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also not provided a technical foundation for this outright ban. In 
fact, EPA had intended to commence with a rulemaking proceeding 
shortly to explore the condition of the New York Bight and to deter- 
mine whether sludge dumping in that area should be allowed to con- 
tinue. This rulemaking procedure would allow the experts to deter- 
mine whether the action Congress is now taking is appropriate. 
The limitations and criteria within the Act and the Ocean Dumping 
Regulations are adequate to prevent and detect adverse environmental 
effects due to ocean disposal. This outright ban by the draft Amend- 
arbitrary and technically unfounded. 
Similarly, the Findings and Policies portion of the Act has been 
greatly changed in the draft amendment. According to the bill, 
Congress has found that "certain ocean waters...are already unrea- 
sonably degraded as a result of dumping..." [Subsection 2(a)(2)]. 
“unreasonably degraded" due to sewage sludge dumping. On the con- 
trary, studies show that the New York Bight Apex receives a diverse 
pollutant load and the contribution of sewage sludge is relatively 
small. 
Congress also has stated in the draft Amendment that it found 
"..certain materials that have heretofore been dumped into the ocean 
waters have potential commercial value if appropriately recycled..." 
[Subsection 2(9)(3)]. While this may be true in some areas, it is 
