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Revised Zoning Permit Application Proposed Slate Belt Heat Recovery Facility May 30, 2017 Page 2 of 24

followed by our responses are below each item as indicated by “response. Below is the first comment from Page 2 of the April 11, 2017 letter:

The Application for Plan Examination and Building dated March 31, 2017 references the proposed use as Industrial, Tanks and Towers, and Agricultural Industry S31l.5 (B)/ S3ll.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).

Response: The applicant concurs with the above comment. The Project complies with all of the referenced design requirements as discussed in detail below and operation of the Facility will comply with all of the referenced operational requirements

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:

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.

two (2) additional acres of land for each additional capacity of one hundred (100) tons per

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The applicant shall clearly delineate the acreage of the proposed Synagro lot (7.01 acres) that is not impacted by steep slopes, slate spoils, and the Sediment Basin No. 2 as shown on the Site Plan. Based on the information and Site Plan submitted, the Zoning Officer has determined that this requirement has not been met.

Considering the provisions of Section 315 (B) (35) that require an additional two (2) acres of land for each one hundred (100) tons per day, the Zoning Officer recommends that the applicant shall provide daily tonnage receipt reports to the Township during the operational life of this facility as a condition of any future approval in order to ensure continued and ongoing compliance with this provision in perpetuity.

Response: The Zoning Ordinance defines lot area as “the area within the lot lines, excluding space within all existing and future road rights of way.” In that regard, the lot area is not limited to the developable/buildable area, and previous applications and Township approvals within the Solid Waste District have similarly employed the Zoning Ordinance definition and have not excluded steep slopes, slate spoils or sedimentation basin areas from the acreage of the site. The resulting lot area provided for the Facility as documented in the Site Plan is five acres, sufficient for a facility that will accept up to four hundred (400) tons of solid waste per day.

Regarding the request that the Applicant provide tonnage reports to the Township, the Applicant agrees to this request and will provide the requested tonnage reports. Five (5) acres was the minimum applied as 400 tons per day of solid waste is the anticipated throughput of the biosolids. The term “solid waste” is specifically addressed in Section 315(b)35.a of the Plainfield Township Zoning Ordinance and was utilized for the site area.

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.

Entrances and exits to the facility are not separated and clearly designated on the Site Plan. Pursuant to the requirements set forth 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 an arterial or collector road. There is not a separate entrance and exit to the facility shown on the Site Plan. Further, the entrance and exit to the facility is not located along either an arterial or collector road. Therefore, the conditions and provisions associated with this additional requirement are not being met.

In addition, the applicant shall provide the Zoning Officer with a drawing that shows the proposed traffic pattern for the entire site. It is not clear to the Zoning Officer based on what was submitted how the vehicular truck traffic is moving through the interior parallel roads of the Grand Central Sanitary Landfill.

how the vehicular truck traffic is moving through the interior parallel roads of the Grand Central

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Response: The plan has been revised to show the traffic pattern for the entire site.

c. All access roads shall be paved.

The proposed driveway and the loading/outgoing access roads are not clearly shown as paved on the Site Plan. Therefore, this provision is not being met as currently proposed.

Response: The plan has been revised to show the proposed driveways, access roads, and loading areas to 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.

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

satisfaction of the Township Engineer, Fire Chief, Slate Belt Regional Police

Department Chief, Zoning Officer, Building Code Official and the Emergency Management Coordinator.

Response: The Applicant will comply with the Ordinance. A written report demonstrating facility compliance with the applicable codes and standards will be submitted by the applicant as part of the building permit submission. An overview meeting with the Plainfield Fire Department has already occurred and Applicant is awaiting feedback from the Department. The applicant will coordinate with the first responders to determine if the input received to date will be impacted by either site location.

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.

In order for the Zoning Officer to make a determination regarding this provision,

additional information is required and requested from the applicant as to how each item listed above will be specifically addressed. Some of these items are also listed within Article 5 as set forth below. It is the 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), pursuant to Section 410 of the Zoning Ordinance.

testing laboratories (with the costs to be borne by the applicant), pursuant to Section 410 of

Revised Zoning Permit Application Proposed Slate Belt Heat Recovery Facility May 30, 2017 Page 5 of 24

Response:

construction, the Facility will operate pursuant to environmental regulatory and permitting requirements and will have a continual duty to comply with all applicable and required regulations and permit requirements as they are controlled and regulated by the Agencies of the Commonwealth of Pennsylvania and the United States of America. Copies of all approvals / permits will be provided to the Township as they are obtained. Specific compliance with operational requirements cannot be demonstrated in advance of the approval, construction and actual operation of the Facility, but will be provided to the Township once the Facility is operational to show continued compliance following approval.

