Michigan Attorney General Files Lawsuit Against Advanced Disposal Services Arbor Hills Landfill

Michigan Attorney General, Dana Nessel announced her office had filed a lawsuit against Advanced Disposal Services (ADS), the owner and operator of the Arbor Hills Landfill, for failing to comply with State and Federal Regulations and endangering the public health, safety, and welfare of residents living in the shadow of the massive landfill. The announcement was made at the Northville Township Community Park Pavilion near 5 Mile and Beck with the landfill as a backdrop.

Landfill Flares Malfunction Again Likely Causing Community Odor - EGLE Issues Two Violation Notices

The Michigan Department of Environment, Great Lakes, and Energy (EGLE) issued two new Violations Notices to Advanced Disposal Services this week. Both Violation Notices were repeat violations (i.e. – similar violations have been cited and obviously not corrected). Both Violations Notices are the result of recent malfunctions to the landfill flares which resulted in excess emissions and likely community odors.

Northville Township Supervisor Testifies on the Impact of Landfill Regulations

Northville Township Supervisor Testifies on the Impact of Landfill Regulations

On September 15, 2020, Northville Township Supervisor Bob Nix, accompanied by Township Treasurer, Fred Shadko, and The Conservancy Initiative President, Ralph Lassel, testified before the Michigan House Ways and Means Committee. Mr. Nix stressed that the proposed house bills the committee is considering represented an opportunity to fix the problems with the current regulations and asked the legislators for their help.

Arbor Hills PFAS/PFOS Contaminated Stormwater Concern

In June 2020, The Conservancy Initiative (TCI) became aware of Advanced Disposal Service’s (ADS) permit applications which proposed to treat landfill wastewaters (leachate) on-site and discharge into Johnson Creek. At that time, TCI also learned stormwater contaminated with PFAS/PFOS chemicals from fire suppressants has been held at the site in an open-air pond since a fire in 2016.

Odors from Arbor Hills have an Impact Even 3 Miles Away

Recently, one of The Conservancy Initiative’s (TCI) very loyal members wrote to TCI to report a pattern they were seeing in the odors at their home. Their astute observations motivated TCI to dive a little deeper into some of the recent landfill odor events to see how odors correlated with weather patterns. This document presents a description of the analysis performed and the conclusions made by this investigation.

Landfill’s Controversial Johnson Creek Permit Applications are Put “On-Hold”

Landfill’s Controversial Johnson Creek Permit Applications are Put “On-Hold”

The Conservancy Initiative is happy to report that Advanced Disposal Services (ADS) has asked the Michigan Department of Environment, Great Lakes, and Energy (EGLE) to place its controversial water discharge permit applications “on-hold”. We believe ADS was surprised by the overwhelming opposition to these permit applications and has placed them “on hold” to avoid the permits being denied.

Landfill is Water-logged - Another Violation Notice Issued

Landfill is Water-logged  -  Another Violation Notice Issued

The Conservancy Initiative has learned the Michigan Department of Environment, Great Lakes, and Energy (EGLE) has issued another significant Violation Notice dated 7/28/20 to the Arbor Hills Landfill owner/operator, Advanced Disposal Services. The Violation Notice provides detail that many of the gas recovery wells at the landfill are restricted by leachate accumulation which is blocking or restricting gas flow in the wells.

The Friends of the Rouge Explain the Importance of Johnson Creek and Oppose Landfill Plans

The Friends of the Rouge (FOTR) is a nonprofit 501(c)(3) organization founded in 1986 to raise awareness about the need to clean up the Rouge River. The Conservancy Initiative is very appreciative to learn that FOTR has sent a letter to EGLE explaining the importance of Johnson Creek and their opposition to the proposals by Advanced Disposal Services to discharge treated landfill leachate.

The Conservancy Initiative encourages all our members to review the FOTR letter to understand better the biodiversity that is represented in this cold water stream.

In addition to providing a link to the FOTR letter opposing the landfill,s discharge plans, we also are including a link to the Friend of the Rouge website for you to explore. The virtual kayak tour of the Rouge River looks pretty interesting.

