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Plainfield Township Zoning & Code Office

6292 Sullivan Trail

Nazareth, Pa. 18064

Phone: 610-759-6944 x 103

Fax: 610-759-1999

Matthew Goodrich, Esquire VIA UPS GROUND DELIVERY

Applicant's Authorized Representative
641 Market Street
Bangor, PA 18013

April 11, 2017

RE: IS Day Response to Zoning Permit Application and Site Plan dated 3/31/2017
Zoning Officer Comments

Dear Attorney Goodrich:

The following materials were received and reviewed for the above-referenced matter:

Application for Plan Examination and Building Permit dated March 31,2017 and
time-stamped received on March 31, 2017

Overall Synagro Alternate Facility Siting Plan dated 3123/2017 (Site Plan
Submission)

Site Plan Review Application Narrative Responses

Haarslev Industries Belt Dryer BD 3000 information

Preliminary/Final Subdivision Land Development Plan for the Green Knight

Energy Center (not Synagro) drawn 8/31/99 and revised 02/23/00 (previously
approved and recorded on March 15, 2000)

Upon review and examination of the above submitted materials, the Zoning Officer
hereby denies the Zoning Permit Application for the following reasons further set
forth herein. However, this application and the Site Plan submission is further
subject to Planning Commission review in accordance with Section 409 of the
Plainfield Township Zoning Ordinance.

Synagro Alternate Site Zoning Permit Application Review Letter 1

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Respollses/Commellts

The Application for Plan Examination and Building dated March 31, 2017
references the proposed use as Industrial, Tanks and Towers, and Agricultural
Industry S311.5 (B)I 5311.5 (C). It is the determination of the Zoning Officer that
the proposed use is not Agricultural Industry but is an Industrial use (Biosolid
Processing Facility) as specifically defined in the Plainfield Township Zoning
Ordinance as a Material Separation Facility (as defined in Sec. 201 B), which is
permitted by right and only in the Solid Waste Processing and Disposal District
(SW). The Material Separation Facility has additional requirements for the
Permitted by Right Use as set forth in Section 315 (B) (35) as follows:

a. The site shall contain at least three (3) acres for any facility with a
capacity to treat or dispose of up to three hundred (300) tons of solid waste
per day.

b. Entrances and exits to the facility shall be separated and clearly

designated; entrances and exits shall each be at least thirty (30') feet in
width and shall be located along either an arterial or collector road.

c. All access roads shall be paved.

d. Measures and procedures to prevent and minimize fire hazard shall be

established and practiced at the site or facility. A report describing these
procedures shall be provided to the Township.

e. Each facility shall be operated and maintained in such a manner as to

minimize health hazards, odors, dust, noise, environmental degradation,
unsightliness, the attraction, harborage or breeding of insects, rodents or
vectors and to eliminate conditions which create safety hazards or impose
an undue burden upon the Township or its municipal services
infrastructure.

f. The operation of the facility shall comply with all applicable State and
Federal regulations.

g. The facility shall comply with the performance standards in this Ordinance
(Article 5).

In reviewing the additional requirements for the permitted by right use as set forth
in Section 315 (B) (35) as listed above, the Zoning Officer offers the following
comments in bold italics:

Synagro Alternate Site Zoning Permit Application Review Letter 2

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a. The site shall contain at least three (3) acres for any facility with a
capacity to treat or dispose of up to three hundred (300) tons of solid waste
per day. The size of the site shall be increased by two (2) additional acres
of land for each additional capacity of one hundred (100) tons per day, or
fraction thereof.

The applicant shall clearly delineate the acreage ofthe proposed

Synagro lot (7. 01 acres) that is not impacted by steep slopes, slate spoils,
alld the Sediment Basill No.2 as shown on the Site Plan. Based on the
illformation and Site Plan submitted, the Zoning Officer has determilled
that this requiremellt has 1I0t beell met.

Consideril,g the provisions ofSection 315 (B) (35) that require an

additional two (2) acres oflalldfor each one hUlldred (l00) tons per day,
the ZOI,iI,g Officer recommends that tire applicant shall provide daily
tonnage receipt reports to the Township dllring the operation~llife of
this facility as a conditiOl' ofany fllture approval in order to ensure
contillued and OI,goil'g compliallce with this provisioll in perpetuity.

b. Entrances and exits to the facility shall be separated and clearly

designated; entrances and exits shall each be at least thirty (30') feet in
width and shall be located along either an arterial or collector road.

Entrallces alld exits to the facility are 1I0t separated and clearly
designated on tlte Site Plall. Pursuant to the requirements !iet fortlr in
Section 315 (B) (35), the entrances and exits shall each be at least thirty
(30') feet in width and shall be located along either all arterial or
collector road. There is not a separate entrance and exit to the facility
shown on the Site Plan. Further, the elltrance and exit to the facility is
not located alollg either all arterial or collector road. Therefore, tire
conditions alld provisions associated with this additional requirement
are not beillg met.

In addition, tlte applicant shall provide the Zoning Officer witlt a

drawillg that shows the proposed traffic patte", for the elltire site. It is
not clear to tlte Zoning Officer based 011 what was submitted llOw tl,e
vehicular truck traffic is moving through tire interior parallel roads of
the Grand Central Sallitary Landfill.

c. All access roads shall be paved.

