economics over the years; recognizing to a reasonable degree the results
of the history of the reclamation program and the reliance built upon it.
We do not believe that, based on current average ownerships through-
out the program, the average ownership, norm, or common size of farm
under our proposal, would approach the 960-acre figure. On the other
hand, we think there are enough controls in our approach to prevent
the establishment or continuation of large ownerships by absentee
farmers, investors, and non-family corporations.

 EQUIVALENCY
 S. 14 would authorize the Secretary to apply an equivalency formula
to acreage limits for districts having a growing season of 180 days or
less. The purpose of equivalency is to help assure the viability of farms
on project lands where productivity is less, and to assure that owners
of less productive land within a given district would not be at a com-
petitive disadvantage compared to owners of better lands in the dis-
trict. We support the application of equivalency with the 180-day
division, which would separate those projects where equivalency would
be least needed or equitable from those where it may be necessary or
desirable.
 Our approach, contained in Section 7 of our proposed amendments
would authorize the Secretary, at his discretion, to apply equivalency
on a case-by-case basis, if requested by a district after a vote of the
district. We prefer the case-by-case approach which is manageable and
is consistent with past practice in the application of equivalency to
particular projects. We do not believe a system-wide approach, advo-
cated by some, would be manageable or equitable.
 On projects where equivalency has been previously authorized, the
amendments would allow the Secretary to reassess existing equivalency
determinations to conform to the new overall standards of the amend-
ments. The Secretary would retain discretion to determine whether
application of equivalency to a given project or district would be
appropriate.
 A serious problem is present by the suggestion which has been
made a number of times which would require the application of
equivalency based upon the request of a single landowner. This pro-
vision could create serious inequities among landowners and would
cause administrative havoc. We strongly recommend the application
of equivalency only on the request of the district as a whole.

 LEASING CONDITIONS
 We support the purpose of section 7 of S. 14, which would place
limitations on leasing. Leasing can be a worthwhile device for pro-
viding access for new farmers to the reclamation program and for
providing extra income to a small farmer. We also recognize that
leasing has been a principal device for circumventing the requirements
of the law. Consequently we believe leasing should be carefully moni-
tored and controlled to avoid abuses.
 S. 14 would apply acreage limits to leased lands. In Section 9 of
 our amendments, we would amend Section 7 (a) of S. 14 to require that
 both acreage and residency limitations should apply to leasing. Section