The EPA Risk Assessment report draws specifically on DRN/GeoSystem’s data in their conclusion that the PGC did not go nearly far enough in their Risk Assessment and that the contamination was worse than the PGC’s assessment led everyone to believe. Worse in terms of possible other contaminants on-site and how much of the Delaware River could be impacted.
According to DEP, upon receipt of EPA’s evaluation of PGC’s Risk Assessment, did not know about the DRN/GeoSystem’s data. Thankfully DEP had denied the Club’s assessment on other findings – albiet much weaker ecologically speaking reasons. The PGC had scheduled a meeting with DEP to challenge DEP’s denial, but cancelled the meeting once they recieved EPA’s report. According to DEP, the PGC admitted they knew of the DRN/GeoSystem data but didn’t believe it so didn’t include it into their report. DEP suggested that they could have collected their own data if the didn’t trust DRN’s data.
Background
I think alos that our comprehensive comments to PGC’s Risk Assessment report empowered and encouraged EPA to do a much more thorough job themselves. If you stood next to a park or recreational trail used throughout the year and shot a gun up into the air so that gun shot rained down on that park or trail, even during times when people play, run, walk, cycle or otherwise use the area you’d be stopped by the authorities, probably ticketed or fined. If you continued those shoots 12 times a year every year you’d be in even bigger trouble. It would only take one call to get the authorities to act.
If you stood on the banks of the Delaware River 12 times a year and for 4 to 6 hours threw trash in, handful after handful, you’d be stopped and probably get a fine. If you stood on the banks of the Delaware River and shot a gun up into the air so that gun shot came raining down onto the water, even when boaters were boating by, you’d be stopped and probably fined. If that is the case then why is it that the Philadelphia Gun Club can do that very same act, a whole gun club not just one person, and shoot their gun up into the air so gun shot rains out over and into the river, polluting the river and putting in jeopardy anyone boating by, with no permit and no repercussions?
A curtain the Philadelphia Gun Club has hung to hide their actions on the site does not protect river users from the rain of gun shot, and does nothing with regards to the gun shot from the club’s shooters that stand and shoot openly from the banks of the river. Check out this video to see for yourself: http://youtu.be/W76vm4vTcr0
Up to 12 times a year the gun club shoots out over the Delaware River. Boaters in open topped boats with no face, eye, neck or body protection power through the area at their own risk of getting pelted in the face or body with the falling shot, shot so dangerous it cut the skin of a person sitting still in a kayak when hit – could you imagine the harm to a person traveling at a high rate of speed on a motor boat who happened to run into a rain of shot?
We have witnessed power boats travelling with the driver exposed and powering through the area right by the gun club during the time of a shoot. We at the Delaware Riverkeeper Network don’t understand how this dangerous situation can be allowed to continue. And as the boat season lengthens with the warmer winters we are seeing more and more boaters go by when the club does its shoots during the months of November through March.
We have asked the Pennsylvania Department of Environmental Protection to act on the pollution that is raining into the water, and the Coast Guard to address the safety issue these shoots create – so far neither have acted. (Learn more about Delaware Riverkeeper Network legal actions on the matter)
Now it is also time for our politicians to get involved. To sign a statement of concern that can be used to help convince our legislators to take a stand on this issue go to our action alert.
In Plainfield Township, Northampton County, PA, the 80 acre Hower Farm is being proposed for disposal of processed sewage sludge i.e. “biosolids”. The property is located at 6249 Hower Rd., Nazareth, PA. Biosolids are the product from wastewater treatment processes where the liquids are separated from the solids and the solids are treated to produce a semisolid, nutrient-rich product, as defined by the US Environmental Protection Agency.1
The Nazareth Borough Municipal Authority bought the property in the fall of 2021. The Municipal Authority’s sewage treatment plant (Nazareth Borough Municipal Authority Wastewater Treatment Plant, Lower Nazareth Township, Northampton County, PA) would supply the sewage sludge; it is uncertain if other sources of sewage sludge would be used as well.
While the Hower farm property is preserved farmland, the Pennsylvania Right to Farm Act does allow for the permitted disposal of biosolids on the land. Community members and neighbors to the Hower Farm property remain concerned about the possibility of pollution to groundwater and the Little Bushkill Creek, possible damage to wetlands on and adjacent to the property, stormwater runoff and flooding, the historic nature of the property being ruined, and air emissions and odor that could result from the spread of the biosolids.
Biosolids are known to contain many pollutants that are contained in sewage sludge and, depending on the waste stream to the sewage treatment plant, can contain toxic and/or hazardous materials, radioactive substances and unregulated toxic compounds such as per and poly-fluoroalkyl substances (PFAS).
