By Rick Sullivan, Mary Griffin and Ken Kimmell in The Berkshire Eagle, Monday February 7, 2011

Holding General Electric accountable for 40 years of pollution by requiring the company to clean up the Housatonic River is a critical matter of generational responsibility. Governor Patrick and his environmental agencies are committed to doing everything in their power to see this natural resource restored and protected for future generations of Berkshire residents and visitors.

From the 1930s to the 1970s, GE released from its manufacturing facility in Pittsfield hundreds of thousands of gallons of transformer oil laden with polychlorinated biphenyls ( PCBs), contaminating the facility and adjacent properties. These probable carcinogens also flowed down the Housatonic, depositing PCBs in the river banks and floodplain.

The contamination in Pittsfield and the first two miles of the river downstream has been largely remedied. The question now is how to clean up the rest of the river, in particular the stretch where most of the PCBs can be found - from the confluence of the east and west branches of the river in Pittsfield to Woods Pond in Lenox.

Unlike the first two miles of river, which flow through a developed portion of Pittsfield, this stretch includes some of the most biologically rich ecosystems in the commonwealth. In recognition of this ecological value, the Upper Housatonic Watershed was recently designated as an Area of Critical Environmental Concern. The natural value of the Housatonic significantly complicates the clean-up. Removing all the PCBs from the river bottom, banks and adjacent floodplain would require massive tree- cutting, dredging, soil removal, construction of new roads and staging areas, and elimination of habitat for plant and animal species found nowhere else in the commonwealth. We must make GE remedy the damage it has caused, but we must not destroy the river in order to save it.

The commonwealth, through its environmental agencies - the Executive Office of Energy and Environmental Affairs, the Department of Environmental Protection, the Department of Fish and Game with its Division of Fish and Wildlife - has carefully reviewed the thousands of pages of information provided by GE in its Corrective Measures Study. Our agency heads have canoed this stretch of the river and attended public meetings in the Berkshires, and we have reviewed the written comments that public agencies, environmental groups, and citizens have filed. We have come to the conclusion that none of the alternatives laid out by GE achieves the remediation goals without causing irreparable harm to this unique, diverse and vital ecosystem.

Therefore, the commonwealth has proposed to the U. S. Environmental Protection Agency, the agency charged with deciding the remedy, a phased, long-term remedy that minimizes human health risks posed by PCBs in the environment while taking care not to do damage to the ecosystem for small benefit. This approach would require GE to remove PCBs where needed to protect human health or where other compelling goals can be achieved without causing ecological harm, but not perform intrusive work where the unavoidable damage to this unique ecological resource would exceed the benefit of lower PCB concentrations.

The key components of the commonwealth's proposed remedy are as follows:

  • Excavate Woods Pond to remove approximately 300,000 cubic yards of contaminated sediment. This would reduce the average concentration of PCBs to a level that is highly protective of human health and eliminate up to 25 percent of the mass of PCBs in the entire rest of the river from Lenox to the Long Island Sound. Deepening the pond by two to five feet would also enhance recreational uses of the pond - all without causing significant environmental damage. No rare species habitats would be impacted, and a staging area for this work is located nearby, along with a rail line to transport the excavated material off-site.
  • Perform no excavation or stabilization work on the river or its banks at this time. Such work is not necessary to meet the human health standards established by EPA, and armoring the banks, as was done in the first two miles of the river, would alter one of the defining characteristics of this meandering river - its propensity to form new channels over time, creating new wetland habitats.
  • Carefully manage areas of the floodplain where there is possibility of human health risk due to PCB concentrations. These total 57 acres in all, a significant portion of which contain rare species habitats. It is not necessary to excavate within these sensitive areas, although more controls to reduce public exposure such as signs and advisories are warranted.
  • Transport all excavated material off- site. Under no circumstances should there be a hazardous waste landfill constructed in Berkshire County for the clean-up. For this community, which has been severely harmed by PCB contamination, to be burdened with a new hazardous waste dump would add insult to injury.
  • Don't let GE walk away. The company should perform ongoing monitoring to gauge the success of remediation efforts, and be required to remove more PCBs when new techniques are developed to do so with less environmental impact.

In this plan, the commonwealth offers a concrete, practical and viable solution to the rest of the river clean-up that holds GE accountable for its past actions. It protects human health from the scourge of PCBs without doing serious damage to the environment, and without subjecting this unique and beautiful ecosystem to tree clearing, road building, excavation and dredging. We urge the citizens of the Berkshires to review our proposal, and engage in a public discussion of what is best for this precious natural resource.

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Rick Sullivan is secretary of Energy and Environmental Affairs, Mary Griffin is commissioner of the Department of Fish and Game, and Ken Kimmell is commissioner of the Department of Environmental Protection.