By Rebecca Martin
On Monday, June 29 at noon, the Ulster County Recovery Resource Authority (UCRRA) will hold their monthly meeting. We have provided the following pubic comment.
Dear Members of the UCRRA Board,
We wish to commend you for your hard efforts in creating a Local Solid Waste Plan for Ulster County. From our early conversations with professionals, Ulster County and specifically UCRRA is seen as a leader on managing solid waste.
However, in regard to the BioMass section of your document (page 111-112), we request that the board consider a resolution to remove the BioHiTech facility in Ulster County from its plan.
Recently, we have learned about BioHiTech, a “Municipal Solid Waste Processing Facility” with a project that is now online in West Virginia and another currently under scrutiny in the City of Rensselaer.
The proposed facility in the City of Rensselaer initially referred to itself as a “composting facility” in its Environmental Assessment Form for SEQR. Far from it. As we understand it, this “emerging technology” produces Refuse-derived Fuel (RDF) by first collecting municipal waste. After removing any valuable metals, the plastic and fibers are dried and shredded into confetti. They are then trucked away to cement plants where it is incinerated to supplement coal in creating energy. The remaining waste is dumped in unnamed landfills or garbage incinerators.
With a population of 9300 residents, the City of Rensselaer community is already shouldering four polluting facilities (a nearby massive asphalt receiving facility, the Rensselaer Cogeneration gas-fired power plant, a major Amtrak hub and the Dunn Construction and Demolition debris landfill (situated next to a pre-K to 12 public school) and across the river, Global oil terminal). “The proposed BioHiTech facility project, situated near a DEC potential environmental justice area, would be built on top of a capped toxic waste site, the former BASF property, where existing contamination affects the soil, groundwater, and nearby Hudson River. It would accept constant shipments of municipal garbage. Trucks would make about 82 trips in and out of the facility every day, according to the applicant.” This would be tragic for Rensselaer.
So it is of great concern to us that in UCRRA’s most recent plan, it calls to contract a consulting firm to evaluate the possibility of permitting and constructing a local landfill or a BioHiTech Facility within Ulster County.
In section 7.11 Technology Selection, it says, “..three technologies have been selected to pursue in the 10-year planning period. Feasibility studies for siting a local landfill, installing a BioHiTech (biomass) Facility, and waste exportation by railroad will be conducted”
To be clear, we understand that to date, UCRRA has not included incineration as a solution to municipal solid waste within Ulster County. That’s wise given the history of environmental advocacy here, as the outcry would be fierce. Let it be known that we also do not support Ulster County engaging in incineration anywhere.
On page 74, section 5.2.9 Local Environmental Justice it says,. “Environmental justice means the fair treatment and meaningful involvement of all people regardless of race, color, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. Fair treatment means that no group of people, including a racial, ethnic, or socioeconomic group, should bear a disproportionate share of the negative environmental consequences resulting from industrial, municipal, and commercial operations or the execution of federal, state, local, and tribal programs and policies. Environmental justice, under the NYSDEC Policy 29 aims to enhance public participation and the review of environmental impacts from proposed construction of facilities in environmental justice communities, and to reduce disproportionate environmental impacts in overburdened communities.”
If UCRRA is indeed concerned about Environmental Justice communities in Ulster County, then it should also be concerned in its role to potentially exploit communities outside of Ulster County, those who would bear the brunt of our shipment of shredded plastics and fiber for incineration. We encourage you to think hard about how you would feel if you and your family were living near an incinerator burning waste in general, and then the waste of those from another state.
For all of these reasons, we request that the UCRRA board consider passing a resolution to remove BioHiTech from its current Local Solid Waste Management plan as a potential future option in Ulster County.
In addition, we sought advice from Neil Seldman and made a small donation to the Institute for Local Self-Reliance to review UCRRA’s 2011 and 2020 Local Solid Waste Plans and provide a memorandum to outline the pros and cons for Ulster County. All incineration plans are stated as “a very bad idea.” He goes on to say that he “will not comment on this very outdated 20th century technology.” Most, if not all of us, are aware of Seldman’s work and hold him in high esteem. We are submitting the memorandum as an attachment to our public comment.
READ: Ulster County Resource Recovery Agency Local Solid Waste Management Plan
READ: Institute for Self Reliance Memorandum on Ulster County Local Solid Waste Plan
READ: Riverkeeper Opposes Waste Facility on the Hudson River in Rensselaer