665 
Mr. D’Amours. Thank you very much, Captain Swanson. 
Mr. Eidsness, at various points in your testimony you have been 
critical of the lack of specificity in the proposals and yet you pro- 
pose a simplified fee with the more complex questions to be an- 
swered later in your rulemaking processes. 
How can you want us at this point to be more specific and yet 
desire a system that would allow you to be general and to become 
specific in your rulemaking later down the road? 
Mr. Erpsness. Mr. Chairman, that is a very fair question and I 
am glad you asked it. 
Let me back up. I have a strong professional background in the 
public finance area, as a consultant and as a local government offi- 
cial, so perhaps I suffer from knowing too much about the princi- 
ples of local finance and I tend to bring that viewpoint with me 
here to Washington. 
I think it would be desirable to have many of the specifics 
worked out; if not enunciated in a bill now, at least somehow read 
into the record so that it is clear as to how the Federal establish- 
ment is to establish and operate the user fee system. 
I also know there are a number of very significant questions that 
need to be resolved that will take a great deal of time and staffing 
out and public debate such as you are doing now. 
What we suggest is in the absence of an ability to get specifics in 
a bill now—and that may not always be the case—that the EPA 
through its rulemaking process could go through what I perceive to 
be a fairly long and comprehensive analysis of alternatives to de- 
velop a fee system which will answer many of these questions and 
then come back to the committee, or the committees, for their over- 
sight and concurrence on how this system would work. 
As I pointed out in my testimony—and once again this comes 
from my local government perspective—there are three very im- 
portant principles that need to be met and I know that these are 
the principles that you are dealing with in one way or the other. 
One is administrability, two is equity and three is auditability. I 
also want to reiterate that in terms of setting up any financing 
mechanism such as a user fee system at the local level, and I 
assume the same principles would apply at the national level, that 
we would both want to be absolutely certain to know the basis for 
the costs allocation. 
In other words, what costs are eligible to be allocated out to the 
permittees which you are wrestling with, and two, what is the for- 
mula for allocation, and three, how is it to be administered. I think 
it is going to take some time to work those things out and if we can 
do it with you in the statute, that is wonderful. If we can’t, though, 
I think the rulemaking process can do that and you can oversee 
ene work done by the Agency through full public disclosure and 
ebate. 
Mr. D’Amours. Thank you, Mr. Eidsness. 
Captain Swanson, you are saying now, as I understand it, that it 
isn’t appropriate to recover research costs. But isn’t NOAA cur- 
rently supporting other user fee proposals that are pending before 
Congress to recover such costs? 
Mr. Swanson. It is my understanding there are cases where 
NOAA is supporting user fees to support research. 
W967 @Q 29 42a 
