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Due October 31st.
Please send the following message to the email addresses below and sign the petition below.
Subject: E5101222-012
Please reject BP Point Breeze LLC’s Chapter 105 water obstruction and encroachment permit application for a warehouse complex at 6310 W Passyunk. BP Point Breeze’s proposal to replace 1.43 acres of impacted wetlands with a wetland mitigation area is not adequate to protect the impacted Exceptional Value wetland. After identifying that the impacted Exceptional Value wetland is inhabited by the Northern Red-bellied Cooter (turtle), identified as “threatened” by Pennsylvania, BP Point Breeze is proposing to create intentional nesting areas within the wetland mitigation area. However, there are several issues with the company’s proposal.
The most significant concern is that BP Point Breeze is proposing to collect stormwater from the proposed parking lots and then discharge that water into the wetland mitigation area. This water will likely contain oil and other auto-related substances, including fine particle road dust, that accumulate in parking lots. This is particularly concerning because the north parking lot is located in an area where all vehicles entering and exiting the facility will pass and the collected stormwater is specifically designed to discharge into the wetland mitigation area. It is completely inappropriate to discharge stormwater from a parking lot at the entrance of a heavily trafficked shipping facility into an area that is attempting to replace an Exceptional Value wetland and provide a habitat for a species that is known to be threatened in Pennsylvania.
The Pennsylvania Fish and Boat Commission (PFBC) specifically requested that PB Point Breeze submit their plans to construct a habitat for the threatened species found on the property, but no further communication is included in the application. Appendix B of the application, titled “PA Fish and Boat Correspondence” is simply a letter from PFBC requesting further communication, but there is no further communication from PFBC regarding the proposed threatened species habitat.
It is additionally concerning that the wetland mitigation area will be created by digging into land located in the 100-year floodplain that could disturb legacy soil pollution. The application includes multiple assessments of the undeveloped portions of the site that imply that there is further soil contamination from legacy industrial activity at the site, “including abandoned concrete rubble, rusted metal equipment and piping.” The application also states that there was “evidence of coal silts through upper portions of soil profiles within study area” which is specifically where the wetland mitigation area and turtle habitat is being proposed. It is not appropriate to construct a threatened species habitat by digging into this likely contaminated soil.
Additionally, BP Point Breeze claims they have notified the surrounding community and addressed their concerns, but provides no evidence of this. PB Point Breeze even claims it chose this location because other possible locations would have been met with resistance from nearby residents because of traffic issues and loss of greenspace, but provides no evidence that residents impacted by this facility would not have the same concerns. The proposal includes significant traffic issues, specifically 95 trailer parking positions and 244 auto parking spaces.
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