In response to the public’s concerns that many of the clean-up options being considered for the Rest of River could cause more harm than good, EPA directed GE to conduct a detailed analysis of the impacts of the alternatives on the ecology of the Housatonic River and its floodplain. This analysis, contained in a report entitled the Example Areas Analysis (EAA) Report, includes an evaluation of six areas, specified by EPA, that represent typical examples of areas that would be affected by the clean-up work. The impacts evaluated include destruction of animal and plant habitat (e.g., forests, vernal pools and wetlands), and loss of rare animal and plant species.
The report describes the current ecological condition of each of the example areas, the ecological effects of the clean-up alternatives on each of those example areas, and the likelihood that a restoration effort could successfully repair those negative effects.
GE believes careful consideration of this report is critical to coming up with the right solution for the Housatonic, one that properly balances the benefits of excavating PCBs with the negative impacts those excavation activities will have on the river’s unique ecology and its recreational uses. This issue is particularly important since much of the clean-up activity would occur in an area designated by Massachusetts as an Area of Critical Environmental Concern (ACEC).
The conclusions of this report are stark. All but one of the clean-up alternatives will substantially harm the ecological integrity of the six example areas that together comprise more than 120 acres of the Housatonic River and its floodplain between the confluence and Woods Pond Dam. The one exception, the Ecologically Sensitive Approach (ESA), would have virtually no negative effects in four of the six example areas and the effects in the other two areas would be less than those from any of the other alternatives.
GE believes the best approach is to let nature take its course and avoid negative impacts in all six areas. However, the EAA report makes clear that, of all the alternatives evaluated, the ESA removes the most sediment and soil from the river and floodplain and causes the least amount of harm to the river and the animals and plants that call it home.
Executive Summary of the EAA.
