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However, obtaining this land was extremely difficult, and we 
were not able to obtain it. Whether we would ever have been able 
to obtain it is still a question. 
Mayor Kocu. Then there is the environmental impact on the 
land. 
Ms. SEALE. I might add that if we were required to use that land 
for dredge material as well as sludge, I believe it would last less 
than 1 year. 
Mr. Carney. So that what you are saying is that in less than 1 
year you would not have the available land necessary to get rid of 
dredge material? 
Ms. SEALE. Right. You would have used it all up that quickly. 
The volumetric capacity of upland sites is limited. 
Mr. Carney. You are doing a multimedia study. Are you aware 
of the fact that EPA has just announced that they are doing a mul- 
timedia study, with EPA, Food and Drug, NOAA, and I believe 
some participation of the Corps of Engineers? 
Mr. McGouau. Yes. 
Mr. Carney. Is this a redundancy? 
Mr. McGouacu. We are undertaking our analysis to contribute to 
the record on upcoming rulemaking proceedings and meet the 
burden of proof on the city to get an ocean dumping permit. We 
are hiring consultants to advise us and to help us participate in the 
rulemaking process. It is something like an adversary process. 
Mr. Carney. If you say you are getting into the adversary proc- 
ess, is it your belief that NOAA, or EPA, or the Corps of Engineers, 
or Food and Drug have already determined what direction their 
studies are going to go in? 
Mayor Kocu. No, sir. When you appear before a Government 
agency—and that is what we will be appearing before—we ap- 
proach them like a ratemaking agency. We want to come in with 
our best case. That is why we will do whatever we can to prepare 
our own case and make our presentation and not rely on what 
somebody else does. 
Mr. McGoueu. If I may add something. I have not clearly stated 
an important distinction in what the city and agencies will do. The 
agencies will be developing the methodologies and tests. What we 
will be doing is the actual testing. As the gentleman from Dela- 
ware said, we have the burden of demonstrating that the dumping 
of sewage sludge will not unreasonably degrade the area. So our ef- 
forts will not be duplicative. We will be doing actual tests—water 
column, sediment, and so forth—in the areas of the bight where we 
now dump, and in other places, to demonstrate, we hope, although 
the scientific evidence will lay it out, that sewage sludge does not 
unreasonably degrade the marine environment. 
So there is a difference in function. It is not really an adversary 
proceeding. The agencies will focus on methods, on parameters, set- 
ting the parameters. We will focus on finding out exactly what the 
impact is of our sewage disposal activities. 
Mr. Carney. But your program is basically based on ocean dump- 
ing at its present site? 
Mr. McGouau. No. The proceedings will address this question. 
They will assess the most environmentally sound place for the dis- 
posal of these wastes. We have a lot of questions to which we 
