Item B: Delta Sand and Gravel Metro Plan Amendment

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Ms. Arkin said LRAP A did not l1ave the staff or the funding to do fence line testing of dust emissions. She said LRAP A was sampling the quality of the air for a large area and could not pin point problem areas. She said if th.e neighbors COtllplained about dust emissions LRAP A had no means to address the issue. She added that there \vas a DEQ standard for enlissions that \vas ellforced but referred to another application wIlere the applicants had gone beyond the enforced standard for enlissions. Ms. Arkin noted tha.t the record contained a letter from School District 4J stating that the expansion site was close to a plaruled school site and expressed concern over health to the children due to particulate matter generated by Delta. Mr. Becker said the enlission standard \vould the sall1e as it wa.s cUITently and \vould not change regardless of proximity to residential areas and as long as the facility lnet the standard then proxiInity would not matter. Mr. Zdzienicki said LRAP A was a complaiIlt driven agency that did no analysis utlless someone made a cOlnplaint Ms. Colbath sa.id LRAP A \vould be tile body to enforce stricter standards for dust enlissions. She acknowledged that it would be hard to enforce those standards and expressed a desire to look at other lnitigation measures that nlight be taken. Sllesaid she \vould assume that all mitigatiol1smeasures \vould be il1cluded in the application but rai.sed concenl that staff \vas trusti11g that an LRAP A permit \vould be issued and questioned whether tllere was an)' evidence that the permit would be confinlled.. 'Ms. . Scl1ulz said the expansion area would be added to the existing permit. She added that LRAPA 11ad said tIlat it had completed the revie\v of the proposal and tIle Ctlrrent permit remained valid. She tIoted that this \vas documented in the record. Ms. Colbath questioned \vhether there '\rvas sufficient evidence about enlissions to tIle west side of the site and questioned \vhether there was any detail in the record about an air dispersion model to the west of the site. Ms. Schulz said east winds happened so infrequently that there \vas nOCOtlCem among staff about dust lnitigation to that side. In response to a question from Ms. Colbath regarding ho\\! far the planlled elenlentary school was from the site in quystion,Ms. Schulz said it \vas beyond the identified 1,500 foot impact area. Mr. Lawless noted that there \vasa conflict due to dust that could be nlinimized to a level that met DEQ standards.. He said the pernut issued by LRAPA was a.separate process" He said the issue ,vas whether there were some mitigation metl1odsthatcould meet LRAPA and DEQstandards. He said it was a separate matter whether LRAP A traveled around the boundaries of the property and took dust emission readitlgs" Mr. Belcher said LRAP A standards did 110t take into account the proximity to residents" The only option '\rvas some sort of setback to deal with that issue. t\1INUTES-Lane County Plan:ning Comnlission July 25, 2006 Page 9