TOWN OF BERNALILLO APPROVED ANNEXATION OF FISHER SAND AND GRAVEL

Posted on January 13, 2015 by admin

The Mayor and Council of the Town of Bernalillo approved an ordinance to annex the Fisher Sand and Gravel Site, which is located along I 25, just south of Placitas. The ordinance also changes the zoning of the site to M-1 and permits Fisher to apply for a Conditional Use Permit.

ES-CA continues to oppose all mining in the Placitas, Algodones and Bernalillo area. ES-CA representatives testified at the meeting and also submitted a number of recommendations to the Mayor and Council. Many of these recommendations were adopted into the ordinance, and, while the Board continues to oppose mining, we believe that the ordinance gives the Town much control over the operation of the facility, most importantly stating that all mining activity will cease within seven (7) years of the beginning of operations.

Fisher initially asked for no time restriction on the length of operations and then asked for fifteen years. ES-CA countered with a recommendation of no more than two years. ES-CA ultimately requested a five year limitation, but the Mayor and Council voted to accept a seven year limitation.

Major components of the ordinance are:
• Hours of operation will be limited to Monday through Friday, 7 am to 5 pm.
• No asphalt operation will be permitted.
• Fisher must reclaim the site within one year of ceasing operations and they must also provide a bond to insure that reclamation occurs.
• Water use will be strictly monitored by the Town.
• The conditional use permit will be reviewed every year to insure that Fisher is in compliance with all of the requirements of the approval.

ES-CA officials have met with Mayor Jack Torres and Fisher VP Dave Olson on numerous occasions to discuss this matter. We believe that we will be able to work with Fisher on any issues that arise during the life of this project and ask that residents contact us immediately about any issues affecting them that come from the operation of this facility.

ES-CA would like to thank Mayor Torres and the Council for their consideration of ES-CA’s submissions and for incorporating many of the recommendations into the final ordinance. The ES-CA Board believes that we have taken the best course of action in this matter. We did not believe that there was an option that would have prevented Fisher from operating and we believed that the best course of action was to gain some control over the operations. Limiting the lifetime of the operation, limiting the hours of operation, prohibiting any asphalt operations and fostering a working relationship with both the Town of Bernalillo and with Fisher, gives us a good measure of control and we believe that is the best outcome in this situation.

This project will also provide a sorely needed detention basin to help alleviate the storm water flooding that has occurred in Bernalillo in the past few years. While ES-CA remains committed to protecting the interests of Placitans, we also are committed to working with all residents in the County and must be cognizant of their needs.

ES-CA looks forward to continuing to work with the Town of Bernalillo on issues of mutual interest. ES-CA will also continue to monitor the operations of Fisher and will respond to any issues that arise.

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Proposed Gravel Mining Legislation

Posted on January 12, 2015 by admin

The 2015 Legislature will consider legislation crafted by ES-CA and drafted by Representative Jim Smith, and according to Jim, Senator John Sapien has asked that he be included as a co-sponsor. This legislation is important not only to the health and welfare of Placitans, but to other New Mexicans that cannot locally defend their well-being against well-funded mining operators and their lawyers.

There are two Bill drafts. The, Zoning Enforcement law would bolster a County’s ability to administratively enforce its zoning laws in regards to gravel mining violations. Sandoval County interprets NM Statute 4-37-3 NMSA 1978 to limit penalty to a mine that has violations, such as Fisher or Vulcan (previously Lafarge), to a one time fine of $300. Bernalillo County interprets the same statute to allow the penalty per violation and per day which significantly increases its ability to enforce a violation. Still, with substantial daily profits out of mines like Vulcan’s, even if the penalty were assessed daily, it may not represent even 1/100th of a mine’s daily revenues. The proposed legislation clarifies that stated fines related to gravel mining are per violation and per day.  The fines are also increased to $1,000 per violation and jail time of up to a year.

