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concerned about potential risks to human health and the environment 
associated with proposed land-based alternatives to the ocean dumping of 
sewage sludge. Those risks will be fully evaluated as part of the prepa- 
ration of a comprehensive Special Permit Application. However, the City 
is concerned that the proposed amendments will prevent EPA and the 
affected parties from making a technically sound decision on the most 
feasible mode of sewage sludge disposal in the New York metropolitan 
area. Our specific objections to the draft Amendment are briefly 
highlighted below. Major provisions in the proposed Amendment, as they 
affect the future of sewage sludge disposal in the ocean, are presented 
first followed by other noteworthy provisions on which we wish to 
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comment. 
MAJOR IMPLICATIONS 
1. The major implication of the proposed Amendment may be the outright 
ban on dumping of sewage sludge at all existing or proposed ocean 
sites (e.g., 12-Mile, 65-Mile, or 106-Mile sites) due to revised 
provisions of the Act which directly prohibit specific constituents. 
Section 102(a) of the current Act prohibits radiological, chemical, 
and biological warfare agents and high-level radioactive waste from 
ocean disposal. The proposed amendment [Section 102(a)(1)] adds 
, three additional prohibited materials. Each of these prohibi- 
from the draft Amendment are discussed individually in the 
