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City Government

Air Quality In The Eye (and lungs) Of Beholders

 July 15, 2007 ⋅  Post a comment

Two writers with opposing views on the air quality issue in the Treasure Valley asked to use the GUARDIAN as a discussion platform. Tim Kempf of Eagle is keenly interested in growth issues and fancies himself as using a scientific approach to issues. Michael Barnett of Nampa sees air quality as being somewhat stable, but the issue has become political and we citizens are victims of propaganda. Both views have interesting points and should offer plenty of stimulation for comments.

We present both views here and offer “further reading” from Barnett. His treatise is much too long to display on the page. Kempf won a coin toss and goes first.
–EDITOR

By TIM KEMPF
In order to assess the air quality in the Treasure Valley one may rely on either of two methods-1) review the historical Air Quality Index (AQI) data that is available on the Idaho Department of Environmental Quality website, or 2) use the “If it quacks like a duck …” approach.

The first approach is very convincing as a simple plot of the data using the graph wizard with Microsoft Excel will show that the number of poor air quality days and the amount of pollution in our air is high and has increased over the past decade. It is also common knowledge for residents of the valley, and you will learn this very quickly after having recently moved to the area, that we experience strong temperature inversions which trap the air and allow for high levels of pollution to build.

Should you choose to use this first approach, I would caution you to consider that the distribution of the data is subject to the number of monitoring sites, the location of those sites and how Air Quality Index Alert Days are organized into categories. A true measure of the quantity of all pollutants in any location and at any time would surely reveal that our condition is even worse than often reported.

Now considering the second and more accurate approach, simply step outside, open your eyes and breathe. I do this everyday and when the air quality is particularly bad, as it has been for much of this spring and summer, I experience a visceral reaction that takes me back to my childhood days. I was born in the Conemaugh Valley of Greater Johnstown, Pennsylvania (coal country) and grew up in Pittsburgh, our country’s second most polluted city after Los Angeles. The haze that hangs over our valley, the bitter, metallic taste of the air and the headaches all remind me of home.

For those of you who still don’t believe and need more data I think a third approach might do the trick-a simple analysis of the relative change in the number of doctor’s office visits for individuals that have asthma or heart disease.

Oh, and one more thing, there are three primary reasons for all this pollution and they may be expressed in an old real estate mantra-cars, cars and cars.

EMISSIONS TAX SCAM

By MICHAEL BARNETT

Those writers calling for vehicle emissions testing outside Ada County are sadly misinformed victims of the air quality propaganda machine. If they look at the actual data – AQI indices, median, 95th percentile, etc. – they would find that, despite our growth, annual numbers have stayed within a fairly constant range since 2000, with 2003 being the highest – but still within NAAQS requirements.

Data also shows that motor vehicles are not the primary source of our problem pollutants. Per the latest, although somewhat dated, EPA emissions inventory numbers for our area, highway vehicles account for less than 1 percent of PM-2.5 and just under 25 percent of ozone precursor emissions.

Instead of whining about why nobody else has to test their cars, Ada County residents should instead be asking why they continue to pay what amounts to an emissions tax. Answer? It pours bucks into the treasury, and you’re easy pickings because you don’t have lawyers or lobbyists.

Emissions testing here, now, is akin to an ISP trooper showing up at your door and issuing you a speeding ticket because they think you might exceed the speed limit at some undetermined time in the future. Do you want government like that? I don’t.

By Michael Barnett

I’ve been reading through the articles and comments in the Boise Guardian, and am disappointed to see that the air quality propaganda machine is as successful as it seems to be. I see lots comments about “worse than LA”, “been going downhill since I’ve been here”, “Yellow and Orange Alerts”, “Lose federal dollars”, “economic doom”, “federal takeover”, etc. Please take a few moments and read “the other side”.

Treasure Valley air is in compliance with all National Ambient Air Quality Standards. That statement is not open for interpretation, regardless of what you think or what you hear. It is a fact of the law, whether you think the air is good or bad, or if you couldn’t care less. Might that change in the future? Sure, in fact it probably will, but more than likely it will change because EPA keeps tightening the standards and not because our air is actually getting worse. Also, you must remember that the law does not define “clean” air, it only defines a “dirty” air threshold and what happens when that is crossed, and we are not there – yet.

DEQ’s “Alerts” are a speculative forecast system and do not reflect the actual, calculated Air Quality Index for a particular day. They’re guessing. Sure, they’re equipped to do that, and that’s their job, but it’s still a guess. It’s not at all unusual for the documented AQI for a particular day to be as many as 50 points below what DEQ predicted it would be – but they almost never miss on the low side. Hmmm… DEQ’s Chicken Little air quality Alert system seldom, if ever, matches what the EPA reports real-time on their Region 10 website. In a recent Idaho Statesman interview, the Director of DEQ stated that we’ve had fifty-some “bad” air days already in 2007. There is no such thing as “bad” as an air quality classification, and she was clearly presenting “moderate” days in the worst possible way in order to sway public opinion. To me, that represents irresponsible leadership – and an agenda. So, the next question becomes “why would they make it sound worse than it is?”

It’s simple, really. They want your money, and they need to justify their programs. After all, if you’re a regulatory agency and nobody is violating your regulations, who needs you?

