Local Perspectives Opposing DEP Approvals Ignored By Media
DEP Has Been “Invisibilized”
We’ve been trying to expose the DEP role and regulatory authority in the warehouse sprawl issues for years now.
Those efforts have proven fruitless. The warehouse issue has been narrowly and falsely portrayed as a local “home rule” land use issue.
So instead of repeating all that, we thought we’d reprint a verbatim local official’s opposition to DEP’s approval of a proposed waster quality management plan amendment that would allow development of the huge proposed Jaindl warehouse in rural White Township, Warren County:
Program Interest No. 435437, Activity No. AMD210001
WQMP.publiccomments@dep.nj.gov
NJ Department of Environmental Protection
Division of Watershed Protection and Restoration
Bureau of NJPDES Stormwater Permitting and Water Quality Management
PO Box 420, Mail Code 501-02A
501 East State St.
Trenton, NJ 08625-0420Dear Mr. Mahon,
My name is XXXXXXX and I am concerned about where Jaindl wants to build these warehouses.
I am concerned about the potential negative impacts to the Delaware River and the Buckhorn Creek and area’s drinking water wells from the proposed groundwater sewage disposal system planned. These proposed warehouses are going to be built on top of very porous karst rock formations so, over time, that sewage could reach the river or well water supply. Stormwater runoff too, which typically has motor oil, antifreeze and heavy metals, could also reach the Delaware River or groundwater. There were photos shown at the DEP Public Hearing on August 5th showing underground streams flowing from under this property into the Delaware. And those photos were taken during a drought!
White Township, approximately 20 years ago, requested to remove all farmland in the township from the sewer service area to protect land from intense overdevelopment from industry and residential/commercial units. The DEP made a deal with the township allowing the sewer service to be removed from the majority of the township as long as sewer service was kept on the Route 46/water St corridor from Belvidere to Buttzville along the Pequest River. This goes against the agreed upon sewer service area between the township and DEP when the amended sewer map to remove most of the sewer service area was created. The entity who purchased this property and is applying for sewer knew at the time of purchase that there was no sewer service which would limit intense overdevelopment such as being proposed. Other industrial sites throughout White and Harmony township have been used such as leaf mulching operations, quarries, gravel pits, sludge processing which didn’t require sewer service. The township residents also knew this was not in the sewer service area, so intense overdevelopment like this wasn’t on the radar. This property also lies within the Warren County Agriculture Development Area (ADA) which encompasses productive agricultural lands that have a strong potential for future production in agriculture, is reasonably free of suburban and conflicting commercial development, has high class farm soils, and compatibility with comprehensive county and state plans. The county ADA is largely free of sewer service on farmland except for a few parcels that most likely had sewer service before the ADA was created. The state ADA guidelines recommends not having water and sewer systems in the ADA, and does not have proximity or accessibility to major highways and interchanges. The County ADA exempted large areas of Greenwich, Lopatcong, Pohatcong, and Alpha due to sewer service, the state plan wanting these areas to be development and the proximity to Route 78 interchanges. Allowing sewer service for intense uses in a remote parcel such as this goes against all state planning guidance. By allowing expansion of sewer service in the ADA, this creates a precedent whereby developers will continue to try to add more sewer service and high density development to the ADA areas. There are plenty of areas outside the ADA with sewer service that can be developed. An example in White Township is this, in October 2014, the Fratezi farm Block 51 Lot 4 was denied an addition to the County ADA to be eligible for farmland preservation because the State Agriculture Development Committee (SADC) because of the sewer service area that the parcel was in. This property is identified as part of the White Township Farmland Preservation plan as properties for future preservation. Regardless of zoning analysis, this property at one time was zoned Residential in either 1.5 acre or 3 acre building lots. Perhaps that zoning is a better fit than the industrial zone since massive sewer systems won’t be needed for low density residential development. Zoning can be changed at any time, as we see time and time again its changed in the developers favors for things like affordable housing. Over the last several decades the state has lost so much farmland there are very few towns in the outlying Northwestern and Southern counties that are completely rural. There is high density development and warehouses scattered everywhere with the pressure getting greater. The state is quickly running out of land to develop leaving behind any trace of rural areas to more high density housing and warehouses leading to even more pollution.
The state planning commission warehouse siting rules and recommendations states that in the NJ Highlands, large areas of prime farmland are at risk for warehousing. These guidelines recommend Highlands area warehouses be placed in areas that have sewer service areas, are close to highway access points, this site would take a 15 to 20 minute drive thru rural winding two lane roads to reach the highways. The recommendations also state that warehouses should not significantly affect or eliminate the region’s prime farmland or farmland soils.
Pumping 30,000 GPD of sewage will eventually reach the river through those same underground streams. Even if the levels of nutrient pollutants in that sewage are below state water quality standards like Jaindl said, it is still a new source of pollutants that should not be allowed to reach the river, the Buckhorn Creek or our wells. The river has Special Protection Waters status. How will new pollution impact the river? The Highlands Act and state Green Acres program has done extensive preservation and protection of the Buckhorn Creek. This sewer project has the potential to damage and destroy the Buckhorn Creek. There is an imaginary line dividing the Highlands Planning and Preservation area where the one side protects the Buckhorn Creek since we need to protect the water for drinking purposes down stream. That imaginary line also has the planning area where there is less restrictions. Perhaps the DEP needs to reevaluate the Highlands Act to further protect the water once these rivers and streams enter the planning area.
Approving this Sewer Service Area will put the drinking water supply at risk, especially when the Wellhead Protection Area expands from the increased well pumping (40,000 GPD) to meet the site’s water needs.
I kindly request NJDEP deny this permit and not allow sewer service expansion that goes against all sound planning and environmental regulations.
We’ll keep you posted, but expect another DEP rubber stamp approval.