Bring You Up to Speed
To the Editor:
For those of you who have not been keeping track, please allow me to bring you up to speed on the latest in the landfill development project fiasco next to Forest Lake State Park in Dalton and Bethlehem. As you know, Casella submitted a wetlands permit application in September, 2020, seeking approval from the New Hampshire Department of Environmental Services (NHDES) to permanently impact (destroy) over 17 acres of high-value, high-functioning wetlands that feed into the Alder Brook Wetlands Complex, which feed into the Ammonoosuc River. Over the course of the past year, NHDES has made two requests for more information, reviewed the application, deemed it administratively complete, held a public hearing on July 14, and even extended the public commenting period to September 13, 2021. Per RSA 482-A:3 XIV(a)(5), the department was to either approve or deny the application within 45 days of the closure of the commenting period, thus a decision would have been due on or about October 28, 2021. However, that is now NOT going to happen, as stated by NHDES in an August 26, 2021 letter to Casella. NHDES has moved the goal posts on us, as they are now requesting an “amended” permit application from Casella, covering only Phase I, and they are NOT going to issue a decision on the wetlands permit application currently on file which details Phases I-III. The apparent goal of the amended application request from NHDES is to limit the scope of the wetlands destruction on paper, in essence segmenting the project in such a way that minimizes the true, overall wetlands destruction of the full buildout of the “proposed” 180-acre landfill development. (Proposed, because despite what Casella is telling NHDES, we know there will be even more expansions in the future, as 1889 acres of land are under contract.
In fact, Rene Pelletier of the NHDES Water Division was recently quoted in the Caledonian-Record that Casella had been forewarned that “an amended application would be requested by DES because the department was not going to approve what the company deemed to be all three phases”. Thus, NHDES is colluding with an obviously inept applicant, whose February 2021 solid waste permit application was deemed “incomplete” by NHDES on June 1, 2021, thereby circumventing the law in order to help them save face. This is an outrageous and unacceptable development, as the public has invested much time, effort, and money throughout the permitting process, only to be denied a decision by NHDES, and in violation of RSA 482-A:3 XIV(a)(5).
The continued incompetence of Casella Waste Systems has shone thru in yet another newsworthy week of surprising developments. Casella has proven throughout the permitting process that they simply do not have the engineering expertise and ability to build a NEW landfill, particularly at this site, as evidenced by the August 26th letter from NHDES to Casella. In that letter, NHDES informed Casella that since their wetlands permit application was so inconsistent and out of sync with their solid waste and air permit applications, an “amended” application was required in order for the NHDES Wetlands Bureau to NOT issue a DENIAL of their permit. The proper action would have been for NHDES to ultimately deny the wetlands permit application, which would ultimately lead to the same outcome, albeit a “new” versus “amended” wetlands permit application submittal. Regardless, the optics are not good as public trust in the objectivity of NHDES fades and the abilities of Casella continue to be questioned.
Finally, if Casella’s engineers can’t even get their application paperwork right, imagine what else they can’t get right in the real world. Just this year, their NCES landfill in Bethlehem was hit with a serious permit violation in July, for landfilling over 24,000 TONS of garbage OUTSIDE of the permitted landfill space, AND, there was a 154,000 gallon leachate spill from May 1-3, completely undetected by them for nearly 2 days! Some operator! Yet they expect us to believe the can safely build and operate an unneeded and unwanted “state of the art” landfill in such an environmentally-sensitive area, only 2800 feet from Forest Lake, surrounded by wetlands that ultimately drain into the Ammonoosuc River, upstream of Littleton? “Can’t Happen”, to quote Casella’s engineer Joe John Gay, despite the best efforts of NHDES to collude with and cover for them. Now we play the waiting game, to see what Casella resubmits to NHDES for both its wetlands and solid waste permit applications. Regardless, knowing what we now know of their “proposed” plans, things really are not looking very promising for Casella in Dalton and Bethlehem. Perhaps it’s time for them to consider a Plan B, and seek out a more suitable site, preferably down south or in Massachusetts, as their dream of turning the North Country into the trash receptacle for New England is well on its way to being dashed.
Dalton, N. H.