346 
that the city is one of the major PCB dispersers? And that when 
heavy rains come, New York’s sewage is washed raw into the 
water? And when New York staunchly defends its isolated position 
as an ocean dumper of sludge—about 40 percent of the Nation’s 
sludge is deposited in landfills, 20 percent is applied to agricultural 
lands, 25 percent is incinerated, and only 15 percent is discharged 
into the oceans from barges and pipelines? 
The judiciary has now joined the ranks of those who, in the face 
of undisputed evidence of severe degradation and stress, take an 
ecologically and morally unacceptable stand in favor of dumping 
sludge into the bight apex. Judge Abraham Sofaer has apparently 
written off the degraded areas of the bight. He refers to it as “an 
area so polluted that discernible [sic] improvement in conditions 
might not be achieved for many years to come” and “an area of 
ocean that appears to be beyond immediate reclamation.” 
When we seriously degrade a land area, we seek to stop our ac- 
tivities that have created the problem. We try to reclaim it and we 
act with alarm. But we act irrationally and illogically when we 
find we have injured this area of ocean. Too many people have a 
ho-hum attitude. This is particularly true in the case of the foot- 
dragging, recalcitrant officials of New York City. The city’s prac- 
tices result in delay, distortion of facts, and the continued ocean 
dumping of sludge, thereby seriously damaging plants and animals 
of the Bight and putting toxins such as PCB’s into the food chain. 
I want to depart from my prepared testimony to point out that 
the testimony we heard this morning of the mayor and from the 
city indicates that the thrust they are contemplating at this time, 
the thrust of their action, is to assess, to monitor and survey the 
results of ocean dumping. I am concerned about the kind of results 
we will get from this sort of survey. 
Within the same written statement submitted by the city today 
it says that the composting merely stabilizes the sludge. It refers to 
its reducing the volume of sludge and making it more aesthetically 
acceptable. They left out one key fact: Composting eliminates path- 
ogens. 
Now I will go back to my prepared statement. 
With regard to the national implication of the bill, the bill that 
has been drafted by the committee is excellent in its scope and 
intent. We agree that all sludge dumping into the bight must be 
stopped immediately. It is incorrect for the city to say, in the face 
of a mass of scientific data, that no significant impact will be 
caused by continued dumping at the existing site. It is undisputed 
that the ocean disposal of sewage sludge has severe, adverse envi- 
ronmental impacts on the New York Bight. 
Attempts to hide this fact by stating that sludge dumping is but 
part of the cause of this effect misses the point—the effect is due to 
the cumulative impact of pollution in the bight including sludge. 
These impacts pose a danger to human health, welfare, the marine 
environment, ecological systems, and economic potentialities. They 
include depression of oxygen available to the benthic community, 
microbial pollution at dumpsites, and introduction of toxic chemi- 
cals into both ecological systems and the food chain. 
And, arguments that sewage sludge is less significant a factor 
than waste water discharges and raw sewage are not relevant to 
