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THE OTHER SIDE: Housatonic hypocrisy

“There is overwhelming documented evidence that the proposed toxic-waste site in Lee (Upland Disposal Facility) has long been known by the key players to be a poor choice for dumping PCB’s or any other ‘forever’ chemical.” — Lee Select Board Chair Bob Jones, September 11, 202

I thought I had left “Whose Housatonic?” behind. But … but … but, my friend Denny Alsop had another idea. Denny is a river advocate extraordinaire; he has canoed from one end of the Commonwealth to the other, urging all of us to take better care of our waterways.

These days, now that the Environmental Protection Agency (EPA) has revised its website and made looking for documents akin to wandering blind through a gigantic cave filled with angry bats, driving me to madness, Denny had somehow stumbled upon a remarkable document.

“Whose Housatonic?” was about a lot of things: GE’s use and misuse of polychlorinated biphenyls (PCBs), the failure of our environmental agencies to force a thorough cleanup of our Housatonic River, and the overriding issue of who should make the critical decisions about our river. In particular, I focused on the efforts of the Berkshire County Regional Planning Commission (BCRPC) and the organization it founded, and gets paid to manage, the Rest of River Municipal Committee. The Rest of River Committee played a central role negotiating a behind-the-scenes, confidential settlement agreement with GE and the EPA. The committee consists of unelected representatives chosen by the select boards of Lenox, Lee, Stockbridge, Great Barrington, and Sheffield, all the towns alongside the last section of the river waiting to be cleaned. The committee went out of its way to oppose the action of the Housatonic River Initiative (HRI) in the U.S. Court of Appeals in The Housatonic River Initiative v. U.S. Environmental Protection Agency, as HRI fought for a more democratic decision-making process, a better cleanup, and against a Lee PCB dump:

“HRI laments the public’s exclusion, but there is no known way to negotiate with the public at large, and mediations almost always occur in a confidential setting as standard operating procedure. Moreover, the public did have a seat at the table: the elected representatives of the affected municipalities, here acting through the Committee, were and are the best voices of the people in our democratic system. And all of the municipal Select Boards voted unanimously in favor of the settlement; none has wavered from that decision.” (Emphasis added.)

We have all paid a price as people mess about with our language, and there are times I just have to laugh as folks try so hard to turn up into down. Trump argued all the photos of his inauguration crowds were inaccurate. GE—Trump-like—argued that cleaning the river would destroy it. The EPA and GE agreed to turn a PCB dump into an “Upland Disposal Facility.” Then EPA described what they always did: ordering GE to send the most toxic PCB waste to an out-of-state licensed facility (the “there”) while permitting them to dump lower-level PCB waste in Hill 78 and Building 71 landfills across from Pittsfield’s Allendale Elementary School (the “here”). Yes, that’s what happened in 2000. But the practice obviously needed re-branding, and so EPA and BCRPC and the Rest of River Committee ran with a new name for an old practice: the new and improved “Hybrid Disposal.”

Nobody described how this works better than the great George Orwell, whose “1984” can easily be confused with our now:

“The Ministry of Peace concerns itself with war, the Ministry of Truth with lies, the Ministry of Love with torture and the Ministry of Plenty with starvation. These contradictions are not accidental, nor do they result from ordinary hypocrisy: they are deliberate exercises in doublethink.”

So, let me take just a moment to deconstruct the Rest of River Municipal Committee’s bold doublethink claim that they actually represented me and you. First off, whoever said democracy was easy? But isn’t it preposterous to say “There is no known way to negotiate with the public at large”? I don’t know—how about holding a series of convenient neighborhood meetings and asking people their hopes and dreams for the river, what they think about a cleanup, and treatment and landfills? What about polling? How about an online vote?

At least, for god’s sake, how about trying to find out what people want instead of assuming you know best? Then, onto this claim: “the public did have a seat at the table: the elected representatives of the affected municipalities, here acting through the Committee.”

I can hear George Orwell laughing. I don’t know about your town, but in mine, Great Barrington, democracy lies bedridden in the intensive care unit. If the Rest of River Committee imagines that the approval of the Great Barrington Selectboard counts for an exercise in true democracy, how about they take a look at the facts. Let’s start with the total number of registered voters in GB:

Massachusetts Secretary of State Registered Voters and Party Enrollment as of February 1, 2023. Highlighting added.

