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inconsistent with an EPA determination? For example, a State imposed 

 moratorium on sludge application to land. These are difficult issues, but 

 we have been successful in the past. Many previous sludge dumpers have 

 implemented alternative means of disposal, including recycling/reuse 

 technology. It is our hope, given time, that many more will cease ocean 

 dumping in the future. 



There are those who claim that relocation of sludge dumping further 

 offshore would result in an "out of sight, out of mind" reaction. Let me 

 state that this is inaccurate. Of the roughly 100 industries which ocean 

 dumped their wastes at the 106-Mile Site, only two remain. Even though they 

 were "out of sight", they were not "out of mind". We intend to carefully 

 scrutinize 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 forbids a new applicant 

 from proposing the ocean dumping of municipal sludges not now dumped. 

 However, the "burden of proof" that such dumping will not "unreasonably 

 degrade" the environment is entirely on the applicant. 



In conclusion, therefore, though the combined effort to substantially 

 improve the water quality of the .Hudson estuary, the efforts to find 

 alternate disposal sites for contaminated dredged materials, and our efforts 

 to resolve the sewage sludge and other ocean dumping issues, we believe that 

 a substantial improvement in both the estuary and the Bight Apex is 

 attainable, and we are actively working towards that goal. 



