to act on the Commission's behalf in an emergency.
The Commission understands that the Office of Management and Budget is to prepare the plan, and wants to submit to OMB its views on the topics to be addressed in the plan.
The Commission agrees that the central premise of any reorganization plan should be the retention of the collegial body.
I would have personally preferred the course of a single-head, Executive branch agency, as proposed by the president's Commission on the Accident at Three Mile Island.
However, the President's
- ecision was to retain the collegial structure, and that decision clearly has wide support both inside anc outside this Commission.
It is the view of che Commission that retention of the Commission structure logically requires the Commissioners as a collegial body to possess the basic authority typically held by the heads of other administrative agencies. The Commission believes that this authority must inexorably extend to any matter that the Commission, acting in its collegial role as head of the agency, deter-mines to be important to the mission of the agency.
Only then can it ensure the proper discharge of the agency's statutory responsibilities.
Since I am not fully in accord with this principle, my views differ in scme respects from the position of the Commission.
I will provide those views to you at the end of this letter.
Turning to the specific items to be addressed in the plan, the Commission's position is as follows:
mYn, The Resoective Roles of the Commission as a Collecial Body the Chair-1 and the Executive Director for Ocerations.
The collegial Commission i
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Director, Office of Panagement and Sudget Room 255 Old Executive Office Building W shincton, D.C. Zg593
Dear Mr. McIntyre:
In its January 7,1980 letter to you regarding the NRC reorganization plan, the Cc=ission stated that it intended to deliberate further on the plan Tnis letter contains those and would provide additional recomendations.
recomendations:
In the past, the Commission has requested statutory status for the The importance of this office 1.
Office of Inspection and Enforcement.
is cc:dparable to that of the other NRC offices with statutory status,
- However, and it actually has a larger staff than those other offices.
although there is widespread agreement on the need for stronger inspecti and enforcement action, the Comission is considering a variety of managerial and structural alternatives to best achieve functions as soon as i rescives these the inspection and enforcemen outstanding issues.
Tne reorganization plan should clarify the cespective roles of NRC ar.d FEMA in the review and approval of State and local plans for offsite 2.
In his December 7 statement, emergency response to nuclear accidents.
the presiden directed FEMA to take the lead for all off-site nuclear However, under current law, NRC ame roenc'v ciannino and response.
continues 'to have responsibility for a review o-State an, local
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plans insofar as these plans are sign 171can,,wo licensina As ~vou ;av know, NRC has recently pecposed new rules, wnich eme roenc'y
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deci ions would as a ceneral ma'tter require NRC concurrence in appropriate State Toc =1 5ercancy plans as a conditicn to 1:s granting licenses.
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such plans will be an open issue in NRC 11 censing and enrorcemeg:..n.
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January 15, 1930 Honorable John F. Ahearne Cha.' =an U. S. Nuclear *:te:ulatorv. Cc=ission
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TGCCP.MTIONS CF ??SSIE NT'S CCP."ISSION CN ACPS RC~d
Dear Dr.. Ahearne:
2e following cc=ments are offered in response to Mr. Chilk's letter of Never.ber 9,1979 re:uesting dat the AC?S p:cdide the C:=issica with its vie s and analysis of the role of the ACRS as contained in the recomenda-tions of the repre of the President's Co=ission (?~) ed the Accident at Three Mile Island.
Individual reco.mendations f:cm de reprt are listed below wid ACRS com ents following.
1.
"The Advisory Cc mittee en Rea:ter Safeguards (ACOS) should be retained, in a streac,tmaened ro.le, to cont nue ::cv;;:.n:. an inde:enden: che:k on sa fe tv. ma tters. " The ACPS agrees.
2.
"The memoers of the Cc=mittee should conti~~
- % pa rt-time app intees;.... "
te AGS agrees.
3.
- ~ne staff of AC?5 should be strengthened to p:cvide increased capaci:y 1
for independent analysis." The ACFS agrees that current staff su: pert is inadequate to p:cvide suitable independent-analysis capability; to keep abreast of SRC Staff, industry, and foreign group activities on specific safety matters; to p cvide technical and backg:cund infen ation to the
.r embers so the latter can make the best use of their limited time; and to p cvide p cper support to the numerous AGS sub:ccmittees.
Tne Cc=ii. tee derefere recuests that ten additional, senior-staff psitiens.be auther-
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i:ed for the ACRS staff in order to meet de sense of the ?~'s rece:.en-1 d.ations and to p:cvide a. adeccate technical su=prt base for i. proved
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creration o'f the Cc=ittee.
Tnese==sitions are intended :: be in addi-tica to $=se authorited in de Fellowship Program.
5:vever, if budgeta:y limitations :: event $is level of support, the Cc=ittee w::uld accept sc=e j
cK'_C 7_ __ - 5"?W7"2. T. 'Y7 F" 'g.ent, senic: pasitions.
