Home > Uncategorized > US Army Corps of Engineers Proposes Draft Dredging Permit for Controversial BL England Plant

US Army Corps of Engineers Proposes Draft Dredging Permit for Controversial BL England Plant

Public Comment Period Closes Tomorrow

Many thanks to Fred Akers for the heads up on this and my bad for not getting word out and preparing comments.

For those interested, here is the Army Corps public notice.

Here is my letter requesting a 60 day extension of the public comment period and a public hearing.

It might be interesting to see how the Corps responds to the issues I raise about compliance with the Obama Executive Order on climate change adaptation.

[*Apologies for failure to mention that Sierra Club (& I think Delaware Riverkeeper) have filed a lawsuit on DEP’s Clean Water Act Section 305(b)permit for failure to require installation of cooling towers.]

January 13, 2015

Dear Mr. Deems:

Please accept my comments below on USACE public notice CNAP-OP-R-2014-1110-83 for a draft 404 permit for the B.L. England power plant in Beesley’s Point NJ, see:

http://www.nap.usace.army.mil/Missions/Regulatory/PublicNotices.aspx

I request that the USACE hold a public hearing on this draft permit and extend the comment period by 60 days.

A public hearing and comment period extension are warranted for the following reasons:

1) There is enormous local, regional, statewide, and national public interest in the operation of this plant and its adverse impacts on natural resources, the Great Egg ecosystem, local air quality, climate change, and the nearby Pinelands National Reserve. Thousands of people have participated directly in the debate over the continued operation of this plant.

Most recently, the continued operation of the plant was brought into doubt when the NJ Pinelands Commission rejected a proposed Memorandum of Agreement with the NJ Board of Public Utilities to allow a 22 mile South Jersey Gas natural gas pipeline through the Pinelands. The pipeline was designed to serve as the fuel source for a planned re-powering of the plant.

The plant has been under a NJ Department of Environmental Protection enforcement Order to either shut down operations or re-power and install new pollution controls to comply with applicable emissions standards. We understand that the NJ DEP recently extended the shut down or re-powering deadlines of this Order for 2 years.

The rejection by the Pinelands Commission of that proposed pipeline means the BL England plant lacks a long term source of fuel.

There is a distinct possibility that the plant may shut down or be unable to obtain financing to re-power, or other necessary regulatory approvals to re-power.

During the consideration of the pipeline by the Pinelands Commission, hundreds of citizens attended public hearings, signed petitions, and/or filed oral or written comments in opposition to the pipeline and the continued operation of the plant.

This enormous public interest in the continued operation of the BL England plant and its impacts on the environment alone justifies a public hearing on this draft permit, particularly as the draft permit is intended to allow continued operation of the plant

2) the plant has adverse local, regional, and global impacts. Some of these impacts include slaughter of aquatic life in Great Egg Bay; emissions of criteria air pollutants which harm public health and nearby Pinelands forests and vegetation; and emissions of greenhouse gases that contribute to global warming.

3) the plant is located in a coastal hazard zone and is vulnerable to climate change driven sea level rise and storm surge. The issue of coastal vulnerability and all forms of energy and critical infrastructure is a hugely controversial and significant issue to the people of NJ.

On November 1, 2013, President Obama issued an Executive Order on climate change adaption that calls for enhanced public involvement. See:

http://www.whitehouse.gov/the-press-office/2013/11/01/executive-order-preparing-united-states-impacts-climate-change

Section 1. Policy. The impacts of climate change — including an increase in prolonged periods of excessively high temperatures, more heavy downpours, an increase in wildfires, more severe droughts, permafrost thawing, ocean acidification, and sea-level rise — are already affecting communities, natural resources, ecosystems, economies, and public health across the Nation. These impacts are often most significant for communities that already face economic or health-related challenges, and for species and habitats that are already facing other pressures. Managing these risks requires deliberate preparation, close cooperation, and coordinated planning by the Federal Government, as well as by stakeholders, to facilitate Federal, State, local, tribal, private-sector, and nonprofit-sector efforts to improve climate preparedness and resilience; help safeguard our economy, infrastructure, environment, and natural resources; and provide for the continuity of executive department and agency (agency) operations, services, and programs.

A foundation for coordinated action on climate change preparedness and resilience across the Federal Government was established by Executive Order 13514 of October 5, 2009 (Federal Leadership in Environmental, Energy, and Economic Performance), and the Interagency Climate Change Adaptation Task Force led by the Council on Environmental Quality (CEQ), the Office of Science and Technology Policy (OSTP), and the National Oceanic and Atmospheric Administration (NOAA). In addition, through the U.S. Global Change Research Program (USGCRP), established by section 103 of the Global Change Research Act of 1990 (15 U.S.C. 2933), and agency programs and activities, the Federal Government will continue to support scientific research, observational capabilities, and assessments necessary to improve our understanding of and response to climate change and its impacts on the Nation.

