Dear Administrator McCarthy,
I am writing to urge the Environmental Protection Agency (EPA) to reevaluate and reverse the decision to stop polychlorinated biphenyl (PCB) dredging in the Hudson River. Last month, the Commissioner of the New York State Department of Environmental Conservation wrote to EPA Region 2 Administrator Judith Enck, expressing his department's concerns with the amount of PCBs remaining in parts of the Hudson River. I share those concerns that dredging is not complete, and remaining PCBs continue to pose a threat to the Hudson River and those who rely on it.
Without additional dredging, PCB hotspots continue to remain in the Hudson River. The remaining contamination will result in continued injury to natural resources and slow the economic and ecological recovery of the river. Navigational channels will remain contaminated, and highly contaminated areas will remain adjacent to dredged areas meaning recontamination is to be expected.
As we have previously discussed, analyses have indicated that fish in the Lower Hudson River will not achieve the protective goals outlined in the 2002 Record of Decision (ROD) until decades later. This is because data collected after the 2002 ROD demonstrate that pre-remedial sediment concentrations in the Upper River were 2-3 times higher and decay rates were greatly overestimated relative to values generated by models used to support remedy selection. These result in 3-5 times higher estimates of post-remedy PCB sediment concentrations and Lower River fish that will remain unacceptably contaminated for decades longer. Upper river fish will also take much longer to achieve protective goals of the ROD. EPA's 5-year review of the Hudson River dredging should fully consider this new data.
The federal government has a responsibility to ensure that the Hudson River is protected, and that the damage inflicted upon it by previous generations does not prevent future generations from safely enjoying its many natural resources. I hope that the EPA will listen to the concerns of New York State, as well the other federal trustees, and ensure that the river is fully cleaned-up.
Thank you for your consideration in this urgent matter. Please do not hesitate to reach out my office should you have any questions or concerns.
Sincerely,
Kirsten Gillibrand