To be added to Jeff Jordan's testimony:



STATE OF MAINE

BOARD OF ENVIRONMENTAL PROTECTION

|PINE TREE WASTE, INC. |) | |

|WESTBROOK, CUMBERLAND CO. |) |TESTIMONY OF JEFFREY JORDAN |

|TRANSFER STATION |) |CITY MANAGER OF SOUTH PORTLAND |

|#S-022074-WH-A-N |) |FOR INTERVENORS |

My name is Jeffrey K. Jordan , and I am the City Manager for South Portland. I have held this position since August of 1996. I am providing this testimony to the Board of Environmental Protection on behalf of the City of South Portland.

Traffic/Public Safety Concerns:

In preparing this testimony, I have reviewed those portions of the application of Pine Tree Waste/Casella that pertain to traffic, specifically Attachment 10, Vehicle Movement (dated August 18, 2000) and Attachment B, Revised Vehicle Movement Narrative and Traffic Study (dated December 6, 2000). After reviewing these documents, I have the following comments and concerns about the traffic study of the proposed project. I think it is important that this Board look carefully at the assumptions and conclusions of the traffic study in order to assure our citizens that the traffic study realistically represents the true impact of this 1,000 ton a day facility on traffic in the communities that surround this proposed facility.

One reason that South Portland sought intervenor status was to assure that proper planning, study, and analysis was undertaken to accommodate the development of a transfer facility that could accommodate nearly all of southern and central Maine’s total solid waste needs. The development of this project and its careful consideration in the permitting process is important to the City of South Portland as we plan for the implementation phase of the soon-to-be-published Maine Mall Area Traffic Master Plan prepared by Vanasse Hagen Brustlin, Inc, a study funded by the Maine Department of Transportation. This plan calls for an investment in excess of $25 million to improve the mobility and safety of the commuting public through portions of South Portland, Portland, Scarborough, Westbrook and Gorham. I want to make sure we get it right.

The Maine Mall Area Traffic Master Plan will be utilized by the State and municipalities throughout the Southern Maine region to:

❑ Reduce congestion

❑ Preserve arterial capacity

❑ Improve safety

❑ Facilitate the safe movement of people and goods

❑ Provide pedestrian safety

❑ Improve access

The specific project goals include:

❑ Define the constraints under which the existing traffic infrastructure operates

❑ Project future traffic demand

❑ Evaluate the ability of the transportation infrastructure to accommodate the current and long term growth and traffic shifts associated with changing land use, increased traffic demands and roadway system enhancements

❑ Investigate various alternatives to address identified deficiencies and accommodate increased demand

❑ Consider and summarize the ramifications of each improvement alternative on surrounding properties, roadways and the environment; and

❑ Provide recommendations to policy makers based on the relative measures of effectiveness of each alternative on the transportation system, its cost, and the overall impact of the alternative on the surrounding environment.

The Maine Department of Transportation, the Portland Area Comprehensive Transportation Study (PACTS), the five communities within the project area, and the business community have worked for almost a year and a half on this $100,000 study to plan for the continued economic viability and growth of our five communities. It is imperative that significant changes in our assumptions and models be considered as we begin to invest significant dollars to catch up to the significant growth and development of this area generally.

We feel that the applicant’s traffic study may have underestimated the trips utilizing Spring Street/Cummings Road for access to Interstate 295 serving coastal Cumberland County. The growth of traffic associated with large retail, industrial and office development in South Portland, Scarborough and Westbrook are all critically interrelated since the only direct and practical connection from Interstate 295 to the “Greater Maine Mall Area” is through the City of South Portland -- either from Exit 3, the Westbrook Street Ramp, or from Exit 7 Turnpike Spur (also known as Route 703). See Exhibit I-38 (Maine Mall Area Transportation Plan Figure 1-1). Any decision by this Board must include comprehensive study of the potential market share of the proposed facility to accommodate municipal solid waste and construction and demolition

waste material (“C & D”) from the eastern portions of Cumberland County, whose primary point access to the facility would begin at Interstate 295.

