To the editor:
This is a response to changes to Citizens Coordinating Council (CCC) meetings by the EPA from Citizens for PCB Removal (CPR).
CPR wishes to go on the record opposing the proposed changes to the CCC meetings as outlined in the July 30, 2024, email from Ashlin Brooks.
Reducing the number of meetings to only two times per year (when there were originally monthly meetings) is unacceptable. This is a slap in the face to current and long-term citizen stakeholder groups who comprise the majority of the CCC membership (at least who regularly attend the meetings). It has always been our opportunity to question directly (and publicly) the Potentially Responsible Parties (PRPs) (read General Electric) as well as the staff of government agencies enforcing the Superfund site, the Consent Decree, and residential and watershed issues. We have long complained that the four meetings per year were not sufficient, and yet now the desire is to reduce even that number.
The more intimate and formal settings for the CCC meetings allow for that direct communication where questions and answers and ideas are exchanged without the potentially unruly crowds that can be part of the open public meetings. While CPR acknowledges the need to have more open public community meetings as have been proposed, these should not be used to eliminate CCC meetings.
It is also disingenuous to suggest that CCC members have meetings without the EPA. This would also essentially eliminate other government members (Massachusetts Department of Environmental Protection, Connecticut Department of Energy and Environmental Protection, some city and town representatives, business entities) from also being willing to attend. If you think that stakeholders are not talking outside of CCC meetings, then the EPA Case Team is naïve. It also assumes that the CCC is only for citizen stakeholders. The government and business members are there to hear us and respond to our issues. Their attendance opens the possibility of being influenced by new information which they might not hear otherwise.
CPR is also confused as to why agenda items for discussion will not be accepted prior to a meeting but be introduced during the CCC Open Session. CPR has proposed items in the past so that the EPA and others will be prepared to answer specific questions rather than have the canned response of “we will get back to you on that!”
Once again, there is mention of the Challenge (for alternative technologies) that was listed in the 2018 agreement and was used when the EPA responded to Sen. Elizabeth Warren’s questions as a reason to believe that the EPA was being proactive at the site. Yet there is still no Challenge six years later and seems to be no intention of one actually being created.
The EPA has made it clear that the current remedy is set and that it will not be altered, even though they often use testing samples that were completed over 20 years ago and do not incorporate newer testing standards and technologies. They also ignore newer studies showing the potential harm from airborne PCBs and the more stringent levels that should be used for PCB air sampling. The EPA should look at the current five-year study of the Hudson River remediation project where the data shows that the remedy has not achieved the desired and expected results. Instead, the EPA has said that more study and data collection is needed. This is clearly a delay tactic at that site and unfortunately will lead to similar issues here for the Housatonic River site. It is at regularly scheduled CCC meetings that these and other issues come to the public because those meetings get reported in local newspapers and online media. CPR believes we need more CCC meetings, not less.
The EPA states in this email that these decisions were made including “recent feedback from members.” CPR has always been forthright with its opinions and statements, and I was interviewed by Tobias Berkman when he was chosen by CBI to facilitate the CCC meetings. The EPA and CBI should make public those conversations and discussions by other members that may have influenced these proposals. I give CBI and EPA permission to share my comments. Transparency in this process is imperative.
Reconsider this awful decision and at least have four CCC meetings per year. Yes, this site has been ongoing since prior to the signing of the Consent Decree in 2000 and those long-term EPA employees on the Case Team wish it was over, but you are getting paid for what you do and the citizen stakeholders are not. OUR TIME IS VOLUNTARY! Treat us with respect and reverse these proposals.
CPR demands that EPA shares these comments via email to ALL CCC members.
Charles Cianfarini
Interim executive director of CPR
North Adams
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