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represents an all-but-permanent writing off of an area of 

 ocean for waste disposal, it is logical that Congress, as 

 representatives of all our citizens, have a role in the 

 irreversible resource commitment that this entails. The 

 parallel to the situation with marine sanctuaries would seem 

 pretty close. 



The flaw in this logic has to do with the realities of 

 the site designation process. The overriding reality is 

 that the vast majority of site designation actions represent 

 merely the ratification of historical dumping practices. 

 Even where new sites are designated, they are designated in 

 close proximity to historical, "interim-designated," 

 dumpsites. Most significantly, as the designation process 

 proceeds, so does the dumping, so that completion of the 

 site designation process seldom represents the dedication of 

 a new areas of the ocean for ocean dumping. 



The inescapable consequence of this is that, making 

 provision for congressional review of prospective site 

 designation actions is unlikely to forestall or even 

 temporarily delay undesirable siting decisions and resource 

 allocations. To the contrary, it will merely perpetuate 

 a status quo of active ocean dumping — either at the same 

 site which is to be finally designated, or at an inferior 

 site which the proposed designation seeks to upgrade. 



Consequently, an across-the-board congressional review 

 process is likely to be counterproductive in the vast 

 majority of cases. On the other hand, a more limited 