The Gravel Mining Law would increase oversight by bringing gravel mines with five acres or more of active working area under the Mining Act. This would not prohibit a small operator from mining five acres, reclaiming, and then mining another five acres. Currently, gravel mining is excluded from the Mining Act, so mega mines, such as the several we have in the Placitas area, are excluded from many of the environmental and health safeguards required of other large mines. A few of the safeguards they are currently excluded from include water discharge plans, off-site storm water control, reclamation, and periodic re-permitting to ensure they are not causing harm. While some safeguards can be imposed by county or municipal ordinances, if a mine is on BLM land, local ordinances do not apply and there is a lot of BLM land surrounding Placitas. If this Bill becomes law, the Mining Act will also protections to BLM lands and their nearby communities, like Placitas,

The New Mexico Legislature starts January 20th and runs through March 21st. ES-CA will announce when these bills will be heard in committees. New Mexico Legislators have a greater tendency to seriously consider bills when citizens turn out to be heard. Please plan to attend all committee hearings and show your support.

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Placitas Library Well

Posted on January 10, 2015 by admin

Sandoval County District 1 Commissioner James Dominguez has been meeting with County Manager Phil Rios and other County officials to try to resolve the issue of the well that services the Library and the Placitas Fire Station.

Commissioner Dominguez reports that the engineers, retained by the County, have determined that there is available water in the current area of the well. The County is going to pull up the well pump and screen, clean them, and then lower them back down to a deeper location, where the water is present. The County expects that this will provide a number of years of water, while they look at a more permanent solution.

The County should begin work on this project on Monday, January 12, and should complete the work within the next two weeks.

In addition, Commissioner Dominguez is also discussing the issue of the heating/cooling system with the appropriate County personnel and is working to find a solution.

In the interests of keeping communications coordinated, we ask that if anyone has any questions or comments about these issues, that they forward them through Karen Cox and/or Marian Frear who can then communicate directly with Commissioner Dominguez.

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ES-CA BOARD MEETING OF JANUARY 5, 2015

Posted on January 7, 2015 by admin

The ES-CA Board of Directors held its monthly meeting on January 5, 2015. Attending were: Bob Gorrell; Ed Majka; Susan Fullas; Chris Daul; Lynn Koch; Jerry Saxton; and, Joan Fenicle (who was representing Tony Hull). New officers were elected as follows: President – Bob Gorrell; Vice President – Ed Majka; Treasurer – Susan Fullas; and, Secretary – Lynn Koch.
Orin Safier gave his last report as Treasurer and as a Board member or ES-CA. Orin is moving to Denver and ES-CA, as well as the entire Placitas community, will miss him and the time and service he has given to the community. Orin also reported that the ES-CA website has been updated and improved through the work of an outside consultant.
Dick Ulmer reported for the Land Use Planning Trust that the judge is reviewing ES-CA’s petition to intervene in the County’s lawsuit against Vulcan (formerly Lafarge). The LPT is continuing to raise money for legal fees for the lawsuit and all residents are encouraged to contribute. We cannot let the mining companies operate outside of the law.
Ed Majka, Chris Daul and Bob Gorrell reported on the Fisher Sand and Gravel proposed ordinance for annexation to the Town of Bernalillo and mining in general. Bob has prepared two pieces of legislation that would strengthen the State’s control of sand and gravel mining and give counties more enforcement power over these operations. ES-CA will be meeting with State representatives to have this legislation introduced in the upcoming Legislative session.
ES-CA representatives have been assisting the Placitas Library in attempting to restore water to the building. We have been working with County officials and hope to have a short term fix within the month.
The next Board meeting is scheduled for Monday, February 2, 2015, beginning at 6:30 pm at La Puerta Realty, located on Rt. 165. All are welcome to attend.

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Fisher to be Annexed by Town of Bernalillo

Posted on December 20, 2014 by admin

The annexation of Fisher Sand and Gravel Mining site is on the Agenda for the December 22, 2014 meeting of the Town of Bernalillo Council. The Town desperately needs a storm water detention structure at the Fisher location and this will be a condition of the approval. Fisher will be permitted to mine gravel, but for a limited duration (Revised Fisher Ordinance (DRAFT)12-19-14). Flooding in Bernalillo is chiefly caused from storm waters flowing from the Sandia Tribal Lands and a good amount flows though the arroyo that crosses the Fisher property.

In 2010 County Zoning administratively approved Fisher for terrain management grading only. Fisher instead immediately began gravel mining without any approvals from the County. Nevertheless, the County chose not to enforce its zoning regulations. In January 2012, after two years of illegal gravel mining, Fisher began moving an asphalt plant onto their property and Placitans turned out in force to let the County Commission know that enough is enough. The County then filed on January 27, 2012 a non-compliance notice against Fisher (CorrectionLtr_27Jan2012). The mining stopped, but Fisher never removed the mining equipment or completed the grading. The County chose not to take any enforcement action. The County turned a blind eye to Fisher which allowed them over the last two years to make a deal with the Town of Bernalillo for annexation.

