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b) A requirement by Congress that continued use of the 12 Mile 

 Site be subject to preparation of a comprehensive multi-media 

 assessment by EPA in cooperation with the States of New Jersey 

 and New York. The multi-media assessment under the NEPA 

 format should analyze the various land based alternatives 



and ocean disposal at the 12, 60, and 106 mile sites to 

 determine the most environmentally acceptable disposal method 

 and the technological, economic, and legal requirements 

 necessary to produce acceptability. Congress should mandate 

 that the assessment be completed no later than three years 

 from the date of reauthorization of the MPRSA. Final decision- 

 making on the most acceptable disposal method or methods should 

 than take place by EPA, Congress and the affected states and 

 implementation begin within the recommended five year interim 

 ocean dumping authorization. 



c) The enactment by Congress of user fees for ocean disposal 

 at the 12 Mile Site. The fees should be tied to the five 

 year interim ocean disposal authorization and designed to 

 provide a framework for final resolution of the disputed issues. 

 A fee structure should be established to accomplish the 

 following purposes: 



1) Prepare a multi-media assessment under the NEPA format, 



2) Continue monitoring and surveillance by EPA, the 

 Coast Guard and NOAA, 



3) Conduct research on the impact of ocean disposal of 

 sewage sludge, 



4) Conduct research on land based sludge management and 

 disposal technologies applicable to the New York/ 

 Northern New Jersey metropolitan area, and 



5) Help finance facilities necessary for implementation 

 of the adopted long term sludge disposal method. 



At the fee levels we recommend, a fixed percentage of the fees, 

 between 10-15%, should be collected by EPA and be adequate for 

 the purposes above. The remainder of the fees should be levied 

 but not collected by the federal government. Rather, the fees 

 should be placed in special trust accounts established by each 

 of the sewerage agencies and dedicated for the financing of 

 long term sludge disposal methods. The funds could be drawn 

 upon by the sewerage agency to finance the selected long term 

 sludge disposal option. 



The user fees should be graduated over the five year period 

 to lessen the economic impact on the industrial users and 

 communities within the service area. The fee structure should 

 be sufficient in size to accomplish the federal purposes (1-5 

 above) and make a meaningful contribution to a facilities 

 financing program, A fee tied to a portion of the estimated 

 short term cost differential from dumping at the 12 Mile Site 

 versus the 106 Mile Site may be an equitable starting point. 



