Recently, we at Berkshire Environmental Action Team (BEAT) have found ourselves responding to the same question many times. Which of the PCB cleanup solutions for the Housatonic River does BEAT support? The sudden increase in concern has been generated by the distribution by GE of a 25-minute video that presents GE’s view on the subject. The video has been shown on television and is now being mailed to residents of Berkshire County. We welcome this increased concern and interest, especially if people look farther than the video for answers to a very important question. Let me give you my take on the GE video. A copy of the transcript (created by BEAT) is available here.
First a little context. Over the past few years, GE was forced by EPA and the courts to remove some of its PCBs from two miles of the Housatonic River in Pittsfield. Now the EPA is deciding how best to approach the cleanup of the rest of the river. The cost to GE, which could be substantial, will depend on decisions made by EPA and the courts. GE’s video is part of a well financed and choreographed appeal to public opinion in the hope that we, the public, will put pressure on EPA to require as little as possible from GE.
The first three minutes of the video are devoted to painting a picture of the river as a wild and scenic waterway that should be cherished and protected from change. It begins with sweet sounds of music playing as the waters rush by. A soothing and nurturing female voice begins the narrative as an autumn leaf floats slowly down the river. There is little in the way of details or specifics. Those will come later. This is clearly a stage-setting introduction. It is meant to define the task at hand, and to introduce GE as the caring and nurturing party in the debate.
OK. Let’s stop right there. BEAT doesn’t have money to pay people to play violins or to hire voice talent, but we do have a nine-year history of working to protect the river. My first reaction to the introduction is to observe that whatever health the Housatonic River has, it has despite the abuse meted out by GE. For GE to present itself as the river’s caretaker is an insult to those organizations, BEAT included, who work day in and day out to actually protect the river.
The video begins with the following four text panels.
“The Housatonic River has always been a defining element of the Berkshires. It has provided power for mills, scenic beauty and recreation for all and served as an important refuge for wildlife, including dozens of threatened, rare or endangered species.
In the coming months the U.S. Environmental Protection Agency will determine the future of the Housatonic River when it decides whether to require additional construction activity in and along the river.
GE funded the production of the film you are about to see which examines three of the alternatives being considered and their consequences.
Please watch for the next 25 minutes to learn about what these alternatives would mean for the future of the Housatonic River and its wildlife, and for the residents of the Berkshires.”
Already, we have a problem. EPA is not deciding “whether to require additional construction activity”. EPA is deciding how best to proceed with the cleanup of PCBs. Also, although EPA is in the fact-gathering and discussion phase of the proceedings, GE is attempting to limit discussion to “three of the alternatives being considered and their consequences.” These are three alternatives that GE would like us to focus on. Just understand that at this point in the process we are not limited to any list of proposals or alternatives – certainly not to a list created by GE.
[opening music, birds singing, leaves floating serenely on the river]
“For centuries it has carved its way across this floodplain. It has witnessed the arrival of the Europeans and the coming of the Industrial Revolution. For generations, the Housatonic River of New England has remained a magnet for nature lovers who come to enjoy its beautiful scenery and abundant wildlife. During the twentieth century, polychlorinated biphenyls, PCBs, were released to the river and spread into the riverbed and the surrounding area. Despite years of cleanups, some PCBs remain. The question now is what should be done about them. How we answer that question will impact generations to come.”
BEAT is glad GE has brought up the issue of history. For years, GE dumped its PCBs into the Housatonic River, home of “abundant wildlife.” We’re talking about a period that included the post-World War II era. During this period, the river deteriorated from the pristine waterway described in the video to a horrific running concoction of all sorts of industrial and residential waste. GE was a major contributor to this mix. Over the years, thanks to more progressive environmental regulations and efforts of individuals and organizations, the river has been cleaned of its visible pollutants and most of its invisible pollutants. PCBs remain.
Notice that GE says that “polychlorinated biphenyls, PCBs, were released to the river…” as if this were some sort of unfortunate accident. No mention of the fact that it was GE that released them into the river. They even avoid saying that PCBs were released INTO the river. They say they were released TO the river as if this dumping were some sort of offering on the part of GE. Yes, mistakes were made. Nowhere in this video will GE take responsibility for its actions, but the sweet music will continue to play.
In the past, GE has taken the position that the period between 1932 and 1977, during which they used PCBs in their electrical transformers, was a different time. People didn’t know about the harm that could result from PCBs. The following historical information is taken largely from the website of the Housatonic River Initiative (HRI). Citations and further details can be found there.
In 1936, one year before GE began using PCBs, Dr. Lewis Schwartz, Senior Surgeon with the United States Public Health Service, wrote a paper in which he warned of the dangers of Pyrenol, the version of PCBs used by GE. In it Dr. Schwartz said:
“In addition to the skin lesions, symptoms of systematic poisoning have occurred among workers inhaling the fumes. Those working with the chloro diphenyls (PCBs) have complained of digestive disturbances, burning of the eyes, impotence and hematuria. The latter symptom developed among a number of men making amino diphenyl, which is used in the making of a rubber antioxidant. Causes of death from yellow atrophy of the liver have been reported among workers exposed to the fumes of the chloro naphthalenes.”
Also in 1936, Dr. Schwartz cautioned in an article that “workers in chlorinated naphthalenes and di phenyls (PCBs) should be periodically examined for symptoms of systemic poisoning.”
This is not some obscure reference. This is the United States Public Health Service. And in case you’re thinking that maybe GE was unaware of the problems associated with the chemical that they were using in massive amounts, here’s a statement made in 1937 by F. R. Kaimer, Assistant Manager of a GE plant in Pennsylvania where PCBs were being used to treat wire. [NOTE: halowax is a name for PCBs used by one of its manufacturers.)
“It is only one and a half years ago that we had in the neighborhood of 50 to 60 men afflicted with various degrees of this acne about which you all know. Eight or ten of them were very severely afflicted – horrible specimens as far as their skin conditions were concerned. One man died and the diagnosis may have attributed his death to exposure to halowax vapors but we are not sure of that … we had 50 other men in very bad condition as far as the acne was concerned. The first reaction that several of our executives had was to throw it out – get it out of our plant. They didn’t want anything like that for treating wire. But that was easily said but not so easily done. We might just as well have thrown our business to the four winds and said, ‘We’ll close up,’ because there was no substitute and there is none today in spite of all the efforts we have made through our own research laboratories to find one.”
