As a matter of record, the Republican and Democratic Parties of Lincoln County stand in bipartisan opposition to the construction and operation of the proposed Alto Concrete Batch Plant (hereinafter referred to as “the proposed batch plant”). Public sentiment by residents and engaged citizens runs high in opposition to this project and transcends party affiliation. Both parties agree the proposed batch plant at the proposed location on the Billy the Kid Scenic Byway (NM SH 220), would be out-of-place and inappropriate for this scenic, quiet, semi-rural, residential and recreational area. The construction and operation of this plant would pose severe impacts to the quality of life and economic viability of properties and businesses in the Alto area.
The purpose of this joint statement is to review the ill effects of this project itemized in your Resolution 2021-24 and on the Alto C.E.P. website. This also informs you of our determination to send copies of this statement and attachments to all relevant agencies and legislators, including the Governor. Briefly, the negative environmental and societal impacts are summarized below:
➢ potential impact to the viability of the area's natural water sources due to the volume of water consumption and/or emissions from plant operations, including aerosol emissions and water runoff from the plant site into nearby natural streams or seepage of water runoff into the local aquifer
➢ water use in the range of 72,000 gallons per day for making concrete and mitigating dust
➢ wastewater disposal that will seep into shallow aquifers and impact neighboring wells and potentially the famed Snowy River Cave System
➢ heavy truck traffic and associated dust, light and noise pollution creating a nuisance, annoyance and disturbance to residents, visitors and indigenous wildlife
➢ potential health issues for individuals with a wide variety of pre-existing conditions ➢ air pollution associated with dust and other fumes
This plant is planned along one of the most scenic byways in Lincoln County, and indeed all of New Mexico. It would be visible for miles and represent a permanent scar on the landscape and our reputations as responsible caretakers of our land. Local businesses could lose sustainability or viability due to the out-of-place presence of a heavy industrial facility creating an impactful source of fugitive emissions, noise and increased heavy truck traffic in an otherwise pristine, quiet, and scenic alpine setting. Property values for residences and neighborhoods in proximity to a heavy industrial facility are estimated to fall anywhere from 10% to 50% or even more depending on the property's location.
To be clear, our bipartisan objection is not directed at a single individual, company or specific industry. Rather, ours is an objection to the inappropriate introduction of heavy industry into a pristine, scenic and natural setting, thereby preventing many from enjoying such setting, and benefitting only a few.
Because of the amount of turmoil the proposed concrete batch plant has created within the Alto community, our political parties have joined together to urge the Lincoln County Board of Commissioners to enact ordinances to prevent future attempts by heavy industry to encroach into inappropriate areas - such as the area along and surrounding the Billy the Kid Scenic Byway. It is our bipartisan opinion that such ordinances should not simply prohibit industrial growth within inappropriate areas, but also identify areas within the county where industrial growth would be beneficial and therefore encouraged.
Sincerely,
THE REPUBLICAN PARTY OF LINCOLN COUNTY NM
THE DEMOCRATIC PARTY OF LINCOLN COUNTY NM
Additional Facts Regarding the Proposed Alto Concrete Batch Plant
• In a recent poll of Alto Lakes residents, approximately 93% of the responding residents stated they were Opposed or Strongly Opposed to the proposed batch plant.
• During the Public Comment periods of the recent New Mexico Environment Department (NMED) Public Hearing on the proposed batch plant, no one spoke in support of the project.
• Using models certified by ASTM International for concrete batch plant operational noise levels and measurements of the ambient noise levels at the proposed site of the proposed batch plant, the environmental consulting firm SWCA calculated noise levels from operations would exceed the established EPA safe noise levels by over 10 decibels at the business location of High Country Landscapes and Nursery. Similarly, residents in the Legacy Estates neighborhood would experience noise levels 5-10 decibels above the established EPA safe noise levels.
• In the Air Quality Permit Application for the proposed batch plant, the applicant stated that up to 305 round trips of truck traffic to and from the plant will be required during periods of peak operation for raw materials delivery and concrete delivery.
• In the Air Quality Permit Application for the proposed batch plant submitted to NM Environment Department, water sprays are stated to be the primary means of suppressing fugitive emissions. However, the source of the water for those water sprays, the amount of water required to achieve the required suppression levels and the specific water spray equipment are not specified.
• The potential impacts of water runoff from plant operations (e.g., water sprays, water used for plant equipment cleaning and delivery truck cleaning) are not addressed in the NM Environment Department process for Air Quality Permit application review and approval.
• The proximity of Little Creek and Rio Bonito to the proposed batch plant (approximately one-quarter mile and two miles respectively) have generated significant concerns due to the potential for water runoff and alightment of fugitive emissions providing a source of contamination of these natural water streams.
• Potential environmental impacts to the Fort Stanton Snowy River Cave National Conservation Area and the Fort Stanton Snowy River Cave System have not been
addressed in the Air Quality Permit application or the draft NMED permitting documents for the proposed batch plant.
• A Letter of Concern has been released by the Fort Stanton Cave Study Project regarding the potential for contamination of the cave system due to water runoff into Little Creek and Rio Bonito. That letter was submitted as part of the NMED Administrative Record for the Air Quality Permit application for the proposed batch plant. Furthermore, copies of this letter have been provided to the Governor of New Mexico, the New Mexico Environment Secretary, the Secretary of the Interior, the National Director of the Bureau of Land Management and the New Mexico State Director of the Bureau of Land Management, in addition to other Federal and State officials.
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