12 



and similar waters in a preferred environmental position at the expense of other 

 portions of our surroundings. 



(d) A system of taxes on massive disposal could be used in lieu of a permit 

 system. At present, such a tax approach would be diflBcult to administer because 

 the relative impact of the different materials dumped is diflBcult to determine. 

 When the variable of dumping locations is added, as would be necessary, the 

 rate of taxation to be assessed for a dumping action seems almost impossible to 

 determine. 



(e) The present permit system could be modified to incorporate a require- 

 ment that the Administrator of EPA consult with the Secretaries of the Interior 

 (Fish and Wildlife Sendee) and Commerce (National Oceanic and Atmospheric 

 Administration) respecting each permit application. Such a requirement would 

 ensure that added environmental expertise was brought to bear on the application 

 of criteria as well as in the development and modification of the criteria. How- 

 ever, the added administrative burden of mandatory comment in each permit 

 application could be overly burdensome. The proposal now gives the Administrator 

 discretion to consult when he deems such consultation to be necessary. 



(4) Relationship tetween local short-term uses of man's environm,ental and the 



maintenance of long-term productivity 



The proposal provides adequate authority to protect the oceans and similar 

 waters from the degradation resulting from dumping wastes in them. In the 

 short term, adoption of the proposed bill would involve (1) markedly increased 

 dredging costs, particularly for areas where the dredge spoil was polluted, (2) 

 increased expenditures for sewage treatment facilities, esi)ecially in the New 

 York area where much undigested sewage sludge is dumped at sea, (3) increased 

 funding demands for both public and private solid waste disposal and research, 

 and (4) development of methods to detoxify or render harmless the nation's 

 outdated chemical and explosive munitions. The oceans would no longer be a 

 least-cost, convenient sink for many wastes. In the short term the proposed 

 bill would increase pressures on land disposal sites and may also contribute 

 to some air and water pollution. 



In the long term, advances in recycling and resource development technology 

 should decrease the pressures placed on land-based disposal, except perhaps in 

 the case of polluted dredge spoil. Presently, alternatives to diked land disposition 

 of such spoil appear limited, but research and management efforts are being 

 stepped up, as evidenced by the program contained in Section 123 of the recently- 

 enacted River and Harbor Act of 1970 (P.L. 91-611) . 



(5) Any irreversible or irretrievable commitments of resources 



The bill would commit Federal funds to the administration of the new regula- 

 tory machinery. It would also require increased Federal and private financing 

 of efforts to develop alternative means of waste treatment and disposal. Certain 

 activities such as dredging would become suflaciently expensive in some cases 

 that the dredging either might not be done to the detriment of navigation, or 

 might take a greater show of Federal or private funds than at present And, it 

 would force industries and municipalities to construct new and environmentally 

 desirable methods of disposing of wastes on land. 



D. COORDINATION WITH OTHEK AGENCIES 



The proposed bill was prepared by the Council on Environmental Quality with 

 the guidance and assistance of an interagency task force including representa- 

 tives of the OflBce of Management and Budget. 



Enclosure. 