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FEB 211980
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CHAIRMAN
'Mr. Harrison Wellford Executive Associate Director for Reorganization & Management Office of Management & Budget Room 246 Old Executive Office Building Washington, DC 20503
Dear Mr. Wellford:
The Commission appreciates the opportunity to comment on the early working draf t, dated February 15, 1930, of the NRC reorganization plan.
On the general matter of the powers of the Chairman vis-a-vis those of the collegial Commission, the draft plan does not reflect tne Commission's earlier recommendation that the collegial Commission should continue to be the funda-mental authority of the agency.
The Commission had proposed this principle could be maintained by giving a majority of Commissioners so voting the power to call any matter of agency business, including personnel matters, before the collegial body for decision.
The assumption was that with the normal scope of Cc= mission and Chairman functions defined as they are in the draft plan, the exercise of this ultimate collegial authority in matters normally handled by the Chaiman would be rare, and would occur only in cases where a majority felt the Chaiman was abusing his prerogatives. The Commission believes it to be a useful check on the powers of the Chairman, and one with which a reason-able Chaiman would have no great problem.
By way of comments on specific points:
1.
The Commission understands the words " functions... concerned with...
policy formulation for... the licensing and related regulatory functions of the Commission..." (Sec.1.(a)), to include such matters as the agency's policy, planning, and program guidance documents, the budget, and any significant changes in the way the staff carries out its regu-latory duties or in.the organization of the staff for those duties.
If the Commission is mistaken in this reading, then further definition of
" policy formulation" should be provided in the draft plan.
The Com-mission would oppose a narrower reading.
Also, the' Commission.would exn9ct.thtln cases of dispute as to whether
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a 1stituted such " policy formula-ould determine the matter.
If i
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.y.. u%4 UNITED STATES
- d bd S NUCLEAR REGULATORY COMMISSION i$ N.')E wAssincTon. o.c. 2osss q CPW}
May 1,1980
.c?oFFics on iwa CHAIRMAN I
Mr. Ronald K. Peterson Office of Legislative Affairs Office of Management and Budget Old Executive Office Building Washington, D.C.
20503
Dear Hr. Pete:
sen:
The Cecmission has reviewed the OMB draft bill "To establish a Muclear Safety Oversight Committee" forwarded by your letter of March 26, 1980. The bill would authorize by statute the committee which the President created on March 18, 1980, in E.O.12202.
Recognizing that the comittee's purpose is to advise the President on the progress of Federal, State and industry actions in response to the recommendations of the President's Cor.uission on Three P.ile Island, the Commission does not object to the draft bill.
The Cox.ission, however, believes that the characterization of the committee's broad function as " oversight" rather than " advisory" could raise questions about the Commission's independence from the Executive Branch.
Therefore, the Commission reco= ends that the accomoanying letter to the Congress include an explicit statement that the committee is not to seek to influence decisions or actions regarding matters before the Commission.
Since we believe the intent of the bill to be in accord with such a limitation on the co=ittee, its explicit statement would not entail a change of the bill or the functions of the committee.
The Commission recognizes that the work of the committee could serve as a basis for actions and proposals by the Executive Branch that might bear upon the Corrission's regulatory activities. We reccmmend the letter accompanying the draft bill contain a statement that the Executive Branch will consult NRC and consider the Comission's views, in developing any such actions or proposals.
We are confident this is what the Executive Branch would do in any event.
Commissioners Gilinsky and Bradford have the following separate corment:
Clearly, the President should have complete freedom to structure a Committee to advise him on nuclear safety.
However, establishing the Nuclear Safety Oversight Committee by statute would undermine the stature and authority of the Muclear Regulatory Com.ission and therefore the public acceptability of its decisions.
Moreover, the integrity of the regulatory process would be brought into question by a statutory Oversight Committee which reports, in part, to the Secretary of Energy.
DOE's long-term waste management facilities will be subject to NRC licensing as will other DOE activities.
The consequences, both real and apparent, cf statutorily establishing the Oversight Comittee can readily be appreciated if one considers the consequences of statutorily establishing a five-person SEC Oversight Committee reporting to the Secretaries of the Treasury and Cc=erce or an eleven-person I.C.C. Oversight Cor:nittee reporting to the Secretaries of Comerce and Transportaticn.
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Mr. Ronald K. Peterson Therefore, Comissioners Gilinsky and Bradford feel that the proposed bill should not be submitted to Congress.
The Comission appreciates the opportunity to comment on the draft bill.
Sincerely, n u ohn F. Ahearne haiman
Enclosure:
Letter of Chairman Ahearne to William M. Nichols, Esq.,
dated Feb. 7, 1980 e
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February 7,1980 r.tAIRMAN '
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William M. Nichois, Esq.
Generai Counsel Executive Office of the President
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Office of Management and Budget Washington, D. C.