Keep in mind that I am pointing this out because the first three minutes of the GE video is aimed at portraying GE as the steward of the river. You may object and say that 1937 is early in the story. Surely they changed their ways as the picture became more clear. In 1990, filmmaker Mickey Friedman interviewed retired GE workers for his documentary entitled “Good Things To Life.” Among those interviewed were retired GE workers Ed Bates and Charles Fessenden. They worked with PCBs at GE in the 1940s through the 1970s when it was phased out. Around the age of 40 or 50, Ed and Charlie started noticing that they were going to a lot of wakes and funerals for friends. They were concerned. They read in the paper that there was a high incidence of cancer in Pittsfield. In 1979 they heard that a researcher from Harvard University was going to do an independent study of GE workers and the incidence of cancer. They contacted GE and offered to be part of the study. They were not included. They wondered what was going on. They submitted the names of fellow workers who had died and tried to get them included in the study.
Ed: “Charlie and I had submitted the names, 60 names back in 1983, and they finally gave us the list of 60 names and the causes of death in 1988, five years later, to do 60 of them, 61. Out of 61 there were 13 people they excluded from the study because they said that they couldn’t find them or it was out of the time range and we agreed with that. Left 48 names on their with the causes of death. … Out of these 48 names and the 48 causes of death, every one of them was wrong. Every one. And Charlie and I knew some. They had a fellow dying in a fire – and so Charlie and I went to every town hall in Berkshire County. We got their death certificates which indicated they were wrong.”
That music on the video is beginning to sound a little more Gothic to me now. The entire interview and the outcome of the study are available on HRI’s website. Here’s some more from Ed and Charlie.
Ed: “We used to use an average of 20,000 gallons of Pyrenol a week. And this is, if you did simple mathematics, this is 140,000 pounds of Pyrenol, of PCBs a week that we were handling. And we had a loss rate, spillage, over-filling of about 3%. So this says that every week we would lose between 4,000 and 5,000 pounds of PCBs that would go down the drain and into the river.”
Now keep in mind that to dispose of some of their PCB-laden waste, GE would donate it to parks and schools. Shocking? This is the same GE that after being forced to clean its PCBs from the river in Pittsfield, decided to dump those PCBs next to an elementary school.
The narrator continues:
“Wildlife is thriving here, even though the river and surrounding areas contain PCBs. Between the 1930s and 1970s PCBs were commonly used in electrical machinery. Equipment manufactured by GE in Pittsfield contained them as well. Over time, some of these PCBs contaminated the river and the surrounding areas.”
Is wildlife thriving despite PCBs? This is a major point in the debate. I will leave it for now, and address it fully when GE addresses it fully, later in the video.
“Between the 1930s and 1970s PCBs were commonly used in electrical machinery.” Again GE uses the passive voice. PCBs were used, not GE used PCBs. The fact that they were commonly used has no bearing on the issue at hand, unless GE is again attempting to argue that they had no knowledge of the risk PCBs posed. And in fact, GE was a major consumer of PCBs and the only source of PCBs in the Housatonic. “Equipment manufactured by GE in Pittsfield contained them as well.” Again, this was the only source of PCBs in the Housatonic River. This sentence gives one the impression that GE is being unfairly singled out. “Over time, some of these PCBs contaminated the river and surrounding areas.” Again, no responsibility on GE’s part. I feel quite confident that a team of GE’s PR people thought carefully about every word and phrase in this video. They say PCBs contaminated the river. In fact, PCBs go where CEOs send them. GE dumped PCBs into the river, buried barrels of PCB-laden waste in landfills, allowed PCBs to drain directly into the river, and gave away PCB-laden fill as clean fill. Again, nowhere in this video does GE take any responsibility for this environmental tragedy.
The following narration completes GE’s three-minute introduction.
“The most highly contaminated sections have been cleaned up. Ten years ago, work crews began to remove PCBs from the former GE facility in Pittsfield and from two miles of river passing through the city of Pittsfield. One hundred and ten thousand cubic yards of sediment and soil were removed. The river and its banks were dug up and lined with rock, and in some places brick. The end result was a radical reduction in the amount of PCBs in that stretch of the Housatonic. The question now is what is best for downstream sections of the river.”
Again, most of this is best addressed when it comes up more fully in the video. But I would like to briefly address the issue of “The river banks were dug up and lined with rock, and in some places brick.” Yes, part of the river in Pittsfield was made to look ugly, although it is now recovering nicely. It’s interesting that GE supported this approach to restoring the riverbank over the objections of environmental groups, most notably HRI. Now they point to the result as a rationale for not making them clean the rest of the river. How convenient. In effect they are saying, “But look at what a terrible job we did the last time you asked us to fix it.” Also, much of this Pittsfield section had already been lined with riprap in the 1930s and 1940s by the Army Corps of Engineers. It is unlikely that this approach would be used on the rest of the river farther south.
In October of this year, GE presented to EPA a report called the Revised Corrective Measures Study Report, also called the CMS. In this report GE described its recommendations for removing PCBs from the Housatonic River downstream of the stretch in Pittsfield that has already been remediated. Remember, these are GE’s proposals. EPA doesn’t have to accept them. There are other options out there as well.
In this report, GE came up with ten approaches to remediating the sediments that make up the riverbed of the Housatonic River. They called these approaches SED 1 through SED 10. They also came up with nine approaches to cleaning PCBs from the river’s floodplain. They called these approaches FP 1 through FP 9. They call different combinations of these approaches by their combined designations. For instance, if they want to talk about an approach that uses SED 3 to clean the riverbottom and FP 4 to clean the floodplain, they call it SED 3/FP 4. This is their nomenclature, and it makes sense as a way to discuss their various proposals.
With this in mind, let’s go back to the video’s narration.
“We’ll examine three approaches. Monitored Natural Recovery: PCBs are captured before they can enter the river upstream while nature buries the PCBs remaining in the river. SED 3/FP 3: Five miles of river and 44 acres of forest and wetlands will be excavated. Another 37 acres of riverbed and 60 acres of Woods Pond will be capped with clean soil. The Ecologically Sensitive Approach or ESA: A far less damaging approach that still protects human health.”
So the first proposal GE would like us to consider they call “Monitored Natural Recovery.” Notice that this proposal doesn’t have a SED or FP designation, and there’s a good reason for this. This option doesn’t include cleaning the riverbed or the floodplain. GE could have called it “Watching the River Flow,” or even the “Please-Don’t-Make-Us-Clean-Up-Our-Mess Approach.” But their PR people went with “Monitored Natural Recovery.”
GE would have us believe that this approach involves allowing natural recovery to occur – the river heals itself over time. I’m surprised GE is even trying to get away with this one, although it’s not the most surprising idea presented in the video. (That award would have to go to the bucket of sand analogy which comes up later.)
The idea that nature will bury the PCBs over time is very appealing. We would all like it to be true, but it just doesn’t work that way. BEAT has been organizing river cleanups in the Housatonic River since 2002. We jump in with waders and shovels and dig out and pull out shopping carts, bicycles, bowling balls, and all sorts of objects that are often partially buried in sediments. This might sound like we’re making GE’s point, but those sediments came from some other part of the river. In some places we pull out old tires, bottles, radios, and televisions that had been covered in sediment for years but have recently been revealed as the force of the flowing river uncovers them.
