33 



would limit potential conflicts with long-line fishing interests along 

 the Continental Slope and the oil and gas exploration that is possi- 

 ble there. 



We are also considering the separation of industrial and munici- 

 pal waste dumping within the site in order to both minimize poten- 

 tial synergistic effects and more importantly, to facilitate our abili- 

 ty to monitor separately the two types of dumping. 



We note on the bottom of page 18 the types of comments we have 

 received on the two notices having to do with the petition to redes- 

 ignate the 12-mile site and with the proposal to designate the 106- 

 mile site. 



Discussed on page 19 is the work we are doing with NO A A, the 

 task team that was set up to review the information on the 12- and 

 106-mile sites. We have dates in there that we plan to meet in 

 terms of completing our technical evaluation of the 106-mile site by 

 July 31, and to complete our evaluation of the scientific informa- 

 tion on the 12-mile site by August 31. 



We begin again, on page 20, discussing in somewhat more detail 

 the point I had made earlier that the authorization to use a site is 

 independent of site designation, and that a permit is required. We 

 briefly discussed the criteria for the permit process. 



We note, beginning on the bottom of page 20, that within the 

 permit context in dealing with each of these expected permit appli- 

 cations, a major difficulty that we expect to face, is the availability 

 of alternative disposal methods. 



We note, especially when we talk about densely populated, heav- 

 ily urbanized areas, consideration of both economic costs as well as 

 environmental impacts, concerns about institutional problems and 

 developing land-based alternatives. 



We note, specifically at the bottom of page 20 and over to 21, the 

 difficulty of implementing land-based alternatives especially when 

 States impose their own rather specific requirements such as a 

 moratorium on sludge application to land. 



We note that we have been successful in the past, we noted earli- 

 er, I believe about at page 10, when we talked about the number of 

 dumpers there were previously, there were 250 municipalities 

 dumping 10 years ago, and there are only 28 treatment plants 

 today. 



So we express our hope that for most of the ocean-dumped resi- 

 dues, that we will be able to find land-based alternatives. 



We tried to respond, continuing on page 21, to the concerns ex- 

 pressed by some that the relocation of the site out to the 106-mile 

 site makes it out of sight, out of mind, and we note that of the 

 roughly 100 industries which are ocean-dumping their wastes at 

 the 106-mile site, only 2 remain, and therefore, we believe that al- 

 though they were out of sight, they are not out of mind, and that 

 we have a track record not only of reducing the number of munici- 

 palities dumping but reducing the number of industries dumping 

 even at the 106-mile site. 



We say, and I would like to read this, we intend to carefully scru- 

 tinize the applications of existing sludge dumpers. Ocean dumping 

 will be allowed only if these applicants can demonstrate that there 

 is a need for ocean dumping. What of new applicants? Nothing for- 

 bids a new applicant from proposing the ocean dumping of munici- 



