City of Albany - Rapp Road Landfill Expansion - Letter sent to DEC on December 3, 2008
Published on 12/3/2008
December 3, 2008
Re: NOTICE OF COMPLETE APPLICATION
NOTICE OF COMPLETION OF SDEIS
NOTICE of PUBLIC HEARING
City of Albany - Rapp Road Landfill Expansion
My name is Dominick Calsolaro. I am the Common Council Member for Albany's First Ward. I live at 35 Clare Avenue, Albany, New York 12202.
I would like to first thank the New York State Department of Environmental Conservation for rescheduling this public hearing from November to December. The documents that are to be discussed at this hearing total more than 5,000 pages and the original thirty day notice for the public hearing allowed for an insufficient amount of time for interested parties to review this massive amount of information. I do not think 60 days is enough time either, but it obviously has to do.
I am opposed the any further expansion of the Rapp Road Landfill by the City of Albany. I have attached documents to this presentation that will explain further my opposition to the expansion. I will limit my remarks tonight to what I feel are the reasons the Fourth Supplemental Draft Environmental Impact Statement (SDEIS) is NOT complete.
First: On page 1-1 of the Executive Summary, it states that "...the City investigated a number of alternatives..." In my opinion, not all feasible alternatives to expanding the landfill were investigated. (A) I found no mention of investigating the feasibility of turning the landfill into a Resource Recovery Park, or of constructing a Resource Recovery Park in another location besides the Pine Bush. In researching Resource Recovery Parks I have found that many municipalities are now creating them or converting existing landfills to such resource recovery parks. These parks emphasize the reuse, recovery, and recycling of waste before burying or incinerating waste. These parks take organic waste almost totally out of the equation. The goal of these parks is zero waste. Many of these parks are already reducing landfill waste by up to 70%. I believe that the $42 million projected by the City as the cost for the expansion of the landfill would be better used in creating a Resource Recovery Park. Until this alternative is fully investigated, I don not feel that the SDEIS is complete.
(B) The alternative of transporting the City's waste was only given scant mention in the Executive Summary (p.1-16). Over the past few years, DEC has approved the expansion of many commercial landfills in the western part of the State. This increase in landfill capacity outside of the Albany area would be able to handle the waste generated by the City. The cost of exporting the City's waste to another landfill was estimated by the City to be $1,750,000 during the fiscal year 2007 (copy attached). This $1.7 million is a lot less than the 2007 cost for "landfill consumables" (supplies, fuel, utilities, etc.) and employee costs which combined in 2007 to equal $4,380,123. The exportation of the City's waste must be more fully studied and evaluated before summarily dismissing this alternative as not feasible.
Second. The excuse given by the City for the necessity of a fourth expansion of the original Greater Albany Landfill (GAL) - that excuse being found on page 1-3, and mentioned over and over again throughout the document - "...the expansion should provide the critical time necessary to address the future solid waste management needs of ANSWERS." I call this excuse the, "same old, same old" excuse for seeking another expansion of the landfill. How long is DEC going to let the City get away with doing nothing to find an alternative to the landfill in the ecologically sensitive Pine Bush? On page 1-7 of the Executive Summary it is acknowledged that "...since the early 1990's..." the City knew that it needed to find an alternative to destroying more of the rare in-land pine barrens located over a primary aquifer, and to find a long-term solution to using a landfill located in the Pine Bush. Yet, after more than fifteen years, the City has failed to meet its obligation to find a "long-term landfill solution." How long is this "critical time" supposed to last? Will it be another fifteen years, or twenty, or thirty? Until DEC steps in and says to the City that the Pine Bush will no longer be your dumping ground, the City will continue on its present course of taking the easiest way out - that is - asking DEC for the right to keep expanding the Greater Albany Landfill. The SDEIS, in my opinion, is not complete until a viable alternative to expanding the landfill is presented to DEC. The Coeymans site, according to the Fourth SDEIS (p.1-7), will take 10-20 years to be constructed and all mitigation requirements met. So, if the City was serious about using the Coeymans site, which was selected in the early 1990's, then the time period of 10-20 years would have been met by 2009. But, the City chose not to fully begin the process for the Coeymans site, and now 15 years later we are still talking about the 10-20 year period necessary for Coeymans to be used as the next landfill site by the City. Again, if DEC allows the City to keep expanding the present landfill, the City's history shows that it will continue to do little to find a viable alternative to the Pine Bush landfill. Until the Coeymans site is fully examined and the necessary processes begun for siting a landfill on that land, the SDEIS is incomplete.
Third. The Fourth SDEIS should not be considered complete until the DEC has in its hands the documents necessary for the City to meet its commitment as stated on page 1-6, "...to deed over all City-owned lands to the north and west of the landfill to the State or Nature Conservancy [to] ensure the end of any future landfill expansions..." Unless this commitment is in legal form, and all parties have signed on to the transfer of these lands, then the Fourth SDEIS is not complete. These documents must be made a part of the SDEIS so that in a few years from now, a fifth expansion of the original Greater Albany Landfill is not requested by the City with the oft-mentioned caveat, that this will be the LAST expansion of the landfill.
Fourth. There seems to be some contradictions in the SDEIS Executive Summary. On page 1-6 it is stated that the Eastern Expansion "...provides benefits that far exceed the minor (my emphasis) environmental costs of the project." But, on page1-8 it states, "As a result, the natural landscape and ecology of the site will be unavoidably eliminated. Additionally, the new landfill edge may lead to ecological impacts into Preserve lands through runoff, increased light penetration into forested areas, and blowing of trash." It further goes on to state, "Without proper treatment of the runoff from the landfill slopes, there can be physical and chemical modifications of the adjacent soils that promote less desirable species, including invasive species..."So, what are the environmental costs of the project - are they "minor" or is the natural landscape and ecology of the site going to be forever eliminated? This contradiction must be resolved before the SDEIS is considered complete.
Again, I urge the DEC not to approve the expansion of the expansion of the expansion of the original Greater Albany Landfill. The City has failed to meet its obligation of finding alternatives to operating a landfill in the environmentally and ecologically sensitive Pine Bush. The City has known about the need to find alternatives since the early 1990's, and has failed to do so. DEC must no longer be an "enabler" to the City's addiction to the garbage-for-profit business. The DEC must act like the strong parent and put its foot down and tell the City that enough is enough. The City has had more than fifteen years to develop alternatives to the landfill in the Pine Bush, but it has failed to take advantage of the numerous opportunities given to it by DEC through previous approvals of expansion requests, thus no further expansions should be approved by DEC.
Common Council Member - First Ward
City of Albany, New York