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Cart before the horse?
Long road from Lancaster to buy Harrisburg incinerator
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A thorough environmental site assessment
is needed at the Harrisburg incinerator
before the sale
Most people wouldn’t think of buying a home without
a formal pre-sale inspection.
Why have the Harrisburg and Lancaster
waste authorities skipped this vital environmental step?
‘Both waste authorities are out of their cotton-picking minds if they don’t insist on a pre-sale environmental assessment.’
Common sense demands that a thorough and independent environmental site assessment of the Harrisburg incinerator and its grounds be conducted before the proposed sale of the incinerator between the Harrisburg and Lancaster waste authorities.
Rear of Harrisburg incinerator
Other reading of interest
Pollution liability fears threatened Allentown incinerator project
The Harrisburg incinerator is a notoriously tainted industrial facility holding a mountain of incinerator ash that has been the center of ongoing environmental controversies for the last three decades.
Toxins likely have migrated off site with wind and groundwater, endangering neighbors and Susquehanna River wildlife alike.
Documents on file at the Pennsylvania Department of Environmental Protection (DEP) reveal that the Harrisburg incinerator illegally processed and disposed of hazardous material for years, if not decades.
As well, more than 1,000 pages of additional DEP records, posted here today, represent 1,000 more reasons to conduct an honest environmental assessment at the site. These 1,000 pages of DEP documents reflect years of serious environmental and regulatory problems at the incinerator.
Amazingly, neither the Harrisburg nor Lancaster waste authority appears to have reviewed these documents before the proposed sale.
A thorough environmental site assessment goes further.
An environmental site assessment identifies the nature and extent of contaminants on a given piece of property.
An environmental site assessment is the "process of estimating and evaluating significant short-term and long-term effects of a ... project on the quality of its location's environment," one business dictionary explains. "It also includes identifying ways to minimize, mitigate, or eliminate these effects and/or compensate for their impact. An environmental impact assessment is prepared on the basis an environmental assessment."
As well, there is a site assessment procedure that could qualify the incinerator ash pile as an EPA Superfund site.
Most homebuyers are familiar with a pre-sale home inspection. A home inspection discovers any problems with a property so that any dangers or complications are known to all parties, and can be addressed, before an important transaction is made. Many people wouldn't think of buying a home without a formal inspection.
Officials of both the Harrisburg and Lancaster waste authorities have skipped this vital step.
Both authorities say they have a limited environmental report conducted by the same consultant.
This is woefully inadequate and unacceptable for a $150 million transaction of this importance.
As one professional said to me, "Both waste authorities are out of their cotton-picking minds if they don't insist on a pre-sale environmental assessment."
It's in the interest of the Lancaster County Solid Waste Authority, its officers, and its bond investors to know what they are buying, and what problems they may be liable for, before the sale goes through.
It's in the interest of the Harrisburg Authority and its officers to know the same, and to be able to warranty the sale.
The city of Harrisburg as well long owned the incinerator, and has a great interest in understanding the property's potential liabilities.
‘Have both waste authorities and the receiver learned nothing from Harrisburg’s financial crisis? The avoidable crisis essentially was brought about by precisely this: rushing in to high-stakes financial transactions while professinals who should have known better ignored obvious problems and facts.’
To simply pretend and hope a problem does not exist -- in the face of all documentary evidence to the contrary posted here -- without first conducting a thorough environmental assessment is inexcusable, and represents grave legal, financial, and fiduciary errors on the part of both waste authorities, their officers, underwriters, the city and the receiver.
It also flies in the face of simple everyday common sense.
Have both waste authorities and the receiver learned nothing from Harrisburg's financial crisis? The avoidable crisis essentially was brought about by precisely this: rushing in to high-stakes financial transactions while professionals who should have known better ignored obvious problems and facts.
Officials for both waste authorities have said that an environmental assessment may be conducted after the proposed sale, but only if demanded by environmental agencies.
This non-strategy represents the height of folly and risk taking, given the history of the site, and the documents on file at the DEP.
Both waste authorities have an overriding interest not only to protect the public, but also to limit liability in this transaction, and to shed as much light as possible on the condition of the property before any sale is finalized.
By not conducting an environmental assessment pre-sale, both authorities not only are possibly risking the health and well-being of neighbors around the incinerator, they are each exposing themselves, and the city of Harrisburg, to great potential financial liability, and unnecessarily entering into an risky financial transaction in the dark.
Unfortunately, the entire transaction so far has been conducted like this, in the dark, with little transparency and public oversight.
What's there to hide? Let's lay all the cards on the table, now.
The more than 1,000 pages of environmental complaints posted here suggest there is plenty to hide.
Now is the time to find out, not later.
-- Bill Keisling
posted May 30, 2013
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