The Hower Farm Property
The Hower Farm property flows down to the Little Bushkill Creek and an intermittent stream flows through the property to a pond and the stream. The Little Bushkill Creek has a designated use as a High Quality-Cold Water Fishery. It has also been determined to be impaired in meeting its designated uses. Little Bushkill Creek is a tributary to Bushkill Creek with an approximately 17.5 square mile (mi.2) watershed.2 The Bushkill Creek flows to the Delaware River.
The Hower Farm property’s headwater stream begins in the property and runs into the Little Bushkill Creek which raises more concerns that the Little Bushkill Creek will become polluted and impaired by the runoff created from the spread of biosolids on the property and the farming practices that are being used on the land, which are different than how the farm was cultivated for decades. According to concerned community members, there is a plan to place two detention basins on the property to address stormwater. However, the land is comprised of two large slopes that are vulnerable to erosion.
The Hower Farm is located in an agricultural area of the township, surrounded by open land and next to a community park. The Farmer’s Fairgrounds host the local Farmers Fair there annually. The historic house on the property was most likely built in the early 1800’s but is slated for demolition by the Municipal Authority.
Municipal Authority Refused to Grant Permission
The Municipal Authority has refused to grant permission for the Northampton County Conservation District to disclose the farm conservation plan for the property to Delaware Riverkeeper Network, which we have sought through Right to Know and letters to various agencies. DRN’s requests to Nazareth Borough for assistance in gaining access to the farm conservation plan have yielded no success. The farm conservation plan has important information that is supposed to ensure that the farming practices used on the preserved land, which would include the land application of biosolids, does not negatively effect the environment and is beneficial to regional conservation of natural resources.
DRN submitted comment to the Delaware River Basin Commission on an application for the Nazareth Borough Municipal Authority Wastewater Treatment Plant to renew its current docket (1.6 mgd WWTP and its discharge) and change from chlorine disinfection to ultraviolet (UV) disinfection.3 A copy of the comment is below under Supporting Documents.
The Nazareth Borough Municipal Authority (NBMA) has a General Permit from the PA Department of Environmental Protection to apply sewage sludge (Class B biosolids) to land from their sewage treatment plant. This general permit can be used on property other than what the permit was originally planned for because DEP evaluates the sludge that is being produced by the sewage facility (rather than the location where the biosolids would be applied) in its determination of compliance with DEP biosolids regulations. On October 27, 2023, NBMA issued notice that they planned to start applying biosolids to the Hower Farm. This is required to be done 30 days in advance of the applying of the sludge.
The Community
The community members working to protect the region from the harmful impacts of sewage sludge and biosolids land application have formed a nonprofit corporation Save Plainfield Township (see https://www.saveplainfieldtownship.com/). Plainfield Township, where the Hower Farm is located, filed a Notice of Appeal with the Environmental Hearing Board objecting to the 30-day notice. Violations of Pennsylvania environmental laws and objections to the General Permit were cited. Save Plainfield Township has intervened in the appeal in support of the Township. Delaware Riverkeeper Network is in support of this legal action.
On November 4, 2023, PADEP published a notice for an individual “Draft NPDES Permit for Discharges of Stormwater Associated with Construction Activities (PAD480199)” based on the application NBMA filed with PADEP to discharge stormwater runoff from stormwater infrastructure they plan to construct on the Hower Farm. The permit would allow the demolition of the farm house, barn and other structures and the installation of stormwater basins, land cover changes such as driveways, associated piping and a storage area for the biosolids produced by the NBMA sewage treatment plant. The discharge would flow to the Little Bushkill Creek, crossing neighboring property.
DRN requested that the 30-day comment period be extended beyond the original deadline of Dec. 4 (see extension request below). PADEP granted the extension to December 19, 2023. DRN, Save Plainfield Twp., Plainfield Twp., and several members of the public submitted comments to PADEP criticizing the proposed permit and the deficiency of the application. Among the objections to the proposed permit was that the Erosion and Sediment Control (E&S) Plan and a Post-Construction Stormwater Management (PCSM) Plan were inadequate and did not comply with effluent standards required in federal regulations at 40 CFR Part 450. For technical details see below for a copy of DRN’s comments prepared by stormwater experts Meliora Design.
Update
As of mid-January 2024, PADEP has not issued a NPDES permit. There has been no application of biosolids to date.
“Plainfield Township, Little Bushkill Creek, Restoration Plan”, prepared for Plainfield Twp., November 2013 Project No.: 19999838. See DRBC draft docket here.
In February 2012, ten concerned Eastwick residents met to discuss two recent home invasions that threatened the quality of life in their quiet Southwest Philadelphia community. From that initial meeting, bimonthly meetings were quickly established where the group began to address a host of community concerns. They contacted agencies responsible for tackling such issues as chronic illegal dumping, insufficient lighting at the local rail station and the need for increased policing in targeted areas. The committee of ten also encouraged their neighbors to get involved and to become more aware of activity in the community that appeared questionable or suspicious.
