The Kutztown Planning Commission shared concerns regarding the draft Berks County Comprehensive Plan Tuesday night.
Borough Planning Commission Chair Karen Feridun presented a letter of recommendations and comments to Kutztown Borough Council. The letter is addressed to the Berks County Planning Commission.
Feridun told the board that the planning commission could not tell the difference between the old comprehensive plan and the new one since they only had the new map.
'Without the maps to compare, it was very hard to know whether this has been an issue in the past or is this a huge change that we need to be concerned about,' she said.
Borough Council approved sending the letter with their own letter, supporting Kutztown Planning Commission's remarks to the Berks County Planning Commission.
'In general, we thought that the plan was well written and thorough,' wrote Feridun in the letter to the Berks County Planning Commission. 'We certainly support the 'smart growth' principles that were listed.'
Concerns outlined in the letter included the condition and maintenance of local bridges judged structurally deficient and functionally obsolete. Karen noted that the number of bridges listed demonstrate a serious need.
'We suggest that a much stronger emphasis be placed on responding to this urgent need to maintain the service and safety of our local bridges,' wrote Feridun.
Agricultural conservation and protection were also among their concerns.
While they commended the county for safeguarding rich farm land area with various conservation programs such as Clean and Green, they remained concerned about protection of Class 1 and II soils from pollution and contamination.
'We suggest that more emphasis be placed on what else can be done to protect these areas of rich farm soil from such 'trumping' developmental pressures,' Feridun wrote. 'Even though we do support 'compacting' future growth... we remain concerned about the designation of certain existing farmland with prime agricultural soils as suitable for future growth.'
Even with Berks County's active conservation programs, Feridun wrote that farm land remains vulnerable to contamination from trucked-in sewage sludge containing toxins from industrial, municipal and medical waste.
While the Kutztown Commission supported the County's statement, 'The County will only support sewage sludge application on land within Agricultural Preservation Areas in accordance with appropriate standards,' they were concerned about what is currently called 'appropriate standards' which still allows for significant contamination, according to Feridun's letter.
'We found little mention of pollution of the soil in your plan,' wrote Feridun. 'Given the importance of our agricultural economy, we urge you to add more emphasis on addressing the biggest sources of soil pollution, i.e., contaminants from agricultural and landscaping practices, such as bio-solids, excess nutrients, herbicides and pesticides.'
Another item of concern was the plan's mention of some 34 CERCLIS sites identified by the Environmental Protection Agency. CERCLIS stands for Comprehensive Environmental Response, Compensation, and Liability Information System, which allows people to retrieve Superfund data.
Feridun noted that 23 of those sites are located in Hamburg or related to the Hamburg industrial sites.
'We suggest that the County add the priority of working with Hamburg and its environs on addressing these pollution issues for overall environmental protection and to ensure the safety of the Schuylkill River that enters the county near Hamburg,' wrote Feridun.
The Kutztown Commission was also concerned about the County encouraging municipalities provide for intensive animal operations and other intensive agricultural uses.
'We cannot support this item without clarification in the language as to its intent (implied allowances),' wrote Feridun. 'Our understanding of the phrase 'intensive agriculture' is that it includes CAFOs and the use of bio-solids.'
According to Feridun's letter, intensive animal operations involve a very large number of animals raised on a limited area of land.
'CAFOs, Concentrated Animal Feeding Operations, require large amounts of feed, water, and pharmaceutical interventions; whereas, intensive agricultural activities involve a much heavier use of fuels, pesticides, herbicides and chemical fertilizers.'
'While these intensive methods may produce a greater yield in the short run, these methods contribute to a real increase in the soil, water and air pollution of the surrounding area,' wrote Feridun. 'If it is the intention of item 7 to encourage such 'intensive animal and agricultural activities' as we have described, then we object to the inclusion of this statement!'
Also, while the Kutztown Commission appreciated the many references in the plan to the importance of protecting the water supply, 'we are concerned that the proposed quarry expansion in Richmond Township poses a real threat to the ground water supply in the East Penn Valley region.'
Feridun's letter noted that they are aware that the County hired two registered professional geologists who submitted their report in July 2007, which included a detailed evaluation of the potential impact that such a quarry expansion by Lehigh Cement could have on the pattern of ground water flow, quantity of ground water, quality of ground water, number of sink holes, etc. and made recommendations to further study, according to Feridun's letter.
Pulling an excerpt from the report, 'The most significant issue of concern is the current limited understanding of the surface and groundwater consequences that this quarry will present.' Also from the report's final paragraph, 'Tetrahedron Consultants Inc. (geologists' firm) discovered during our study that the Delaware River Basin Commission had not been contacted regarding Lehigh's future plans. Therefore, the County and/or Richmond Township should contact DRBC to express concerns regarding future ground water withdrawal and the effects that mining would have on surface water bodies.'
The Kutztown Commission suggested that Lehigh Cement's expansion of Quarry #5 is not 'reasonable' at this time, recommending it be excluded from remarks in the Berks County Comprehensive Plan until necessary testing and evaluations are completed and until all procedural steps of the DRBC have been followed.
Also, in other news, the draft Kutztown 2012 Comprehensive Plan is available for review at Borough Hall and online at http://www.kutztownboro.org/commissions/PC/comprehensiveplan.php.
During the Kutztown Planning Commission's Aug. 13 meeting, public comments regarding the draft Comprehensive Plan will be accepted. The meeting will be held at 7:30 p.m., in the Kutztown Municipal Building, 45 Railroad Street,