Date:   September 6, 2022

Re:      Proposed SPDES Permit to Holtec for discharge into Hudson River SPDES Number: NY0250414


Stop the Algonquin Pipeline Expansion organization (SAPE) hereby requests that DEC must uphold the NYSDEC Commissioner’s Policy-29 known as CP-29 in scheduling multiple information sessions and public hearings accessible online as well as in person and a minimum 60-day comment period on applications of Holtec International and any of its subsidiaries/affiliates, including but not limited to Indian Point 2 LLC, for renewal of New York State Pollutant Discharge Elimination System (SPDES) permits.

Peekskill is an Environmental Justice community on the Hudson River overwhelmingly burdened by environmental racism with a long history of numerous heavily polluting industries including the Indian Point nuclear facility. It is directly impacted as a frontline community adjacent to the site. It is imperative that the New York State Department of Environmental Conservation (DEC), concerning this proposed SPDES permit,  comply with Commissioner’s Policy 29, known as CP-29, which requires that any permit before the department must first prepare and submit an enhanced Public Participation Plan if the proposed permit directly affects an Environmental Justice community. This Plan provides the community with a better opportunity to learn about and comment upon a proposal that involves pollution or other damaging impacts.  

CP-29 also requires the applicant to identify community stakeholders, actively elicit public comment throughout the entire permit review process and ensure that relevant documentation is made available and accessible throughout the community. To that end, the DEC must hold information sessions and public hearings for the proposed SPDES permit and take the required steps to ensure full access and engagement of the impacted community. Opportunities for the community to publicly address the DEC should also be accessible online via Zoom or WebEx platform. Translation information for comprehension by non-English speaking residents must also be made readily available.

We believe releases of toxic effluents – radioactive and other – to the Hudson River is a matter of utmost public interest and importance and issues pertaining thereto should be aired as fully and transparently as possible. SAPE seeks the cleanest, safest decommissioning of Indian Point, with particular attention to environmentally just practices that protect all Lower Hudson Valley communities today and for generations to come. Our members include individuals who have focused on Indian Point site environmental concerns for many years.


Suzannah Glidden, co-founder

Stop the Algonquin Pipeline Expansion (SAPE)