Opinion
OPPOSITION TO NBMA BIO-SOLID LAND APPLICATION
About a year and ½ ago my husband and I began contacting our local leaders and government agencies to express our objections to the proposed Nazareth Borough Municipal Authority (NBMA) sludge/bio-solid waste dumping on the Hower Farm property. Their comments were almost always the same…we understand your concern and we feel for you but as long as the NBMA follows the DEP rules there is nothing we can do about it. So we started looking into the DEP/EPA rules and found there is a problem, the rules and regulations are outdated and no longer fit today’s society.
Let’s start with PFAS (polyfluoroalkyl substances), the forever chemicals. Science is proving they are causing problems everywhere. The EPA’s Toxic Release Inventory (TRI) Program currently has 787 chemicals listed on its TRI Chemical List, 172 of these are PFAS, 13 PFAS were added from reporting years 2022 & 2023 alone. However, the DEP does not require testing to check for these PFAS in the bio-solid waste that is being applied across the country.
PA DEP Title 25 – Municipal Waste Management – chapter 271 requires a setback of 300 feet from an occupied dwelling for the spreading of bio-solid waste. This setback may be suitable for a 300 acre farm that only has the farmer’s home on it but it is not realistic for an 80 acre farm that is surrounded by private homes with properties that abut the farm, as is the case with the preserved farm land NBMA bought in Plainfield Township. When people purchase a home they buy the dwelling and the property with the intention of living on all of it. As rural farm areas become more populated this 300 foot setback needs to be changed. The setbacks should start at the property line not the dwelling.
In 2002, during the public comment period for revisions to PAG08 (General Provisions for Beneficial Use of Bio-solids by Land Application) Trudy Johnston of Material Matters was part of the opposition to Odor Control Requirements. Among other things, they argued that the science of odor control was only in its early stages; this requirement would place an enormous additional obligation requiring training and experience on companies applying the waste; and that it was not necessary since only 3% of sites evoke complaints. The DEP rescinded this requirement in PAG08. That was 21 years ago and it has never been updated even though now excessive odor is one of the biggest complaints of bio-solid waste sites!
I am not a scientist but I am a mother who raised a child with a severe breathing disorder. Excessive odors cause people to gag, when a person gags they have trouble breathing, when a person with lung problems has trouble breathing they are in distress and they go the hospital. So yes, excessive odors can be hazardous to one’s health. This odor control requirement needs to be put back into PAG08 regardless of the industry’s concern for training expenses. Their obligation, and the DEP’s obligation, should be to the health and safety of the general public not their own pocketbook!
To me it seems that the DEP and the bio-solid waste industry in general, have been negligent in updating the regulations and guidelines for the spreading of bio-solids while they allow the usage to increase. The rules need to be updated and changed but until that is done the dumping of bio-solid waste can not be looked at with a one-size-fits-all solution. Each project needs to be looked at on an individual basis.
When you look at NBMA’s plan for dumping bio-solid waste on Hower farm there is only one obvious conclusion, the Hower Road property is not the right location for dumping bio-solid waste. This NBMA application needs to be denied.
Barbara Gumeny