The proposed driveway and tire loadillgloutgo;"g access roads are 1I0t
clearly shown as paved on the Site PIQl,. Therefore, this provisioll is not
being met as currently proposed.

Synagro Alternate Site Zoning Permit Application Revie'w Letter 3

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d. Measures and procedures to prevent and minimize fire hazard shall be

established and practiced at the site or facility. A report describing these
procedures shall be provided to the Township.

A written report shall be provided to the Township. The report shall be

to tlte satisfaction oftlte Township Engineer, Fire Chief, Slate Belt
Regional Police Department Chief, Zoning Officer, Bllilding Code
Official and the Emergency Management Coordinator.

e. Each facility shall be operated and maintained in such a manner as to

minimize health hazards, odors, dust, noise, environmental degradation,
unsightliness, the attraction, harborage or breeding of insects, rodents or
vectors and to eliminate conditions which create safety hazards or impose
an undue burden upon the Township or its municipal services
infrastructure.

III order for the Zoning Officer to make a determillation regarding this
provision, additional information is reqllired and requestedfrom tire
applicant as to how eaclt item listed above will be specifically addressed.
Some ofthese items are also listed wit"i" Article 5 as set fort" below. It
is the recommendation ofti,e Zoning Officer to the Plainfield Township
Board ofSupervisors that as a condition ofany flltllre approval ofthis
proposed lise and the occllpancy ofany proposed structllre associated
with tlris lise, that evidence that all performance standards are complied
with be provided via certification oftests by appropriate govemment
agencies, or be recognized testing laboratories (witlr tire costs to be bome
by ti,e applicant), pllrsuant to Section 410 oftire Zoning Ordinance.

f. The operation of the facility shall comply with all applicable State and
Federal regulations.

Tire Zoning Officer cannot make a determinatiOll at t"is time as to

wlretlrer tire operation oftire facility is in compliance witlr all applicable
State and Federal regulations, Ti,e following iliformation shall be
provided before any zoning or bllilding permits can be issued to tire
satisfaction ofthe Zoning Officer, Plalll,ing Commission, a"d tire
Township Engineer:

1. Evidence ofPelll,DOT Higlrway Occllpancy Permit compliance,

as applicable.

2, Evidence ofAct 537 (Pennsylvania Sewage Facilities Act)

compliance from tire Pennsylvania Department ofEnvironmental
Protection,

Synagro Alternate Site Zoning Permit Application Review Letter 4

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3. Evidence of Water Obstruction Act of 1913 compliance.

4. Evidellce ofSolid Waste Mallagemellt Act, Act 97 of 1980

(illcluding umellclmellts) compliance from tlte Pennsylvania
Departmellt ofEllviromllental Protection.

5. Evidence ofMunicipal Waste Planlling, Recycling alld Waste

Reduction Act compliance from tlte Pennsylvania Departmellt of
Enviromllental Protection. Clarification is required from tlte
Com",omvealtlt ofPennsylvania Department ofEnvironmental
Protection as to whether the proposedfacility is defilled as a
"Resource Recovery Facility" as setforth in the Municipal Waste
Planning, Recycling and Waste Reduction Act.

6. Evidence ofAct 167 Storm water Management Act/Plainfield

TownslJip Storm water Ordinance (BH.thkiJ/ Creek,
Martins/Jacoby Creek and Delaware River Sub-Basin 1
Waters/,eds Act 167 Storm water Management Ordinance). A
review from tire LelJigh Valley Plam,ing Commission (LVPCj is
required.

7. Evidence of Federal Water Pollution Control Act Amendmellts of

1972 (Section 404, 33, U.S.c. 1334) compliance.

8. Evidence ofClean Streams Law compliaIIce from tire

Pennsylvania Department ofEnvironmental Protection and the
Northampton County Conservation District (including but not
limited to Chapter 93, Chapter 102 alld Chapter 105).

9. Evidence ofClean Air Act compliance from the Pennsylvania

Department ofEnvironmental Protection Bureau ofAir Quality
alld tl,e Environmental Protection Agency (EPA), as required.

10. Jurisdictional determinations from the Army Corps ofEngineers

and tire Pennsylvania Department ofEnvironmental Protection
(PA DEP) as to whether tire Sedimentation Basin No. 21Sedimellt
Pond as shown on the Site Plan are considered to be "Waters of
the United States" or "Waters ofthe Commomvealth".

11. Evidence ofPennsylvania Natural Diversity Inventory (PNDI)

compliance.

Synagro Alternate Site Zoning Permit Application Review Letter 5

 12. Evidellce ofcompliance with all applicable Pellnsylvania
Historical alld Museum Commission notification requirements.

13. Evidence from the Pennsylvania Department ofEnvironmental

Protectioll that the proposed site is ill compliance with the
current approved Operating Permit ofthe Grand Celltral
Sanitary Landfill (Facility ID No. 100265).

