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COMMENT GUIDE
On our Website:
- A Decision is Coming...
- Write a Letter Today!
- Address/Fax List
- Coastal Resources FAQ
- SLC Factsheet
- 44 Reasons to Stop SLC
State Guidelines:
- Consistency Review
- Coastal Policies
+ Development
+ Fish and Wildlife
+ Flooding and Erosion
+ General Safeguards
+ Public Access
+ Recreation
+ Historic and Scenic Resources
+ Agricultural Lands
+ Energy and Ice Management
+ Air and Water Resources
+ Wetlands
- Coastal Policies (pdf)
- Scenic Areas
- Public Notice
- Coastal Laws (pdf)
SLC Documents:
- Main application (pdf)
- Map of Proposal (pdf)
- Appendix A (big pdf)
- Appendix B (pdf)
- Appendix C (pdf)
- Appendix D (pdf)
- Figures & Photos (big pdf)
NEW DEADLINE: MARCH 18th

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44 REASONS
why Coastal Resources should stop St. Lawrence Cement
REASON #1:
Just one new job.
While SLC dodges the topic in its Coastal application, it has conceded to other regulatory agencies (such as NYS Dept. of Environmental Conservation) that "the proposed project would result in little net change to SLC employment." (DEIS p. 3-14) With 154 workers already in the area, and only 155 after construction, an increase of one new, permanent job is expected. This is not adequate economic benefit to offset the harsh negative impacts to the Coastal Zone.
REASON #2:
Serious health hazards.
The Columbia Memorial Hospital medical staff voted 35-1 in March 2001 that the plant would pose "a serious risk to the health of our community." Lung and heart patients, residents with asthma, kids and the elderly would suffer most. These CMH doctors voted 55-0 in September 2004 that changes to the plant design proposed by SLC, including a somewhat lower stack, would actually increase the potential harm to their patients in the local community.
REASON #3:
Bad track record.
SLC's owners have paid major fines in the U.S., Canada, and Europe for air and water pollution, as well as for price fixing -- profiting at the expense of public health and host communities. For example, the Holcim-run plant in Midlothian, Texas, which SLC itself touted as a model for its Greenport plan during a company-sponsored trip for local representatives, was subsequently fined $220,000 by Texas regulators for failing to make that community's air "cleaner" as promised.
REASON #4:
Waterfront noise and blight.
SLC's enormous new docking facility would include open stockpiles of coal, right next to a new public park on the Hudson waterfront. Families would be expected to enjoy picnics, sports and boating amid fugitive dust, sirens from cranes, diesel barge emissions, and dangerous wakes from HudsonMax vessels from the SLC operations next door. The State and Federal governments have made substantial investments to revitalize the City's waterfront (and that of the Village of Athens) for recreational and commercial activity; those investments would be wasted by siting of SLC's project.
REASON #5:
Harm to clean industries.
SLC's environmental impact statement, filed with a separate agency (NYS DEC) "estimates that in total, there is no new net spending in the regional economy in the future." (DEIS Page 3-15) Meanwhile, the presence of a major industrial polluter would arrest the growth of the existing area economy based on a balance of agriculture, retail, tourism, home renovation, light manufacturing, and a booming real estate market. Business owners from all of these sectors have expressed their firm opposition to the project due to the likely harm to their continued growth and productivity from SLC's polluting and blighting activities.
REASON #6:
Increased pollution.
SLC has argued in bad faith that local air would become cleaner due to the closing of an older but much smaller plant. Page 4-3 of their NYS DEC air permit application and subsequent company emissions calulations show a potential 43% increase in regulated pollutants, including 2.1 times more dust, 3.4 times more volatile organic compounds, and 12.6 times more carbon monoxide. Recent company claims to have reduced its emissions are not supported in its application to Coastal Resources, which fails to present any data or assertions that can be verified by independent experts.
REASON #7:
Substandard technology.
Contradicting claims of a new "state of the art" facility, a June 29, 2001 memo from U.S. EPA Region II concluded that SLC had failed to make use of the latest technologies -- some of them already in place at other facilities owned by the same company. And In 2003 and 2004, the major national engineering firm Camp, Dresser & Mckee presented detailed new evidence to State regulators that SLC had failed to keep up with additional advances in the cement industry, proven to be far more effective than the Greenport plant design in reducing pollution, such as Selective Catalytic Reduction.
REASON #8:
Region-wide impacts.
