Having already voiced his opposition about the proposed trash incinerator project in the town of Romulus, Geneva Town Supervisor Mark Venuti recently wrote a letter to the State Citing Commission about deficiencies in the Public Involvement Program plan filed by Circular enerG, LLC. Venuti wrote that two key stakeholders were missing from the Plan’s stakeholders list.
Venuti also wrote about an environmental justice issue that does not conform to the standard requirements but he believes should be considered by the Commission.
A copy of Venuti’s letter to the Commission is available below:
Hon. Kathleen H. Burgess, Secretary NYS Board on Electric Generation Siting and the Environment Empire State Plaza, Agency Building 3 Albany, NY 12223
Re: Deficiencies in Public Involvement Program Plan filed by Circular enerG, LLC Case No. 18-F-0150
Dear Secretary Burgess:
I am writing to notify you and the Board of significant concerns about the Public Involvement Program Plan (PIP Plan) filed with the State Board on Electric Generation Siting and the Environment by Circular enerG, LLC on March 13, 2018.
The Town of Geneva opposes the trash incinerator project, as does the Seneca Watershed Intermunicipal Organization, which I chair. The resolutions in opposition of the Town Board and the Watershed Organization have previously been sent to you.
The Town of Geneva joins in and adopts the comments made by Earthjustice in its April 3, 2018 letter to you as if fully set forth in this letter.
In addition, I would like to add two key stakeholders missing from the PIP Plan stakeholder list and not named in the Earthjustice comments. These are the Finger Lakes Institute and the Geneva Area Chamber of Commerce. The City of Geneva, like the Town of Geneva, is on the west shore of Seneca Lake, across the lake from the proposed incinerator. Both are in Ontario County, adjacent to host Seneca County. Although the Town of Geneva is on the PIP Plan stakeholder list, for some reason the City of Geneva is not (although it has been named in the Earthjustice comments). Both municipalities are close to the site, likely in the view-shed of the smoke stack, and likely will have incinerator truck and train traffic running through and around them. Residents draw drinking water from Seneca Lake and make other uses of it. The Geneva area is a tourism and Finger Lakes wine country hub, surrounded by farms, with a tremendous stake in the quality of the land, air and water. The Finger Lakes Institute is located in the City of Geneva just above the west shore of Seneca Lake, and is a research facility dedicated to the health of the Finger Lakes. The interest of the Geneva Area Chamber of Commerce is obvious and no less than the Seneca County Chamber of Commerce that was included on the PIP Plan list. These two important stakeholders should be added to the PIP Plan stakeholder list; their contact information is on the annexed Exhibit A.
Hon. Kathleen H. Burgess, Secretary Page Two
Finally, I would like to raise an environmental justice issue that does not conform to the standard requirements but should be considered. The PIP Plan in the Project Summary makes claims, like burning trash is a State-preferred method of energy recovery, that will be debunked later when the merits of the project are discussed. It’s the claim that this trash incinerator will help the region move away from landfilling that I would like to briefly focus on. This incinerator is not being built to handle the trash generated in this area. The trash needed to feed the immense furnace will come from far and wide to be burned in the heart of the Finger Lakes region. The Town of Geneva and other area municipalities have solid waste management plans and projects, like food composting and fix-it clinics, that safely and beneficially reduce waste, and that is the way out of landfilling. This incinerator will work against the three Rs, reduce, reuse, recycle; it will provide another place to which people can export their waste and avoid responsibility for it. And here is the environmental justice issue: this area is already the largest destination of other people’s waste in the State of New York. We have the two largest landfills in the State within 15 miles of each other and the proposed incinerator site. A third large landfill is about 40 miles away. Our goal over the next ten years is to move, as the State says, “Beyond Waste,” and to stop being the host of other people’s waste. This incinerator is not the answer to the waste problem; it’s the enabler. It would be an unjust additional burden that would threaten our present livelihoods and the future of this area. I ask that you require the proponent to consider this aspect of the project: the inequity of bringing millions of tons of other people’s waste into a region that already hosts, to its detriment, many millions.
Mark Venuti Supervisor firstname.lastname@example.org
Copy to: John B. Rhodes, Chairman NYS Public Service Commission John.email@example.com
James Denn Public Information Officer James.firstname.lastname@example.org