PLEASE SEND COMMENTS TO USDA to Help Stop Saratoga Biochar Solutions, LLC from getting a $20.5 million grant for its project. (The deadline for comments is July 19, 2024)

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Saratoga Biochar submitted an Environmental Assessment to USDA (prepared by its consultant) and applied for a $20.5 million grant from the USDA Fertilizer Production Expansion Program. USDA has determined that the proposed Saratoga Biochar project in the Town of Moreau will have no significant environmental impacts. We were alerted to this and the public comment period on Friday, June 21 by a legal notice that appeared in the Albany Times Union.

 

To read our more complete summary of the Environmental Assessment, go to https://docs.google.com/document/d/13hKMR9_Ag-K4iFnJpwzJdjqCmk0dk0-DoHKpnj2_i1o/edit

 

SEND YOUR COMMENTS TO

Josef Simme, NEPA Senior Environmental Specialist by:

            Email: josef.simme@usda.gov

            Phone: 540-613-1119

            Mail: ℅ Phoebe Drenckpohl, 12295 W. 48th Avenue, Wheat Ridge, CO 80033

DEADLINE: July 3, 2024

 

Note: In the Environmental Assessment written on behalf of Saratoga Biochar Solutions, LLC, biochar, which is the waste product of pyrolysis (just as ash is the waste product of incinerator) is always referred to as “carbon fertilizer.” However, Saratoga Biochar has not demonstrated that using the waste from sewage sludge pyrolysis would be safe or that it would help farmers to produce healthy crops and increase their yields.

Saratoga Biochar claims that its proposed facility, when fully built out, would be able to divert 15% of New York’s biosolids [aka sewage sludge] from landfills. Landfills currently accept 68% of the 377,000 dry tons of biosolids produced annually in the State of New York. When landfilled,  biosolids and organic materials release methane, a potent greenhouse gas. Saratoga argues that pyrolysis to make biochar is less impactful on the climate and would expand the production of fertilizer for farmers.

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However, the Environmental Assessment does not examine the value of Saratoga Biochar’s sewage sludge biochar as so-called carbon fertilizer or soil amendment, its effect on crop production or the safety of crops as livestock feed or as crops for livestock or human consumption, or the effects on adjoining lands and groundwater and surface water. Saratoga Biochar has provided no evidence that its biochar would not be contaminated with toxic substances, including heavy metals and PFAS or other persistent organic pollutants, that could adversely affect soil, plants, and food and feed. In fact, Saratoga Biochar has acknowledged that its biochar product will likely be contaminated by these substances.

Beyond concerns related to the impacts the biochar product if used in agriculture, the operation of the facility presents numerous negative environmental impacts that appear to have been summarily dismissed or ignored by the USDA in its evaluation of the Environmental Assessment.

 

GUIDANCE ON COMMENTS

 

We call on all concerned area residents, organizations, and elected leaders to submit a cover letter along with the comments you submitted to NYS DEC opposing permits for Saratoga Biochar. (If you cannot find your comments to DEC, either write new comments or contact Clean Air Action Network at contact@cleanairactionnetwork.org or visit the Not Moreau Facebook.)c

 

 

We are asking everyone to cc our elected officials (senators and representatives) in Washington and Albany. Please scroll down for their addresses.

 

 

A. FOR YOUR COVER SHEET TO USDA

Omit the numbers and put the points in your own words, if you wish.

 

Concerns about the comment period process for the Environmental Assessment

 

1.             I object to the extremely short, 10-day comment period just prior to a national holiday (July 4th) for a more than 1,000-page Environmental Assessment. This is an unacceptable way to conduct a public participation process.

 

2.             I request at minimum a 30-day extension of the comment period. A number of municipalities have previously registered their opposition to the Saratoga Biochar facility in board resolutions and statements or comments to the NYS DEC. A town or village board meeting is typically required for them to vote about whether to submit comments and most small municipalities only meet once monthly, especially during the summer.

 

3.             Area residents, municipalities and community organizations were not aware that Saratoga Biochar was going to submit an Environmental Assessment to the USDA or that it was applying for a very large grant under the Fertilizer Production Expansion Program.

 

4.             The legal notice was published in the Times Union, which is the Albany NY newspaper. This is not the primary newspaper read in the Town of Moreau.

 

5.             We are not aware that notice about the Environmental Assessment was given to the Moreau town government or other affected municipalities.

 

6.         Due to the size of the file, the Environmental Assessment was not downloadable from the USDA website. Fortunately, a persistent attorney representing an organization of concerned citizens opposing the Saratoga Biochar project managed to reach someone at USDA, who kindly divided the document into 3 downloadable files. 

 

Background for USDA:

 

1.         The Town of Moreau has enacted a moratorium on all industrial and manufacturing projects in the town, which will be in effect until the end of 2024. The town is currently working on revising its zoning rules for industrial and manufacturing projects and is considering strengthening the protections for town residents in other town laws.

 

2.         The NYS DEC draft permits are not evidence of intent to issue such permits. The state has not indicated what decision it will make on this facility. A citizens group is prepared to go to court if the state issues final permits for Saratoga Biochar.

 

3.         Saratoga Biochar has not proven the safety of its process or its product, and it has no experience in construction, operation or manufacturing biochar from sewage sludge.

 

4.         Saratoga Biochar understates and otherwise misrepresents the Disadvantaged Community impacts. NYS DEC has yet to issue its evaluation of such impacts.

 

5.         DEC has yet to determine the project's attainment of NYS environmental and climate goals.

 

6.         No reliable data supports a finding that the “carbon fertilizer” product would be safe. Spreading contaminated biochar on agricultural lands may have devastating impacts on that farmland, its crops and all that come in contact with them, including livestock and people that eat them.

 

B. ATTACH The COMMENTS YOU SENT TO DEC OPPOSING PERMITS FOR SARATOGA BIOCHAR.

If you cannot find them, email contact@cleanairactionnetwork.org or visit Not Moreau’s Facebook for guidance.

 

C. AMPLIFY YOUR MESSAGE

 

Cc your U.S. Senators (Chuck Schumer and Kirsten Gillibrand) and Member of Congress (Paul Tonko), and also NYS Assembly Member Carrie Woerner and NY State Senator James Tedisco.

 

To mail your comments via USPS to our U.S. Senators, send them to 

The Honorable (Name)

United States Senate

Washington, DC 20510

 

To mail your comments via USPS to your Member of Congress, send them to 

The Honorable (Name)

U.S. House of Representatives

Washington, DC 20515

 

We will post the email addresses of our US Senators and Member of Congress, as soon as we locate them.

 

Members of the NYS Legislature:

 

To mail your comments to Carrie Woerner via USPS, send them to

The Honorable Carrie Woerner

112 Spring Street, Suite 205

Saratoga Springs, NY 12866

 

Or email her at woernerc@nyassembly.gov

 

To mail your comments to State Senator James Tedisco via USPS, send them to

The Honorable James Tedisco

636 Plank Road, 2nd Floor

Clifton Park,  NY 12065-2046

 

Or email him at tedisco@nysenate.gov

 

D. Send us a copy of the whatever you submit to USDA.

Bcc or forward to contact@cleanairactionnetwork.org

 

E. Please ask at least two other people to send in comments.

Also try to give them a hand if they need any help.

 

F. If you can help generate more comments, please send an email to contact@cleanairactionnetwork.org or ____________________

 

 

We sincerely thank you for caring enough to take action.

 

– Tracy Frisch for Clean Air Action Network