And then how about we contrast this number with the actual number of votes cast in the most recent election for the Selectboard:

Official results of the May 10, 2022 annual Great Barrington town election. Highlighting addd.

So, if you subtract the votes for Ms. Blanks, who might actually have done a decent job, you have 497 votes out 4,897 eligible voters. I am not good with calculators, but it hardly seems these two recent victorious members of the Great Barrington Board of Selectmen represent much more than 10 percent of us. So just maybe it would have helped the democracy case if the Rest of River Committee actually asked the rest of us about the river.

Onto an amazing example of self-serving delusion and supreme arrogance: “the elected representatives of the affected municipalities, here acting through the Committee, were and are the best voices of the people in our democratic system.” (Emphasis added.)

Finally, as anyone who has followed the news know, this is far from the truth: “And all of the municipal Select Boards voted unanimously in favor of the settlement; none has wavered from that decision.” See, for example, The Berkshire Eagle’s reporting of March 29, 2023 and April 20, 2023, and The Berkshire Edge’s reporting of June 22, 2023 and August 16, 2023.

So, there are many reasons to be disappointed with the results of this secret negotiation and the EPA’s final cleanup plan. GE will be leaving massive amounts of PCB-contaminated sediment and bank soils in the river system. One of the great hopes of many might be delayed many, many decades: to fish and safely consume the fish. The dream of swimming will probably be postponed to never. And rather than finally mandate a lasting solution to the contamination, the treatment and destruction that Superfund (CERCLA) held out as a goal, the EPA and the Rest of River Committee accepted a PCB landfill for Lee:

CERCLA §9621. Cleanup standards (a) Selection of remedial action. Highlighting added.

Now I want to be clear, unfortunately the question of the appropriateness of treatment has been unsuccessfully litigated by HRI, and both the EPA’s own court system, the Environmental Appeals Board (EAB), and the U.S. Court of Appeals deferred to the EPA’s judgment that treatment wasn’t appropriate. Project Manager/Team Lead Dean Tagliaferro from the EPA made crystal clear to Leslee Bassman of The Berkshire Edge that landfilling was a done deal: “We are certainly willing to work, and we have worked and offered to meet with anybody on implementing the remedy, but the remedy is selected and that’s the way we’re moving forward,” he told her. “And part of the remedy is the landfill. So, the landfill is part and parcel of the remedy. There’s only one path forward and it’s this path.” (Emphasis added.)

Sadly, the EPA’s prior statement about treatment over-emphasizes what they imagine as problems without acknowledging the recent developments and positive results of TerraTherm’s successful treatment of dioxin contamination in Vietnam:

“EPA’s decision not to require treatment was upheld by the EAB after being specifically appealed. Numerous challenges remain regarding the use of innovative treatment technologies. At present there is no proven and viable in-situ method that would avoid excavation of soil and sediment on the scale of the Housatonic River cleanup. Ex-situ methods like chemical extraction, thermal desorption, or even incineration, can often present operational challenges and leave treatment residuals that would still require land disposal after treatment. Thus, it is likely that, if an innovative treatment approach were selected here, it would still be necessary to dispose of treated soil/sediment in a landfill.”

Over many years, HRI has unsuccessfully advocated for the implementation of alternative treatment technologies, including Thermal Desorption, which, contrary to the EPA’s assertions, produces a volatilized highly concentrated liquid that’s isolated, and sterile soil that can be used as landfill cover or revitalized and reintroduced into the river. (See here and here for more details.) Unfortunately, while this difference of opinion could easily be resolved by performing rigorous and transparent pilot tests of Thermal Desorption, much like USAID did in Vietnam, the EPA has repeatedly failed to allow these tests.

So here we are: The UDF will be built on the 75 acres previously operated as an active sand and gravel quarry by The Lane Construction Corporation. The UDF will have a capacity of 1.3 million cubic yards of PCB-contaminated sediments and soils. The UDF will have a consolidation area with a maximum footprint of 20 acres and a maximum elevation of 1,099 feet above mean sea level.

In “Whose Housatonic?,” I focused on the major issue of who has influenced and made the critical decisions about the kind of cleanup we will have for the Housatonic River, and why they decided to let GE build a massive PCB dump in Lee. But as you’ll see, and as Bob Jones tells us, I was unaware of critical information that makes even more clear the tragic injustice of some of the decisions made during these secret negotiations.

