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framework that allows for responsible scientific interpretation and 
implementation. Incorporating regulatory language in the Act will 
preclude EPA from readily revising their regulations to keep pace 
with advancements in scientific knowledge. 
The proposed Amendment to the Act represents a change in Congres- 
sional policy from mandating strict regulation of ocean dumping to 
prohibiting dumping of any materials. This change will compromise 
‘any efforts to balance the impacts of disposal options for sewage 
sludge. The elimination of the word "unreasonable" in the proposed 
definition of "degrade", coupled with the unique and newly defined 
prudent and feasible test which prohibits dumping if an alternative 
exists, makes a meaningful basis for the assessment of impacts impos- 
sible. This unjustifiably deletes the presently required balancing 
of disposal options to determine which constitutes an "unreasonable" 
risk to human health and the environment. 
The City of New York is committed to active participation in the 
upcoming-EPA site-designation rulemaking process. A comprehensive 
Special Permit Application, including testing, technical development, 
and multimedia tisk assessments also will be prepared. The current 
Ocean Dumping Act provides the mechanism for this assessment. The 
proposed Amendment to the Act and its implications would eliminate 
the vehicle for this process. In addition, it will eliminate the 
option of all ocean dumping through the outright, unqualified prohi- 
bition of carcinogen, mutagen, and teratogen materials, which is 
technically unsubstantiated and unrealistic. Therefore, the proposed 
Amendment should be withdrawn. 
