250 
waste materials are being dumped or discharged in close proximity to 
one another (i.e., the New York Bight Apex). Another problem is the 
length of time in which renovation is to be expected. In the case of 
the New York Bight Apex, there are multiple sources of waste mate- 
tials dumped into the ocean and dumping of sewage sludge has been 
continuous since 1924, 
The draft Amendment to the Act does not provide a way to determine 
the potential success of renovation. It would appear to become the 
responsibility of EPA to generate yet another set of regulatory 
criteria responsive to such a difficult determination. 
Federal law should clearly state the intent of Congress and the broad 
scope for pertinent regulations. For laws affecting scientific and 
technical fields, it is important to allow current knowledge to be 
incorporated with ease into regulations. In contrast to giving the 
EPA Administrator discretion to develop regulations, the draft 
Amendment would add very specific requirements, criteria, and duties 
the Act, the flexibility of the Ocean Dumping Regulations, and the 
success of their implementation. The draft Amendment has borrowed 
language directly from EPA Ocean Dumping Regulations [Subsection 
227.6] for part of a list of prohibited materials presented in 
Subsection 102(a). The draft Amendment also includes additionai 
environmental permit application criteria in Subsection 102(a)(3), 
additional interim permit criteria in Subsection 104(c), and 
additional environmental site designation criteria in Subsection 
15 