Lucky for me, Judy Herkimer of the Housatonic Environmental Action League—a Connecticut river advocate of many decades, and, like Denny, an avid defender of the dream of a fishable and swimmable Housatonic—has become a master of navigating the EPA documents cave. And she quickly found and forwarded the following fascinating document.

Front page of the May 9, 2018 BCRPC letter to the EPA. Highlighting added.

It is important to remember that, in recent years, Green Berkshires had successfully secured the protection of countless acres of land alongside the Housatonic River as an Area of Critical Environmental Concern (ACEC), and several thousand residents had signed an HRI petition in favor of treatment and against dumping. There were demonstrations against GE’s plans for three “here” local dumps. And the EPA had responded to this mounting public pressure by ensuring that its cleanup plan required GE to send PCB-contaminated sediment and soil “there”—to an out-of-state, licensed toxic-waste site. GE made clear in 2014 that the cost of transporting waste out of town was one of its critical concerns:

The EPA’s reissued RCRA permit from September 2015. Highlighting added.

With so many millions at stake, GE was willing to do whatever it took to make sure the EPA agreed to on-site disposal. They appealed the EPA’s decision to the EAB, which ruled that the EPA had failed to provide a convincing enough rationale for ordering the transportation of contaminated waste to an out-of-state facility.

In my opinion, this expected failure was a prime example of the chickens coming home to roost, a clear consequence of the results of the EPA’s previous precedent-setting bad decisions. First, the EPA’s bizarre opposition to treatment alternatives, putting up with GE’s clear failure over the past decades to honestly test and fairly evaluate remediation alternatives. You can see my analysis of these repeated failures here. Then, while turning its back on treatment, the obvious alternative to landfilling, the EPA foolishly agreed to allow GE to dump significant amounts of contaminated sediments and soils from the cleanup of the first two miles of the river in their unlined Hill 78 and newly constructed Building 71 dumpsites across from the playing fields of the Allendale Elementary School. Then, even though every local pediatrician in Pittsfield was legitimately concerned with the obvious dangers to public health, the EPA doubled down by continuing to insist year after year that these landfills were absolutely safe.

Nevertheless, the EAB gave the EPA one more chance to better justify its decision to order out-of-state disposal by remanding, and asking EPA to consider again “the permit condition requiring GE to dispose of the excavated material off-site rather than on-site.” EAB explained further:

“The Region failed to exercise considered judgment in deciding that the contaminated materials excavated during the cleanup should be disposed off-site. The Region rejected on-site disposal based largely on its finding that on- site disposal would not comply with a Toxic Substances Control Act landfill regulation, but the Region failed to explain why a waiver of the landfill regulation was not appropriate for GE’s proposed on-site disposal locations, particularly in light of GE’s contention that the Agency routinely grants such waivers, and the Region failed to reconcile seemingly inconsistent statements in the record. This lack of considered judgment necessitates a remand of the Permit decision to the Region to reconsider selection of the disposal location.” (Emphasis added.)

Here are the TSCA regulations the EAB is referring to:

The Toxic Substances Control Act (TSCA). Highlighting added.

And this explains what must be done to achieve a waiver from these regulations:

TSCA approval of chemical waste landfills, section (c)(4) Waivers. Highlighting added.

Here’s where you need to embrace irony big time, because both the EPA and the Rest of River Committee did their very best to dismiss and disqualify the expert testimony HRI offered from David DeSimone, former Professor of Geology at Williams College, testimony that directly addressed the technical requirements TSCA demands and by extension offered a compelling case for why GE wouldn’t qualify for a waiver:

Former Geology Professor at Williams College David DeSimone’s geological evaluation of the proposed Woods Pond landfill site in Lee. Highlighting added.

Here’s what TSCA requires: “The landfill site shall be located in thick, relatively impermeable formations.” And here is DeSimone’s analysis:

“This location is underlain by highly permeable sediment of sand and gravel texture. Infiltration of PCB leachate through these sediments would not be inhibited by any impermeable sediment prior to reaching marble bedrock. The marble would allow rapid migration of contaminants. Very rapid migration of contaminants along fractures/joints enlarged by dissolution would pose an even greater risk of contamination at further distances from the landfill. The surficial geology consists of high permeability sand and gravel sediments with unpredictable lateral and vertical stratigraphic continuity.” (Emphasis added.)

Ultimately, he concludes, “This is a poor site for a landfill.” (Emphasis added.)

