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unlikely that metropolitan New York sewage sludges can be success— 
fully marketed or found to have commercial value even when industrial 
pretreatment standards are enforced, as well as the lack of social 
acceptance for such materials, and the large quantities produced. 
In the same portion of the draft Amendment, Congress stated that 
",..-ocean sites that have heretofore been used for the dumping of 
materials have not been adequately studied to determine the full 
.environmental effects of such dumping..." [Subsection 2(a)(4)]. This 
clearly does not apply to the 12-Mile Site which has been one of the 
most intensively studied marine areas in the world for effects of 
pollution and environmental stress. In addition, the determination 
of what constitutes a complete investigation is difficult and 
determining the "full environmental effects" of any activity is 
impossible. 
The proposed Subsection 2(b)(1) represents a change in Congressional 
policy which eliminates rather than limits the ocean dumping of 
materials that require special care. This unduly restrictive policy 
is inherent in the draft nies? definition of degradation of the 
marine environment and in proposed prohibitions under the ocean 
dumping permit program. 
The concept of "unreasonably degrade" [emphasis added] has been elim- 
inated from the Act in Subsections 101(4)(d) and 102(a) and replaced 
with just the word "degrade." This term is defined in draft 