The Applicant will comply with this ordinance. Following approval and

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

The Zoning Officer cannot make a determination at this time as to whether the operation of the facility is in compliance with all applicable State and Federal regulations. The following information shall be provided before any zoning or building permits can be issued to the satisfaction of the Zoning Officer, Planning Commission, and the Township Engineer:

1.

Evidence

of PennDOT

Highway

Occupancy Permit

compliance,

as

applicable.

2. Evidence of Act 537 (Pennsylvania Sewage Facilities Act) compliance from the Pennsylvania Department of Environmental Protection.

3. Evidence of Water Obstruction Act of 1913 compliance.

4. Evidence of Solid Waste Management Act, Act 97 of 1980 (including amendments) compliance from the Pennsylvania Department of Environmental Protection.

5. Evidence of Municipal Waste Planning, Recycling and Waste Reduction Act

compliance from the Pennsylvania Department of Environmental Protection.

Department

of Environmental Protection as to whether the proposed facility is defined as a

"Resource Recovery Facility" as set forth Recycling and Waste Reduction Act.

Clarification is required from the Commonwealth of Pennsylvania

in the Municipal Waste Planning,

6. Evidence of Act 167 Stormwater Management Act/Plainfield Township Stormwater Ordinance (Bushkill Creek, Martins/Jacoby Creek and Delaware River Sub-Basin I Watersheds Act 167 Stormwater Management Ordinance).

A review from the Lehigh Valley Planning Commission (LVPC) is required.

Act 167 Stormwater Management Ordinance). A review from the Lehigh Valley Planning Commission (LVPC) is required.

Revised Zoning Permit Application Proposed Slate Belt Heat Recovery Facility May 30, 2017 Page 6 of 24

7.

Evidence of Federal Water Pollution Control Act Amendments of 1972 (Section 404, 33, U.S.C. 1334) compliance.

8.

Evidence of Clean Streams Law compliance from the Pennsylvania Department of Environmental Protection and the Northampton County Conservation District (including but not limited to Chapter 93, Chapter 102 and Chapter 105).

9.

Evidence of Clean Air Act compliance from the Pennsylvania Department of

Environmental Protection Bureau of Air Protection Agency (EPA), as required.

Quality and the Environmental

10. Jurisdictional determinations from the Army Corps of Engineers and the Pennsylvania Department of Environmental Protection (PA DEP) as to whether the Sedimentation Basin No. 2/Sediment Pond as shown on the Site Plan are considered to be "Waters of the United States" or "Waters of the Commonwealth".

11. Evidence of Pennsylvania Natural Diversity Inventory (PNDI) compliance.

12. Evidence of compliance with all applicable Pennsylvania Historical and Museum Commission notification requirements.

13. Evidence from the Pennsylvania Department of Environmental Protection that the proposed site is in compliance with the current approved Operating Permit of the Grand Central Sanitary Landfill (Facility ID No. 100265).

14. Evidence that the proposed Wastewater Treatment Plant Area is compliant with all applicable Pennsylvania Department of Environmental Protection and Delaware River Basin Commission requirements, provisions 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 proposed fill-in and reduction in size of the Sediment Basin No. 2 is approved by the Pennsylvania Department of Environmental Protection. An enlargement or reduction in size of a Sediment Basin/Pond can only be approved by the Pennsylvania Department of Environmental Protection. A revision to NPDES Permit No. PA 0070483 is likely required. In addition, evidence is required from the Pennsylvania Department of Environmental Protection that confirms that the use of the Sediment Basin No. 2for this proposed facility is in compliance with the current approved Operating Permit of the Grand Central Sanitary Landfill (Facility ID No.

100265).

in compliance with the current approved Operating Permit of the Grand Central Sanitary Landfill (Facility ID

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16. Evidence from all of the applicable State and Federal agencies that all required State and Federal permits that are required to legally operate a facility as proposed for this site have been obtained by the applicant.

