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preparation of our special permit application, which provides the 

 information for a risk assessment of ocean disposal compared with 

 the incineration alternative. 



I would like to emphasize that we are not attempting to rely 

 on the administrative procedures as a dilatory tactic to avoid the 

 difficult task of determining disposal options. On the contrary, 

 I feel that we have done a great deal to identify what is known 

 and needs to be known about ocean disposal and to develop a 

 rational framework for making decisions about long-term disposal 

 options. We are doing everything we can to show all parties the 

 City's good faith. We are actively soliciting and promoting a 

 timely decision on the merits. We would strongly support any 

 efforts by this Committee or the Congress to promote adequate 

 resources and timely regulatory action by EPA, including the 

 provisions contained in H.R. 1761. 



If Congress repudiates the administrative process and compells 

 a ban on ocean disposal, the question of the appropriate level of 

 Federal assistance naturally arises. The City believes that 

 the best evidence currently available indicates that there would 

 be no discernable environmental benefit from stopping ocean disposal 

 at the present time, and that quite possibly there would be a 

 significant environmental detriment. There is certainly no evidence 

 that we are aware of that would indicate that the additional expense 

 of land-based alternatives would provide an environmental benefit 

 comparable to the benefits that could be derived through other 

 investments. In the absence of financial assistance, the necessary 

 funds would be diverted from other environmental and social goals 



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