Comments about Air Quality Permit

February 21, 2006



Re: Comments about Air Quality Permit Application No. 3324 (IDEA ID No. 24829 - PRN20050001) -- C and E Concrete Inc, HMA Plant


Dear Citizen:

The New Mexico Environment Department (NMED), Air Quality Bureau (Bureau) has received comments from you and others expressing concerns about C and E Concrete Inc’s plans to apply for an air quality permit to construct the C and E Concrete – Hot Mix Asphalt Plant near Ramah in Cibola County near your home or property.

All public comments will be included as part of the permit application record.

This letter is in response to the letters of concern received by the Bureau to date. At their request, this letter is also responding to the letters sent to Governor Richardson and Ron Curry, Secretary of the Environment Department. I have tried to classify the concerns raised in those letters in an attempt to provide a response to everyone, regardless of whether or not they asked a particular question.


How does the Bureau determine the impact of the proposed facility on the ambient air quality to ensure the health of citizens is protected?

The EPA and the NMED have established health based ambient air quality standards for certain common pollutants. These health based standards take into account our most sensitive populations such as children and the elderly. Emissions calculations and computer-based ambient air modeling analyses are used to determine if a facility will meet or exceed these standards. A facility is required to demonstrate through modeling that it will meet all state and federal ambient standards before the Department will issue an air quality permit. If the permit is issued, it will contain conditions to ensure that the facility will operate as represented by the company in the application and in compliance with all applicable state and federal regulations and ambient air quality standards.


Why didn’t I receive notice from the company of their planned operation?

Pursuant to New Mexico air quality regulations (20.2.72.203 NMAC), each company that applies for an air quality permit must satisfy comprehensive public notice requirements before the permit application can be ruled administratively complete. Section B (1) of the 20.2.72.203 NMAC requires applicants to notify the owners of record, as shown in the most recent property tax schedule, within one-half (1/2) mile of the property on which the facility is proposed to be located. Applicants are not required to notify property owners who live further than ½ mile from the property boundary.

In addition to the above notice, C & E Concrete Inc. is also required to submit a radio or television public service announcement, post a public notice in at least four publicly accessible and conspicuous locations, provide notice by certified mail to municipalities, counties, and tribes within 10 miles, and publish two newspaper notices, one in either the legal or classified sections of the newspaper and the other in the general sections of a newspaper serving the area.


Can we request an extension of the public comment period?

Once the Bureau has completed a preliminary review of the permit application and deemed it administratively complete, it will make available for public inspection the permit application and publish a public notice in a newspaper of general circulation in the area closest to the location of the source. The notice will also be sent to the nearest NMED Field Office. In addition to describing the permit application (a summary of estimated emissions and ambient impact), the notice will affirm that all interested parties have thirty (30) days, from the date the notice is published, to notify the Department in writing of their desire to review and comment on the Department’s analysis.

The Bureau published a public notice as described above in the Grants Daily Beacon on January 31, 2006, and in accordance with 20.2.72.206 NMAC, the public has until March 2, 2006 to submit written comments. After receiving public comment, and after the Department’s analysis (including the Statement of Basis and Air Dispersion Modeling Summary) becomes available, the Bureau will provide (per 20.2.72.206.B NMAC) an additional thirty (30) day period for individuals to review and comment on the analysis.


Can we request a public hearing for this permit application?

New Mexico air quality regulation, 20.2.72.206.C NMAC, requires that a public hearing be held if the Secretary of the Environment Department determines that there is significant public interest. The Secretary has determined there is significant public interest in this application, so a public hearing will be held to gather information and data regarding this permit application before issuance or denial of this permit. Once a venue and date has been set, the applicant and the public will be notified of the place, date, and time of the hearing. At the public hearing, interested parties will be a given a reasonable opportunity to submit data, views, and arguments (orally or in writing) and to examine witnesses testifying at the hearing.


How does the Bureau regulate issues such as facility or truck traffic noise, increased truck traffic on public roads, degradation of natural beauty and quality of life for residents, threats to wildlife, water quality, water conservation, property values, etc.?

