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From: "Ben Oostdam" <boostdam@hotmail.com> Save Address
To: Seif.James@dep.state.pa.us Save Address
CC: boostdam@hotmail.com Save Address
Subject: (1)How DEP is doing (2) Mascaro permit renewal
Date: Wed, 28 Feb 2001 15:59:55
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PDER-Seif

Re: request for comments about (1) extension of Mascaro’s permit and (2) on how PDER is doing.

====================================

Last year, when I visited PDER to look for information about Mascaro’s operations, I made the suggestion that more constructive use be made of the WWW. I was told that lack of staff made this impossible. Recently, though, I noticed considerable efforts to increase and improve the department’s website. Here is my opinion: it certainly is a very good-looking website, but gives a critical researcher the impression of window-dressing. It looks as if the department determines what the public should be told, but that little is done to include what the public needs or wants to know, especially to make a well-informed judgment on such matters as hearings and requests for public input about permits and their extension. Although a search engine is made available, this should not release the department from the responsibility to educate and inform the public by providing, summarizing and organizing necessary and essential information; in short, the department should do the research, not the public.

Here are my recommendations, which I will gladly discuss in more detail.

A . . . There should be a separate page for each permittee dealing with considerable quantities of (potentially) toxic substances.

(This should definitely include Mascaro’s NYC sludge operation.)

B . . . The page should be in the form of an executive summary, with multiple links to details.

C . . . These links should provide essential information about the permittee’s organizational structure, annual budget, amounts and composition of toxic materials handled, description of operations, copy of permit, compliance record, details on complaints and conflicts and their resolution, fines assessed and collected, relevant lawsuits, political contributions, and donations, as well as - at a minimum -annual summary analyses reports.

D . . . In addition, links should be provided to a summary Environmental Impact Statement, as well as to a distinct statement about the tangible direct and indirect benefits accruing to the Commonwealth of PA , the municipality, and the public from the permittees operations, including the amounts of taxes and permit fees.

E . . . Although (a) link(s) to the permittee’s website(s) should be provided this should not be just substituted, i.e. the department should be responsible that relevant and correct information is provided to the public.

F . . . One person should be assigned to establish and maintain the site, liaise with the permittee, and be responsible to answer the public’s questions.

G . . . Questions and answers should be linked to the site, and a section of FAQ established.

H . . . As conditions of the permit , the permittee should be charged a reasonable fee to allow the above to be done, provide the information on a timely basis and appoint a contact person.

I . . . A (E-)mailing list should be established of interested members of the public to receive notices about hearings, renewals, requests for comments, etc.

J . . . By means of this communication, I request that you give serious consideration to the above recommendations, acknowledge receipt of this (my second) E-mail sent to you this month on this subject, and

K . . . Provide the public with copies of all comments received by posting them on your website and Emailing me and other respondents the relevant URL.

In conclusion, I register my protest about renewal of the permit because insufficient data are available or provided by PDER for a positive judgment on the alleged benefits of "bio-solids", whereas their harmfulness to the environment and the public is uncondonably disconsidered.

Thank you very much for your consideration, and kindly have a look at my website entitled: "Pennsylvania Sludge Issues": http://PA_Sludge.tripod.com/ which contains information substantiating my complaint and in which I will post a copy of this comment and of your auspicated response.

Sincerely:


=================== *]~~~< ============= >~~~[* ===================
Ben Oostdam, Ph.D.,
Professor of Oceanography (Emeritus 1997)
Managing Director, Environmental Science Research Associates (ESRA)
http://members.tripod.com/~esra_68/ESRA/ESRA.html
E-Mail: boostdam@hotmail.com
Home Page http://members.tripod.com/~boostdam/index.html
Index of Websites: http://www.angelfire.com/pa/boostdam/index.html

===================================================================


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