Affairs of the American Association of Port Authorities. I am regu- 

 larly employed as general manager of the Maine Port Authority whose 

 principal office is at Portland, Maine. 



The AAPA is a corporate body whose membership includes all of 

 the public port agencies, boards, commissions or authorities respon- 

 sible for the planning, developm.ent, operation and maintenance of the 

 seaports and seaport facilities along the coasts, bays, rivers and Great 

 Lakes of the United States and its insular possessions. Our U.S. voting 

 members are variously formed as State, city or district bodies respon- 

 sible to the public for the development of commerce and navigation. 



In 1970 the Nation's seaports handled 559 million tons of foreign 

 trade (as versus 417 million in 1969) plus heavy volumes of coastal 

 and insular trade and defense shipments. To help do so efficiently and 

 economically, over 3 billion in non-Federal funds have been invested 

 by local port interests in terminal and cargo Imndling facilities since 

 the end of World War IL 



AAPA interest in H.E.. 4723 is based largely on the fact that seaport 

 facilities are totally dependent on Federal and private channel and 

 pierside dredging, which, in turn, would be affected by the new spoils 

 disposal permitting requirement contained in the subject legislation. 

 The port industry unquestionably supports the goal of improving, to 

 appropriate standards, the quality of the water of the Nation's har- 

 bors, and would approve of strict regulation of dumping of materials 

 such as garbage, sewage, munitions, chemical and various other delete- 

 rious commodities and agents into the waters, navigable or other- 

 wise, of the country. We do wish to question, however, the inclusion 

 of dredged spoil in this category and oppose the transfer of dredged 

 spoil disposal permitting from the Corps of Engineei'S, U.S. Army, 

 wherein it was reaffirmed as recently as Friday, Decemberj-SS, 1970, 

 with the President's Executive Order 11574. 



The handling and disposition of dredged spoil is an engineering 

 matter and should continue to reside with the Engineers, for the better 

 protection of the Nation's environmental well being. There are two 

 basic considerations: (1) where the material is to be placed and (2) 

 how it is to be handled to placement. 



Location of disposal is primarily a planning problem and increas- 

 ingly a long range planning problem, for the community. Large land 

 areas such as are needed for the receipt of spoil, particularly along 

 harbor waterfronts, are both exceedingly scarce and costly in many of 

 the Nation's older, highly urbanized find heavily poj)ulated areas. 

 Some available areas are wetlands which are prohibited for disposal. 

 Some areas are earmarked for recreational or residential use which 

 lend themselves to spoil disposah under carefully managed fill 

 conditions. 



In port areas faced with problems such as these, progress toward 

 locating, obtaining and condemning or helping to finance the con- 

 struction of land containment areas must be measured against very 

 patient long-range standards. Such problems cannot be "ordered" to 

 be solved according to the regulations of a policing-oriented body 

 focused on regulating the outfall of new material and effluents into the 

 waters. 



The handling of spoil material from the dredging site to the con- 

 tainment or disposal area, like plaiming, is an engineering function. 



