Based on our evaluation of the current levels of PCBs in the Upper Hudson River relative to a wide variety of benchmarks, we conclude that PCBs are very likely causing harm to the environment and are sufficiently high to pose risks to human health. PCB levels in the upper river have declined since the discharges from the GE facilities were curtailed, and will continue to decrease over the next century even without active remediation. However, the large quantity of PCBs residing in the sediments of the Upper Hudson River are not permanently sequestered, but rather are currently leaking back into the water, comprising the largest single source of PCBs to the river. Based on our review of field data and models, we believe that both EPA and GE have likely underestimated both the potential magnitude of PCB release from these sediments under typical conditions and the probability of large releases during extreme weather conditions. For these reasons, we believe active remediation such as the planned dredging is beneficial, as it takes advantage of the present opportunity to permanently remove this large quantity of PCBs from the environment. We recognize that cleaning up the PCBs that had been discharged into the Hudson over the past 50+ years will be expensive and will take manyyears. The technology exists to dredge, treat, and dispose of the contaminated sediments. Successful dredging, which will require careful planning and diligent execution, will accelerate the recovery of the Upper Hudson River and substantially reduce the risks to the Lower Hudson. The issue of PCBs in the Hudson River has been studied and debated for a generation. We conclude that the risks are real, the problem will not solve itself, and that the proposed remediation (withmon-itoring) is feasible, appropriate, and prudent.

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