Link to Johnson Creek Letter

Link to Friends of the Rouge Website - therouge.org

Advanced Disposal’s Unauthorized Discharge to Johnson Creek - July 6th-7th

The Conservancy Initiative (TCI) has learned that Advanced Disposal Services (ADS) had an unauthorized discharge estimated at 27,600 gallons into Johnson Creek on July 6 - 7th. The discharge was from their water treatment facility which is located across Napier Road from the landfill (referred to as the Arbor Hills Remediation Site and described at the end of this article). The unauthorized discharge was self-reported to EGLE by ADS’s contractor upon discovery.

The Conservancy Initiative learned of the event when an email documenting the event was posted on EGLE’s MIWaters database. The Conservancy Initiative applauds EGLE personnel for insisting these records are posted to the public database to promote transparency.  

It appears the mismanagement of groundwater wells designed to direct groundwater flows away from the landfill may have caused the unauthorized discharge. Groundwater was being pumped into a holding pond with insufficient capacity causing the pond to overflow into Johnson Creek. This mishap was 100% avoidable and a violation notice is expected to be issued by EGLE. TCI will continue to follow-up to receive clarification on this incident.

Unfortunately, a sample of the material discharged to Johnson Creek was not obtained at the time of the incident so we do not know the true impact on Johnson Creek. This incident fits a pattern of operation we have been accustomed to from ADS. The incident is especially alarming as it happened while ADS is petitioning EGLE to allow the use of Johnson Creek as cost savings by discharge several wastewater streams. This is an excellent example of why we must be vigilant in our opposition to any proposal from ADS to use Johnson Creek for its discharge. We simply cannot entrust the environmental health of the trout stream to an unproven environmental steward.

TCI will continue to obtain more clarity into this event and pass those details on as soon as we learn them.  Below is a short description of the wastewater treatment plant on the Arbor Hills Remediation Site.

Arbor Hills Remediation Site

Most of us were unaware that Advanced Disposal Services has a permitted wastewater treatment facility located on the property just east of Napier Road near the Railroad Tracks. This facility has existed since at least 2002 and probably longer.  A slurry wall was installed to contain groundwater leaving the Arbor Hills Landfill and the treatment plant was used to treat groundwater on the east side of the slurry wall (outside the landfill). <Click Here for a Drawing showing the layout of the Remediation Site including the wastewater treatment plant and location of the slurry wall.> The permit allows for up to 100,000 gal/day treated groundwater to be discharged to Johnson Creek from December 1 through April 30 via an unnamed tributary that runs along the southern boundary of the Northville Ridge Subdivision.

The treatment plant is no longer needed as the groundwater contamination was resolved as of 2011. The holding ponds associated with the treatment system are now used to hold groundwater which is regularly pumped away from the slurry wall until it can be discharged to the Johnson Creek in accordance with the permit during the winter months. The permit requires close supervision of the facility with daily observations of water quality recorded and water samples analyzed up to 3x per week.

Community Leaders Request Attorney General to Begin Legal Proceedings Against Arbor Hills Landfill

Bob Nix, Northville Township Supervisor, Kurt Heise, Plymouth Township Supervisor, and Brian Turnbull, Mayor of the City of Northville have authored a letter asking the Michigan Attorney General to immediately commence legal proceedings against Advanced Disposal Services. Legal proceedings are believed to be the only path to obtain enforcement of existing violations, penalties commensurate with the violations, and corrective actions. A copy of this letter as well as the letter that requested the start of the enforcement proceedings can be obtained below.

The Conservancy Initiative believes this is a significant step. Our efforts have come a long way. The Conservancy Initiative has made similar requests over the past several months and has not received a response from the Attorney General. Today, three leaders of these influential communities joined our request, We greatly appreciate the continued support of our community leaders and are hopeful this unified approach will bring results.

When you see Bob Nix, Kurt Heise, and Brian Turnbull please thank them for their support.

Letter from Community Leaders - July 16, 2020

Letter requesting the start of enforcement proceedings - December 6, 2018

Enforcement Notice to Advanced Disposal - January 24, 2019

State Senator Polehanki and Representative Koleszar Oppose Discharge to Johnson Creek

State Senator Danya Polehanki and State Representative Matt Koleszar have sent a letter supporting The Conservancy Initiative’s and Northville Township leadership’s efforts to oppose Advanced Disposal Service’s permit request to treat and discharge leachate into Johnson Creek. The Conservancy Initiative greatly appreciates the support from our elected representatives. Their letter is attached.

