We, the undersigned faculty of the University of North Carolina, Wilmington agree that the proposed Carolina Cement Company/Titan America (“Titan”) cement manufacturing facility and associated limestone mines would: (1) be harmful to the health of the residents of New Hanover County and surrounding areas; (2) will not benefit the local economy as promised; and (3) will negatively impact air and water quality and the quality of life in the Cape Fear Region. Titan and the State have rushed to obtain permits and have fought efforts to inform our region of the actual societal and environmental impacts of the plant. In order for our community and state agencies to understand fully the cumulative effects of such a proposal, including all the externalities, we ask that all permit approval be delayed until a complete and comprehensive review of all impacts occurs. Titan has fought to avoid comprehensive review, and it recently declined the $4.5 million in promised state and local incentives. Acceptance of public monies under North Carolina’s Environmental Policy Act (“SEPA”) would have forced Titan to submit to comprehensive review prior to the issuance of any state permits. Furthermore, recent activity at the local political level has created an opportunity to revisit the decision to encourage high-polluting, low-technology industry to our environmentally sensitive region. Partly due to public outcry about the decision to grant Titan the incentives, a new Board of County Commissioners has been elected, and an opportunity now exists for the Board and residents to be involved in the permitting process and in shaping our region’s economic portfolio in a way that does not compromise the health of its residence or its environment. The proposed facility would be harmful to the health of residents of New Hanover County and surrounding areas. Air pollutants released by cement plants are harmful. They include particulate matter, sulfur dioxide gas, sulfate particulates , nitrogen oxides, carbon dioxide and monoxide, hydrochloric acid, mercury and a host of other air toxics. The Department of Energy reports that cement manufacturing has become the, "largest source of U.S. carbon emissions other than fossil fuel combustion." According to the EPA’s Toxics Release Inventory, cement plants self-reported releases to the air and land (in the form of waste disposal) of 142 different air toxics. Some of these air toxics are known to cause cancer, others impair reproduction and the normal development of children, and still others damage the nervous and immune systems. Many are irritants that can worsen already existing respiratory conditions, such as asthma, which leads to more lost school days, emergency room visits, and hospitalizations. Children and the elderly are particularly susceptible to the effects of air pollution. Children’s defense mechanisms have not yet fully developed; they breathe more rapidly and have more lung surface area for their body size. Because exercise increases the penetration of pollutants into the lungs, our children’s outdoor activities make adverse health effects more likely. There are 14 schools within 10 miles of the proposed plant, and the site is only 10 miles from downtown Wilmington. The magnitude of the risk is underscored because over 200 regional health professionals have publicly registered joint opposition to the project. Mercury is of particular concern. High temperature combustion of materials containing mercury (such as coal and limestone used in the manufacturing of cement) is a significant regional and global source of mercury. Titan concedes that some airborne mercury will be deposited in the Northeast Cape Fear, and wastewater containing mercury may be discharged directly. Southeast North Carolina’s marshy environment is particularly favorable to transformation of aerially deposited mercury into the well-known toxic form, methylmercury. Methylmercury bio-accumulates in organisms as it moves up the food chain. Humans are exposed to methylmercury almost exclusively from eating fish. The Northeast Cape Fear is already designated as “impaired” for mercury contamination. Southeast North Carolina is under a fish consumption warning but the people who eat the fish may have few choices except to continue eating and risk the toxic effects. Children are most vulnerable to mercury’s effects, whether exposed in utero or as young children, because methylmercury disrupts the orderly development of the brain and nervous system. Mercury’s effects may manifest in school-age children as vision and hearing difficulties, delays in language acquisition and fine motor skills, lower IQ, and memory and attention deficits. These effects translate into a wide range of learning difficulties in the classroom. According to the National Academy of Sciences, children so affected will likely have to struggle to keep up in school and might require remedial classes or special education. Impairments can last a lifetime. The proposed Titan Cement Facility