14. Evidence that the proposed Wastewater Treatment Plallt Area is

compliant with all applicable Pennsylvania Department of
Environmelltal Protection and Delaware River Basin
Commission requirements, provisiOllS and regulations. The
receiving stream needs to be identified. Both the Waltz Creek and
the Little Bushkill Creek are designated as High Quality Cold
Water Fisheries and as Migratory Fisheries.

15. Evidence that the proposedfill-in and reduction in size ofthe

Sediment Basin No.2 is approved by the Pennsylvania
Department ofEnvironmental Protection. An enlargement or
reduction in size ofa Sediment Basin/Pond can only be approved
by tire Pennsylvania Department ofEnvironmental Protection. A
revision to NPDES Permit No. PA 0070483 is likely required. 11,
addition, evidence is requiredfrom tire Pennsylvania Department
ofEnvirollmental Protection tlrat confirms t/rat tire use oftire
Sediment Basin No.2 for tlris proposedfacility is in compliance
with tire current approved Operating Per",it oftire Grand Central
Sanitary Landfill (Facility ID No. 100265).

16. Evidencefrom all oftire applicable State and Federal agencies

t"at all required State and Federal permits tlrat are required to
legally operate a facility as proposed for this site /rave been
obtained by the applicant.

g. The facility shall comply with the perfonnance standards in this Ordinance
(Article 5).

Section 501 EnvirOllmelltal Preservation Required. Tire applicant slrall

fUTllislr proofto t"e Townslrip to tire satisfaction oftire TownS/lip
Engilleer and tire Zonillg Officer t/rat tI,e use provides for tire
preservation and tire minimum destruction ofnatural drainage areas,
minim"m gradil,g and destruction oft/re ground surface, the
preservatioll ofsubstantial stands oftrees andforested areas, and the
preservation ofattractive views and any other natural amenities and
features on tire existing site.

Synagro Alternate Site Zoning Permit Application Reviel1! Letter 6

Sectioll 502 Nuisances Prohibited. The applicant shallfumish proofto
the Township that the proposed structure shallllot be IIsed or occupied
ill a ",anner that creates a dangerous, injurious, noxious, or otherwise
objectionable conditiOll,fire, explosion, or other hazards, heat,
electromagnetic or other radiation, noise or vibration in violation of
Plainfield Township noise regulations under Section 410, .~moke, dust,
odor or other form ofair pollution, or any other condition in such
manner or on such amount as to adversely affect the reasonable lise or
vallie ofthe surrounding rea or adjoining premises or be dangerous to
public /zealth or safety.

Sectioll 503 Steep Slopes. As noted elsewhere in this letter, the applicant
shall f"mish proofofcompliance with Ordinance No. 356 (duly adopted
December 12, 2012 and which amended Section 503 ofthe Plainfield
Township Zoning Ordinance entitled Steep Slopes in its entirety).

Section 504 Areas with High Water Table. Proofshall be fllTllished to

the Towllship that the proposed land lise will not directly or indirectly
result in the pollution ofthe groundwater. Such a lise would be
prohibitedfrom developing in any area which has a year-round 01'
seasonal high water table which comes to within any distance ofthe
ground surface, which violates Pennsylvania Department of
Environmental Protection regulatiolls. The determination ofsuch
hazards ~'hall be made by the appropriate State agency and/or by a
qualified sanitary engineer, geologist 01 soil scielltist approved by the
Board ofSupervisors.

Section 505 Development Along Waterbodies. The proposed Site Plan

does not appear to be in compliance with Section 505 (Development
Alollg Waterbodies) ofthe Plainfield Towllship Zoning Ordinance.
Pursuant to Section 505 ofthe Zoning Ordinance, all areas within fifty
feet (50') ofthe banks ofany streams, lake or pond shall be in open
space. There is not fifty feet (50') ofopen space between tI,e proposed
structures/improvements and the sediment pond; the ZOIling Officer has
determined that this requirement has not been met. The proposed Site
Plan identifies the ~'edi",ent pondlbasin as "Existing StreamS/Ponds" OIl
Sheet 2 of 4. The fifty feet (50') ofopen space requirement between the
pond and all proposed structureslimprovemellts is not being met in the
determination ofthe Zoning Officer.

Section 506 Alluvial Soils Areas. The applicallt shall fumish proofto
the Zoning Officer that the areas proposed for the development are not
within all UAlluvial Soils" area.

Section 507 Flood Plain Regulatiom', All Special Flood Hazard Areas
shall be shown on the Site Plan. Specifically, the limits ofZone A on

Synagro Alternate Site Zoning Permit Application Review Letter 7

FEMA FIRM Map Panel 42095C0132E are very close to the proposed
driveway for the project. Confirmation is needed that the proposed
driveway or any other proposed improvement/structure is not within
Zone A. Compliance with Ordinance No, 368, which was dilly adopted
June 11, 2014 and amended Section 507 (entitled Flood Plain
Regulations) ofthe Plainfield Township Zoning Ordinance, is required.

Section 508 Filling, Excavation and Grading. All NPDES, Northampton

County Conservation District and Departmelll ofEnvironmental
Protection regulations shall apply to tlJis proposed use. The applicant
shallfllmish proofthat Section 508 ofthe Township shall be complied
with. A 'Zoning permit is required before any activities that require the
moving ofearth or the filling or excavation ofan area can commence.

