Comments on Public Health Risks Related to the
Proposed Asphalt Plant in the City of Brunswick

By David Kyler
Executive Director Center for a Sustainable Coast
July 7, 2004

My name is David Kyler. I represent the Center for a Sustainable Coast, a non-profit membership organization established in 1997 to represent the public interest in issues related to coastal Georgia's growth, economy, and environment. On behalf of our board, advisors, and members, I wish to advise the city about public health risks associated with the proposed asphalt plant that raise serious questions which must be addressed. These questions strongly suggest the need to find a more acceptable location for the proposed facility, away from any residential area.

Operation of the asphalt plant will produce substantial diesel truck traffic, estimated to be at least scores if not hundreds of arrivals and departures per day at the plant site. Cumulatively, especially at peak periods, due to the number of trucks and the length of time they will have engines idling while at the site, there is likely to be a harmful level of diesel exhaust released into the air in the plant vicinity. This burden could prove to be an unacceptable health risk to those living in the area, with serious short- and long-term implications for families, especially children and the elderly.

Based on extensive study, EPA has listed diesel exhaust as a carcinogen, as well as a serious cause of respiratory illness. In an EPA report giving the relative health risk of diesel soot and several of its most lethal components, Glynn County is among the top 40% of counties at risk in Georgia, based on average particulate density in the air. We know that concentrations of critical particulates are much higher in some areas of Glynn County than others, based on personal observation of industrial emissions, paralleled by health records of residents living in both the City of Brunswick and in certain areas of unincorporated Glynn County. The severity and frequency of respiratory illnesses in the Brunswick area, including asthma among children, indicate adverse consequences of already existing air quality problems in the community that the proposed plant would further compound.

Given average ranking of local health risks linked to diesel soot and its constituents, further amplified by the knowledge that these average ratings are greatly exceeded in certain places within the city and county, any further loading of the community's air with these particulates must be carefully evaluated prior to approval of activities that would generate them. While the state does have limited regulatory authority over some of these air emissions, there are no standards nor regulations in Georgia to prevent excessive, cumulative air quality degradation caused by site-specific pollutants emitted by a multitude of diesel-burning trucks and possibly other heavy equipment related to the proposed asphalt plant operation.

Until these effects are further studied, evaluated, and, as necessary, appropriately regulated, we strongly advise against approval of this plant in, or nearby, any areas occupied by residents, school children, or other vulnerable groups.

To be sustainable, human activities must use resources responsibly, in ways that will ensure that future generations can also benefit from nature's bounty, while leading healthful, productive lives. Actions in the present that impose avoidable harm or unjustified risk on this and future generations of our citizens are not sustainable, and cannot be responsibly approved by public officials who are obligated to protect the public interest.

I urge you to carefully consider these comments in reaching a decision to prevent approval of the proposed asphalt plant, at least until these crucial health questions can be reliably answered by qualified, objective experts. The public's welfare and living environment depend on your insight and accountability.
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