539 



Without really effective control, the problem of ocean disi)osal may become 

 critical within a few years. The amount of waste to be disposed of is growing 

 rapidly. Some of the proposed alternatives to ocean disposal — such as recycling — 

 are still in the developmental stage and are not yet technically or economically 

 feasible. At the same time, the responsibilities of the various jurisdictions in- 

 volved — local, state, national, and international — are poorly defined. 



Clearly, it is time for an effective federal program to deal with the problem. 

 For as the Council on Environmental Quality stated in its Report to the President 

 last October : "The Nation has an opportunity unique in history — the opportunity 

 to prevent an environmental problem which will otherwise grow to a great magni- 

 tude." It may be added that an effective legislative response to the challenge 

 laid down in the Council's report is of great importance not only nationally, but 

 also internationally, particulary at this time. Positive action in this area now 

 would contribute toward U.S. leadership in pollution control in the family of 

 nations, whose representatives wiU be meeting at the United Nations Conference 

 on the Human Environment in Stockholm next year. Ocean pollution is expected 

 to be a major topic at this conference. 



We believe that in order to be effective, federal legislation should embody a 

 system for issuing permits for ocean disposal. Further, the issuance of such per- 

 mits should be based upon consideration of such elements as what types of 

 wastes may be safely disposed of in the oceans, in what quantities, and at what 

 sites and times. Effective criteria need to be developed, along with adequate en- 

 forcement procedures and appropriate penalties for violations. 



Some of the legislation now pending before Congress proposes absolute dead- 

 lines and absolute bans against all ocean disposal. Although research may one 

 day demonstrate that some kinds of waste should not be disposed of at any site, 

 at any depth, in any ocean, research may also demonstrate that some kinds of 

 waste can be so disposed of without damage to the marine ecosystem. The In- 

 stitute therefore would support legislation authorizing the issuance of federal 

 permits, in accordance with carefully developed criteria. 



The logical agency to coordinate such a program would seem to be the Environ- 

 mental Protection Agency (EPA). We believe that EPA's Administrator should 

 develop the criteria on which permits are based. In this task he should develop 

 be required to consult with the National Oceanic and Atmospheric Adminisitraition 

 (NOAA), which has or is developing the relevant expertise. We suggest further 

 that the job of serveillance. enforcement, and general administration be dele- 

 gated to the Coast Guard, which already has the necessary experienced man- 

 power, shore installations, communications network, and ships. 



In summary, the American Petroleum Institute believes : 



1. That the ocean disposal of wastes should be controlled 



2. That the federal level is the only level of government that can achieve 

 effective control 



3. That a system of permits based on carefully developed criteria is far 

 preferable to absolute bans on all ocean disposal. 



4. That in developing such criteria, EPA should be required to consult with 

 NOAA 



5. That the responsibility for enforcement and day-to-day administration 

 should be delegated to the Coast Guard. 



[Telegram] 



Western Oil and Gas Association, 



Los Angeles, Calif., May 11, 1971. 

 R. J. McElroy, 



Chief Clerk, House Committee on Merchant Marine and Fisheries, 

 House of Representatives, Washington, D.C.: 



Regret inability to participate in recent hearings H.R. 4723. Request following 

 comments be added to hearing record which understand still open. 



We are concerned that definition "material" in section 3(c) will prohibit 

 present practice of depositing cleaned drill cuttings (rock chips) to ocean from 

 offshore drilling operations. Also, that present practice approved by Califofmda 

 water quality boards of depositing excess drilling mud which is an oil free and 

 nontoxic clay and water combination into ocean will be prohibited. "Offshore 