Neighboring counties and States are mounting challenges to the proposal, including the Massachusetts DEP and the Governor of Maine, the Village of Athens in Greene County, the Environmental Management Council of Dutchess County, and the Attorney General of Connecticut - - who has stated that he will sue New York State if it permits this facility. It is not in the interest of the State to antagonize our regional neighbors, with whom it needs to work collaboratively to reduce public health threats and promote sound development policies in the NorthEast.
REASON #9:
Waste incineration.
Cement kilns often double as incinerators of tires and toxic waste. An SLC executive told Hudson's Council President that that the company "will not make a lifetime commitment to not burn hazardous waste at the plant," and refused to modify a proposed (now tabled) "host agreement" with the City for that specific reason.
REASON #10:
Bad precedent.
If such a massive project, burning 500 million pounds of coal annually, were permitted in the heart of the Hudson Valley, it would set a bad precedent making it virtually impossible to prevent other blighting and polluting proposals that would follow. Opponents do not reject all industry, and indeed include many business leaders among us. Rather, the scale of the St. Lawrence cement project is too extreme and inappropriate for this location; it is the rare development project which cannot coexist with cleaner, more sustainable industries which are driving the region's low unemployment rates and improving property values.
REASON #11:
American Lung Association
Echoing the concerns of the Columbia Memorial Hospital doctors, the nationally-respected American Lung Association has concluded that "The pollution belched by this coal-burning plant would not only trigger asthma attacks in children and cause serious respiratory problems in seniors with lung disease, it would put at risk the health of those of us who do not currently suffer from respiratory problems."
REASON #12:
Continued Catskill blight
SLC's old Catskill site would remain active as the dump for the Greenport plant. Both dry and wet wastes (including mercury-filled sludge from the plant's "pug mill") would be trucked over the Rip Van Winkle Bridge daily to be landfilled in Catskill. The Catskill site would also be used for bagging slag cement. In short, the Valley would get two blighted industrial sites on the river, not just one.
REASON #13:
SLC uses 'mitigation' as blackmail
St. Lawrence should get no credit for promising to take down rusted, crumbling structures on its own property - - if and only if it gets its Greenport permits. These blighting structures could and should have removed by SLC years ago, duing the past quarter century that it has owned its Hudson Valley properties. If the State were now to accept the removal of such structures as "mitigation" from the new blight of the Greenport project, that would encourage other companies to delay remediating their own properties, so as to use defunct and delapidated structures as bargaining chips in permitting reviews. Blackmail is not an acceptable form of mitigation.
REASON #14:
SLC's lawlessness and bad stewardship
SLC's unpermitted bulldozing of wetlands in Hudson's historic and ecologically important South Bay during the Spring of 2004 is a glaring example of the company's poor stewardship of its property, and lawless attitude toward its Hudson Valley operations. Similarly, the Catskill plant was subject to some 16 enforcement actions by NYS DEC in the 1990s. Such examples point up the lack of trustworthiness of the applicant to meet its stated goals of pollution control and site management.
REASON #15:
Highly visible plume.
SLC's own application materials grudgingly admits that there would be a visible plume on the Greenport plant an unacceptable percentage of the time: 82% in Winter, 49% in Fall, and 34% year-round. While the company attempts to "define down" the definition of a "worst case plume," the application shows that the true worst case is a plume of more than 20,000 feet in combined height and length. Moreover, one protected viewshed should not be impaired to (allegedly) improve another.
REASON #16:
Risk to vulnerable populations.
St. Lawrence's proposed coal-fired stack would be within a mile of John L. Edwards Elementary School, Columbia Memorial Hospital, the Cavell Cancer Treatment Center, the Hudson Correctional Facility, local water supplies, and densely populated residential neighborhoods in Hudson and Greenport. Many other educational and health care facilities can be found within a five-mile radius of the plant. Siting a heavily-polluting facility near such vulnerable residents and facilities is not smart land use planning.
REASON #17:
Contrary to Estuary Management Plan
SLC's proposed waterfront operations run counter to Governor Pataki's Hudson River Estuary Management Plan. That plan specifically cites the City of Hudson as a prime location for expanding public access to the River; and the highest priority of Estuary Plan is to expand such access. By grievously harming the public's ability to enjoy the Hudson waterfront park and the commercial-recreational facilities being developed there, due to noise, light pollution, fugitive dust, and boating hazards, SLC's plans interfere with the State's clear priorities for the Hudson River.
MORE REASONS TO FOLLOW! Check this page regularly throughout the comment period, as the remaining 44 Reasons will be steadily added to this site.
Please write a personal, heartfelt letter today to the agency, telling them why you oppose SLC. Click HERE to get started. For more info about this agency and the project, please explore the links at left, or contact us by phone (518.822.0334) or email (click HERE).
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