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be selected with regard to risk to human health, the environment, and 
economic and technological feasibility. 
The purpose of this document is to evaluate and comment on the draft 
Amendment (dated 25 February 1982) to the Act entitled "Ocean Dumping 
Amendments Act of 1982." The comments address the need for specific 
proposed revisions to the current ocean dumping act. In our opinion, 
the existing Act already provides the policy and provisions for adequate 
protection of the marine environment. The EPA regulations provide a 
framework for evaluating the most acceptable means of disposal. Further, 
these regulations are currently under review and are expected to be 
revised to reflect the present scientific knowledge. Specific provisions 
of the proposed Amendment will seriously impair the ability of EPA and 
the affected parties in properly evaluating and implementing acceptable 
disposal methods for wastes currently dumped in the ocean. Many of the 
proposed sebhaeniis and provisions are already incorporated into the 
existing and evolving EPA regulations in a technically sound manner con- 
sistent with the standards and criteria binding upon the United States 
under the London Dumping Convention and its Annexes. Incorporation of 
the proposed Amendment prohibitions will preclude some important multi- 
media comparisons currently mandated under the Act and required under the 
Regulations. 
New York City is committed to active involvement in the site-designation 
rulemaking process and has undertaken a major effort to reevaluate the 
environmental effects of sewage sludge disposal at the 12-mile dumpsite 
based on the latest scientific information. The City is increasingly 
