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There is no technical justification for the pro- 
posed ban on ocean dumping at sites within the 
New York Bight Apex. These sites were designated 
only after careful consideration of information from 
comprehensive environmental impact statements, and 
the advice of responsible scientists and interested 
members of the public. The results of these assess- 
ments and other comprehensive studies indicate that 
no significant adverse impacts will be caused by 
continued dumping. 
The proposed amendments set regulatory criteria, 
many of which are tentative and based on evolving 
technical knowledge, into legislation. Similar 
criteria already are incorporated into EPA's exist- 
ing Ocean Dumping Regulations and the London Ocean 
Dumping Convention in a manner that allows for 
responsible scientific interpretation and imple- 
mentation. 
These amendments will compromise any efforts to 
balance New York City's disposal options for sewage 
sludge. The omission of the word "unreasonable" 
in the proposed definition of "degrade" and the 
new definition of "degrade" itself, coupled with the 
uniquely defined "prudent and feasible" test makes 
a meaningful assessment of impacts impossible. This 