Response: Applicant will comply with this ordinance requirement.

states that the operation of the facility shall comply with all applicable State and

Federal regulations. Specific compliance with such operational requirements cannot be demonstrated in advance of the approval, construction and actual operation of the Facility, but the Applicant acknowledges that all pertinent Federal, State and/or

County permits will need to be secured in order to proceed with the Project. The zoning application provided general descriptions of the proposed environmental controls for air, water, and land pollution prevention and the permit applications to be submitted to PADEP will provide further details on the control measures and demonstrate compliance with applicable environmental regulations. The Applicant

will

approvals/permit/authorizations/clarifications issued by the pertinent agencies upon receipt. The Applicant understands and agrees that compliance with all applicable State and Federal laws and regulations during the lifetime of Facility operations is a condition of approval by the Township, and compliance testing will be performed at the Facility as required by the applicable regulations and/or permit conditions and will be provided to the Township upon request. Applicant disagrees that evidence of compliance from all the referenced State and Federal agencies is required at this point in the zoning approval process since the Zoning Ordinance requires operational compliance by the Facility, not prior approvals from all relevant agencies, but Applicant will nonetheless provide the Township with all the requested compliance information in the course of the development, construction and operation of the Facility consistent with the standard protocol for local zoning approval by the Township.

The provision

provide

the

Township

with

copies

of

all

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

Section 501 Environmental Preservation Required. The applicant shall furnish proof to the Township to the satisfaction of the Township Engineer and the Zoning Officer that the use provides for the preservation and the minimum destruction of natural drainage areas, minimum grading and destruction of the ground surface, the preservation of substantial stands of trees and forested areas, and the preservation of attractive views and any other natural amenities

The site

has been an active industrial site for nearly a century as documented on historical aerial photographs which have been provided in the enclosed Steep Slopes Narrative. The proposed facility will not alter the existing drainage, requires minimal grading, and the area has no forested area. The proposed facility will be situated within an existing, developed, reclaimed mining area and will not negatively impact any attractive views or natural amenities considering the surrounding topography and land uses.

Response: The Applicant will comply with Ordinance Section 501.

considering the surrounding topography and land uses. Response: The Applicant will comply with Ordinance Section 501.

Revised Zoning Permit Application Proposed Slate Belt Heat Recovery Facility May 30, 2017 Page 8 of 24

Section 502 Nuisances Prohibited. The applicant shall furnish proof to the Township that the proposed structure shall not be used or occupied in a manner that creates a dangerous, injurious, noxious, or otherwise objectionable condition, fire, explosion, or other hazards, heat, electromagnetic or other radiation, noise or vibration in violation of Plainfield Township noise regulations under Section 410, smoke, dust, odor or other form of air pollution, or any other condition in such manner or on such amount as to adversely affect the reasonable use or value of the surrounding area or adjoining premises or be dangerous to public health or safety.

Response: The Applicant will comply with Ordinance Section 502. As noted above, the Facility will operate pursuant to PADEP permitting and regulatory requirements, which are specifically designed to prohibit the creation of any dangerous, noxious, or otherwise objectionable condition. Consistent with the applicable requirements, Facility operations will be contained within the confines of the proposed building with the exception of the unloading and loading, which will include dust and odor management controls to minimize nuisances despite being outside the confines of the plant building. As any business in the Township, the Applicant will be required to provide a safe working environment for its employees. Potential external nuisances are further addressed in the response to comments below.

Section 503 Steep Slopes. As noted elsewhere in this letter, the applicant shall furnish proof of 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).

Response: The Project complies with the Ordinance Section 503 as amended by Ordinance No. 356. A Steep Slope Narrative has been enclosed for the Township’s review and approval. The narrative concludes that all steep slopes in the project vicinity are man-made (e.g. quarry highwalls and reclaimed quarry slopes, quarry waste rock piles, landfill side slopes) which was verified with aerial photos, historical photos, and historical topographic documentation. As a result, to the extent that any Project-related slope area falls within the Steep Slope Overlay District, it would expected to be classified under Ordinance No. 356 as a “Class C Steep Slope” since it consists of man- made slopes that naturally contained less than a 15% grade. Because permitted uses and development of such Class C Steep Slopes include “all uses in compliance with the provisions of the underlying district, which are not prohibited by any other Ordinance,” Ordinance No. 356 does not pose any independent restrictions on the Project.

