292 
The seaports of the United States, as you know, are heavily dependent upon 
channel and terminal dredging for their safe and efficient accommodation of 
water-borne commerce. As such, the AAPA is most interested in the disposal 
of dredged spoils, especially those which are contaminated by municipal, indus- 
trial, and agricultural pollutants. The goal in H.R. 17603 to designate portions 
of United States navigable waters and those above the Outer Continental Shelf 
and their submerged lands as areas for spoils disposal appears to be a con- 
structive step toward resolving the growing spoils disposal problem. Likewise, 
the establishment of Federal material standards with the aid of information 
to be required from any organization or person applying for authorization to 
discharge or dispose material in designated areas is a realistic requirement, 
and one that hopefully will result in the promulgation of equally realistic 
controls and procedures based on such data. Finally, the continuance of the 
status quo for at least two years from the date of enactment of the bill to allow 
for a thorough investigation and study of potential water and submerged land 
areas to be designated for spoils disposal is reasonable, provided, of course, 
that the necessary studies can be completed in that time and their findings 
implemented. 
LR. 17603 is, in our opinion, a more realistic and workable approach to the 
disposal problem than, for example, H.R. 17099 or 17238. The latter bills would 
in effect bring dredging to a halt in ports where “reasonable progress” by States 
toward furnishing containment lands was not forthcoming within one year of 
their enactment. These bills ignore the fact that certain ports have virtually no 
such land available, or none at a reasonable cost. These bills would also require 
dredging organizations to pay to use such containment areas, even though they 
did not cause the pollution, and to share such revenues with the public agencies 
that allowed the pollution to occur. 
Only three points in H.R. 17603 warrant possible further thought. The goal of 
“no damage” in line 24 of Section 5B (c) is virtually impossible to attain in a 
strict sense. It would be more realistic to determine the degree of damage that 
can be tolerated in a designated area. In addition, under Section 5B (f), I believe 
some grace period should be given to existing permitees to adapt to any new 
standards issued, with the time allowed dependent upon the degree and nature 
of the change. Finally, upon the establishment of the standards mentioned in 
Section 5B (c) and (f) I believe it would be appropriate to present them to the 
public through local hearings before they are implemented. This is presently 
required in the bill only in instances where State standards would be substi- 
tuted for Federal] standards. 
Thank you for a chance to comment on the bill. We think it is a step in the 
right direction in a very difficult problem, and look forward to being invited to 
comment on it more formally at such time as hearings are continued on it. 
Sincerely, 
Paut A. AMUNDSEN, 
Executive Director. 
NATIONAL WILDLIFE FEDERATION, 
Washington, D.C., July 27, 1970. 
Hon. JOHN D. DINGELL, 
Chairman, Subcommittee on Fisheries and Wildlife, Committee on Merchant 
Marine and Fisheries, Washington, D.C. 
DEAR CONGRESSMAN DINGELL: We wish to thank you for the invitation to 
testify on these bills dealing with the depositing of certain waste materials in 
our coastal waters and in the ocean. The National Wildlife Federation supports 
favorable consideration of the principles expressed in H.R. 15827, H.R. 15828, 
H.R. 17603, and H.R. 18454. 
From our knowledge as an association of independent state organizations 
and their affiliated local groups, the National Wildlife Federation continues in 
its belief that contamination of the environment by water and air pollutants, 
by toxic chemicals, and by solid wastes, constitutes the major natural resources 
problem of the age. In this area, one of the most crucial and demanding problems 
we face is that of disposal of waste materials in our waters, not only those waters 
covered by the bills now under consideration but all waters. In some cases, such 
as Lake Hrie, we are told that it is already too late to act and in others the point 
of no return is fast approaching. 
