Below is the text of a letter Sustainable Saratoga sent to the Town of Moreau Planning Board and Town Board regarding the proposed Saratoga Biochar Solutions plant in the Moreau Industrial Park.
April 7, 2023
To: Town of Moreau Planning Board, Town of Moreau Town Board
Saratoga Biochar Solutions is a company seeking to build a large biochar plant in the Moreau Industrial Park using biosolid human waste as the feedstock. The Moreau Planning Board, an appointed body with no background in biochar manufacturing or its potential problems, authorized the plant on a 4 to 2 vote in late 2022. The New York State Environmental Quality Review Act (SEQR) provides a guide for local governments to ensure that environmental considerations are incorporated into their planning processes. Saratoga Biochar’s proposed facility raises many potential environmental concerns including air emissions of nitrogen dioxides, the persistence of PFAS and other contaminates in the final biochar product, potential spills, and noise and odor impacts. Despite these concerns, the Planning Board concluded the SEQR process with a negative declaration rather than requiring further study through an Environmental Impact Statement.
This situation is particularly troubling because Saratoga Biochar Solutions has never built or operated such a plant and the technology needed to safely use biosolid human waste as a feedstock is not widely accepted. . The plant is expected to process 15% of the biosolid human waste produced in New York State to make biochar in a process known as pyrolysis. Biosolid waste contains polyfluoroalkyl substances, commonly known as PFAS, which are toxic “forever chemicals” that do not break down under natural conditions. Although the Saratoga Biochar Solutions executive team assures us that the pyrolysis process used in the plant will break the PFAS bonds, a 2021 research brief issued by the EPA says more research must be done to verify that pyrolysis can in fact break apart the chemicals. PFAS are associated with serious health risks, including cancer, developmental delays in children and decreased fertility. Likewise, nitrogen dioxide, a byproduct of the pyrolysis process, is known to pose risks to human health. Without further review and an environmental impact study, it is not clear if Saratoga Biochar’s plans to mitigate the release of nitrogen dioxide is sufficient to protect the community from these harmful emissions.
The executive staff of Saratoga Biochar Solutions has no experience in biochar manufacture, and are businessmen, not scientists or engineers. The reassurances by the company are not based on years of experience or well-tested technology and may be overly optimistic.
The Planning Board and elected officials in Moreau should rethink the review process. The Planning Board does not have the necessary skill set to evaluate a new technology like that planned for the biochar plant and should not simply rely on the applicants to determine whether or not the plant has potential negative environmental impact. The Town of Moreau and its neighbors should engage in serious environmental review with a qualified third-party environmental consultant before deciding to site the plant in the Moreau Industrial Park. Sustainable Saratoga asks the Planning Board to conduct a due diligence environmental review of the plant before allowing it to proceed any further. A complete and careful environmental review is warranted to make sure that our neighbors in South Glens Falls, Moreau, Fort Edward and Hudson Falls are not subject to serious health risks from the proposed biochar plant and that the end product is free of PFAs and other contaminants.
Yours Truly,
Dianna Goodwin
Chair, Sustainable Saratoga
