672 
The ocean dumping law provides a scientific and regulatory 
framework for evaluating the comparative environmental effects of 
waste disposal in various media. As a matter of fact, that is what 
the Federal district court last fall mandated be done, because the 
Federal district court said that you couldn’t establish when ocean 
dumping was unreasonable unless you knew what the comparative 
costs and the comparatively environmentally degrading effects 
were from other kinds of solid and human waste disposal processes, 
such as incineration and landfill. 
If user fees in one medium are to be set at high levels, then user 
fees become a mechanism for shifting disposal away from that 
medium. The medium which you are prejudicing by the high fee 
structure could very well be the least environmentally degrading 
method of disposing of sewage sludge available. 
So the question is, what level of user fees would be sufficient to 
shift sewage sludge disposal away from the ocean and toward other 
media such as incineration or landfill? Would this be a rational 
way to utilize user fees? Would the application of user fees thwart 
or impede our effort to get sewage sludge disposers to seek the 
least environmentally degrading method of sewage sludge disposal? 
Do you see what I mean? Is it upsetting the formal array of 
market forces, particularly the concern to seek out the least envi- 
ronmentally degrading way of disposing of sewage sludge and 
maintain this user fee structure for us to do things that were un- 
necessarily degrading to the environment? 
Now, I have asked all my questions and would be happy to have 
you proceed to speak to them. 
My 5 minutes have expired. Thank you very much, Mr. Chair- 
man. 
Mr. D’Amours. You are welcome, Mr. Scheuer. 
[The following was received for the record:] 
QUESTIONS OF Mr. SCHEUER AND ANSWERED BY EPA 
Question. If I understand you correctly, you favor collection of user fees to cover 
the costs of permit processing, site designation, and limited monitoring, but oppose 
fees to fund research programs. 
a. Please break down your fiscal year 1983 budget request for activities that you 
are recommending be covered by user fees. Specifically, 
What is the cost for site designations proposed to be covered by user fees? 
What is the cost for permit processing? 
How would you propose that cost for site designation allocated among users? 
Answer. The Agency’s proposed user fee system would seek to recover those costs 
directly related to the administration of services rendered to permittees. These func- 
tions include permit processing, site designation, and those monitoring activities 
conducted in direct support of the operating, as opposed to general research, pro- 
gram. 
Site designation includes the tasks of site surveys, environmental impact assess- 
ment preparation, and actual designation proceedings. The fisal year 1983 budget 
request is approximately $2.5 million for site designation and monitoring activities. 
Approximately half of allocated funds will be used to designate dredged material 
disposal sites for use by the Corps of Engineers. The Agency does not propose to 
recoup any funds expended in support of the COE dredged material disposal pro- 
gram through user fees; these activities would continue to be funded through gener- 
al revenues. 
A breakdown of total costs for site designation and monitoring activities follows: 
Vessel Operation, $800,000; Scientific Party, $400,000; Laboratory Analysis, $900,000; 
Report Preparation, $400,000. 
