The $20 Million Lie
We have now confirmed that Wegmans and their consultants have provided DEQ with incorrect information relating to their alternatives analysis.
We also have confirmation from DEQ that we were right again!! First it was the amount of wetlands, now it's the cost of at least this one alternative. How many other bogus assertions have regulators accepted?
This is a bit complicated, but to get a permit to destroy the wetlands, DEQ must conclude that Air Park is the LEDPA (Least Environmentally Damaging Practicable Alternative). DEQ already acknowledges that Air Park is more environmentally damaging than the Archie Cannon site, so for the Air Park site to be the LEDPA, Wegmans must demonstrate that other alternatives are not practicable because of cost, logistics, or the ability fulfill the basic purpose of the project.
In addition to the infographics above, we are providing additional information with more details for those interested in learning more. Click the links below to open the files.
In addition to the standard alternatives/LEDPA analysis, Wegmans must overcome the presumption that there is a practicable alternative because Wegmans proposes a project within a “Special Aquatic Site.” The Wegmans project is not water dependent, so practicable alternatives that do not involve special aquatic sites are presumed to be available, unless clearly demonstrated otherwise. Where a discharge is proposed for a special aquatic site, all practicable alternatives to the proposed discharge which do not involve a discharge into a special aquatic site are presumed to have less adverse impact on the aquatic ecosystem, unless clearly demonstrated otherwise.
Regulations specifically identify the following areas as special aquatic sites: sanctuaries and refuges, wetlands, mud flats, vegetated shallows, coral reefs, and riffle and pool complexes.