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3. Revise the definition of "dumping in section 3(f) of the Act to clarify 
what is current Corps aeeeiss, namely that carriage of dredged material by 
Pipeline (pipeline dredges) to aa ocean dumping site is “dumping” subject to the 
Ocean Dumping Law (rather than to the Clean Water Act). 
4. Congress should reassert and clarify its intent under section 107(c) that 
the Coast Guard's responsibility to "prevent...unlawful dumping” extends to other 
Federal agencies and that the Coast Guard is not free to allow (as is provided ina 
Memorandum of Understanding between the Coast Guard and the Corps) the Corps of 
. Engineers to monitor its own dimping. 
5. Define "emergencies" of the sort that would justify waiver or relaxation 
of normal public notice or environmental evaluation procedures as "a situation which 
would result in an unacceptable hazard to life if corrective action requiring a 
permit is not undertaken within a time period less than the normal time needed to 
process the application under required procedures." Approval of emergency ocean 
dumping should also be explicitly predicated on each of the following: (1) a deter- 
mination that the emergency admits of no feasible solution other than ocean dumping 
under relaxed procedures; (2) a determination that there is every probability that 
the damage consequent upon such dumping would be less than would otherwise occur; 
(3) a requirement that public notice and environmental evaluation requirements be 
followed to the fullest extent practicable; and (4) where Annex I constituents may 
be present (under the London Dumping Convention), a requirement of advance Department 
of State consultation with the Intergovernmental Maritime Consultative Organization 
(IMCO) and with the Governments of Canada and Mexico to the extent either of the 
latter is "likely to be affected" by the proposed dumping. Dumping without a permit 
should be sanctioned only where unavoidably necessary to safeguard human 
life at sea. In the case of the Corps of Engineers, approval of emergency dumping 
should be required to come from the Chief of Engineers, in consultation with the 
Secretary of the Army. In the case of EPA, approval of the Administrator is 
necessary. 
