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go to special accounts for use by the municipalities to improve 

 sludge quality and identify and implement alternatives to ocean 

 dumping. The proposal also mandates that EPA: 



• assess land and ocean disposal options using their 25% 

 share; 



• develop a plan for improving the overall water quality 

 of the Bight Aprex; 



• present this plan to Congress within three years; 



• establish sewage sludge quality standards within one year; 



• charge additional user fees for administering and monitoring 

 ocean disposal under Section 102 of the Ocean Dumping Act; 

 and 



• upon Congress' authorization, assess further additional fees 

 for implementing ocean disposal alternatives or water quality 

 improvements . 



The proposal further provides that after 1986 no ocean dumping 

 anywhere would be permitted unless pretreatment programs are fully 

 complied with or a scheduled phase-out of ocean dumping is agreed 

 to between the municipality and EPA. 



While the proposal retains some of the features of the New 

 Jersey plan, the logic of the proposal is marred by the a priori 

 determination that dumping at the 12-mile site is unacceptable and 

 must be banned. Thus, the multimedia assessment may assess all the 

 media and all locations — other than the 12-mile site. Likewise, 

 the New York Bight Restoration Plan, to be submitted by EPA some 

 time after the 12-mile ban is well on its way to being implemented, 

 shall assess pathways of pollutants into the Bight and determine 



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