662 
Again, this subsection is not definitive as to the frequency of as- 
sessing these user charges. Is the Agency expected to recoup its 
costs on an annual basis or a multiyear period? Second, the term 
pro rata can be subject to many interpretations, chief among them 
pro rata by volume or pro rata by some formula accounting for 
volume and waste toxicity. 
Subsection 104(b)(8)(B) sets aside a fee for sewage sludge dispos- 
ers to support the financing and operation of an Ocean Waste Man- 
agement Commission. The organization and purpose of this Com- 
mission appears as an amendment to H.R. 6324. 
We are opposed to this fee for two reasons. First, the fee will be 
used by the Commission to conduct and evaluate sewage sludge 
research, yet no such research fund is defined for other ocean 
disposers. 
The Agency believes that this is a discriminatory fee if imposed 
solely on sewage sludge disposers and believes that fees to cover all 
necessary ocean dumping research should be assessed on all ocean 
dumpers. 
Second, we are opposed to the creation of yet another Govern- 
ment body engaged in marine research and policy. As I stated ear- 
lier in my testimony, the dumping program is already administered 
by four agencies—EPA, NOAA, COE, USCG—and the National Ad- 
visory Commission on the Oceans and Atmosphere [NACOA] is also 
available to provide its counsel and advice. 
Let me expand on our concerns with the establishment of such a 
Commission. 
Our fundamental problem with the proposed Commission is that 
its stated purpose is duplicative of the purposes of other agencies 
and commissions. The scope of the Commission is defined as adviso- 
ry and research. The Federal Government already has three major 
agencies involved in marine environmental research: NOAA, EPA, 
and COE. They all have acquired considerable expertise over the 
years. Furthermore, we do not believe that adding another agency 
to the bureaucracy is good public policy. 
We recognize that Congress is interested in having permittees ac- 
tively involved in the Government’s research activities and we en- 
tirely agree that permittees should have some input to research 
priorities. We can accomplish this purpose through existing mecha- 
nisms. 
It should be noted here that much of the Federal research pro- 
gram is carried out or reviewed by independent scientists from in- 
stitutions such as the Scripps Institute of Oceanography, the Woods 
Hole Oceanographic Institution and Cal Tech. We believe that by 
relying on such a wide base of scientific opinion, we can insure that 
the proper scientific basis is developed and used for our decision- 
making. 
Similarly, NACOA’s charter establishes it as an advisory council 
to Congress and the agencies. Its scope includes that of sewage 
sludge, as well as other issues. We believe that this broad scope is 
appropriate for an advisory body, as it promotes the recognition of 
other interlocking issues. Focusing on a single issue can result in 
the advisory body assuming the posture of an interest group, 
rather than adviser. We believe that an advisory role is important 
to good policymaking, and in that regard the Congress has estab- 
