Deadline is this Tuesday, Sept 13 at 5:00 pm to receive comments.
Comments may be sent by email to mailto:SolidWaste...@dec.ny.gov
or mailed to:
Melissa Treers, P.E.
New York State Department of Environmental Conservation
Division of Materials Management
625 Broadway
Albany, NY 12233-7260
Comment Letter
New
York’s Revised Solid Waste Regulations Must Prohibit Further
Acceptance of Fly Ash until an Adequate Environmental Review
Is Conducted
I respectfully
submit the following comment on DEC’s proposed revisions to the
solid waste
regulations and the draft generic environmental impact statement
(Draft GEIS)
accompanying those proposed changes.
I urge DEC to
prohibit the further acceptance in New York solid waste
landfills of fly ash
and the residue from air pollution control (APC) devices until
it has conducted
an adequate environmental review that addresses the risks
presented by
incineration and the management and disposal of incineration
wastes.
The review
conducted in the Draft GEIS is not adequate because it fails to:
1. identify
all areas of relevant environmental concern,
2. take a “hard look” at the environmental issues
identified, and 3.
present a reasoned elaboration for why the identified
environmental impacts
will not adversely affect the environment.
Burning trash emits
carbon dioxide into our atmosphere and creates dioxins, which
are among the
most dangerous known chemical compounds.
The EPA considers dioxin-bearing wastes to be “acutely
hazardous” and
therefore subject to stricter management standards than other
hazardous wastes.
The proposed
regulations continue to allow combustion of certain types of
solid waste
without any consideration in the Draft GEIS of alternative
methods of waste
disposal or of the health and environmental hazards of
incineration and
disposal of incineration wastes.
It is essential
that an adequate environmental review of the risks of
incineration and measures
for disposal of incineration wastes be conducted.
(19K)