The engineering firm appointed by Eldred Township has found several faults with the Nestle application before the township zoning board. Hanover Engineering sent three letters dated April 15 referencing Nestle’s geological, environmental and civil engineering reports.

* The first point is that Nestle’s own test results and their response to Hanover’s initial geological review do not support Nestle’s claims that “the proposed water extraction will not cause a reduction in groundwater quantity available to other properties within the recharge area and that the proposed use is sustainable.”

Hanover, using test numbers provided by Nestle, determined the proposed withdrawal causes a 39 percent reduction in the groundwater quantity available within the recharge area. “All of this from a single 80-acre property that occupies only 21 percent of the 0.57 square mile recharge area as calculated by the consultant.

“In our opinion, this represents a disproportionately large usage of water within this basin by a single user which may eventually prevent other land owners within the basin from being able to utilize their properties as they wish due to lack of groundwater availability. The sustainability of this project may ultimately depend on controlling and curtailing the water usage of other prospective users in the basin.”

Nestle will be leasing the property owned by Rick Gower and Gower Estates, but will be drawing water directly from adjacent property owners. These adjacent property owners are not only not in any position to be compensated for the loss of their water, but are also going to be subjected to restrictions on the use of their property by the well head protection regulations which will be imposed as part of the permit if it is approved.

Trucking company

The special exception review by Hanover delineates a number of existing problems with the current uses of the Gower property, including the trucking company which is based on the property.

Hanover said there is a question as to when this operation began and if it complies with the requirements of the “light manufacturing within the commercial district,” if it is properly permitted and if a special exception has been granted for the use.

The property is used for both the trucking company and a residence. The current uses appear to be in opposition with the well head protection regulations as well.

Hanover also points out that the “Manufacturing, Light” requires all activities to be “carried on entirely within a fully enclosed building.” The letter notes that this is not what is proposed within the application.

Roads, sewage

Hanover says the issue with regard to roads, sewage, drainage and setbacks has not been addressed sufficiently.

The Nestle design includes two above ground “silos” which will be used as water storage tanks. Storage tanks are not permitted within the zone or within the well head protection zone.

The proposed plan also shows temporary and possibly permeant structures being built within the 100 year floodplain setback.

Environmental impact

The third letter submitted by Hanover addresses the Environmental Impact Statement. Hanover says Nestle did not study the entire parcel for impact, but only a relatively smaller area.

The study did not identify all of the possible wetlands on the parcel as well as all of the Ordinary High Water Mark boundaries for the Buckwha Creek and another tributary found on the site.

Hanover also took exception to the slope at which the surface water will be discharged back into the Buckwha.

The environmental review lists numerous deficiencies and requests the applicant to conduct further studies and investigations.

The zoning hearing board is scheduled to meet for the third of what promises to be many more hearings tonight at 7 at the Kunkletown Volunteer Fire Company.