Due to the actions of ES-CA: In the draft ordinance, the Town of Bernalillo has included protections that prohibit an asphalt plant, and include time limits, reclamation, and a performance bond to enforce terms. Over the last year, Mayor Torres has been in communication with ES-CA, and we have submitted a list of recommendations (11Nov2014_Recommendations regarding Fisher Sand and Gravel) that would minimize impact to our communities. Most of our recommendations are included in the draft ordinance. The most important item is the cut-off date. Mining negatively impacts lives and property values and an end-date will mitigate these impacts. The communities around the Lafarge mine had clear expectations from an earlier operator that the lease and mining would cease in 2015, but there were no teeth in the agreements and the current operators are thumbing their nose at the County. In my opinion, the Mayor of Bernalillo has brokered a workable solution which will not make everyone happy, but is tolerable for most.

Please support the ES-CA Land Protection Trust (LPT) which is working very hard to implement legal and legislative remedies to protect us against mining’s further expansion in Placitas. To gain a seat at the table in deciding our future, LPT has recently filed a motion to intervene in the Lafarge vs. County of Sandoval zoning lawsuit. More information at www.es-ca.org.

Posted in Current Issues, Partner Post, Zoning and Land Use | 4 Comments

ES-CA Board Meeting of December 2, 2014

Posted on December 6, 2014 by admin

The Eastern Sandoval Citizens Association Board had its regular monthly meeting on December 2, 2014. In attendance were Board members: BG; Chris Daul (CD); Ed Majka (EM); Orin Safier (OS); and, Jerry Saxton (JS). A quorum was reached. Arriving later were Board Members Tony Hull (TH) and Lynn Koch (LK).

The minutes of the November Board meeting were approved unanimously without changes.

Guests attending the meeting were: Sandoval County District One Commissioner Elect James Dominguez; ES-CA Board Elect member Susan Fullas; Joan Fenicle, Chris Frye; Dick Ulmer; Judy Labowitz; Marsha Masden; Bill Wilhelm; Marvin; and, Nonnie.
Mr. Dominguez was asked to speak first and he thanked everyone for their support and stated that he would be very supportive of Placitas, as well as the whole district and County. He then asked that the Board advise him of the pressing issues. The Board proceeded to discuss the following matters:

a. Gravel Mining
BG reviewed the draft mining legislation that he has been working on. Mr. Dominguez stated that he supported the legislation and was working with Commissioner Walters to have the County express its public support for the legislation. They are:
1. Include sand and gravel mining operations greater than 5 acres within the Mining Act.
2. Allow Counties to impose penalties up to $1,000 per day for gravel mining zoning violations.
3. Allow Counties to impose a construction aggregate severance tax for local use.

b. Fisher Sand and Gravel
EM and CD reported that CD has met with Bernalillo Mayor Jack Torres and reviewed ES-CA’s recommendations for annexation of the site by Bernalillo. CD stated that Mayor Torres expressed his concurrence with the recommendations. CD is meeting with Mayor Torres on December 2 to discuss this matter again. CD will advise the Board concerning: (1) date of Mayor and Council meeting at which the application for annexation is to be discussed; (2) Mayor’s position on the recommendations; and (3) whether the application can be reviewed by the public. BG noted that the recommendations apply to the County as well, if they should retain jurisdiction. BG also noted that the County has not been pursuing the current outstanding violation issued to Fisher. Mr. Dominguez promised to look into that matter.
As an update, the matter will be listed on the December 22, 2014 meeting of the Bernalillo Mayor and Council. All interested persons are welcome to attend the meeting. Please feel free to contact ES-CA for additional information.
c. Land Use Planning Trust
The LPT is sending out a fundraising mailer to all Placitas residents. A motion to intervene in the County lawsuit against Vulcan was filed with the court on November 10. Seven notices of violation were filed by NMED against Vulcan.
d. I 25 Interchange
BG is continuing to follow-up with the District 3 Engineer.
e. Pipeline
OS noted that we still have not received any documents from our records request. Mr. Dominguez said that he would push the County to make a records request and that he was meeting with a PRC Commissioner to discuss this matter.

