Copy of The Business Council's June 14, 2000 letter
Staff Contact: Ken Pokalsky
to EPA administrator Carol Browner urging the EPA to reaffirm
its 1984 decision not to dredge the Hudson River to remove PCBs
June 14, 2000
Ms. Carol Browner
Environmental Protection Agency
1200 Pennsylvania Avenue N.W.
Washington, DC 20460
Dear Ms. Browner:
RE: The Business Council opposes dredging to remove PCBs in the Upper Hudson River
For several years, The Business Council has been carefully monitoring your agency's reassessment of its 1984 decision against dredging to remove PCBs in the Upper Hudson River. Our conclusion is that the decision should be reaffirmed. We believe dredging should neither be proposed, nor requiredfor three key reasons:
- A dredging
project would severely disrupt the recreational and economic assets not
only of the river itself, but also of a large area of upstate New York
surrounding the river.
- This massive
disruption would be a grossly, even irrationally disproportionate assault
on a "threat" that seems to us to have been mischaracterized
and exaggeratedone that is already being addressed with effective,
much less risky strategies.
- And it still
seems likely, as EPA concluded in 1984, that bank-to-bank dredging could
cause devastating damage to the ecology of the Upper Hudson River.
As the representative of the statewide business community and as the key advocate for economic growth in New York State, The Business Council is of course concerned, first and foremost, about the impact of dredging on the recreational and environmental qualities that are so important to the economy around the upper river.
We cannot know precisely what a dredging operation would entail, because there have been no successful prior models for a project on this scale.
But it seems clear that a dredging operation big enough to remove the PCBs under the riverbed would take 10 years or more. For all that time, the scenic beauty, water quality and recreational use of a 40-mile stretch along the upper river would be severely disrupted. Wildlife populations would be threatened. What is now a clear, quiet river would be polluted by silt.
And that's just the effect in the river. Along shore, major facilities would have to be constructed to pipe and receive the dredged materialsome 1.3 million cubic yards, by the best available estimate. Installations would have to be established to dewater the material, decontaminate it, and load it onto trucks for shipment elsewhere.
Tens of thousands of truckloads would be dispatched through the adjacent rural communities to take the dredged materialwhere? Some community somewhere would have to agree to host a secure, confined hazardous waste disposal facility of epic size, to hold (or incinerate) all this dredged material. Yet even far smaller such facilities are almost impossible to develop and get approved.
Arguably, such disruption might have to be tolerated, if it were necessary to remove an even greater threat to the environment and to human health. But it seems to us that such is not even remotely the case in this matter. EPA itself has acknowledged that the river is safe to swim in, to boat in, to drink.
As the American Council on Science and Health has reported, "there is no scientific evidence that trace levels of environmental PCBs are a health threat to the public." That is what we face in Hudson River water todaytrace levels.
Even larger amounts would have to be regarded with something less than hysteria. As Dr. Renate Kimbrough, who was the first to identify a carcinogenic effect in a study of rats fed with large quantities of PCBs, has now reported, "long-term human exposure to PCBs at higher levels than are found in the environment is not related to an increase in deaths from cancer or any other diseases." She based that finding on a study of a control group with far more long-term exposure to PCBs than anybody living in New York today will ever havethe GE workers who handled them at the company's plants.
If this is what the research shows, why take such grave environmental and economic risks, on an uncertain new strategy of dredging? Why abandon a clean-up strategy that is already in place and working?
We would agree that even though the risk is low, the fewer PCBs in Hudson River water, the better. But that's just what we're seeing today: steadily decreasing amounts of PCBs in the river and its ecosystem. Concentrations in sportfish are trending down, at a rate that suggests fish will reach EPA safety levels within 10 to 12 yearsor about the same length of time it would take to complete a dredging project.
Biodegradation, dechlorination and sedimentation are combining to produce these reduced levels of PCBs in the water. Of the three, sedimentationthe depositing of layers of soil on top of the PCB concentrations on the river bottomis by far the most important.
Yet sedimentation would be stopped dead in its tracks (indeed, it would be reversed) by dredging. Dredging would cut through the layers of sediment that are currently covering PCB deposits, and release more PCBs back into the water as the material is removed. How many years would it take for these new releases to be washed downstream, or to be biodegraded, or to be deposited on the bottom and eventually covered again by sedimentation?
Absent dredging, the only real threat of reversing the decline in PCB levels in the river appears to come from PCB deposits that are currently underground and on-shore. Studies indicate that such releases have been the source of the only increases in PCB levels observed since GE's use of PCBs ceased in 1977.
It is those underground, on-shore deposits that General Electric and the New York State Department of Environmental Conservation have been working so hard, and so successfully, to contain over the past decade. To us, it makes much more sense to encourage and facilitate that clean-up process, than to launch a dredging effort that would create more problems that it could possibly solve.
Yet there are voices in our society whose approach to these matters seems to be motivated more by vengefulness, than by sound scienceand these voices are calling upon you to order dredging, regardless of the cost or consequences.
To them, big corporations like GE are evil polluters, who must be punished. And if dredging would be a big and costly punishment for GE, then, you are being told, that is what EPA must dowithout regard to the consequences for the environment, the river, the communities surrounding it, or the economy. Only in such a mindset, it seems to us, is it possible to support a solution that clearly will create more environmental problems than it could ever solve.
We do not believe that EPA will make a decision based on vengefulness. We believe that EPA will make the decision that is driven by sound science, and by the facts at handand reject dredging.
Daniel B. Walsh
June 14, 2000