Federal regulations (The Clean Air Act) and state regulations do not provide the Air Quality Bureau legal authority to regulate impacts that are not specifically related to air quality. Thus, the Bureau cannot deny any applicant an air quality permit based on these issues. Many of these issues, such as noise, odor, nuisance issues, truck traffic, quality of life issues, and property values, fall under the jurisdiction of local ordinances. The Bureau does not have the authority to regulate mobile sources (autos, trucks, etc.).


How does the Bureau regulate issues such as proximity of the facility to national forests, monuments, parks, and recreational or scenic sites?

In addition to the health-based emissions standards that apply to all ambient air, federal regulations afford additional air quality protection of Class I areas that are designated by Congress. These areas include any international park, national wilderness (greater than 5,000 acres), national memorial park (greater than 5,000 acres), or national park (greater than 6,000 acres). There are several of these areas in New Mexico, including Bosque del Apache, Wheeler Peak Wilderness, San Pedro Parks Wilderness, and Carlsbad Caverns National Park. Congress did not designate El Morro National Monument, the Ice Caves, the Bandera Volcano areas, the Cibola National Forest, and El Malpais as Class I areas, but these areas do have the same level of protection provided elsewhere in New Mexico.


An overview of the C & E Concrete Permitting Process

Completeness Determination: The Bureau is required to make a determination of whether the application is administratively complete (20.2.72.207 NMAC) within thirty (30) days after its receipt of the application. The C & E Concrete application (No. 3324) was received on December 19, 2005. On Jan. 17, 2006, the Bureau ruled the C & E Concrete Inc air quality permit application administratively complete.

1st Public Notice: After ruling the application administratively complete, the Bureau published a notice in the Grants Daily Beacon on Jan. 31, 2006. Interested parties have thirty (30) days, from the date the notice is published, to notify the Department in writing of their desire to review and comment on the Department’s analysis.

2nd Public Notice: Due to the public comment received by the Department on this permit application, a second thirty (30) day comment period will be initiated before a decision on the permit is made. However, the Department does consider and include as part of the permit application record all public comment received up until the issuance or denial of the permit.

Public Hearing: After an application is ruled administratively complete, the Department usually has 90 days to issue or deny the permit, depending on the particular process under which the application is being reviewed. However, based on the public interest in this permitting process, Ron Curry, the Secretary of the Environment Department, has determined that a Public Hearing will be held before this permit is either issued or denied.

If you have any questions regarding this letter or about this permitting process, please feel free to call me at (505) 955-8002.

If you would like to review the permit application, please contact Linnie McCLellan at the Bureau's Grants field office, located at 1212 ½ Lobo Canyon Road, Grants, NM 87020, Tel. (505) 287-8845, Fax. (505) 287-3415. Alternatively, the application and the completeness determination letter is published on the Permitting section of the Air Quality Bureau web site (www.nmenv.state.nm.us/aqb) under the Draft permits for interested parties link. Later, the Department’s Analysis, Modeling Review, Draft Permit and any further announcements, such as information about the Public Hearing, will also be published at this link as each document or announcement becomes available.


Sincerely,



Longying Dong
Environmental Scientist
New Source Review Unit


cc: Governor Richardson
Ron Curry, Secretary of the Environment DepartmentMary Day, Office of the Secretary, NMED

New E-Mail address

e-mail all ideas posts or what ever you want to say to...

savehwy53@yahoo.com

We need an attorny!!

If anyone knows a good attorny that has dealt with environmental issues let us know!