The Federal Government must build on recent progress and pursue new strategies to improve the Nation’s preparedness and resilience. In doing so, agencies should promote: (1) engaged and strong partnerships and information sharing at all levels of government; (2) risk-informed decisionmaking and the tools to facilitate it; (3) adaptive learning, in which experiences serve as opportunities to inform and adjust future actions; and (4) preparedness planning. (emphasis mine)

The State Board of Public Utilities and the NJ DEP are involved in major policy initiatives on energy resilience and coastal and infrastructure adaptation policy.

A public hearing would provide an opportunity for the public to learn about and participate in coastal hazard and climate vulnerability/adatpation issues.

4) Because I just recently learned of this draft permit and the comment deadline expires tomorrow, a public hearing and an extension of the comment period would provide necessary time to prepare adequate written technical comments.

5) There are significant cumulative impacts from this plant that require public  scrutiny. The plant impacts fish, wildlife, water resources, natural resources, air quality, Pinelands forests and vegetation, and global climate.

As I was, it is highly likely that the interested public is not aware of the issuance of this draft permit and will not be able to meaningfully participate in the permit process if the comment period is not extended and a public hearing opportunity provided.

To deny the public meaningful opportunity to participate in this significant set of issues would contradict President Obama’s Executive Order on adaptation to climate change and sound agency decision-making.

6) We believe that the public interest would be best served by a shutdown of the plant.

As such, we believe that the USACE should deny the permit as a means of promoting and protecting the public interest.

I appreciate your timely and favorable request to extend the comment period by 60 days and hold a public hearing,