Section 504 Areas with High Water Table. Proof shall be furnished to the Township that the proposed land use will not directly or indirectly result in the pollution of the groundwater. Such a use would be prohibited from developing

not directly or indirectly result in the pollution of the groundwater. Such a use would be

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in any area which has a year-round or seasonal high water table which comes to within any distance of the ground surface, which violates Pennsylvania Department of Environmental Protection regulations. The determination of such hazards shall be made by the appropriate State agency and/or by a qualified sanitary engineer, geologist or soil scientist approved by the Board of Supervisors.

the

Ordinance.PADEP administrates the Regulations set forth by that Agency. The Applicant will comply with all applicable PADEP requirements, and determination of substantive compliance with those requirements rests with PADEP as reflected in Ordinance Section 504. Sedimentation Basin No. 2 (former Doney #2 quarry) does connect to groundwater, but is a permitted and regulated erosion and sediment control facility which is covered under the landfill’s NPDES permit. Per previous comment, modification of the basin will be required and will be processed through PADEP, the regulating Agency with subsequent evidence of approval to be provided to the Township.

Response:

The

applicant

will

comply

with

Section

504

of

Section 505 Development Along Waterbodies. The proposed Site Plan does not appear to be in compliance with Section 505 (Development Along Waterbodies) of the Plainfield Township Zoning Ordinance. Pursuant to Section 505 of the Zoning Ordinance, all areas within fifty feet (50') of the banks of any streams, lake or pond shall be in open space. There is not fifty feet (50') of open space between the proposed structures/improvements and the sediment pond; the Zoning Officer has determined that this requirement has not been met. The proposed Site Plan identifies the sediment pond/basin as "Existing Streams/Ponds" on Sheet 2 of 4. The fifty feet (50') of open space requirement between the pond and all proposed structures/improvements is not being met in the determination of the Zoning Officer.

Response: Enclosed is a copy of the PADEP approval to install the sediment basin as a developed water resource and not a naturalized water impoundment. Sedimentation Basin No. 2, formerly the man-made Doney #2 quarry, is a regulated erosion and sedimentation control facility, not a stream, lake or pond. The drawing will be revised to characterize the basin accordingly. As such, this requirement is not applicable to the instant Application and is controlled/regulated by PADEP.

Section 506 Alluvial Soils Areas. The applicant shall furnish proof to the Zoning Officer that the areas proposed for the development are not within an ''Alluvial Soils" area.

Response: The Applicant is in compliance with Ordinance Section 506. Soils from the County soil survey are currently depicted on the site plans. Existing soils are mapped as “PQ – Pits, Quarries”, which is not an “alluvial soil.”

on the site plans. Existing soils are mapped as “PQ – Pits, Q uarries”, which is

Revised Zoning Permit Application Proposed Slate Belt Heat Recovery Facility May 30, 2017 Page 10 of 24

Section 507 Flood Plain Regulations. 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 is not within Zone A. Compliance with Ordinance No. 368, which was duly adopted June 11, 2014 and amended Section 507 (entitled Flood Plain Regulations) of the Plainfield Township Zoning Ordinance, is required.

Response: The Applicant complies with Ordinance Section 507. The Site plans have been revised to incorporate the Floodplain associated with Waltz Creek. As demonstrated in the revised Site Plan, the project is not located within Zone A of the floodplain.

Section 508 Filling, Excavation and Grading. All NPDES, Northampton County Conservation District and Department of Environmental Protection regulations shall apply to this proposed use. The applicant shall furnish proof that Section 508 of the Township shall be complied with. A zoning permit is required before any activities that require the moving of earth or the filling or excavation of an area can commence.

The Applicant will comply with the Ordinance. Section 508.

Applicant acknowledges that authorization from PADEP and/or NCCD is required prior to commencement of earth moving activities and Applicant will

provide such authorization to the Township upon receipt.

Response:

Section 509 Outdoor Storage Control. The Applicant shall identify whether any outdoor storage facilities are proposed.

Response: No outdoor storage facilities are proposed for this permitted use. The Applicant is in compliance with the Ordinance Section 509.

Section 510 Sewage Waste Treatment and Disposal Control Evidence of Act 537 (Pennsylvania Sewage Facilities Act) compliance from the Pennsylvania Department of Environmental Protection shall be required.

Response: The Applicant will comply with Ordinance Section 510. Specifically, PADEP Sewage Facilities approval will be provided to the Township following completion of the Act 537 plan revisions relative to the proposed sanitary facilities for the center.

