EPA Docket Center Docket ID No. EPA-HQ-OAR-2002-0051

The cement industry collectively emits at least 12,000 pounds of mercury each year, yet currently is free to operate without any regulatory requirements to reduce mercury pollution. In its December 2005 rule proposal, EPA once again refused to establish requirements for cement plants to reduce their mercury emissions. Cement plants also emit dioxin, hydrochloric acid, hydrocarbons, and other toxic pollutants. While cement plants continue to reap enormous profits as they pollute our environment with unhealthy amounts of mercury and other air toxics, the agency charged with protecting the environment and the health of Americans is doing nothing. I implore you to rewrite this rule to include limits on mercury and other toxic pollution from cement plants, to the full extent that the Clean Air Act requires. For far too long, cement manufacturers have poisoned our air and water with mercury and other pollution. It is time for EPA to do its job and protect our health and our environment. I feel the EPA may also be "guilty by association" whether intended or not, as a cement plant was proposed on the Hudson River, and this timely suspension of mercury contamination rules just too convenient. I worked in the archaeology of the Marathon Battery National Priority Superfund Site in Cold Spring, NY and other Region 2 sites and on the proposed PCB cleanups of the upper Hudson River since 1983, most recently for TAMS, now part of TYCO. In part I base this complaint given issues of Frederick Church's NY State maintained "Olana" where the Hudson River School of art started, his "Niagara" and others the first artwork purchased by the Congress, where it still hangs, and a nearby proposed cement plant. Please, more research on scrubbers, and more regulation on mercury, the scourge of the "top of the food chain". First half written by the Earth Justice organization, the second half by me. See: "State Sues E.P.A. for Files on Household Pollutants" -NY Times 2/15/06