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Changes in the ocean dumping program are urgently required. 
It is against this background that the AAPA has read with alarm 
the text of certain ‘Discussion Drafts’ of proposed amendments to 
the act which are under consideration by the subcommittees. 
Changes are proposed that would threaten the virtual shutdown 
of ocean disposal of dredged material for many ports, with devas- 
tating impact upon the national, regional, and local economies 
which these port operations serve. 
The amendments of concern to the AAPA include those which 
propose: 
One, a policy allowing “no degradation” of ocean waters. Such a 
policy is unrealistic and unnecessary, and would establish a bias 
against ocean dumping that is unsupported by recent scientific evi- 
dence and experience. 
Two, criteria for permit decision and site designation which do 
not take proper account of all relevant factors affecting the “public 
interest” including such vital port concerns as the need for ocean 
dumping, and the economic, commercial, and governmental consid- 
erations associated with such dumping. 
Such an approach fails to recognize and properly weigh the inter- 
ests of all sectors of the ‘“‘public” in contrast to the limited views of 
mission-oriented, environmental interest groups. 
Three, a requirement for “final” site designation before any 
ocean dumping may be allowed. At a time of budget and manpower 
cutbacks within the Federal agencies involved, such a provision is 
unreasonable and unrealistic, and could effectively halt much 
needed dredging operations. 
Four, permit conditions which would impose costly “special fees”’ 
and affirmative research obligations upon ports as permit appli- 
cants. Such conditions would tax many ports to the point of threat- 
ening continued operations. 
Five, incorporation of prohibitions of the London Dumping Con- 
vention without needed clarification of the relationship between 
convention requirements and the provisions of the act. 
In its prepared statement the AAPA offers alternative language 
of amendment which would avoid the many problems presented by 
these proposed changes and respond to port concerns in a fashion 
that would continue to assure the protection of the marine environ- 
ment, a goal that ports, no less than other interests, value so 
highly. 
The AAPA recommendations may be summarized as follows: 
One, continue the present policy of prohibiting only unreason- 
able degradation of the marine environment and base this determi- 
nation upon a consideration of all factors affecting the “public in- 
terest.” 
Two, provide that the determination of “unreasonable degrada- 
tion’ shall include consideration of the “criteria” to be established 
under section 102, which are to be applied to dredged material per- 
mits under section 103; and further provide that these criteria 
shall include all factors affecting the “public interest” including 
the need for proposed dredging and dumping operations and the 
costs and economic and governmental conditions associated with 
such operations. 
