Buffalo Niagara Riverkeeper is one of Western New York’s leading non-profit organizations regarding the protection and stewardship of the region’s fresh water resources. As such, our interest in this permit application and the larger subject of waste management practices is to ensure that the policy, process, science and community-based analyses used to evaluate the request are given careful and thoughtful attention in order to ensure that no adverse impact will occur to the community or environment now or in the future, as a result of the proposed activity. The existing facility and proposed expansion locations are located in the Niagara River watershed, approximately two miles from the Niagara River and three miles from Lake Ontario. The Niagara River is currently being addressed by the New York State Department of Environmental Conservation, the International Joint Commission, and US Environmental Protection Agency based on its designation as an “Area of Concern” which is due, in part, to contaminated bottom sediments. Lake Ontario provides drinking water to approximately 8 million people throughout the United States and Canada.
Riverkeeper submitted comments to the NYDEC Office of Hearings and Mediation Service to address the findings of three basic permit documents that will inform the Siting Board’s decision on CWM’s proposal for RMU-2. These documents include: the New York State Hazardous Waste Facility Siting Plan (Plan, 2010), the CWM Draft Environmental Impact Statement (DEIS), and the Facility Siting Criteria and CWM scoring anticipated for RMU-2. Based on our review of these documents and our knowledge of the project area, Riverkeeper concludes that the proposed RMU-2 facility is not consistent with the State Hazardous Waste Facility Siting Plan and therefore a permit should not be issued for its construction.