Data Center Danger in Panther Valley

The massive data center complex proposed in Nesquehoning is alarming in it's size and scale. As we can see from the developers plan in the image below, four massive buildings are sandwiched between Dennison Run (an Exceptional Value trout stream) on the left, and Broad Run (an Exceptional Value trout stream) on the right. The buildings are arrayed in a straight line because they back up against the Nesquehoning coal mountain that drains into the Exceptional Value wetlands that lie between the parking lot and the houses along Stock Street. Their recent application for a National Pollutant Discharge Elimination System (NPDES) permit is facing strong headwinds precisely because of the location: discharging waste- or storm-water is difficult when you are surrounded by streams and wetlands (the ground is already saturated). In technical terms, the infiltration rates are poor and the previous land use as a coal mine complicate storm water management because of the toxins and heavy metals in the ground that act as leachate and would be spread (or carried into Nesquehoning Creek and the Lehigh River) by waste- or storm-water.

This proposed development is in one of the most ecologically sensitive areas of Northeastern Pennsylvania and has implications that reach far beyond today for the homeowners on Stock Street and surrounding neighborhoods. The expectation of this development is not one of economic prosperity but of economic disaster. Sited so close to the massive buildings operating 24x7, the homes on Stock Street and nearby Lake Hauto in the area will lose property value, become unsellable, and devolve into blighted properties, creating an economic burden for the municipality. The total economic lifecycle cost of approving this development far outweighs the proposed benefits, where the profits will go to shareholders and the residents will be left with another mess like the Tonolli Corporation battery recycling plant.

But what about the business and all the potential employees? Businesses take an incomplete development as a paper loss, file for bankruptcy, restructure, and move on to the next hot venture. Data centers are speculative investments that are mirroring the Warehouse-building craze. The number of permanent employees attached to Data Centers are orders of magnitude less than the contractors paid to build the centers and install the computers. Let's not waste our community, neighbors, water, and taxpayer money on this latest speculation. We must protect our neighbors, our water, our wetlands, our fisheries, and our future.

Some of the key points to raise to the developers and PA-DEP include:

1. What post-construction monitoring will PA-DEP require to verify that erosion and sediment controls, post-construction stormwater management facilities, and other environmental protection measures perform as represented during permit review?

2. How will PA-DEP verify that groundwater recharge, wetland hydrology, stream baseflow, and other hydrologic functions remain consistent with assumptions made during permit review?

3. What monitoring will be conducted within Broad Run (Exceptional Value), Dennison Run (Exceptional Value), and downstream receiving waters, including Nesquehoning Creek, to evaluate changes in water quality, sedimentation, temperature, aquatic habitat, or biological conditions?

4. Will PA-DEP require routine biological monitoring, including aquatic macroinvertebrates (such as mayflies), fisheries, water temperature, or other biological indicators capable of detecting degradation that may not be apparent through visual inspections alone?

5. Did PA-DEP consider requiring an independent third-party environmental compliance monitor, selected or approved by PA-DEP and funded by the permittee, to oversee construction activities, verify implementation of erosion and sediment controls, and provide independent reporting throughout construction? If not, why was such oversight deemed unnecessary?

6. How frequently will PA-DEP inspect the Carbon Node East Development project during active construction, and will inspection frequency increase following major storm events, observed deficiencies, or documented permit violations?

7. How did PA-DEP incorporate lessons learned from previous enforcement actions involving large utility-scale solar projects in Pennsylvania when determining the monitoring and compliance requirements for Carbon Node East Development?

8. What adaptive management provisions will apply if monitoring demonstrates increased sedimentation, groundwater impacts, degraded wetland hydrology, elevated stream temperatures, or adverse biological trends?

9. Will PA-DEP require public availability of monitoring reports, inspection reports, enforcement actions, corrective action plans, and long-term environmental monitoring results so affected residents can independently evaluate project performance?

10. What permit conditions authorize PA-DEP to require corrective actions, additional monitoring, restoration, permit modification, or suspension of construction if environmental impacts exceed those anticipated during permit review?

11. Please identify every monitoring plan, inspection protocol, adaptive management strategy, compliance document, enforcement policy, and factual finding relied upon by PA-DEP in concluding that long-term environmental performance can be verified and maintained throughout construction and operation of the Carbon Node East Development project.

Please attend the public meeting and hearing on Thursday, August 20 starting at 5pm at the Panther Valley Junior/Senior High School. The NPDES Stormwater permit application documentation and conceptual plans are available for review at the Carbon County Conservation District Office, 5664 Interchange Road, Lehighton, PA 18235 at 610-377-4894.

Please submit written comments to:

DEP Northeast Regional Office, Waterways & Wetlands Program

2 Public Square

Wilkes-Barre, PA 18701

or email your comments to Pamela Kania, P.E., Program Manager at: RA-EPWW-NERO@pa.gov.

Reference: Applicant Carbon Node East Development, LLC

Permit Application Number PAD130057