To place my remarks in context, I would like to state that NOAA 

 believes that waste management practices should be designed and 

 implemented to minimize significant risk of harm to living and 

 nonliving resources in any environmental medium: the oceans, 

 land, ground water, fresh water, and the atmosphere. 



If it is determined that disposal, as opposed to any alternative 

 such as recycling, is the preferred option to solve the waste prob- 

 lem, then disposal practices, including the specification of the 

 quantity and quality of wastes, location of disposal sites, timing of 

 the sites, and the disposal technology least likely to cause signifi- 

 cant harm should be chosen. 



NOAA does not oppose selection of the ocean as a medium for 

 disposal if a rigorous comparative assessment of all reasonable op- 

 tions indicates that choice poses the least risk of significant harm. 

 We believe that the current practice of dumping municipal 

 sewage sludge at the 12-mile site is causing, or at least contributing 

 to, conditions that damage the marine environment of the New 

 York Bight and its resources. We believe that the environmental 

 quality of the New York Bight can be improved by changes in 

 sludge-disposal practices combined with increased control of other 

 pollution sources. 



The Environmental Protection Agency will describe other source 

 controls in its testimony today. 



I would like to characterize, the New York Bight and some of the 

 resources at risk, and describe environmental effects observed to 

 date. Then I will outline recommendations for improving environ- 

 mental quality in the area and conclude with our position on alter- 

 native ocean-disposal sites. 



The New York Bight Apex, the nearby Hudson-Raritan Estuary, 

 and western Long Island Sound are degraded marine environ- 

 ments. Considering their proximity to the most populated and in- 

 dustrialized urban area in the Washington-Boston corridor, it is not 

 surprising that these ecosystems are strained. Rates of contami- 

 nant input to the bight are the highest observed in the world. 



In 1976, NOAA published a comprehensive examination of the lo- 

 cation and magnitude of contaminant inputs into the bight. The 

 report indicated the relative importance of various inputs and iden- 

 tified gaps in data. Since then a number of studies have added to, 

 confirmed or clarified portions of those data. NOAA and EPA are 

 presently compiling and assessing the results of these studies in 

 order to update estimates of contaminant input to the bight. Some 

 of these updated estimates will be provided in EPA's testimony 

 today. 



The most important documented contaminant effects are on indi- 

 viduals or given species of living marine resources. Anatomical or 

 physiological abnormalities and localized losses of species have 

 been reliability attributed to contaminants. There are fewer illus- 

 trations of how communities and entire ecosystems have been in- 

 fluenced by contaminants, because such effects are subtle and gen- 

 erally require more sophisticated field sampling. 



Among the obvious impacts of ocean dumping is the closure of 

 virtually all the apex to the taking of bivalve moUusks for human 

 consumption. This closure is based on contamination by coliform 

 bacteria and prohibits harvesting. It centers on the sewage dump- 