Committee reports were given as follows:
Treasurer’s Report: OS reported a current balance of $16,967.68. OS noted that the Officers and Directors Insurance was due and that he would pay the $810.00 due.
Watchdogs: Scot Stevens was not present. ED reported that there were now 22 people signed up as Watchdogs.
Membership: JS deferred.
Political/Legal: EM reported that the ESCAFCA bonds had passed.
IT Management: OS noted that our consultant was about finished with his work and OS would be testing it and reporting back.
Communications: CD noted that the Signpost had published our article and had also run an informative article on Vulcan.

Follow-up items included the ES-CA Statement of Support, concerning proposed uses for the Buffalo Tract of the BLM land. It was decided that ES-CA will try to meet with our Congressional delegation to discuss.

New business considered the following:
a. LPA-KURP Radio
Joan Fenicle and Chris Frye made a presentation about the new Placitas radio station and requested a donation from ES-CA for equipment purchases. Discussion ensued and the Board voted to contribute $1,000.00 to the station, pending approval by the membership.
b. Mission Statement/Rules of Engagement
The board decided to defer discussion of this item to the next meeting.
c. Election of 2015 Officers
The Board decided to have a consent agenda vote at the beginning of the next meeting and proposed: Bob Gorrell – President; Ed Majka – Vice President; Susan Fullas – Treasurer; and, Lynn Koch – Secretary

The next Board meeting is scheduled for Monday, January 5, 2015 at La Puerta Realty, beginning at 6:30pm. All are welcome to attend.

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Gravel Mining Lawsuit Intervention–Background Documents

Posted on December 5, 2014 by admin

by Dick Ulmer, Chairman, ES-CA Land Use Protection Trust Board

We wanted to post the documents that have been filed that relate to the County lawsuit to enforce the terms previously agreed to govern the nonconforming gravel mining in Placitas by Vulcan Materials (previously Lafarge, and before that it was M.T. Investments–the latter of which still hold the Gravel lease, and have subleased to Lafarge/Vulcan).   Mt. Adams is the owner of record for the land.

Following is a brief explanation of the various documents (and a link to each):

This is the key document.  When the Bernalillo ETZ (the local zoning agency at that time) was putting area zoning into effect (and recognizing that a mining lease existed since 1973), they brought together surrounding residents, developers, and the mining operator to provide input to this certificate (and representatives of each involved party signed the certificate) which allowed this mine to operate in nonconformance with local zoning regulations.  However, as a direct result of those discussions, certain terms were formally agreed by the parties and those were documented as terms of the certificate (highlighted areas are mine and represent areas of current violations).

On 4/21/2014, the Sandoval County Attorney filed this complaint in District Court, due to Lafarge’s failure to correct (or even acknowledge) violations of the Nonconformance Certificate (enforcement of zoning in our area now falls with the County, and the ETZ ceased to be).

At various dates, the defendants in the County complaint responded (clearly written as a collaboration between the defendants)—basically stating that the Nonconformance Certificate no longer applies (which would mean that there are no local zoning terms limiting or otherwise governing their operation), and that the County has no right to enforce them or take them to court over this.  The County obviously disagrees (and with no public hearing or discussion with the signatories who approved the 1988 Certificate, we would contend that this agreement could not have been set aside).

With the filing of this petition to intervene by members of the ES-CA Land Protection Trust Board of Directors (who individually own homes adjoining or near to the mine), we seek to represent the interests of the Placitas community who have strongly encouraged ES-CA to take this action.  With the filed complaint, we not only support the County’s position and charges, but we seek to augment the charges to include violations that the operation is “extending (time) and expanding (intensity)” beyond that which was intended when the nonconformance was permitted.

I have included these which clearly show the violations charged by the County.  And since these were taken, most surrounding residents know that the mining activity has substantially expanded and greatly enlarged the “disturbed area” which is the source of much of our dust on NM windy days.  (if you have access to Google Earth, go back and look at the size of the area being mined in 1996 and then look at the current area and see how much it has grown and the lack of any visible re-vegetation/reclaiming).

Finally, this document (from a website that tracks court cases) is the current status of the legal action—and shows the various challenges of judges, and that this is now in the hands of the Chief Judge for the court.  We hope that our intervention may help to put this on a faster track to a conclusion.

