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those workshops, together with evolutionary views resulting from changed outlooks 
on waste disposal issues, it is possible to analyze monitoring from several perspec- 
tives: 
There is a category of “compliance monitoring” for which the dumpers and EPA 
have primary responsibility, with EPA administering a program of monitoring con- 
ducted by dumpers in accordance with permit provisions. This effort is oriented to- 
wards specific wastes, concentrations, water quality and other factors associated 
with regulatory matters. 
A second, “site-specific” type of monitoring is required to assist EPA in decisions 
on whether use of given sites should be continued or discontinued, and in what cir- 
cumstances, and to meet NOAA’s concerns on waste interactions, ecosystem re- 
sponse to stress including pollution, and the ability of ocean systems to accept 
wastes under differing conditions. These joint needs can often be met by common 
data, and cooperative programs have been formulated to obtain the required infor- 
mation. One such program involves EPA’s Narragansett Laboratory and NOAA’s 
Northeast Fisheries Center and Office of Marine Pollution Assessment, which pro- 
vides periodic data on the conditions in and about several key dumpsites. Another is 
NOAA’s Northeast Monitoring Program, developed through NOAA’s research in the 
New York Bight and designed in consultation with EPA. In addition, programs by 
NOAA’s National Marine Fisheries Service to assess commercial fish and shellfish 
populations, incidence of disease, reproductive capabilities, etc. also contribute moni- 
toring data since they represent periodic measurements that reveal both natural 
and manmade variations and the reaction of living marine resources to environmen- 
tal stress. 
Finally, NOAA is concerned with broad-scale trends associated with the health of 
the oceans and of its living (and other) resources, and considers the implication of 
ocean waste disposal together with other causes of ocean pollution. Data from all 
monitoring efforts contribute to this ‘environmental monitoring” function, as does 
information from programs of research. The larger time-frame and the broader 
issues in ocean pollution as a whole make it impracticable to define given studies 
solely as monitoring; nevertheless, all meaningful information is intergrated proper- 
ly. In this regard, we believe it important to establish the relationship between mon- 
itoring and research, as noted in the answer to question #3. 
In general, therefore, permittees and EPA have compliance monitoring needs and 
responsibilities, EPA and NOAA are involved in site-specific monitoring related to 
dumpsite management and ecosystem response purposes, respectively, and NOAA is 
concerned with broader environmental issues relating ocean dumping to ocean pol- 
lution overall and the continuing health of the oceans on a mesoscale time frame. 
Question 2. Is there general agreement between the Federal agencies on the moni- 
toring activities that are necessary for ocean dumping? 
Answer. Both EPA and NOAA are in general agreement on the activities neces- 
sary, as described above. 
Question 2(a). How would you define monitoring in terms of what activities would 
be carried out and in what ocean areas for purposes of collecting a fee? 
Answer. Permittee costs for monitoring are incurred by dumpers, but EPA should 
recover some appropriate portion of the administrative costs for maintaining the 
data and reviewing and asserting it. Costs associated with EPA and NOAA site-spe- 
cific monitoring requirements, as described in the answer to question #1, should be 
recovered through user fees. Costs associated with NOAA’s broader environmental 
mission in ocean pollution should not be recovered or be part of the fee process. The 
ocean area of greatest concern in the near term lies off the northeastern coast. Next 
in order of urgency are the southeast, Great Lakes, Gulf of Mexico, and in the 
southwest, northwest, and Alaska. These are relative priorities, based on levels of 
concern, with conditions subject to change. ne 
Question 3. Can you determine the effects of ocean dumping from your existing 
monitoring program? : 
Answer. Properly integrated programs of research and monitoring are required to 
determine and predict the effects of ocean dumping. Monitoring does discern 
changes in ecological conditions and reveal trends in the quality or quantity of sea- 
food catch, incidence of disease in fish and shellfish, alterations in the water 
column, bottom buildup of material, changes in benthic populations, variations in 
dissolved oxygen concentrations, etc. These trends may be of great significance 
whether there is ability to demonstrate cause and effect vis a vis dumping or not. 
But questions such as the degree to which data obtained through monitoring can be 
associated directly with dumping, or how dumping contributes to contamination 
from all sources in given regions, rely on programs of research. Research is also 
needed to devise strategies for monitoring, e.g., the measurements to be taken, their 
