96 



-6- 



A few of these points deserve amplification. 



With reaard to the productivity of nearshore versus 

 offshore waters, there are recent indications that tradi- 

 tional oceanographic techniques may have systematically 

 underestimated, by as much as a factor of ten, the 

 productivity of the central oceans. (Kerr, R.A. , "Are the 

 Oceans' Deserts Blooming?," Science 220: 397-98, April 22, 

 198 3) . And studies using baited automatic cameras dropped 

 to the bottom of the ocean have revealed a surprising 

 population of large fishes and other scavengers that find 

 and consume dead animals and other organic matter that fall 

 from the waters far above. (Isaacs, J.D. and R.A. 

 Schwartz lose, "Active Animals of the Deep-Sea Floor," 

 Scientific American 233: 85-91, Oct. 1975). Nevertheless, 

 the general proposition, reflected in the table, that 

 nearshore ocean dumping represents a more direct and immedi- 

 ate threat to the human food chain than offshore dumping, 

 and stands to more seriously affect marine productivity, 

 almost certainly remains valid. 



On the issue of the ability to reopen closed shell- 

 fishing beds if sludge dumping were relocated out of the 

 12-Mile Site, EPA has recently acknowledged that ending 

 sludge dumping at the 12-Mile Site would, indeed, allow at 

 least a partial reopening of shellfish beds in and around 

 that dumpsite: "[I]t is believed that shellfishing may 

 be reopened in the eastern third of the Apex if dumping at 

 the 12 Mile Site were discontinued." (Notice of Petition to 

 Redesignate the 12 Mile Site, 47 Fed . Reg . 56665, 56667, 

 Dec. 20, 1982). 



