316 
be regarded as "practicable" "when they are available at 
reasonable incremental cost and energy expenditures, which 
need not be competitive with the costs of ocean dumping ...." 
Note on the New York City Situation 
New York City, which has been at the forefront of efforts 
to frustrate Congressional desires to phase-out harmful sludge 
dumping practices, will doubtless oppose much, if not all, 
of the draft amendments. We would simply point out with 
respect to New York City that ocean dumping of its sewage 
sludge need not be an all-or-nothing proposition. The sludge 
which New York City ocean-dumps is generated by 12 separate 
sewage treatment plants, sese eda throughout the City. In 
1978, these plants in aggregate were producing a total of 
some 1,500 dry tons of sludge per week. At that time, 
consultants to New York City (i.e., the engineering firm of 
Camp, Dresser & McKee) proposed short- and long-term alterna- 
tives to ocean dumping, which would have permitted the City to 
comply with the 1981 phase-out requirement. The CDM plan 
contemplated (1) dewatering the sludge at two locations-- 
one at the Owls Head plant, and the other at either the Hunts 
Point plant or the Bowery Bay plant; (2) composting of the 
sludge cake produced at these plants at College Park, and at 
the Freshkills landfill and South Shore incinerator sites; and 
(3) one-time application of the compost at 16 landfill and 
parkland sites (with a total available acreage of 2,800 acres) 
at a loading rate of about 500 tons per acre (this would provide 
about 8 inches of compost, which would be mixed with about two 
parts of existing topsoil to enrich the topsoil and to provide 
structural integrity). 
