A Terrible Idea for an Inappropriate Site
A Terrible Idea for an Inappropriate Site
Acuity Corporation, headquartered in Massachusetts, has been trying for more than five years to locate a Construction and Demolition Site in Claremont, New Hampshire. Encountering obstacles at both the State and local levels, they are now trying again, this time by obtaining from the NH Department of Environmental Services (NH DES) a modification to a 1987 facility permit held by a subsidiary. They have submitted an application for the modification to NH DES., and they envision using this permit as part of a stratagem to avoid the need for local approvals altogether.
Their proposal is vehemently opposed by residents throughout the area, as demonstrated by their presence in large numbers at previous hearings and their signatures on a current petition. Their application reveals serious, unaddressed issues in at least five areas (aside from legal questions), which are described at greater length in the latter sections of this document. Here is a summary of the five areas.
Any C&D site should be located far from a city center and residential area. Instead, the proposed site for this facility is within the residential confines of Claremont, accessible only via residential streets and located within a short distance of a school and homes.
The waste volumes proposed for the site would require as many as 70 truckloads traversing the city’s streets daily, which equals as many as 140 trips of at least two miles each within the City. The impact on local roads and the pollution from exhaust and dust on children make the site completely inappropriate for receiving up to 500 tons of solid waste per day.
Attributes of the proposed site make it completely inadequate for a C&D facility. The site is one acre in size, which after setbacks will leave approximately one half acre for operations. For comparison, a properly-cited C&D facility in Epping NH operates on roughly 40 acres of a 75 acre site.
The small lot size will not allow the sorting and separation required to process recyclables. This may be why the application includes a commitment to only accomplish as much recycling “as practical”, and why a second lot, located across the street, is included in their operating plan The proposed use of two sites raises issues on the appropriateness of a permit for one site that will include two sites, non-adjacent in its operation, and the use of a public street for continuous traffic of loaded trucks between the sites on a public byway.
The site is also adjacent to (and perhaps atop of) one of four named and mapped aquifers in Claremont. The contamination of an aquifer cannot, for all practical purposes, be remediated within a human lifetime.
The use of a Modification to an existing, two-page permit from 1987 to allow a change in use of this magnitude demands a detailed plan that accounts for all aspects of the envisioned operation.
Instead, the operating plan that accompanies the application is missing critical information. For example: There is no detail provided on how sorting and storage of recycling will be carried out and transferred from the site. There are no specifications of the exact types and destination for recycled materials. There is no plan for dust management aside from the use of water when necessary and no plan for capturing, storing and treatment of leachate, which is all the more glaring given the planned use of water to control dust.
The processing of C&D at this site will produce significant amounts of myriad pollutants and toxic materials. These include:
Particulate Matter and Diesel Exhaust. Supposedly, the trucks carrying C&D loads to the site will be covered. Whether enforced or not, trucks will nonetheless be followed by dust plumes and exhaust clouds as they traverse local roads, passing schools and homes.
Runoff. Storing waste materials on any site produces leachate and, as noted above, the operating plan includes no specific design for catchments, storing or processing of liquids included inadvertently in loads or produced by precipitation, fire suppression or drenching of materials to control dust.
Asbestos, Lead and Mercury. The operating plan describes an idealistic environment in which loads including asbestos will be rebuffed upon arrival , following visual inspection. However, asbestos is often included WITHIN materials and is not visible, or may be underneath tons of other debris, making it undetectable. The reality is that where C&D debris is collected, there will be asbestos, lead and mercury.
PFAS. Claremont is the recipient of a sizable federal grant for remediating and developing one brown-field site already. PFAS have been used in industry and consumer products for decades and are in countless building products: protective coatings for roofs, flashing, floor materials including carpeting, insulation, textiles, plastics and firefighting foam. With PFAS regulation at the federal and state levels changing rapidly, the risk for cleanup costs related to PFAS increased tremendously on April 19, 2024, when the U.S. EPA finalized a rule listing PFOS as “hazardous substances” under the Superfund law.
The Sugar River region of the Upper Valley is in the process of changing its image from empty mills, heavy industry and a destination for waste to one of outdoor recreation, natural beauty and local food production. The addition of a new C&D site in the area will be a dramatic setback to this work.
As part of the efforts to rebrand the region, the residents of Sullivan County made a huge effort to close an incinerator in Claremont and Claremont itself has invested in redevelopment of its downtown area. The Claremont Grower’s Collaborative has established itself as a vibrant group of young farmers redeveloping the rich farmland in the area. Meanwhile, Discover Sugar River Region, a destination management organization (DMO), has been promoting and nurturing Sullivan County as a tourist destination since 2022. The addition of a large, new waste facility will have brand and reputational impacts that will stretch decades into the future.
Citizens of the Sugar River region have spoken clearly through their active opposition to the proposed C&D site. The only benefit to the area cited in Acuity’s application is the availability of recycling, which the company only commits to do to the degree “practical”, while the negative impacts are extensive, serious and in some cases permanent. Similarly, the application claims alignment with the DES Hierarchy for waste management because it will reduce landfill waste through the same uncommitted level of recycling. The application does not address the importation of waste from outside of New Hampshire, a crisis Acuity’s proposed business would only exacerbate.
As noted above, Acuity’s application, and their plan of operation, reveal a sleight-of-hand tactic to allow a major solid waste facility to appear, uninvited and unwanted by the region in which it will be located and at a location and on a site that cannot safely accommodate the processing of 500 tons of C&D waste per day.