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We prefer to negotiate the monitoring requirements of our 
NPDES and Section 102 permits directly with the EPA on a case- 
by-case basis, and would not care to see EPA, or NOAA, carrying 
out that function in-house. Each geographic location, and each 
waste stream, requires it own carefully tailored monitoring pro- 
gram. We simply do not see any value in handing a Federal agency 
a "blank check", with the amount to be paid by coastal sewerage 
agencies, for them to use in creating yet another Federal 
bureaucracy with no consideration for cost-effectiveness. I 
suppose that what we are saying is: thanks for offering to help 
us out, but we would rather do it ourselves. 
One aspect of the proposal that troubles us is the frequent 
reference to "reasonable costs". We have no basic quarrel with 
the concept and appreciate the difficulty of drafting tighter 
language. However, we have lived through situations in which 
there are genuine differences of opinion as to what is reason- 
able. Since under the proposed arrangement, the public funds 
of our agencies will have to be spent for the various activities, 
we propose that there be a mechanism for resolving any such 
questions without the necessity of litigation or other lengthy 
and expensive administrative hearings. We believe an arbitra- 
tion arrangement should be built into the language of the pro- 
posed bill; if the Ocean Waste Management Commission is created, 
we believe it would be an appropriate body to resolve any ques- 
tions that may arise on what constitutes "reasonable costs". 
If the Commission is not established, a satisfactory arrange- 
ment would be to have the Federal agency and the local agency 
each designate a representative who would agree on a third 
member of the reviewing group. We do not anticipate great pro- 
blems over this matter but I believe you can understand our 
desire not to be compelled to undertake unnecessary or even 
Marginal activities without some opportunity to challenge 
the proposed assignments. 
Our position on user fees for research on ocean utiliza- 
tion and disposal of sewage sludge is different from that on 
monitoring. We have long expressed our concern with the cutbacks 
at the Federal level in ocean pollution research, particularly 
with the drastic cuts proposed for NOAA's program in FY 1983. 
One of our member agencies, Orange County Sanitation Districts, 
has already joined with NOAA in co-sponsoring research in this 
area at the California Institute of Technology, with NOAA pay- 
ing two-thirds and the Sanitation Districts paying one-third. 
Because we strongly believe that more research in this area 
should be done, and we recognize the potential benefits to our 
ratepayers, we Support the proposal that an independent, re- 
search-oriented Commission be created, and funded by fees 
collected from those who use the ocean for sewage sludge. 