Section 509 Outdoor Storage Control. The Applicant shall idelllify

whether any outdoor storage facilities are proposed.
.
Section 510 Sewage Waste Treatment and Disposal Control Evidence of
Act 537 (Pennsylvania Sewage Facilities Act) compliance from the
Pennsylvania Department ofEnvironmental Protection shall be
required.

Section 511 Noise Control. The applicant shall fUrIlish proofthat the
proposed use is in compliance with the Sound Level Limits by Receiving
Land Use and time as setfortI, in Section 511 A ofthe Zoning
Ordinance. Sections 511 B, C, D and E shall apply for an Industrial use.

Section 512 Vibration ColltroL Tire applicant shallfumisll proofof

compliance with Section 512 to tl,e Township.

Section 513 Dust, Dirt, Smoke, Vapors, Gases and Odor!t" Control. The
applicant shallfumish proofofcompliance with Section 513 to tile
Township.

Section 514 Light, Glare and Heat Control. The applicant shallfumis"
proofofcompliance with Section 514 to tile Township.

Section 515 Electric, Diesel, Gas or othe,' Power. Tile applicant shall
f"misll proofofcompliance with Section 514 to tire Township.

Section 516 Colllrol ofRadioactivity, Electrical Emissions and Electrical

Disturbances. The applicant shallfumisll proofofcompliance witll
Sectio" 516 to tile Township.

Synagro Alternate Site Zoning Permit Application Review Letter 8

 The final determination of proof of compliance with Article 5 shall be
made to the satisfaction of the Township Zoning Officer, the Township
Engineer and any qualified expert that the Township employs in order to
provide a scientific or engineering opinion.

Section 410 Performance Requirements. It is recommendation of the Zoning

Officer to the Plainfield Township Board of Supervisors that as a condition of any
future approval of this proposed use and the occupancy of any proposed structure
associated with this use, that evidence that all performance standards are complied
with be provided via certification of tests by appropriate government agencies, or
be recognized testing laboratories (with the costs to be borne by the applicant). It
is the recommendation of the Zoning Officer that specifie types of equipment,
machinery and devices are instaIled or used as required in order to determine
whether or not the proposed operation is in compliance with all applicable
performance standards. Permits and certificates required by other government
agencies shall be submitted to the Zoning Officer as proof of compliance with
applicable codes. Regulation of Nuisance Characteristics and the Standards to be
enforced shaIl be in accordance with Section 410 C and D of the Plainfield
Township Zoning Ordinance and all applicable State and Federal regulations.

Section 410 Traffic Impact Requirements. A review of the level of traffic impact
by the Township Engineer is required for an Industrial Material Separation
Facility pursuant to Section 410 E (Traffic Impact Requirements) of the Plainfield
Township Zoning Ordinance. The Zoning Officer will defer to the comments and
recommendations of the Township Engineer on this matter. However, the Zoning
Officer reserves the right to make the final determination or interpretation as to
the specific uses in the latest edition of the publication entitled "Trip Generation,
An Information Report" as published by the Institute of Transportation Engineers.
If a Major Traffic Impact is determined, all applicable provisions of Section 410 E
(1,2,3, and 4) shall apply to this proposed use.

The foIlowing dimensional requirements will apply to the proposed facility

located within the Solid Waste Processing and Disposal District as per Section
318 H, 1, and J of the Zoning Ordinance:

a. Minimum Lot Size: 5 acres is required for proposed 400 tons of solid
waste per day.

b. Minimum Lot Width: 200 feet

c. Maximum Building Coverage: 25%

d. Maximum Building Height: 50 feet

Synagro Alternate Site Zoning Permit Application Review Letter 9

 e. Maximum Structure Height: 75 feet (403 B. Accessory Structures 150% of
50 feet)

f. Maximum Impervious Coverage: 45% (318 J Maximum Impervious

Coverage in in the Solid Waste Processing and Disposal District)

g. Front Yard: 50 feet

h. Side Yard: 25 feet each/50 feet both

l. Rear Yard: 50 feet

Comments on the dimensional requirements are as follows:

a. Clarification is needed as to the final proposed silo height. The site plan
narrative references the silo as 65 feet, and Sheet 1 of 4 of the Overall
Synagro Alternate Facility Siting Plan shows the proposed maximum
structure height as 51.65 feet.

b. Both the Site Plan narrative and the Overall Synagro Alternate Facility
Siting Plan shall be revised to reference the correct dimensional
requirements as set forth above.

c. The proposed loading and offloading road encroaches upon the proposed
Green Knight lot (5.18 acres). The setback requirements for the rear yard
for both proposed lots and the front/side setbacks of the Green Knight lot
are therefore not being met as currently proposed on the Site Plan, as
determined by the Zoning Officer.

d. The lot or yard requirements for any new building or use shall not include
any part of a lot that is required by any other building or use to comply
with the requirements of this Ordinance. Therefore, that requirement of the
Zoning Ordinance is not currently being met by the proposed Site Plan, as
per Section 404 A (1) of the Zoning Ordinance.

