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the environmental problems, dislocation and expense the draft 
amendments would impose upon the residents of the City. Feasible, 
permanent land-based options for sludge disposal in the City of 
New York, given the absence of land and large amounts of sludge 
produced by our treatment plants, do not exist. Moreover, sign- 
nificant environmental problems make these land-based alternatives 
unworkable even in the short term. In light of EPA's current 
efforts to revise its cagtlavions, I urge the Committee to turn 
away from the pending amendments. By doing so it will permit 
the scientific community to develop the technical information 
necessary to make reasoned decisions on all of the substantive 
issues raised by the ocean disposal controversy. New York City 
is committed to participating actively in this process and taking 
on appropriate responsibilities for monitoring the impacts of our 
ocean dumping. 
If the Committee believes that the process now in motion 
is compromised along the way, or EPA or other agencies fail to carry 
out their responsibilities, or that the stringent criteria already 
set out in the Act are ignored it can take action at a later date. 
To take action now would be premature and counterproductive. 
That completes my prepared testimony. I appreciate the 
Committee's patience in hearing me out. As I have indicated 
previously, I am submitting along with my written testimony, 
attachments which analyze the specific provisions of the draft 
amendments to Title I of the Act, and summarize the existing sci- 
entific findings on ocean disposal of dredged materials and 
sewage sludge. 
Commissioners Seale and McGough and I will be happy to- 
answer any questions you might wish to ask of us. 
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