11 
We recommend deferral of the bills because of two recent developments which 
indicate the concern of the Administration for the ecological effects of ocean 
dumping. On February 10, we sent to the Congress a legislative proposal which 
was introduced as H.R. 15905. The bill, in part, directs the Secretary to estab- 
lish water quality standards for the waters of the contiguous zone. In addition, 
the bills would make subject to abatement water pollution activities in the 
waters of the contiguous zone which adversely affect water quality in the 
territorial sea, and pollution of the seas resulting beyond the contiguous zone 
from discharge of material transported from United States territory. 
In a message to the Congress on April 15, the President urged that we now 
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). He announced that the Chairman of the Council on Environmental Quality 
had been directed to work with this Department, 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 1, will 
include effects of ocean dumping on the environment, adequacy of existing con- 
trol authority, extent and effect of the toxic wastes now being discharged, avail- 
ability of suitable sites for disposal on land, alternative methods of disposal, 
such as incineration and re-use, and innovative techniques for disposal at sea. 
There are also substantive grounds on which to question the premises of the 
bills. Although the bills may have the effect of improving the situation in the 
New York Bight area, they may also have the effect of simply transferring the 
problem to another location. The bills would permit dumping close to shore in 
areas 25 miles or more north or south of the Ambrose Lighthouse, which would 
have the effect merely of moving the ecological disaster area farther up or down 
the coast. 
We are gravely concerned about the problem of dumping in the New York 
Bight. The subject bills do not appear to us to provide the needed comprehensive 
solution. We believe the study called for by the President is a step toward finding 
solutions to the overall problem rather than stopgap measures. | 
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 yours, 
FRED J. RUSSELL, 
Under Secretary of the Interior. 
U.S. DEPARTMENT OF THE INTERIOR, 
OFFICE OF THE SEORETARY, 
Washington, D.C., July 24, 1970. 
Hon, Epwarp A. GARMATZ, 
Chairman, Committee on Merchant Marine and Fisheries, the House of Rep- 
resentatives, Washington, D.C. 
Dear Mr. CHAIRMAN: Your Committee has requested the comments of this 
Department on H.R. 17603, a bill “To amend the Fish and Wildlife Coordination 
Act to provide additional protection to marine and wildlife ecology by requiring 
the designation of certain water and submerged lands areas where the deposit- 
ing of certain waste materials will be permitted, to authorize the establishment 
of standards with respect to such deposits, and for other purposes’, and H.R. 
18454, a bill “To amend the Fish and Wildlife Coordination Act to provide 
additional protection to marine and wildlife ecology by providing for the orderly 
regulation of dumping in the coastal waters of the United States”’. 
We recommend that consideration of H.R. 17603 and H.R. 18454 be deferred 
pending completion by the Council on Environmental Quality of its compre- 
hensive study of ocean dumping. 
The bill provides civil penalties of not more than $10,000 for each infraction 
of the prohibition against dumping unless in a designated area, and for each 
violation of standards applicable to dumping within such areas. The Secretary 
of the department in which the Coast Guard is operating and the Secretary 
of the Interior, respectively, would be responsible for enforcement. 
56-788 O—71——_2 
