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The City is committed to active participation in the EPA 
proposed site-designation rule-making process, which will 
update the environmental information concerning the 12-mile 
site, and other possible sites further offshore. In addition, 
we plan to prepare a comprehensive Special Permit Application 
which will include the results of detailed chemical and bio- 
logical testing, as well as multimedia analyses. These 
assessments will compare the specific risks to the environment 
and human health from ocean dispsoal and land disposal. Amending 
the Act in the manner suggested by the draft amendments under 
consideration would preclude these balanced efforts. It would 
also reverse a growing predisposition in the scientific 
community that multimedia assessments are the right approach for 
our increasingly complex society. 
I can understand the frustration of some members of this 
Committee with delays that have occurred in undertaking 
comprehensive environmental assessments and appropriate research 
and monitoring on ocean disposal sites. In response, I can only 
assure you that New York City is fully committed to meeting our 
share of the responsibility for the work that is necessary to 
arrive at a reasoned decision on waste disposal issues in our 
region. If the City had not felt that the land disposal scheme 
pursued in the late 1970's was environmentally unwise, we would 
not have contested its implementation in Court. Judge Sofaer's 
opinion addressed the potentially grave impacts of an outright 
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