An Environmental Justice Analysis prepared by Land Economics Consultants, LLC for DUDEK, the consultants hired by The City of Vallejo for the environmental impact report on the ORCEM cement plant and industrial port proposed for South Vallejo has just been released. The report indicates that, “significant and unavoidable” cumulative environmental impacts would result should the plan go forward. Projected Nitrogen Dioxide levels from the cement plant are projected to exceed Bay Area Air Quality Management District thresholds resulting in, “adverse human health effects,” and a “risk to public health,” according to the report.

The report concludes that emissions from the cement plant would, “create an adverse and disproportionate impact on the low-income populations of area A,”* although it stops short of indicating that minority populations would be disproportionately impacted in the context of the diverse population mix in Vallejo.

It is worth noting that this report has been completed well past the period of public comment on this project leaving no opportunity for Vallejo residents to make public comment.

Here is the report in its entirety for you to examine:


*South Vallejo


  1. April 28, 2016 @ 4:43 pm Wayne Law

    It goes way beyond just that impact and most of Vallejo citizens are being caught unaware! The trains that will be suddenly running up and down tracks that have been silent for about 20 years will surely make them aware. Maybe the dust literally starts flying from the trucks running up and down the streets (to the tune of over 250 a day) they might see some reason for concern? Finally the dead fish odor washing over Vallejo while they dredge the Napa River to allow the ships to arrive could inspire them to ask City Council why they didn’t know.

    This is the legacy that our City and City Council want for themselves in our waterfront areas?


  2. April 28, 2016 @ 5:23 pm Anonymous

    It is of note that the COV had to be forced/shamed into preparing this report.


  3. April 28, 2016 @ 6:07 pm whatamimissing

    Are we reading different reports? Your link goes to a report that says “As shown in Tables 3 and 4 below, this analysis shows that operation of the combined Orcem/VMT project would not exceed either the California or Federal recommendations for exposure of people to NO2.” In another section it says “It is now widely accepted that global climate change is creating adverse impacts for everyone on the planet. Impacts 3.6-1 through -3 create adverse effects that are significant and unavoidable, but they are not disproportionately experienced by minorities or low-income populations in Vallejo.”
    These quotes from the report contradict your claims that the emissions “create an adverse and disproportionate impact on the low-income populations of area A”.


  4. April 30, 2016 @ 12:17 pm Gretchen Zimmermann

    Dear Ms. Ouse,

    I have read the Environmental Justice Analysis For the Vallejo Marine Terminal and Orcem Project submitted by Land Economics Consultants, LLC (LEC) April 26, 2016.

    I question why, for this analysis, only the City of Vallejo is used as the comparison population to determine whether the VMT/Orcem disproportionately affects a minority population. That’s a very myopic view. Why not use Solano county as the comparison population? The report concludes that “Due to the relatively high concentration of minorities in the City of Vallejo, and their relatively broad distribution throughout the city, no disproportionate impacts are expected to be created for minority populations by the proposed Project.” The Vallejo neighborhoods identified in this report have 76.8% and 75.7% minority populations. When compared to Solano Solano county’s 59.9% minority population, the project certainly disproportionately impacts a minority population. The fact that adjacent Vallejo neighborhoods have similar demographics in no way diminishes this impact.

    Because this project requires a port, we’d be justified in using use the demographics of the San Francisco Bay as our comparison population. The project isn’t being proposed for San Rafael (29.4% non-white), Berkeley (40.5% non-white) or San Mateo (41.3% non-white)*. It is being proposed for Vallejo, with a minority population of 74.5%. When viewed with the proper perspective we must reach very different conclusions about the project’s adverse impacts on minority populations.

    I’m concerned that another adverse impact is hinted at in the report but not specifically listed as such in the summary. On Page 19 it states that ” Low-income populations … tend to be concentrated along the rail line and near industrial areas. The activities associated with manufacturing industries and railroad transportation which generate noise and emissions can depress residential real estate values in close proximity …. In this case, adverse noise impacts generated by the operation of the proposed project are likely to be experienced disproportionately by low-income populations.” I must conclude that resumption of railroad transportation will further reduce property values, causing financial hardship to both homeowners and their tenants in those areas. Vallejo suffered greatly during the Great Recession, with a high percentage of minority and first-time home buyers tragically losing their homes and their savings when the housing bubble burst. I don’t know what percentage of homes in these areas are currently owner occupied, but, many of these homes only recently emerged from being underwater, and resumed rail traffic will sink them back under. The resumption of rail service proposed by VMT/Orcem is a recipe for a streak of blight right through the heart of Vallejo.

    The report states that “Project benefits include: Skilled labor employment opportunities, Additional fiscal resources, and Potential for attracting further manufacturing operations.” It does not quantify nor substantiate those presumed benefits in any way. One report I read states that only 30 permanent jobs would be created at the cement plant. To be fair in evaluating the benefits of the project we need a rational analysis and not a handful of assumptions and not on some inflated IMPLAN-based study. To be fair to ourselves and our community we should also look at the jobs that could be created by other kinds of projects, like the formerly proposed Brooks Street project, and then pursue the development of a project that best suits our needs. We should not be distorting the facts to make the VMT/Orcem project seem like a good deal for our city.