Section 511 Noise Control. The applicant shall furnish proof that the proposed use is in compliance with the Sound Level Limits by Receiving Land Use and time as set forth in Section 511A of the Zoning Ordinance. Sections 511B, C, D and E shall apply for an Industrial use.

time as set forth in Section 511A of the Zoning Ordinance. Sections 511B, C, D and

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Response: The Applicant will comply with Section 511 of the Ordinance. The proposed process equipment will be located within an enclosed structure which will reduce sound levels and the Facility will comply with the Township requirements as noted in the application.

Section 512 Vibration Control. The applicant shall furnish proof of compliance with Section 512 to the Township.

Response: The Applicant will comply with Ordinance Section 512 as noted in the application and will ensure that proposed equipment to be used at the Facility will comply with the referenced Township requirements.

Section 513 Dust, Dirt, Smoke, Vapors, Gases and Odors Control. The applicant shall furnish proof of compliance with Section 513 to the Township.

Response: The Applicant will comply with all Ordinance requirements contained within Section 513. Currently compliance is noted in the application. The Applicant maintains the proposed equipment will comply with the referenced Township requirements. The facility operation incorporates a comprehensive engineered odor control system for the mitigation of dust, dirt, vapors and odors. No smoke or gases will be generated by the process. Further, the Applicant will submit an air quality permit application to the PADEP and will be responsible for complying with the applicable regulations and permit requirements upon issuance.

Section 514 Light, Glare and Heat Control. The applicant shall furnish proof of compliance with Section 514 to the Township.

Response: The Applicant will comply with Ordinance Section 514 as noted in the application and will submit a lighting plan to the Township to details steps that will be taken to address light and glare.

Section 515 Electric, Diesel, Gas or other Power. The applicant shall furnish proof of compliance with Section 514 to the Township.

Response: The Applicant will comply with Ordinance Section 515 as noted in the application. That section states:

ELECTRIC. DIESEL, GAS OR OTHER POWER. Every use requiring power shall be so operated that any service lines, substation, or other facility shall:

A. Conform to the highest applicable safety requirements,

B. Be constructed and installed as an integral part of the architectural features of the plant, and

safety requirements, B. Be constructed and installed as an integral part of the architectural features of

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C Substations or other structures must be concealed by evergreen planting from residential properties.

Applicant will ensure that each of these referenced requirements applicable to uses requiring power will be met at the Facility.

Section

Disturbances. The applicant shall furnish proof of compliance with Section 516 to the Township.

Electrical

516

Control

of

Radioactivity,

Electrical

Emissions

and

Response: The two (2) parts of Section 516 are as follows:

A. No person shall operate or permit the operation of any device or conduct or permit any use to be conducted which does not comply with the regulations of the Pennsylvania Department of Environmental Protection's Division of Radiology, the Federal Nuclear Regulatory Commission, and the Federal Nuclear Regulatory Commission.

B. No person shall conduct or permit any use to be conducted which causes electrical disturbances (except from domestic household appliances) to adversely affect any equipment at any time other than the equipment creating the disturbance.

The Applicant will comply with the Ordinance Section 516 and all required Agency permitting requirements as noted in the application.

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 specific types of equipment, machinery and devices are installed 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 shall be in accordance with Section 410 C and D of the Plainfield Township Zoning Ordinance and all applicable State and Federal regulations.

Response: The Applicant will comply with Ordinance Section 410. Applicant will

comply with this ordinance requirement.

performance standards cannot be demonstrated in advance of the approval, construction and actual operation of the Facility, but the Applicant acknowledges that all pertinent Federal, State and/or County permits will need to be secured in order to proceed with the Project. Those permits are designed to require the

Specific compliance with operational

in order to proceed with the Project. Those permits are designed t o require the Specific

Revised Zoning Permit Application Proposed Slate Belt Heat Recovery Facility May 30, 2017 Page 13 of 24

performance demonstrations as reflected in the Ordinance and the zoning application provided general descriptions of the proposed environmental controls for air, water, and land pollution prevention. The permit applications to be submitted to PADEP will provide further details on the control measures and will demonstrate compliance with applicable environmental regulations. The Applicant will provide the Township with copies of all approvals/permit/authorizations/clarifications issued by the pertinent agencies upon receipt. The Applicant understands and agrees that compliance with all applicable State and Federal laws and regulations during the lifetime of Facility operations is a condition of approval by the Township, and compliance testing will be performed at the Facility as required by the applicable regulations and/or permit conditions and will be provided to the Township upon request. Applicant disagrees with any suggestion that evidence of compliance from the referenced State and Federal agencies is required at this point in the zoning approval process since the Zoning Ordinance requires performance compliance by the Facility, not prior approvals from all relevant agencies, but Applicant will nonetheless provide the Township with all the requested compliance information in the course of the development, construction and operation of the Facility consistent with the standard protocol for local zoning approval by the Township.