Accessory Uses Determination (WWTP and Switch Gear). It is the determination

of the Zoning Officer that the proposed Wastewater Treatment Plant (WWTP)
area is an Accessory Use that is "clearly customary and incidental to the principal
use." The Minimum Yard requirements as listed in Section 318 H shall be
applicable for the Accessory Use. The Wastewater Treatment Plant area shall only
be used for the Principal Use of the Material Separations Facility.

Synagro Alternate Site Zoning Permit Application Revie'w Letter 10

 The existing Switch Gear of the Green Knights Energy Center is proposed to be
located on a separate parcell10t located within the Commercial Industry (CI)
Zoning District. The Switch Gear, which is clearly an Accessory Use to the Green
Knights Energy Center, would not be a Permitted Accessory Use on another lot
located within the CI Zoning District in the determination of the Zoning Officer.

Geotechnical Site Investigation Report. A Geotechnical Site Investigation Report

for the proposed site to the satisfaction of the Township Engineer shall be
provided.

Existing Utilities. The main structure on the site is proposed to be built where
there are existing overhead electric utilities, as well as existing utilities poles. A
relocation plan shall be submitted to the Township. Proof of coordination with the
local utility provider and the utility provider's approval of the relocation of the
utility facilities shall be furnished to the Township.

Traffic Visibility Across Corners. The applicant shall furnish proof to the
Township that the proposed use is in compliance with Section 404 C (Traffic
Visibility Across Comers) for all sightlines at intersections of driveways or access
ways with streets.

Operating Hours. The applicant shall identify the proposed operating hours for
this proposed facility and all proposed Accessory Uses. Additional information is
required from the Commonwealth of Pennsylvania Department of Environmental
Protection in tenus of whether the proposed operating hours are not in conflict
with the current Grand Central Sanitary Landfill Operating Penuit and all other
applicable Plainfield Township ordinances.

Plainfield Township Driveway Ordinance. Compliance with the Plainfield

Township Driveway Ordinance shall be confirmed to the satisfaction of the
Driveway Administrator and the Township Engineer.

Land Development/Major Subdivision approval by the Plainfield Township

Planning Commission and Plainfield Township Board of Supervisors is required
for this proposed use and the two lots (Synagro 7.01 acres and Green Knight 5.18
acres) before any zoning and building permits can be issued. All applicable
provisions of the Subdivision and Land Development Ordinance shall apply.

Principal Buildings Section 402 A. Every principal building shall be built upon a
lot with frontage upon a public or private street improved to meet Township
standards or for which such improvements have been insured by the posting of a
performance guarantee pursuant to the Subdivision and Land Development
Ordinance, excepting however, those principal buildings specifically approved by
the Board of Supervisors. Future compliance with this section is unclear, as the

Synagro Alternate Site Zoning Permit Application Review Letter 11

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proposed access road is owned in part by Plainfield Township (Tax Map Parcel
ID# E8 14 1A 0626E) and temporary use ofthe access road was granted to Grand
Central Real Estate Company, Inc. and Grand Central Sanitation, Inc. via an
Easement Agreement dated March 12, 1997. This section of what is currently an
improved road may once again in the future be used as part of the Recreation
Trail pursuant to the Easement Agreement provisions once the landfill has entered
the closure phase of its life cycle, and the amount of the frontage may be
impacted. A determination on this provision must be made as part of the required
Site Plan review and the formal Subdivision and Land Development (SALDO)
review.

The metes and bounds of Tax Map Parcel ID# E8 I41A 0626E should be used to
delineate the exact location of the section of the access road that is owned by
Plainfield Township in order to determine whether or not any of the proposed
yard and lot measurements are impacted by said parcel. It would appear that a
portion of the proposed side yard setback is encroaching onto the E8 141 A 0626E
parcel.

Impact to Future Recreation Trail. As described above, part of the proposed

access road is owned by Plainfield Township. It is the recommendation of the
Zoning Officer that the current and future impact of this facility on the Recreation
Trail should be studied and provided to the Township, to the satisfaction of the
Planning Commission, the Township Engineer and the Zoning Officer.

Signage. Article 6. All signage proposed for this facility and use shall be
identified to the Township in order for the Zoning Officer to determine
compliance with Article 6 of the Zoning Ordinance entitled "Signs".

Compliance with Ordinance No. 356 (duly adopted December 12,2012 and
which amended Section 503 of the Plainfield Township Zoning Ordinance
entitled Steep Slopes in its entirety) cannot be determined by the Zoning Officer
based on the Site Plan submission. As defined and in accordance with Ordinance
No. 356 (Section 503 B), Class A, Band C Steep Slopes shall be clearly
delineated on the Site Plan where applicable. Section 503 I and Section 503 J of
Ordinance No. 356 list both the Permitted Uses and Development on Class A
Slopes and the Prohibited Uses on Class A Slopes. Pursuant to Section 503 B (5)
and (6) of the Zoning Ordinance as amended by Ordinance No. 356, the burden of
proving the correct boundary shall be on the applicant, supported by engineering
and/or surveying data or mapping, testimony of a soil scientist, or other evidence
acceptable to Plainfield Township. Compliance with Ordinance No. 356 shall be
confirmed by the Township Engineer.

