Rebecca Martin Consulting: August and September 2023 debrief
Since becoming a full time consultant in July, I have been really enjoying my new role with a whole assortment of interesting and challenging case work. Going forward, I will provide a debrief on these large campaigns (in no particular order) so that you can follow along.
Stay in touch. I will, too.
Rebecca Martin
rebeccamartinconsulting@gmail.com
Hudson River Drinking Water Intermunicipal Council/Hudson 7
As a founding member and acting coordinator of the Hudson 7 since 2017, the council is near and dear to me. During my recent transition, I was pleased to be hired to put my strategic management skills to work to help develop their initiatives in 2023-2024. It’s a large list of items that include helping to establish their new 501c3, supporting the participating municipalities drinking water operators, maintaining the group’s watchdog role on key issues threatening water quality and more. The Hudson 7’s current draft goals, work plan and task timeline will all be discussed and adopted at the next Hudson 7 full council meeting on October 19.
For more information:
Beacon Island Development Coal Ash
For nearly a year, I have been working in collaboration with Captain John Lipscomb of Riverkeeper and Kate Hudson of Waterkeeper Alliance. Together, we have been looking into a matter which has the potential to adversely affect Hudson River water quality, aquatic species and their habitat in connection with the Port of Albany’s proposal to site a facility for assembling and shipping wind farm components on Beacon Island in the Hudson River.
The island is covered with 2-million tons of a mixture of fly ash that was deposited there in the past (up until 1970) by coal-fueled power plants no longer in operation, and located in the 100-year floodplain that contains tidal wetlands, is in a tidal portion of the river, and will experience increasing sea level rise and storm-driven tidal surge as the effects of climate change increase. Our overarching goal presented by this construction proposal was to prevent and/or mitigate any and all potential water quality impacts and potential impacts to aquatic species and their habitat that could result from this project if not properly addressed in its design and implementation. So far, the process has been primarily research focused to learn how other coal ash sites in flood plains have been contained long term. Although we are in full support of the development of clean energy, including wind power that is necessary to avoid and/or mitigate the rapidly accelerating impacts of climate change, we also believe that all siting, construction, and operations at clean energy projects like the Port of Albany Beacon Island proposal can and must be done in a manner that minimizes negative environmental, and river impacts to the maximum extent possible.
At the same time in November of 2022, we learned about potential changes to the EPA’s Coal Combustion Residuals (CCR) regulations and in 2023, with the changes announced to close the regulatory gap left open by the EPA’s 2015 CCR rule, we have been closely following the process to understand how the changes may impact the Beacon Island site and others like it.
“….For example, one of our founding member groups, Hudson Riverkeeper, has been engaged for years working to address coal ash dumps in the Hudson River floodplain, including dumps contiguous with the Hudson River itself. One of these sites, Beacon Island, which is currently proposed as part of an expansion of the Port of Albany, contains approximately 2 million tons of coal ash that was deposited there by the nearby Albany Steam Station, but is not on the station’s property. Groundwater is actively flowing through the site and into the tidal Hudson River, which is already a Superfund site, serves as a drinking water source for many communities, and is essential fish habitat. It seems inconceivable that EPA might promulgate new coal ash regulations designed to fill the large gaps left by the 2015 rulemaking, but not address the elephant in the room: off-site coal ash dumps situated in floodplains of important waterways and drinking water sources such as the Hudson River. We strongly urge the agency to include regulation of these massive off-site toxic pollution sources in your final rule.”
For more information:
- Tree clearing at Port of Albany puts $29.5M grant for wind facility at risk
- Disposal of Coal Combustion Residuals from Electric Utilities Rulemakings
The Port of Coeymans
I have had the privilege to continue to collaborate with the Clean Air Coalition of Greater Ravena and Coeymans on a regular basis. It’s a tremendous group of advocates with a mission to “…address the environmental and public health concerns of waste management, incineration, tire burning, and port expansion in the Town of Coeymans, New York. We are concerned with the impact all will have on the Capital District and the Hudson River, specifically on the Greater Ravena-Coeymans area. The CAC aims to build a stronger community able to create a cleaner and more equitable future for the environment, the river, and the people who live here.” Recently, we launched a new petition (the second in a series) to try to curb the Port of Coeymans expansion as planned. Following this effort, several of the advocates were both harassed and falsely accused of trespassing by Carver Companies (based on an unsworn statement by a Carver employee) while identifying plants on a public road. The group pushed back and the charges were dismissed (“Carver Companies Bully Neighbors: Two Women Speak Out”)
For more information:
Mid-Hudson Solid Waste Collective
What started as a monthly solid waste advocate “information share” call with Lower and Upper Hudson Solid Waste advocates for nearly four years has evolved to become the start of a New York State Zero Waste Coalition. It is proof that staying the course pays off.
