738 
Through a rational system of user fees, the Federal Government 
has the opportunity to promote both economic and environmental 
efficiency in the allocation and use of resources. The Federation 
has found in our own review of many natural resources programs, 
ranging from grazing to forestry to water resource development, 
hydroelectric power, and so on, that resources that are underpriced 
tend to be overused, and wasted rather than conserved. 
Today, the oceans, a resource held in common for all citizens, are 
underpriced and in danger of being overused for purposes of waste 
disposal. An ocean-dumping user fee would supplement regulatory 
control, deter unnecessary ocean dumping, and spur the research 
and utilization of economical and environmentally sue alterna- 
tives 
I Soeile like to go directly to where we feel the draft user fee pro- 
posal now before the subcommittees is insufficient. We feel it is de- 
ficient in two important respects: 
First, that ocean dumping fees should be levied for all classes of 
material dumped in the oceans, including dredged material; and 
second, that ocean dumping fees should relate to fair market value 
rather than simply keeping the Federal Government whole for its 
administrative expenses of the dump site designation and permit- 
ting program. 
With regard to the first point, we would note that the Merchant 
Marine Committee, in its action last year on the Omnibus Recon- 
ciliation Act, proposed a user fee that would apply to all classes of 
materials. We support this concept, and encourage the committee 
to pursue it further this year. 
Presently there is a bias toward ocean disposal in the Corps of 
Engineers’ dredging program that results from the requirement of 
local sponsors to provide for the lands and easements, rights of 
way, retaining works and stabilization measures required for the 
on-land disposal of dredged material. Local sponsors of Federal 
navigation projects, we feel, should bear a parallel responsibility 
for the costs involved in open ocean disposal. 
Regarding the second point, we feel that an important principle 
for Congress to follow in establishing user fees for ocean dumping 
is that the user should pay according to the benefits he receives 
and the costs imposed on society. The draft proposal now before the 
subcommittee we feel takes an unduly narrow view of the cost to 
society of ocean dumping; that is to say, simply the Federal Gov- 
ernment’s administrative costs, and bears no relationship to the 
fair market value of ocean dumping when compared to other waste 
disposal options. 
We urge the Congress to consider ocean dumping in its larger 
context, and end the practice of offering valuable waste disposal 
sites at nominal cost or at no cost. 
We feel the market value could be established by a review of the 
costs of competing disposal alternatives. It need not be imposed im- 
mediately, but rather could be phased in over a period of years. 
We recognize that the composition of material that is dumped in 
the ocean varies widely, and suggest that consideration might be 
given to allowing a range of administrative flexibility in establish- 
ing the fee based upon the degree of degradation of the marine en- 
vironment. 
