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State releases proposal for public comment

Group urges public participation -- and public caution

RAVENA AND HUDSON -- Nearly 5 million tires could be burned yearly in a Hudson Valley cement plant, according to an application released for public comment today by State regulators.

Friends of Hudson, the 4,000-member citizens group best known for its key role in the successful six-year fight to prevent a coal-fired proposal by St. Lawrence Cement in Columbia County, will aggressively analyze the application and encourage citizens to make their views known to the State.

The organization learned on Wednesday that an application by LaFarge cement to burn tires in its Ravena cement plant has been deemed complete by the New York State Department of Environmental Conservation, and ready for public comment.

LaFarge seeks a permit to burn 4.8 million tires annually, storing up to 100,000 tires at a time in trailers on site, with an average of 13-20 trailers arriving and leaving the facility, located directly across from a public school, every day.

“As we did with St. Lawrence,” said Friends of Hudson lead attorney Jeff Baker of Young Sommer..LLC, “We will leave no stone unturned to ensure that this proposal is fully vetted. No project can be built unless it meets the strictest standards of environmental requirements.”


In recent years, Friends of Hudson has gathered extensive research, and expressed major concerns, about the use of Tire Derived Fuels (TDF) in cement kilns, which are generally not constructed or managed with incineration in mind.

In the case of LaFarge, specific concerns have come to light about the burning of whole tires, which are more likely to cause more frequent kiln “upsets” than shredded tires. Such upsets result in major temperature fluctuations and emissions spikes, as significantly more pollution and toxic chemicals are released in comparison to normal operating conditions.

According to the DEC’s notice, an “opening would be installed midway down the kiln tubes, and would open and close once every rotation of the kiln tube to deposit approximately 6 tires at a time in each of the two kilns.”


There is also significant concern about the reliability of LaFarge’s current management and monitoring processes. According to LaFarge’s self-reported Compliance Summaries to the DEC in the past four years, numerous human error and equipment malfunctions have resulted in a steadily rising number of Title V air permit compliance deviations.

“It would be unreasonable and irresponsible to allow this French-owned company, for the sake of its bottom line, to take even more risks with the health of local and downwind residents,” said Susan Falzon, Deputy Director of Friends of Hudson.

“This facility has a troubled history, and the public deserves every assurance that this plant is being operated safely and cleanly before it is asked to accept the additional risk of burning whole tires .” The facility, which received a $276,000 environmental fine from DEC in 2001, was recently awarded a Dirty Dozen Award by the Citizens Environmental Coalition in June 2005.

The dangers and public health risks inherent in tire burning, coupled with LaFarge’s past performance record at Ravena, give cause for skepticism about the ability of LaFarge to safely and reliably burn tires at this site. According to Peter Jung, Board President of Friends of Hudson,

“Citizens have a right to know what’s coming out of that stack at every moment and the state of New York has an obligation to ensure it. This project should not go forward unless there is highly reliable and highly accurate technology to ensure that emissions are within acceptable limits at all times.”


The proposal, which has been brewing for several years, has raised concerns throughout four New York counties, as well as downwind states such as Vermont and Western Massachusetts.

Friends of Hudson has attended public meetings on the project in Ravena-Coeymans, participated in scrap tire management conferences, and also hosted information sessions in area towns such as Coxsackie, New Baltimore, Castleton-on-Hudson, Stuyvesant, Valatie, and Kinderhook, among others. The Lafarge plant is situated close to the border of Albany and Greene county, and just across the Hudson River from the Rensselaer-Columbia border.


Burning tires in cement kilns is a particularly risky means of disposing of used tires, which Friends of Hudson recognizes should not be allowed to accumulate in dumps, either. In its dirty dozen award for Lafarge, Citizens Environmental Coalition stated that ‘Tire burning is not an adequate recycling solution to NYS scrap tire problem, as it merely converts solid waste to air pollution, and could provide a major disincentive to genuine recycling. ... This problem can be addressed through genuine recycling and re-use, such as road construction. In fact NYS Department of Transportation has committed to using all of the stockpiled tires in the state in road construction. Such recycling and reuse applications could address the challenge of scrap tire management in the state in a considerably more benign manner than TDF.”


It is the policy of Friends of Hudson to conduct careful research with responsible experts before taking a position on any issue. The organization will provide more information to members and to the general public once our experts have completed their review and analysis of the application. Friends of Hudson is encouraging citizens and elected officials in affected areas near and downwind of the Ravena plant to get as much information as they can and to participate in the review process.

“The expressed will of the public, combined with meticulous research by our legal and technical experts enabled us to prevail in the case of St. Lawrence Cement and we urge the same level of public participation now,” said Falzon.

The public can submit written comments on this application from now until September 2, 2005 to: William J. Clarke, NYSDEC Region 4 Headquarters, 1150 North Westcott Road,Schenectady, NY 12306 (518) 357-2069 |

The application and draft permit can be reviewed at the DEC’s Region 4 Headquarters; the Ravena Coeymans Selkirk Community Library at 15 Mountain Road in Ravena; and the Castleton Public Library at 85 South Main Street, Castleton.

A public information session will be held on Thursday, August 4, 2005 at 7 PM at the A.W. Becker Elementary School off Route 9W just north of the Village of Coeymans. A Legislative Hearing to take public comment will be held at the same location on Thursday, August 25 at 7 PM.

For more information, please contact Susan Falzon, (518) 822-0334 or e-mail