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Question 6. Are changes needed in the Ocean Dumping Act in order to preclude 
the dumping of harmful wastes and, if so, why? 
Answer. The Act has been in force since 1973. Except for dredged material, no 
permits have been issued to any waste generator except those already using the 
ocean prior to 1973. The Act is probably adequate to discourage ocean-use if proper- 
ly interpreted and implemented, although there is always room for minor improve- 
ment. 
Question 7. Will the effect of the Sofaer decision be to allow more coastal cities to 
go back to the oceans for disposal of their wastes because of the “economic” consid- 
erations? 
Answer. While we cannot foretell the ramifications of legal decisions, it appears 
the Judge Sofaer decision implies that all consequences of all alternatives to sludge 
disposal be considered prior to prohibiting one (ocean dumping). Economics will be 
one consideration in this process. 
Question 8. Your budget justification for substantial decreases in your ocean 
dumping program indicates that many of NOAA’s activities focus on local or region- 
al projects which should be carried out at that level. Will the states take responsibil- 
ity for their ocean dumping activities that may affect another state’s waters or 
marine environment? 
Do the states have the expertise or appropriate research vessels to carry out these 
activities? 
Answer. We do not know if states will continue projects initiated by NOAA. Some 
states have expertise and access to vessels, if they house oceanographic institutions 
or universities with oceanographic departments. However, all the particular exper- 
tise required in a given situation may not be within the state. There are, to our 
knowledge, no state government agencies comparable to NOAA in concept or over- 
all expertise. Further, difficulties may arise concerning problems cutting across 
state boundaries and jurisdictions. 
Question 9. Is it possible to determine the economic value of a fishery resource 
and its food source within a designated site area? 
Answer. It is possible to assign an economic value to a fishery resource with limit- 
ed movements (particularly sedentary shellfish) within a designated site area. It is 
also possible to assign an economic value to the portion of a more mobile fishery 
resource which migrates through a particular site, but the extent of resource loss or 
degradation will generally be unknown in such migratory cases. 
The economic value of resource food sources within a site area can be assigned 
only arbitrarily, whatever rationale is employed. While such arbitrary values may 
be useful for perspective, they may have little relationship to the broad social value 
of the food resource. 
Question 10. Do we know the long-term sublethal effects of pollutants, individual- 
ly or in combination, on marine species throughout the food chain? 
Answer. Our knowledge of long-term sub-lethal effects of pollutants is limited but 
increasing rapidly. For contaminants such as PAHs, specific PCBs, several heavy 
metals, and certain gross petroleum hydrocarbons, we do know something about 
long-term sub-lethal effects. For example, exposure to certain PAHs or petroleum 
hydrocarbons results in implementing the production of mixed function oxidases. 
These enzymes break down certain organic molecules into simple constituents. We 
also know that certain materials such as a range of the DDTs are also broken down 
into simple molecules which may be even more toxic than the parental molecules. 
We know, further, that a range of marine organisms, when exposed to toxic metals, 
develop an immunity to them. Equally important, we are beginning to understand 
something about the ability of marine animals to accumulate low levels of pollut- 
ants through increased enzyme levels, development of partial immunity, or other 
mechanisms. 
Finally, we know from laboratory studies, and more recently from certain field 
studies, that exposure to very low levels of the aforementioned contaminants can 
result in impaired reproduction, survival of eggs and larvae, and even mortality in 
adult organisms. 
Question 11. Are you under any time constraints in providing EPA with new in- 
formation or analyses in support of their site designation program? 
Have you requested sufficient funds to produce scientific information in time to 
meet decision deadlines? 
Answer. We understand that there is an EPA requirement to designate approxi- 
mately 130 dumpsites, about 124 of which are dredged material sites. NOAA re- 
ports, data, and comments were used in designating those sites which are now legal- 
ly established. 
