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be taken into consideration on land dumping vis-a-vis ocean dump- 
ing? What is your standard? 
Ms. Hurp. Right at this point in time, we do not have a major 
policy or a set of regulations in the sludge area. One of the major 
priorities in our agency over the next 9 months to a year is to de- 
velop a comprehensive policy on sludge and a set of regulations 
and guidelines. 
At this point in time, we have a work group. We have put togeth- 
er a work plan. We have done an extensive review on the docu- 
ments that are in existence on health effects, on environmental im- 
pacts. We recognize some of the weaknesses of those reports. We 
will go back, and with technical experts, evaluate and redo those 
documents, and put into place guidance to the people out in the 
field who have to manage the sludge. 
Mr. D’Amours. Well, I understand that, and I understand that 
you are working on these questions, but I am talking about the 
law. Do you think the law is clear? You are working on regulations 
that you hope will clarify this, but we are talking about the con- 
gressional responsibility of working with the law. Do you think the 
law is clear? 
Ms. Hurp. We believe the law establishes a good framework so 
we can develop a workable program. Yes. 
Mr. D’Amours. Well, you were in my office when we met with 
Anne Gorsuch and a group of Congressmen—— 
Ms. Hurp. Yes. 
Mr. D’Amours [continuing]. Asking her—praying to her—to 
appeal the Sofaer decision. If you remember, much of the conversa- 
tion centered around the problem of vagueness in the law. 
Has the EPA changed its position? Has the law since then 
become clear to you? Has it clarified itself in some way? 
Ms. Hurp. The reason why we did not appeal the New York 
court case was the fact that we felt that our regulations were not 
in conformance with the Federal law. Basically, the issue was the 
EPA should consider all the statutory factors that are set forth in 
section 102(a) of the act to determine whether ocean dumping un- 
reasonably degrades the ocean. 
Mr. D’Amours. Well, I was asking you to remember the conver- 
sations we had in my office that dealt with the lack of clarity of 
the law. Do you remember those? 
Ms. Hurp. I remember the conversation. Yes. 
Mr. D’Amours. Do you now think the law is pretty clear as to 
how we establish degradation and unreasonable degradation? 
Ms. Hurp. I believe, again, that the law establishes a framework. 
It establishes a number of factors that should be—— 
Mr. D’Amours. So what you are saying then is you think that 
the determination of unreasonable degradation ought to be made 
in the bureaucracy rather than in the Congress. 
Ms. Hurp. I believe it should be made through a process that we 
have technical experts help us establish that program. Yes. 
Mr. D’Amours. In your testimony, you referred to revenue shar- 
ing. Have you seen the revenue sharing in the proposal, in the 
draft amendments that we have circulated? 
Ms. Hupp. Yes. Steve has reviewed it in detail. 
Mr. D’Amours. Do you have any problems with them? 
