750 
over the “reasonableness” of particular items should be resolved by binding arbitra- 
tion. 
Question 3. Are your agencies willing to collect the information necessary for EPA 
to designate a site for the dumping of sewage sludge? 
Answer. Under current regulations, if a new site is proposed for ocean dumping of 
sewage sludge, the entity making the proposal (or requesting a permit to dump 
there) is required to provide sufficient data to EPA for a designation decision to be 
made. We see no reason to change this system. 
Question 4. You have indicated you would be willing to share the monitoring costs 
with the Federal Government but that you would be opposed to EPA or NOAA 
doing any routine monitoring. Why? 
Answer. We are not opposed to EPA or NOAA engaging in monitoring activities. 
We believe, however, that distinction must be made between ‘“‘compliance’”’ monitor- 
ing, which should be carried out by the permittee with spot-checking by the EPA, 
and the term “monitoring” as it is used by NOAA. Their “monitoring” (NOAA’s) is 
our “research” (the permittees). We are willing to share in “monitoring” by NOAA, 
as part of their Title II responsibilities, or in similar activities by EPA. The problem 
here is simply one of semantics; there are too many interpretations of the word 
“monitoring.” 
Question 5. What range or costs do you feel are reasonable if EPA were to assess 
your agencies a fee for: 
a. processing the permit? 
b. designating a dump site? 
c. monitoring ocean dumping at the site? 
d. research on the long-term effects and alternatives? 
Answer. EPA has indicated in its testimony before Congress this year that a § 102 
permit processing fee would run about $8,000.00. That seems reasonable to us. We 
do not have any idea what EPA’s administrative costs of site designation are, so we 
cannot respond to part (b) of your question. We are flatly opposed to the assessment 
of user fees for “monitoring” and “research,” parts (c) and (d) of your question, as 
we are convinced that such a fee could become a “blank check’’ to be applied to 
whatever program costs the agency chose to include. Without some control over the 
monitoring and research expenditures in the hands of the permittees, we are con- 
cerned that the funds raised in this manner might be wasted by EPA. This is the 
reason that we support the Commission proposal; we need to be assured that our 
money will be spent for useful and constructive purposes. 
Question 6. If there is no Ocean Waste Management Commission, what would 
your agencies like to see as an arbitration mechanism to resolve the differences be- 
tween your agencies and the Federal agencies regarding what costs are reasonable? 
Answer. Even with the Commission, we refer you to the procedures of the Ameri- 
can Arbitration Association. We gave a copy of their procedures to Ms. Barbara 
Wyman of the Committee staff. 
Question 7. What amount do you feel is necessary for ocean dumping research 
each year and how should it be divided between the permittees and the Federal 
Government? 
Answer. We believe that an overall effort in the range of $5 to $6 million per 
year, on sewage sludge effects alone, is adequate for research and NOAA-defined 
“monitoring,” if it is properly directed. Of that amount, we have expressed support 
for the Commission proposal, in which the permittees would put up approximately 
one-third of the total, or $2 million per year. 
COMMISSION 
Question 8 With regard to the Ocean Waste Management Commission proposal, 
do you have any recommendations concerning the qualifications of the Commission- 
ers or the Advisory Committee? 
Answer. We see two problems in the draft language, in the qualifications and con- 
flict-of-interest provisions affecting Advisory Committee members. First, the rigid 
requirement that six disciplines be represented at all times on the Committee is un- 
workable. There is no way to predict the year-to-year variations in the Commission’s 
priorities, and it would be a mistake to tie the Commission’s hands on picking the 
type of expertise it really needs. We suggest three changes; first, that the Commis- 
sion choose, “to the maximum extent practicable’ Committee members from among 
the listed disciplines; second, that physical and chemical oceanography be split into 
two categories, rather than one, and third, that ‘marine sediment transport geolo- 
gy” be changed to ‘“‘marine geology.” 
