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posed the first sensible plan I have seen. Briefly, the draft of the 

 proposed plan would be to continue ocean disposal of sludge at the 

 present 12-mile site for another 5 years, while an indepth study is 

 conducted to examine the relative impacts of each land and ocean- 

 based disposal option. 



This is a logical plan which will allow the authorities and pre- 

 sumably the regulatory agencies, the time necessary to intelligent- 

 ly evaluate all disposal options. With the participation of NJDEP 

 and USEPA, it is anticipated that the study will produce options 

 for sludge disposal which will be acceptable to and consistent with 

 the policies of each agency. Hopefully, the results of this study will 

 provide solutions based upon facts — not rhetoric or political expedi- 

 ency. It will be nice to be told, for a change, what we can do in- 

 stead of what we cannot do. 



The second question you asked me to address is: "If we were com- 

 pelled to stop ocean dumping, what responsibilities do you feel the 

 Federal Government should have to provide financial or other 

 types of assistance to the authorities?" 



In response to this question, I would note at the outset that pi ; «- 

 ently there are no acceptable alternatives to ocean disposal of 

 sludge. Notwithstanding that the PVSC and the other New Jersey 

 authorities have studied and developed land-based alternatives to 

 ocean dumping, the inability of the regulatory agencies to arrive at 

 mutually consistent and acceptable policies has precluded the im- 

 plementation of land-based alternatives to ocean dumping. 



Moreover, recent scientific studies have concluded that the abili- 

 ty of the ocean to assimilate waste may be far greater than previ- 

 ously anticipated. Indeed, these studies suggest that presently the 

 ocean is the preferred medium for the disposal of sludge. In that 

 regard, for example, we respectfully address your attention to the 

 following studies: The 1978 "Environmental Impact Statement on 

 the Ocean Dumping of Sewage Sludge in the New York Bight," 

 prepared by the USEPA, the 2-year study entitled "The Role of the 

 Ocean in a Waste Management Strategy," prepared by the Nation- 

 al Advisory Committee on Oceans and Atmosphere, the report enti- 

 tled "A Preliminary Assessment of the Environmental Consider- 

 ations for the Disposal of Sewage Sludge in the New York Bight: 

 Present Ocean Dumping Conditions and Proposed Land-Based Al- 

 ternatives," prepared by Ecological Analysts, Inc., for the city of 

 New York, as well as the "Comments Supporting the Redesigna- 

 tion of the 12-Mile Site and the 106-Mile Site," prepared by the 

 PVSC and the other New Jersey authorities with the assistance of 

 Ecological Analysts, Inc., and Seamotion, Inc., and submitted to the 

 USEPA for consideration during current rule-making proceedings 

 concerning ocean dumping of sludge. 



We believe that NJDEP's proposed plan to study all available op- 

 tions for sludge disposal is the proper way to go. As indicated previ- 

 ously, we believe that both the NJDEP and USEPA should partici- 

 pate in this study to the end that mutually agreeable solutions will 

 be identified. In view of the previous financial commitment already 

 made by the PVSC and the other New Jersey authorities to the de- 

 velopment and construction of land-based alternatives, at the direc- 

 tion of USEPA, it is only fair that the Federal Government partici- 

 pate in the cost of the proposed NJDEP study along with those au- 