Click Here for a copy of letter from Senator Polehanki and Representative Koleszar.

Neighborhoods in Plymouth Township Experience Odors

It is true that the majority of the Arbor Hills Landfill Odor Complaints are made by Northville Township residents. It is also true that when weather conditions create light winds out of the North to Northwest and the landfill is acting up, residents in Plymouth Township experience the noxious odors.

These types of weather conditions were present over the past weekend and into the early part of this week. (July 11 - 14th). These Plymouth Township residents didn’t think they had moved close to a landfill. Guessing many didn’t even know what they were smelling.

How many times have you been greeted by the odors along M-14 in the early morning or evening drives?

Odors+in+Plymouth.jpg

Odor complaints were received the past several days from Plymouth Township residents due to landfill operations and winds out of the North to Northwest.

Our Comments on the Landfill's Proposal to Treat PFAS Impacted Water On-site and Discharge to Johnson Creek

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June 26, 2020



Tarek Buckmaster

EGLE Water Resource Division 

Industrial and Storm Water Permit Group

PO BOX 30458

Lansing, MI 48909-7958



Tiffany Myers

EGLE Jackson District Office

301 E. Louis Glick Highway

Jackson, MI 49201-1556



[Click Here for a PDF version of this letter]



Re:   PFAS Removal from Impacted Stormwater Pond

Advanced Disposal - Arbor Hills Landfill

10690 West Six Mile Road, Northville, MI 48197

Mr. Buckmaster and Ms. Myers,

On June 24, 2020, The Conservancy Initiative became aware of a proposal[1] by Advanced Disposal Services (ADS) to treat and discharge an undeclared volume of PFAS impacted stormwater into Johnson Creek utilizing the existing NPDES permit (Permit No. MI0045713) for the Arbor Hills Remediation Site. The Advanced Disposal Services proposal was submitted to the Department of Environment, Great Lakes and Energy (EGLE) on June 2, 2020, less than one week after The Conservancy Initiative raised concerns regarding ADS’ NPDES permit application for the discharge of treated leachate to Johnson Creek.[2] 

20200622_103417.jpg



The Conservancy Initiative is writing to voice our strong disapproval of ADS’ proposal. Permit No. MI0045713 authorizes the discharge of treated groundwater from the Arbor Hills Remediation Site (located East of Napier Road in Wayne County) from December 1 through April 30.  Discharge is prohibited May 1 through November 30 unless the discharge was unavoidable to prevent loss of life, personal injury, or severe property damage, and there was no feasible alternative to the discharge.  Clearly, the impacted stormwater from the landfill site (located West of Napier Road in Washtenaw County) is not covered by this permit.



The Conservancy Initiative understands that treatment technologies exist which are capable of removing the PFAS contamination, but insists that any consideration for on-site treatment and discharge to surface waters must proceed through a rigorous permit approval process. The residents of Northville Township are blessed to have Johnson Creek meander through our township. We intend to protect this treasured asset and will fight to ensure that no short cuts are taken to improve the bottom line of a Corporation, let alone the landfill, that has taken advantage of the Township for the past decade.



The impacted stormwater originated from a fire at the landfill site in November 2016[3]. It is hard to believe this impacted water has been held in an open stormwater pond for almost 4 years and it should be of no surprise that nearby groundwater wells are now also impacted with PFAS chemicals.[4] The Conservancy Initiative requests to be notified of the planned disposition of this impacted stormwater and will be submitting a Freedom of Information Act Request to better understand its history. We reserve the right to submit detailed comments on any future permits being considered for Advanced Disposal Services, or its successors, and request to be notified prior to any permit actions being considered.



We are confident an antidegradation analysis,[5] required during the permit review process of a new discharge source, will determine the proper disposition for the PFAS impacted stormwater is at a properly licensed off-site disposal facility. Although this may be more costly for ADS, there are no social or economic development and benefits that will be foregone in the area if a permit is denied.



I look forward to hearing from you or your staff in the near future.

