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What other recommendations would you make to improve the 

 regulatory process? 



ANSWER Mr. Rees: We anticipate that the Corps and EPA will very 

 shortly begin a joint effort to revise the EPA implementing 

 regulation for the Ocean Dumping Act (40 CFR 220-228) . At this 

 time, we do not anticipate that additional changes in the Ocean 

 Dumping Act would be necessary and that reguired programmatic 

 changes which we have identified can be made through the 

 rulemaking process. 



Do you think that Title V adequately addresses the 

 problems associated with the regulatory process? If not, why? 



ANSWER Mr. Rees: Title V may only serve to exacerbate rather 

 than improve the regulatory process. Implementing a regulatory 

 process for which two Federal agencies essentially have been 

 assigned joint and equal responsibility will be extremely 

 difficult at best. As noted in a previous response, the 

 procedural detail in Title V is now codified and reduces 

 administrative flexibility, should we find implementation 

 difficulties. 



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