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In addition. New York State has extended a moratorium on all 

 landspreading of municipal sewage sludge on the "better" 

 agricultural soils of the State. As long as this moratorium 

 remains in place, even the cleanest sludges are not allowed to 

 be landspread on approximately half of the State's agricultural 

 lands. While the State may revise both its moratorium and its 

 sludge quality criteria for landspreading, the sludges currently 

 produced by the City could not be disposed by land application 

 or composting except in very limited, highly degraded land 

 areas. 



2. Why is the City of Philadelphia able to find landbased 



disposal alternatives for its sewage sludge while NYC dumps 

 all of its sludge? 



There are a number of reasons why the City of Philadelphia h»s 

 been able to dispose of its sludges on land, while New York City 

 has continued to ocean dispose its sludge. As stated above. New 

 York City's sludges generally cannot pass either U.S.D.A. or New 

 York State criteria for the quality of sludges that can be 

 land-applied. Philadelphia's sewage sludges generally may 

 contain lower concentrations of heavy metals which makes them 

 more appropriate for land application. In fact, some 35 percent 

 of Philadelphia's sludges are reported to be suitable for land 

 application to local farms and parks and some are even suitable 

 for commercial trade to other states. The City of Philadelphia 

 has been applying most of its sludges (60 percent) to abandoned 

 strip-mined lands in western Pennsylvania which are already 

 environmentally degraded. Since suitable strif>-mined lands are 



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