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In our view, the only thing that will give EPA the 
incentive to take its site study and designation responsibilities 
seriously, is a firm statutory prohibition against continued dumping 
at any site that has not been formally studied and designated (perhaps 
following a no more than 2- to 3-year transition period). 
Effect of the Draft Amendments: 
The draft amendments would amend section 102(c) of the Act to 
limit dumping to formally designated sites and to prohibit designation 
of any site until an analysis has been undertaken and completed of 
"the environmental effects which will likely result from the dumping". 
(§ 4(3), p- 9). Bi ut eur ls 
We enthusiastically support this site designation amendment as a 
much-needed reaffirmation of the existing mandates of the Ocean Dumping 
= 
Law and the London Dumping Convention. (The Subcommittees and Committee 
may wish, however, to consider providing a 2- to 3-year phase-in 
period for completion of ongoing site study and designation work to 
: Se 
avoid the dislocation that might well result fromthe shock of an 
abrupt ban on dumping at 92 percent of the ocean dumpsites utilized 
around the country). Some minor wording changes in the language of 
the site designation amendment are suggested later in this statement. 
3. DREDGE SPOILS 
Background: 
Dredged material, the product of navigational dredging, accounts 
for 90 percent of all U.S. ocean dumping and implicates a like percentage 
of all interim-approved ocean dumpsites. Although largely composed of 
sand, clay, and silt, a small but significant percentage of dredged 
material (probably in the range of 10-25%), particularly in heavily 