The point is that the river is powerful and dynamic and the riverbed is always changing. Sedimentation rates and patterns on the riverbottom change with the seasons and with weather, and they’re different along different stretches of the river. If the riverbottom were always uniformly collecting sediment, the Housatonic River would slowly fill in and disappear. We certainly shouldn’t count on the idea that “…nature buries the PCBs remaining in the river.” Nothing stays buried for very long in the river.
Sometimes GE supplements this approach of having Mother Nature sweep things under the rug by dropping a thin layer of sand over the PCB-laden bottom. They like this idea. It’s cheap. They plan to do this in Silver Lake, despite cautions from local people that Silver Lake is fed in part by underwater springs. Underwater springs would bubble up right through the sand and bring the underlying PCBs to the surface again.
Keep in mind that according to GE, “monitored natural recovery” and capping will solve our problem by putting a very thin layer of sediment on the PCBs. Then we’ll have PCBs in the sediment. Wait a minute. Isn’t that the problem we’re trying to get rid of? GE’s own studies tell us that the average sedimentation rate along most of the river is between 0.05 inches per year and 0.6 inches per year. Is this really what GE sees as the solution to having PCBs in the soil? We need to get rid of PCBs – not hide them from view.
Notice the other part of the “Monitored Natural Recovery” approach. The narrator says that in this method, “PCBs are captured before they can enter the river upstream.” Most people don’t realize that PCBs are still going into the river upstream of the section in Pittsfield that is supposedly already cleaned. GE has been dragging its corporate feet for years on the issue of cleaning Silver Lake, Unkamet Brook, and their former property on East Street, all of which are upstream of previous cleanup activities, and all of which continue to send PCBs into the river. (Actually, Unkamet Brook is upstream of all of the previous work. The other two are upstream of most of the previous work.) If GE had the technology to prevent this, as the narrator suggests, why have they still not done it? I will have more to say about this when later in the video GE points to the cleanup of their former property.
The second approach presented by GE is SED 3/FP 3. This is the combination that uses GE’s approach SED 3 to clean the riverbottom and GE’s approach FP 3 to clean the floodplain. This combination is also the straw dog used to scare us, and it starts right here. “Five miles of river and 44 acres of forest and wetlands will be excavated. Another 37 acres of riverbed and 60 acres of Woods Pond will be capped with clean soil.” Later in the video, when GE describes each of the three showcased options in more detail, SED 3/FP 3 is portrayed as bringer of doom with images of heavy machinery and predictions of devastation. They describe 30 staging areas for construction crews and describe massive construction and destruction along the river.
Let’s keep in mind that this approach that GE and their paid spokespeople are warning us about, with their visions of heavy equipment and destroyed riverbanks, is GE’s proposal, not EPA’s proposal. Nobody other than GE is saying we should do this. The intent is to first convince us that there are only three proposals on the table, and then convince us that we had better quickly choose one of the other two that they are offering. I’m certainly not going to fall into the trap of defending SED 3/FP 3. I don’t like it either. Instead, I would like to suggest that if GE finds this option scary, they should come up with a different one. I have an idea that might help them.
GE estimates the cost of implementing SED 3/FP 3 to be somewhere between $200 million and $300 million. Meanwhile, here’s what the trade journals are saying about another part of GE’s business. [Note: bn is billion.]
“GE has said that it will invest $1.4bn in cleantech research and development in 2008 as part of its Ecomagination initiative. As of October 2008, the scheme had resulted in 70 green products being brought to market, ranging from halogen lamps to biogas engines. In 2007, GE raised the annual revenue target for its Ecomagination initiative from $20bn in 2010 to $25bn following positive market response to its new product lines.”
Could the problem be that all of the GE people with imagination are working in Ecomagination leaving no creative people for the cleanup. I suggest that GE go back to the drawing board and look for some real solutions. Spend some of your money cleaning the river you polluted. Stop saying, “It can’t be done.” Ask the people in Ecomagination for help. Put them on the cleanup. But of course, that wouldn’t work. The current system by which GE proposes how it will be made to clean the river ensures that GE’s incentives lie in the direction of not finding an effective solution.
The third solution offered by GE is SED 10/FP 9. Confused? You don’t remember SED 10/FP 9 being mentioned in the video? SED 10/FP 9 is what GE calls the “Environmentally Sensitive Approach or ESA.” They like this option, so they won’t use their scary sounding designations. They will give it a warm and fuzzy name. Keep in mind that the whole point of EPA’s task is to find an ecologically sensitive approach to cleaning up GE’s mess. The fact that GE calls SED 10/FP 9 the ecologically sensitive approach is just another way for GE to say “We like this one.”
The narrator continues:
“The highest remaining concentrations of PCBs exist between Pittsfield, south of the confluence of the two branches of the river, and Woods Pond dam, in the adjoining towns of Lenox and Lee. South of the dam, the river is cleaner. In the 11 mile stretch between the confluence and Woods Pond, the river is wild. Home to more animals than people. It is one of the few places in the state where there is virtually no development along the river bank. The largest landowner is the Commonwealth of Massachusetts.”
This seems to be basically accurate, although this is where GE begins to make its point that the wildlife and natural communities along the river are immune to the well documented effects of PCBs. I’m not surprised, since GE states many times in the CMS that if they don’t like EPA’s final decision, they reserve the right to sue the government. Their rationale is that GE does not believe that PCBs are harmful to people or to animals, and therefore they shouldn’t be made to clean the river. In the CMS, GE says that tests on humans show no evidence that PCBs cause cancer or non-cancer adverse effects. This is very hard to reconcile with the majority of research done in this field. Perhaps GE should learn a lesson from the tobacco industry. If only the people who profit from a product say the product is safe, people tend to doubt your claims.
GE further says that the effects of PCBs on humans based on animal tests can’t be trusted because the tissues of the animals used in the studies are much more sensitive to PCBs than are human tissues. It’s hard to reconcile this with GE’s contention that animal populations along the Housatonic River are “thriving” despite high levels of PCBs in their tissues. Are animals overly sensitive to PCBs in the laboratory and insensitive to PCBs in the wild?
The narrator continues:
“Professor Robert Brooks of Pennsylvania State University, first came to study wildlife on the river in the 1970s.”
[Professor Brooks in a canoe on the Housatonic River] “When you spend some time in a place, canoeing or walking, you really get to know it well. And I’ve come to appreciate what incredible biodiversity there is in this section of the Housatonic. To have a resource like this in your backyard is a real treasure.”
Does this seem odd to anyone else? Is it just me? Berkshire Community College has a biology department and an environmental studies department. MCLA does too. Not very far away we have the Five Colleges including the University of Massachusetts. Just to the west we have SUNY Albany. I’ll bet many of our local biologists and environmental scientists would have been willing to speak about PCBs and the Housatonic River for free. But GE wouldn’t want to give most of them a public platform.
