365 



It is the position of AIMS that the foregoing procedure prescribed 

 Iby the President in his Executive Order 11574 should be followed as 

 the most practicable and expeditious method of considering and acting 

 on dumping permit applications. 



To transfer from the Secretary of the Army and Chief of Engineers 

 to the Administrator of the EPA complete authority to issue permits 

 for the disposal of dredged material resultuig from waterwaj^ improve- 

 ment projects, including dredging of access channels and berths to 

 private facilities, would in our opinion seriously jeopardize the eco- 

 nomic justification and progress of essential waterway improvement 

 projects now under study or recommended by the Army Engineers 

 and those which have been authorized by Congress, including perhaps 

 those projects for which funds have already been appropriated. 



Wliile the Corps of Engineers has consistently endeavored through- 

 out the years to develop and maintain a balanced evaluation of the 

 effects of a waterway improvement project on navigation, industrial 

 and economic growth, fish and wildlife, water quality, pollution, con- 

 servation, esthetics, ecology, and other environmental factors, we are 

 of the opinion that because it is the primary function and concern of 

 EPA to preserve the environment, no matter how laudable it may be, 

 EPA will not be in a position to evaluate on an impartial and equitable 

 basis all the foregoing factors related to a waterway improvement 

 ]3roject. 



It is logical to conclude that from the standpoint of EPA, environ- 

 mental considerations will outweigh all others by far, and influence 

 the EPA Administrator to require that dredged material be trans- 

 ported for disposal far at sea or to inland locations. 



In either case, the effect of such a requirement on projects under 

 study or recommended by the Corps of Engineers cr authorized by 

 Congress would be to greatly increase the cost of sr- ^ projects, and 

 thereby jeopardize their economic justification by adversely affecting 

 the benefit-cost ratio. 



"We have been reliably informed that for each 30 miles the dredged 

 material is transported, the cost of spoil disposal is doubled, thereby 

 substantially increasing the cost of the waterway improvement project. 



If the material is ordered to be disposed at sea, it would be necessary 

 to use oceangoing barges. Most of the barges now in use for transport- 

 ing spoil disposal are not constructed for oceangoing operation. The 

 cost of constructing oceangoing barges for spoil disposal at sea would 

 be very substantial and would, of course, be added to the cost of the 

 project. 



Should the EPA Administrator take the above action with respect 

 to disposal of dredged material, this would also seriously affect the 

 continued maintenance of channels at their authorized project depths, 

 since the cost of such channel maintenance would be greatly increased. 



If equivalent appropriation increases are not provided annually in 

 the President's budget and by Congress in Public Works Appropria- 

 tions Acts, the maintenance of channels at their authorized project 

 depths will not be possible, and the estimated return to the Federal 

 Government on its original investment in deepening of the channels, 

 based primarily on savings in transportation costs, will not be realized. 

 It is axiomatic that if channels are not maintained, the cargo-carrying 