Synagro Alternate Site Zoning Permit Application Review Letter 12

 All Special Flood Hazard Areas shall be shown on the Site Plan. Specifically, the
limits of Zone A on FEMA FIRM Map Panel 42095C0132E are very close to the
proposed driveway for the project. Confirmation is needed that the proposed
driveway or any other proposed improvement/structure are not located within
Zone A.

NPDES Permit Required. As over one (1) acre of disturbance is proposed for this
project, Plainfield Township is not currently able to issue allY permits (either
zoning or building) for this project as per Section 102.43 of the Commonwealth of
Pennsylvania Department of Environmental Protection (PA DEP) Erosion and
Sediment Control Rules and Regulations, 25 Pa. Code 102.43 and Section 611 of
the Clean Streams Law, the Act of June 22, 1937, L.L. 1987, as amended, 35 P.S.
691.611. 25 Pa. Code 102.43 states, "With the exception of local stormwater
approvals or authorizations, a municipality or county may not issue a building or
other permit approval to those proposing or conducting earth disturbance
activities requiring a Department permit until the Department or a conservation
district has issued the E&S or individual NPDES Permit, or approved coverage
under the general NPDES Permit for Stormwater Discharges Associated With
Construction Activities under I02.5 (relating to permit requirements}."

Stormwater Conveyance. The Site Plan narrative indicates that stormwater runoff
is to be directed and conveyed to the existing Sediment Basin No.2 and that
Sediment Basin No.2 will be modified as required to accommodate the additional
volume. Information shall be provided on specifically how the stormwater runoff
is to be conveyed to Sediment Basin No.2. Act 167 (Stormwater Management
Act}/Plainfield Township Stormwater Ordinance (Bushkill Creek, Martins/Jacoby
Creek and Delaware River Sub-Basin 1 Watersheds Act 167 Stormwater
Management Ordinance) compliance is required. Proof of compliance with the
current Grand Central Sanitary Landfill Operating Permit to use this
Sedimentation Basin No.2 as a storrnwater facility is required from the
Pennsylvania Department of Environmental Protection. In addition, all existing
stormwater facilities shall be identified on the Site Plan.

Riparian Buffer Ordinance. In the event that either the Army Corps of Engineers
or the Pennsylvania Department of Environmental Protection take jurisdiction of
the Sediment Basin No.2 as "Waters of the United States" or "Waters of the
Commonwealth", the Riparian Buffer Ordinance of Plainfield Township shall
apply, with all applicable requirements of that ordinance for buffers to take effect.

Lot LinesNard Requirements. Confirmation is required from the Township

Engineer that the front, side and rear yard and all lot line design configurations as
set forth on the Site Plan are in conformance with the Plainfield Township Zoning

Synagro Alternate Site Zoning Permit Application Revie'w Letter 13

 Ordinance and the Plainfield Township Subdivision and Land Development
Ordinance (SALDO).

Front Lot Line. It is the interpretation of the Zoning Officer that the proposed
Front Lot Line (Street Line) does not meet the definition as set forth in the
Plainfield Township Zoning Ordinance as follows: "A lot line separating the lot
from a street right-of-way. The front lot line shall be the same as an existing or
future right-of-way line (whichever establishes a greater width)." The lot line is
not shown as separating the lot from a street right-of-way, as required by Section
201 B ofthe Plainfield Township Zoning Ordinance.

Section 703 Design Standards for Off-Street Parking Facilities; Section 704 Off-
Street Loading.

a. Section 703 A (7): The access drives/driveways as proposed are not at

least ten feet (10') from the rear lot line as required. The solid fence and
planting screen of at least four (4 ') feet is not shown on the Site Plan.
Therefore, the requirements of this section are not currently being met as
shown on the proposed Site Plan.

b. Section 703 D (I) (2) (3) (4): The required dimensions shall be shown for
all access drives, including the loadingloffloading area. Provisions are not
shown for parallel drainage along the access drives. The proposed loading
and offloading drive encroaches upon the parking areas of both the
proposed Green Knight lot and the proposed Synagro lot. Therefore, the
requirements of Section 703 0 are not currently being met as shown on
the proposed Site Plan.

c. Section 703 E: The applicant will provide infonnation to show that the
required parking facilities, including driveways, are to be graded, surfaced
with asphalt or other suitable material, and drained to the extent necessary
to prevent dust, erosion, or excessive water flow across streets or
adjoining properties.

d. Section 703 F: Any parking area designed for use by six (6) or more cars
after dusk shall be adequately illuminated. All fixtures used to illuminate
parking areas shall be arranged to prevent light from shining beyond the
boundary of the property. Lighting fixtures are not proposed for the
sixteen (16) space Synagro parking lot. While the applicant indicates in
the Site Plan narrative that adequate lighting will be provided in the
parking lot and employee working areas by using wall mounted lighting
fixtures, the Site Plan does not show specifically how the lighting of the
parking areas will be achieved, the extent of the lumens and the reach of

Synagro Alternate Site Zoning Permit Application Review Letter 14

'.

