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4. OTHER ISSUES ADDRESSED BY THE DRAFT AMENDMENTS: Expanded Statement of “Findings 
and Policies" (§2, p- 2) 
We especially support the addition of findings relating to: the resource value 
of many ocean-dumped materials; the lack of adequate studies of many ocean dumpsites; 
and the need for a comprehensive research and monitoring plan to ensure the reasonable 
use of the ocean for waste disposal. 
Expanded Coverage of Dumping by U. S. Agencies and Instrumentalities (§4(2), 
p- 6, lines 9 and 10). 
We support the broadening of MPRSA coverage to encompass dumping by agencies and 
instrumentalities of the U.S., whether or not the material was transported from U. S. 
shores "for the purpose of dumping". This change is needed to bring under pea 
the casual dumping (in peace-time) of jet fuel and other materials by naval vessels - ‘ 
and by aircraft, simply because it is considered more costly or more trouble to off- 
or 
load these materials upon return to the home port or base. Unlike the situation for 
private vessels, no link between the dumping and transportation of a material from 
a U. S. port need be established in order for the U. es to assert requiaeeny 
jurisdiction over dumping by a public vessel operating in international waters.: 
The public status of the vessel and the involvement of a U. S. agency or instrumen— 
tality furnish an ample "jurisdictional nexus" for U. S. regulatory control. 
(The language and’location of this provision could be improved, however) . 
Prohibition i ing Known or Su Carcinogens, Mutagens, and 
and Teratogens (§4(1), p. 4). 
We support incorporation in the statute of a tight restriction on dumping carcino- 
gens (and like campounds) similar to that presently contained in §227.6 of EPA's 
Ocean Dumping Regutations. It may well be, however, that a total ban on dumping 
such compounds--as the draft amendments would mandate—(regardless of how low their 
levels may be in an ocean-cumped waste) goes too far. It might be more appropriate 
to include this paragraph within proposed paragraph (E) (p. 5, lines 3-18), so 