It was this increased vigilance that prompted one of those concerned residents to question surveying close to his home in late April. Upon doing so, he learned that the area being surveyed was the location of a proposed one hundred million dollar residential development project, as well as potential expansion of the Philadelphia International Airport, all on a 128-acre undeveloped parcel adjacent to John Heinz National Wildlife Refuge. Further inquiry revealed that, unbeknownst to the community, Philadelphia City Council was poised to approve a rezoning bill on June 12th that would allow the developer to begin the 5-year project to build 722 apartments with parking lots to accommodate 1,034 vehicles—on 35 of the 128 acres, which is currently zoned for single-family homes and also partially designated by FEMA (Federal Emergency Management Agency) as a Special Flood Hazard Area.
Stunned that such a massive, high-density project was about to take place on land currently serving as a natural barrier against flooding, the ten concerned residents quickly formed the Eastwick Action Committee (EAC), and joined with the Friends of Heinz Refuge (FOHR) to establish the Eastwick Friends & Neighbors Coalition (EFNC).
Halting the Proposed Development
EFNC immediately mounted strategies to halt the proposed development until the community could be fully apprised of the developer’s and the City’s plans. EFNC’s goal was to ensure that no development in the targeted location would result in harm to current or future residents or to the habitat at the John Heinz National Wildlife Refuge. EFNC swiftly gained the support of notable environmental groups including Delaware Riverkeeper Network, Keystone Conservation Trust and the Pennsylvania Chapter of the Sierra Club as well as pro bono legal representation by the Public Interest Law Center of Philadelphia and Dechert LLC and the support and technical guidance of Penn Urban Studies Program. The community was soon spurred into action, circulating a petition door-to-door, engaging the media with press releases, and mobilizing volunteers for next steps in the process to oppose the rezoning bill at the upcoming City Council hearing.
On June 12, 2012 members and supporters of EFNC provided passionate and fact-based testimony that resulted in City Council tabling the proposed rezoning bill that would have given the developer’s project the green light. On November 20, 2012, Councilman Kenyatta Johnson, who had previously supported the proposal, pulled the rezoning bill, denying the developer’s request to rezone the 35 acres to build the massive apartment complex. Councilman Johnson stated that the community had spoken “loud and clear” and deserved a say in what happens in their community.
EFNC celebrates this victory with the understanding that the future remains uncertain for the 128-acre parcel. Armed with this knowledge, EFNC has seized the opportunity to launch a comprehensive community education, engagement, and visioning process that will allow residents, business owners and stakeholders, who are open to new growth and development, but in a sustainable and ecologically responsible manner, an opportunity for meaningful and equitable dialogue and participation to ensure that when future development does occur residents are safe, localized and catastrophic flooding impacts are addressed, and environmentally sensitive lands, wildlife, and green spaces are protected. This community assessment report, which reflects the sentiments of 93% (244 of 250 qualifying Eastwick residents) who live in the area immediately adjacent to the 128-acre parcel, is just one step in that direction.
UPDATE – We need you to say NO to Camp FIMFO on December 18th
We need you for public comment!On December 18th, 2024 the Township of Highland Planning Board will be holding their public hearing regarding the next steps for Camp FIMFO and accepting comments on their DEIS. This hearing is open to everyone, not just residents, and we need your help to pack the room! The hearing will be held from 6-8pm at The Eldred Junior/Senior High School located at 600 Route 55 in Eldred NY, for members of the public to each deliver a 3 minute public comment. If the two hour time slot runs out and there are still people left who need to comment, the Planning Board will need to hold another hearing in January, 2025. We encourage everyone to use their full 3 minutes of comment time.
Submit Your Comment Digitally and Verbally. All written comments can be emailed to the Planning Board at planningboardzba@townofhighlandny.com and please CC your comments to DRN at keeper@delawareriverkeeper.org, until January 10th. If you sent in a written comment before December 4, we recommend resending your comment to ensure it is in the comment window. If you are speaking at the public hearing, please also write down your comment and email it to the Planning Board for their records.
“Say NO to Camp FIMFO” lawn signs are available.
As everyone is well aware we need to continue to scream from the rooftops our opposition to Camp FIMFO. Yard signs put on public display to the Town of Highland Planning Board and Northgate Resorts that we are saying NO to Camp FIMFO. Additionally, this will help us spread the word to those who may not yet know about Camp FIMFO and help us raise broader public awareness.
A community member has generously offered to help serve as a pickup point for those interested in getting a yard sign. We ask that you join our No Camp FIMFO – Protect Our River Action Platform where we will be sharing the information on how you can get in touch to get a yard sign. We are urging folks to use the secure platform so we can keep this information from opposition.