Leslee Bassman offered EPA the opportunity to talk about the Housatonic River remediation and Lee’s upland disposal facility. The EPA’s Dean Tagliaferro explained to Bassman the EPA’s decision not to revise its decision-making regarding off-site disposal before the EAB: “How can we justify to a court that [PCBs aren’t] safer in a similar landfill? We felt both options were safe—a landfill here or a landfill there—both options are safe.” (Emphasis added.)

Bassman goes on to write:

“According to Tagliaferro, the EPA was then faced with two choices: to revise the information, return with the same remedy to the EAB, and possibly lose again; or mediate the remedy with a settlement. The EPA selected the latter, resulting in the 2020 revised permit. The biggest change to the remediation option was a hybrid combination of disposal that wasn’t evaluated in 2010, he said. The 2020 permit allows for the lower-toxic-level waste to be deposited into the UDF, with the materials containing higher concentrations of PCBs being shipped out and includes 12 enhancements omitted from the 2016 permit.” (Emphasis added.)

Calling Mr. Orwell: The biggest change, “hybrid disposal,” is no change at all. This is exactly the high level goes “there” and the low-level stays “here,” the version of hybrid disposal that the EPA and GE had agreed to 23 years ago in 2000:

Summary of the 1.5 Mile Reach Removal Action. Highlighting added.

We will never know for sure, but if the EPA exercised some humility and utilized the testimony of David DeSimone, they would actually have done what EAB suggested: revise the analysis and return with the same remedy to the EAB but with a highly legitimate case that the Lee site wasn’t appropriate in many ways and wouldn’t meet TSCA regulations.

Instead, as Bassman reports, the EPA countered DeSimone’s concerns:

“Tagliaferro responded to comments made by Pittsfield geologist Dr. David DeSimone that the UDF bottom liner would ultimately leak and the system fail, making the Lee site a ‘poor choice’ for the landfill due to its permeable bedrock. Tagliaferro said there is no question that the sand base is ‘permeable,’ but the five layers of liner will keep the toxic materials from reaching the sand. ‘The PCBs will bind to the soil, and the contamination [level of the PCBs in the UDF] is so low that it will not threaten the groundwater,’ he said.” (Emphasis added.)

There are several problems with Tagliaferro’s argument. First off, there is no guarantee that additional liners would compensate for the underlying reality that, from a geological perspective, this is a very poor site for a toxic waste landfill. Second, information about the longevity of landfill liners comes from laboratory tests and mathematical projections. There are no existing PCB landfill sites with liner systems that have lasted long enough to provide accurate and reliable projections. Finally, the EPA itself, in its 1988 efforts to revise its waste disposal regulations, admitted the potential unreliability of liners and the reality that it may take years to even adequately appreciate and deal with leaks:

Federal Register Vol. 33, No. 158, Tuesday, August 30, 1988. Proposed Rules 33345. Highlighting added.

Finally, recent tragic events in Canada, Hawaii, Turkey, and Libya have made clear that nature, emboldened by the climate crisis, will overcome the mechanical ingenuity of humankind, and its fires will reduce towns and its inhabitants to cinder. Its floods will sweep away several-story buildings. Its earthquakes will shatter cities. So it is definitely past time to feel satisfied and/or rely on even five layers of high-density polyethylene (HDPE)—with barely a 30-year history of lining landfills.

In contrast, if the EPA had truly listened to HRI and DeSimone—and please push past the irony now—or even the Berkshire County Regional Planning Commission of 2018, they would have been able to make a persuasive case to the EAB for off-site disposal. Why the BCRPC? Because there was a time when the BCRPC was advocating for science and the true interests of the people of South County, even Lee.

Remember the May 9, 2018 document sent by BCRPC Executive Director Nathaniel Karns to EPA Project Coordinator Dean Tagliaferro, entitled “RE: Proposed Hazardous Waste Landfill Sites in Lee and Great Barrington.”

Excerpt from May 9, 2018 letter from the BCRPC to the EPA. Highlighting added.

In this document, the BCRPC argues, persuasively and without any ambivalence whatsoever, against the very major decision they helped to negotiate and set in stone just a few years later. In 2018, BCRPC Executive Director Nathaniel Karns makes the case that there are multiple problems with GE’s plan for a PCB landfill at the Woods Pond/Lane Construction Site.

