DEP now receiving public comments for two different permit applications related to Synagro biosolids plant in Plainfield Township - public hearing in Wind Gap scheduled

There are two permit applications the PA DEP is accepting comments/complaints on, associated with the Synagro crap bakery planned for Plainfield Township, Northampton County PA.

• NPDES Draft Permit (stormwater specific)  Public hearing November 7, 2018
• General Permit application (general, including wastewater, air) Comments/complaints due by Oct 17, 2018

This is a bit confusing, but here are the details.  The General Permit application is not yet what is called a "draft permit," but the NPDES permit is a draft permit.  Once a permit is a draft permit, a local public hearing may be scheduled, if the DEP determines it is warranted based on municipality concerns.

The NPDES Permit application went straight to draft permit status (Draft Permit No. PA0276120), since it is much smaller than the General Permit.  This allowed the local pubic hearing to be scheduled for November 7.  The announcement of the hearing is at the end of the document located at this link

• DEP will give speaking priority to those who register prior to the hearing date by submitting their name via email to Colleen Connolly at coconnolly@pa.gov
• This author suggests you put "Registration for hearing on PA0276120" in the subject line.
• "Walk-in" members of the public can sign up to speak at the hearing if time is available.
• DEP will require that your comments to be made orally be submitted in writing, which may be done at the hearing.  (Therefore you need not submit your comments via email, and it is unknown at this point if they would be accepted if you do).
• Speakers are limited to 2 questions and a total of 5 minutes.  This may mean two questions and/or unlimited comments for up to 5 minutes.
• Additional written comments are typically accepted by DEP up to a few weeks following the hearing - the closing date has not yet been published.
• Note that an NPDES permit is specific to stormwater, so complaints about air quality (for example) are not best made here - they may be ignored.  Feel free to vent if it floats your boat though ;)
• If you are concerned about runoff from the site into the Little Bushkill or Waltz Creek or Sedimentation Basin #2 (freshwater pond) from the various possible sources (accidents, trucks tracking shit across the parking lot, etc) then this hearing is for you.  Synagro and its engineer EarthRes claim this shit factory will be magically insulated from these water bodies by "vegetative buffers" and anyone with half a brain knows that is bull shit. Of course when the General Permit public hearing occurs, general comments about all kinds of shit will be appropriate.

DEP Hearing for Synagro NPDES (stormwater) Permit

November 7, 2018

6pm to 9:30pm

Wind Gap Middle School

1620 Teels Road Wind Gap PA

The General Permit application (Permit Application No. WMGR160) will go through a more lengthy process initially, and then track like the process above for the NPDES draft permit.  At the moment the permit application is considered "administratively complete."  Next, DEP will accept written "technical deficiency" complaints from anyone until October 17, 2018.  Then it will process the complaints, and request Synagro to update its application to address concerns that the DEP agrees need more detail, etc.  Once Synagro submits satisfactory updates, DEP will change the General Permit status to a draft permit.  At this point, a public hearing will be scheduled as in the case of the NPDES permit.  The DEP announcement for the public "technical deficiency" comment period for this permit is on page 17 of the document at this link

• Hard copy complaints may be mailed to Chris Solloway, Group Manager, Division of Municipal and Residual Waste, Bureau of Waste Management, P.O. Box 69170, Harrisburg, PA 17106-9170 by October 17.
• Complaints may be submitted via email to ra-epbenuseall@pa.gov by October 17.
• Put "Comments on WMGR160NE001" in the subject line of the email
• This permit is for the entire facility, so any concerns (wastewater, air quality, odors, etc) may be brought up (though stormwater is most appropriate for the NPDES hearing).
• Complaints may be truly "technical" - addressing specific deficiencies contained in the Application, or more general in nature or in between.
• At this point there is no way of knowing when a public hearing on the General Permit will be held, but it is safe to assume there will be one.

This is your chance to speak up!  The Delaware Riverkeeper has a form and sample comment letter for the General Permit application comments due October 17.  This allows you to submit a complaint using a "fill in the blanks" approach, and not concern yourself with attaching an email and using an email program.  The DEP instructions state that your complaint may make a recommendation that:

1. The application be revised.
2. The application be approved.
3. The application be rejected. DING! DING! DING!  We have a winner!!!

The Riverkeeper reports that it is preparing a similar form for signing up for the NPDES Permit November 7 hearing.  A link will be provided here when that is available.

Note:There are other permit applications for this project.  If in the next week, an additional permit (eg Air) reaches draft status, it could be added to the November 7 hearing so as not to have to schedule an additional hearing.