Sunday, January 27, 2019

Deficiencies in Synagro Land Development Plan to be reviewed at Tuesday Planning Commission meeting in Plainfield Township

--- RESCHEDULED TO FEBRUARY 21, 2019 ----

Reports from the various consultants working to assist Plainfield Township planners in assessing compliance with the Zoning Ordinance and SALDO (subdivision and land development ordinance) are on the agenda to be reviewed on Tuesday, January 29, at 7pm at the Plainfield Township Fire Company on Sullivan Trail in Wind Gap.


These are attached below, and include:
  • Material Matters remaining deficiencies in Nuisance Mitigation Plan dated Dec 17
  • Benchmark Civil Engineering traffic review dated Dec 21
  • Plainfield Township Zoning Office review dated Dec 21
  • Material Matters general comments on application dated Dec 28
  • BCM Engineers comments dated Jan 17
  • Hanover Engineering general zoning comments (Robert Lynn) dated Jan 17
  • Hanover Engineering wetlands specialist comments (Jason Smith) dated Jan 18
The challenge for Plainfield's planners is to figure out what to do with this hefty pile of crap.  Synagro has refused to accept that the township Zoning Office has determined that variances are required*.   Any other Applicant would either walk away (Synagro can't possibly show the hardship needed for the variances), or file an Application for an Interpretation and in the alternative a Variance with the Zoning Hearing Board.  Synagro has done neither.  The Zoning Hearing Board is the venue to determine if the Zoning Officer erred in determining that a variance is required, so it is unclear what Synagro's strategy is.  Sooner or later, they will have to appear before the ZHB.  

*In its December 21, 2018 review, the Zoning Office identified a third variance that may be required - see the very bottom of this post for an explanation.

Why did Synagro and Waste Management spend hundreds of thousands of dollars on an application in which the Zoning Officer has determined that Synagro can't even access the proposed site?  The answer is this plant will be highly lucrative and it is impossible to find locations that permit such a shit factory.  This opportunity is too damned good to pass on, and a three or four hundred grand is nothing in comparison to the income this would generate for both Synagro and Waste Management.

On Tuesday evening, the charade will continue, as planners begin the process of plowing through the reports listed above.

Endgame

How does this end?  Currently, Synagro has allowed through February 28th for planners to finish their review and make a recommendation.  This will not be sufficient.  The reviews pending discussion have found significant deficiencies remain, and when the planners are ready to discuss a recommendation it will likely require more than one meeting to agree on its terms.  Planners have two choices when the make their recommendation on the Preliminary Land Development Plan:
  • Recommend approval of the Plan, with a lengthy list of conditions that all reamining deficiencies be addressed and additional conditions be met (for example)
  • Recommend the BOS deny the plan, with justifications
It will likely require at least three more meetings including the Tuesday meeting for this shitshow to reach a conclusion.
Update: The deadline for a decision from the planning commission has been extended by Synagro to March 31.

Reviews on tap to be discussed Tuesday











Third variance identified in Zoning Office review letter dated Dec 21

In the Synagro application for a General Permit for its facility (click to see document), Form L contains a Contingency Plan in case of emergencies.   There are several references in Form L, including Form L Figure 2 Facility Plan (pdf page 99 in the document linked to), to sulfuric acid and sodium hydroxide being stored in above ground storage tanks (ASTs) "adjacent to" the dryer building - outside.  Plainfield's ordinance permits above ground storage tanks of up to 600 gallons of regulated liquids.  Note that Synagro's site plan being reviewed by township planners does not show these tanks outside the building, and in other places the tanks are shown inside the drier building.

Graphic in Synagro's DEP General Permit application - Form L Figure 2

At a minimum, Synagro would need to inform DEP that its Contingency Plan isn't accurate if the AST's are inside.  A portion of the text of Form L is shown below:

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