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.

Response: The Applicant is in compliance with the Ordinance. The necessary information on vehicular traffic associated with the proposed facility is included with the project narrative. Upon receipt of the Township Engineer’s review letter, the applicant will address any remaining comments/concerns and will meet all Traffic impact requirements contained in Section 410 of the Ordinance.

The following dimensional requirements will apply to the proposed facility located within the Solid Waste Processing and Disposal District as per Section 318 H, I, and J of the Zoning Ordinance:

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

Response: The Applicant meets the requirement of the Ordinance Sections 318 h-j et seq.

b. Minimum Lot Width: 200 feet.

The Applicant meets the re quirement of the Ordinance Sections 318 h-j et seq. b. Minimum

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Response: The Applicant meets the requirement of the Ordinance.

c.

Maximum Building Coverage: 25%

Response: The site plan has been revised to comply.

d.

Maximum Building Height: 50 feet.

Response: The Applicant meets the requirement of the Ordinance.

e.

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

Response: The Applicant meets the requirement of the Ordinance.

f.

Maximum Impervious Coverage: 45% (318 J Maximum Impervious Coverage in in the Solid Waste Processing and Disposal District)

Response: The site plan has been revised to comply.

g.

Front Yard: 50 feet.

Response: The Applicant meets the requirement under the Zoning Ordinance.

h.

Side Yard: 25 feet each/50 feet both.

Response: The Applicant meets the requirement under the Zoning Ordinance.

i.

Rear Yard: 50 feet.

Response: The Applicant meets the requirement under the Zoning Ordinance.

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.

Response: The plan has been revised to note 65-feet, consistent with the project narrative and meets the Ordinance.

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.

Alternate Facility Siting Plan shall be revised to reference the correct dimensional requirements as set forth

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Response: The dimensional requirements as noted above have been revised in the project narrative and plans as requested and noted.

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.

Response:

submitted and this is not uncommon in a unified development. There are no landscaping/buffer yards requirements that would require the two (2) lots to be physically separated. The application complies with the Ordinance. There is a longstanding relationship of this type already in existence between the Green Knights LFGTE and the existing Landfill occupant/owner.

A cross access agreement between the two (2) tenants will be

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.

Response: This requirement is not applicable under the Ordinance as no part of either of the proposed lots are using overlapping lot or yard requirements. The Applicant will comply with the Ordinance and requests clarification as to its alleged applicability.

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. The existing Switch Gear of the Green Knights Energy Center is proposed to be located on a separate parcel/lot 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.

Response: The switch gear will remain on the Green Knights lot. Wastewater Treatment Plant will not be used for the Green Knights facility and/or Landfill and shall only be used for the Material Separation Facility.

Geotechnical Site Investigation Report. A Geotechnical Site Investigation Report for the proposed site to the satisfaction of the Township Engineer shall be provided.

Site Inv estigation Report for the proposed site to the satisfaction of the Township Engineer shal

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Response: A courtesy copy of the Geotechnical Report was previously supplied to the Township Engineer for Site #1. Although it is not a specific requirement under the Ordinance, as a further courtesy the Applicant will provide a copy of further and forthcoming Geotechnical reports in the same fashion and upon completion.

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.

Response: Upon receipt, a copy of the utility provider's approval of the relocation of the utility facilities shall be furnished to the Township. All requests related to the relocation plan and operation of utilities shall be provided.

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 Corners) for all sightlines at intersections of driveways or access ways with streets.

Response: The Applicant will comply with the Ordinance. Section 404c

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 terms of whether the proposed operating hours are not in conflict with the current Grand Central Sanitary Landfill Operating Permit and all other applicable Plainfield Township ordinances.

Response: Clarification will be requested from DEP on any potential conflicts on proposed operating hours and will comply with all State and Federal Regulations regarding the same. The Landfill has restrictions on open hours of operation for accepting incoming waste and the Facility will operate under the same hour constraints as the Landfill. Incoming/outgoing traffic may be restricted by DEP,

which is the delegated authority for such regulations.

as conditions of the authorization from DEP. All parts of the Ordinance will be met

along with all Regulatory Agency requirements as to Operations.

Any restrictions will be noted

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.

