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likely, relocate and close their operations within the Newark Bay 

 system if they are not able to dredge. Many are concerned with the 

 high cost of permit process and the additional costs that could result 

 with requirements to cap sediments they would dredge from their 

 f acil i t ies . 



In order to understand the seriousness created by the 

 uncertainty of our permit, one must understand how the marine industry 

 operates. Shipping lines must plan in advance, usually six months, 

 regarding shipping routes. In order to provide a truly intermodal 

 transportation system, steamship lines must make arrangements for 

 terminals, warehousing, trucking and railroads. Once these agreements 

 are reached with other ports such as Halifax, Philadelphia, Norfolk, 

 Baltimore, and Boston, it will be difficult for the Port of New York & 

 New Jersey to recapture the tonnage loss. 



3. In the past, how often was the port dredged? 



The Port Newark and Elizabeth facility is dredged annually, 

 at least once and possibly, two times each year. The entire facility 

 is not dredged each year but selected berths are dredged on an 

 as-needed basis. The entire Port of New York and New Jersey's annual 

 maintenance dredging volume ranges from 6 to 10 million cubic yards. 



4. Have there been any previous problems with contaminated sediments? 

 If so, when? 



With regards to dredging, under the previous ocean dumping 



guidelines the Port Authority of New York and New Jersey did not have 



any problems with sediment quality at the Port Newark and Elizabeth 

 Port Authority Marine Terminal. 



5. Have any safety problems arisen due to the fact that the Newark Bay 

 port has not been dredged in three years? 



At the present time, the Port Authority has not yet 

 experienced any significant safety problems because of increased 

 siltation at our berths. However, there have been operational 

 constraints placed on terminal operators that may reduce the level of 

 safety margin for both vessel and workforce. In order to unload and 

 load a vessel rapidly because of berth depth limitations, terminal 

 operators have increased the number of cranes working on a ship, thus 

 creating a more difficult working environment. In addition, there have 

 been at least 14 ship groundings since January 1992 at the facility 

 because of shoaling of the berths due to lack. of dredging. 



6. In your testimony, you raise a very important question, "how clean 

 is clean?" Do you feel that the EPA criteria adequately assess this or 

 does the criteria go too far? What changes, if any, would you 

 recommend to better assess what is considered clean sediment, or 

 sediment that does not pose a threat to the environment of public 

 health? 



EPA criteria fail to consider the question of how clean is 



