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Mr. D’Amours. Thank you very much, Mr. Garabedian. 
Do I understand your position to be essentially that you do not 
think we ought to be dumping any sewage sludge into the oceans? 
Is that basically your position? 
Mr. GARABEDIAN. That is our position. 
Mr. D’Amours. I did not say any sewage sludge that degrades. Is 
it any sewage sludge, whether or not it can be shown to degrade 
the ocean environment? 
Mr. GARABEDIAN. That is ccrrect. There are several key reasons 
which I attempted to outline. 
Mr. D’Amours. Why would you object to the dumping of sewage 
sludge which does not degrade the environment? 
Mr. GARABEDIAN. There are site-specific issues and general con- 
siderations. The site-specific one would be, for instance, the New 
York Bight which is overstressed. It would not make sense to be 
stressing it with even additional nutrients. We all agree it would 
not do any good there. 
Mr. D’Amours. What harm would additional nutrients do? 
Mr. GARABEDIAN. We are talking an overstressed environment 
there. There certainly is no need for the additional nutrients. We 
simply would be adding an additional load which would put a 
stress on oxygen availability. That is an example of oxygen stress. 
When it comes to the question, say, of moving from the New 
York Bight or any other overstressed location to open ocean areas, 
it does not make sense to us to dump the dredge disposal when it 
has ready uses on land. In fact, it is clear to us that, through pre- 
treatment, sludge toxins can be eliminated. That, to us, is not a 
reason to dump in the ocean. 
Mr. D’Amours. Even Jacques Cousteau, for instance, would say 
that the dumping of clean sludge, so to speak, with nutrient value 
is beneficial and has a beneficent effect. 
Mr. GARABEDIAN. He is saying that is true in some situations. 
That is his statement. 
Mr. D’Amours. Would you object to even that dumping? 
Mr. GARABEDIAN. Mr. Chairman, I would answer your question 
this way: Personally, if the law were to specify that before sewage 
sludge could be dumped in the ocean there had to be a pretreat- 
ment program in effect, I would say that would be a sound way to 
go. It would be sound because, first, it would eliminate toxics from 
the ocean; and, second, because I would be surprised if, once the 
toxins were eliminated, there would be any resistance to using it 
for land applications. 
Mr. D’Amours. You just said a few minutes ago that pretreat- 
ment works. We have the technology and it works, and, therefore, 
we could solve all of our problems by pretreating all of our sludge. 
Do you have any studies on the relative cost and the ability of mu- 
nicipalities such as New York and others to absorb this cost? 
Mr. GARABEDIAN. Mr. Chairman, I do not have any cost figures 
with me, though I would be delighted to submit them for the 
record. (See letter on p. 351.) 
The point is that it is working in other cities. Philadelphia is a 
prime example. We are concerned that, if New York is allowed to 
continue with its sludge dumping, if there are no demands made on 
it or pressure put on it to cease, other cities which have in recent 
