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it is simply not true that the continued use of the 12-mile site 

 is a bad choice environmentally. Dr. Gift will address this in 

 his testimony. The bottom line, based on the available scientific 

 evidence, is that halting sewage sludge disposal at the 12-mile 

 site would cause no significant, and probably no measurable 

 improvement in the environmental condition of the Bight. In 

 addition, there are significant air and groundwater pollution risks 

 associated with the non-ocean alternatives. 



We think that this is the kind of analysis that should form 

 the basis for waste management decisions. It is becoming clear 

 that there is no political solution to the problem of sewage sludge 

 disposal which will be widely acceptable. Let the facts speak. 

 And if the concensus of informed opinion among scientists and 

 experts arrives at a different answer than currently appears to be 

 the case, we will embrace it. 



The City of New York is strongly in favor of developing a 

 sound informational basis for making decisions about waste manage- 

 ment. We support the necessary research and monitoring to 

 determine the condition of the Bight and the effects of various 

 disposal options. We support adequate funding for NOAA and EPA 

 in this effort. We also support any fee provision which fairly 

 allocates the cost of obtaining the information among the generators 

 of the relevant wastes, which is non-punitive, and which does not 

 pre- judge the merits of the disposal options. 



The City recognizes that a decisionmaking process which is 

 driven by information will never be static. New information will 



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