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ocean dumping in a much more efficient way than direct regulation. Instead of re- 

 quiring all dumpers to meet the same discharge requirements as is done under the 

 current regulatory approach, charges would allow individuals to reduce their dump- 

 ing according to their particular pollution control costs. Dischargers with lower 

 treatment costs or alternative disposal costs would reduce the volume of waste 

 dumped more than those with high control costs. In other words, the charge system 

 would take advantage of the differences in the marginal treatment or abatement 

 costs for dumpers. The net effect is reduced overall cost for a given level of ocean 

 dumping reduction. 



Second, the amounts of harmful chemicals entering the marine environment 

 could be reduced by designing a charge system which varied according to the type 

 and concentration of contaminants in the waste. Under such a system innocuous 

 material, such as cannery waste, would be ascribed a low dumping fee. This gradu- 

 ated fee based on contaminant concentrations would create an incentive for dump- 

 ers to reduce the contaminant levels in the waste or reduce the volume of waste 

 dumped. For instance, municipalities with high contaminant loading from industry, 

 would have the incentive to use their legal authority under the Clean Water Act to 

 establish local industrial pretreatment requirements. 



Third, charge system could also be designed to encourage the use of appropriate 

 dumpsites. Dumping at sites with a large capacity to assimilate wastes could be 

 charged less than dumping at accumulative sites. This charge system would reduce 

 the net enviornmental effects of ocean dumping without curtailing the volume of 

 dumping by encouraging waste dumping at appropriate sites. 



Fourth, a charge system could act as an important counterbalance to the growing 

 pressure to dispose our wastes in the ocean. The oceans, unlike our backyards and 

 local groundwater supplies, do not have strong political constituencies. Thus, there 

 often is pressure to dispose of wastes in the ocean because it is the path of least 

 political resistance. Ocean disposal is generally the path of least economic resistance 

 as well. A significant percentage of the cost of land-based disposal is for the land. 

 The oceans, on the other hand, are a common property resource for which our 

 market exchange system does not attach a price for its use. A charge system on 

 waste disposal in the ocean attempts, therefore, to bring this disposal method into 

 political and economic parity with other disposal methods. By so doing waste dispos- 

 al decisions are more likely to be made on the basis of relative environmental risk 

 rather than on political or economic expediency. 



An ocean dumping charge would also provide a source of revenue which could be 

 used for a number of important functions. First, the revenue generated from the fee 

 could help finance the ocean monitoring program. A point repeatedly emphasized by 

 marine scientists is that ocean dumping must be accompanied by a monitoring pro- 

 gram to assess its effects especially if the volumes dumped continue to increase. 

 These scientists reason that, although past studies suggest the ocean is capable of 

 Eissimilating a significant amount of waste, our current knowledge of the marine en- 

 vironment is very rudimentary and incapable of accurately predicting the long-term 

 effects of ocean dumping. The problem, however, is that while dumping is increasing 

 there are no increases expected in monitoring efforts. In fact, cutbacks in federal 

 funding will significantly reduce the amount of scientific work conducted in this 

 area. Revenue generated by an ocean dumping user fee, therefore, could be a vital 

 source of funding for these monitoring programs. 



Second, revenue from dumping fees could help minimize the environmental ef- 

 fects of this activity if it was used to help finance site designation studies. As was 

 discussed earlier the deleterious effects of ocean dumping could be reduced by 

 dumping at sites with the appropriate characteristics. The EPA has failed to make 

 significant progress in conducting the studies necessary to determine appropriate 

 dumpsites. One of the major stumbling blocks has been the cost of these site desig- 

 nation studies. In an era of declining federal expenditures on environmental pro- 

 grams, it seems unlikely that adequate federal funding will be made available for 

 these studies. On the other hand, it seems equitable to require those who make it 

 necessary to conduct the studies in the first place — the dumpers — to incur the costs. 

 Indeed, there is extensive precedent for requiring parties who receive special gov- 

 ernmental services to pay the cost of those services. Financing site designation stud- 

 ies through ocean dumping fees is therefore both necessary and reasonable. 



Third, part of the revenue from the ocean dumping charge could be valuably used 

 to fund research and development of sound alternative waste disposal techniques. A 

 number of environmentally benign and potentially cost effective waste disposal 

 measures have been developed with the help of federal research and development 

 monies. Federal monies, for instance, provides crucial support for the researchers 

 who are developing Ecorock, a road paving material made out of sewage sludge and 



