366 



capacity of vessels will be reduced, due to reductions in draft occa- 

 sioned by lack of channel maintenance, thereby causing an increase in 

 transportation cost per ton of cargo. 



Such increased transportation costs are usually reflected in increases 

 in the prices of goods and services to consumers. Thus, it is the general 

 public that will ultimately bear the burden of higher costs involved 

 in the construction and maintenance of waterway improvements that 

 may be caused by requirements imposed by the EPA Administrator for 

 disposal of dredged material far at sea or at inland locations, rather 

 than at far more economical waterway or shore locations adjacent to 

 or in the vicinity of the river and harbor construction or maintenance 

 projects, which for the most part is the present practice. 



The Corps of Engineers has endeavored to follow the latter practice 

 in the interest of maintaining the cost of waterway improvement and 

 maintenance projects at a minimum, thus helping to achieve a favor- 

 able benefit-cost ratio so as to establish the economic justification of 

 improvement projects. 



We could not be sure that the Administrator of the EPA 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, Md. and Va., 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 Har- 

 bor Act of 1970, with the stipulation, 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 project for construction. 



We wish to call attention to the fact that one of the conditions of 

 local cooperation stipulated by the Chief of Engineei^, 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 bj 

 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. 



The Baltimore district engineer in his report (p. 53) on the Balti- 

 more Harbor and chamiels project states as follows : 



Disposal in deep water in the Atlantic Ocean is planned for the material 

 dredged from the Cape Henry Channel while disposal in deep water in Chesa- 

 peake Bay is planned for the York Spit and Rappahannock Shoal Channels. 



The Board of Public Works of the State of Maryland : 



Has given assurance. * * * that 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 esti- 

 mates for the plans of improvement in Baltimore Harior are 'based on disposal 

 of the dredged material in Chesapeake Bay opposite Kent Island below the Wil- 

 liam Preston Lane, Jr. Memorial Bridge. This area is considered to be economi- 

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

 and overboard. A final determination will be made at the time of preparation of 



