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Office. 



2. EPA should review ongoing monitoring efforts and develop both a 

 research plan for determining environmental impacts from dredge disposal sites 

 and guidance for their regional offices on how to monitor for environmental 

 impacts. 



3. One legislative proposal considered during the last Congress was to give 

 EPA permitting authority over ocean disposal permits. We believe this proposal 

 has merit and should be reconsidered. The bifurcation of permitting now between 

 EPA and the ACOE is not serving either the maritime interests or those 

 concerned about the protection the marine environment or the recreational and 

 commercial fishing economy. Also, the current practice of having the Corps 

 permit federal projects amounts to a federal agency permitting itself with little, if 

 any, oversight. 



4. EPA needs a Congressional mandate to develop sediment quality criteria 

 and to develop rational means of applying the criteria to regulate dredged material 

 and prevent continued contamination. Sediment quality criteria offer a means of 

 helping to characterize the potential for sediments to have adverse effects on 

 marine organisms and if applied as water quality standards are applied in 

 developing water-quality based NPDES permits, to offer a stronger means of 

 promoting pollution prevention and the prevention of future contamination. 



5. Substantive public participation needs to be garnered by both the EPA 

 and ACOE to help develop long-term management options that integrate public 

 and private interests. Contaminated dredged material management is going to 

 move into an increasingly heightened stage of crisis management if a redoubling 

 of effort isn't made to find solutions that are environmentally protective and meet 

 the needs of various constituents. 



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