Written Public Comment — Rio Rancho City Council Meeting, November 13, 2025
This will be in the Agenda Packet
Subject: Opposition to Ordinance R-136 and the Intergovernmental Agreement for Project Ranger / Castelion Corporation
To the Honorable Mayor and Members of the Rio Rancho City Council,
I respectfully submit this written comment in strong opposition to Ordinance R-136 and the related Intergovernmental Agreement (IGA) between the City of Rio Rancho and Sandoval County for “Project Ranger,” a solid-rocket-motor and hypersonic-missile manufacturing plant proposed by Castelion Corporation.
This ordinance should not be adopted because the project’s approval process was riddled with procedural defects, omissions, and misrepresentations that violate the Local Economic Development Act (LEDA) and the Open Meetings Act (OMA) and place serious public-health, financial, and safety risks on the residents of Rio Rancho.
1. No Proper Public Hearing or Baseline Studies
Neither the City nor Sandoval County held a lawful public hearing prior to funding approval.
No baseline groundwater, air, or soil testing has been conducted, despite the project’s use of ammonium perchlorate, a highly toxic oxidizer known to contaminate groundwater for miles and cause thyroid and developmental disorders in infants and children.
Without baseline data, there is no way to measure or remediate future contamination. The Council must not transfer public funds in the absence of this critical information.
2. Timeline Discrepancies and Violations of Law
An independent review of the Timeline of Project Ranger Approvals (Updated Nov 4 2025) reveals serious procedural errors that invalidate prior approvals:
- Secrecy and concealment (June – July 2025): Project Ranger was listed only as an “advanced-manufacturing employer.” Castelion’s identity and the defense-weapons purpose were withheld until after County bonds were announced. (Timeline Doc. 1-2).
- Land deals before disclosure: The County purchased 466.8 acres and sold 30.73 acres with no maps or stated purpose, violating the Anti-Donation Clause of the New Mexico Constitution.
- Bond approval without public record: On July 23 2025 the County voted intent to issue $125 million in Industrial Revenue Bonds with no company name, safety review, or cost-benefit analysis (Id. 2).
- False safety assurances: The August 27 IRB memo claimed that “Sandia and Los Alamos reviewed and approved the site.” The only document available—Project Ranger Sandia Commentary (Oct 16 2025)—was heavily redacted and explicitly stated that it was not a full safety assessment.
- Open Meetings Act violations: On September 24 2025 three lease agreements were added to the County agenda less than 24 hours before the vote, violating OMA § 10-15-1(F)(1).
- Back-dated City-County IGA: The County approved the City–County IGA on October 22 2025, claiming the City would pass a supporting resolution on November 13 2025—with County having an effective date of November 1 2025. This is a chronological impossibility, rendering the IGA void ab initio. (City-County IGA § 1–2).
- The Sandoval County Commission approved the City–County Intergovernmental Agreement (IGA) for Project Ranger on October 22, 2025, even though the City of Rio Rancho had not yet acted on the measure.
The County’s ordinance claims the City “will pass” a supporting resolution on November 13, 2025, while simultaneously assigning the agreement an effective date of November 1, 2025.
This creates a chronological impossibility — an agreement cannot take effect before one of the contracting parties lawfully adopts it.
Such sequencing renders the IGA void ab initio under New Mexico law because mutual consent and contemporaneous authorization were absent at the time of execution.
(City–County IGA §§ 1–2; Timeline Document, p. 7; see also State ex rel. Clark v. Johnson, 120 N.M. 562 (1995); State ex rel. Newsome v. Alarid, 90 N.M. 790 (1977).*) - Further, County officials have publicly stated that “this is a done deal” “we dont need to hear further public comment” at the Oct 22 approval and gives assurance that the City “will pass it” on November 13 without meaningful public participation.
This pre-determined outcome, coupled with the back-dating of legal documents, smacks of collusion between the County and City to evade public scrutiny and to create the false appearance of procedural compliance.
