13 
Our recommendation is based on the President’s message to Congress on April 
15th and by the President’s action in this area. In that document the President 
urged that we direct our attention to ocean dumping with hope of avoiding “the 
same ecological damages that we have inflicted on our lands and inland waters.” 
(H. Doc. 91-308). 
When the President issued that message, he also announced that the Chair- 
man of the Council on Environmental Quality had been directed to work with the 
Department of the Interior, the Army, other Federal agencies, and State and 
local governments on a comprehensive study of ocean dumping. That study, to 
be submitted to the President by September ist, will include the effects of ocean 
dumping on the environment, the adequacy of existing control authority, the 
extent and effect of the toxic wastes now being discharged, the availability of 
Suitable sites for disposal on land, the alternative methods of disposal, such as 
incineration and re-use, and the innovative techniques for disposal at sea. 
Therefore, we also recommend that no action be taken on H.R. 17603 and 
H.R. 18454 until the Council on Environmental Quality completes its task. 
Our Council is presently sponoring a study by the Massachusetts Institute 
of Technology on the economic aspects of selected ocean related activities and a 
small part of that study will address itself to ocean dumping. The C.E.Q. has 
been following the progress of this aspect of the study. This study will be com- 
pleted in August and we will submit copies to the Committee for their informa- 
tion. The study, of course, will represent the views of the contractor and not 
necessarily of the Government. 
The Office of Management and Budget has advised that there is no objection 
to the presentation of this report from the standpoint of the Administration’s 
program. 
Sincerely, 
EK. L. DIL1on, 
Acting Executive Secretary. 
TENNESSEE VALLEY AUTHORITY, 
OFFICE OF THE BOARD OF DIRECTORS, 
Knozville, Tenn., July 24, 1970. 
Hon. Epwarp A. GARMATZ, 
Chairman, Committee on Merchant Marine and Fisheries, The House of Repre- 
sentatives, Washington, D.C. 
DEAR Mr. GARMATz: This is in response to your letter of May 21 requesting our 
views with respect to H.R. 17603, to amend the Fish and Wildlife Coordination 
Act to provide additional protection to marine and wildlife ecology. 
The bill would add a new section to the Coordination Act to authorize the 
Secretary of the Interior, acting through the Fish and Wildlife Service, to desig- 
nate those portions of the navigable waters of the United States and the sub- 
merged lands underneath into and onto which sewage, sludge, spoil, or other 
waste could be safely discharged. In making such designation the Secretary 
would consider all ecological and environmental factors, including the effect of 
such discharges on the marine and wildlife ecology. For the areas designated for 
such discharges, the Secretary would establish standards for the discharges 
which are designed to insure that no damage to or loss of wildlife resources or 
pollution of the navigable waters will result therefrom. The states may establish 
their own standards for such discharges and if the Secretary finds that the state 
standards are equal to or more stringent than the federal standards, the state 
standards would then apply to such discharge activities within their jurisdiction. 
Discharges of sewage, sludge, spoil, or other waste into areas other than those 
designated by the Secretary would be prohibited. Violation of these requirements 
would subject violators to civil penalties of up to $10,000 for each offense. 
TVA recommends that action on the bill be deferred pending the outcome of 
the study of ocean dumping which the President directed the Council on Environ- 
mental Quality to make in consultation with other Federal agencies. While our 
main interest is in the inland waters which H.R. 17603 covers along with ocean 