The change came over the summer when New York Public Interest Group (NYPIRG)’s Anne Rabe visited our call to request that the group work together for a once in a decade opportunity to provide public comments on New York’s Solid Waste Management Plan. As facilitator for many years, we decided to grow this initiative and include advocates from New York City to Ithaca to get the job done. With the assistance, skill and generosity of the Manhattan Solid Waste Advisory Boards (MSWAB), we were successful (see the link below).
Last week, the group took a big step and adopted its new mission, “To transform New York State waste management policy by prioritizing waste prevention, reuse, recycling and composting and to achieve no burning and to stabilize and minimize burying. Consistent with the internationally peer-reviewed Zero Waste Hierarchy, as codified by the Zero Waste International Alliance, we organize and advocate to assure the protection of public health and nature through cost-effective pollution prevention, waste reduction, greenhouse gas reduction, and environmental justice.” It will choose its new name this week and provide public facing information for new members to sign on and participate in this important work.
For more information:
Hudson River PCBs
In pressing government agencies to make meaningful progress to restore the Hudson River and to hold GE accountable for its PCB pollution, our current coalition of partners (Riverkeeper/Scenic Hudson/Clearwater) continue to advocate for a “not protective” finding in EPA’s Third Five Year Review (FYR) of the Hudson River PCBs Superfund Site. We anticipate the FYR to drop this fall followed by a 90-day public comment period. In the meantime, we have been working to bring together Lower Hudson groups to engage the EPA on meaningful public engagement this time around…and it’s working.
For more information:
- Riverkeeper PCBs landing page
- Riverkeeper, Scenic Hudson and a coalition of partners request meaningful public engagement for Lower Hudson PCBs Study
Indian Point Decommissioning
Since the spring, I have been attending weekly Stop Holtec Coalition calls led by strong advocates from Westchester and Rockland Counties and elsewhere, facilitated by Food and Water Watch’s Santosh Nandabalan (mainly), Emily Skydel and Alex Beauchamp. They have worked tirelessly to get the “Save the Hudson” legislation (sponsored by Assemblymember Dana Levenberg and Senate Environmental Conservation Chairman Pete Harckham) passed through both the NYS Assembly (with bipartisan support) and NYS Senate (unanimously). The bill went on to be signed into law by Governor Hochul on August 18, 2023.
This legislation will help to safeguard the Hudson River (for now) from the threat of radioactive wastewater discharges (Tritium) at Indian Point by Holtec International, the firm responsible for decommissioning the nuclear power plant.
For more information:
Hudson River Anchorages
On July 25, 2023, the Coast Guard issued an information bulletin (MSIB 2023-001) which suddenly redefined the Port of New York, making the area North of Cuomo Bridge subject to the Coast Guard’s Inland Navigation Rules. Under these rules, any vessel may anchor anywhere for any duration, provided that they don’t interfere with traffic and have adequate nighttime lighting.
In June, as a proactive measure, the Hudson 7 hosted an educational forum with the Coast Guard and have since established an Anchorage committee that will continue to meet on a regular basis to discuss the council’s plans for engagement. As part of that effort, the council submitted a letter to the Coast Guard to request the Regulated Navigation Area (RNA) process as they decide whether or not to make a designation request.
More information coming soon through Riverkeeper’s Anchorage Campaign page.
The Threat of Landfill Leachate to Drinking Water in the Hudson and Mohawk Rivers
“The Hudson and Mohawk Rivers Leachate Collaborative” is an independent project that I have developed (as project manager) with my partners Jen Epstein, Data Analyst and Monica Mercola (Public Employees for Environmental Responsibility/PEER), our Legal Consultant. Together we will set out to analyze landfill leachate disposal through municipal wastewater treatment plants in the parts of the Hudson River and Mohawk River that are used as drinking water supplies. We are currently meeting with potential fiscal sponsors to fundraise for this important work that will explain the connections between solid waste and drinking water quality, the regulatory loopholes that exist in the management of landfill leachate, wastewater, and drinking water and show how landfill leachate moves from landfills to surface water, via municipal wastewater treatment plants.
More information coming soon.
KingstonCitizens.org
Established in 2006, KingstonCitizens.org is a non-partisan, grassroots, volunteer organization committed to nurturing transparency in local government through public engagement and participation. It’s a group that I have been leading for my entire career in advocacy upstate. Over the summer I build this timeline to provide a comprehensive public record of our campaign advocacy for nearly 20 years. You can review our entire history or choose from one of the 25 categories to select a campaign category that interests you. There is more work to be done on it, but it’s a start.
Recently, KingstonCitizens.org and our sister group TownOfUlsterCitizens.org came together to learn more about FEMA Reports/Maps and flooding in the Lower Esopus Creek Watershed. We expect to do more advocacy around this in the coming months to raise awareness to help protect our communities from imminent flooding, due in large part to our changing climate.
For more information: