DRN filed comment to PADEP in response to Holbert’s conditional use permit application for the expansion of their operation despite habitual permitting violations.  DRN requested a public hearing.  Prior to the DEP’s decision, the Upper Delaware River National Park Service entered into negotiations with Holbert and requested DRN to hold back our demand for the hearing.  The NPS described the tentative negations that Holbert would only be able to have a total of 5 acres disturbed at one time, would acknowledge that they are, in fact, in the Upper Delaware River Management Planning district and that these negotiated terms would be written into their DEP permit so they would contain a higher degree of enforceability.  DRN complied with the NPS request and will continue to closely follow this issue.  There are other blue stone quarries and other potentially detrimental land uses, such as large-scale foresting, that could try and follow the same path as Holbert.  It’s a positive result if the NPS can negotiate these terms.
 
The Holbert Quarry, located in Lackawaxen, PA and within the Upper Delaware River Wild and Scenic designated area, has been granted permission by the town to expand their quarry in violation of the Upper Delaware River Management Plan.  Pennsylvania DEP is now reviewing the quarry’s permit application.  The Delaware Riverkeeper Network has urged the state to schedule a public hearing be held prior to the  before any decisions are made regarding issuance of a permit for the Holbert Quarry to conduct noncoal surface mining activities in Lackawaxen Township pursuant to the Noncoal Surface Mining Conservation and Reclamation Act and the Clean Streams Law.
 
The Delaware Riverkeeper Network believes the Holbert Quarryand proposed operations under consideration for permitting pose a significant threat to the water quality, environments, aesthetics and health of the Delaware River and the River Corridor.
 
The Delaware Riverkeeper Network was among those that worked so diligently to support and secure Wild and Scenic designation of this reach of the Delaware River; a designation granted in direct response to the quality, health and beauty of this reach of the River.  And we were leaders in the effort to secure the Special Protection Waters designation that was granted in direct response to, and in order to protect, the high quality waters that have been shown, through years of careful data collection and research to exist in this portion of the River. 
 
As documented by the Upper Delaware River Management Plan (RMP), the current footprint of the quarry is clearly within the Wild and Scenic River Corridor.  The Commonwealth of Pennsylvania is obligation by Executive Order 2003-5 and through its membership on the Delaware River Basin Commission to take actions, including making decisions that are consistent with “the goals, policies, and objectives of the Upper Delaware Scenic River Management Plan.  And pursuant to the Clean Streams Law and Clean Water Act it has an obligation to protect the high quality waters of the Upper Delaware, protecting the quality of those waters from degradation.
 
The proposed quarry operations will require clear cutting of forests, blasting, crushing of stone, and increasing truck traffic all of which will result in increased polluted runoff, noise pollution, air pollution, water pollution, and the industrialization of now natural landscapes.  A minimum of 40 acres will be affected and pollution inputs are proposed for a tributary and to the Delaware River.  The proposed quarry operations will result in land disturbances in the River Corridor and pollution inputs into this reach of the River that will degrade the existing high quality waters and environments of the River in contradiction to the goals of the Management Plan, and state and federal water quality protection laws.  Protecting the high quality waters and healthy environments of the Delaware River’s upper reaches are of high priority concern to the Delaware Riverkeeper Network and our members and is deserving of careful examination at a public hearing. 
 
This reach of the River and its tributary, the Lackawaxen, are irreplaceable for supporting recreation and ecotourism vital to the region.  Damaging the forests, wildlife and water quality that are what attracts and sustains ecotourism and recreational visits to the region undermines the protections and goals embodied and articulated in the Upper Delaware River Management Plan and are issues of high priority concern to the Delaware Riverkeeper Network and our members and are deserving of careful examination at a public hearing.
 
The Dwarf Wedgemussel is an endangered species put at risk by the pollution inputs and land disturbance caused by the proposed quarry operations.  Pollution, siltation and temperature changes that could result from the changed landscape and mining operations are of high priority concern to the nation and the Delaware Riverkeeper Network and are deserving of careful examination at a public hearing. 
 
That the operators of this facility have already been found in violation of previous permits and approvals is another major concern that needs public airing.  A failure to comply with the approvals and permits already provided operators is a critical issue and gives an obvious glimpse through the window of the future if additional permits and approvals were to be given. 
 
What is being proposed is a heavy industrial use, a kind of Use specifically prohibited in the River Management Plan, and as such there is significant precedent that is being laid with the decision made for this operation.  A careful examination in the context of a public hearing is more than appropriate in this precedent setting regard, it is necessary.
 
Communities lower down on the Delaware River already experience extreme flood damages resulting from the rainfall and runoff that occurs up river.  Any activities that remove forest cover and increase runoff contribute to the volume of water that causes these damages.  A careful assessment of the pollution and runoff impacts the deforestation and land compaction resulting from the proposed operations will have on downstream communities is worthy of careful examination in a public hearing context. 
 
The Delaware Riverkeeper Network has been working for over two decades to protect this reach of the Delaware River and its tributary streams.  We have members throughout the region that rely upon, appreciated, respect and appreciate the health and beauty of the Upper Delaware River and its watershed.  We respectfully request a public hearing be held on the Holbert Quarry permit applications before any decision