524 



Under present conditions we would proceed using the best means 

 available to us. 



In other words, if the EPA standards were not fully developed we 

 would proceed as at present. If they developed further we would 

 modify our work. 



Mr. DiNGELL. Would you have any reason to believe that you would 

 apply any lesser environmental safety standards before the enact- 

 ment of this legislation than you would after ? 



General Groves. I don't really think, sir, it makes much difference. 

 We would use the best that we have. EPA is the source of those stand- 

 ards and that is where we would look to get them. 



Mr. DiNGELL. You would in any event get the standards on water 

 pollution and so forth from EPA ? 



General Groves. Yes, sir. This is inherent in the five point environ- 

 mental statement if nothing else. We would have to coordinate it with 

 the various governmental agencies. 



We would solicit and I am sure we would obtain EPA's comments. 

 We would certainly abide by them. 



Mr. Dingell. What you are saying is that really your behavior, 

 either before or after the enactment of H.R. 4723 insofar as environ- 

 mental protection, will be very little different. 



General Groves. I see no basic difference, except in the time neces- 

 sary to adopt alternate methods. 



General Groves. Now if the law required that the dredged spoil 

 be disposed of at some more distant location, perhaps in an enclosed 

 location on land, say, in any case the cost of the project wouM 

 undoubteidly go up. This can lead you to a mmaber of possibilities 



If we were to follow the one course that might be taken when you 

 run a five-point environmental statement analysis through section 

 102(c) of the act and you arrive at the point where you have certain 

 irreconcilable conflicts and if at that point you decided you would 

 invoke the provisions of section 102(d) which says, in effect, you re- 

 formulate and start over and you come up with a project that does 

 have an adverse environment effect which, to eliminate would result 

 in higher cost, the first question you have to answer is to whom do 

 you charge these higher costs ? 



If you could charge it to mitigation of the environmental damag-j 

 under our present understanding of the system, it would have no 

 effect on the project economics. If, on the other hand, you had to pull 

 them into the project cost and, in effect, charge them to navigatior 

 the cost of the project would go up, the benefits would remain constant. 



So, it is conceivable that the B-C ratio could become unacceptable. 

 This is one possible outcome. 



Another possible outcome, almost a cer'tain outcome, is that if you 

 had to go to sea and if you were going to have to do this on a large 

 scale, we have only a limited hopper dredge capacity, which is already 

 fully employed. It would take us about 5 years to build new dredges. 

 If 3^ou went to the industry, using a scow and dipper, it would take 

 them at least 2 years probably to react. So if this hits you throughout 

 tlie Nation, the effect on Baltimore Harbor might be that the work 

 would stop while we got a new capability. 



This is one of the possible outcomes. It might become economically 

 unfeasible. In any case, it might be delayed or stopped. 



