496 
had any role in the oxygen depletion event, it was an insignificant 
one at most. 
2. NOAA published a report which shows that beach pollution 
in the New York-New Jersey area is derived from land-based sources, 
not ocean-dumped sewage sludge. Ocean-dumped sewage sludge does 
not, in fact, contain floatable materials. 
3. NACOA published its report referred to earlier following 
an exhaustive two-year appraisal of information related to ocean 
disposal of waste materials. NACOA's report concluded that the 
human health and environmental impacts of placing sewage sludge 
in the ocean are small, and that ocean disposal of sewage sludge 
should be allowed when cross-media comparisons show this to be 
the most desirable option. 
4. NOAA has concluded that any contribution of sewage sludge 
to the degradation of the New York Bight is so small that stopping 
sludge dumping would have no beneficial effect on that environment. 
5. Extensive monitoring and research studies of ocean dump- 
sites, including more than a dozen sites around the United Kingdom, 
and of marine pipeline discharges of sewage sludge, especially in 
Southern California, have confirmed that there are no impacts on 
human health, and that environmental impacts are minimal when 
digested sludge is ocean-disposed, even in large quantities. 
6. The studies cited in the previous paragraph indicate 
that, although at some sites the biological populations are de- 
graded in small areas of the ocean floor at or near the discharge 
location, the net effect of ocean disposal of sludge is beneficial. 
Over a much wider area, the biological populations are considerably 
enhanced. At many sites even the small areas of degradation are 
not found. Scientific opinion is now moving towards the view 
that sewage sludge can be used beneficially to enhance ocean pro- 
ductivity if distribution into the marine environment is properly 
managed. 
7. Several studies of ocean dumpsites and pipeline discharges 
of sewage and sewage sludge, where dumping or discharge has been 
discontinued, have shown that natural ecological conditions are 
restored within a few years or less. The impacts of ocean dis- 
posal of sludge are, therefore, readily reversible and if any 
site were to become unacceptably degraded, removal of the inputs 
would restore the site quickly. 
RECOMMENDATIONS: 
We have carefully studied the draft amendments to Title I of 
the MPRSA that were prepared by the Oceanography Subcommittee and 
we are strongly opposed to them. The proposal would make a number 
of signiiicant changes in a law which, to our knowledge, has never 
been implemented as written and intended. We believe the original 
nine critezia in §102(a) are an excellent set of criteria. We point 
