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were to emerge unscathed through the legislative process, 

 it is unlikely that the ocean's many enticements as 

 a first-resort disposal option can be fully neutralized in 

 this fashion. For example, even with the cost advantage 

 removed, it would remain politically attractive in many 

 instances to avoid antagonizing voting constituents by use 

 of land-based disposal options by going to the ocean — 

 which harbors very few voters. 



Consequently, we would advocate very strongly a further 

 amendment which would make clear that the dominant factor 

 to be considered in assessing the suitability of sludge 

 (or any other waste) for ocean dumping is the resultant harm 

 to the marine environment or human health . (We would not 

 object to a comparative harms analysis, wherein the impacts 

 on human health and the environment were evaluated for each 

 disposal medium and method, as long as a comparison of 

 costs for the different alternatives was not allowed to 

 skew the outcome) . The costs of an alternative should be 

 decisive only where the least risky land-based alternative 

 offers no colorable environmental advantages over ocean 

 dumping (i.e., costs would come into play only where all 

 other factors were equal) . 



In short, where ocean dumping is reasonably likely to 

 cause or contribute to harmful impacts on the marine 

 environment, it shouldbe a last-, rather than a first-resort 

 disposal option. 