Response: No driveways are proposed onto Township roads. The two (2) driveways to be utilized for the proposed facility will be connected to the Landfill access road which is a private access road and also serves the Green Knights facility. The driveway ordinance is not applicable with respect to driveways.

road and also serves the Green Knight s facility. The driveway ordinance is not applicable with

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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.

Response: An application for land development and subdivision approval will be

filed by the applicant.

applicable State and Federal Regulations of the same.

The Applicant will comply with the Ordinance and

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 proposed access road is owned in part by Plainfield Township (Tax Map Parcel ID# E8 14 IA 0626E) and temporary use of the 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.

Response: The enclosed easement agreement referenced does not specify the landfill and/or associated operations. The agreement states that “(t)he parties recognize that, at some time in the future, Grand Central Real Estate and/or GCS’s need for the easement granted under paragraph 7 may cease.” There is no specific timeframe or event noted that would trigger the easement to cease. Such a cessation can only be initiated by Grand Central Real Estate and/or GCS. The agreement speaks for itself. The agreement does not operate to the detriment of the proposed use. A copy of said easement is attached to the instant application. The applicant will adhere to the easement agreement as drafted.

The metes and bounds of Tax Map Parcel ID# E8 141A 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 141A 0626E parcel.

Response: The recorded subdivision plan was included in the original submission to The metes and bounds of Tax Map Parcel ID# E8 141A 0626Eare incorporated in

the submitted plans.

as is applicable. The applicant will comply with the Ordinance.

The Applicant will provide the metes and bounds description

applicable. The applicant will comply with the Ordinance. The Applic ant will provide the metes and

Revised Zoning Permit Application Proposed Slate Belt Heat Recovery Facility May 30, 2017 Page 18 of 24

Impact to Future Recreation Trail. As described above, part of the proposed access road is owned by Plainfield Township. Itis 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.

Response: The trail has been relocated to avoid conflicts with the Grand Central facilities. The proposed facility will not have any adverse impact on the recreational trail. Attached is the easement agreement for the Township’s reference. The Applicant will comply with the Easement Agreement as drafted.

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".

Response: The design of the facility signage required by PA DEP will be provided

to the Township prior to installation.

state, federal and local regulations and law.

The Applicant will comply with all applicable

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, B and 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.

Response: As noted above, all steep slopes in the vicinity of the proposed facility (e.g. quarry high walls, reclaimed high walls, material stockpiles and landfill slopes) are man-made. The Steep Slopes Narrative has been enclosed to document in the form of historical aerial photography and topographic maps the same that all steep slopes onsite are manmade (Class C slopes). The Ordinance 356 does not apply as cited by the Zoning Officer.

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.

Response: Zone A from the flood map has been provided on the revised site plans. The Applicant is in compliance.

Zone A. Response: Zone A from the flood map has been provided on the revised site

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NPDES Permit Required. As over one (1) acre of disturbance is proposed for this project, Plainfield Township is not currently able to issue any 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 I 02.43 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 §102.5 (relating to permit requirements)."

Response: The Applicant will comply with all applicable PADEP permitting requirements, including any required NPDES Permit. The Applicant understands and agrees that compliance with all applicable State and Federal laws and regulations – including NPDES requirements - during the lifetime of Facility operations is a condition of approval by the Township, and compliance testing will be performed at the Facility as required by the applicable regulations and/or permit conditions and will be provided to the Township upon request. Applicant disagrees that evidence of compliance from PADEP is required at this point in the zoning approval process since the Zoning Ordinance does not require prior approvals from all relevant agencies, but Applicant will nonetheless provide the Township with the requested compliance information in the course of the development, construction and operation of the Facility consistent with the standard protocol for local zoning approval by the Township.

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 stormwater facility is required from the Pennsylvania Department of Environmental Protection. In addition, all existing stormwater facilities shall be identified on the Site Plan.

Response: A stormwater management report will be submitted as part of the land development submission to Plainfield Township. The sedimentation basin was analyzed as

part of the Act 167 compliance for the Landfill’s southern expansion as approved by the Township, LVPC, and PADEP. Modifications to the basin will be verified as part of the

permitting process for the proposed facility.

appropriate agency requirements and required Ordinance policies. Applicant disagrees with any suggestion that evidence of compliance with the current Grand Central Sanitary

The Applicant will comply with the

any suggestion that evidence of compliance with the curren t Grand Central Sanitary The Applicant w

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Landfill Operating Permit from PADEP is required at this point in the zoning approval process since the Zoning Ordinance does not require prior approvals from all relevant agencies, but Applicant will nonetheless provide the Township with the requested compliance information in the course of the development, construction and operation of the Facility consistent with the standard protocol for local zoning approval by the Township.

