294 
Dr. Knauss. I see what you are asking. EPA is going to be forced 
to come out with new regulations, as I understand it, within a year 
or year and a half. You would like to think that those regulations 
would be based upon adequate research findings. They are going to 
be based upon the best evidence one has at this time. 
I do not think any of us are going to be completely satisfied that 
those regulations that they establish in a year or 18 months are 
going to be the final word. I would hope that they would be contin- 
ually amended and updated as we learn more. 
I guess what I am trying to say is that I would like to think that 
within a decade of solid research and monitoring one would do a 
significantly better job in amending those regulations. 
Mr. D’Amours. John, I am going to have to excuse myself. I have 
to be at another meeting for a little while. Therefore, I am going to 
have to leave now. 
I have a list of questions here which I would like to have submit- 
ted for the record. If there is no objection, I would like to submit 
them to you and ask you to answer for the record. 
Dr. Knauss. I will do my best, sir. 
[Material to be supplied follows:] 
QUESTIONS SUBMITTED BY CONGRESSMAN D’AMOURS AND ANSWERED BY NACOA 
(1) As you know, the NACOA report has been widely quoted in the last year by 
parties looking to expand the use of the ocean for disposing of wastes. In your view, 
do you feel the report has been accurately characterized or have its findings been 
distorted? 
Since its publication in January, 1981, the NACOA report has been referenced in 
several documents including the June, 1981, report, ‘Use of the Ocean for Man’s 
Waste,” and the 1981 ‘National Marine Pollution Program Plan” by the Inter- 
agency Committee on Ocean Pollution Research, Development, and Monitoring 
(COPRDM). The report has been quoted in public statements such as those made 
during these hearings by General Gay, Ms. Hurd, and Mayor Koch. Most signifi- 
cantly, the report was quoted by Judge Sofaer of the Southern District of New York 
in his ruling in The City of New York v. EPA. 
These documents and statements have not distorted the NACOA findings per se, 
but have focused attention on making use of the ocean’s assimilative capacity with 
regard to sewage sludge. This was only one of NACOA’s recommendations. NACOA 
wants to stress the importance of other recommendations such as the reuse and re- 
cycling incentives, the use of broadly representative regional advisory committees to 
advise EPA regional administrators, and the development of a comprehensive cross- 
media approach to waste management. This latter recommendation is particularly 
important, and dependent upon vital research and monitoring efforts. The adminis- 
tration has embraced the concept of assimilative capacity, but has reduced research 
and monitoring efforts in recent budget cuts. The shift to a muiti-media approach, 
which includes use of the ocean, must be backed by marine pollution research and 
monitoring safeguards. 
(2) As you probably know, EPA is recommending a straight reauthorization of the 
present law. Do you feel the current law provides clear direction of the regulation of 
ocean dumping, or is further clarification needed? 
The MPRSA, in its present form, does not provide clear direction with respect to 
the regulation of ocean dumping. NACOA supports certain principles contained in 
the proposed amendments that could provide a measure of clarity: considering pru- 
dent and feasible alternatives prior to ocean dumping, emphasizing reuse and recy- 
cine, careful site designation, expressing the need for research and monitoring, and 
user fees. 
Our nation is in transition from moving toward the elimination of all ocean 
dumping to recognizing that the ocean is one option in a multi-media approach. 
During this transition, responsible departments and agencies, such as EPA, the 
Corps of Engineers, and NOAA, should be given the latitude to develop the scientific 
and regulatory framework that adjusts to this new concept, as it presents a very 
difficult problem in waste management. 