could emit mercury in amounts as high as 263 pounds per year as requested in its draft air quality permit - and the State’s Division of Air Quality agreed! The limestone located in this region contains a particularly high level of mercury, thereby increasing the level of mercury emission. Accordingly, this region is a particularly poor choice for the siting of a cement manufacturing facility. The proposed facility will negatively impact the Cape Fear Region. Construction and operation of the proposed project will result in heavy impacts to the coastal environment, from filling of wetlands to air pollution. The effect on fish populations is a key concern according to the chair of the North Carolina Marine Fisheries Commission (NCMFC). The Northeast Cape Fear River has been designated as a Primary Nursery Area by the North Carolina Marine Fisheries Commission, and both the river and Island Creek have been designated as Anadromous Fish Spawning Areas by the NCMFC and the North Carolina Wildlife Resources Commission. Seven of the nine diadromous fishes that are known to occur in the Cape Fear River drainage have been documented in the Northeast Cape Fear River and/or Island Creek by the Division of Marine Fisheries and others. These species include American eel, American shad, Atlantic sturgeon, blueback herring, hickory shad, shortnose sturgeon, and striped bass. There has been a fishing moratorium since 1991 on the shortnose sturgeon (listed as federally endangered), and the Atlantic sturgeon (currently being considered for listing as federally threatened. In addition, the stocks of the blueback herring and striped bass populations are depleted regionally as well as locally; accordingly, a fishing moratorium was implemented in 2008. Also of concern, the East Coast stocks of American shad are at all-time lows according to the latest 2008 Atlantic States Marine Fisheries Commission stock assessment. The status of the American eel is unknown but the Atlantic States Marine Fisheries Commission has concerns. Several of the species that inhabit these waters serve as a valuable food source for other marine species such as king mackerel and tuna. Both of these species have shown evidence of being impacted by the presence of mercury in the food chain. Through these fishing moratoria and other restrictions our commission has tried to meet its statutory duties regarding conservation of these fisheries resources. Degradation of habitat and water quality by projects such as the proposed Titan facility limits the State’s ability to restore these fisheries. Millions of taxpayer dollars are now being spent to restore viable breeding populations of these fishes to the Cape Fear River system by creating fish weirs at the locks and dams. The aim is to bring back viable and economically stimulating sport fisheries. Toxic emissions from this facility could pose substantial risk to the critical fisheries of the Cape Fear system by polluting the air, wetlands and waters that are critical to healthy fish stocks. It makes little sense to restore these fish populations while poisoning them. These ecological and economic impacts would be felt for decades, long beyond the useful life of the plant itself. Titan’s cement plant would produce up to 2.4 million tons of cement per year, requiring some millions of tons of limestone annually to be quarried from the same limestone formations that now support a major drinking water source, the Castle Hayne formation. New Hanover County just brought on-line a well field tapping 4 million gallons per day of drinking water, half of it from the Castle Hayne formation. Titan would mine this same formation and create several serious problems in our aquifer. Blasting contaminates the water with explosives by-products, including toxicants like benzene. Dewatering of limestone quarries would remove millions of gallons of water per day from the aquifer, creating a “cone of depression” around Titan’s mining operations that could disable New Hanover County’s wells as well as the drinking water wells of numerous private residences. If Titan mines 2 million tons of limestone per year, it would need to create quarries 20 acres in area and 60 feet deep each and every year for the lifetime of the operation – potentially thousands of acres in the next half-century, removing this land permanently from any other productive use and tying up a major water supply for the residential population and other users for decades. The proposed facility will not stimulate the local economy as projected. Titan has projected that the proposed facility will: (1) create 160 new jobs, which would pyramid into 720 new jobs within the county; (2) bring an additional $235 million dollars of economic activity to the county, and (3) result in an additional $20 million of rental and dividend income to the county. The profits will go to the foreign ownership. However, Titan’s economic models failed to account for many key factors, such as dispersive forces (those forces that