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When we voiced these concerns to the staff at EPA, they 
indicated that they interpreted the 1981 deadline to be an ab- 
solute mandate, which required us to cease dumping, without 
regard to the land-based consequences. 
It was at this point that aie City of New York brought 
suit in the U.S. District Court of the Southern District of 
New York, arguing that the 1981 deadline only applied to sludge 
dumping which unreasonably degraded the ocean -- in light of 
all the criteria set forth in the Act, including those relating 
to the environmental consequences of available alternatives. In 
April 1981, Judge Sofaer of the District Court ruled favorably 
on the City's suit permitting continued ocean disposal of sludge 
because no adequate assessment had been made of the Sone eneee 
of alternative modes of disposal. The judgement pursuant to this 
opinian directed EPA to revise its ocean dumping regulations 
to allow consideration of all of the statutory criteria and per- 
mitted the City to continue dumping until new regulations were 
promulgated and EPA went through the procedure of designating 
either the existing site, or a new site, for future disposal. 
New York City is not the only local government concerned 
with potential hazards associated with alternatives to ocean 
disposal. Similar concerns exist, I believe, on the West Coast, 
in Massachusetts and in other neighboring municipalities on Long 
Island, Westchester and in New Jersey which currently dispose of 
sewage sludge in the ocean. For example, Long Island is one of 
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