Everything you wish you didn't know about TSP And PM-10

Description of Particulate Matter (TSP and PM-10)
Characteristics: Not all air pollutants are gases. Particulate matter is a collective term used for very small solid and/or liquid particles found in the atmosphere. While individual particles cannot be seen with the naked eye, collectively they can appear as black soot, dust clouds or grey hazes. Particulate matter may be generated by natural processes (e.g., pollen, bacteria, viruses, fungi, mold, yeast, salt spray, soil from erosion) or through human activities, including diesel trucks, power plants, wood stoves and industrial processes. Individual particles vary considerably in size, geometry, chemical composition and physical properties. The effect of particulates on human health and the environment varies with the physical and chemical makeup of the particulates.
One of the major characteristics of particulate matter is particle size. Particles can range in size from 0.005 - 500 micrometers or microns (um), which is equal to one-millionth (10 -6) of a meter. Particles less than 2.5 microns in diameter are known as "fine" particles; those larger than 2.5 microns are known as "coarse" particles. Fine particles with diameters of less than 1 um, move like gases. Because of their low settling velocities, fine particles may be transported 1,000 kilometers or more from their source. Under the influence of gravity, larger particles do not remain suspended and tend to settle out of the air, sometimes creating localized areas of high particle disposition.
Total suspended particulate matter (TSP) refers to all particles in the atmosphere. TSP was the first indicator used to represent suspended particles in the ambient air.
In July 1987, EPA began using a new indicator, PM-10, which includes only those particles with aerodynamic diameter smaller than 10 um. Ten microns is approximately one seventh the diameter of a human hair. This fraction of TSP is responsible for most of the adverse human health effects of particulate matter because of the particles' ability to reach the lower regions of the respiratory tract. Recent data suggests that particles 2.5 um or smaller may pose the greatest threat to human health because, for the same mass, they absorb more toxic and carcinogenic compounds than larger particles and penetrate more easily deep into the lungs. EPA is considering adopting a new standard for PM-2.5 to better address the potential health problems associated with these tiny particles.
Sources: Particles are either emitted directly into the atmosphere or produced in the atmosphere from the physical and chemical transformation of other vaporous or gaseous pollutants.
The major sources of atmospheric particulates are fossil-fuel combustion (which produces ash and soot), industrial processes (involving metals, fibers, etc.), transportation, wind and soil erosion (producing fugitive dust), and photochemical reactions (complex chain reactions between sunlight and gaseous pollutants). Fugitive dust and particles from industrial processes tend to be larger in size ( > 1 um). Particles from combustion and photochemical reactions are usually smaller in size ( < 1 um).
Because of the large number of sources, particulate matter may contain hundreds of different chemical elements. Fine particles (PM-10) may contain substantial quantities of sulfate, ammonium, nitrate, elemental carbon and condensed organic compounds. Carcinogenic compounds and heavy metals such as arsenic, selenium, cadmium and zinc are also concentrated in these particles. Larger particles, such as soil particles, fly ash, road aggregate, wood ash, soot and pollen are composed primarily of minerals, including silicon, aluminum, potassium, iron, calcium and other alkaline elements.
Concentration: Particle concentrations are expressed as ug/m3 (micrograms of particle per cubic meter of ambient air). Under very clean atmospheric conditions, the TSP level can be as low as 0-10 ug/m3. In a very dirty environment, TSP concentration can be as high as 1,500 ug/m3. In monitoring studies of more than 1,400 sampling sites across the United States, annual arithmetic mean TSP values ranged from nine to 288 ug/m3. The lowest values were reported at remote sites, while high values were associated with industrial settings.
Health Effects: Studies of air pollution on health have linked particulate matter (alone or in combination with other air pollutants) with a number of significant health effects. These include increased mortality and aggravation of existing respiratory and cardiovascular disease, as evidenced by increased hospitalization, school absences and lost work days.
The health effects of atmospheric particulate matter are related to its ability to penetrate the respiratory system. In general, respiratory defense mechanisms are able to remove 99 percent of particles larger than 10 um from the inhaled air stream. Smaller particles ( > 2.5 um), called "inhalable," can cling to protective mucous and removed in the upper respiratory system. Fine particles ( < 2.5 um), also called "respirable," can enter the lungs and end up in lung capillaries and air sacs (alveoli).
In the lungs, particulates slow the exchange of oxygen and carbon dioxide in the blood, causing shortness of breath. The heart may be strained because it must work harder to compensate for oxygen loss. Laboratory studies show that high concentrations of components of particulate matter cause persistent cough, phlegm, wheezing and physical discomfort. Particulate matter can also alter the immune system and affect removal of foreign material from the lung (i.e., bacteria and pollen).
Absorbed substances of particular concern include sulfur oxides (SOx), chlorinated hydrocarbons, polycyclic aromatic hydrocarbons (PAHs), and heavy metals such as lead, cadmium, zinc and mercury. Soot, fly ash and particles from automobile and diesel exhaust contain many of these compounds. PAHs and heavy metals are predominantly found in very small particles, which is of concern because some PAHs, such as benzo(a)pyrene, are known carcinogens. Chronic exposure to these particles causes cancers in laboratory animals.
As of 1994, there were 31 million people in the United States in areas that do not meet EPA's current standard for PM-10. However, because PM-10 standards may not be a reliable indicator of the problem presented by fine particles (< 2.5 microns), the 31 million number may be much lower than the real number of people affected by fine particles.
Ecological Effects: Particulate matter causes damage and soiling to materials, and is a major cause of visibility impairment in many parts of the U.S. The same fine particles linked to serious health effects also affects our ability to see by scattering and/or absorbing light. Certain particles, such as sulfates and nitrates, grow in size as humidity increases, making them more effective as impairing visibility.
Visibility conditions vary across the country. Much of the rural eastern U.S. has poorer visibility than rural western sites due to higher levels of particulates from both anthropogenic and natural sources, as well as higher average humidity.
Natural visual ranges in the eastern U.S. is about 90 miles, but current conditions range only from 14-24 miles. In the western U.S., natural visual range is about 140 miles; current conditions range from 33-90 miles.
The CAS established special protection for visibility in certain national parks and wilderness areas. In response, EPA is developing a "regional haze" program intended to ensure continued progress toward the national visibility goal of "no man-made impairment."
Particulate matter can damage vegetation both directly and indirectly. When exposed to particulates, plants may suffer increased disease, leaf cells may be damaged, yield and growth rates may be reduced and plants may even die.
Dust on the leaves of crops, trees and shrubs inhibits photosynthesis and plant growth. Particles carrying heavy metals can contaminate soil and vegetation in urban areas, along highways and near smelters. Once in the soil, heavy metals can accumulate to phytotoxic levels in vegetation and suppress growth. In addition, particulate matter can scatter sunlight and cause a reduction in solar radiation, thereby affecting crop productivity.
One of the most visible effects of particulate matter is the soiling or staining of buildings and textiles. Particulates can also cause chemical deterioration of paint, resulting in corrosion of metal objects.

