348 
and beaches, the development of anaerobic deep sea environments, and the damage 
to deep sea organisms which are used to extremely stable conditions. 
Based on this informed scientific opinion, it is concluded that dumping of sewage 
sludge at the 106-mile site (the chemical wastes site) has a potential for irreversible, 
long-range, and therefore unreasonable degradation of the marine environment, and 
that the use of this site for this purpose would be contrary to the intent of the act 
(the MPRSA) and the Convention (the International Convention on the Prevention 
of Marine Pollution by Dumping of Wastes and Other Matter). 
It is also unfortunate that the dumping of sludge in the ocean is 
of no direct use to us. However, there is a need for sludge which 
can be applied to the land. Our agricultural soils are losing produc- 
tivity due to cropping patterns and erosion. Fertilizer prices are 
skyrocketing due to rising energy costs; ammonia, the chief source 
of nitrogen, is primarily manufactured from natural gas. 
Our testimony last year documented requests by five New York 
State agricultural communities for New York City sludge. Strip 
mined, developed, and other lands where the soil has been removed 
also can be reclaimed using sludge. Although sludge is not a waste 
product by any means, we cannot accept the opposite proposition 
that sludge dumping is safe and acceptable, although we would not 
go as far as Mayor Koch did before these committees in 1979 when 
he suggested in response to a question that sludge was invented by 
God. 
The city of New York has a pretreatment program that is being 
initiated right now; at least the study is being initiated. I am very 
concerned about the honorable mayor’s comments this morning 
that they would support industrial source reduction efforts if the 
Federal Government mandated—and, if I am not mistaken, he said 
“funded”’ it. I am concerned because this kind of statement could 
very well pull the rug out from under the pretreatment program 
the city is attempting to initiate. 
I am talking a lot about the city of New York. This is not a New 
York issue alone. It is a national issue. Cities, municipalities in vir- 
tually every State have successfully undertaken pretreatment pro- 
grams that reduce heavy metals and other toxicants to safe levels. 
The test is not, as the New York commissioner stated this morn- 
ing, to eliminate heavy metals. The test is to reduce them to safe 
and acceptable levels. 
Some examples of the kinds of studies that have been done: A 
study in Chicago funded by the National Science Foundation found 
that cadmium usually does not exceed 3 parts per million in resi- 
dential sewage, and is usually 1 to 2 parts per million. 
In a town in Pennsylvania which not too long ago had 1,000 
parts per million of cadmium, it is now down to less than 15 parts 
per million. Philadelphia is perhaps an excellent example. In the 
early 1970’s they had 200 parts per million of cadmium. By 1975, it 
was 105 parts per million. They cut it in half, and today it is less 
than 25 per million. That was at their northeast plant. At their 
southwest plant they cut from 35 parts per million in 1975 to less 
than 15 parts per million. 
Washington, D.C., had a cadmium content of 15 to 20 parts per 
million, which is now reduced to 8 to 10 parts per million. 
Regarding New York City there has been discussion of the differ- 
ent plants. One sewage treatment plant has an output in its sludge 