 

                                                                       Regards,



                                                                        /s/

                                                                       Dave Drinan

                                                                       Director, The Conservancy Initiative

 

cc:       (all via email) D. Nessel (AG), N. Gordon (MDAG), T. Siedel (EGLE), P. Argiroff (EGLE), C. Alexander (EGLE), S. Sliver (EGLE), J. Russell (EGLE), M. Steffler (EGLE), C. Dijak (EGLE), R. Burns (EGLE), J. Schinderle (EGLE), E. Browne (EGLE), L. Lee (EGLE), L. Bean (EGLE), Mary Ann Dolehanty (EGLE), J. Olaguer (EGLE), C. Ethridge (EGLE), S. Miller (EGLE), R. Nix (Northville Twp), F. Shadko (Northville Twp), M. Banner (Northville Twp), S. Frush (Northville Twp), S. Heath (Northville Twp), M. Herrmann (Northville Twp), C. Roosen (Northville Twp), M. Koleszar (State Representative), D. Polehanki (State Senator), S. Shinks (Washtenaw Co. Commissioner), E. Pratt (Washtenaw Co. Water Resource Commissioner), T. Eggermont (Washtenaw Co), B. Turnbull (Northville City), K. Heise (Plymouth Twp), M. Gallegher (NPS), C. Jankowski (NPS), P. Cullen (Wayne Co.), M. McCormick (Friends of the Rouge)


[1] PFAS Removal from Impacted Stormwater Pond, Advanced Disposal - Arbor Hills Landfill, June 2, 2020

[2] Advanced Disposal Requests Permission to Dump Leachate to Johnson Creek, The Conservancy Initiative, May 27, 2020

[3] Fire at Recycling Center, Joanne Maliszewski, hometownlife.com, November 20, 2016

[4] Michigan Department of Environment, Great Lakes, and Energy, Michigan PFAS Action Response Team, Washtenaw County, Salem Township, Arbor Hills Landfill, Inc.

[5] Antidegradation/Antibacksliding, EGLE Water Bureau Permits Section Procedure No. 14

Northville Township Submits Comments Opposing Landfill Discharges to Johnson Creek

Northville Township leadership has been very active opposing any proposed use of Johnson Creek by the Arbor Hills Landfill. On June 25th the Township sent written comments to the Michigan Department of Environment, Great Lakes and Energy (EGLE) opposing the two permit applications submitted by the landfill operators.

Click Here for a PDF copy of the Township Letter. The letter is also posted on the Township Website.

The Conservancy Initiative Submits Comments on Johnson Creek Permit Applications

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June 23, 2020

Tarek Buckmaster

EGLE Water Resource Division

Industrial and Storm Water Permit Group

PO BOX 30458

Lansing, MI 48909-7958

[Click Here for a PDF version of this Letter]

cc:   (all via email)

D. Nessel (AG), N. Gordon (MDAG), T. Siedel (EGLE), P. Argiroff (EGLE), C. Alexander (EGLE), S. Sliver (EGLE), J. Russell (EGLE), C. Dijak (EGLE), R. Burns (EGLE), J. Schinderle (EGLE), E. Browne (EGLE), L. Lee (EGLE), L. Bean (EGLE), Mary Ann Dolehanty (EGLE), J. Olaguer (EGLE), Chris Ethridge (EGLE), Scott Miller (EGLE), R. Nix (Northville Twp), F. Shadko (Northville Twp), M. Banner (Northville Twp), S. Frush (Northville Twp), S. Heath (Northville Twp), M. Hermann (Northville Twp), C. Roosen (Northville Twp), M. Koleszar (State Representative), D. Polehanki (State Senator), S. Shinks (Washtenaw Co. Commissioner), E. Pratt (Washtenaw Co. Water Resource Commissioner), T. Eggermont (Washtenaw Co), B. Turnbull (Northville City), K. Heise (Plymouth Twp), M. Gallegher (NPS), C. Jankowski (NPS), K. Kucel (Wayne Co. Drain Commissioner), M. McCormick (Friends of the Rouge)

Re:     Two NPDES Permit Applications Submitted by Advanced Disposal Services for the Arbor Hills Landfill Requesting to Modify Existing NPDES Permit Number MI0045713 Arbor Hills Remediation Area

Mr. Buckmaster, 

Executive Summary

The Conservancy Initiative (TCI) is an environmental nonprofit 501c(3) corporation located in Northville Township with a mission to improve the environment by working with neighbors, government entities, area businesses, and community leaders to create a clean and safe place to live and work. TCI is very concerned regarding the two NPDES permit modification applications (MI0045713)[1],[2] submitted on behalf of Advanced Disposal Services (ADS) related to the Arbor Hills Landfill, Salem Township. We are writing to submit preliminary comments related to these applications and point out several potential compliance concerns which we believe need to be considered when addressing the applications. TCI requests to be notified if these permits move forward, requests to be copied on comments to ADS by EGLE, and be given the opportunity to provide technical comments. TCI recommends the permits be denied.