    Gretchen Zimmermann
    Valleo CA

    *Based on 2010 Census data


    • May 1, 2016 @ 10:23 am Gretchen Zimmermann

      PS: I corrected the spelling of “Vallejo” before I sent the email to the City.

      Ms. Ouse replied to me ON SATURDAY and said my letter would be added to the public record. We may be past the official public comment period but we can still comment. I feel that the report is so flawed we should demand one that is done properly.


  5. May 1, 2016 @ 8:52 am wharf rat

    Test squeak


  6. May 2, 2016 @ 9:09 am wharf rat

    Bay Area Air Quality Management District (BAAQMD)

    Arguably one of the most powerful regulatory agencies in the Bay region the BAAQMD board of directors is comprised mainly of politicians , is our air quality a political issue subject to the whims of politics and egos or is it based in good science and public health ? . With air quality being the single most contested issue with the VMT / Orcem proposed project can our Mayor vote on City council action items or even participate in discussion on this proposal / process or is He in conflict of interest with both City and BAAQMD requirements for impartiality and fair hearing rules ? I recall no recusal or statement of conflict when he voted to approve moving ahead with this process including a hefty rent abatement ! if perception is politics perhaps he has some house cleaning to do ? He sits on the board that can grant this proposed project the ”green” light it needs to move foreword , He is in effect an Employee of BAAQMD , by this virtue should he not recuse himself from any official involvement ? . Certianly this recently accepted EJ report is an embarassment to Vallejo Citezens and should be so for City Staff as well ! I can not think of any City in the region that would except a report of this quality , it stands as an ”anti economic development statement” by conscripting populations and property to a status of poverty (impoverished – disadvantaged – poor) when we well know the highest levels of poverty reside in City Hall (a impoverished and poor thought process with a poor delivery system,”currently a City Manager Keen Brainchild”), as Community members gradually peel this onion a strong smell is excaping fouling the winds of an election year . (wr)

    BAAQMD Board & Agency mission statement:

    ”The Air District aims to create a healthy breathing environment for every Bay Area resident while protecting and improving public health, air quality, and the global climate”.

    Values: (variable?)

    Five core values drive all aspects of our work and vision for the future:


    Our programs and policies are founded on science, developed with technical expertise, and executed with distinction.


    We are at the forefront of air quality improvement and pioneer new strategies to achieve healthy air and protect the climate.


    We include and engage all stakeholders to create broad acceptance for healthy air solutions.


    Our staff are genuinely committed to our mission and values.


    We maintain the right of Bay Area residents to breathe clean air.


    We aim to achieve our mission through a number of strategic goals:

    Reduce and eliminate health problems caused by air pollution.
    Achieve and maintain air quality standards for all criteria pollutants.
    Create high-quality, relevant regulatory programs and ensure they comply with federal, state, and local laws.
    Through incentives and partnerships, establish the Bay Area as a leading area for emissions reductions in mobile sources, land-use planning, innovative technology, and energy.
    Through educational programs and partnerships, engage all Bay Area residents to spare the air every day.
    Serve as an air quality authority in the development of policy and information.
    Apply state-of-the-art tools, techniques, and technology in our operations.
    Retain a top-performing and motivated workforce.
    Apply environmental stewardship best practises in our operations.

    (where does south Vallejo fit in on this laundry list ?) (wr)

    Mayor Osby Davis
    Board of Directors

    Board Position: Member
    District:Solano County
    Appointed:January 2016
    Term Expires:December 2017

    (wonder how or by whom He was appointed) ? He will sit well after his term as Mayor expires , where will his loyalties be ? He has well known connections to developers such as Callahan of waterfront fame , should not the BAAQMD board represent the broader population such as their mission statement alludes to ?. (wr)

    Board mission statement:

    The Board of Directors oversees the Air District as it develops policies, plans, rules, permits, enforcement, outreach, and grant programs to protect air quality, public health, and the global climate.

    ”Is a review of Our Mayors voting record and potential conflicts of interest overdue ? one would think following the exposure of the MISEDC scandal this would be automatic ? but there seems to be an entitlement attitude at City Hall or a ”catch Me if you can” philosophy, inbred in local Government such as seen with the MISEDC disaster .
    This traces back to the bizarre zoning / land use status interpreted with some strange Kafka like criteria for the General Mills property proposed to
    shift from a food industry use (flour mill) to a deep water port facility that proposes to foist air credits off as mitigation for pollution to south Vallejo neighbourhoods . Perhaps the ”Kafka Marine terminal” would be a better fit or how about ”Port Orwell” ? better fits imo”. (wr)

    ps: problems posting hyperlinks , sorry . (wr)


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