130 
ing projects, but would be essential in the planning process for deeping projects for 
deep-draft navigation to insure that impacts to the total environment are mini- 
mized. 
Mr. Chairman, in your letter to the Chief of Engineers requesting that the Corps 
present testimony there today, you also requested our comments on, and suggested 
changes to, a discussion draft of Ocean Dumping Act amendments prepared by your 
staff. However, as we have only recently received these draft amendments (March 5, 
1982), we are not in a position to provide you with a detailed assessment of antici- 
pated impacts without formal coordination within the Administration. 
In summary, the predominant scientific opinion, including that of NACOA, which 
was established to provide advice to the President and Members of Congress, is that 
the ocean is an environmentally acceptable disposal option for dredged material. 
Further, available scientific research clearly indicates that the ocean disposal of 
dredged material should be regarded equally viable to any other disposal alternative 
from an environmental perspective, and that ocean disposal should not be disregard- 
ed for reasons other than scientific knowledge of unacceptable effects upon dump- 
ing. The point has been fully recognized by representatives to the LDC and is re- 
flected in the fact that the LDC has developed a scientifically-based set of broad 
dredged material exclusions from the mandatory biological and chemical testing for 
prohibited materials that are required for other waste materials proposed for ocean 
disposal. 
This concludes my formal statement, Mr. Chairman. We will be pleased to repond 
to any questions you may have. 
General Gay. I brought with me today to assist in answering 
questions, Colonel Max Imhoff, who is the Commander of the 
Water Resources Support Center; and his staff biologist, Mr. David 
Mathis; I also have Dr. Robert M. Engler, the corps’ scientific advi- 
sor to the U.S. Delegation of the London Dumping Convention and 
also chairman of the corps’ Ocean Dumping Technical Committee; 
Mr. Charles Calhoun, project manager for dredging operational and 
technical support of the corps’ environmental laboratory; and, to 
perhaps answer questions that might arise on New York and 
dredging operations in New York our district engineer from the 
New York district, Col. Walter M. Smith. 
The Corps of Engineers in fulfilling its mission to maintain, im- 
prove and extend waterways of the United States is presently re- 
sponsible for approximately 25,000 miles of Federal inland water- 
ways and over 1,000 harbors. These channels and harbors are of 
vital importance to the economic well-being of this Nation. The 
corps, acting on behalf of the Secretary of the Army, is also respon- 
sible for issuing permits for the transportation of dredged material 
for the purpose of ocean disposal under section 103 of the Ocean 
Dumping Act, as well as for the discharge of dredge or fill material 
under section 404 of the Clean Water Act. 
Although the corps does not issue permits for its own activities, 
the corps is required by law to comply with the same criteria 
which would apply to a permit applicant. 
Since 1973, an average annual volume of 61 million cubic yards 
of dredged material, or about 20 percent of the total quantity 
dredged under Federal jurisdiction each year, has been disposed in 
the ocean. On the basis of volume, dredging is by far the largest 
single source of materials disposed in the ocean. 
Under the existing ocean dumping criteria, ocean disposal of 
dredged material is regarded as a last alternative and is then al- 
lowed only after these materials have undergone and passed toxic- 
ity and bioaccumulation laboratory tests. 
Under the Ocean Dumping Act, EPA is assigned lead responsibil- 
ity for designating ocean disposal sites. This site designation re- 