Next meeting

We have a meeting at Inscription Rock Trading Post Friday night at 6:30pm
Please try to be there so that we can plan our next strategy and the County Commission meeting on Monday 13th.

PUBLIC NOTICE

There will be a community meeting open to all persons that live along HWY 53 to discuss the issues regarding C & E Concretes proposed asphalt plant at the Tinaja gravel pit.


WHERE:
Ramah Elementary School cafeteria

WHEN:
Wednesday February 8th
6:30pm

C&E concrete plans to build an asphalt plant in the midst of our pristine community. The plant will produce over 500 tons of chemical pollutants a year and an increase in truck volume of over 50 trucks a day.
This proposal is cause for great concern for everyone that lives in our community or drives our scenic byway.

Do your part! Get the facts! Wed. Feb.8th 6:30

We all must do our part!!

What can you do to help stop C&E?

1. Call and write your government officials today! Tell them you do not approve!

2. There is no time to lose!

3. Call your county commissioners

4. Get this issue on the agenda at the county commissioners meeting.

5. Express your concerns to everyone.


Office of the Governor
490 Old Santa Fe Trail
Room 400
Santa Fe, NM 87501
Phone number: 505-476-2200 :

Office of the Lieutenant Governor
State Capitol suite 417
Santa Fe, NM 87501


Lieutenant Governor’s Office
Attn: Constituent Services
State Capitol Building
Room 417
Santa Fe. NM. 875011


Mr.Ronald Curry
Secretary of New Mexico Environmental Department
Harold Runnels Building; Room 4050
1190 St. Francis Drive
Santa Fe, New Mexico 87502

Ms. Longying Dong
New Mexico Environment Department
Air Quality Bureau
Permit Section
2048 Galisteo
Santa Fe, New Mexico 87505

Commissioner Bennie Cohoe
Cibola County Court House
515 High Street
Grants, NM 87020

Other Cibola County Commissioners:
Elmer Chavez
Frank Emerson
Isaac E. Padilla

Medical Opinion generously supplied by Ann Heath..........

