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The average cost of permit processing is $8,000. The total cost to the Agency of 
permit processing is dependent on the number of permits processed in the fiscal 
year. 
One possible option for cost recovery would be that costs for all site designation 
activities for section 102 permits be allocated among all section 102 permittees ac- 
cording to tonnage dumped. Projected annual costs would be used to calculate the 
fee at the beginning of each fiscal year. Sites could amortize over a period of time, 
such as 5 years, to make the annual fee more realistic and less burdensome. 
Question. H.R. 6118 specifies that EPA collect a special fee to cover the “‘reason- 
able costs to be incurred by the administrator in carrying out the periodic monitor- 
ing of the site. . .” 
a. Would you subscribe to this type of monitoring fee? 
b. What do you estimate to be the costs of such monitoring to the dumpers? 
c. Should this monitoring be done at all sites? With what frequency? 
Answer. (a) We would subscribe to a user fee which covers the costs of compliance 
monitoring. 
(b) EPA’s fiscal year 1983 budget request includes approximately $1.25 million for 
monitoring activities. The Coast Guard currently spends roughly $350,000 annually 
on monitoring. Of course, this is in addition to the compliance monitoring required 
of the permittees as a condition of the permit. This totals $1.6 million which would 
be allocated to permittees in accordance with a formula, perhaps on the basis of dis- 
posed tonnage. 
(c) Some monitoring activity should be conducted at all sites at which ocean 
dumping occurs. However, the type and frequency of monitoring required varies 
greatly with the type of wasted dumped, the amounts dumped, and the type of site 
used. Appropriate monitoring programs must be developed on a site-specific basis. 
In general monitoring frequency is completed seasonally, quarterly in northern re- 
gions and semi-annually in southern regions and the Gulf of Mexico. 
Question. You support the concept of user fees for sludge dumpers. 
a. Do you also support these user fees for industrial dumpers? 
b. Do you support imposition of these user fees on dumpers of dredged spoils? If 
not, why not? 
Answer. (a) Yes, we support the concept of user fees for all section 102 permittees, 
including industrial dumpers. 
(b) The Corps of Engineers disposes the majority (95 percent) of dredged material 
disposed of in the ocean. Additional dredged material is disposed of by other federal 
agencies, e.g. the Department of the Navy. We do not believe that a fee should be 
charged to another federal agency. 
We understand that the Corps is reviewing the advisability of charging fees to 
aa aa dumpers of dredged material and we will defer to their determination of 
this issue. 
Question. Do you have the ability to carry out your programmatic responsibilities 
in ocean dumping with your current budget request, or would user fees be required 
to maintain your programs in permitting, site designation, and monitoring? (i.e., did 
your budget request anticipate user fees? When did your agency decide to support 
user fees?) 
Answer. We have the ability to carry out our programmatic responsibilities in 
ocean dumping with the current budget request. That request reflects our costs for 
the fiscal year 1983. The request was not based on an anticipated increase in permit 
processing fees or the establishment of user fees. The fees would be used to recover 
the costs which comprise the ocean dumping program (exclusive of research). Once 
Congress authorizes a fee system, the Agency will develop the administrative and 
regulatory resources necessary to implement it. 
The Agency has been reviewing the utility and desirability of user fees for quite 
some time. The result of that analysis, favoring the institution of user fees, was first 
stated publicly in EPA’s testimony before the Merchant and Fisheries Committee, 
Subcommittees on Oceanography and on Fisheries and Wildlife Conservation and 
the Environment, on March 18, 1982. 
Question. The Ocean Dumping Act provides a scientific and regulatory framework 
for evaluating the comparative environmental effects of waste disposal in various 
media. Obviously, if user fees in one media are set at high enough levels, user fees 
become a mechanism for shifting disposal away from that media. 
(a) What level of user fees would be sufficient to shift sewage sludge disposal away 
from the ocean and toward other media? Would this be a rational way to utilize 
user fees? 
