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amendments on waste disposal options in general and their more 
specific impact on New York City -- as best we have been able 
to assess them in the limited time available to us -- and to 
recommend a different course of action to the Committee than 
that contemplated by the amendments. 
IMPACT OF DRAFT AMENDMENTS ON WASTE DISPOSAL OPTIONS 
New York City is concerned that the proposed amendments 
will seriously impair EPA's ability to evaluate alternative 
disposal methods for wastes currently dumped in the ocean. 
Based on an assessment of the draft amendments and their im- 
plications, the City objects to a number of the proposed 
mandates and prohibitions included in the proposed amend- 
ments, all of which seem to be without technical justification. 
The City's major comments and concerns are as follows: 
1. As drafted, the proposed amendments would totally 
eliminate the ocean disposal of all currently 
dumped wastes by prohibiting the dumping of 
material with known or suspected carcinogens, 
mutagens, and teratogens in any quantity. Such 
a prohibition is inappropriate in a law enacted 
to regulate, rather than to eliminate, ocean 
dumping especially since the alternative to dump- 
ing may lead to greater human exposure to such 
materials. 