The medical literature has extensive data on the health dangers of air pollutants. For the purpose of this discussion, I will focus first on the known health dangers of the pollutants mentioned in the legal document filed by the New Mexico Environment Department Air Quality Bureau.
Sulfur dioxide is a known cause of tightening of the airways (bronchoconstriction). It can be blown great distances from its site of production, as well as becoming “acid rain”, capable of profound and well documented effects on flora and fauna. Other studies of sulfur dioxide and particulate matter show a consistent relationship between these levels and death rates, even at levels below current National Ambient Air Quality Standard levels. Death rates are largely increased in those over 65 and with underlying heart and lung conditions. There are certainly areas affected by this plant with high concentrations of elderly who would thus be put at an increased risk of death. Furthermore, studies have shown increases in hospital admissions as sulfur dioxide levels increase, as well as increases in the severity of asthma symptoms. Particulate matter has also been shown in studies to increase deaths from all causes, as well as specifically from heart disease and lung cancer. There are also numerous studies showing an increase in acute breathing problems as levels of particulate matter rise. This effect is more severe in people with asthma and in children and has also been well documented in levels below the National Ambient Air Quality Standard levels. One study of children in California even showed a reduced rate of growth of lung function correlating with particulate matter levels to a magnitude of effect that was compared to active smoking! (Mason: Murray & Nadel's Textbook of Respiratory Medicine). Many studies have shown an increase in both emergency room and hospital admissions as particulate matter levels rise (The effects of outdoor air pollution and tobacco smoke on asthma, Immunol Allerg Clinic N Amer, 01-Feb-2005, Tatum). These increases were again seen in levels below the National Ambient Air Quality Standard levels. Similar effects were also seen in asthma severity and amount of medication used for asthma symptoms. Exposure to fine particulate air pollution was actually ranked as ninth on the top ten list of occupational lung diseases by the American Cancer Society Prevention Study. This was based on effects on heart and lung disease and death as well as lung cancer rates. (Chest, Literature Reviews Top Ten List in Occupational Pulmonary Disease, Pope CA, Burnett RT, Thun MJ, et al. Lung cancer, cardiopulmonary mortality, and long-term exposure to fine particulate air pollution. JAMA 2002)
Nitrogen dioxide is a precursor to smog and results in production of ozone. Multiple studies have shown that nitrogen dioxide makes people more likely to get both bacterial and viral infections and may increase the risk of chronic obstruction pulmonary disease (COPD or emphysema) (Mason: Murray & Nadel's Textbook of Respiratory Medicine, 4th ed., Copyright © 2005). Even low levels of nitrogen dioxide, particulate matter, and carbon monoxide have been linked to low birth weight babies (which often have many more medical problems both in infancy and later, even including more learning difficulties) (Impact of ambient air pollution on birth weight in Sydney, Australia. Mannes T - Occup Environ Med - 01-Aug-2005). In addition, studies have shown an increased risk of heart attacks by as much as one-third as levels of nitrogen dioxide levels increase.(Exposure to urban nitrogen dioxide pollution and the risk of myocardial infarction.Grazuleviciene R - Scand J Work Environ Health - 01-AUG-2004)
Both carbon monoxide and nitrogen dioxide levels have been associated with risk of Sudden Infant Death Syndrome. A higher outdoor nitrogen dioxide level doubled the risk of SIDS deaths. (Outdoor carbon monoxide, nitrogen dioxide, and sudden infant death syndrome.Klonoff-Cohen H - Arch Dis Child - 01-JUL-2005). Outdoor carbon monoxide levels have also been shown to be associated with hospitalizations due to angina pectoris (a lack of blood flow to the heart that can be a precursor to a heart attack. (Air pollution and hospitalization due to angina pectoris in Tehran, Iran: a time-series study. Hosseinpoor AR - Environ Res - 01-SEP-2005)
In the medical literature, there have also been concerns raised about the risk of cancer and poor pregnancy outcomes with volatile organic compounds, even at lower levels of exposure.( Kumar: Robbins and Cotran: Pathologic Basis of Disease, 7th ed., Copyright © 2005). More specifics are difficult to track until we can be provided with more details on which volatile organic compounds will be released.
Overall air pollution studies are also both quite convincing and quite alarming. The risk factor from air pollution is comparable to being moderately overweight. Air pollution has now been associated with increased risk of myocardial infarction, lung cancer, respiratory mortality, and an increased risk of emergency department visits and hospitalization of patients with COPD and asthma. (Chest, Literature Reviews Top Ten List in Occupational Pulmonary Disease, Pope CA, Burnett RT, Thun MJ, et al. Lung cancer, cardiopulmonary mortality, and long-term exposure to fine particulate air pollution. JAMA 2002). A Denver study showed an increase in breathing symptoms and medication use by patients with emphysema (COPD) related to overall pollutant levels, despite being in compliance with EPA standards (Winter air pollution and disease parameters in advanced chronic obstructive pulmonary disease panels residing in Denver, Colorado, Journal of Allergy and Clinical Immunology,Volume 115 • Number 2 • February 2005,Philip E. Silkoff, MD). There have also been significant links shown between levels of carbon monoxide, particulate matter, volatile organic compounds, and nitrogen oxides and childhood cancer, especially leukemia. One study even proposed that most of these cancers are probably started by such exposures! (Childhood cancers and atmospheric carcinogens.
Knox EG - J Epidemiol Community Health - 01-FEB-2005; 59(2): 101-5) A number of studies have shown an association between hospital admissions as well as deaths and levels of air pollution. One large study looked at levels of particulate matter, nitrogen dioxide, sulfur dioxide, carbon monoxide, and ozone. Looking at over 4 million emergency room visits, it looked at visits for asthma, emphysema, pneumonia, upper respiratory infections (colds, sinus infections, etc) and found that even small increases in pollution levels significantly increased rates of visits for these diseases. (Ambient air pollution and respiratory emergency department visits.
Peel JL - Epidemiology - 01-MAR-2005; 16(2): 164-74). Another study showed an increased risk of stroke as air pollution levels rise. This was correlated to levels of particulate matter, nitrogen oxides, and carbon monoxide and showed up to a thirteen percent increased risk of dying from a stroke as these levels increased. These authors concluded that eleven percent of all strokes are due to outdoor air pollution. (Outdoor air pollution and stroke in Sheffield, United Kingdom: a small-area level geographical study.
Maheswaran R - Stroke - 01-FEB-2005; 36(2): 239-43). Levels of long-term breathing symptoms (cough, breathlessness, mucus, and difficulty breathing) were found to be almost fifty percent higher in areas with increased levels of particulate matter, nitrogen oxides, sulfur dioxides, carbon monoxide, and ozone. This same study also showed a drop in lung function in people in these areas as well. (Association of outdoor air pollution with chronic respiratory morbidity in an industrial town in northern India.
Kumar R - Arch Environ Health - 01-SEP-2004)
I firmly believe these data conclusively show the danger to our area from the proposed plant. As a physician and resident of the area, I do not wish these health effects for either myself, my family, my patients, my neighbors, or my community. Furthermore, as medical director of the three emergency medical services that serve this area, I am concerned about the increase in heavy truck traffic and its associated risk of severe motor vehicle accidents. In an area where emergency medical responses can take up to or even over one hour, this could well increase the number of deaths (and certainly the number of significant disabilities) to citizens of this area, as well as all those who travel through here. In summary, I feel the proposed plant has a significant potential for a grave health risk to our entire area.
Sincerely,


