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Kimberly A. Merchant
Deputy Regional Permit Administrator
Division of Environmental Permits
New York State Department of Environmental Conservation, Region 8
6274 East Avon-Lima Road
Avon, New York 14414
E-mail: DEP.R8@dec.ny.gov , firstname.lastname@example.org
Re: Comments on the Proposed Renewal and Modification of the Lockwood Ash Disposal Landfill SPDES Permit, ID: NY-0107069 Application ID: 8-5736-00005/00001
Dear Ms. Merchant:
I am writing to request a legislative hearing on the proposed Lockwood SPDES permit because there is a significant degree of public interest in this permitting process and how it relates to other ongoing permitting and regulatory processes at the Lockwood Ash Disposal Landfill and the Greenidge Generating Station. A public hearing will aid DEC’s decision-making processes by providing a forum for the collection of public comment.
Multiple requests were made and ultimately denied by DEC for an extended public comment period since the time frame covered the holiday season when many were unable to review the permit application materials. Further, multiple requests were made for additional material, describing the basis for the Type II SEQRA determination announced on Dec 8. These documents were deemed essential in order for the public to make substantive comments but were not provided prior to the comment deadline.
I object to the proposed renewal and modification of the SPDES permit for the Lockwood Ash Disposal Landfill without the preparation of a full environmental impact statement evaluating the environmental impacts of the repurposing of the Greenidge Generating Station and its component landfill as a bitcoin mining operation.
The overall project of which the renewal of the Lockwood SPDES permit is a part is the repurposing of Greenidge Station for bitcoin mining operations. DEC has treated this project as a matter for negotiations between DEC and Greenidge Generation Holdings Inc only, without the inclusion of public participation.
DEC’s efforts to exclude the public from participation in the negotiations surrounding the repurposing project is contrary to the requirements of SEQRA which mandate public involvement in processes of giving regulatory approval to actions that may have an impact on the environment.
DEC seeks to exclude the Greenidge repurposing project from SEQRA review by treating each of the required permits for the project as separate processes and then characterizing these individual permitting processes as exempt from review under SEQRA. It is a clear violation of SEQRA not to consider these permit renewals together.
There are coal ash ponds on the Greendidge Generating Station site as well as the Lockwood site. Both SPDES permits have Mercury Minimization Plans that allow Greenidge and Lockwood to make mercury discharges of 50 ng/L, far in excess of the standard 0.7 ng/L mercury limits. 50 ug/L isn’t justified and the facility should meet the water quality standard of 0.7 ug/L. DEC has required 0.7 ug/L in SPDES permits for wastewater treatment permits lately and they should be required here. Links to the discharge variance and some research from the UK provide all of the different technologies that could be used to reduce mercury in wastewater discharges:
The coal ash discharges from Lockwood are into the Keuka Outlet, the coal ash discharges for Greenidge are into adjacent Seneca Lake. Both permits require groundwater monitoring. It is a clear violation of SEQRA not to consider these permit renewals together.
This use of segmentation on a grand scale is completely contrary to the requirements of SEQRA.
DEC must consider the cumulative impacts of the Greenidge toxic discharges, the Lockwood toxic discharges and the Ferro toxic discharges in evaluating the Lockwood permit renewals.
DEC has approved a dilution study workplan pursuant to the Greenidge SPDES permit that allows Greenidge and Ferro to mix their toxic discharges in an inland pond and discharge the mixed discharges into Seneca Lake.
It is a clear violation of SEQRA not to consider the cumulative impacts of the discharges from these three sources into Seneca Lake, its tributary Keuka Outlet and the connected groundwater aquifer in the Town of Torrey.
Because of the above points and objections, I request that a legislative hearing be scheduled on the proposed Lockwood SPDES permit and that the current permit application be rejected.
YOUR NAME AND TOWN HERE