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the Bight Apex from the Hudson-Raritan effluent plume is 

 probably the largest single input source and therefore any 

 restoration plans would have to give major considerations to 

 on-land water pollution control from both point dischargers 

 and non-point sources. As we have suggested different time- 

 frames, five years versus three, timing is also a problem. 

 Whatever time-frame is selected, it seems the first stage 

 of restoration is a decision on sludge disposal. Therefore 

 we suggest phasing in the restoration analysis after such 

 a decision is made. This should also assure that efforts will 

 not be diverted from the task at hand. 



If it is determined that ocean disposal is an appropriate 

 option for disposal, is it best to continue dumping at the 12 

 mile site or move to a deep water site such as the 106 mile 

 site? The thrust of the State's recommendations centers 

 around the need for a comprehensive multi -media assessment 

 following a NEPA format. The options of ocean disposal at 

 a shallow water site versus a deep ocean site should be 

 determined as part of the multi-media assessment. 



A request to address the proposals of Representatives Hughes 

 and Forsythe and Representatives Carper and Dyson to curb 

 dumping activities at specific sites. The Department has 

 recently received copies of the May 16 Staff Draft act and 

 subsequent (May 19) revision suggesting optional approaches. 

 The initial version of the staff proposal is based on a firm 

 3 year phaseout for disposal at the 12 mile site. However, 

 the staff has been very willing to address the concerns which 

 we raised with the initial proposal. The May 19 option paper, 

 although not fully compatible with our recommendations, repre- 

 sents significant progress. Ue believe that with additional 

 discussions, a consensus position could be attained. The 

 Department of Environmental Protection will continue to work 

 toward an acceptable solution to the current dilemma involving 

 sludge disposal in the Bight. If such a program can be developed, 

 we sincerely hope that it v;ill enjoy the support of both 

 Subcommittees. 



I wish to thank the two Chairman and the members of the Subcommittees 

 for extending an invitation to the State to testify and participate in the 

 reauthorization process. 



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