The BCRPC refers to Lee’s 2000 Master Plan, which “specifically cites the unique impact of the underlying limestone in parts of Lee (including the Woods Pond site).” The letter goes on:

“[The 2000 Master Plan] cites the gravel mines in north Lee for their potential for redevelopment and reuse … to redevelop industrial and commercial areas as they become vacant, underutilized or inappropriate, particularly gravel mining and heavy industrial sites. Depending on site conditions, planned redevelopment might encompass office/light industrial or specialized housing and recreation, if not conservation uses.” (Emphasis added.)

The BCRPC invokes the 2016 Open Space Plan Lee adopted, specifically highlighting the bedrock and surficial geology of the site, the potential for groundwater contamination, and the existence of one of two town aquifers which lies beneath the site:

Excerpt from May 9, 2018 letter from the BCRPC to the EPA. Highlighting added.

The BCRPC emphasizes Lee’s Zoning Bylaws:

“The Woods Pond site is primarily zoned Conservation-Residential (CR) with only a small western portion zoned ‘Industrial’ (I) since at least 1974. The CR zone allows dwellings, farm, forestry or nursery, resorts, accessory uses to those, and municipal uses by-right. Some other uses are allowed by Special Permit granted by the Zoning Board of Appeals but these are closely related out-door recreation and farming uses. The I zone allows a variety of manufacturing and business uses by-right. Landfills of any sort are not listed as being permitted by-right or by special permit in either zoning district. Lee’s Zoning Bylaws do not ‘expressly permit variance for use’; therefore under Massachusetts General Laws, Chapter 40A, the Zoning Enabling Act, Section 10: Variances, use variances are not permitted (see Attachment D). The Town Land Use Clerk has confirmed that the Lee Zoning Board has never considered nor granted any use variances.” (Emphasis added.)

The BCRPC raises the issue of water quality and the Lee aquifer:

“Traces of PCBs were reported (Mass. DEQE, 1975) in water quality samples taken from the aquifer, suggesting that contamination may have seeped into the recharge area through induced infiltration from Woods Pond and the Housatonic River. This information led to a decision by the DEQE to discourage development of a public drinking water supply at the Woods Pond location despite significant quantities of groundwater. However, according to recent information from the Tri-Town Health Department, this aquifer is not contaminated. (p. 47)” (Emphasis added.)

One can imagine a future where a substantially remediated Woods Ponds and retesting by the state might offer the chance for the communities of Lee and Lenox to use this water—a prospect that disappears if/when a massive PCB landfill prone to possible leaks is constructed above it.

The BCRPC adds this:

“In the late 1960s the USGS conducted a series of bedrock and hydrologic studies to identify areas where future exploration of groundwater aquifers would most likely provide high-yield, high-quality groundwater supplies. These included extensive studies of the Housatonic River Basin. The MassGIS Aquifer Mapping datalayer is based on these USGS hydrologic atlas series. These studies identified a 600-acre, medium yield aquifer south of Woods Pond, located in saturated sand and gravel in deposits of stratified glacial drift. The soils are porous and permeable. A medium yield-aquifer is one that yields 100-300 gallons per minute and has a transmissivity yield of 1400-4000 square feet per day.” (Emphasis added.)

Town of Lee: Open Space and Recreation Plan Map Attachment E. Aquifers are depicted in bright green. Image courtesy of the BCRPC.

Again, reinforcing DeSimone, but this time from the BCRPC: “The soils are porous and permeable.”

The BCRPC emphasizes the potential value of usable water:

“The location of this aquifer is shown on the Water Resources Map (Lee Open Space and Recreation Plan (2015) (Attachment E). The previous Lee Open Space and Recreation Plan, published in 2000, cites that the Lee mill located south of Woods Pond withdrew two million gallons of water per day from this aquifer for its processes, verifying its potential use for industry (the mill subsequently closed and was included in an EPA Area-wide Plan). The towns of Lee and Lenox have been denied the use of this productive aquifer as a public drinking water source due to the high concentrations of PCBs in Woods Pond, and the concern for PCB contamination from infiltration of surface water into the aquifer. This is a significant loss for the Town of Lenox, which struggles to meet high demand for drinking water during the busy summer tourist season, resulting in the Town seasonally having to purchase water from the City of Pittsfield.” (Emphasis added.)

Now onto the BCRPC’s discussion of the critical issues of Bedrock and Surficial Geology:

Excerpt from May 9, 2018 letter from the BCRPC to the EPA. Highlighting added.