Such conduct undermines the integrity of both governing bodies, violates the Open Meetings Act’s intent for transparent deliberation, and demonstrates that the City Council’s vote is being treated as a rubber-stamp action rather than a legitimate legislative review.
- The Sandoval County Commission approved the City–County Intergovernmental Agreement (IGA) for Project Ranger on October 22, 2025, even though the City of Rio Rancho had not yet acted on the measure.
Proceeding tonight based on this defective sequence would compound these violations and expose the City to legal challenge.
3. Conflicting Oversight and Fire-Safety Gaps
Castelion representatives told residents the facility would operate under Department of Defense oversight, but Rio Rancho Fire & Rescue confirmed this is not a DoD facility.
Fire-code variances already granted by Sandoval County allow no sprinkler or hydrant systems in explosive-storage buildings.
Local responders lack the specialized training and equipment to manage perchlorate and solid-propellant fires—placing our firefighters and neighborhoods at unacceptable risk.
4. Mortgage-Insurance, Tax, and Economic Impacts
A rocket-propellant site of this scale will alter regional fire-insurance classifications.
Homeowners within a five-mile radius could face higher mortgage-insurance premiums, possible denial of coverage, and decreased property values. Wildfire risk has already factored into the mortgage insurance rate rise.
Mortgage-Insurance and FHA Exposure
According to the Wildfire Report on Castelion Project Ranger (Common Ground Rising, Oct. 27 2025), roughly 24 percent of Rio Rancho homeowners hold FHA-insured mortgages, making them uniquely vulnerable to reclassification of the West Mesa as a high-fire-risk zone. FHA and VA loan underwriters require active hazard coverage; if standard insurers withdraw or raise rates, affected borrowers can face loan default, escrow increases, or loss of eligibility for refinancing.
Average homeowner premiums in the region are now about $1,200 per year, but wildfire-risk reclassification would likely raise rates 20 to 100 percent—to $1,500–$2,400 per year—and some homes could become uninsurable under standard carriers. Wild Fire Report on Castelion Project Ranger § II.4 (2025). MarketWatch (2024) and Insurance Information Institute data confirm that such premium increases follow high-risk designations across Western states. See MarketWatch, “As wildfire damage climbs to $40 billion, homeowners face higher insurance costs,” Nov 2024; Insurance Information Institute, Wildfire Premium Studies (2024).
In practical terms, nearly one in four Rio Rancho households with FHA mortgages would be at immediate risk of rate shock or foreclosure if insurance markets tighten. This, in turn, would depress home values, erode the city’s property-tax base, and shift the fiscal burden onto remaining homeowners. (Wild Fire Report, supra § II.4; Legislative Analyst’s Office, Economic Effects of Wildfire Property Damage on Local Tax Revenues, 2023.*)
Meanwhile, the County’s LEDA and IRB tax exemptions remove millions from the property-tax base, shifting the cost of roads, fire protection, and emergency response onto Rio Rancho homeowners.
This ordinance therefore increases financial risk to residents while granting subsidies to a private weapons manufacturer.
5. Lack of IPRA Transparency
Public records requests (IPRAs) for the hazard analysis, lease terms, and emergency-response plans remain unanswered.
No council should approve funding for a project whose safety documents are withheld from public view.
6. Premature and Unlawful Use of Public Funds
The City’s proposed $1 million LEDA contribution for roadwork tied to Project Ranger was negotiated before the City had legal authority to enter the IGA and before environmental review.
This violates both LEDA § 5-10-10(B) and the Anti-Donation Clause, which require a clear public benefit and completed Project Participation Agreement prior to fund release.
7. Public Safety Obligations Ignored
The County never conducted a plume, evacuation, or transportation-hazard study before adopting the October 22 ordinance.
Under state law (N.M. Stat. Ann. § 59A-52-7), local governments have a duty to ensure adequate fire protection.