the proposed lighting to sufficiently illuminate the parking lot. Therefore,

the requirements of Section 703 (F) are not currently being met as shown
on the proposed Site Plan.

e. Section 703 G (1) (2): All parking spaces and access drives shall be at
least ten feet (10') from any side or rear lot lines. The access drives for the
proposed Synagro lot are not ten feet (10') from the rear lot line. All areas
not serving as parking spaces, aisles, access drives, or pedestrian
walkways shall be permanently landscaped and maintained. Landscaping
is not shown on the proposed Site Plan. Therefore, the requirements of
Section 703 G (1) and (2) are not currently being met as shown on the
proposed Site Plan.

f. Section 704 B (2): The maneuvering room is not sufficiently separated

from other parking to eliminate traffic conflicts within off-street loading
and parking areas as currently proposed.

g. Section 704 B (3): The maneuvering room is not entirely on the lot
proposed to be served. The maneuvering room is outside of the yard area.

h. Section 704 B (6): The traffic pattern as currently proposed on the Site
Plan is a hazard to the vehicles/pedestrians accessing or departing the
parking area.

1. Section 704 B (7): All of the requirements listed in Section 703 F and 703
G are not currently being met.

The Building Code Official of Plainfield Township has provided an initial

response letter. Said letter dated April 7,2017 is enclosed and incorporated herein
into this letter by reference.

Certification of ownership and acknowledgement of plan signed by owner and

developer. It is not clear to the Zoning Officer whether the owner of the property,
Waste Management, is represented by the Applicant's Designated Representative.
Synagro Technologies, Inc. is the Applicant but does not have ownership of the
parcel. Proof of equitable ownership is required.

In addition to the issues and determinations set forth within this letter, the Zoning
Officer review letter shall incorporate any and all issues and recommended
conditions of approval as identified by the Township Engineer and the Planning
Commission as part ofthe required Site Plan review.

Synagro Alternate Site Zoning Permit Application Review Letter 15

.
As set forth above in this review letter, building and zoning permits cannot be issued for
this project until all of issues identified within this letter are addressed or any other issues
that may be identified during the required Planning Commission Site Plan review and the
formal Subdivision and Land Development (SALDO) review are addressed.

Pursuant to the provisiom' ofthe Plablfield Towllship ZOllillg Ordinallce, a Site Plall
review by the Plallllillg Commissioll is required before a determillatioll on whether to
issue or delly the ZOllillg Permit call be made. The applicant has granted Plainfield
Township an Extension of Time for the recommendations of the Planning Commission
concerning the site plan to be forwarded to the Zoning Officer by May 31, 2017. The
applicant has granted the Township an Extension of Time for the final decision from the
Zoning Officer on whether to issue or deny the Zoning Permit until June 30, 2017. The
Extension of Time is incorporated herein within this letter for reference as an enclosure.

The applicant has requested that the Application and Site Plan review take place at the
May 15, 2017 Planning Commission meeting at 7:00 P.M. The location is tentatively set
for the Wind Gap Middle School (1620 Teels Road, Pen Argyl, PA 18072).

This review letter was prepared by the Plainfield Township Zoning Officer in conjunction
with the Plainfield Township Manager/Alternate Zoning Officer. All references to the
Township Engineer in this letter shall mean the appointed Alternate Township Engineer
for this project, which is Hanover Engineering Associates, Inc., with Mr. Farley Fry, P.E.
and Robert Lynn, P.E. representing.

If there are any questions or if additional information is required, please do not hesitate to
contact the undersigned officials.
Sincerely,

f1:L'!i;'L
Zoning Officer

Sincerely,

~--
Thomas Petrucci
Township Manager
Alternate Zoning Officer

Enclosures (Building Code Official Ltr. dated 417/2017; Ext. of Time dated 4/5/2017)

Cc: Plainfield TO\"llship Board of Supervisors, Individually

Plainfield TO\\llship Planning Commission, Individually
Joyce Lambert, Plainfield Township Planning Commission Secretary
James Hecht, Synagro Project Manager (via email only)
David Backenstoe, Esq., Plainfield Township Solicitor
Farley Fry, P.E., Township Engineer for Synagro Applications
Robert Lynn, P.E. Township Engineer for Synagro Applications

Synagro Alternate Site Zoning Permit Application Review Letter 16

 Letter of Transmittal
Plainfield Township
To: Matthew Goodrich, Esq. Date: 4/11/2017

Attention: Matthew Goodrich, Esq. /Jessica McClain, Administrative Assistant

If enclosures are not as noted, please notify our office.

Sender's Name: Thomas Petrucci

TitleIPosition of Sender: Township Manager

Sender's Address: Plainfield Township Municipal Building, 6292 Sullivan Trail, Nazareth, PA 18064
Telephone: 610-7596944 ext 102

Recipient's Name: Matthew Goodrich, Esq.

Recipient's Tit1e1 Position: Applicant's Authorized Representative/Attorney

Recipient's Organization Name: Karasek Law Offices, LLC.
Recipient's Street Address: 641 Market Street, Bangor, PA 18013
Method of Delivery: UPS Ground- Tracking # IZ377E240338198931

Applicant- Synagro Technologies, Inc.

