Item B: Delta Sand and Gravel Metro Plan Amendment

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Lane County Board of Commissioners and Eugene City Council January 29,2007 Page 5 Opponents argue that Delta has not conducted an air dispersion model similar to that conducted by Eugene Sand & Gravel Company in its application to locate a new mining and processing site north of :Eugene. This application is not similar to that of Eugene Sand & Gravel Co. Delta is not attempting to establish a dust-producin.g facility as Eugene Sand & Gravel attempted. It is merely asking to expand its current mining site with its current dust-producing and dust- minimizing operations. In its permitting of the Delta operation, LRAP A has already factored in the dust-producing considerations that the opponents claim. m.ust be accomplished in tl1is proceeding. Nonetheless, in consideration of the potential dust created by the haul roads (and considering that mining does not create a significant amount of dust and that the crusher is operated and limited in production by the LRAPA permit), Delta requested that LRAPA conduct an air dispersion model for its haul roads. LRAP A published its "Delta Sand & Gravel Haul Road Analysis" on November 1, 2006, and a copy of that 'publication is included in the record of this 'proce.eding. In that analysis,LRAPA stated: "The modeled impacts from each haul road, added to am.bientmonitored concentrations, is below the PMIO national ambient air quality standard." .LRAPA's analysis took into account myriad factors, including haul road length and width, truck tire size, number of trips, etc., to reach its conclusion. Opponents continue to offer the testimony of Dr. Stephen Kimberley, regarding the negative health effects of "rock dust." Delta continues to point out that Dr. Kimberley has not visited the site and has not testified that Delta's mining operation will create the kin.d of "rock dust" that he has testified about. He has merely provided testimony on the effects of "rock dust." He has provided no evidence that Delta actually produces his type of "rock dust" while performing mining operations at its current facility. Based upon Dr. Kimberley's own testimony, the "rock dust" that he discusses is the type of dust that occurs during the crushing of rock and rock material. If De"lta produces any of the type of "rock dust" that Dr. Kimberley discusses, it produces that dust at the rock crusher. The rock crusher, and the dust it creates, is regulated and limited by the LRAPA permit and its production cap. Delta has continually maintained that the rock crusher will not be moved or relocated as a result of approval of this application. Delta has continually testified that its rock crushing operation will not change as a result of its obtaining additional resource to mine. Furthermore, Delta has testified and visually demonstrated that it does not create significant levels of any kind of dust during its mining operation. Delta's potential prod'uction of dust prim.arily occurs at the rock crusher and on its internal haul roads. Delta's operation of both the crusher and its haul roads are regulated by LRAPA under it current permit. That permit requires a production cap on the crusher an.d requires that the haul roads be continually watered. Delta's adherence, to those requirements permits it to operate its crusher and to haul aggregate material on its internal roads. Delta has met those requirements for decades and opponents have provided no evidence that Delta cannot continue to meet those requirements as applied by LRAP A to the expansion area. 4. Delta has demonstrated that potential noise impacts can be minimized.