So the guy from Pennsylvania is going to tell us not to worry about the stuff dumped in our backyard by the company that after dumping it pulled up stakes and left town. Come to think of it, GE’s CEO Jeff Immelt used to live in Pittsfield but decided to leave town. Somehow I’m not reassured.
At some locations along the river south of Pittsfield there are places where the riverbank includes high mud walls that are used by kingfishers and swallows for nesting. Any attempt at removing PCBs from these high-walled banks would probably result in at least the temporary loss of nesting habitat for these birds. GE would like to focus our attention on this issue as the video resumes.
“The river is carving through the floodplain creating these microhabitats. That creates tremendous diversity, both in habitats and in species that live in those habitats. In this section we see very high banks, those are prime nesting sites for kingfishers and bank swallows. Kingfishers also use these sites for foraging perches.”
I am glad that Professor Brooks is calling attention to the microhabitats along the river. I would like to do that as well. GE has put a lot of energy into convincing us that there are three options for remediating the river. They are, as I’ve said, “Monitored Natural Recovery” in which GE watches (monitors) the river as it supposedly heals itself, SED 3/FP 3 in which we dig up the entire river with heavy construction equipment and send wildlife scurrying into the hills, and SED 10/FP 9 which GE renamed “The Ecologically Sensitive Approach” in an effort to sell it to us.
The fact of the matter is that we can choose to remediate each microhabitat in a way that is best suited to that habitat. To suggest that if we choose SED 3/FP 3 we will have to destroy the nests of kingfishers and swallows is wrong on at least two counts. First, we aren’t choosing one approach for the whole river. Second, we are not limited to the three approaches GE is asking us to consider. So what’s the solution to the high banks? Leave them alone. Chances are they don’t have high levels of PCBs anyway. Just leave them. Keep in mind that these high banks are cut back by the river every year, revealing a new face as the river continually changes its shape. And if we do find that the banks have high levels of PCBs, we don’t want birds nesting in that soil anyway. GE doesn’t want us to apply our analytic skill to the process because that takes some of the scare out of remediation. Am I alone in thinking that GE is trying to scare us out of remediating the river?
I mentioned earlier that GE’s report to EPA is called the revised Corrective Measures Study or CMS. This is the report in which GE makes its suggestions for PCB remediation to EPA. The original CMS was submitted by GE in 2008. EPA sent it back stating “EPA has completed its review of the General Electric Company’s (GE’s) Corrective Measures Study (CMS) and, after consideration of input received from the public and state and federal agencies, EPA is requiring GE to address over 150 inadequacies or other comments.” What didn’t EPA like? Of the 150 inadequacies, EPA bulleted 18 of them. Here’s one of those 18.
“EPA notified GE of EPA’s concerns regarding the need for a balanced assessment of the CMS evaluation criteria, including that the CMS focuses unevenly on the short-term detrimental effects rather than the long-term positive effects of the remedial alternatives and highlights percent reductions in PCB concentrations, rather than the more important effects of the risks remaining after the cleanup.”
In other words, stop telling us how scary the remediation is going to be and start telling us how you’re going to clean the river. I don’t think the revised CMS did any better than the original CMS on this point. GE has no incentive to do an honest appraisal of how best to clean the river. As a corporation, their incentive is to convince everyone that a cleanup cannot be accomplished without destroying the river. EPA asked GE for their suggestions. GE has answered. They have failed. They say it can’t be done. I think at this point EPA should take GE out of the process and brainstorm with the public, with other agencies, and with scientists to find a real solution. GE’s only role in cleaning up their mess should be to pick up the tab for the cleanup.
“There is plenty for the kingfishers and other birds to eat. Twenty-five types of fish, including perch and large mouth bass, thrive in the river and its backwaters.”
Does GE really want to point to the fact that fish make up most of the diet of kingfishers? Do I have to remind GE that they are required by law to maintain the warning signs along the river that forbid us to eat the fish in the river? We are also prohibited from eating the ducks that are on the river.
Those Housatonic perch that the narrator is talking about as the video shows a kingfisher eating a fish, have a mean PCB concentration of 87.3 mg/kg in their fat tissue. (NOTE: mg/kg is the same as parts per million). For large mouth bass the percentage is 97.1 mg/kg. And I’m not sure what the narrator means by thriving. The fish are reproducing and surviving despite observed anatomical malformations and high levels of PCBs in their tissues. If GE considers this thriving, then I would suggest that they are setting the bar a bit low.
“The region is also home to larger mammals that range through the thousands of acres of wetlands and forests flanking the river.”
“Black bear, bobcat, fisher, coyote. They use this forested riparian corridor as an important habitat and dispersal corridor.”
Yes, you can find large mammals along the Housatonic River. You can also find large mammals in the rest of the county and in the rest of the state. This is hardly something to point to in order to say PCBs aren’t affecting wildlife.
One mammal species for which we have PCB-related data is the mink. This is a mammal whose diet is made up mostly of fish. Researchers at the University of Michigan fed fish that were caught in the Housatonic River to young mink (kits). Why were they doing this study? According to the researchers:
“The Housatonic River flows through habitat that has historically sustained viable populations of piscivorous species, such as mink. Recent field studies have demonstrated a paucity of this wildlife along the more highly contaminated sections of the river. Viable populations inhabit nearby reference areas, suggesting that PCBs potentially have an adverse effect on these species. Thus, the present study was designed to evaluate whether farmraised mink fed diets containing PCB-contaminated fish from the Housatonic River would exhibit impaired reproductive performance and/or offspring (kit) growth and survival.” Remember the narrator’s claim that wildlife is thriving along the Housatonic River?
So what was the result of the study? Half of the mink kits died. The concentration of PCBs in the fish they were fed was 4 mg/kg. Remember that the mean tissue concentration in the perch and large mouth bass were many times greater than this (87.3 mg/kg and 97.1 mg/kg). Also, according to the researchers, “Because inclusion of PCB-contaminated fish that comprised less than 4% of the diet impacted mink kit survival, it is likely that consumption of up to 8-fold that quantity of HR fish, as could be expected for wild mink, would have an adverse effect on wild mink populations.” In other words, wild mink living along the Housatonic River would have eaten 8 times as many fish and those fish would have been much more contaminated.
“The river and the surrounding area also provide critical habitat for twenty-eight state-listed endangered, threatened, and special concern species. Sensitive species like the Jefferson Salamander, the wood turtle, and the wood frog, can all be found here.”
The amphibians (frogs, toads, salamanders) living along the Housatonic River are not thriving. Certainly wood frogs aren’t. I’ll save a discussion of amphibians for later in the video when GE’s narrator and Professor Brooks tell us about vernal pools. But what about those threatened and endangered species?