Advanced Disposal’s Compliance Record

Since 2016, the communities downwind of the Arbor Hills Landfill have been plagued with excess emissions and noxious odors that have resulted from the landfill operators failing to consistently comply with State and USEPA regulations established to protect the community and the environment. Environmental enforcement proceedings have been on-going at the landfill since 2016. Violations are continuing; there were at least 4 Violations issued to date in 2020 and 17 Violations issued in 2019. Currently, ADS is negotiating with the Air Quality and Materials Management (Waste) Divisions to reach a settlement. The Attorney General’s office is actively involved.

Several passages in the permit application are reminiscent of past exchanges with the landfill operators:

  • The application actually declares compost leachate is being used for dust suppression which is not allowed. ADS should be aware this is not allowed as EGLE included it in a Compliance Concern in 2018. A TCI member observed the ADS road watering truck entering and exiting the compost facility as recent as June 22nd.

  • The leachate containment dike at the compost facility was breached due to unusually heavy precipitation. EGLE cited deficiencies in the containment dike in 2018.

We have searched and could find very few instances of NPDES permits in the State of Michigan for the discharge of treated landfill leachate. None involving a cold water fishery. With a history of repeated air, water, and solid waste violation notices and no history of operating a water treatment system, what assurances are there that ADS is capable of operating a wastewater treatment system to treat landfill leachate prior to discharge to a cold water fishery?  Odor violations and operating violations can be overcome.  However, a breakdown in the treatment system for whatever reason, can cause irreparable harm to the trout stream.

Johnson Creek

Northville Township is blessed to have Johnson Creek wind through our community. It is the focal point of several area parks. Many residents and visitors enjoy visiting Fish Hatchery Park, hiking in Cold Water Spring Nature Area, or visiting the banks of Johnson Creek at any of numerous locations in the area. Johnson Creek has been featured in two articles recently in the “The ‘Ville, Northville’s News and Lifestyle Magazine[3] which document the importance of Johnson Creek to our community.

As reported by the ‘Ville, Johnson Creek is the last cold water fishery in Wayne County. The sustainable actions of EGLE, Township Public Works personnel, residents, and Nongovernment Organizations (i.e. - Alliance of Rouge Communities, Friends of the Rouge) have helped improve the health of both Johnson Creek and the Rouge River downstream. Despite these efforts, Johnson Creek and the Rouge River remain on Michigan’s list of Impaired Waters (Clean Water Act Section 303(d))[4],[5]. TCI is concerned the requested permit actions simply represent cost savings for the landfill, with little consideration for the sustainability of the streams. TCI believes the proposed changes will increase the possibility of mishaps, may jeopardize water quality, and the landfill has not considered all the possible alternatives (including the continuation of disposal of leachate offsite).   

NPDES Permit Modification: Compost Pond - Arbor Hills Landfill

The need for this permit appears to have come about from the management (or mismanagement) of stormwater at the compost site. The permit application describes the compost facility:

The compost pad is sloped towards the Compost Pond so any direct precipitation that falls on to the compost pad will drain directly into the pond. The Compost Pond does not have an outlet.

There is a natural stormwater retention area located immediately south of the Compost Pond. The Compost Pond and the low‐lying natural stormwater retention area are separated by a berm designed to prevent stormwater overflow from the retention area into the Compost Pond, vice versa. The low‐lying stormwater area does not have a natural outlet.    

