Wednesday, February 20, 2019

Synagro proposes to route all its Plainfield Township biosolids plant traffic to Pen Argyl Road in latest attempt to avoid a zoning variance - but not really

Tomorrow evening (see sidebar), Synagro will attempt to claim that they satisfy all township requirements, and that two zoning variances the township has determined are required are not really required (which is not Synagro's authority to determine).  Yesterday we looked at the fact that Synagro no longer has DEP's commitment to approve of a waiver to fill in a freshwater pond in order to obtain space to build a driveway and parking area, and also to meet the township's setback requirements and avoid a variance.  Today we look at the second variance, which involves access to the proposed plant.

On July 16, 2018, Synagro finally took a step to address the fact that a year earlier the Plainfield Township Zoning Officer had informed Synagro a year earlier that a zoning variance would be needed, since Synagro did not satisfy the specifications in the zoning ordinance for access to its site.  Synagro's engineer David Allen, PE (working for EarthRes Group) did a song and dance presentation that evening, in which he revealed an access point to Pen Argyl Road from the site - which is a collector road and would satisfy one criterion required by the ordinance.  David Allen PE hedged when asked if all of Synagro's trucks would use this new access point.  He said "some combination of this one as well as the entrance to the haul road from Rt 512."  In other words, this was tossing shit at the wall and hope someone would believe it.  The added access point is at the upper right:

Synagro's first attempt to provide an access that meets the ordinance

Here are the requirements of the ordinance Sec 27-316 specifically for a Material Separation Facility (which Synagro's use is if you read the ordinance definition - basically the reuse of crap through a heating process for use off site):
1. Entrances and exits to the facility shall be separated and clearly designated; 2. entrances and exits shall each be at least 30 feet in width and 3. shall be located along either an arterial or collector road.
There are three requirements for the the access drives, and Synagro has never met any of them and today still does not today as we shall soon see.

Both DEP and the township require a 50' throat length for "low volume" driveways, which Synagro's use would be at 37 trips per day.  A low volume driveway is a use of normally over 25 and under 750 trips daily, while a "minimum use" driveway is a use of normally 25 or fewer truck trips per day.  Throat length is the distance between the edge of pavement of the road and the first cross road on the site - in this case the landfill haul road.  David Allen PE stated back in July that the 30' throat length available was sufficient for a minimum use driveway but not a low volume driveway.  He proposed the new access point to Pen Argyl Road would be a minimum use driveway, and on the site plan depicted it as "Minimum Use Driveway" as seen here:

Minimum use driveway from Pen Argyl Road proposed July 2018
Does this look like separate entrances and exits, 30' in width?

Look at the kooky alignment vehicles would have to use to use this access point.  It had to be made 75' wide to allow trucks exiting and entering to not cross into oncoming traffic as they complete their turns.  They will still meet head-on as they travel through the throat.  Clearly, Synagro shit the bed with this first attempt.  It doesn't even satisfy the requirement to access the site from an arterial or collector road, because Synagro's total volume per day exceeds that of a minimum use driveway.

By October, Synagro's Traffic Engineer Jason Shetler on October 8 admitted this access to Pen Argyl Road to meet the requirements of the ordinance won't even be used and will be gated!



Testimony from October 8, 2018 planning commission review
That driveway... it isn't a driveway

Synagro then went back to the drawing board and pulled a new one out of its ass, realizing the "minimum use" emergency vehicle gated entrance wasn't going to win the day.
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The latest is that the proposed access point to Pen Argyl Road was moved east to where a 50' throat length could be obtained.  Actually, the throat length is only 43' but Synagro's engineer appears to be suggesting installing curbing over existing pavement on the haul road to make it look like 50'.

Current proposed access to Pen Argyl Road

A closer look at this late term abortion:


Synagro is now proposing a Low Use Driveway
Notice how a truck (red) blocks the entire haul road if oriented normally

If you are following along, Synagro previously had a minimum use driveway to Pen Argyl Road as a smoke screen to make it look like they satisfied the ordinance requirement to be from a collector road - but they intended to put a gate across it and it would only be for emergency vehicles, and even if used could not handle the daily traffic.  Notice this proposal retains the bizarre approach angle, which would require a truck driver exiting to see traffic to the left at about a 190 degree angle from in front of his truck.  He would of course time share his attention to southbound traffic with being alert for northbound trucks entering that would plow right into him.  What the fuck is the "STOP" bar for, parallel to Pen Argyl Road?  An exiting truck can't possibly use it, as the movements on the diagram show.

Now they propose a low use driveway, which could handle all of their daily trip proposed volume.  But everyone knows they don't plan to use it.  This is just an extension of the smoke screen, which has already been revealed as nonsense.  The improvement here is Synagro might argue they can route all their traffic from this point.  Do you see separate entrances and exits 30' wide each?  Bwa ha ha. 

Let's see what is written in the report that Synagro's traffic engineer Traffic Planning and Design submitted in December 2018:


Word salad in the conclusion of Synagro's Traffic Engineer report
Note the white space - the report doesn't indicate that a human prepared it


This report continues to play both sides of the fence.  We did an analysis which uses Pen Argyl Road only, but we recommend that access be from Route 512.  The last paragraph begins by stating what is obvious - Pen Argyl Road access is only being provided to claim that access is from a collector road as required.  But in the very next sentence, we're back to assuming all traffic will access from the Route 512 access point.  No one from Traffic Planning and Design had the guts to even put their name on this report!

If they tell PennDOT "we don't plan to use it, except for in case of emergency" PennDOT should not issue a low use permit.  That is a minimum use.  The only reason they want it to be considered low use is so they can act like it satisfies the township requirement to route their trucks through it.  Then put a gate across it.  We see what you're doing.  Look at this other truck turn diagram from the current truck turns submission, which in fact shows all trucks using Route 512 and no trucks using the Pen Argyl Rd access point.  You just could not make this shit up:


Question Mark Guy sees an issue

You should ask yourself, would PennDOT issue a Low Use Highway Occupancy Permit for Pen Argyl Road?  Highly doubtful.  PennDOT should laugh Synagro out of the room. There is a scoping meeting that has been requested between PennDOT and Synagro that Plainfield Township will attend that has not yet taken place (Synagro stated that it would request this meeting way back in July) to start that discussion.

Note that the latest proposal does nothing to provide separate entrances and exits, 30' wide each, even if PennDOT were to approve this driveway.  They still need the zoning variance.

Question Mark Guy sees bidirectional truck traffic in current plan, when entrances and exits must be separated
Plainfield Township's consultant points out glaring deficiency

What to expect at the February 21 meeting


Synagro is pushing for only two more meetings, on February 21 and March 11.  At this point, there is no summary of all the outstanding deficiencies in their application.  Tomorrow, expect Synagro to claim they have met all requirements and answered all questions, and expect the township's consultants to summarize outstanding deficiencies in each of their respective specialties.  One consultant who has gotten very little time at meetings is Trudy Johnston, who has been reviewing Synagro's Nuisance Mitigation Plan - a thick document that has gone through multiple reviews and updates off-line.

The zoning variances are game changers - Synagro can't meet the ordinance requirements of the open space around water bodies or the access road.  But there are numerous outstanding items that must be discussed as well.  It's time for an itemized list, so that the commission can make a recommendation.  Here's one - take your shitty project elsewhere!

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