Finger Lakes Group
Winter 2007 Newsletter
Proposed Seneca Army Depot Ethanol Plant
by Kate Bartholomew
I am writing today as a private citizen and life-long resident of the Finger Lakes Region, to comment negatively on the EPA's plan to de-list a portion of the former Seneca Army Depot to enable Empire Biofuels Development to proceed with plans to construct an ethanol refinery at the site and plant experimental crops. I feel the issue is too important to ignore.
How is it that a site which, during the Cold War, purportedly housed the largest stockpile of nuclear weapons in the free world and which is still riddled with at least 500 concrete bunkers, each of which, depending on their individual level of contamination, would require, at minimum, $50,000 to remove, is suddenly able to be declared "sufficiently remediated" to grow experimental crops? Forgive me if I find this difficult to believe, especially since the EPA Superfund ROD for Seneca Army Depot, EPA ID: NY0213820830 from September 29, 2006, provide no evidence of changes to the site - the page is blank. Has the work been completed, or is it yet to take place?
I'm also suspicious of the site's suitability for any type of agricultural use when even the ROD advises against groundwater use until acceptable levels of contamination are attained - not to mention advising against locating any daycare or public schools within a specified area around the contamination site. So when, exactly, will this acceptable level be achieved? And let us not forget the ubiquitous predilection toward secrecy and duplicity, spurred on by national security concerns, during the Cold War—are we truly certain of all the exact locations of contamination on the former Depot grounds?
Perhaps I would feel less driven to make comment if the purpose for which this site is being de-listed weren't so questionable in its own merit. The site is being prepared so that Empire Green Biofuels, in partnership with Cilion, Inc., of California, can construct an ethanol plant and biomass facility capable of producing 50-60 million gallons of highly flammable corn-based ethanol per year. Not only will each gallon of ethanol be 30% less efficient than a comparable gallon of gasoline, but it will require at least 6 gallons of water and one gallon of gasoline to complete the process to generate one gallon of ethanol. And that water will be withdrawn from Seneca Lake at a rate of at least 1.73 million gallons per day, used in a process of distillation and cooling, and then returned - somehow - back to the environment.
In addition, the 3,400 acres proposed for experimental crops of willow and switch grass remove a large tract of rich wildlife habitat from an area previously listed as a conservation area. To make a bad story worse, these crops are not destined for use in an upgraded, cellulose-based ethanol process in the future —instead they are to be used to directly supply 50% of the energy to power the ethanol plant— and the willow won't be able to be harvested for at least 10 years from planting.
While I find this project rife with problems at many levels—not least of which being the Negative Declaration issued by the Seneca County IDA as lead agency—I am only asking that the EPA carefully reconsider its decision to de-list a portion of the Seneca Army Depot Super Fund Site.