EGLE field staff indicated the berm separating the two ponds was breached this winter and ADS was informed that all waters were considered contaminated and must be handled as leachate[6]. The adequacy of the pond’s isolation was cited in a Compliance Concern dated 8-2-20184 (item 2). It is unclear if any corrective actions were taken to address this concern. The comingling of the two ponds has driven the need for this permit application. TCI believes several questions should be investigated and if appropriate, compliance actions may be necessary before this permit moves forward:

1) What actions, if any, were taken to upgrade the berm separating the Compost Pond from the Storm Water Pond as cited in the 8-2-20184 Compliance Concern?

2) Historic photos obtained from Google Earth (Attachment 1) indicated the two ponds have been comingled previously. The photo from the spring of 2017 shows a large flood of leachate contaminated waters. TCI encourages the EGLE Water Division compliance staff to verify how this contaminated water was disposed of? If water wasn’t disposed of, was it allowed to seep into groundwater at the site?

3) As stated in the permit application, precipitation appears to the naturally ponding on the site.

There is a natural stormwater retention area located immediately south of the Compost Pond…. The low-lying stormwater area does not have a natural outlet.

A review of property maps and USGS topography maps confirm there are no known tributaries that drain the site. USGS maps indicate wet areas near the location of the stormwater ponds (Attachment 2). TCI encourages EGLE to consider if additional wetlands should be designated at the site.

4) A recent Compliance Concern dated 8-2-2018[7] clearly states (Item 3) that water from the compost pond cannot be used for dust suppression. Only clean stormwater can be used for dust suppression. Advanced Disposal's permit application states compost pond water is being used for dust suppression.

6.1.3  Approximately 10,000 gallons of water is taken from the Compost Pond for dust control at the landfill operations during dry and warm days.

A TCI member observed the ADS road watering truck entering and exiting the compost facility as recent as June 22nd.

5) The permit application includes a review of Reasonable Alternatives and Best Management Practices. Best Management Practices to minimize stormwater running onto the pad must be in place and robust before the permit moves forward. Practices to minimize water run-on are not addressed.

6) The permit application is incomplete. The application does not specify the actual treatment processes or the discharge locations proposed to the utilized. The application does not adequately address antidegradation / antibacksliding requirements. ADS seems to be leaving the final design of the treatment system to EGLE.

NPDES Permit Modification: Arbor Hills East Landfill

There are two landfills at Arbor Hills. The leachate from Arbor Hills West is disposed at Ypsilanti Community Utilities Authority (YUCA) utilizing a longstanding agreement with the municipal sanitary sewer authorities. Disposal of leachate from Arbor Hills East (AHE) is more costly as it is collected separately and sent by tanker truck to a commercial disposal facility. The permit application states:

The current Wastewater Disposal Contract between ADS and YCUA prohibits the discharge of AHE leachate to the YCUA sewer system without the advance, written approval of YCUA due to the historical presence of polychlorinated biphenyls (PCBs) …

1.       PCBs are a pollutant of significant concern for Johnson Creek. The Clean Water Act requires a Total Maximum Daily Load (TMDL) to be developed for Johnson Creek. Advanced Disposal and/or YCUA should be asked to provide historic PCB concentration information as there appears to be some history here. Treatment strategies proposed for PCB removal must be proven technologies and designed for worst-case scenarios.

2.       The permit application is incomplete. The application does not adequately address antidegradation / antibacksliding requirements. 

3.       ADS has not considered possible alternatives. TCI believes the best disposal option for the landfill leachate is utilizing a Public Owned Treatment Works (POTW) which preferably discharges into a large waterway capable of buffering the impact (i.e. Great Lakes Water Authority or Ypsilanti Community Utilities Authority). Expansion of an existing or construction of a new POTW in the area could provide additional social and economic benefits to the community and allow costs to be shared. Below are some options which could be investigated:

1)      A Public Urban Development (PUD) of 500+ homes is planned for the south end of Salem Township. State grants which were to fund a sewer line to YCUA but are being delayed.[8] A partnership with Advanced Disposal may be a win-win solution.  

2)      Alternatives may exist to build a new Publicly Owned Treatment Works in partnership with a developer to service the landfill and PUD.

3)      Expansion of the Hamlet of Salem POTW to accommodate the landfill.

4)      Do nothing. ADS has been operating with trucked off-site disposal of leachate from Arbor Hills East for many years. The estimated cost savings do not seem substantial enough to risk the quality of Johnson Creek. ADS should be encouraged to consider using the potential savings to fund an alternative source similar to the suggestions above.