By ignoring that duty, the County transferred risk onto Rio Rancho residents and first responders—without consent, compensation, or readiness.
Conclusion
The record surrounding Project Ranger reveals a pattern of environmental negligence, fiscal irresponsibility, and procedural misconduct that places the City of Rio Rancho and its residents at unacceptable risk.
The proposed Castelion rocket-motor and missile manufacturing facility would introduce highly toxic chemicals, including ammonium perchlorate and associated oxidizers, into a wind-prone and wildfire-susceptible landscape. The County’s own timeline and the redacted Sandia hazard report confirm that no baseline environmental studies, plume modeling, or groundwater assessments were completed before approving millions in public subsidies. (See attached Exhibit A on Fire)
These omissions carry dire fiscal implications. As documented in the Wild Fire Report on Castelion Project Ranger (Oct. 27, 2025), wildfire or detonation incidents could generate public losses between $515 million and $2.5 billion—far exceeding the $10 million – future $135 million in LEDA and IRB subsidies. Insurance costs for homeowners are projected to rise 20 to 100 percent, with 24 percent of Rio Rancho homeowners—those holding FHA-insured mortgages—facing heightened foreclosure and refinancing risk once the area is reclassified as a high-fire zone. These cascading costs would erode the City’s tax base, reduce property-tax revenues, and divert resources from essential services.
Equally alarming are the hazardous-waste and rocket-propellant transportation routes identified along Paseo del Volcán, U.S. 550, and I-25, all of which traverse residential and commercial corridors without a publicly disclosed safety or spill-response plan. Despite Castelion’s claims of “Department of Defense oversight,” Rio Rancho Fire & Rescue has confirmed this is not a DoD facility. Neither the New Mexico Secretary of State (SOS) nor the New Mexico Environment Department (NMED) has issued any independent findings, operational permits, or environmental-impact determinations.
In effect, this project operates without active federal, state, or municipal oversight, relying instead on self-certification by a private weapons manufacturer.
From a governance standpoint, this lack of oversight—coupled with back-dated agreements, omitted hearings, and unfulfilled IPRA requests—renders the City’s participation both legally indefensible and morally untenable. Proceeding under these conditions would violate the Local Economic Development Act (LEDA), the Open Meetings Act (OMA), and the public-trust obligations of this Council.
For these reasons, I respectfully urge the Council to:
- Vote NO on Ordinance R-136 and the Intergovernmental Agreement with Sandoval County;
- Suspend all LEDA and IRB funding pending independent environmental, fiscal, and fire-risk review;
- Require disclosure of all Sandia, LANL, DOD, NMED, and SOS documentation related to Project Ranger; and
- Hold a new, fully noticed public hearing in compliance with LEDA § 5-10-3 and OMA § 10-15-1 before taking any further action.
Environmental due diligence, fiscal accountability, and public safety are not obstacles to progress—they are the foundations of lawful governance. The City must act not as a silent partner in secrecy, but as the guardian of its citizens’ health, homes, and future.
Respectfully Submitted,
Elaine Cimino
Rio Rancho Resident
November 13, 2025
Exhibit A
After reviewing the RRFR Automatic Aid to Sandoval County (Attachment V5) document, here’s a detailed analysis of the key inconsistencies and contradictions related to fire suppression, hazard classification, oversight, and emergency readiness for Project Ranger:
🔥 Fire-Suppression and Oversight Inconsistencies
1. “No-Water Suppression” Variance vs. Local Fire Authority Responsibility
- What it says: The report confirms that Project Ranger requested and received a variance from the New Mexico State Fire Marshal (SFMO) to exempt automatic sprinkler systems for all Hazard Division 1.1 and 1.3 buildings because “water/traditional fire suppression is adversely reactive with oxidizers.”
