The following is the letter I recently wrote to the Nashua Planning Board regarding the serious impacts of a proposed asphalt plant on Temple Street in Nashua. The main points are the proposal is not permitted by the Nashua City Ordinances because it is incompatible with previously approved housing next door. It also must address environmental, traffic and visibility concerns as required by these ordinances.

Concerns with Asphalt Plant Proposal

Nashua Planning Board
229 Main St
Nashua, NH, 03060

Members of the Nashua Planning Board,

I write to express substantial concerns with the asphalt plant proposed for Temple Street in Nashua. This proposal seems contrary to past usage, and the neighborhoods established in the area based thereon. Since the proposed address was previously used as a lumber yard a large number of homes and other residential buildings have been approved and developed nearby. These include multi-family homes on  Murray Ct, and an 88 apartment building approved by the Planning Board in the last few years. Section 190-19 of Nashua Ordinance states the purpose of the General Industry District at the Temple Street site includes: 

• Provide a reasonable amount of space for heavy industrial uses, provided they are environmentally sound and do not detract from neighboring land uses.
• Encourage attractive, landscaped, and sensitively sited industrial development that is compatible with surrounding land uses.

Since the Board has permitted residential development in close proximity to the proposed location, an asphalt plant is no longer compatible in this location. It is well documented that Asphalt plants release toxic pollutants including sulfur dioxide, nitrogen oxides, carbon monoxide, and volatile organic compounds. Further, they have been directly attributed to the release of chemicals linked to serious health issues, including respiratory problems, birth defects and cancers. Clearly pollutants directly attributed to serious health problems are not “compatible” with homes literally next door.

Nashua is currently suffering from a lack of affordable housing. This results in fewer people being able to live and raise a family in the city, which has led to an inability for businesses to hire and retain talent, according to New Hampshire’s Business and Industry Association. Permitting a toxic asphalt plant near a large section of affordable housing will add further pressure on this limited supply. 

In addition to the health and housing concerns, there are additional requirements that must be met before approving this facility:

• Nashua Ordinance 190-19 requires all freight-handling areas be screened from view so as not to be visible from a property not zoned GI or the public right of way. Standard facilities of an asphalt plant include collectors and storage facilities which stand dozens of feet tall. Since these are clear freight-handling areas, they must be screened from the residential sections of nearby East Hollis St.
• Nashua Ordinance 190-15.D.2.C requires the average daily trips to not exceed other uses of the zoning district by more than 10%. It is estimated this plant will result in 150 trucks transiting the facility daily, which should be evaluated in comparison to the number of trips of the site as a lumber yard. These will leave the site via the Temple St to East Hollis St intersection, which is notoriously congested, and require a costly improvement to facilitate access by these large trucks.
• The proposed location is also directly across from the Nashua River, which feeds the Merrimack River and is a source of drinking water to hundreds of thousands of people downstream. Therefore, the site plan must account for stormwater runoff to avoid water pollution resulting as a side-effect of spills and other contamination at the plant. Since water pollution has been observed at other asphalt plants across the country, Nashua must protect the river it has worked so hard to clean up from past industry pollution.

Given these environmental and health impacts, as well as the plan’s obvious incompatibility with surrounding uses previously approved by the Board, the only viable option is for the Planning Board to deny the Asphalt Plant Application.