361 



would give appropriate consideration to project cost factors in the event the 

 authority to issue dumping permits is transferred from the Secretary of the 

 Army and Chief of Engineers to the EPA Administrator. 



A case in point, which is typical of other projects, is the Baltimore Harbor 

 and Channels, Maryland and Virginia, navigation improvement project which 

 would primarily provide for the deepening of the channels through Chesapeake 

 Bay into Baltimore Harbor from 42 to 50 feet mean low water. As you are aware, 

 this project was authorized by the River and Harbor Act of 1970 with the stipu- 

 lation, however, "that construction shall not be initiated until approved by the 

 Secretary of the Army and the President" This project has not yet been cleared 

 by the Office of Management and Budget, including the Bureau of the Budget. 

 Until it is, the Secretary of the Army and the President cannot be expected to 

 approve the pi-oject for construction. 



We wish to call attention to the fact that one of the conditions of local coopera- 

 tion stipulated by the Chief of Engineers, which has been accepted by the states 

 of Virginia and Maryland, is that these States will "provide without cost to the 

 United States * * * (suitable areas determined hy the Chief of Engineers to be 

 required in the general public interest for initial and subsequent disposal of spoil, 

 and also necessary retention dikes, bulkheads, and embankments therefor, or the 

 costs of such retaining works" (emphasis supplied) . 



The Baltimore District Engineer in his report (page 53) on the Baltimore 

 Harbor and Channels project states as follows : "Disposal in deep water in the 

 Atlantic Ocean is planned for the material dredged fi*om the Cape Henry Chan- 

 nel while disposal in deep water in Chesapeake Bay is planned for the York Spit 

 and Rappahannock Shoal Channels." The Board of Public Works of the State of 

 Maryland "has given assurance, ***** tlmt disposal areas will be provided 

 in the waters of Chesapeake Bay opposite Kent Island, or in overboard or diked 

 areas near Baltimore Harbor, or in combinations of the two areas. The cost 

 estimates for the plans of improvement in Baltimore Harhor are based on dis- 

 posal of the dredged material in Chesapeake Bay opposite Kent Island heloio 

 the William, Preston Lane, Jr. Memorial Bridge. This area is considered to be 

 economically equal to and representative of all the potential disposal areas, both 

 diked and overboard. A final determination will be made at the time of prepara- 

 tion. The effect of such action would be to substantially increase the cost of the 

 method of dredging" (Emphasis supplied). 



According to the report of the District Engineer, the above plans for disposal 

 of dredged spoil have been coordinated with the proper Federal agencies and 

 concerned agencies of Virginia and Maryland. 



The total estimated cost of the Baltimore Harbor and Channels improvement 

 project is about $100,000,000 resulting in a benefit-cost ratio of 2 to 1. I would 

 like to iwint out, however, that if H.R. 4723 is enacted in its present form, the 

 Administrator of the EPA would then have the authority and power to revise the 

 above spoil disposal plans outlined in the report of the Baltimore District En- 

 gineer as approved by the Chief of Engineers, and require that some or all of the 

 dredged spoil be transported for disposal at sea or some other more costly loca- 

 tion. The eiffect of such action would be to substantially inci*ease the c-ost of the 

 project. This would adversely affect the benefit-cost ratio and might endanger the 

 economic justification of the project. This could ci-eate a problem with respect 

 to clearance of the project by the Office of Management and Budget for approval 

 by the President and Secretary of the Army for construction. 



xA.s I have previously stated, the U.S. Army Corps of Engineers is making every 

 effort in consultation with the Environmental Protection Agency, Department 

 of the Interior, Maritime Administration and other Federal, State and local 

 government agencies to determine suitable locations for the disposal of dredged 

 material resulting from waterway improvement projects. In our opinion, there is 

 nothing to be gained and much to be risked from the standpoint of the formula- 

 tion and progress of the waterway improvement program if the authority to 

 determine spoil disposal sites is transferred from the Secretary of the Ai-my and 

 Chief of Engineers to the Administrator of the EPA. We therefore strongly re- 

 affirm our recommendation that H.R. 4723 be amended to provide that the 

 authority to issue permits for transportation and disposal of dredged material 

 resulting from waterway improvement projects shall be retained by the Secre- 

 tary of the Army and Chief of Engineers. 



The Lake Carriers Association, representing companies operating U.S. flag 

 shii>s on the Great Lakes, has endorsed our position and recommendation with 

 respect to H.R. 4723. 



62-513—71 24 



