Thank you for supporting our efforts to require the City of Albuquerque's Environmental Health Department to take into account cumulative impacts when issuing air pollution permits.
The Mountain View Coalition consists of Mountain View Neighborhood Association, Mountain View Community Action, and Friends of Valle de Oro National Wildlife Refuge and is represented by New Mexico Environmental Law Center.
Albuquerque-Bernalillo County Air Quality Control Board
Environmental Health Department
Attn: Air Board Liaison
P.O. Box 1293
Albuquerque, NM 87103
June 2, 2023
Dear Board Members,
We, the undersigned organizations and individuals, are in full support of the Health, Environment and Equity Impacts (HEEI) Regulation proposed by the Mountain View Coalition that is currently under review by the Albuquerque-Bernalillo County Air Quality Control Board. Please enter this letter with all of the names appended into the official record.
The Mountain View Coalition (made up of Mountain View Neighborhood Association, Mountain View Community Action, and Friends of Valle de Oro National Wildlife Refuge), in partnership with New Mexico Environmental Law Center, filed their historic, precedent-setting cumulative impacts regulation on November 21, 2022 to the Air Quality Control Board.
While industry is lining up to oppose community-driven efforts for long-overdue equity in air permitting, a broad coalition of community-based groups is expressing wholehearted support for the Mountain View Coalition’s critically needed regulation.
The proposed rule is the culmination of a decades-long effort by the impacted community to address the disproportionate and cumulative impacts of toxic pollution from industry in low-income communities of color. The pattern and practice of siting and permitting polluting industry in Mountain View and other overburdened neighborhoods has had devastating consequences, including resulting in a drastically lower life expectancy in these communities compared to wealthier, white communities in Bernalillo County.[1] The City of Albuquerque’s Environmental Health Department (EHD) has a long history of rubber-stamping air pollution permit applications with no consideration for the cumulative impacts of their decisions; EHD’s harmful track record is a blatant example of environmental racism.
Albuquerque and Bernalillo County are becoming increasingly known for bad air quality—the American Lung Association recently gave Bernalillo County an “F” for air quality related to ozone and a “D” for fine particulate matter —and the health effects associated with air pollution.[2] As demonstrated in this recent report, air pollution does not affect everyone in Albuquerque equally; the effects of air polluting industrial permits overwhelmingly impact low-income communities, and communities of color experience the adverse health impacts of air pollution disproportionately.[3]
The new proposed HEEI rule will allow regulators to address the disparate impacts of air pollution negatively impacting the health and quality of life of Bernalillo County residents by giving EHD and the Albuquerque/Bernalillo County Air Quality Control Board the power to deny air pollution permits for facilities proposed in communities already bearing the disproportionate burden of air pollution. This rule will also contribute to better air quality county-wide and provide for a healthier Bernalillo County overall. Additionally, the regulation will have the effect of attracting clean industries to Bernalillo County, stimulating pollution control technology innovation and businesses, and saving the County many millions of dollars in health care costs related to air pollution.
The regulation requires EHD to deny a permit application if it will be located in an overburdened community and if it negatively impacts the health of residents in that community. Specifically, the HEEI rule requires EHD and the permit applicant to work together to first identify whether the proposed polluting facility will be located in an overburdened community, meaning a community that is already facing the disparate impacts of existing air pollution.
If the facility is proposed to be located in an overburdened community, the applicant must perform a Disparate Impact Screening and evaluate nine identified Health Indicators. The permit application will be denied if any one of nine health indicators in the area already exceeds the county average for those indicators.
As organizations and individuals who care deeply about environmental justice and are committed to dismantling structural racism, we recognize racial disparities in government policy regarding decisions where polluting industries are sited. We know that race continues to be the most significant indicator of where such industries are sited.[4] We recognize the history of government agencies targeting neighborhoods like Mountain View with harmful businesses that especially impact vulnerable populations including children, the elderly, and people with compromised immune systems. We know air pollution exacerbates health conditions including asthma, cancer, cardiovascular disease and life expectancy. The status quo of issuing air permits in overburdened communities is completely unacceptable on moral and ethical grounds.
For all of the above reasons, we the undersigned organizations and individuals urge the Air Quality Control Board to adopt the proposed Health, Environment and Equity Impacts regulation submitted by the Mountain View Coalition in partnership with the New Mexico Environmental Law Center to address our collective concerns raised above.