20503
Dear Mr. Nichols:
At yo'ur request, the Com:issicn has reviewed the draft executive order whic51 would establish the "Oversignt Comittee en Nuclear Safety." We recognize the imper,.ance of the President's interes; in tracking the Ccmission's actions wnich. respond to the report of the president's C mission on the Accident at Three Mile Island; thus, we understand the reascn for the Com-mittee.
However, we have two minor concerns abcut the C:=i tee.
Our first concern is thaii the draft execu:ive order can be interpreted to create doubts about. the Cc=.ission's inde;endence because the order charac-terizes the. Cemittee's broad function as " oversight" rather than " advisory,"
and because it grants the Cc=nittee largely undefined authority to cbtain information, advice and assistance from other agencies, including the Cem-mission.
Consequently, we would urge tha: the order state explicitly that the C:mittee is no: :: undertake substantive decisionmaking regarding cases j
er ruic akings pending before the NRC.
M:reover, we believe tha.:he Order should specifiy in greater detail (1) the categories of "inf:=ation,. advice or assistance" that the Comi :ee is expe::ed to need, (2) the statutes and the extent authorities which are to be consulted in ::nstruing the terms "::
m a (a) the procedures a.e ici.t ewec Tor Co=1::ee pemi::ed by law,n ano req 0ests directed to the C =ission.
Our second co=nent relates to the ambiguity in the draf t crder about.he Cc=ittee's role with respect to Federal safety research for light water We are unable to determine what activities the Advisory Codi::ee react:rs.
would be expected to perfom, incident : its " rec =ending the generai context of a Federal research prsgram."
The Energy Reorganizati:n Ac: of 1974. specifies the Cc=issien's statu:Ory role in safety research, as well as
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he responsibilities of other Federal agencies (42 USC 55545).
In cicsing, the C0=issien wishes to emphasi e its intention Oc cooperate cresiden: and the C:=i :ee with respa -
. fully and voluntarily with the TMI followup actions. We trust that our c:ments en the craf t executive order are helpful.
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m May 1, 1980 Mr. Ronald K. Peterson Office of Legislative Affairs Office of f!anagement and Budget Old Executive Office Building Washi.ngton, D.C.
20503
Dear Mr. Peterson:
The Comission has reviewed the OMB draft bill "To establish a Muclear Safety Oversight Comittee" forwarded by your letter of March 26, 1980. The bill would authorize by statute the comittee which the President created on March 18, 1980, in E.0.12202. Recognizing that the comittee's purpose is to advise the President on the progress of Federal, State and industry actions in response to the recocnendations of the President's Comission on Three Mile Island, the Comission does not object to the draft bill.
The Comission, however, believes that the characterization of the conmittee's broad function as " oversight" rather than " advisory" could raise questions about the Cornission's independence from the Executive Branch. Therefore, the Co=ission recorrends that the accompanying letter to the Congress include an explicit statement that the cornittee is not to seek to influence decisions or actions regarding matters before the Cornission.
Since we believe the intent of the bill to be in accord with such a limitation on the comittee, its explicit statement would not entail a change of the bill or the functions of the comittee.
The Comission recognizes that the work of the comittee could serve as a basis for actions and proposals by the Executive Branch that might bear upon the Coccission's regulatory activities. We recommend the letter accompanying the draft bill contain a statement that the Executive Branch will consult NRC and consider the Comission's views, in developing any such actions or proposals.
We are confident this is what the Executive Branch would do in any event.
Commissioners Gilinsky and Bradford have the following separate concent:
Clearly, the President should have complete freedom to structure a Comittee to advise him on nuclear safety.
However, establishing the Nuclear Safety Oversight Coccittee by statute would undermine the stature and authority of the Nuclear Regulatory Comission and therefore the public accaptability of its decisions.
Moreover, the integrity of the regulatory process would be brought into question by a statutory Oversight Cormittee which reports, in part, to the Secretary of Energy.
DOE's long-term waste management facilities will be subject to URC licensing as will other DOE activities.
Ik [ The consequences, both real and acparent, of statutorily establishing the Oversight Cor:nittee can readily be appreciated if cne considers the consequences T -
of statutorily establishing a five-person SEC Oversight Comittee reporting to cne decretarTes or tne ireasury anc termerce or an eleven-person 1.c.c. Oversignt 00f oCoerktee.r.eportint.to..the.Secretar.i es.c f.. Correrce. and. Iransucetati cn.
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s Mr. Ronald K. Peterson Therefore, Comissioners.Gilinsky and B; adford feel that the proposed bill should not be submitted to Congress.
The Comissicn appreciates the opportunity to cuanent on the draft bill.
Sincerely.
Original Signed 37 JohnH. Arearne John F. Ahearne Chaim.an E1 closure:
Letter of Chairman Ahearne to William M. Nichols, Esq.,
dated Feb. 7, 1980 Cleared with all Cars.' Offices by SECY C/R avanct }
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