Additional Comments Summary Response to Additional Comments

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RESPONSE SUMMARY REVISED DRAFT ORDER OF APPROVAL NO. 10052 Comment Period – September 13 – October 28, 2010 Summary Response to Additional Public Comments Received (NOC 10052) September 13 – October 28, 2010 The Agency has reviewed all the comments received in writing or offered orally at the public hearing. These comments are considered a part of the overall public record for the proposed NOC order of approval. In many ways, the comments received during this public comment period were similar to the comments that were received during the previous comment period. The Agency grouped the comments into recurring themes, and replied to the comments in a summary fashion. 1. Previous comment concerns are consistently raised The Agency identified nine general categories of comments during the original comment period (documented above) and the comments received during the latest comment period generally fall into those categories Those nine comment categories included: Odors from the facility are a persistent nuisance Odors are an embarrassment to residents during guest visits Odors from the facility negatively impact school operations Facility impacts have negative impact on property values Emissions from the facility are negatively impacting resident’s health Complaint record does not accurately reflect the level of impacts Odors have gotten worse in the last 2 years, especially during night, early morning, & weekends. Limit the operational level of Cedar Grove until they can perform Cedar Grove has no credibility in community, cannot police themselves Many of the same points were made during the original comment period and hearing, although many of the comments received were from community members who had not previously commented. Some of the comments received during this comment period exhibited stronger opinions. For example, there was a stronger sentiment for action that would shut operations on the site down. There were also comments regarding qualified support for composting objectives tempered by the impacts to the residents. There were more specific comments received this time regarding Cedar Grove’s evening operations and their contribution to impacts in the neighborhood. There were some suggestions that these evening activities was being done to avoid scrutiny. The Agency has no information to support the notion the evening work was being done to avoid scrutiny.
RESPONSE SUMMARY REVISED DRAFT ORDER OF APPROVAL NO. 10052 Comment Period – September 13 – October 28, 2010 2. General support and concerns with respect to the proposed order of approval conditions Comments received on the proposed revisions to the order of approval (in comparison to the original public comment proposal) were generally supportive, with some qualified reservations. Some commenters said that the revisions would be helpful to the community providing they are implemented and enforced. Others thought they would help, but expressed doubts that they would lead to enough emission performance improvements to resolve the impacts to the community. The Agency believes that the proposed revisions will support improved emission performance from Cedar Grove’s operations. 3. Confusion regarding this permit process, other agency activity outside of permitting, and the roles/responsibilities/authority of the various agencies that regulate Cedar Grove’s operations The Agency acknowledges the confusion that surrounds the various regulatory roles and actions regarding Cedar Grove’s operations. Despite that confusion, the Agency must continue to implement its program in accordance with the laws and rules that govern the facility. The Agency anticipates scheduling follow-up workshop meetings in the near future within the affected community to discuss the programs and actions of this Agency and answer questions. 4. General concern regarding the validity of technical work done by others and the independence that work will have Some commenters expressed a general concern about the validity of information collected or developed by the Agency, by Cedar Grove, or by contractors working for Cedar Grove. The Agency will be issuing a regulatory order which requires Cedar Grove to collect specified emission data through testing and will require the use of outside contractors who have the technical expertise and capacity to perform this work. That is a common practice for compliance testing requirements at other regulated sources. The key to collecting technically valid emission data starts with the original test order, the subsequent test planning, and observation and oversight of the testing work, and the complete documentation and review of the final report. The Agency will review and oversee the work specified in the regulatory order. One commenter said money for testing should be obtained through other sources rather than have Cedar Grove pay the testing contractor. The Agency disagrees with this comment. The need for this emission data is a result of Cedar Grove’s operations at this site and thus, Cedar Grove has an obligation to clearly identify the emissions from its facility. Others should not
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Additional Comments Summary Response to Additional Comments

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