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Show 532 NEW YORK bers, 9 of whom are heads of State departments or agencies desig- nated in the act and 7 of whom are appointed by the Governor.17 The seven members so appointed cannot be employees of any State department or agency, and must have professional training or ex- perience and attainment so as to be "qualified to analyze and interpret matters of environmental concern."18 Four of the appointees may be from fields of public health, natural sciences, urban studies, or such other disciplines as may relate to environment, ecology, or natural resource management; but the remaining three appointees are re- quired to represent specific interests, with one representing the con- servationists of the State, one representing industry and "as such shall be employed by a manufacturer or public utility," and the third representing agriculture.19 The most striking feature of the act as it relates to the board is the very limited authority conferred. While the statute provides that the board must meet at least quarterly, may determine rules for its own procedure, and may ap- point an executive secretary to serve as its administrative agent, the only real authority of the board is to review environmental standards and criteria, and no standard or criterion can become effective unless and until it is approved by the board.20 Beyond that, the commis- sioner seems to have control over formulating policy without any veto power in the board, and there seems to be no requirement for the commissioner to submit the statewide environmental plan to the board for its review, comments, or recommendations. However, it should be noted that the act provides that the commissioner shall be chairman of the board,21 and that the board "shall exercise and per- form such other functions, powers, and duties as may be requested by the chairman."22 The latter provision, rather than conferring any powers on the board, seems to confirm the rather comprehensive power of the commissioner. As a related matter, the 1972 act also preserves and continues in existence the council of environmental advisers in the executive department.23 The council seems to operate independently of the de- partment of environmental conservation, and is not required to co- ordinate with either the commissioner or the board, but has the primary duty of advising the Governor on matters of environmental policy affecting the State.24 The environmental conservation law is quite comprehensive, run- ning 855 pages as codified, and covering a range of subjects beyond water resources. Water resources is the subject of article 15 and water pollution control is the subject of article 17, and the highlights of those articles will be mentioned below, but space does not permit discussion of some water-related subjects such as fish and wildlife (art. 11) and marine and coastal resources (art. 13). "ECL sec. 5-0101. "Id. 18 Id. soECL sec. 5-0107.2. »ECL sec. 5-0101. ^BCL sec. 5-0107.8. »»ECL sec 7-0101. »ECL sec. 7-0107. |