Ann Heath, MD
Fellow, Board of American Family Physicians

Here are just a few of the expressed concerns Hwy 53 community members have.

Air quality:
· Many of our Hwy 53 residents moved to this pristine area for health reasons. Our climate and elevation are good for people with asthma and other respiratory difficulties.
· Many of our residents have spent their life savings to retire in our beautiful mountain community. Health reasons are a common theme for retiring in our clean mountain air.
· Our elderly and our children will be the first to suffer from the tons of pollutants emitted each day.
· Our pristine forest lands and the wild life will suffer the impact of the pollutants released.
· No one from C& E or the EPA have made mention of the increase of diesel truck emissions or the diesel generators and their potential impact.

Health risks:
· There are obvious and documented health risks whenever Tons of TSP, Nitrogen Oxide, Sulfur Dioxide and Carbon Dioxide are released into the air. The proposed plant will dump over 500 tons each year into our mountain air, not to mention increase diesel truck emissions from increased truck volume.
· Over 200 school children each day (often dark mornings) wait for school busses to pick them up. 50+ additional trucks each day exponentially increases the risk of accidents involving children waiting for the bus.
· Ramah residents and school administration, complain that C&E gravel trucks pass through their small town ignoring the 20 mile an hour school zone signs and travel an estimated 40 to 45 mph.
· Door to Door health survey found that 45% of residents living within ½ mile of asphalt plants suffer from deterioration of their health after the opening of the asphalt plants.
· Typical health complaints from residents living around asphalt plants are sinus and respiratory problems, increased head aches and increase of blood pressure.