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.

Response: Sediment Basin 2 is a regulated sediment control facility serving GCSL

and permitted by PA DEP.

quarry to a “developed water resources” opposed to a naturalized “water

impoundment”. The applicant will be in compliance.

Enclosed is the PA DEP letter approving the reclaimed

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

Response: No response required.

and SALDO. Upon receipt of the Township Engineer’s review, the applicant will

address his comments/concerns and will comply with appropriate requirements.

The Applicant will comply with the Ordinance,

Front Lot Line. Itis 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 of the Plainfield Township Zoning Ordinance.

Response: The Applicant will comply with the Ordinance and will satisfy any pertinent requirements for the creation of a private street right-of-way to the west of the Green Knight lot and/or extension of the proposed facility’s lot to the right-of- way of Pen Argyl Road. The Applicant will comply with the 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.

Site Plan. Therefore, the requirements of this section are not currently being met as shown on

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Response: The site plan has been revised to comply with Section 703 A (7) which notes; “Parking facilities, including access drives and driveways shall be located at least ten feet from the side and/or rear lot line or shall be screened from neighboring properties by a solid fence or planting screen at least four (4’) feet.”

The Zoning section does not specifically prohibit cross access between two (2) lots. The Applicant will meet the standard for unified developments with cross access and common parking facilities.

b.Section 703 D (1) (2) (3) (4): The required dimensions shall be shown for all access drives, including the loading/offloading 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 D are not currently being met as shown on the proposed Site Plan.

Response: Section 703 D (1) specifies the minimum width of driveways along the street line. The plan complies. Section 703 D (2) specifies parallel drainage along a public street will not be interrupted (i.e. the existing gutter line will not be removed by a driveway). Section 703 D (2) specifies 50’ separation is required between any two (2) access drives along 1 street for 1lot. The plan complies. Section 703 D (4) specifies no access drive/driveway shall be closer than 30 feet to any street intersection. The plan complies.

c. Section 703 E: The applicant will provide information 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.

Response: The facility access roads, driveway and loading areas will be paved. Preliminary grading has been provided in the site plans. Grading and drainage will be addressed in more detail in the Land Development Plans. The Applicant will comply with the Ordinance. Section 703 et seq.

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 the proposed lighting to sufficiently

of th e parking areas will be achieved, the extent of the lumens and the reach

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

Response: Additional site lighting has been provided to illuminate the proposed parking spaces. The Applicant complies with the Ordinance. Section 703 (F) et seq.

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 (I) and (2) are not currently being met as shown on the proposed Site Plan.

Response: Section 703.A.7 notes that landscaping or a 4-foot high solid fence will be provided. 703 G (1) is under the heading of Landscaping and would appear to applicable to landscaping is provided in lieu of a solid fence. The Applicant is entitled to relief from this determination to allow open cross access between the proposed facility and the Green Knight LFGTE Plant.

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.

Response: Truck turning exhibits have been prepared to show sufficient maneuvering room. The Applicant will comply with the Ordinance.

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.

Response:

maneuvering room on the proposed lot. The Applicant will comply with the

Ordinance.

Truck turning exhibits have been prepared to show sufficient

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.

Response: Parking has been proposed away from the southern side of the building in order to provide separation between the loading and unloading areas. Designated cross-walk area is shown on the revised drawings and will be marked along with posting speed limit signs (15 mph) adjacent to the facilities to minimize potential hazards to vehicles or pedestrians.

s peed limit signs (15 mph) adjacen t to the facilities to minimize potential hazards to

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

Response: Section 704 B (7) incorporates the requirements for illumination 703 F and landscaping 703 G of parking areas for loading spaces. The Applicant will comply with the Ordinance.

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.

Response: The associated building plans and documents will be submitted with the application for building permit for the Building Code Official’s review. The Applicant will comply with the Ordinance.

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.

Response: Attached please find a certification and acknowledgement of the Site Plan by Grand Central Sanitary Landfill, Inc., the owner of the property.

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 of the required Site Plan review.

Response: The Applicant will comply with all legal requirements.

Commission as part of the required Site Plan review. Response: The Applicant will comply with all