In recent data prepared by the Greater Portland Council of Governments more than half of the building permits issued during the 1990’s in Cumberland County came from the twelve communities east of Westbrook. See Exhibit I-39 (chart of Net Residential Building Permits in Cumberland County). New residential construction or renovation is a significant source of C& D. If in fact C&D is a major portion of the market targeted by Pine Tree Waste/Casella, much of the new waste would be coming from the strong growth areas along the coast. Access to the facility would naturally come through South Portland, along Western Avenue or from Route 703 to Maine Mall Road and Cummings Road/Spring Street to the proposed facility. Thus, the impact of the proposed facility cannot be evaluated unless the applicant reevaluates projected traffic that would come from I-295 to this facility in light of the Maine Mall Transportation Plan.

The second important reason South Portland sought Intervenor status was concern regarding the development of a new West End Fire Station in the City of South Portland, which will serve the continuing growth in this section of the City. In October of 1997, MMA Consulting Group, Inc., of Boston, Mass., provided the City of South Portland with the results of a detailed study regarding the provision of services by the South Portland Fire Department. The full report of MMA Consulting Group, Inc. is submitted as Exhibit I-30. I draw the Board's attention to the following statements in this report:

P. 3, Section C. Summary of Findings:

The Service Area. The South Portland Fire Department provides fire protection, fire prevention, emergency medical and other related services to a resident population of approximately 25,000 and to a large daytime, seasonal and transient population (some have estimated a day time population of 100,000). The Department responds to some 3,000 emergency calls per year, about two-thirds of which are for EMS activities. The City Fire Department provides coverage within four minutes to most of the eastern and central sectors of the community. In the west and northwest, because there is no fire station close enough to this densely developed and developing area, the Department provides four-minute EMS/BLS and fire protection services only seven percent to 20 percent of the time, and ALS eight-minute responses 73 percent to 89 percent of the time. The fire and EMS/BLS responses are significantly below standards dictated by flashover considerations, and for EMS, by the American Heart Association. The Cash Corner Station (Engine 5) is the closest career fire facility to this western sector. In the central part of the City, limited cross-town road connections result in lengthy running times, as well.

At page 34-37 of the report, response times for emergency medical and fire calls North and Northwest are summarized. At the time of this report, the recommended response times were not being met North and Northwest of I-295. Only 7% of the emergency medical responses were within 6 minutes. The report states that “the need for a more rapid response in the western and northwestern area of the City is apparent. The data support planning for, and immediate construction of, a new fire and rescue station in this area.”

At this time, the City is in the process of purchasing land for a West End fire station. We now expect to purchase a suitable lot later this winter on Western Avenue.

However, in order for the City to properly plan for our response capabilities, it is imperative that accurate and complete traffic information be available to the City to assist in our planning effort for the final development, equipping and staffing of this new West End Fire Station. The application for the proposed facility does not include such information.

In conclusion, I hope that the Board consider carefully the traffic impact analysis presented on the Applicant’s behalf and assure that the five surrounding communities can adequately plan for and assure that we have made appropriate amendments and plans to supplement the work of the Maine Mall Area Traffic Master plan. In an era of constrained financial resources, it is important that we appropriately plan and invest for future traffic safety and mobility issues to better serve the public who live, work or visit the Greater Maine Mall area, if a facility of this unprecedented magnitude is in fact built at this site.

FURTHER, AFFIANT SAYETH NOT

DATED this __ day of January 2001.

Jeffrey Jordan

STATE OF MAINE

_________________, ss.

Personally appeared the above-named Jeffrey Jordan before me this day of January 2001, and made oath that the above-stated facts are upon his own personal knowledge, information or belief, and he swears that he believes them to be true.

Before me,

Notary Public/Attorney-at-Law

(Print Name)

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