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higher or more complicated fee structure. It seems to me that some 
kind of Federal guidelines on these things would be important, not 
to drive or to attract industry from one State to the other. 
Mr. ForsyTHE. That is a good point. 
The draft amendments include a new definition of degrade when 
used in the context of the marine environment. Do you believe the 
proposed definition will clarify the use of this term and eliminate 
the confusion and ambiguity often noted with regard to the term 
“unreasonable degradation’’? 
Dr. Knauss. I must confess that when I read the draft legisla- 
tion—and I did not study it in great detail—I had great difficulty 
in seeing how there would be an improvement or any elimination 
of the confusion. It seemed to me at the first reading, and even at 
the second, that the problem was not going to go away. 
Mr. ForsyTHE. Your testimony states that NACOA concurs with 
the dumping fee system proposed in the draft amendments. I guess 
I really asked that one, except that in the amendment I believe it 
states “only those dumpers receiving interim permits and for those 
materials found to degrade the marine environment, or for which 
no prudent feasible alternative exists’ will be assessed the fee. 
Should the special fee be imposed on all dumpers? 
Dr. Knauss. Many of us who are environmentalists and lovers of 
the ocean would like to see it at least as difficult to put things in 
the ocean as on land or in the air. One of the ways in which one 
can try to do something about the ocean—that common area that 
belongs to all of us—would be to establish some kind of fee for ev- 
erybody who uses the ocean commons. 
Mr. ForsyTHE. I guess I have a problem with that comment when 
I consider all my water and aquifer problems on land. I am begin- 
ning to feel I should be more afraid of what is happening to the 
aquifers than the ocean at this point in time. 
Hopefully, there will be a time when we will have the perfect 
answer as to which is the best alternative, but certainly not today. 
Can the PCB content in sludges dumped in the New York Bight 
be controlled? 
Dr. Knauss. I am not competent to answer that question. 
Mr. ForsyTHE. At the present time, do we have the technology to 
get the PCB’s out of the sludge once they are in the plant? 
Dr. Knauss. I presume one can do that sort of thing if one is 
willing to pay a high enough price. I just have no idea of the 
degree of difficulty and what it would take to do so. 
Mr. ForsyTHE. Are you aware of any studies carried out in areas 
where sludge dumping has been discontinued which have shown 
that the natural ecological conditions cannot be restored within a 
few years’ time? 
Dr. Knauss. I am not aware of anything with respect to sludge. 
There have been a number of cases, I believe, that are reasonably 
well documented for abandoned dredge spoil areas. Although 
dredge spoils are not sewage sludge, some of them are reasonably 
contaminated. Dredge spoil areas have been studied over the years 
and within a decade the local ecology, at least superficially and 
even more than superficially, looks similar to what it was prior to 
its being a dumpsite. That is dredge spoils, not ocean sludge. 
