613 



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finding that the Draft EIS violates both the letter and spirit of 

 those laws in a wide range of areas. 



The Navy's Draft EIS serves to illustrate the importance of 

 the current moratorium. Further research and studies are essen- 

 tial. As stated in the "Executive Summary" conclusion to our 

 comments to the Navy: 



Without a delay to undertake needed research, it is 

 our view that the Navy's Final EIS will run the likely 

 risk of illegally serving as a pro forma ritual pre- 

 ceding a predetermined result. To correct those defi- 

 ciencies, a supplemental DEIS must be prepared, with 

 its preparation awaiting the accumulation of relevant 

 data during the two-year moratorium period. These 

 corrective measures are necessary to meet both the 

 letter and spirit of NEPA and the concerns of Congress 

 which underly the recent amendments to the Ocean 

 Dumping Act. 



C. Further Legislative Action 



Given our specific concerns in relation to the Navy's 

 consideration of ocean disposal, we support the recent initiative 

 by Congressman Duncan Hunter to amend the Ocean Dumping Act to 

 prohibit ocean disposal of obsolete nuclear submarines (H.R. 

 4117). As part of the justification for his amendment. 

 Congressman Hunter noted that there are "too many questions still 

 unanswered about dumping radioactive wastes in the ocean." Press 

 Release , 12 October 1983. Until there is adequate evidence of 

 good faith compliance by the Navy and other federal agencies with 

 the moratorium's purpose of completing further research, we 

 believe that a permanent ban on submarine scuttling is warranted. 



For this same reason, we believe that this Subcommittee, and 

 the full Congress, should extend the current end-date of the 

 moratorium (6 January 1985) by several years. Such an amendment 

 to the Ocean Dumping Act should direct EPA and other federal 

 agencies (1) to develop a comprehensive research and monitoring 