are associated with a new plant opening). Over the time, dispersive forces reduce economic activity because of: (1) increases in input costs; (2) congesting existing infrastructure; (3) the perception that an area is favoring low technology or heavy manufacturing; (4) crowding effects that discourage other competitors; (5) commuter employees who live outside the county and take their income out; and (6) the disastrous economic effects of pollution in health, property and other economic loss. Based on studies of the actual long-term economic effect of new plant location decisions in the Southern States that are far more accurate than the hypothetical models used by Titan, Titan Cement overestimates the positive employment impact by as much as 15 times. These studies confirm that location of low-technology firms may actually decrease countywide employment and long-term economic activity. Clean and sustainable industries seek a healthy environment for their employees, and polluting industries hamper recruiting efforts. Entrepreneur and successful CEO Chuck Agnoff has personally witnessed prospective new, clean industries reject this area because of environmental concerns even before Titan health concerns arose. He wrote in an editorial opposing Titan: The reason I've now stopped supporting similar recruitment efforts for new companies is a matter of conscience. How can I tell prospective employers to relocate in a city, which may soon be inundated with mercury and other pollutants spouting out of a cement plant smokestack with over 8,000 children within five miles of it? Worse yet, there is the specter that all of us within a 27-mile radius will be affected, not just for a single day, but every day of the year.....Gaining a few hundred well-paying jobs at a cement plant sounds particularly good in these tough economic times, but we will surely lose thousands of future jobs.... For those of us who remain, we will become victims of mercury pollution. Is this what you came here for? Is this what you want for your children and grandchildren? I surely don't. The studies also show that new low-technology or heavy manufacturing locations result in a decrease in resident consumer spending and associated sales tax collection, since for each 100 workers hired, the county of the location lost on the average 72 residents. The only industries that consistently generated positive economic effects at the county level were high technology, financial services, and some sectors of communications and other services. Conclusion For the foregoing reasons, we, members of the faculty of the University of North Carolina, Wilmington, speaking only for ourselves (and not the University), agree that the proposed Carolina Cement Company/Titan America cement manufacturing facility and associated limestone mines would: (1) be harmful to the health of the residents of New Hanover County and surrounding areas; (2) will not benefit the local economy as promised; and (3) will negatively impact air and water quality and the quality of life in the Cape Fear Region. In light of Titan’s concerted efforts to avoid comprehensive review, we the undersigned faculty remains concerned about the proposal and insists that: 1. The state agencies heed the precautionary principal and delay the issuance of any permits until a comprehensive environmental review of all impacts is completed. 2. That the New Hanover County Board of Commissioners revisits the decision to encourage high-polluting, low-technology industry to our environmentally sensitive region. Information about the human health impacts of the proposed facility was extracted from research by Dr. Steve Skrabal and Dr. Martha Keating. Dr. Skrabal is a marine chemist with whose research interests include the chemistry of heavy metals in sediments and waters of estuaries and the ocean. Dr. Keating is the Director of Research Translation at Duke University’s Children’s Environmental Health Initiative. Her research focuses on addressing the impacts of environmental exposures on vulnerable populations, environmental justice, and regulatory policy development. Drs. David Hill and Frederick Opper also provided information and over 200 physicians in the Wilmington area have signed a letter opposing the plant on the basis of health concerns, particularly for vulnerable populations such as children and the elderly. Information about the environmental impacts of the proposed facility was extracted from a comment letter by Mac Currin, Chairman of the N.C. Marine Fisheries Commission. Information about the economic impacts of the proposed facility was extracted from research by Dr. Craig Galbraith, who is the senior Professor of Entrepreneurship and Technology, and GlaxoSmithKline Faculty Fellow in economic development at the Cameron School of Business at UNCW. Chuck Agnoff, Star-News opinion, April 24, 2009; HYPERLINK "http://www.starnewsonline.com/article/20090424/ARTICLES/904244005" http://www.starnewsonline.com/article/20090424/ARTICLES/904244005