Plainfield Township planners consider Enforcement, Shutdown and Fines protocol for proposed Synagro crap factory submitted at eleventh hour

On August 30, 2019, five business days prior to what is planned to be the final planning commission review of Synagro's land development plan, Synagro submitted a thick package of updated materials.  This consists of a full set of plans (including modification of a driveway) and truck movement diagrams, as well as over 300 pages of narrative.  Normally, there is a three week requirement for new materials to be submitted, which has been violated multiple times by Synagro.  Chairman Levitz admonished Synagro about this only 3 months ago.  The three week requirement is to allow for consultant review, and review by planners prior to a meeting.  An ethical applicant would extend the deadline (currently September 30, 2019) for a decision, when submitting materials they would like considered with 5 business days notice.  Mr. Levitz' point addressing this issue was, if you want the commission to consider something it is common as well as professional courtesy to submit it in a timely manner.  In this case the township is not dealing with an ethical applicant, so neither of these courtesies are relevant.

Included in the submission is the latest draft of the Nuisance Mitigation Control Plan.  This document is prepared by Synagro by request of the township, and township biosolids consultant Trudy Johnson is the expert who is evaluating its contents as suitable on unsuitable.

While some items in Synagro's late submission may have been new to the township, the township had something up its sleeve for Synagro that it delivered a few days later.  On September 4, Ms. Johnson submitted a document titled "Enforcement/Shutdown Provisions Protocol," which was delivered to Synagro on September 6, 2019.  The lack of finalizing agreement on this Protocol and its inclusion in the NMCP is included in the memorandum of Mr. Petrucci (also delivered on September 6), as a justification for recommending denial of the plan.

Planning commission and audience members as well as Pen Argyl solicitor Peter Layman have expressed concern for months that enforcement may not be effective.  Synagro's proposal in the NMCP would result in a situation where months could go by before any action might be taken to resolve a complaint of odors.  To address this, Ms. Johnson has crafted this Protocol, which includes a table of fines due to lack of compliance.  Synagro isn't going to be enamored of either fines or "shutdown".  This blogger did not find this Protocol in the August 30 version of the NMCP submitted by Synagro (attached below), so it appears to be brand new.  It is only two pages, and presented for your inspection:

Synagro Slate Belt Heat Recovery Center Enforcement/Shutdown Provision Protocol on Scribd

  Enforcement/Shutdown Provision Protocol

Here is Synagro's submission of the NMCP on August 30:

Nuisance Mitigation Control Plan - 8.30.2019 Submission on Scribd