Water table:
· How will the toxic chemicals affect our water table?
· How much water does a hot mix asphalt plant and gravel pit use daily?
Fire hazard:
· Hot mix asphalt uses propane heaters and have been known to have explosions.
· What fire plan does C&E have that will serve and protect the community and it’s pristine wilderness it resides in?

Road damage:
· Hwy 53 currently suffers constant road damage from the volume of gravel trucks coming and going to and from C&E gravel pit.
· Who, ultimately will pay for the continuous road repair and re-paving that will be necessary due to the volume increase in big truck traffic?

Road hazards:
· C&E gravel trucks are directly responsible for hundreds of windshield dings, chips and breaks each year on Hwy 53.
· Over 100,000 tourists a year visit the Hwy 53 area attractions. Tourists are slow drivers. C&E drivers feel they own the road and know the road best, they always speed and law enforcement will not pull them over. There are no safe places along 53 for a big truck to pull over.
· Hwy 53 already suffers constant road damage from C&E gravel trucks. The Road repaving that the state did last year from BIA road 125 to Ramah city limits already is experiencing damage from Big truck traffic.
· Will the tourists and residents have to endure the damage to their vehicle due to the disrepair of the road?

Environmental risks:
· Pollutants mix with moisture and accelerate the deterioration of our Native American ruins, artifacts, petroglyphs and pictographs and our historic monuments – these are national treasures
· How will pollution and increased road traffic would affect our National Monuments – El Morro and El Malpais – and The Ice Caves?
· El Morro area situated in a bowl, will pollution stay and mount up?
· Pollutants in the air hinder the detection of forest fires – endangering forests, wildlife and firefighters
· Plant located at the onset of the hydro-geological recharge areas of the San Andres-Glorieta aquifer which runs west through Zuni and Navajo Indian lands, through McKinley and Valencia counties

Property Values:
· Historically, across the US where ever asphalt plants pop up property values go down. Studies document as much as 56% property value loss.
· What will be the immediate and long term affects on our properties along Hwy 53 and outlying areas?

Business loss/ economics/ local jobs

· Hwy 53 is a scenic byway. Almost all businesses along Hwy 53 and those just off Hwy 53, except for C&E gravel are solely dependant on tourism.
· Will the big rig traffic and road damage detour visitors/tourists from driving Hwy 53?
· Will C&E create local jobs? If so will the jobs off set the cost of the constant need for road repair? Will they offer economic stability to our community?
· Will the cost of constant road repair come out of the local tax payer’s pocket? Currently only 17% of Cibola county residents are tax payers.
· Will the state or county raise our taxes due to the need to continually repair the road damage?

Your State HWY 53 is in jeopardy!

C&E Gravel & Concrete plans to build an asphalt plant on hwy 53

Here are the facts!

C&E Concrete PO Box 2547 Milan, NM 87021Permit NO. 3324 Site: Highway 53, Mile marker 52, Sec 33, T10N, R13WTEMPO Agency Interest ID NO. 24829
Cibola County Manager Office - David Ulibarri 1-505-285-2510

§ Plant at Hwy.53 location.
§ Permit No. 3324
§ TEMPO Agency Interest ID No. 24829

Operation schedule: 6 am to midnight, 365 days per year


Estimated emission rates:
Fugitive road dust and material handling
TSP 24.19 lbs per hour, 36.8 tons per year
PM-10 11.89 lbs per hour, 19.8 tons per year
Nitrogen Oxide (NOX) 28.94 lbs per hour, 73,2 tons per year
Sulfur Dioxide (SO2) 64.98 lbs per hour, 95.0 tons per year
Carbon Monoxide (CO) 27.15 lbs per hour, 48.5 tons per year
Volatile Organic Compounds 8.86 lbs per hour, 15.7 tons per year

TOTAL EMISSIONS: 166.01 pounds per hour – 1.5 TONS PER DAY
547.5 tons per year

There is no information provided regarding water usage for this proposed operation.