328 
trator of NOAA, issue permits for the transportation and dumping of material as 
described in section 101(a), and subject to the prohibitions of section 102 (a) (1) 
[as amended], if the Administrator determines that..—-" (It seems unnecessary to 
reference the penalties section, §105, but it is important to make clear that the 
prohibitions of proposed §102(a) (1), which derive from the London Dumping Convention, 
are absolute and are not subject to the "prudent and feasible alternative" test. 
Section 101(a) should be amended to add a new paragraph (3) encompassing the 
dumping of material eraneeoreedd by a public vessel or aircraft of the United States, 
or by an agency or instrumentality of the United States [without regard to whether 
it was transported fram a U.S. port or for the purpose of ocean dumping]. Subsections” 
2(c) and 102(a) should be revised to cross-reference §101 (a) - 
This series of amendments is necessary to plug the loophole in the Ocean Dumping 
Law which allows hazardous oily wastes (including surplus jet fuel) to be ocean 
dumped with impunity by Naval vessels and others. Documentation of this problem 
has been furnished to the Oceanography Subcommittee Staff. 
p. 7, line 25; p. 8, line 1: This paragraph (D) is awkwardly worded. Revise to 
read: "The persistence and permanence of the effects of the dumping, and the potential 
for bioaccumulation of contaminants". 
p- 8, line 15: Change "ecosystem, such as those important for the foodchain", 
to "ecosystem, including the human foodchain". 
p. 8, lines 16-18: Revise paragraph (H) to read as follows—"The cumlative 
effect of such dumping on human health and the marine environment when considered in 
‘conjunction with existing and projected pollutant success in the vicinity of the 
dumpsite". 
p- 9, line 1: Change “or" to "and", to read "feasible and prudent". 
