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effort to develop sludge standards which would lead to further 

 improvements in sludge quality and further progress by EPA in 

 developing pretreatment standards could be helpful. Development 

 by EPA of national emission standards for hazardous air pollutants 

 would also be helpful in evaluating the incineration option. 



As I stated before. New York City would be willing to pay its 

 fair share of fees for disposal if such fees were to add to 

 information from which principled decisionmaking process could flow. 

 While there is room to debate on how such a fee would be calculated, 

 it should certainly be based on some computation of real costs. 

 And whatever these real costs are, they at least should be consistent 

 with the findings of the multimedia assessment. But computation of 

 fees on the basis of the cost differential between the 12- and 

 106-mile sites assumes that the 106-mile site is more appropriate 

 and that use of the 12-mile site therefore constitutes an economic 

 windfall. We do not think that the evidence supports this assumption. 

 May 16 Staff Draft 



This proposal, in the form of a document circulated for 

 discussion by Congressmen Hughes and Forsythe, would mandate a 

 firm phaseout of the 12-mile site by December 31, 1986. It would 

 limit ocean disposal until then, both monthly and annually, to dry 

 ton quantities disposed of in 1982. It would preclude other 

 disposers using the site. A "special dumping fee" would be assessed 

 against users of the 12-mile site by EPA, which would cost the City 

 of New York $2,300,000 in 1984, $3,680,000 in 1985, and $5,060,000 

 in 1986. Twenty-five percent of the fees collected would go for 

 monitoring, surveillance, and development of a miltimedia assessment 

 of sludge management in the New York and New Jersey region, to be 

 conducted by the Federal Government. Seventy- five percent would 



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