EPA looked at three species that they felt were representative of the 28 threatened and endangered species. They studied the bald eagle, the small-footed myotis (an insect-eating bat), and the American bittern (a wading bird). They concluded that “The risk characterization indicates that American bitterns … and bald eagles are likely at high risk, and small-footed myotis are at intermediate risk as a result of exposure to PCBs and other contaminants in the PSA.” [NOTE: PSA is primary study area or the river above the Woods Pond dam] I believe that if threatened and endangered amphibians had been added to the study group, the conclusions would have been that they too are at high risk. As a matter of fact, in a separate part of the EPA’s report directed at the assessment of amphibian populations in general, rather than at just threatened and endangered species, the EPA said “The risk characterization indicates that there is a high probability of ecologically significant risk to amphibians such as leopard frogs … above Woods Pond Dam. In addition, several large areas of the floodplain may pose risk to amphibians between Woods Pond and Rising Pond, with only small isolated areas of potential risk downstream of Rising Pond.”
The risk to threatened and endangered species does not come from remediation. It comes from the PCB contamination in their environment.
“Because of the unique character of the river and its floodplain, the upper Housatonic was designated an Area of Critical Environmental Concern by the Commonwealth of Massachusetts. As a result, the state must now closely review any action that could damage this natural treasure.”
Let’s pause for a moment to consider the hypocrisy here. We’re being admonished by GE that we have to protect this “natural treasure.” GE is the corporation that dumped PCBs into the river, buried barrels of PCB-laden waste throughout the floodplain , allowed PCBs to drain directly into the river, gave away PCB-laden fill as clean fill, and created a toxic waste dump next to an elementary school. GE is responsible for more Superfund sites than any other corporation in this country. They are telling us to protect this natural treasure? I for one am outraged that GE would even consider admonishing me to take care of the river. Nowhere in this video does GE take any responsibility for the harm they did to this natural treasure.
And yes, the upper Housatonic is now an Area of Critical Environmental Concern. This is just one more reminder that we have to do what’s best for the river and its wildlife, not what’s best for GE’s bottom line.
“This stretch of the Housatonic is also a favorite spot for hunters, birdwatchers, and outdoor enthusiasts. Even the most observant nature lover can’t see the PCBs that remain in the riverbanks. The average amount of PCBs found along this bank is estimated at 15 parts per million. If this bucket of sediment contains over two million grains of sand and soil, PCBs would account for 30 grains. Amounts in the water are more than 1,000 times lower than that.”
To me, this is the most amazing part of the video. Let me see if I can understand the logic. “Even the most observant nature lover” can’t see molecules such as PCBs, therefore PCBs can’t hurt us. I think I learned in third grade that we can’t see molecules, but that they make up the “stuff” of our physical world. And as for the equally childish bucket-of-sand analogy, let me offer this observation. The fact that it takes only 30 grains worth of PCBs to cause all the trouble we’re seeing in the river is compelling evidence for the toxicity of the chemical GE so freely dumped on us. I would also like to point out that their 15 parts per million figure (30 grains of PCBs per 2 million grains of sand) is an average. The river has “hot spots” where the PCB concentrations are very high, and there are places where the river has little to no PCBs. This is one of the reasons we should be able to remediate different parts of the river using different approaches. There is no need to turn the river into one big construction site as GE has been stating in its attempt to scare us away from any remediation.
“To deal with the PCBs, many approaches have been suggested. Most will significantly change the appearance and function of this popular river. One approach is simple – keep the river as it is, and continue to reduce the amount of PCBs entering the water from the former GE facility. This approach has been underway for more than three decades”
Yes, this is a popular river. It would be even more popular if someone hadn’t dumped PCBs in it. And yes, GE managed to do so much damage to the river, that any approach to fixing it will have some painful consequences. One can only wish that GE didn’t favor dumping toxics into the river when that was to their advantage, and fretting about harm to wildlife when that was to their advantage.
What about the idea that we “keep the river as it is, and continue to reduce the amount of PCBs entering the river from the former GE facility.” Since the courts have already mandated that GE reduce PCBs entering the river from its former site, this suggestion offers nothing. It is the approach by which GE walks away from any further responsibility for the harm they have done. And if GE wants to characterize this lack of responsibility as having been “underway for more than three decades,” I will be right there agreeing with them.
“Upriver in Pittsfield there are PCBs in the soil and groundwater close to where factories once used the chemical.”
Factories? What factories? GE is the sole source of PCBs in the river. All of the PCBs in the river are there because GE dumped PCBs into the river, buried barrels of PCB-laden waste throughout the floodplain, allowed PCBs to drain directly into the river, and gave away PCB-laden fill as clean fill. When they were told to get the PCBs out of the river, GE created a toxic waste dump next to an elementary school.
“To keep them from reaching the water, a complex system of pipes and pumps sucks them out of the ground. This effort will continue for years to come”
As I’ve said before, the pipes and pumps being referred to are upstream of the part of the river in Pittsfield that has already been remediated. They are on the former GE site along East Street in Pittsfield. Let me point out three problems with GE’s statement regarding these pipes and pumps.
First, the pipes and pumps being referred to do not keep the PCBs from “reaching the water.” The pipes and pumps are an attempt at sucking the PCBs out of the groundwater. The PCBs are already in the water.
Second, the pumps are not completely effective. They are allowing some of the PCBs in the nearby groundwater to get through – upstream of the cleanup.
Third, there are at least two other sites that are still sending GE’s PCBs into the river and that are beyond the reach of these pipes and pumps – Silver Lake and Unkamet Brook. Are there other PCB dumps that we don’t know about? I know that every time someone puts a shovel into the ground in Pittsfield, they wonder if they’re going to find PCBs and underground barrels.
In 1998, The Berkshire Eagle ran a story entitled “Pollution’s Paper Trail: GE’s trove of records eluded regulators.” It begins,
“GE has recently released to state and federal environmental agencies tens of thousands of pages of records about PCB disposal practices – including historic records of disposal sites that throughout the 1980s GE’s top local environmental officials asserted did not exist. In 1984, the Environmental Protection Agency decided not to place GE’s transformer plant and a long stretch of the Housatonic River in the fledgling Superfund program based primarily on the misperception that the chemical contamination from GE’s 60-year transformer operation was for the most part confined to the 250-acre East Street plant and the river.”
Keeping regulators from putting the Housatonic River into the Superfund program may have been a sufficient motivation for hiding the whereabouts of other contaminated sites. But here’s another possibility. During court cases in 2003, in which some residents of Pittsfield tried to collect damages for the harm done by GE in dumping PCBs on their property without revealing this fact, GE responded that statutes of limitation had expired.
One year later, the Commonwealth of Massachusetts filed a complaint against GE in court. It reads in part, “Specifically, the Commonwealth alleges a failure to notify the Massachusetts Department of Environmental Protection (“DEP”) of a release of hazardous material to the environment, and the making of inaccurate, incomplete, misleading and untimely submittals to DEP with respect to such release.”
