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New York has identified Houghtaling Island, one of the largest undisturbed parcels of land in the Hudson River estuary, as a critical habitat. Nevertheless, the Army Corps has used it for decades as a dump for dredged soil containing varying levels of PCBs, heavy metals, and other contaminants.
We will be submitting additional comments in the next month or so, including a set to the Department of Environmental Conservation, which must certify that the dredging conforms to state water quality requirements. We also plan to submit comments to the Department of State, explaining why we think they should disagree with the Army Corps’ coastal consistency certification.