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against ocean dumping is established by providing that such an al- 
ternative exists whenever an alternative means of disposal will 
have equal or lesser impacts than ocean disposal. 
If we would treat the reference to equal, we would require that 
the alternative means of disposal at least have lesser impacts and 
that the impacts be in terms of significant impacts, not any degra- 
dation as previously defined in the discussion draft. 
In the criteria for feasible and prudent alternative, on the one 
hand you have the alternative and on the other hand you will have 
a feasible and prudent alternative if the alternative can be under- 
taken at a reasonable energy and cost expenditure. 
We think that the statement of these criteria should be in the 
conjunctive and that an alternative should be feasible and prudent 
and have to be considered only where in the context of significant 
adverse impacts it will have less adverse effects than ocean dump- 
ing and where the use of the alternative can indeed be accom- 
plished at a reasonable cost and energy expenditure. 
Both factors should be stated in the conjunctive. 
In our paper our preference would be to retain the concept of un- 
reasonable degradation, to have the ultimate basis for the permit 
decision be on where lies the public interest and to have the deter- 
mination of unreasonable degradation and the public interest be 
determined after a consideration of all public interest factors. 
But if the approach in the discussion draft were to be followed, 
we feel it would require appropriate changes in the definition of de- 
grade and in the criteria for determining feasible and prudent al- 
ternatives as set forth in the statement. 
Mr. Breaux. If ocean disposal was not an alternative that could 
be considered for the Port of New Orleans, where would you go to 
look for a disposal site? 
Mr. Haar. I really have no alternative disposal site because we 
have an area that is highly developed. There is not—the yardage 
that is involved is very, very large. As you know, the last port of 
the Mississippi River involved Plaquemines Parish which on one 
side is a complete wetland for the lower part and on the right de- 
scending back there is a developed area with business, industry, 
and homes, and the whole river is developed, and we really have no 
alternative. 
Mr. Breaux. Most of that area in fact would be surrounded by 
wetland areas and the chances of you dumping dredged material 
from the Mississippi as fill, I will tell you right now, are slim to 
none. 
Mr. Haar. That’s correct. 
Mr. Breaux. You are not going to get any support from Congress 
to enable you to use dredge material as fill in wetlands. It is just 
out of the question. 
Mr. Haar. That’s correct. So we really have no other feasible al- 
ternative. 
I might also point out that the tonnage that Mr. Brinson alluded 
to has a value of $41 billion a year that moves in that lower stretch 
of the river from Baton Rouge to the gulf and that 2 billion bushels 
of grain, some 80 million tons of grain, move in that lower stretch 
of the river every year. — 