The Western Wayne County communities anticipate EGLE will keep the public involved at every step of this controversial permit requests. Please feel free to contact The Conservancy Initiative with questions at any time.  

Sincerely,

                                /s/

Dave Drinan

                                                                                                Director, The Conservancy Initiative

                                                                                                ddrinan@theconservancyinitiative.org                                                                                 

Attachment 1

Various Photos and Maps of the Compost Facility

Available Electronically - Click Here

 

 

Attachment 2

USGS Maps of the Compost Facility

Available Electronically - Click Here


[1] NPDES Permit Modification: Arbor Hills East Landfill, April 3, 2020, Environmental Resources Group, Prepared for Advanced Disposal Services

[2] NPDES Permit Modification: Compost Pond - Arbor Hills Landfill, April 3, 2020, Environmental Resources Group, Prepared for Advanced Disposal Services

 [3] The ‘Ville, April 2020, Vol 3, Issue 4, pgs. 16-18 and The ‘Ville, June 2020, Vol 3, Issue 6, pgs. 8-9

[4] Overview of Identifying and Restoring Impaired Waters under Section 303(d) of the CWA, USEPA

[5] Water Quality and Pollution Control in Michigan Sections 303(d), 305(b), and 314 Integrated Report, Michigan EGLE (see Appendix B2 pages 2770-2771)

[6] Summary of Meeting on 3-10-20, Downloaded from MIWaters

[7] State of Michigan, Department of Environmental Quality, Jackson District Office, CC No. CC-001168

[8] Washtenaw County communities at odds over sewer line project, MLive, Jan 3, 2020

https://www.mlive.com/news/ann-arbor/2020/01/salem-twp-continues-with-sewer-line-pork-project-faces-neighboring-twps-disapproval.html

Northville Township Supervisor Gives Testimony to the Michigan House Committee

The Michigan House of Representatives Committee on Natural Resources and Outdoor Recreation began hearings last week on a series of bills which, if passed, will be the first significant modification to Michigan Solid Waste Management Rules in many years. These Rules are far-reaching, cover all aspects of the waste disposal and recycling process in Michigan. There has been a desire to modify these rules to encourage recycling and discourage landfilling waste for serval years but the broad nature of the rules has produced many obstacles.

Northville Township and The Conservancy Initiative have tracked the rulemaking process very closely and attempted to influence legislators as much as possible. Our interest is the section of the rules which deals with siting and approving a new or expanded landfill. Currently, the host county (Washtenaw County) has all the authority for siting a new landfill in Salem Township. The proposed rules include a small change that will allow a resident from an adjacent community (i.e. - Northville) to be added to the waste planning committee for the host county (i.e. - Washtenaw County). This is helpful, but we are hoping for more.

On Tuesday, June 9th, Mr. Robert Nix, Northville Township Supervisor, testified before the Natural Resource and Outdoor Recreation Committee in Lansing and explained that more must be done to protect the property rights of homeowners located near a proposed landfill expansion or new landfill. Mr. Nix is a very familiar face to many on the committee as he has been raising these issues for several years. He shared with the committee that there are more than a dozen landfills in Michigan which present a similar issue to the Salem Township landfill as they are located near the county line. Mr. Nix suggested the following language be added to the House Bill.

Expansion of existing solid waste facilities and new solid waste facilities shall not be located within 2 miles of the border of an adjacent municipality without the consent of the adjacent municipality through a resolution of their elected governing body

This is not a veto authority, but it does protect the property rights of a homeowner living in an adjacent municipality within 2 miles of a landfill expansion, by requiring approval from the adjacent community. Accommodations may be possible in many instances. The committee promised more discussions.

The Conservancy Initiative would like to thank Supervisor Robert Nix and his team that supported him putting his testimony together, Treasurer Fred Shadko and Trustee Chris Roosen. We would also like to thank State Representative Matt Koleszar and State Senator Danya Polehanki for helping make the testimony a success.

Supervisor Nix’s presentation is linked as well as letters of support which were provided from The Conservancy Initiative and The City of Northville. We are also linking a video (discussion of Northville begins at 30-minute mark; Mr. Nix’s testimony begins at 37-minute mark) of today’s testimony.