My name is Liz Adams, and I am here on behalf of the Capital Group Sierra Club to call for denial of the Permit under subsection(3), (4), and (5) because the proposed quarry expansion will violate standards of air quality, harm public health and have a substantial negative impact on Umstead State Park. I am a research associate at the UNC Institute for the Environment in the field of air quality.
I have measured high levels of PM2.5 on my bike rides around Umstead State Park, especially at the entrance to Wake Stone at Starr Ln, due to fugitive dust emissions from the quarry. I am using a Plume Flow sensor, attached to my bike handles. I rode 2,000 miles from Jul 2019-Jun 2020 around Umstead State Park, tracking my exposure to PM2.5. On some days, the concentration at the quarry entrance reaches as high as 200 ug/m3, and this has resulted in my having a skin reaction that required steroids to recover from.
The exposure to such high concentrations of dust has also led to my having breathing problems at night. My doctor advised me to “stop going near the entrance to Wake Stone”, but I feel that I should be able to exercise safely, while riding into “THE ENTRANCE to OUR STATE PARK”. In addition NC GS§ 63–53 states Specific powers of municipalities operating airports. To lease such airports or other air navigation facilities, or real property acquired or set apart for airport purposes, to private parties,.(can be done)… provided that in each case in so doing the public is not deprived of its rightful, equal, and uniform use thereof. The public will be deprived of the safe use of Umstead State Park, the East Coast Greenway and the Odd Fellows Tract, therefore the permit must be denied.
I created a report outlining the air quality concerns https://docs.google.com/presentation/d/1QKLPu_3ILBoPzKjdnVGzqGkCQJLVfW6pDw5QTXneC4Y/edit?usp=sharing
I have also submitted two formal complaints about the fugitive dust emissions at the entrance to Wake Stone Quarry at 222 Star Ln to the NC Division of Air Quality.
I collected Trail User Survey data and created a report using Google Forms and Data Studio, with 597 people responding over the past month during the COVID restrictions. The report illustrates how many people are concerned about their health and safety if this critical link of the East Coast Greenway/NC-DOT Bikeway #1 is severed or impaired due to the quarry modification and RDUAA proposed security fence. https://datastudio.google.com/reporting/77843e9d-a90b-484b-ae8f-e94b9b5041fc
The online Environmental Justice Report can be created using EPA’s online tool. https://ejscreen.epa.gov/mapper/mobile/EJSCREEN_mobile.aspx?geometry=%7B%22x%22:-78.7668,%22y%22:35.8379,%22spatialReference%22:%7B%22wkid%22:4326%7D%7D&unit=9035&areatype=&areaid=&basemap=streets&distance=3
Here is a PDF copy of the report: https://drive.google.com/file/d/1v6QS__EHICzhvicCxUKVIIp_6MR_A7M2/view?usp=sharing
Note that the cumulative risks and impacts to the diversity of vulnerable Umstead Park Users, especially the children who attend all-day, week-long camps during the hot summer months is not captured in the above report, but it does indicate that levels of PM2.5, especially NATA* Diesel PM (μg/m ) and other criteria pollutants are elevated compared to other areas of the State of NC, and the US.
Please deny the permit modification due to the health and safety risks that this open pit mine has already created, and if allowed, will continue to create for 30+ more years. My concerns are shared by this research article: “This paper examines the inhalation risk associated with non-occupational exposures to respirable crystalline silica near peak sites. In this context peak sites are sites which are likely to release respirable crystalline silica particles into the nearby airshed including quarrying (both hard rock and sand). Communities living immediately adjacent to these sites are potentially exposed to elevated concentrations of respirable crystalline silica.” In addition to ensuring that air quality standards are not violated, the public must be protected from non-occupational exposure to silica. I have ordered a Silica PPI Sampling kit, and will share the results of this community testing effort.
https://pdfs.semanticscholar.org/2f45/88ad359671ea7f3724bd9d86587080ea92cb.pdf
The change of land use for the Odd Fellows Tract from residential R-40 with a long standing use of this land for camping by the boyscouts (up until 2017) to an incompatible industrial use next to a single family home on Wake County land that is zoned R-40 has deprived the owner of any recourse to address their grievances, as the RDU Airport Authority does not have a land use zoning ordinance or process for public hearings as required by N.C.G.S, and the Wake County Planning Department has stated that they will not require a rezoning or special use permit for this change as the land is under the jurisdiction of RDU Airport Authority.
The increase in GHG emissions due to activities required for the development of the new mining pit must be evaluated under Govenor Cooper’s Executive Order 80. https://deq.nc.gov/energy-climate/climate-change/nc-climate-change-interagency-council/climate-change-clean-energy. Site clearing will result in soil stockpiles that release GHG emissions. During mining operations, the capacity of the pre-existing vegetation to assimilate GHGs, especially CO2, is lost. Diesel-powered heavy equipment will be used for mining. Trucking of aggregates from the mining site to the project sites is also a source of GHG emissions. Note, there is no requirement for local sourcing of aggregate in the State of NC, so this site will not necessarily shorten the haulage distance. There are also no Clean Diesel Requirements for the non-road equipment used for mining and clearing activities. The State of NC and RDU Airport Authority must plan to reduce GHG emissions, and encourage sustainable development including voluntarily participation in low emission programs, but the applicant nor RDU Airport Authority have addressed how they will reduce emissions to protect Umstead State Park, the greenway users, and the adjacent home in the mining application. https://www.faa.gov/airports/environmental/vale/media/vale_techreport_v7.pdf
If the permit is not denied, then please require the strictest air monitoring with reports of PM2.5, PM10 and NOx values at the fence line to the public in real time according to NCGS https://www.ncleg.gov/EnactedLegislation/Statutes/PDF/ByChapter/Chapter_74.pdf that states a mining permit may be conditioned upon any reasonable requirements and safeguards the Department deems necessary to assure that exploration activity will comply fully with the requirements and objectives of this Article and of other applicable State environmental and public health laws.
Sincerely, Liz Adams
