340 



THE CONFEDERATION OF ASSOCIATIONS 



OF 



ATLANTIC CIIAHTEHBOATS & CAPTAINS 



230 PARK AVENUE 



SUITE 1221 



NEW YORK, N.Y. 10169 



MARCH 23,1993 TEL . (212)867-3730 



FAX: (212)7511384 



COLONEL THOMAS A YORK, 



DISTRICT ENGINEER 



U.S. ARMY CORPS OF ENGINEERS 



JACOB JAVITS BUILDING 



NEW YORK, NY. 10278-0090 



RE: DEPT. OF THE ARMY PERMIT « 91-1023-OD 

 DEAR COLONEL YORK, 



I READ WITH INTEREST YOUR LETTER OF MARCH 5,1993 TO RICHARD 

 ROE, REGIONAL DIRECTOR, THE NATIONAL MARINE FISHERIES SERVICE 

 (NMFS) . 



I RESPECTFULLY REQUEST THAT YOU CONSIDER THE FOLLOWING POINTS: 



IT IS PRECISELY THE MIGRATORY NATURE OF WHALES , TURTLES AND FISHES 

 THAT CONCERN THE FISHING COMMUNITIES OF THE EASTERN SEABOARD , AND 

 IN FACT THE ENTIRE EASTERN AND WESTERN ATLANTIC COMMUNITY. THERE 

 IS FULLY DOCUMENTED INFORMATION THAT OVER 30 SPECIES OF FISH DO 

 FEED IN THE PROPOSED DUMP AREA, AND THAT MANY OF THE FISHES ARE 

 CLASSIFIED AS HIGHLY MIGRATORY. FOR EXAMPLE: 



SCHOOLS OF MACKEREL, BOTH BOSTON AND SPANISH , SCHOOLS OF WHITING 

 IN THE WINTER, AND PODS OF JELLYFISH ACTIVELY FEED AT THE MUD DUMP 

 SITE THEY DEVOUR WORMS , BAY ANCHOVI ES , SMALL SQUID AND SQUID 

 SPAWN CRABS BOTH GREEN AND BLUE, AND SAND LANCES WHICH PROLIFERATE 

 THE AREA. SHOULD THESE SPECIES EAT AND DEVOUR INFECTED DIOXIN 

 ANIMALS BOTH BENTIIIC AMD FREE SWIMMING THE ENTIRE OCEAN COULD 

 BECOME INFECTED WITH DIOXIN LACED FISHES AND MAMMALS. A WORM OP 

 CRAB CANNOT TELL A PREDATOR WITH A SIGN STATING "DO NOT EAT 

 ME, I'M INFECTED WITH DIOXIN." PLEASE REMEMBER THAT FISHES EATING 

 DAY IS 24 HOURS. 



WE HAVE NOT SEEN ANY REPORT THAT THE 'DREDGED MATERIAL HAS 

 UNDERGONE STRINGENT PHYSICAL , CHEMICAL , AND BIOLOGICAL TESTING, AND 

 HAS BEEN DETERMINED ACCEPTABLE FOR RESTRICTED OCEAN DISPOSAL. 



WE HAVE NOT SEEN THE SPECIFICATIONS THAT WOULD 'RIGOROUSLY 

 CONTROL THE SPECIAL CONDITIONS' OF THE PERMIT. IN FACT, ALL OF THE 

 BRIEFINGS HAVE BEEN NOTORIOUSLY SILENT ABOUT JUST HOW LONG THE 

 NOXIOUS MATERIAL WOULD REMAIN ON THE OCEAN FLOOR UNCAPPED. 



WE DO NOT AGREE, NOR HAS THERE BEEN ANY SCIENTIFIC DATA PROVIDED 

 TO US TO SHOW THAT A CLUMP(THE SIZE OF THE DREDGE BUCKET I 



