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application, it is imperative that a comparative assessment be performed 
to provide maximum overall protection to human health and the environ- 
ment, and thereby manage sewage sludge disposal in a responsible manner. 
The City feels that the combination of the existing Ocean Dumping Act, 
the Ocean Dumping Regulations and Criteria, and the recently issued 
Sofaer decision adequately provide the necessary framework under which 
to conduct this comprehensive assessment. The proposed Amendment of the 
Act, however, will substantially limit the framework for this important 
assessment. 
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