After reading about the proposed Elcon site in Falls Township, a resident asked if there was any actual record of flooding on the 33 acre site. She recalled her experience of nearly buying a Yardley home that, unbeknownst to her, had been gutted and restored after the Delaware flooded a few years ago. She was amazed that Pennsylvania DEP would even consider such a site. What follows is my response.

While one could certainly follow up and get answers to those questions, they would only tell us more about the probability of a flood without assuring us it could not happen.  It’s a matter of risk assessment, not a matter of history.

For the sake of argument let’s assume that the Elcon site has never flooded in recorded history. That does not mean it can’t flood.  Nor does it mean that there is some level of risk that locals should accept.

The risk of flood is different with Elcon than with other businesses.  The other facilities at that location stand to lose their investment in physical assets, as would Elcon. But in the case of Elcon there will be tanks, equipment, containment ponds, and residue storage that would contaminate the river if flooded. Why accept any such risk? What is the upside public benefit? Elcon will do nothing to improve the environment where it is located; there is only downside.

What is the downside risk? Imagine a site handling large volumes of toxic liquids having a mishap: a leak, a spill, a wreck, or whatever. Why should millions of people be at risk of losing their water source for even a day?  With the facility located on a site surrounded  by the river and bodies of water that connect to the river, what possible public good is served by building it there as opposed to a less vulnerable upland location.  Just because Elcon wants it there, and their customers find it convenient doesn’t justify it.

Finally, we know that sea levels are rising and that the river is tidal at the proposed Elcon site.  With extremes of weather more likely in future years, historical risks may be a poor predictor.  Torrential rains can be expected to increase the frequency and severity of river flooding. Polar vortexes may produce unprecedented ice flows and ice dams. Unusually large hurricane surges and the tides they produce may flood low-lying sites that been spared in the past.  Again, why risk it?

The Elcon “thermal oxidizer” vents to the air we breathe. For air quality we rank among the worst in the state.  Should we tolerate more assaults on air quality?

Unfortunately, our permitting system does not consider whether an application is in the public interest or is necessary. It presumes that a property owner should be allowed to do whatever he/she wishes so long as it doesn’t adversely impact the neighbors.