Sincerely,
ABQ Backyard Refuge Program, Laurel Ladwig, Program Director
A Community Voice, Debra Campbell, Director
Ahora Inc. Kevin Shockey, Director
All the Way to Hell, Eliza Evans, Director
American Friends Service Committee - New Mexico Program, Patrick Jaramillo - Program Co-Director
Anthropocene Alliance, Harriet Festing, Director
Asociacion de Residentes de La Margarita, Inc, Wanda Rios, Director
Black Hills Clean Water Alliance, Lilias Jarding, Director
Black to the Land, Zappa Montag, Director
Center for Civic Policy, Oriana Sandoval, CEO
Center for Environmental Transformation, Jonathan Compton, Director
Center for Social Sustainable Systems (CESOSS), Jorge Garcia, Director
Citizens Awareness Network, Deb Katz, Director
Citizens Resistance At Fermi Two (CRAFT), Jesse Deer In Water, Director
Clean Air for All Now! Dennis O'Mara, Co-Chair
Coalition for Wetlands and Forests, Gabriella Velardi-Ward, Director
Common Ground Rising, Elaine Cimino, Director
Community In-Power and Development Association Inc. (CIDA Inc.), Michelle Smith, Director
Concerned Citizens of Cook County, Treva Gear, Director
Conita Real Neighborhood Association,
Do Good LLC, Charles Goodmacher, Director
DPNM Environmental Justice Caucus, Nicole Maestas-Olonovich, CD-2 Chair
DPNM Adelante Progressive Caucus, Nicole Maestas-Olonovich, Political Director
Dynamite Hill-Smithfield Community Land Trust, Susan Diane Mitchell, Director
Earth Ethics, Inc. Mary Gutierrez, Director
Education, Economics, Environmental, Climate and Health Organization (EEECHO), Katherine Egland, Director
FracTracker Alliance, Shannon Smith, Executive Director
Friends of Valle de Oro National Wildlife Refuge, David Barber, President
Greater-Birmingham Alliance to Stop Pollution, (GASP) Michael Hansen, Director
Greater Greener Gloster, Krystal N. Martin Director
Greater Neighborhood Alliance of Jersey City, NJ, Sandra Lovely Director
Indivisible Albuquerque, Rayellen Smith, Director
La Mesa Community Land Trust, Charles Bennett, Director
Land Health Institute, Mayci Shimon, Operations Manager
Marin City People's Plan, June Farmer, Director
Micah Six Eight Mission, Cynthia Robertson, Director
Milton’s Concerned Citizens/Save Blackwater River, Pam Mitchell, Director
Move Past Plastic, Tamela Trussell, Director
Moms Clean Air Force NM chapter/EcoMadres, Ana Rios - NM Field Organizer
Mountain View Coalition, Lauro Silva
Mountain View Community Action, Marla Painter, Board
Mountain View Neighborhood Assoc. Nora Garcia
New Energy Economy, Mariel Nanasi, Director
New Image Life Skills Academy Inc, Vel Scott, Director
New Mexico People's Energy Cooperative, Andrew Stone, President
New Mexico Environmental Law Center, Dr. Virginia Necochea, Director
New Mexico No False Solutions Coalition, Alejandria Lyons, Director
New Mexico Climate Justice, Anni Hanna, Director
Niko Dellios Legacy Fund, Delese Dellios, Director
Northeast Ohio Black Health Coalition, Yvonka Hall, Director
Parable of the Sower Intentional Community Cooperative, Aleta Toure Director
Pat Hurley Neighborhood Association, Julie A. Radoslovich, President
Physicians for Social Responsibility Pennsylvania, Tonyehn Verkitus, Director
Pueblo Action Alliance, Julia Bernal Director
Progressive Democrats of America - Central New Mexico, Lora Lucero - Co-Leader
ProgressNow New Mexico, Lucas Herndon Energy Policy Director
Prosperity Works, Ona Porter, Director
Regeneración - Pajaro Valley Climate Action Eloy Ortiz, Director
Rio Grande Chapter of the Sierra Club (RGCSC), Diane Reese Chair of Board
Rosewood Strong Community, Terri Straka
Saving Island Green Wildlife & Beyond, Dawne Dunton, Director
Social Eco Education (SEE), Martha Camacho Rodriguez, Director
South River Watershed Alliance Jacqueline Echols, Director
Southeast Queens Residents Environmental Justice Council, William Scarborough Director
South Valley Coalition of Neighborhood Associations, Marla Painter, Member, SVCNA
South Valley Regional Association of Acequias, Santiago Maestas, President
Southwest Native Cultures, Terry Sloan, Director
Spirit of the Sun Inc, Shannon Francis, Director
Stephens and Associates-Julia A. Stephens MEP - Principal
Sustaining Way, Michael Brown, Director
The Vessel Project of Louisiana, Roishetta Ozane, Director
The Young Peoples Guild, Joyce Tasby, Director
Together for Brothers (T4B), Christopher Ramirez, Director
Weequahic Park Association, Wynnie-Fred Victor Hinds, Director
WildEarth Guardians, Rebecca Sobel, Organizing Director
Youth United for Climate Crisis Action, Ennedith Lopez, Climate and Environmental Justice Policy Campaign Manager
350 New Mexico, Jim Mackenzie, Co-Coordinator
Notes
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[1] Joint Center for Political and Economic Studies, Place Matters for Health in Bernalillo County: Ensuring Opportunities for Good Health for All, September 2012, pp. 17-18.
[2] American Lung Association, State of the Air 2023, www.lung.org, p. 116.
[3] American Lung Association, State of the Air 2023, www.lung.org, p. 12.
[4] United Church of Christ Commission for Racial Justice, Toxic Wastes and Race in the United States: A National Report on the Racial and Socio-Economic Characteristics of Communities with Hazardous Waste Sites, 1987.