These are the same people making this video and telling us that they are keeping PCBs from reaching the water. Their feeble attempts are inadequate, and we have no assurances that we have been told about all contaminated sites.
“With the flow of PCBs reduced, monitored natural recovery would rely on nature to slowly bury any PCBs remaining in the river.”
Notice that GE is agreeing to reduce, not stop, the flow of PCBs into the section of the river in Pittsfield that is upstream of the already-remediated section. GE should have started with this upstream section to prevent additional PCBs from contaminating downstream sections involved in cleanups. Instead they dragged their corporate feet and put this off for as long as possible. GE should also stop, not reduce, the continued flow of PCBs into the river.
“Habitat would be left intact, and the animals that live here would remain undisturbed. Other plans being considered would have a much greater impact on this ecosystem.”
Now GE begins its presentation of the three remediation approaches it would like us to consider.
“One such approach is SED 3/FP 3. SED 3/ FP 3 calls for the removal of most of the PCBs from the river and riverbanks in the 5 miles of the river south of the confluence of the east and west branches.”
As I’ve said before, BEAT agrees that SED 3/FP 3 is a scary option. GE invented it, named it, and is now presenting it to us. GE needs this option as a way to scare us into accepting its favored options. BEAT believes that GE needs to be sent back to the drawing board, or better yet, removed from the cleanup process. Their only contribution should be to pick up the tab.
“Forty-four acres of forest , wetland, and other natural areas would also be excavated. Woods Pond and about 37 acres of riverbed would be capped with a layer of clean soil.”
Whatever decision is reached in cleaning the river of PCBs, some excavation will be necessary. It’s unfortunate, but this is the result of GE’s decades of disregard for the environment and for the people of Berkshire County. But how much excavation? And what about capping Woods Pond with “a layer of clean soil?”
Clearly, capping won’t work. A thin cap of a couple inches means that one crayfish burrowing into the bottom sediment, or one muskrat rubbing his belly along the bottom will defeat the cap. A thick cap or a cap with stone placed over it will drastically change the substrate for burrowing animals. Also, any cap just postpones the problem. PCBs will still be there, and at some point in the future, when GE’s legal responsibility is past, we will have to deal with it on our own and using our own budgets.
BEAT has been asked if we favor a less aggressive or a more aggressive cleanup than the one suggested by GE. I don’t know how to answer that question. BEAT feels that each microhabitat should be looked at individually, and an appropriate remediation for that microhabitat should be decided upon. In the case of the high riverbanks in which kingfishers and swallows nest, we would favor a less aggressive approach, unless these banks are found to have very high levels of PCBs, which is unlikely. In the case of Woods Pond, we would favor a more aggressive approach. Natural recovery will not take place. Intervention is needed.
By asking us to consider SED 3/FP 3, GE implies that we must choose one remediation approach and apply it. SED 3/ FP 3 does suggest different approaches for different sections, but those sections are quite broad. They are not the microhabitats that GE’s Professor Brooks tells us we must protect.
“To remove the PCBs, the river will become a construction site. Rows of steel sheets will be driven into the ground to build temporary coffer dams so sections of the river can be drained. The riverbed and adjacent areas are then dug up and hauled away. But for each ton taken out, another ton of clean soil must be brought in.”
Again, this can be avoided by making some reasonable decisions about which microhabitats need excavation and which don’t. However, excavation will be needed in some places.
How disruptive is this construction process that GE tells us will destroy the river? Here is a recent photo of the river as it passes Dorothy Amos Park on the West Branch of the Housatonic River in Pittsfield.
This is the area featured in the next part of the video in which GE and its contractor tell us that excavation devastates the river and that the river cannot recover from such construction practices. The photo was taken on January 4, 2011, less than two years after the work in GE’s video.
“Similar work was recently done on the west branch of the river in Pittsfield. Stu Messur was one of the project leaders.”
“Right now we’re standing actually in the bottom of a river that’s been cordoned off with some sheet piling. The river was dewatered and excavation has occurred.”
“This type of construction is slow and difficult.”
“We’re typically talking weeks to do a couple hundred foot stretch. A half a mile of river in the north country like this could take on the order of a year to two years to do.”
Less than two years after the construction showcased by GE as the construction that destroyed the river, the Housatonic River again looks like a normal river and members of the community can use the adjacent park and its basketball courts. It may have been “slow and difficult” for GE, but sometimes that’s the price you have to pay for your mistakes.
“To get at soil containing PCBs, all of the vegetation must first be torn out. All along the river trees that have stood for a century will be cut down and hauled away.”
“These banks obviously did not look like this to begin with. What you had previously here was a nicely vegetated bank along the river. In order to get these soils out, all of that vegetation needs to be removed and destroyed. Any trees that are overhanging the river or that are growing within twenty or thirty feet of the river are going to have to come out. This sort of removal may be required for extensive lengths of the river and actually on both sides.”
“It is estimated that it will take crews at least a decade to complete SED 3/FP 3. Miles of wetlands and forests that surround the river will also be dug out.”
The two photos above are of the same site taken from the same angle. The second photo was taken less than two years after the first. Had the second picture been taken in summer, when leaves were on the trees, it would be even more clear that Stuart Messur’s and GE’s predictions of destruction were unwarranted.
We can only repeat that if we use common sense in remediating the river, GE’s self-invented nightmare scenarios can be avoided. And why is one of the largest corporations in the world using such last-century technology? There are much more advanced technologies than what is shown in the video. There are computer controlled dredging machines that minimize the amount of mud and water escaping from the construction site. There are chemical and biologic remediations that have been shown to work. Housatonic River Initiative (HRI) and Dr. David Carpenter of SUNY Albany have for years been asking GE to investigate alternative technologies. Where is GE’s Ecomagination?
“All of this floodplain soil would be excavated, this groundwater wetland depression in the background would be excavated, and all the trees would be cut. So the vegetation would be completely removed, and we’d just have bare ground. What would happen to the habitats for the animals and plants here? They would be gone.”
The only areas that should have to be remediated to the extent described by Professor Brooks are those areas that have high levels of PCBs. If that area has high levels of PCBs, then it should be dug out and replaced. And as to Professor Brook’s question as to what will happen to the habitats, I would like to point out that if the area has high levels of PCBs, Professor Brooks should be worried about those animals. Keep in mind that the majority of carcinogens are also mutagens (mutation-causing agents). Scientists suspect that that’s how they cause cancer. This means that even for those animals that are able to reproduce, what is the future? What type of genetic load are their offspring carrying?