Respectfully,

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  384. June 17th, 2015 at 19:27 | #384
  385. June 17th, 2015 at 21:31 | #385
  386. June 18th, 2015 at 03:07 | #386
  387. June 18th, 2015 at 04:35 | #387
  388. June 18th, 2015 at 06:53 | #388
  389. June 18th, 2015 at 07:38 | #389
  390. June 18th, 2015 at 13:31 | #390
  391. June 18th, 2015 at 18:06 | #391
  392. June 18th, 2015 at 21:27 | #392
  393. June 18th, 2015 at 22:32 | #393
  394. June 19th, 2015 at 04:43 | #394
  395. June 19th, 2015 at 07:19 | #395
  396. June 19th, 2015 at 08:18 | #396
  397. June 19th, 2015 at 09:56 | #397
  398. June 19th, 2015 at 10:04 | #398
  399. June 19th, 2015 at 11:54 | #399
  400. June 19th, 2015 at 15:37 | #400
  401. June 19th, 2015 at 17:08 | #401
  402. June 19th, 2015 at 17:55 | #402
  403. June 20th, 2015 at 01:17 | #403
  404. June 20th, 2015 at 01:27 | #404
  405. June 20th, 2015 at 03:21 | #405
  406. June 20th, 2015 at 09:55 | #406
  407. June 20th, 2015 at 10:24 | #407
  408. June 20th, 2015 at 16:25 | #408
  409. June 20th, 2015 at 18:38 | #409
  410. June 20th, 2015 at 21:24 | #410
  411. June 20th, 2015 at 22:05 | #411
  412. June 21st, 2015 at 00:38 | #412
  413. June 21st, 2015 at 01:26 | #413
  414. June 21st, 2015 at 08:52 | #414
  415. June 21st, 2015 at 10:33 | #415
  416. June 21st, 2015 at 11:12 | #416
  417. June 21st, 2015 at 11:40 | #417
  418. June 21st, 2015 at 13:13 | #418
  419. June 21st, 2015 at 13:58 | #419
  420. June 21st, 2015 at 21:35 | #420
  421. June 21st, 2015 at 22:55 | #421
  422. June 22nd, 2015 at 09:17 | #422
  423. June 22nd, 2015 at 09:38 | #423
  424. June 22nd, 2015 at 10:38 | #424
  425. June 22nd, 2015 at 14:57 | #425
  426. June 22nd, 2015 at 19:42 | #426
  427. June 22nd, 2015 at 20:00 | #427
  428. June 22nd, 2015 at 22:37 | #428
  429. June 23rd, 2015 at 01:40 | #429
  430. June 23rd, 2015 at 04:48 | #430
  431. June 23rd, 2015 at 08:11 | #431
  432. June 23rd, 2015 at 14:11 | #432
  433. June 23rd, 2015 at 16:02 | #433
  434. June 23rd, 2015 at 19:20 | #434
  435. June 23rd, 2015 at 20:23 | #435
  436. June 24th, 2015 at 06:55 | #436
  437. June 24th, 2015 at 15:04 | #437
  438. June 24th, 2015 at 19:17 | #438
  439. June 24th, 2015 at 22:39 | #439
  440. June 24th, 2015 at 23:18 | #440
  441. June 25th, 2015 at 03:53 | #441
  442. June 25th, 2015 at 07:47 | #442
  443. June 25th, 2015 at 09:31 | #443
  444. June 25th, 2015 at 16:58 | #444
  445. June 25th, 2015 at 19:31 | #445
  446. June 25th, 2015 at 19:51 | #446
  447. June 25th, 2015 at 21:20 | #447
  448. June 25th, 2015 at 21:50 | #448
  449. June 25th, 2015 at 23:08 | #449
  450. June 25th, 2015 at 23:30 | #450
  451. June 25th, 2015 at 23:39 | #451
  452. June 26th, 2015 at 02:08 | #452
  453. June 26th, 2015 at 13:53 | #453
  454. June 27th, 2015 at 01:10 | #454
  455. June 27th, 2015 at 01:13 | #455
  456. June 27th, 2015 at 05:06 | #456
  457. June 27th, 2015 at 06:16 | #457
  458. June 27th, 2015 at 12:12 | #458
  459. June 27th, 2015 at 12:33 | #459
  460. June 28th, 2015 at 01:07 | #460
  461. June 28th, 2015 at 08:37 | #461
  462. June 28th, 2015 at 09:00 | #462
  463. June 28th, 2015 at 09:36 | #463
  464. June 28th, 2015 at 15:45 | #464
  465. June 29th, 2015 at 00:14 | #465
  466. June 29th, 2015 at 01:28 | #466
  467. June 29th, 2015 at 05:07 | #467
  468. June 30th, 2015 at 13:05 | #468
  469. July 1st, 2015 at 04:40 | #469
  470. July 2nd, 2015 at 09:26 | #470
  471. July 2nd, 2015 at 09:39 | #471
  472. July 3rd, 2015 at 04:02 | #472
  473. July 3rd, 2015 at 09:44 | #473
  474. July 3rd, 2015 at 16:25 | #474
  475. July 3rd, 2015 at 16:31 | #475
  476. July 3rd, 2015 at 21:40 | #476
  477. July 4th, 2015 at 00:51 | #477
  478. July 4th, 2015 at 01:23 | #478
  479. July 4th, 2015 at 01:38 | #479
  480. July 4th, 2015 at 02:47 | #480
  481. July 4th, 2015 at 04:39 | #481
  482. July 4th, 2015 at 14:38 | #482
  483. July 4th, 2015 at 15:54 | #483
  484. July 4th, 2015 at 16:30 | #484
  485. July 4th, 2015 at 18:03 | #485
  486. July 4th, 2015 at 23:55 | #486
  487. July 5th, 2015 at 00:00 | #487
  488. July 5th, 2015 at 11:56 | #488
  489. July 5th, 2015 at 13:47 | #489
  490. July 6th, 2015 at 12:11 | #490
  491. July 6th, 2015 at 12:28 | #491
