No NCES expansion
To the Editor:
I attended the April hearing of NH Department of Environmental Services (DES) at Profile School on the NCES request to expand its landfill footprint in Bethlehem. The environmental reasons for denying expansion are so obvious and common sense that it's beyond belief why DES would approve the application. Unfortunately I feel that they will approve it.
If you think as I do that NCES expansion is ill-advised and should not be allowed, please voice your objection by sending your reasons to: SolidWasteInfo@ideas.nh.gov with NCES LF Stage V Application in the subject line. DES will receive public comment until May 20. My comments to DES are written here.
Approving NCES landfill expansion is not the proper balance between waste management and management of water resources.
The mission of NH DES includes several responsibilities. One is "to foster the proper management of municipal and industrial waste"; another is "to manage water resources for future generations". DES does a good job managing how waste facilities are constructed, but granting expansion is NOT a requirement of good management. If the permit is denied, NCES's profit opportunity will end sooner rather than later. If the permit is granted the Ammonoosuc River resource will be threatened for long enough to be considered "forever."
There will be no remedy for the absolutely certain seepage that will eventually occur.
Once the "fail safe" barriers are installed and the area filled with solid waste, there will be no way to remedy the absolutely certain seepage that will eventually occur. As NCES observed, barriers eventually leak. The potential to contaminate the River will last "forever."
DES should not continue to permit expansion based on faulty precedent.
Many mistakes have been made along the way. The first was the long-ago region-wide practice of situating dumps in undesirable land close to rivers, as was done in this case. Errors should not be compounded with additional mistakes -- such as allowing the landfill to expand into an area already too close to the Ammonoosuc River. It is time to stop now.
Allowing this ill-advised expansion is in conflict with RSA 483.
RSA 483 in 1988 established the Rivers Management and Protection Program (RMPP), managed by DES "to protect the State's significant river resources for the benefit of present and future generations". The Ammonoosuc River is one of the state's 18 protected rivers. RSA 483 also established the Rivers Management Advisory Committee (RMAC) "to represent a wide range of river interests" and to work closely with DES in an advisory capacity. NCES expansion is NOT in the Ammonoosuc River's interest.
When will Protection begin and Accommodation end?
If this expansion is allowed, how soon should we expect a NCES request for a height increase of this expansion, similar to its recent (granted) request for the adjacent area? A higher mound will put yet more strain on the underlying "impervious" barrier which will have to remain intact for even more years while the contaminants dissipate. It is worth noting that because man-made mountains are inherently unstable, and because changing weather patterns mean the Northeast will experience more intense rainstorms, the risk of erosion and slippage of these oversized mountains of trash towards the river is a likely danger.
It is time to stop now.
There are waste disposal alternatives. They are not without greater transportation costs which will impact several New Hampshire towns, and the alternatives do not benefit NCES, but alternatives exist. In a few years the Trudeau Road location will fill up, and the NCES operation will end. It makes little sense to increase the potential for significant harm by prolonging the life of the landfill. It makes sense to limit it now.
It makes sense to deny the Expansion.