6 
Our views on all these bills—as well as related bills, H.R. 18918 (and identical 
bills, H.R. 18949 and H.R. 18965); H.R. 18914; and H.R. 19077—were orally 
requested by your staff on September 24. Previously, by your letters dated 
August 17 and August 18, our views were requested on H.R. 18918, etc. and 
H.R. 18914. Our comments on H.R. 19359 were requested by your letter dated 
September 24. We are furnishing our comments on H.R. 18913 ete.; H.R. 18914; 
and H.R. 19077 under separate letters. 
H.R. 15827 
This bill would amend NEPA so as to terminate any license previously issued 
by the Army Secretary (Corps of Engineers) for discharge into the New York 
Bight of “any sewage, sludge, spoil or other waste.” A one-year study would be 
undertaken by the Secretary directed toward restoring these waters. 
H.R. 17603 
Essentially, this bill would authorize the Secretary of the Interior to regulate, 
pursuant to standards to be issued by him, the discharge of “sewage, sludge, 
spoil or other waste” into those waters to be designated by him as allowing 
safe discharge. The waters would include U.S. navigable waters, those of the 
Outer Continental Shelf, and submerged lands below both. Standards would 
be based on all ecological and environmental factors, and would supersede or 
preempt State standards which the Secretary found were not equal to or more 
stringent than the Federal standard. Violations would be subject to civil penalty. 
This bill provides that any Federal license previously issued would be rendered 
of no effect to the extent it authorized any activity inconsistent with determina- 
tions made by the Secretary. 
H.R. 18454 
This bill is generally similar to H.R. 17608, except the waters are specified 
as “coastal waters,” and the standards to be established by the Interior Sec- 
retary would be in consultation with the Chief of Engineers. State standards 
would be preempted unless the Secretary determined that they were more 
stringent than the Federal standard. The bill also provides for termination 
of all preexisting Federal licenses and permits, without qualification as to 
inconsistent activity or prohibited acts. 
H.R. 19359 
Is similar to H.R. 17603 but defines the prohibited waste material as, “sewage, 
sludge, spoil, landfill, heated effluents, or any other waste or substance (solid, 
liquid or gas).” Persons seeking to discharge such material into an area 
designated by the Interior Secretary would have the burden of proving that 
a proposed discharge would not ‘‘endanger the natural environment and ecology.” 
Unlike H.R. 17603, the bill requires the time-phased (1972-1976) treatment 
(primary, secondary and tertiary) of ‘sewage and industrial waste.” Like 
H.R. 17608, this bill would terminate prior Federal licenses and permits ‘to 
the extent they authorize any activity prohibited” by the bill. 
We note that two identical bills, H.R. 16427 and H.R. 16609, introduced 
earlier this year, were referred to us for comments by your letters of March 17 
and March 26, 1970, respectively. These bills, generally similar to H.R. 17603 
and H.R. 19359, would authorize he Secretary of the Interior to designate cer- 
tain navigable waters as marine sanctuaries and prohibit the discharging therein 
of harmful waste material (“sewage, sludge, spoil or other waste’). 
AKC has previously indicated, and we iterate here, that we strongly support 
all efforts directed toward the protection and preservation of our total environ- 
ment—land, sea and air. Accordingly, we favor the ultimate goals of these bills. 
As indicated more fully below, the AEC does not favor enactment of these 
bills because: (1) they are unnecessary and premature in view of the CEQ’s 
recently completed comprehensive study for a policy and legislation to deal 
with ocean dumping; and (2) these bills would unduly and unnecessarily 
interfere with AEC’s operational and regulatory activities. 
As you know, the Council on Environmental Quality, pursuant to direction of: 
the President on April 15, 1970, undertook a comprehensive, long-term study of 
pollution in the marine environment. The CEQ’s report and policy recommenda- 