 

Please email me at the following address if you have questions about this or other mining activities that we are working hard to control.

Dick Ulmer, Chairman

ES-CA Land Use Protection Trust Board

LPT.ES-CA@comcast.net

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RADIO STATION COMES TO PLACITAS

Posted on December 3, 2014 by admin

Radio Free Placitas!

The FCC has given permission for Las Placitas Association (LPA) to construct KUPR, a community FM radio station to serve Placitas, Algodones, Bernalillo, and San Felipe and Santa Ana Pueblos. At 99.9 on your FM dial, KUPR will air locally originated, non-commercial programming – news, emergency alerts, community calendars, music, spoken word, history, children’s programming and much more.

ES-CA has been approached for support of the building phase of this community resource. A studio location and tower have already been secured – the next step is the purchase and installation of antennas, transmitter and microwave connections, so they can begin sending out a signal. This is scheduled to happen by the end of the year. Phase Two will be to equip the studio and begin live programming.

The ES-CA Board of Directors believes the radio station would be an important communications tool and would help us inform the community about breaking ES-CA news and issues. The Board has looked at our mission statement and feels that the goals of the station are complementary to those of ES-CA. The Board is proposing a contribution of $1,000.00. This will be considered by ES-CA membership vote and a ballot question will be sent to all members by e-mail. LPA has pledged to match ES-CA’s donation to make $2,000 for the new radio station.

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NM Environment Department Takes Action

Posted on November 24, 2014 by admin

By Dick Ulmer, Chairman, ES-CA Land Use Protection Trust Board
LPT.ES-CA@comcast.net

NM Representative Jim Smith arranged a meeting between representatives of the New Mexico Environment Department (NMED) and the ES-CA Land Protection Trust (LPT) that occurred on November 14 at the home of Steve Vaughan. The meeting was led by Rep. Smith and Michael Vonderheide, Director of their Environmental Protection Division.

Richard Goodyear, Chief of the Air Quality Bureau at NMED, outlined the protocol his team follow to manage the permit process for gravel mining operations, and also how the investigation process works when complaints are received. At the meeting, we were given a copy of the formal Notice of Violations to Vulcan Materials. The notice follows a NMED inspection that begun on April 1, 2014 following complaints received from Placitas residents about the Lafarge mining operation. Mr. Goodyear explained that the elapsed time from the inspection to the formal violations notice was unusually long and was because of a staffing shortfall that has now been resolved. We were also told that an additional inspection of the facility was held in October (subsequent to the Vulcan acquisition of the Lafarge operation) and several additional violations were identified. He stated that additional action by NMED against Vulcan can be expected.

Mr. Goodyear responded to many follow-up questions from the attendees and his answers should be of significant help in focusing our future efforts and greatly helped LPT understanding the limitations of the current NMED processes. We were told that the monetary penalties that NMED can assess are substantial, and that in his experience, violators do not repeatedly offend as fines increase should that happen. He later indicated that in extreme cases (intentional misrepresentation) NMED had authority to withdraw a facility’s permit.

When asked about air monitoring (specifically of dust particulates), Mr. Goodyear indicated that the only monitoring done by NMED was under a joint plan with the EPA, and that plan is focused on areas with very large emissions concerns. Gravel mining has not been a priority, and in fact the current plan calls for the only monitoring device in our area to be removed. We shared with the NMED representatives our well-documented concerns about small particulates that are generated by gravel mining and crushing operations and the associated health risks. The NM Health Department reports that our state is 2x the national average in such particulate-related deaths. Directly related to this discussion, one of the actions from this meeting was to continue to work with Representative Smith to gain legislative support and NMED funding to ensure that any gravel mine with more than 5 acres of operating area must have continual monitoring with real-time analysis so that we can know immediately if such a health hazard exists for surrounding residents.

