Seven Key Issues
TRAM seeks to address Seven Key Issues that will result in:
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Equity for all stakeholders involved,
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Healthier, safer, and more desirable communities, and
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An efficient APO industry better aligned with stakeholder concerns in the communities in which they operate.
Effectively tackling these issues involves evaluating the impact of individual APOs, as well as the cumulative impacts of multiple APOs in a given area.
1. Air Quality
The Texas Commission on Environmental Quality (TCEQ), responsible for permitting aggregate and concrete operations, lacks real-time air quality data and does not require operators to maintain fence-line monitors. Without fence-line monitors, it is unknown exactly how many pollutants are emitted and carried downwind by these operations.
There is a real need for the TCEQ to quantify and address the individual and cumulative impact aggregates, concrete, and cement operators have on air quality for adjacent communities. The Texas Legislature’s 2021 House Interim Committee on Aggregate Production Operations (APOs) also made this recommendation.
Image showing worker exposure to fine particulate matter.
Photo courtesy of Air Alliance Houston.
2. Water Use & Availability
Responsible and smart water usage practices within the aggregates and concrete industry is a priority for TRAM. We seek to ensure efficient water management strategies that minimize consumption and preserve water resources for both industrial and community needs.
TRAM members on a site visit to RA Aggregates, a gravel mine operation on the Guadalupe River in Kerr County. This facility utilizes several good water conservation and reuse techniques.
3. Surface & Groundwater Contamination
Addressing potential surface and groundwater contamination from aggregate mining operations is of paramount importance. Established best management practices should be required to better protect aquifers, rivers, and wetlands and reduce silting and flooding issues.
Image showing sand mining sediment in the West Fork of the San Jacinto River. Water samples show 25X the normal level of dissolved solids.
Photo courtesy of Lake Houston Area Flood Task Force.
4. Inadequate Planning & Oversight
Weak permitting requirements for APOs in our state do not protect communities or natural resources. Unlike most states, Texas does not require APOs to submit Environmental Impact Assessments, mine plans*, or reclamation plans.
The majority of states follow comprehensive aggregate mining regulations enacted to ensure public health, especially as aggregate operations are increasingly encroaching on cities and towns. Similar regulations have been established in other states to protect the long-term viability of the landscape and natural shared resources. As both the Texas population and aggregate industry grow, more and more communities are experiencing the negative impacts of the under and deregulation of this industry.
*Mine Plans in the San Jacinto River Basin
The San Jacinto River Basin in southeast Texas is the only place that requires mine plans and final stabilization reports. This is due to the hard work of a local grassroots group, the Lake Houston Area Flood Task Force, which worked alongside Texas Aggregates and Concrete Association (TACA) to push the TCEQ to require sand and gravel operators in this area to prepare and submit mine plans upon request. These plans must include best management practices (BMPs) that prevent or control stormwater runoff and the discharge of pollutants, including sediment, into surface water within the San Jacinto River Basin.
Data compiled by TRAM Tech Team. Map created using MapChart.com.
5. Truck Traffic & Driver Safety
TRAM’s trucking concerns include:
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Third-party drivers, paid by the load. APOs often outsource materials transportation to third-party contract companies. These companies operate on commission-based payments, which can lead to drivers taking risks – maximizing loads and potentially compromising safety and adherence to traffic laws.
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APOs do not pay their fair-share for road damage. The Center of Transportation Research estimates that a fully loaded 80,000-pound commercial vehicle damages road pavement at a rate of 26 cents per mile driven (not including impact on bridges and overpasses). However, the current Texas fuel tax from 1991 only collects 3 cents per mile. This leaves a 23-cent-per-mile deficit that taxpayers must cover.
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Truck inspections are not keeping up with increased traffic. Local enforcement groups need to be trained and certified in truck inspections.
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Need for comprehensive drug testing programs and background checks for truck drivers. The recent Bastrop County tragedy underscores the importance of this. Transport trucks are the public’s main interaction with the APO industry. Industry should ensure truck drivers are properly licensed with no prior criminal, drug, and/or driving offenses.
Dump truck runs stop sign and rams semi rock truck at FM1863/FM3009
Photo courtesy of Preserve Our Hill Country Environment.
6. Nuisance Issues
There are a number of nuisance issues aggregate operations can easily address to become better neighbors. Some include:
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Reduce excessive outdoor lighting by installing timers and motion sensor lights, as well as installing shields on all lights to ensure any light emitted is directed downward to only where it’s needed.
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Reduce nuisance noise of backup beepers by using "duck quack" or "white noise" beepers. These direct the sound directly behind the vehicle, increasing safety and decreasing nuisance noise.
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Reduce blasting noise and seismic energy by deploying computer-controlled blasting in quarries to minimize seismic forces leaving their property. The technology (or its equivalent) should be a required best management practice in all APO mines.
Image showing nighttime nuisance lighting of a mining operation.
Photo courtesy of Preserve Our Hill Country Environment.
Lauren Concrete's concrete batch plant in Dripping Springs uses shields to direct any light down and motion sensors and timers to ensure nighttime lighting does not impact neighbors or wildlife.
Photo courtesy of Lauren Concrete, Dripping Springs.
7. Economic Impacts
The aggregate industry exerts a substantial economic toll on local communities. Heavy truck traffic damages roads, leading to costly maintenance for governments. Property values often decline near quarries and processing facilities. Communities face substantial expenses addressing environmental and health concerns, further straining resources. These impacts underscore the need for balanced strategies to reconcile economic interests with community well-being.
Mayfield Ranch homes north of Austin share a fence line with a quarry.