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NACOA views as promising certain efforts in the administration. NOAA’s Office 
of Marine Pollution Assessment is conducting a series of symposia through fall of 
this year to define unreasonable degradation. EPA is undertaking a comprehensive 
multi-media sludge management project, and is consolidating its marine resources 
programs as part of this project. These efforts, which we recommend that Congress 
carefully monitor, could also contribute to the clarity presently lacking in the 
MPRSA. 
(3) You have noted in your testimony that more needs to be done on research and 
monitoring of ocean dumping and you have supported the imposition of user fees to 
assure funding for these activities. Which research or monitoring activities would 
you like to see specified in amendments to the Act? 
The answer to this question is mainly an expression of my own views. I believe 
that legislation should not specify any particular research and monitoring protocols 
per se, but should emphasize measures that ensure adequate monitoring and assess- 
ment of the adverse consequences of waste disposal in the ocean. I do believe that 
legislation should encourage appropriate Federal agencies to develop long term re- 
search and monitoring programs to detect the consequences of ocean dumping. Fed- 
eral agencies charged with the conduct of research and monitoring programs are 
best equipped to develop site specific research and monitoring concurrent with the 
investigation of generic problems handled through laboratory and field investiga- 
tions. 
(4) NOAA’s 1981 draft five-year plan on ocean pollution found that: “Sufficient 
scientific information is not yet available to widely apply this concept (assimilative 
capacity) on a management basis.” NOAA reemphasized this reservation when it 
testified before us last week. Does this finding diminish your confidence in our abili- 
ty to utilize the oceans for waste management? 
The five year plan does make the statement indicated, but goes on to say that: 
“However, waste disposal policies are changing to allow the cautious and studied 
use of the oceans as a waste disposal medium.” I believe that a decade of systematic 
and imaginative research will greatly increase our understanding of the ocean’s ca- 
pacity. Results to date, however, show that during this time we can look at the 
option of doing some ocean dumping of some kinds of waste. But while doing this, 
the ocean must be protected through research and monitoring. 
(5) Current federal regulatory measures are generally directed at individual pol- 
lutants or activities, yet marine ecosystem degradation results from the accumulat- 
ed impacts of all pollution sources. Do you have any recommendations on how to 
deal with this problem? 
I have three recommendations. First, require permit applicants to know the quan- 
tity and kinds of waste they are discharging or dumping. This provides a means to 
characterize wastes from various sources, which is a relatively easy matter. 
Second, charge Federal agencies with determining the relative importance of 
these contributors by assessing the cumulative effects in a given area from all 
sources. This is a much more difficult endeavor, but can be accomplished through 
viable programs of research and monitoring that give the agency an ability to meas- 
ure the effects from each permit. 
Finally, institute procedures that force a choice of granting or renewing permits 
upon the agency, based on an assessment of adverse effects. 
(6) The MPRSA is the only major environmental legislation which calls for a bal- 
ancing test. Do you have any concerns that this situation might, in fact, cause an 
imbalance in considering alternatives? 
NACOA believes that the approach taken by the MPRSA is the correct one. Some- 
where, the cycle must be broken whereby each successive legislative act further pro- 
hibits disposal in a particular medium. During testimony at the present hearings, 
EPA has expressed the belief that it can begin to rework all of its disposal regula- 
tions to require cross-media balancing for all waste management decisions. NACOA 
supports this effort by EPA. Given the difficulty of orchestrating a cross-media ap- 
proach to waste management through various laws by Congressional committees 
having varied jurisdiction, the solution would seem to lie in close Congressional 
oversight on Federal activities that develop comprehensive regulations. 
(7) You’ve stated in your testimony that you do not believe that NOAA will be 
able to provide research results in a timely enough fashion. If NOAA and EPA were 
adequately funded, could they then provide the needed information in a timely 
enough fashion? 
The statement was in reference to charted objectives and milestones in NOAA’s 
most recent Pollution Program Plan. This plan shows activities such as the prepara- 
tion of policy documents and dumpsite assessment reports arranged sequentially 
through fiscal year 1986. Increased funding could accelerate those processes to some 