Also keep in mind that the clever photoshopping done to show how the remediated area would be devoid of trees is misleading to put it nicely. Remediation includes replanting trees. Other remediation efforts tell us that the trees that would be planted there could be of the order of ten feet tall. Remediation for any given microhabitat should be appropriate for that microhabitat. This would mean replanting with native species in a manner that would support wildlife. All of this means that the area after remediation would have more trees than Professor Brooks’ “before” pictures.
“To deal with the PCBs, 30 staging areas will be built requiring the removal of 48 acres of forest. To access them, dozens of new roads will crisscross these once quiet forests and wetlands. If this approach was taken on the river south of the confluence in Pittsfield, the impact would be dramatic.”
Clearly there was no thought given to minimizing the effects of the proposed construction sites. Thirty staging areas of the size represented in the video? This is again clearly designed to scare us. I’m sure if GE puts some thought into it they could figure out how to manage a construction site more efficiently. At least one contractor claims that they could cover the same stretch of river with only two relatively small staging areas.
“SED 3/FP 3 would also have terrible consequences for the region’s vernal pools. Vernal pools are seasonal ponds that provide essential habitat for a wide range of wildlife. They are critical to the functioning of the upper Housatonic ecosystem.”
GE will now attempt to convince us that vernal pools are “thriving” (a word they love) and that remediation of the river will destroy them.
“This is a vernal pool. At this time of year the water is below the surface and the amphibians have left for the time being, but a month earlier we were here and all these pools had water in them. We expect to see wood frogs here, spotted salamanders, and in this vicinity we have one of our threatened species in the state, the Jefferson salamander.”
So far we’re good. Vernal pools are temporary pools, and a month earlier there was water in the pool. And yes, in our area we would expect to see wood frogs, spotted salamanders, and possibly Jefferson salamanders. Note: Professor Brooks did not say that’s what he saw. He said that’s what one would “expect to see.” So what was actually seen in the “thriving” pool before remediation? We’ll get to that in a little while.
The next section of the video’s narration just astounds me. If you know the facts, it can only make you angry.
“Wildlife is thriving, even though the vernal pools contain PCBs. To remove them the pools would be dug out and the surrounding trees chopped down. The impact on wildlife would be devastating.”
“And what’s important is that all of these species come back to the same ponds to breed. They have a lot of site fidelity. So if the ponds are not here or if they’re removed for a few years there’s no place for them to go and those generations will perish.”
“This pool located near the confluence in Pittsfield was dug up and rebuilt in 2006. To get at the sediments, trees were cut down, and the complex systems governing the flow of water were disturbed. More sunlight brought new predators.”
“Basically we’ve replaced the kinds of amphibians that should be here. This summer we had an undesirable amphibian, green frogs, completely lining the shoreline, and they’re a predator on the larvae, the tadpoles, of the amphibians we like to see, which are the spotted salamander and wood frog. So the nature of the pond is completely changed through the excavation and cutting of the trees along the edges.”
So, as the narrator says, “trees were cut down.” Professor Brooks reinforces this point. “The nature of the pond is completely changed through the excavation and cutting of the the trees along the edges.”
After hearing this, how extensive do you think the cutting was? How many trees would you guess were cut? Would you believe one tree. A 15″ diameter cottonwood tree was removed. (This is from GE’s own documentation of their work at the site.) It was removed so that GE’s equipment could get into the site. After the pool was dug out, 10 cottonwoods were planted as part of the restoration. The restoration also included the planting of 20 other trees. I’ve visited the site. There are more trees now than before the remediation.
What about the change in the pool’s inhabitants after remediation? Professor Brooks says that the loss of the “trees” caused a change in the kinds of amphibians in the pool.
Here is a table showing the amphibians present before the remediation and those present after the remediation. (click to enlarge)
Note that wood frogs, spotted salamanders, and even the less common and more sensitive fairy shrimp are present after the remediation.
Here’s another EPA table (click to enlarge) that shows that green frogs were present in 26 of 45 vernal pools looked at before remediation. The vernal pool discussed by Professor Brooks in the video is one of the 26.
Professor Brooks’ is wrong when he tells us that predatory green frogs arrived (they were already there) because of the tree cutting (only one tree was cut) and changed the nature of the pond (the species he discussed were present before and after remediation).
Professor Brooks also brings up the issue of site fidelity. Since the amphibian populations are present in the pool after remediation (GE’s data), we can expect those amphibian populations to return in coming years. He also wonders what will happen “…if the ponds are not here or if they’re removed for a few years.” Not here? Removed for a few years? The post-remediation data show no gaps. Not even one year in which there are no amphibians.
What about the contention that the vernal pool was thriving before remediation. An EPA study looked at 27 vernal pools along the Housatonic River. They found that malformations in wood frogs were correlated to PCB levels in the pools. Population densities of wood frogs were also correlated to PCB levels. Higher PCB levels meant fewer frogs in the pool.
I feel we can safely say that remediation of these pools is necessary and that we can remediate these pools effectively.
I believe that remediation of the vernal pool would have been even less disruptive to the vernal pool habitat if GE had used equipment of appropriate scale. A small excavator such as a Bobcat© or even workers with shovels would often be much more appropriate than the larger equipment typically used by GE for remediation in wooded or brushy areas. Maybe even that one cottonwood tree could have been spared. The cost to GE would be greater due to an increase in the amount of worker hours needed to complete the project, but GE could perhaps console itself by remembering that they saved a great deal of money by not disposing of the PCBs properly in the first place.
The video continues:
“Some people say it’s easy to remediate a vernal pool, and that’s just not the case. These are much more complicated systems than people realize. Even though this is probably one of the best efforts to try to remediate a vernal pool, this shouldn’t be considered a success.”
The vernal pool has more trees than previously, it has the same species of amphibians in it, and the PCB-laden soil has been replaced (Oh, they didn’t mention that part in the video). This can only be considered a failure if you’re GE and hoping nobody will ask you to remediate the rest of the vernal pools along the river.
I’m not saying that this vernal pool is a pool without problems. It wasn’t a very functional vernal pool before the remediation, partly due to the presence of PCBs. We’re going to find these same problems in other vernal pools along the river since they too have elevated levels of PCBs. But the point is, remediation removed the PCB-laden soil and then put this vernal pool back the way it was. The pool now has a chance to recover and become a better functioning pool.
One last point on the issue of vernal pools. In the video, GE takes a photo of a vernal pool, and by using photoshopping techniques, they present their vision of devastation that would be caused by remediation. This technique isn’t necessary when a real post-remediation site is nearby and available for photographing. However, the real site would show that remediation works. There is no destruction. In a photoshopped image, you can remove all nearby trees and thereby scare people. In reality, those trees were just one solitary tree. Frankly, I think GE’s use of this technique throughout the video is disgustingly dishonest.
“Large mammals depend on the interconnected corridor of wetlands and forest that flanks the river.”
“These species will move miles and miles on a daily basis, so you have to have connectivity up and down the corridor and from the floodplains to the uplands to make sure those species have adequate habitats in which to survive.”
