317 
The plan was never implemented, in part because of public 
opposition to placing sewage sludge on parkland, and in part 
because of the ultimately successful legal action initiated by 
New York City to overturn the ban on ocean dumping. 
It is important to recognize, however (both in this 
context and in connection with proposals to relocate New York 
City's sludge dumping from its present 12-Mile Dumpsite to 
Deepwater Dumpsite 106 or to an immediate 65-Mile area) . that 
New York City's 12 sewage treatment systems generate distictly 
different sludges. Several of these systems (e.g., Newtown 
Creek and Bowery Bay) are much more heavily industrialized than 
the rest and generate far more heavily contaminated sludges. 
It seems entirelyconceivable that, under the draft amendments 
to the Ocean Dumping Law, the City's dirtier sludges could be 
deemed to have a prudent and feasible alternative in the form 
of composting and application to the four landfill sites 
identified in the CDM report (i.e., Pelham Bay Landfill in the 
Bronx; Fountain Avenue Landfill and Pennsylvania Avenue Landfill 
in Queens; and Fresh Kills Industrial Park in Staten Island), 
without having to resort to any of the more controversial 
parkland sites. These four landfills by themselves would supply 
at least 1,184 available acres. The cleaner sludges, to the 
extent they could qualify as non-"degrading," might well be 
able to be readily ocean-dumped. Even if they did not qualify 
as non-degrading, it might still be possible to ocean-dump them 
under an "interim" permit on the basis of their lesser harm 
to the ocean and the diminished prudence of applying them to more 
sensitive and controversial parkland sites. (Even among the 
parkland sites identified, 4 sites, accounting for 500 wadileinile 
acres, engendered little, if any, public protest.) 