- Conflict: The SFMO denied the hydrant-exemption but deferred final authority to the local jurisdiction (RRFR/SCFR). Yet RRFR simultaneously states it is unclear who the Authority Having Jurisdiction (AHJ) is—either SFMO, Sandoval County Fire Rescue (SCFR), or RRFR itself.
- ➤ This creates jurisdictional ambiguity: one agency approves variances, another is expected to respond, and neither clearly holds operational command.
- ➤ Such uncertainty violates standard emergency-planning doctrine under the National Incident Management System (NIMS) and NFPA 600 for industrial fire-response hierarchy.
2. Defensive-Only Response Strategy
- What it says: For large-scale fires, RRFR plans a defensive posture, staging 600–4,900 feet away and “allowing the fire to self-extinguish.”
- Conflict: This approach contradicts community-safety assurances given publicly by Castelion and the County that local responders could “contain any incident.” In reality, RRFR admits crews will not suppress but observe and protect exposures for “well over 15 hours.”
- ➤ This directly undermines public statements that fire-risk is “minimal” or “fully mitigated.”
- ➤ It also highlights that no off-site evacuation or toxic-plume plan is finalized, despite the plume-study being incomplete.
3. Federal Oversight Claim vs. Explicit Denial
- What it says: RRFR asked which codes apply. Castelion replied that the site “is not considered a military base or contracted site by DoD” and therefore must follow local code—the opposite of the company’s public claim of Department of Defense oversight.
- ➤ This contradiction reveals misrepresentation of federal involvement. There is no DoD safety jurisdiction, only private adherence to selected DoD manuals (DoD 4145.26).
- ➤ In other words, DoD standards are cited but not enforced—a self-policing loophole with no external verification.
4. Variance Without Mitigation or Backup Systems
- What it says: RRFR asked what alternative fire-safety systems would offset removal of sprinklers/hydrants; no response was provided by Castelion.
- Conflict: This failure violates International Fire Code § 104.9 (requiring equivalent protection when granting variances).
- ➤ Even non-hazard buildings, which could use standard suppression, are apparently included in the exemption—contrary to RRFR’s recommendation that “all non-hazard buildings should still meet IFC requirements.”
5. Water-Storage and Tender System Contradictions
- What it says: The site proposes a 30,000-gallon storage tank and a tender-type truck for small fires.
- Conflict:
- A 30,000-gallon tank is negligible compared with the NFPA 1142 requirement (~250,000 gallons for this hazard size).
- Company personnel are only trained to use handheld extinguishers, not the tender.
- RRFR notes the team is limited to first-aid and extinguisher use only—no trained firefighting capacity.
➤ Thus, there is no realistic suppression capability on-site despite public assurances of “stringent safety measures.”
6. Environmental Contradictions
- What it says: RRFR acknowledges that using water could cause “groundwater contamination and adverse environmental impacts.”
- Conflict: The SFMO approved the sprinkler exemption but gave no plan for toxic runoff containment during monsoon season, even though RRFR explicitly asked how breaches would be mitigated; no response was received.
➤ There is no runoff-containment plan, despite clear acknowledgment of environmental hazards—contrary to NMED water-quality standards § 20.6.2 NMAC.
7. Missing Plume and Transportation-Incident Plans
- What it says: RRFR asked what mitigation strategies exist for chemical-spill or transport incidents on highways (US-550, Paseo del Volcán). Castelion gave no response.
- The plume study, scheduled for December 2025, was not yet completed.
➤ Proceeding without these studies violates LEDA § 5-10-10(B), which requires all performance standards—including safety—before final project approval.
- The plume study, scheduled for December 2025, was not yet completed.
8. Comparison to Intel and LANL Misleading
- What it says: The report compares Project Ranger to Intel for call volume and to LANL/Sandia for operational similarity.
- Conflict: RRFR clarifies that Intel has full sprinklers, hydrants, 24/7 EOC, nurses, and an internal medical facility—none of which exist at Project Ranger.
