10 PROJECTING FUTURE CONDITIONS New York State, the National Oceanic and Atmospheric Administration (NOAA), and some private environmental groups have called for more dredging. They make two arguments: first, that more PCBs were discovered in the river than were known in 2002 when the Record of Decision was signed. It’s true that more PCBs were discovered — it’s also true that GE removed more PCBs than originally estimated. Their second assertion is that PCB recovery rates in fish will be slower than predicted by EPA’s model. They cite a February 2016 study from NOAA using a “model emulation.” EPA found substantial flaws in the NOAA model — namely that it could not accurately predict PCB levels in water and fish — and rejected it. GE’s contractors planted hundreds of thousands of aquatic plants in areas that had been dredged, as here near the shoreline in Saratoga County. ACTUAL DATA VS. NOAA MODEL FIGURE 2: PCB levels in water in the Upper Hudson River were over-estimated by NOAA’s “model emulation” compared to actual data. Chart prepared by GE’s science consultant Anchor QEA. Fort Edward 2000 2010 0.0 0.5 1.0 1.5 2.0 2.5 3.0 Tri+ PCB Concentration (mg/kg wet-weight) U