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23, LOZ testimony, a copy of which is attached to our testimony 
today, and which I request be incorporated into the record of 
this hearing. 
Before discussing the proposed "user fees" and Ocean Waste 
Management Commission, I would like to comment on what I regard 
as a general deficiency of the proposals and, in fact, on most 
legislation dealing with the ocean. The emphasis is always on 
the disposal aspect rather than on the beneficial aspects of 
putting sludge in the ocean. We know from our experiences with 
land disposal that there are great benefits to be derived from 
the proper use of sludge. There is also a growing awareness 
that, under proper conditions, sludge can provide susbtantial 
benefits to the aquatic environment of the oceans. 
We urge Congress and the Executive Branch agencies to re- 
cognize these beneficial uses and to treat the problem not as 
simply getting rid of harmful waste material, but as a problem 
of ensuring that the positive and useful dements of sludge are 
not wasted but are put to beneficial use. Thus we suggest that 
wherever the term "ocean disposal" is used it be broadened to 
"ocean utilization and disposal". See subsection 206 (e)i) (B) (ii) 
of the proposed amendment to H.R. 6324 (p.7). Also in subsection 
(111) I would suggest that "for comparing the human health risks 
and environmental degradation caused by ocean disposal of sew- 
age sludge" should read: "for comparing the benefits as well 
as the human health risks and environmental degradation...". 
I asked my staff at the Hampton Roads Sanitation District 
to review the literature on enhancing the marine environment 
with wastewater solids and although the staff report will proba- 
bly be expanded, I would like to submit for the record of this 
hearing the brief report which is attached to my testimony. 
Now I shall comment on the "user fees" and Commission 
proposals. 
USER FEES 
As we have stated on several occasions, we are committed 
to seeing that our decisions to dispose of or utilize our sewage 
sludges are based upon sound scientific judgment. When we place 
sludge in a landfill, as some have pointed out, we usually pay 
a fee to the landfill owner or operator. This fee reimburses 
the landowner for the cost of taking his land out of other pro- 
ductive uses, and for costs associated with preparing the land- 
fill and for actual handling of the sludge.” For the record, let 
me also note at this point that many of our sewerage agencies 
across the country prepare their sludge for use as a most 
effective fertilizer which is sold to users with a substantial 
financial return to those agencies. The proposal that those 
who place sewage sludge in the ocean should pay a fee, on a per- 