The bonus of joining this action platform as well is it is a closed community with our allies against Camp FIMFO where we will be able to quickly and easily share information and action items with you.
Tell the Highland Planning Board more time is needed for equitable public engagement and public comments
On November 20th, the Town of Highland Planning Board acknowledged that with the holiday season approaching and the public hearing upcoming on December 18th, the accepted DEIS for Camp FIMFO and key information regarding timing of submitting public comments and info for the December 18th hearing needed to be shared immediately. The DEIS was not shared on the Town of Highland’s website until December 6th, and a post about the public hearing was not made until December 11th on the website. We are now less than 1 week away from the hearing. That means the public has lost meaningful time to read the completed DEIS and its Appendices, plan their public comments for written submission and oral testimony, and perhaps many are still unaware and thus unable to accordingly plan for the December 18th hearing! We need you to tell the Planning Board that this is unacceptable and that the public is owed more time to properly prepare and engage in a public comment process.
In the Town of Highland, Sullivan County, New York, Northgate Resorts is proposing to overhaul the former Kittatinny Campground with an operation they call Camp FIMFO. The proposal would transform most of the existing low impact tent camp sites to RV sites, cabins or glamping structures with water, sewage and/or electric hook ups; adding a mountain roller coaster, water slides, a swimming pool, mini golf, more parking, more septic systems, as well as replacing some of the old existing buildings with new.
According to one official on the Upper Delaware Council, this is the largest development project ever to come to the region.
Overall, the true scale and impacts of the project are being masked by a lack of information with differing detals dribbling out over time. It also seems clear that if Northgate gets to have its way, we will be seeing more theme-park-like operations of this kind invading our Upper Delaware region and magnifying the harm.
After careful review, on May 25, 2023, the National Park Service issued a letter stating its determination that the project fails to conform with Land and Water Use Guidelines (LWUG) for the Upper Delaware Scenic and Recreational River. You can read about it in the River Reporter here: https://riverreporter.com/stories/nps-rejects-fimfo,99920
The National Park Service has complimented its letter and public presentation regarding its review of Camp FIMFO with a detailed Significant Project Substantial Conformance Review issued June 26, 2023 (available here). In response, Northgate-FIMFO sent a highly inappropriate letter to the Town of Highland Planning Board. To which the Delaware Riverkeeper Network has submitted its own response, available here.
On September 14 the Delaware Riverkeeper Network held an informational meeting with residents in the Upper Delaware River region to discuss the proposed Camp FIMFO site changes.
On September 27th, the Town of Highland Planning Board held a meeting and voted 3-2 in favor of conducting an Environmental Impact Statement for the project.
The Delaware Riverkeeper Network has secured the expert analysis of an urban planner with 30 years of experience. The findings are clear, the Town of Highland Planning Board needs to require a full Environmental Impact Statement, anything short is a violation of state law and a betrayal of the public trust.
The Environmental Impact Statement (EIS) process is now getting underway. It begins with a public process call “Scoping”. This is where all of the issues of concern that must be addressed in the EIS are identified. You don’t have to provide the analysis of the issue at this stage, just clearly identify the issue to be analyzed. The Town has announced it will accept comments on the draft scoping document between November 3 and November 22. The Delaware Riverkeeper Network does not think a mere 20 days –particularly when they include travel days typically associated with Thanksgiving as well as election time — provides enough time and has submitted a comment urging the Town Planning Board to extend the comment period until December 21. You can review the Delaware Riverkeeper’s letter here. We are also urging others to demand this important extension of time.
The Delaware Riverkeeper Network has submitted comments regarding the Scoping Document. You can review our comment here. Feel free to use our comment as a guide for what you may want to say in a comment you submit.
Submit your comment on the draft Scoping Document to: Ms. Monica McGil, Planning Board Secretary at email address planningboardzba@townofhighlandny.com
–> You can review the notice regarding the public comment process by clicking here.
–> You can see a copy of the proposed document up for comment by clicking here.
Holding tanks from an old landfill – the Barnes Landfill, has been discovered to have leaked tens and thousands of gallons of leachate to surrounding streams:
Some Basic Facts:
The site is ~223 acres and has many areas of wooded steep slopes and fronts along the Delaware River.
The Beaver Brook flows through the central portion of the site.
Much of the project site is located within the 100-year and 500-year floodplains.
Of the 342 campsites that exist currently, only 56 will remain tent campsites. The rest will be turned into sites for RVs including with water and sewer hookups, permanent cabins, or sites with constructed glamping pods or safari type tents.
Delaware Riverkeeper Network is working with the community fully assess and question what is being proposed.