Subject Properties- Tax Map Parcel ID# E8 12 1 0626 and E8 12 IA 0626
Owner- Grand Central Sanitary Landfill, Inc. /Grand Central Real Estate Co., Inc.
Zoning District- Solid Waste Processing and Disposal District (SW)

Dear Attorney Goodrich:

Enclosed please reference the following materials for the above-referenced matter:

Zoning Officer review letter for the Synagro Technologies, Inc. Zoning Permit Application and
Site Plan dated and received 3/31/2017
Building Code Official Response dated 41712017
Copy of Extension of Time dated 4/5/2017

If you have any questions or require additional information regarding this matter, please contact me at
610-759-6944 ext 102 or via email atmanaertw .. lainfield.a.us

Sincerely,

~d=
Thomas Petrucci, Township Manager Date: 4/11/2017
 KEYCODES
INSPECTION AGENCY

1307 West Lehigh Street info@keycodes.net

Bethlehem, Pennsylvania 18018 www.keycodes.net
610-866-9663 Office

Review Comment List Page 1

Project Number: AlO0754

Project: Synagro Technologies, Inc. - Grand Central Sanitary Landfill Date: 04/07/17

Authority Having Jurisdiction: Plainfield Township

Plan Reviewer: Dave Shields

Code(s) of Record: PA UCC

Please note that a review for compliance with the PA Uniform Construction Code could not
be performed as there was no Building Permit application or any associated documents for
buildings, structures or alterations relevant to the PA UCC submitted for review. Once these
documents are submitted in triplicate to the Township, a review for compliance with the PA
UCC will be done.

Sincerely,

~~/~co
David Shields, Construction Code Official
 KARASEK LAW OFFICES, LLC
641 MARKET STREET
BANGOR, NORTHAMPTON COUNTY,
PENNSYLVANIA 18013
TELEPHONE (610) 588-0224
TELEFAX (610) 588-2088

Ronold J. Karasek, Esquire

Matthew J. Goodrich, Esquire

April 5, 2017
Tom Petrucci
Plainfield Township Manager
6292 Sullivan Trail
Nazareth, PA 18064

VIA EMAIL AND REGULAR MAIL

RE: Grant of Time Extension

Dear Mr. Petrucci,

Synagro is granting an extension of time to both the Planning Commission and

Zoning Hearing Board to make a recommendation and hold a Zoning Hearing with
respect to the application filed on March 31,2017. My client respectfully requests that
this matter be tabled and removed from the agenda of the April 17,2017 Planning
Commission Meeting.

We look forward to working with the Township on this project and ask that the
plan be placed on the May 15, 2017 Planning Commission agenda. I have enclosed the
executed Extension of Time form that you provided previously.

Very truly yours,

KARASEK LAW OFFICES, LLC

. MatthewJ. Goodrich, Esquire

M~G
Gq: Client
 EXTENSION OF TIME
On behalf of the A.pplicant, Synagro Technologies, Inc., I, Matthew J. Goodrich, Esq., hereby
waive any applicable requirements of the Commonwealth of Pennsylvania Municipalities
Planning Code (MPC) and the Plainfield Township Zoning Ordinance which mandate that the
Planning Commission render a recommendation to the Zoning Officer on the Site Plan
application submission within forty-five (45) days from the time that the Site Plan application
was received. The Site Plan Application was received on March 31, 2017.
On behalf of the Applicant, Synagro Technologies, Inc., I, Matthew J. Goodrich, Esq., hereby
grant an Extension of Time for the Planning Commission to provide a recommendation of the
Site Plan to the Zoning Officer until May 31, 2017. The Extension of Time shall cover the
period of time from March 31,2017 until May 31, 2017. The Planning Commission shall
have until May 31, 2017 to render a recommendation to the Zoning Officer on the Site
Plan.
In addition, the Applicant hereby waives any applicable requirements ofthe Commonwealth of
Pennsylvania Municipalities Planning Code (MPC) and the Plainfield Township Zoning
Ordinance which mandate that the Zoning Officer either issue or deny the Zoning Permit within
sixty (60) days from the time that the Site Plan application was received. The Site Plan
Application was received on March 31,2017.

On behalf ofthe Applicant, Synagro Technologies, Inc., I, Matthew J. Goodrich, Esq., hereby
grant an Extension of Time for the Zoning Officer to either issue or deny the Zoning Permit until
June 30, 2017. The Extension of Time shall cover the period of time from March 31, 2017
until June 30, 2017. The Zoning Officer shall have until June 30, 2017 to either issue or
deny the Zoning Permit and communicate said decision to the Applicant.
This Extension of Time is granted in reference to the Synagro Technologies, Inc. Material
Separation Facility "Slate Belt Heat Recovery Center" Zoning Permit Application dated March
31,2017 and the Site Plan Application dated March 31, 2017 (identified and named as the "Slate
Belt Heat Recovery Center" Site Plan) and received by the Township Manager at the Plainfield
Township Municipal Office on March 31, 2017.

Date: 'i Is 1..--J1-.!.-- _

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