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out, however, that the existing §102(a) criteria are repeated, 
nearly verbatim, in §403(c) of the Clean Water Act, which regu- 
lates pipeline discharges. We think that the original criteria, 
adopted in 1972 in both laws, should remain on the books until 
such time as experience shows the need for a change. That ex- 
perience has not been gained to date. 
Furthermore, we believe that the proposed switch from "no 
unreasonable degradation" to "no degradation” will, from a prac- 
tical point of view, result in barring the ocean as an option 
to be considered in the handling of sludge. As is evident from 
the thrust of this statement, CCA believes such a course of 
action to be contrary to the national interest. 
_ There is no best method for dealing with sewage sludge today. 
All of the available methods have environmental, human health, 
and economic consequences which vary from location to location 
and no single method will be favored in all locations. The choice 
of the best method of sludge disposal in a particular locality 
is a matter requiring evaluation of all the options. Since EPA 
had banned the use of the ocean for sludge disposal after 1981, 
the agency ceased supporting any research into the effects of 
sewage sludge on the ocean. We acknowledge that there are sig- 
nificant gaps in our knowledge of the effects of ocean disposal, 
and of the best means by which to minimize these effects. Sig- 
nificant gaps also exist in our knowledge of landbased and at- 
mospheric methods of sludge disposal which may even be greater 
than the gaps in our knowledge of the ocean impacts of sludge. 
Inadequate information does not justify a ban on the use of the 
ocean or any other option. 
We believe that effective research and monitoring and analyt- 
ical studies on both ocean and land-based alternatives of handling 
sludges must be continued and accelerated. Only after conducting 
a cross-media benefit/risk/cost analysis, based on adequate data, 
Can a rational decision be made as to the soundest disposal method 
or methods in each locality. Due to the considerable differences 
in ocean environments in different parts of the United States, we 
believe that cross-media analyses must be performed in individual 
areas and that the best disposal option will not always be the 
same. We believe that the existing MPRSA, when properly applied 
by EPA, will lead to these cross-media analyses, and that decisions 
regarding the best disposal option will never be made strictly on 
the basis of economics. 
We are strongly committed to maintaining an ocean disposal 
option, in an effort to develop the best approaches to sludge man- 
agement. This requires adequate studies of the comparative risks 
and benefits of all alternatives. Where the ocean is a potential 
Option, studies will be required of the best methods for putting 
sewage slucge in the ocean to protect the environment and human 
health. Monitoring will be needed to ensure that management of 
sludge dissosal in the ocean is carried out in a manner that 
meets naticnal environmental goals. 