➤ Claiming comparable safety infrastructure is factually inaccurate and misleads the public record.
9. Incomplete Command and Communication Planning
- What it says: RRFR will “operate under our own Incident Command.”
- Conflict: Unified-command protocols under ICS/NIMS require integration with facility ERT and County agencies. Since the facility lacks an ERT and has only security guards, there is no qualified incident-command partner, violating NFPA 1561 standards for emergency management.
⚠️ Summary of Contradictions
| Category | Claim vs. Record | Resulting Risk |
| Federal Oversight | Claimed DoD oversight; RRFR confirms none. | No federal safety enforcement. |
| Fire Suppression | “Advanced suppression system” vs. defensive-only, no sprinklers. | Uncontrolled burn strategy, 15+ hours fire duration. |
| Environmental Protection | “Stringent environmental monitoring” vs. no runoff or plume plan. | Groundwater and air-quality contamination. |
| On-Site Emergency Team | “Full ERT” vs. security guards with first-aid only. | No effective on-site response. |
| Hydrant System | Claimed hydrants “strategically placed” vs. exemption variance. | Limited or no hydrant access. |
| Training & Equipment | Claimed coordination with best-practice agencies vs. “not shareable.” | No verified interagency readiness. |
| Public Transparency | Claimed full compliance and community safety vs. unanswered RRFR questions (17 of 27 unanswered). | Deficient record; failure of due diligence. |
Conclusion
The RRFR Automatic Aid Report confirms systemic contradictions between what Castelion and Sandoval County officials told the public and what the operational record shows.
The facility will lack sprinkler systems, hydrants, a qualified ERT, and enforceable federal oversight, leaving Rio Rancho Fire & Rescue as the first responder to chemical fires it cannot extinguish. What does the RRFD use fire fighting foam? What are the PFAS levels?
These inconsistencies substantiate the argument that the City Council must withhold approval of Ordinance R-136 and the associated IGA until independent environmental, fire-suppression, chemicals, and transportation-hazard reviews are completed.
Please consider speaking and or Writing Comments Sign up to Speak and submit comment by 4 pm Nov 13, 2025
Rio Rancho City Council Meeting Nov 13 2025 Thursday
RGENT: Public Comment Tonight on Project Ranger (Castelion Rocket Plant) 
The City of Rio Rancho Council is holding a meeting tonight where Project Ranger — the proposed solid rocket motor and hypersonic missile facility — is on the agenda.
It’s the LAST item, meaning it may not be heard until after 11 p.m. when most people have to work the next day.
Date: Thursday, November 13, 2025
Meeting begins: 6:00 p.m.
In-person: Rio Rancho City Hall, 3200 Civic Center Circle NE
Watch live: rrnm.gov/2303/Watch-and-Download-City-Meetings Join by Zoom: Click to join
Meeting ID: 833 3815 7719 | Passcode: 554297
Dial-in: +1 720 707 2699 (Denver)
To speak, you must register in person with the City Clerk at least 15 minutes before the meeting starts.
Written comments are accepted until 4 p.m. today to be entered into the record.
Why This Meeting Matters
The Sandia hazard report on Project Ranger was heavily redacted, and multiple public records (IPRA) requests remain unanswered.
Residents still haven’t seen an independent environmental or safety assessment.
Meanwhile, conflicting information has emerged:
Castelion representatives told the public the site would operate under Department of Defense oversight,
but Rio Rancho Fire and Rescue has confirmed it is not a DoD facility and will follow local and state variance rules — not federal military standards.
Castelion Rep Andrew Kreitz states in the Public info meeting that the chemical in this project cannot come in contact with water. Yet there is a sprinkler system for fire suppressant see attachments
This means local taxpayers and first responders would bear the risk — not the Pentagon.
We cannot allow another midnight decision with incomplete data and misleading claims.
Join us and demand independent review, public hearings under Robert’s Rules, and full environmental disclosure before any funds are released.