Public comment template for residents of Glens Falls who live in this census tract (36113070500) [disadvantaged]

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·     “My name is ___. I live in Glens Falls.”

 

Consider talking about your community’s preexisting Health Burdens, for example:

·     “My community is a state-designated disadvantaged community, which already experiences very high health burdens.”

·     “For example, our community is burdened with unusually high rates of an inflammatory lung disease known as COPD.”

·     “Our Census Tract’s average annual age-adjusted emergency department visits for COPD are higher than those in 97% of all Tracts in the state.”

·     “Members of our community also experience disproportionately high heart problems.”

·     “Our Census Tract’s average annual age-adjusted hospitalizations for heart attacks are also higher than those in 93% of all Tracts in the state.”

 

Consider talking about your community’s preexisting Pollution Burdens, for example:
·     “My community is also subject to disproportionately high pollution burdens.”

·     “The State’s Disadvantaged Communities map puts us in the 100th percentile for proximity to Regulated Management Sites.”

·     “In other words, our risk of experiencing a potential chemical accident is already way too high.”

 

Consider talking about why DEC should be decreasing pollution in Glens Falls, not licensing it:

·     “DEC should be working to reduce health burdens in my community by reducing the cumulative pollution we are exposed to.”

·     “Instead, the agency is unconscionably considering putting our health at further risk by allowing a corporation to further pollute our environment”

·     “Moreau is the wrong place to site this facility”

 

Consider talking about the air pollutants the application suggests will reach the community:

·     “Modeling in Saratoga Biochar’s Air Permit Application indicates that the Saratoga Biochar Facility will release numerous co-pollutants into our community.”

·     “For example, maps in the application show Naphthalene emissions reaching Glens Falls.”

·     “EPA says ‘exposure of humans to naphthalene by inhalation, ingestion, and dermal contact is associated with hemolytic anemia, damage to the liver, and neurological damage.’”

·     “Among other pollutant emissions, the maps indicate that PFOA and mercury will reach our community, which is particularly concerning as these substances accumulate in the environment over time.”
·     “EPA says ‘[c]hildren exposed to methylmercury while they are in the womb can have impacts to their cognitive thinking, memory, attention, language, fine motor skills, and visual spatial skills.’”

·     “Of PFOA, EPA says ‘Human studies have found associations between PFOA and/or PFOS exposure and several types of health effects including the harmful impacts to the liver, the immune system, the cardiovascular system, and human development (e.g., decreased birth weight), and increased cancer.’”

·     “The permit materials also lack sufficient air emissions testing procedures. Tests are far too infrequent.” (The DEC draft air permit requires testing once every 5 years.)

Consider talking about water pollution concerns :
·     “In addition to these air emissions, I am also concerned about the truck wash and processing wastewater that will be discharged into Glens Falls publicly owned sewage treatment plant.

·     “According to Saratoga Biochar, each production line would generate tens of thousands of gallons of wastewater daily.”

·     “The company’s permit applications provide no data on contaminants in this water, which would ultimately be discharged as effluent into the Hudson River.

·     “Also DEC’s draft permits ignore this serious source of environmental contamination”

·     “The company has said that it will not pretreat the wastewater before it is discharged. How do we know PFAS from the facility will not get into our wastewater treatment system?”

 

NOTE: [If you want to raise doubts about the usefulness of Biochar end-use product, see Appendix]

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Consider talking about your status as a resident of an environmental justice community:
·     “Why should we continue to deal with higher adverse health burdens than most New Yorkers?”

·     “Does DEC think our community is expendable?”

·     “My community is a state-designated disadvantaged community and I hope DEC will not contribute to our burdens by permitting this project.”

 

Consider talking about your right to a healthful environment:

·     “In addition, under Article 1 section 19 of the New York State Constitution, I have a right to clean air and water, and a healthful environment.”