The BCRPC continues:

“The general soils map unit of Woods Pond site is Copake-Hero-Hoosic soils, which are very deep, somewhat excessively drained and moderately well drained, nearly level to moderately steep, loamy soils formed in glacial outwash, found on outwash plans and terraces (Scanu, 1988, General Soils Map inset page) (Attachment L). These soils have rapid permeability, particularly in the substratum, which would allow rapid infiltration of PCB-contaminated leachate that may leak through landfill linings or other failures at the site into groundwater and into the Housatonic River. It is well documented that hazardous materials leachate can permanently contaminate groundwater sources, particularly when the chemical make-up of the hazardous material is resistant to detoxification processes, such as is the case here with GE’s PCBs of the aroclor group. According to the USGS map, the soil here is greater than 50 feet in depth, but due to extensive gravel mining of this area, the depth to the water table and to bedrock have been compromised. This is evident in the many ponds that dot the gravel pit.” (Emphasis added.)

In the end, the BCRPC makes the following conclusion:

Excerpt from May 9, 2018 letter from the BCRPC to the EPA regarding GE’s proposed hazardous waste landfill sites. Highlighting added.

So, if only. If only the BCRPC had reinforced the technical arguments of David DeSimone. If only the BCRPC had urged the EPA to engage in a rigorous re-examination of the very valid reasons for opting for off-site disposal. If only the BCRPC and the Rest of River Committee had stuck to the analysis that prompted their individual towns to expressly advocate against siting a local PCB landfill.

How about a last look at some local hypocrisy? Included in the BCRPC submission is a letter from former Great Barrington Town Manager Jennifer Tabakin, entitled “Re: Impacts of a Proposed Hazardous Waste Landfill at Rising Pond.”

May 9, 2018 letter from then-Great Barrington Town Manager Jennifer Tabakin to the EPA. Highlighting added.

And what is it Great Barrington wants the EPA to know? That a hazardous waste landfill is not in keeping with the town’s land-use vision. A spill from a landfill would have dramatic, severe, and permanent damage to a major drinking water aquifer. And the mere presence of a hazardous waste landfill at the site would deepen the environmental justice issues and cumulative burden facing the community in the vicinity.

Does anyone in Great Barrington town government acknowledge that the people of Lee could make the same exact claims? What does it says about our town that just a few years later, they would vote to override these same legitimate concerns and burden the citizens of Lee with the very kind of landfill we argued so vociferously against?

And so, here we are in 2023, as the Rest of River Committee substitutes submission for science:

An amicus brief filed by the Rest of River Municipal Committee. Highlighting added.

Given our new climate reality, who with a straight face would expect us to believe that a plastic liner system will last for hundreds of years? A few short years ago, the BCRPC made a compelling case for off-site landfilling. How quickly and how easily the BCRPC and the Rest of River Committee switched sides.
I certainly don’t know, but in addition to the payoff the towns received, could this have something to do with it:

May 2022 EPA Brownfields Program Grant of $500,000 to the BCRPC. Highlighting added.

I will end with what Lee Select Board Chairman Bob Jones had to say:

“There is overwhelming documented evidence that the proposed toxic waste site in Lee (Upland Disposal Facility) has long been known by the key players to be a poor choice for dumping PCBs or any other ‘forever’ chemical. In 1972, Lenox considered the site as a secondary water source for their town, with already existing wells having the capacity to put out 2.3 million gallons of water per day. BRPC acknowledged the geological makeup of the site to be totally inappropriate for that use. Independent experts, geologists, scientists familiar with the site have confirmed it to be an ecologically sensitive site in no way suited for dumping poisonous chemicals.

“The EPA concurred. Yet, just a few years down the road, all of this has been ignored (conveniently forgotten) by all the aforementioned parties. Lee is now a sacrifice community, a depository for decades’ worth of poisons dumped by the General Electric Corporation. The other towns, as part of the Rest of River agreement won’t even have a conversation with Lee Representatives, choosing to rely on their one source of information on the subject: The Rest of River Committee, none of whose members has a background in any of the associated sciences. Every negotiation, every step leading to this outrage was conducted behind closed doors, without the knowledge, input or consent of the residents in the Housatonic River Corridor. When we hear or read about Democracy being threatened, diminished or ignored, we only need look at our own
backyard for evidence of that reality. Lee, and what is being imposed on its residents is a perfect example of ‘Environmental Injustice.’ Tragically, it was done with barely a whimper from our neighbors.”

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