Lafarge Ravena is located directly across the road from the local middle school and high school. This Ravena-Coeymans-Selkirk campus is the site of various athletic activities throughout the year. Children at these and other schools in the area are exposed to the pollutants and toxins. Furthermore, these emissions are carried great distances through the air, and therefore residents to the east, in Columbia and Rensselaer counties and beyond, are also the recipients of Lafarge’s emissions.

Over the past forty-six years, the Ravena plant has been modified several times in an effort to make its technology more efficient and to meet new environmental and regulatory standards. During those years, the plant’s ownership has changed a few times. In 2001, Lafarge acquired the facility from Blue Circle and has stated that it has since invested millions of dollars in emissions technology and efficiency upgrades. 

Despite those investments, Lafarge is no longer able to operate the facility cost effectively. It is not able to meet current emissions standards consistently, and it will not be able to comply with new standards that will be enacted in the near future. The renewal review of the plant’s Title V Air Permit under the Federal Clean Air Act, which expired in 2005, revealed to Lafarge and to state regulators that major changes would be required. Therefore, earlier this year Lafarge notified the New York State Department of Environmental Conservation (DEC) of its intention to build a new dry-process kiln to replace the current kiln, which is considerably less efficient to operate and far more polluting. The 3,200-acre site includes the cement plant, a conveyor system between the plant and its docking and loading facilities on the Hudson River, and the quarry itself. According to Lafarge, most of the existing buildings and structures will remain and be re-used. The kiln and the cement stack will be new.

In order to be granted permits to build and operate the new kilns, Lafrage's modernization proposal must be reviewed under the State Environmental Quality Review Act (SEQRA). This review is designed to allow the state and the public to determine whether the environmental impacts of the project comply with federal and state environmental standards. The SEQRA process is a relatively lengthy one with several distinct steps, each with its own set of requirements. In July and October 2008 respectively Lafarge submitted the Environmental Assessment Form (EAF) and the Scoping Document. The EAF submitted by Lafarge was reviewed by DEC, which determined that this is a major action under SEQRA with potential harmful environmental impacts and therefore issued a “positive declaration,” a finding that requires the company to prepare an Environmental Impact Statement (EIS) for review by the agency and by the public. Subsequently the Scoping Document was prepared by Lafarge and submitted for review. This document outlines the proposed scope of the environmental review. Once the scope has been agreed upon, the company begins the preparation of its EIS.

The public has an opportunity to comment in writing during each stage of the SEQRA process. The Public Comment Period for the Scoping Document ends on November 10. After that date, the DEC will review the comments and decide what will be included in the final version of Scoping Document.

Lafarge and DEC both contend that the new manufacturing process will significantly reduce the emissions impacts of the current process. Friends of Hudson (FoH), the citizen environmental organization that, along with Scenic Hudson and The Olana Partnership, led the successful opposition to the proposed St. Lawrence Cement "Greenport Project," has agreed in theory that the proposal is a positive step. The cement plant at Ravena has long been known as one of the worst, if not the worst, polluters in the region. In 2005, FoH expressed concern that the current facility has frequently exceeded its permitted emissions levels with no repercussions.

Lafarge Ravena is also one of the worst polluters in the country with respect to mercury emissions. In 2007, it was reported to be emitting 400 pounds of mercury annually.  Lafarge and other cement manufacturers have used fly ash, a byproduct from coal-burning power plants, in the cement manufacturing process. Because the latest federal regulations for power plants limit their mercury emissions, fly ash from these plants has increasingly higher amounts of mercury, which in turn goes into the cement-making process. Because of a loophole in federal and state regulations, there are no existing standards for mercury emissions from cement plants. There has, therefore, been no requirement for Lafarge to reduce its emissions of this known developmental toxin, which is especially harmful to women of childbearing age and to the neurological and cognitive systems of fetuses and young children. Simply stated, mercury can impair a child’s ability to walk, talk, and learn.

There is, in fact, nothing that comes out of a cement plant stack that is benign with respect to health and environmental impacts. The SEQRA review of Lafarge’s proposal will examine the quantities of pollutants and toxins that would be emitted from the new process and to what extent these emissions meet the allowable limits. The DEC will ultimately decide whether to reject the proposal, approve it, or require modifications for it to be approved.

This is where the public has an important role to play. During preparation of the EIS, the company will project the potential impacts based upon calculations and modeling conducted by engineers, technicians, and scientists. Since the public has the opportunity to comment on these projections, it can help to ensure that DEC has all of the relevant information and does not simply rely upon the assertions that the company makes. The public also has the opportunity to inform DEC of their concerns about the proposed project. During its participation in the SLC review, Friends of Hudson employed its own technical and legal experts to rigorously examine and test that company’s EIS. More than once, in issues critical to the ultimate determination, the group’s experts found the company’s assertions and conclusions to be inaccurate or inapplicable. For example, conclusions based on the company’s air modeling were found to be faulty because the model itself was not based on sound data. In another striking example, when large helium balloons were raised to the heights of the proposed structures, the company’s previously projected visual impacts were shown to be highly inaccurate and severely understated. It is clear from this experience, as well as from the experiences of other citizen organizations, that full and active public participation in the process is critical to ensure that an environmental review is thorough and accurate before any permitting decisions are made.

Friends of Hudson has pledged to take an active role in this review process. As a first step, the group is submitting written comments on the Scoping Document and is urging all concerned citizens to do so as well. The issues raised in FoH’s comments include the following:

• that mercury emissions be severely restricted despite the absence of federal government guidelines for mercury emissions
• that mercury emissions be measured with and without the use of fly ash in the manufacturing process before permitting fly ash to be used without limitations
• that local onsite meteorological data be collected and used for modeling emissions impacts instead of relying on data from Albany Airport which is not likely to reflect actual conditions
• that the air modeling protocols be made available for public review and comment before being accepted for the review

This is a once-in-a-lifetime opportunity. If this plant is approved it will likely continue to operate for forty to fifty years, a span of nearly two generations. Given that, it behooves the public to ensure that the DEC does not permit anything that falls short of the strictest standards based on the most recent and up-to-date knowledge and understanding of impacts and of control technology. If it is to operate without replacement for decades to come, the Lafarge plant at Ravena must be made to meet or exceed the highest possible standards for the health and safety of the public and our environment. There is no reason why it shouldn’t be able to make such a commitment to the community that has hosted it for so many decades and would like for it to continue to provide the economic benefits it has in the past.

Written comments on the Scoping Document will be accepted by the DEC until 5 PM on Monday November 10, 2008.  The public is encouraged to submit comments reflecting the above issues and other concerns. Long formal documents are not required. A personal note submitted via e-mail is sufficient at this stage. Comments should be addressed to:

Ms. Sarah Evans

NYS DEC

Region 4 Headquarters

1130 North Westcott Road

Schenectady NY 12306

r4dep@gw.dec.state.ny.us

Susan Falzon is the current director of Friends of Hudson. She can be contacted via email at sfalzon@mac.com.