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could continue to be approved for ocean dumping, where the Secretary 
of the Army certifies that there are no "prudent and feasible” 
- alternatives to the dumping of "degrading" material. On the other 
hand, dredged material which contains "blacklisted" (Annex I) constit- 
uents as other than "trace contaminants" (as determined on the basis 
of appropriate chemical and toxicological testing) could not be ocean- 
dumped (as is true-under present LDC requirements), and no waiver could 
be obtained from this prohibition. Similarly, the prohibition against 
dumping at unstudied and undesignated dumpsites would and should 
un-waivably extend to dredged material dumpsites. 
We wholeheartedly support the thrust and intent of these amend- 
ments (although a number of wording changes are necessary to accurately 
convey the intentions of the draftsmen). 
The amendments would, in addition, affect the "Mud Dump Site” in. 
the New York Bight, at which dredged material from New York Harbor 
and associated navigation channels is ocean-dumped, by prohibiting 
after 1985 further dredged material dumping in the New York Bight Apex. 
This would necessitate relocation of dredged material dumping to a 
yet-to-be designated new site 10 or more miles further offshore. Two 
factors may serve to partially mitigate the seemingly harsh implications 
of this prohibition. First, the mounding of dredged material at the 
Mud Dump (the accumulation of many decades of dumping) has prompted 
serious discussion of the need to move the site to avoid interference 
with navigation in the shipping channel in which the Mud Dump is located. 
(On the other hand, perhaps another 10 years of capacity could be 
squeezed out of this site by shifting the dumping within it to a less 
heavily utilized portion of the site). Second, the New York District 
