PaDEP Grants Approval to NBMA for sludge application

On September 18, 2024 Nazareth Borough Municipal Authority (NBMA) was granted approval by the PaDEP to begin land application of their sewage sludge on some portions of the Hower Road farm property that they purchased in 2021.

Plainfield Township has filed a new Appeal against the PaDEP and NBMA; Save Plainfield Township Inc. has joined the appeal as an Intervener. You can get more details about the appeal by reading NOTICE of APPEAL below.

The Delaware Riverkeeper Network has also filed an Appeal against the PaDEP’s approval for sewage sludge to be applied on the NBMA property. The Delaware Riverkeepers Network has published the following Press Release:

Delaware Riverkeeper Network Appeals PADEP Approval for Sewage Sludge to be Land Applied - Nazareth Borough Municipal Authority Plans to Spread Biosolids in Plainfield Twp., Northampton County on the Hower Farm, Plainfield Twp., Northampton County

Delaware Riverkeeper Network (DRN) filed a Notice of Appeal with the Pennsylvania Environmental Hearing Board on October 25, 2024 challenging the PA Dept. of Environmental Protection’s (DEP) approval of the land application of sewage sludge (“biosolids”) by the Nazareth Borough Municipal Authority (NBMA), at the Hower Farm in Plainfield Township, Northampton County.

The Hower Farm is enrolled in the Commonwealth’s Farmland Preservation Program in 2008 and was purchased by the NBMA in 2021. NBMA’s plans to spread Class B Biosolids on the farm property has ignited opposition from the regional community and Plainfield Township. Plainfield Township filed its Notice of Appeal on October 17.

Delaware Riverkeeper Network maintains that the DEP’s approval is in violation of several federal and state environmental laws and Article 1, Section 27 of the Pennsylvania Constitution.

The farmland flows to the Little Bushkill Creek and Bushkill Creek, protected under Pennsylvania’s Special Protection Waters program, and their water quality is threatened by the biosolids land application. Also, at risk are the Exceptional Value Wetlands that are on and adjacent to the property and the headwaters stream that originates on the farm. The biosolids plan is inadequate and doesn’t correctly assess what will be spread on the site or how these substances will impact surface water, groundwater, and other public natural resources. Additionally, not all threatened and endangered plant and animal species have been properly identified and the application will

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adversely affect bog turtle habitat and likely individual bog turtles. In short, pollution and degradation will be caused by the approved biosolids land application.

The protection of our environmental rights is required under Article 1, Section 27 of the Pennsylvania Constitution (the Environmental Rights Amendment, or Green Amendment). However, both the DEP and NBMA failed to fulfill their duties as trustees of public natural resources in connection with the plan to land apply biosolids, sewage sludge and other wastes to the site. This is a major objection DRN has to the DEP’s approval.

Delaware Riverkeeper Network considers DEP’s approval of the application of sewage sludge on the Hower Farm to have got it all wrong. The approval lacks a correct or thorough assessment of how the toxic and hazardous substances in the biosolids will impact the environment, including water and ecosystems, and fails to protect the community. The Nazareth Municipal Authority has no right to ruin the environment just to fill their need to dispose of sewage. We stand with the community and local government to defend the regional watershed and waterways from pollution and degradation,” said Tracy Carluccio, Deputy Director, Delaware Riverkeeper Network.

"We believe that the DEP did not take into consideration the effects that biosolid/sludge land application will have on the surrounding area, nor did they hold a public meeting to hear from residents before giving their approval to the NBMA to spread their sludge. There is a natural waterway on the Hower Road farm that flows into neighboring yards, a pond, wetlands and the Little Bushkill Creek, which is a tributary to the Delaware River. The pollutants from the sludge will directly affect the neighbors with small children who live and play downstream from the farm, and rely on well water for their homes, and may adversely affect wildlife habitats. Nearby neighbors will be subjected to the extreme odor of sludge storage and application, impacting their quality of life. The odors will also threaten activities at the nearby ball fields, the annual Plainfield Farmer's Fair and the Plainfield Recreation Trail. We all have a right to clean water, clean air and an odor free environment, and the Hower Road farm is not the place to spread biosolid/sludge," said Alan Gumeny, representative of Save Plainfield Township, Inc.

The NBMA land sits above our farm. We get all the run off from their parcel and it goes into our pond and the Little Bushkill Creek. The runoff saturates our grass. Our land consists of wetlands and is a habitat sanctuary for so much wildlife. Unless you put the NBMA land into one big giant bubble, there are absolutely no guarantees that any of this will stay clean and free from any potential sludge damage…including our air,” said Rich and Meghan Uliana, Plainfield Twp., Northampton County.

In 2021 the Nazareth Borough Municipal Authority (sewer authority) started reviewing the 6249 Hower Rd property that is in Plainfield Township Northampton County for the purpose of a place to put their sewage sludge on. This property is not suited for what NBMA wants to do. It is sloped and by our homes, there are many issues as to why this is not a good place to spread/dump the sewer plant sludge that is from their wastewater treatment plant. The surrounding properties are at a disadvantage as we have wells and saying that the biosolids/sewage sludge is beneficial is a problem as the pathogen contaminants and many chemicals and heavy metals that would be in this effluent. Our farm is next to this property and my home is directly connected as well as

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several others. Many neighbors would be affected by this “project”, said Millie Beahn, Plainfield Township, Northampton County.

The approval for another permit necessary for NBMA to manage stormwater on Hower Farm has not yet been decided by DEP. The National Pollution Discharge Elimination Permit is required for the site’s erosion and sediment control planning and for the post-construction stormwater system that must be installed to control runoff. The comment period on the draft permit closed in December 2023. DEP found the application from NBMA to be technically deficient when submitted in December 2023 and required revisions.

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As of this date the NBMA has not applied their sludge to the Hower Road farm, however this approval allows them to start at any time. Please help us to continue to support opposition to land application of sludge in Plainfield Township by contributing to: Save Plainfield Township Inc., PO Box 44, Pen Argyl, PA 18072

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