  492. July 6th, 2015 at 13:26 | #492
  493. July 6th, 2015 at 16:27 | #493
  494. July 6th, 2015 at 21:31 | #494
  495. July 7th, 2015 at 00:56 | #495
  496. July 7th, 2015 at 05:49 | #496
  497. July 7th, 2015 at 11:47 | #497
  498. July 7th, 2015 at 13:50 | #498
  499. July 7th, 2015 at 13:50 | #499
  500. July 7th, 2015 at 13:50 | #500
  501. July 7th, 2015 at 13:51 | #501
  502. July 7th, 2015 at 13:52 | #502
  503. July 7th, 2015 at 13:52 | #503
  504. July 7th, 2015 at 16:36 | #504
  505. July 7th, 2015 at 22:01 | #505
  506. July 7th, 2015 at 23:47 | #506
  507. July 8th, 2015 at 01:47 | #507
  508. July 8th, 2015 at 02:45 | #508
  509. July 8th, 2015 at 05:45 | #509
  510. July 8th, 2015 at 05:49 | #510
  511. July 8th, 2015 at 06:17 | #511
  512. July 8th, 2015 at 09:42 | #512
  513. July 8th, 2015 at 10:14 | #513
  514. July 8th, 2015 at 11:46 | #514
  515. July 8th, 2015 at 13:46 | #515
  516. July 8th, 2015 at 14:05 | #516
  517. July 8th, 2015 at 14:07 | #517
  518. July 8th, 2015 at 14:16 | #518
  519. July 8th, 2015 at 15:10 | #519
  520. July 8th, 2015 at 16:16 | #520
  521. July 8th, 2015 at 17:21 | #521
  522. July 8th, 2015 at 20:39 | #522
  523. July 8th, 2015 at 21:26 | #523
  524. July 8th, 2015 at 22:03 | #524
  525. July 9th, 2015 at 05:07 | #525
  526. July 9th, 2015 at 05:36 | #526
  527. July 9th, 2015 at 05:47 | #527
  528. July 9th, 2015 at 05:47 | #528
  529. July 9th, 2015 at 10:21 | #529
  530. July 9th, 2015 at 11:52 | #530
  531. July 9th, 2015 at 14:06 | #531
  532. July 9th, 2015 at 14:34 | #532
  533. July 9th, 2015 at 15:09 | #533
  534. July 9th, 2015 at 17:27 | #534
  535. July 9th, 2015 at 18:22 | #535
  536. July 9th, 2015 at 19:11 | #536
  537. July 9th, 2015 at 19:31 | #537
  538. July 9th, 2015 at 23:40 | #538
  539. July 9th, 2015 at 23:50 | #539
  540. July 10th, 2015 at 00:10 | #540
  541. July 10th, 2015 at 01:35 | #541
  542. July 10th, 2015 at 05:01 | #542
  543. July 10th, 2015 at 05:29 | #543
  544. July 10th, 2015 at 08:54 | #544
  545. July 10th, 2015 at 09:23 | #545
  546. July 10th, 2015 at 11:11 | #546
  547. July 10th, 2015 at 13:05 | #547
  548. July 10th, 2015 at 13:19 | #548
  549. July 10th, 2015 at 13:57 | #549
  550. July 10th, 2015 at 14:43 | #550
  551. July 10th, 2015 at 14:54 | #551
  552. July 10th, 2015 at 15:36 | #552
  553. July 10th, 2015 at 16:20 | #553
  554. July 10th, 2015 at 17:34 | #554
  555. July 10th, 2015 at 17:53 | #555
  556. July 10th, 2015 at 17:53 | #556
  557. July 10th, 2015 at 17:53 | #557
  558. July 10th, 2015 at 19:18 | #558
  559. July 10th, 2015 at 19:45 | #559
  560. July 10th, 2015 at 22:48 | #560
  561. July 11th, 2015 at 00:04 | #561
  562. July 11th, 2015 at 02:08 | #562
  563. July 11th, 2015 at 09:38 | #563
  564. July 11th, 2015 at 11:21 | #564
  565. July 11th, 2015 at 14:57 | #565
  566. July 11th, 2015 at 15:28 | #566
  567. July 11th, 2015 at 16:34 | #567
  568. July 11th, 2015 at 16:55 | #568
  569. July 11th, 2015 at 18:05 | #569
  570. July 11th, 2015 at 18:43 | #570
  571. July 11th, 2015 at 19:58 | #571
  572. July 12th, 2015 at 00:23 | #572
  573. July 12th, 2015 at 00:41 | #573
  574. July 12th, 2015 at 04:06 | #574
  575. July 12th, 2015 at 04:37 | #575
  576. July 12th, 2015 at 07:23 | #576
  577. July 12th, 2015 at 07:51 | #577
  578. July 12th, 2015 at 13:48 | #578
  579. July 12th, 2015 at 14:27 | #579
  580. July 12th, 2015 at 15:43 | #580
  581. July 12th, 2015 at 16:08 | #581
  582. July 12th, 2015 at 16:15 | #582
  583. July 12th, 2015 at 17:08 | #583
  584. July 12th, 2015 at 17:08 | #584
  585. July 12th, 2015 at 17:33 | #585
  586. July 12th, 2015 at 19:25 | #586
  587. July 12th, 2015 at 19:36 | #587
  588. July 12th, 2015 at 20:01 | #588
  589. July 12th, 2015 at 21:28 | #589
  590. July 12th, 2015 at 23:52 | #590
  591. July 13th, 2015 at 02:47 | #591
  592. July 13th, 2015 at 03:55 | #592
  593. July 13th, 2015 at 06:04 | #593
  594. July 13th, 2015 at 06:25 | #594
  595. July 13th, 2015 at 08:45 | #595
  596. July 13th, 2015 at 10:10 | #596
  597. July 13th, 2015 at 11:27 | #597
  598. July 13th, 2015 at 11:44 | #598
  599. July 13th, 2015 at 13:15 | #599
  600. July 13th, 2015 at 13:46 | #600
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