Orange Environment, Inc.

Superior Hudson Valley Landfill 20000727

Superior Hudson Valley Landfill 20000727

Superior Hudson Valley Landfill 20000727

Marc Moran,
Regional Director, NYDEC

Dear Marc,

I laud the Department’s consideration of this as a new and separate application. However, the letter of July 27 mixes issues that you have correctly separated. Therefore, I want to raise several objections regarding the Department’s Notice of Positive Declaration and Draft Scoping statement for Superior Hudson Valley Landfill issued July 27, 2000.

  • There is no complete application. Therefore, there is no basis for issuing this notice. The application may be complete in a week, a year, or never. Why is action being taken when no complete application exists?
  • When I earlier characterized the department as using a warmed over old Turi application, you took offense. However, we have here an explicit and inappropriate use of a warmed over old Turi DEIS. We are told that the department is using this as an EAF/draft scope of issues. The copy of the summary indicates changes from the old DEIS. This hybrid old/new document confuses the separation between old and new application and applicant and makes little sense given the lack of a complete application. Clearly, a de novo DEIS will be required, I hope. Not merely a scratched out Turi document.
  • Finally, the Public requires access to a full and complete application if it is to prepare meaningful scoping issues in written or oral form. Absent this complete and final application, how can the process meaningfully go forward.

We ask that you reconsider this approach. We would like the notice to be rescinded until such time as there is a complete application and it is available for the public to review. We would like there to be a clear separation between this application and the last.

Thank you.


Michael R. Edelstein, President