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at [the 12-Milel site make it unacceptable for use for 

 the ocean disposal of [sewage sludge] " and that EPA 

 supported a resolution of the issue "which restricts the 

 ocean dumping of municipal wastes to the '106 mile ocean 

 dump site'" pending the development of "data... to 

 determine whether ocean disposal of municipal wastes may 

 be authorized under Agency regulations." A copy of this 

 directive is attached as EXHIBIT 2- 



In October 1980, the Chief of EPA Region 2's Marine 

 and Wetland Protection Branch stated in a sworn affidavit 

 (copy attached as EXHIBIT A) that " the Agency believes that 

 significant degradation of the marine environment has taken 

 place at the sewage sludge dumpsite, commonly referred to 

 as the 12 Mile Site, and surrounding areas impacted by 

 activities at the site, and that this degradation is caused, 

 at least in important part, by the ocean dumping of sewage 

 sludge. " (p. 2) . 



In short, there are a number of indications that EPA 

 is itself disposed to administratively de-desicmate the 

 12-Mile Site and to require sludge dumping to be shifted (on 

 an interim basis) to a deepwater dumping site. 



So why is it necessary or even appropriate for Congress 

 to intercede and itself mandate the phased termination of 

 sludge dumping at the 12-Mile Site? 



For several reasons. First, an administrative decision 

 by EPA to require sludge dumping municipalities to incur the 

 added expense of moving their dumping further offshore will 