Well there’s a scary thought. Not only do we have to worry about harm to our own local wildlife, but we also have to worry about the harm being spread to other areas as animals move through our PCB-laden river corridor. Let’s clean up the PCBs. It’s the responsible thing to do.
“Carving the Housatonic River Corridor into dozens of staging areas and access roads wold imperil these species. After about ten years, the trucks will take their last load. But the river won’t be the same. The shady, wild Housatonic of today will disappear into history.
In the best case, it would take at least half a century for these forests to be what they are today. The animals that rely on these forests won’t be able to wait. Generations will grow up alongside the river that bears little resemblance to what it once was.”
At this point, I think we can all agree that GE has lost its credibility. Now they’re just making stuff up. Yes, carving the river corridor into dozens of staging areas and access roads would be harmful to species. Again, nobody other than GE is suggesting we do this. Why thirty staging areas? Another contractor (Genesis Solutions) has said they could cover the same stretch of river with just two relatively small staging areas. Of course, they have no motivation to try to scare us.
“Other approaches being considered by the federal government involving even more digging over longer periods of time would have an even more devastating impact on the region.”
OK. This is just wrong. By the federal government, GE means EPA. Yes, it is true that EPA is considering some very drastic and potentially very harmful approaches to cleaning the river. Why? Because GE submitted them to EPA, so EPA is bound to consider them before commenting. All of this is intended to scare us into putting pressure on EPA to choose the approach that would cost GE the least amount of money, even though it’s not what’s best for the river. GE has no intention of making an honest effort in cleaning the river.
“Fortunately, there is another way. It is called the ESA – the ecologically sensitive approach. A way to clean the river without losing it. Unlike SED 3/FP 3, which calls for the excavation of five miles of river and even more floodplain, this approach would be far less destructive, but as protective of humans and considerate of the wildlife already living in the area.”
Yes, SED 3/FP 3 is more destructive than ESA. Neither plan is acceptable.
“All work done on the river and floodplain would be guided by the following criteria. Sediments and soil would be removed to meet EPA’s human health standards. “
I should hope so. But determining whether a given approach will meet human health standards is not as easy as one might think. Just because GE says this approach will meet human health standards does not mean that it will. From his home in New York, Jeff Immelt’s health will be fine. From his home in Pennsylvania, Professor Brooks’ health will be fine. Those of us who actually live here need to be more skeptical.
“Stretches of the river containing large numbers of species of concern would be avoided. Whenever possible, critical habitats like vertical riverbanks would be maintained whenever feasible. The number of access roads and staging areas built on floodplains would be limited. The natural hydrologic processes responsible for the diversity of habitats in the river and surrounding area would be preserved. Finally, the impact of all removal-related activities would be minimized.“
“As an ecologist, my preference would be to leave the river alone. However, with the ESA, we would be protecting much of the forest and riparian bank that together make up the very critical floodplain for this upper part of the Housatonic. That’s a much better approach to protect the biodiversity and the habitats and the hydrologic functions of this floodplain.”
“Miles of critical habitat and breeding grounds would be saved. Wildlife would be allowed to continue to thrive here. Acres of mature forests, vernal pools, and wetlands targeted for removal by other approaches will be spared. Instead of thirty staging areas and 25 miles of new and expanded roads, the ESA would require just ten mile of access roads, and approximately one third the number of staging areas. Fewer excavated areas, roads, and staging areas mean fewer interruptions for animals that hunt and live along this corridor. And the work would take just seven years.”
Of course “stretches of the river containing large numbers of species of concern would be avoided.” This approach avoids cleaning most everything. Let’s remember what our task is. PCBs are in the sediment and they need to be reduced to acceptable levels. Why? Because they are harmful to people and to wildlife. To decide that an approach is good because it avoids the habitats of endangered and threatened species misses the point that the bigger threat to those species comes from PCBs. All of the advantages mentioned here come from the fact that little to nothing is being done. It’s true that we need to use good judgment in remediating sensitive habitats, but we can’t start with the assumption that an approach is good just because it completely avoids dealing with sensitive habitats, although it is easy to see how after GE’s scare tactics this would seem like a sensible assumption. There are ways, besides GE’s sledge hammer approach, to deal with sensitive habitats. GE has no interest in exploring them.
“The ESA would remove more contaminated sediment than the more destructive SED 3/FP 3. Much of the sediment would be removed from Woods Pond where it has accumulated behind the dam. Because barges would be used in the pond, that removal wouldn’t require damaging access roads and staging areas. The result would be an increase in the depth of the pond and an improvement of the ecological and recreational value of this popular resource. The ESA will allow nature lovers to safely visit the river as often as they like for the rest of their lives. The river will remain one of the jewels of the Berkshires. A thriving home to wildlife and a favorite destination for birdwatchers, hikers, and outdoor enthusiasts.”
What do we have here? A bargaining chip? You mean only if we accept SED 10/FP 9 (I’m sorry. I meant the ecologically sensitive approach.) can we dredge Woods Pond? If this is a good approach to cleaning Woods Pond, we should do it no matter what approach we use on the rest of the river. There are no package deals except in GE’s mind.
“As with all approaches being considered by the EPA, fish consumption advisories will remain in place.”
Again, GE has submitted its report to EPA. If there are problems with the approaches that EPA is considering right now, GE should revise their suggestions.
“The choice is clear. The river can lose much of its wilderness, and the animals and plants that thrive there. Or we can preserve much of that wilderness and wildlife and still protect human health.“
This sums up the problem so clearly. There is no choice that we are being asked to make. There are suggestions made by GE to EPA. EPA doesn’t have to select from GE’s list. We don’t either. The whole concept behind GE’s video is to make us believe that there are three choices and that we had better choose ESA or we may be forced to accept SED 3/FP 3. GE made up this game. Let’s not play it.
“One approach [Monitored Natural Recovery] would require no disruption to the river while PCBs are prevented from migrating into it. Another [SED 3/FP 3]would remove most of the PCBs from five miles of the river and its banks and 44 acres of floodplain. This approach would take ten years and drastically diminish the ecological value and appearance of this river. A third, [Ecologically Sensitive Approach] the ESA, would meet EPA’s human health standards but leave most of the river wild and available for use by humans and animals alike. It would also dramatically enhance the ecological and recreational value of Woods Pond.”
This is GE’s summary of its argument based on faulty assumptions, propaganda techniques, and misrepresentations. If you’ve followed me up to this point, you know I don’t need to comment on this summary.
Three approaches, three futures for the Housatonic River. The decisions made now will determine how future generations will experience this natural treasure for decades to come.
Although it is not true that there are three approaches, the decisions that are about to be made are very important. I don’t have all the answers. Nobody does. But together we have a better chance of making the right decisions. Of course, that assumes we’re all playing honestly. Thanks for listening.