248 
characteristics. Further, the criteria for evaluating permit appli- 
cations includes consideration of specific dumping " 
eeein conjunction 
with all existing and projected pollutant sources on human health and 
the marine environment" [Subsection 102(a)(3)]. Under the existing 
Act, stringent criteria already have been established by EPA in the 
Ocean Dumping Regulations to regulate and minimize any adverse 
environmental and human health effects. 
According to Subsection 102(c)(2)-sites may be designated for a 
period of only six years. Designations may be renewed after repeat-— 
ing the initial site-designation process. (The draft Amendment 
specifies, perhaps incorrectly, that the Secretary of the Army is 
responsible for this renewal activity.) Neither the existing Act nor 
the Ocean Dumping Regulations presently limits the effective period 
it seems more appropriate. The Ocean Dumping Regulations currently 
provide means by which dumping at a site may be modified or termi- 
mated [Subsections 228.10 and 228.11]. 
The draft Amendment would require that while "continuously" monitor- 
ing a designated dumpsite, the EPA Administrator is to evaluate 
whether continued dumping "will degrade, or aggravate the degrada- 
tion" of the dumpsite at the end of the third year. Based on the 
findings of that evaluation, the site designation may be altered 
to either limit, suspend, or terminate the designation [Subsection 
102(c)(3)]. 
13 
