Economics_of_Offsite_Disposal_10_12_2022.pdf Richard Hudson and Joyce Vann
393 Riverside Drive
Florence, MA 01062
October 12, 2022
Sarah LaValley
Northampton Conservation Commission
210 Main Street, Room 11
Northampton, MA 01060
Subject: Response to Notice of Intent Project:\6303\Noho Cutlery\Northampton
Dear Sarah LaValley,
The application’s complete analysis of the alternative of removing the contaminated material is
“Off-site disposal of this volume of impacted soil has been determined to be financially
infeasible.”
The positives of removing the impacted soil are abundant:
● The riparian zone could be replanted with trees and restored fully.
● The value of not worrying about contamination to my neighbor’s well a few hundred feet
north of the project.
● The value to the city of knowing it won’t have run a water line down Riverside Drive.
● The value to wildlife.
● The value of the fence being removed to all the citizens who walk/bike/run down
Riverside Drive and so forth.
There is nothing in the application to indicate that off-site disposal isn’t the preferred solution
except money.
So how does one get at these economic issues? Economists agree that the best way is to
determine economic value. [ref: Google “economic value”] This is what economists use to
evaluate a NEPA EIS.
To get at the economic value of off-site disposal an economist will do a simple thought
experiment. “What is the value of your home?” “What is the value of your home if hazardous
waste was buried next door?” The difference is the economic value. I invite the commissioners
to do this thought experiment with their own homes and come up with the value of your home
and the value if hazardous material is buried next door. Now multiply that number by 10 or 15,
basically the number of abutters. The result is the economic value of off-site disposal of the
hazardous waste. When I did the thought experiment the result was over a million dollars. Your
number may be different, that’s expected, and there’s nothing wrong with that. The applicant did
not include such an economic study so the commissioners are left to do their own thought
experiment to reach the value of removing the waste instead or leaving it buried for the 50 to 70
year lifetime of the erosion barriers. [ref: lifetime from Mirafi Fabric tech specs]
Each commissioner has his number and now has to decide if that number is a reasonable
burden to put on the abutters, on the city knowing they won’t have to run a water line, and the
value lost to groups like the Mill River Conservancy and their goal of protecting the Mill River.
The important thing is that you have a number that you can use just as the application has as an
infeasible cost number. While there are other ways to look at the issues this is how an
economist would look at the issue and is an important tool to use when considering alternatives.
From an economic value standpoint the prefered alternative is clearly off-site disposal and I
encourage the Commision to choose off-site disposal.
Richard Hudson and Joyce Vann
393 Riverside Drive
Florence MA. 01062
Sincerely,
CC:
Wayne Feiden, FAICP Director Planning & Sustainability
Alex Jarrett, Ward 5 City Councilor
Alan Verson, Cutlery Building Associates
Joshua Surette, Senior Scientist Epsilon Associates
Gary Hartwell, Abutter
Gaby Immerman, Mill River Greenway Initiative
John Sinton, Mill River Greenway Initiative