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Mt. Hope 30MW Biomass Power Plant

Date : Mon, 14 Jul 2008 15:41:50 -0400

For Immediate Release
Ms. Rebecca Hill NJDEP Bureau of Watershed Regulation PO Box 418

401 East State Street Trenton, NJ 08625-0418

Re: Block 20001, Lot 5.05 Mt. Hope 30MW Biomass Power Plant Highlands Applicability - Program Interest No.: 435442

Dear Ms. Hill:

The Sierra Club is deeply concerned about the petition submitted by the Mt. Hope 30MW Biomass Power Plant for exemption from the Highlands Water Protection and Planning Act Rules. We believe that this project, which is heavy industry and an incinerator, does not meet the intent or statutory authority of the Highlands Act, which is to enhance, protect, and restore water quality and quantity in the Highlands region. We further believe that this project fails to meet the criteria for Exemption #4 because the documents submitted were as much as 50 years old and do not represent the current conditions on the lands, such as wetlands and other environmentally-sensitive features which have formed on the land and the presence of threatened and endangered species, including the federally-protected Indiana bat.

The Mt. Hope plant would be a depletive use of groundwater, impacting at least three Category 1 streams, which are also designated as Highlands waters. Among these would be the Beaver Brook, which is currently in water supply deficit. The plant would draw 250,000 gallons of water per day from the mine shaft, potentially reducing water levels in Mt. Hope Pond, Mt. Hope Lake, and White Meadow Lake. These groundwater withdrawals, as a depletive use, would violate the Highlands Act. In addition, mercury and other metals and nitrous oxide released from the plant could lead to additional pollution and nitrogen deposition in Highlands groundwater, again in violation of the Highlands Act.

This project is inconsistent with the draft Highlands Regional Master Plan and local zoning ordinances. It would be fueled by wood from the surrounding area, disturbing the forest ecosystem and stream buffer zones, as well as contributing to global warming. Further, the plant would further degrade air quality through emissions from the plant, truck traffic, and blowing biomass dust.

The petition also lacks adequate representation of the potential environmental impact of this power plant. The following is a list of our concerns regarding the completeness of the petition:

 a.. According to the Highlands Water Protection and Planning Act Rules, the exemption category that has been applied for, does not apply to the reconstruction of a structure. The only structures permitted in that exemption are for agricultural or horticultural uses. Therefore, the submitted site plan is incorrect.   b.. The applicant is proposing the demolition of future historic structures with their site plan. However, the Highlands Act includes the special protection of historic features.   c.. The Highlands Act includes special protection for threatened or endangered species. However, this facility is in close proximity to known habitat and hibernaculum for the endangered Indiana bat.   d.. The area of the proposed structures falls on wetlands according to the NJDEP freshwater wetlands map. There also appears to be area of fill in wetland areas. How will your office enforce potential existing encroachments and the impact from this proposed expansion? How can this application be reviewed if there are existing wetland encroachments within the proposed area of development?   e.. The site plan last revised 2/15/08 (which substantially increased the size of the proposed facility) refers to a survey dated April 20, 1988 and aerial plan dated February 16, 1999. I believe a survey that is over 20 years old is an outdated document for this application, especially since some of the existing structures do not match between the survey and the site plan.   f.. The exemption category that has been applied for (as stated on the application) requires details of the site on August 10, 2004. However, the submitted 1999 aerial plan depicts many of the existing structures already demolished. How can these structures be included in the application if they were already gone before August 10, 2004?   g.. A portion of the existing structures were suspended conveyor systems that do not have a continuous area of disturbance at the ground level. Therefore, how can these structures be included in the footprint of the disturbance calculations?   h.. In order to depict the total area of disturbance with this application the detail of any proposed power line interconnection must be provided. Also, any further necessary upgrades to the existing power line must be included in the total area of disturbance.   If you have any questions or would like to discuss this matter further, please feel free to call me at (609) 558-9100.

Sincerely,

Jeff Tittel Director, New Jersey Sierra Club

Received on 2008-07-14 17:00:12

New Jersey Sierra Club, 145 West Hanover St., Trenton, NJ 08618, USA
tel: 609 656 7612, fax 609 656 7618
or email Nicole Dallara, Outreach Coordinator, at nicole.dallara@sierraclub.org

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