In addition to the Air Quality discussions, Bart Faris, an Environmental Scientist with the Water Quality Bureau of NMED shared with us the initial report on the Vulcan water discharge. Alan Friedman, president of one of the water cooperatives that immediately adjoin the Vulcan/Lafarge mine had raised concerns in September with the Water Quality Bureau about the area’s rising arsenic levels and questioned how the mining discharge was being treated. Mr. Faris explained that NMED had sent an October 2, 2014 letter to Vulcan requiring a Notice of Intent for water discharge. The Vulcan response indicated that the Vulcan well was tested at 50 parts per billion (5x the level permitted in our drinking water), but stated that level was not sufficiently high (needs to be greater than 100 ppb) to be a discharge violation. However, the discussion and the analysis provided has raised several areas of concern for NMED Water Quality Bureau and they will investigate further. Alan is continuing to work with Mr. Faris to determine if there are actionable violations related to water.
This was a very productive discussion and our thanks go out to Representative Smith, NMED, ES-CA and our community volunteers for their continued participation on behalf of this community.

ATTENDEES:
Jim Smith (NM State Representative); Michael Vonderheide (NMED); Stephen Vaughan (LPT); Bob Gorrell (ES-CA); Ed Majka (ES-CA); Tom Ashe (LPT); Dawn Foster (Resident–subject matter expert); Bart Faris (NMED); ‘Robert Byrd (LPT)’; Alan Friedman (Resident–subject matter expert); Goodyear, Richard (NMED); Sondra Sage (NMED); Dick Ulmer (LPT)

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ES-CA Contemplates Intervention to the Lafarge Lawsuit

Posted on November 10, 2014 by admin

Sandoval County has filed suit against the mining operation and seeks to enforce the terms of the 1988 Nonconformance Certificate issued by the now defunct Sandoval County / Bernalillo Extra-territorial Commission. The Lafarge lawyers seek to have the District Court set aside the terms of the certificate and allow them to continue mining with no restrictions. Given the other active mining operations, and those being proposed (Fisher, BLM, etc), it is important that the County demonstrates that it is willing and able to enforce the protections put in place for our communities. These operators, if allowed to run unchecked as Lafarge is arguing that they should be allowed to do, will continue to degrade our health, life styles, and property investments. The ES-CA Land Use Protection Trust (LPT) is considering filing to intervene in the lawsuit.

LPT is not funded by ES-CA memberships. LPT was formed to ensure the protection of our communities, and will fund the legal action by contributions from those in the community who have recognized the ongoing threat posed by these mega-mines. Several ES-CA surveys indicate that the majority of Placitas residents have increasing concerns about gravel mining in our area.

If you have not heard, Lafarge is now Vulcan; different operator, same mode of operation. The Lafarge lease expires in 2015, and despite many attempts to dissuade the property owner, Mount Adams Investment, with Bill Gates as a major shareholder, they have told us they are negotiating a new lease with Vulcan that would continue mining for many years beyond the stated intent of the property owners at the time they were permitted to operate as a nonconforming use.

LPT believes that Lafarge/Vulcan and other mining operations generate dust particulates that can impact health and well-being more than 30 miles away from the site, that the amount of water being used is excessive and depletes this precious resource, and that having these sites close to our neighborhoods has shown substantial impact to the value of our properties. It was recently uncovered that the highest concentrations of arsenic from water wells center at the Lafarge gravel mine that used 96,000,000 gallons of water in 2013, pumped out of the main aquifer serving Plactias, the Town of Bernalillo, and other nearby communities. Everyone in Placitas has to deal with the heavy truck traffic and broken windshields (their current permit allows an average of 44 trucks per hour).

The LPT has retained one of New Mexico’s best Land Use attorneys to review the County’s case, and their recommendation is that the LPT Board members (both as the representatives of ES-CA and as individual property owners who are directly impacted), and ES-CA as the incorporated non-profit representative of the broader community, should be the named interveners. This intervention would include ES-CA as a party to and in support of the County’s suit. The LPT’s attorney has recommended several legal arguments that, if we intervene, could be added to strengthen the case against the operator. ES-CA’s intervention will greatly increase the risk to the mining operators of continuing to do business as usual, which will increase the probability of success for our communities. If the judge should send this case to mediation, only by having a “seat at the table” will ES-CA be able to influence the outcome. The alternative is to just leave it to the County, but our community experience with this option has not been positive.

However, the ES-CA Board does not want to take this step without asking our membership if they concur with entering the suit. Please cast your vote for or against ES-CA intervening in the lawsuit when the ES-CA Board sends the survey question out to members.

If you would like to find out more about LPT and the lawsuit, contact LPT Chair Dick Ulmer at (505) 404-0416 or dick.ulmer@comcast.net .

Posted in Uncategorized | 3 Comments