Some history is in order. In the 1970’s the air in Ada County was deemed non-compliant with the Clean Air Act because of high levels of PM-10 (particulate matter 10 microns or less in diameter). The primary cause of the PM-10 was woodstove smoke, and the vehicles of the day contributed their share. Programs, including vehicle emissions testing, were implemented to clean up the air. That was accomplished, thanks mostly to major technological improvements in wood stoves and a local reduction in their use as a primary heating source. Between 1991 and 1999 there was not one single day of air quality regulation Exceedance in Ada County. DEQ finally got off the dime and asked the EPA to reclassify northern Ada County. Why they waited so long to do that is open to speculation. I think it’s because the emissions testing program was, and continues to be, a major cash cow for everybody involved. Unfortunately, at the same time DEQ filed for reclassification, EPA was in the process of implementing some new Particulates standards, and the trucking lobby was challenging them. The truckers initially prevailed in having the new, tougher standards struck down. EPA eventually prevailed at the U.S. Supreme Court level, but by then it was too late for Ada County. To make a long story short, a group calling itself Idaho Clean Air Force, which, interestingly enough, included just-unseated ACHD Commissioner Gary Richardson, sued the EPA to keep them from reclassifying Ada County’s air as Attainment. It’s significant here to understand that the lawsuit did not question the actual air quality in Ada County, but was instead based on the administrative procedures EPA used during the reclassification process. Ada County’s air was actually well within either the old or the new standards. Why would ICAF seek to block what most people would have thought was a good thing? My first conclusion is that environmental groups want absolutely no public acknowledgement that things can actually get better, because that threatens their entire agenda and hampers membership recruitment and fund raising. Second, and what I think was the major cause, was that the “Leaders” of the Treasure Valley had just recently decided that ways needed to be developed to increase local fee revenues in order to address future transportation issues in the Valley. I can’t argue with that concept, because we could certainly use some efficient mass transit here. But I strongly object to the underhanded way things subsequently developed.

The Flying Y project was in progress, and a lot of people thought that the lawsuit might hinder that, so COMPASS, our Metropolitan Planning Organization required by federal law, stepped in to broker a settlement to the lawsuit. In short order, a compromise – if you can call it that – was reached and the action never went to trial on its merits. The compromise included acquiescence to leave northern Ada County’s air quality rating in a Maintenance mode, and, as part of that, to continue the vehicle emissions testing requirement. Another element that was tossed in was that COMPASS promised to do everything they could to implement vehicle emissions testing throughout their jurisdiction, which includes Canyon County. So, that’s where that whole thing started. It seems very contradictory to me that less than ten years ago our local “officials” caved in and let happen exactly what they are now supposedly attempting to prevent – a negative air quality classification. Except now they can smell all that fee revenue.

Oh, and by the way, the taxpayers picked up a several-hundred-thousand dollar tab for the ICAF lawyers.

Canyon County residents successfully fought against the implementation of vehicle emissions testing in our jurisdiction. The numbers did not then, and do not now, justify the cost to residents of that kind of program given the virtually non-existent air quality improvement it yields. When I inquired about pass/fail rates, revenue and disbursement, etc., with the Ada County Air Quality people, I got the song-and-dance runaround and never did get out of them everything I requested.

Having failed to fool the local rubes on vehicle emissions testing, COMPASS and DEQ enlisted Senator David Langhorst, D-Boise, to escalate the air quality issue to the state level. Thus was born the Treasure Valley Air Quality Council, which made its recommendations to the Legislature during the 2007 session. If you traced the Council’s proceedings, you would find that they dismissed vehicle emissions testing early in their deliberations as a non-effective strategy, but when they got right down to the end and presented recommendations, guess what? They included a call for a Valley-wide vehicle emissions testing program. Hmmm… imagine that. The Legislature did not act on the Council’s recommendations during the 2007 session, but I’m certain that with all the effort behind it, we’ll hear about it again in 2008.

So, that’s basically where we are today. It seems nearly everyone in the Valley is convinced we’re about to die, our economy is about to collapse, and, depending on which argument you hear, the feds are about to either disown or assimilate us because our air is hopelessly polluted. None of that is true. Here are some things I’ve learned:

Despite our growth, our air quality is actually holding pretty steady, with pollutants down since 2002. I’m not making that up. If you go to the EPA archives of actual Primary Pollutant concentrations reported by DEQ and graph out the various benchmark values for our problem pollutants for the past six or seven years, the graphs are not trending upward, and 2002 was the worst year. Last year is not yet fully reported, and for 2007 you have to use the EPA Region 10 site archives instead of the general EPA site, but the data is there if you choose to mine it. Also, as recently as two weeks ago the EPA updated their national report on air quality status, and no Idaho counties were listed as problem areas. As I said before, what will probably get us eventually are the tougher standards – which I am not arguing against. In fact, I think that’s how it should work. Clean air is a desirable commodity; my point is that our air complies with every definition extant in the law that says we do not need remedial regulations, yet somebody local wants to impose punitive sanctions on us. You are being systematically convinced our air is foul in order to facilitate new regulations – and the fee revenue they will generate.

PM-2.5 and ozone are the pollutants of current local concern. I know the pros at DEQ would argue with me on this, but I maintain that automobiles are not a significant source of PM-2.5 and the EPA emissions inventories agree with me. The PM-2.5 problem is more of a Canyon County problem – most recent local PM-2.5 Exceedances happen here — and like it or not, jobs or not, wink-nod-look-the-other-way, the sugar factory is the main culprit. Ozone is so weather and temperature dependent that it’s hard to get a handle on. All of the control strategies are based on the concept that reducing precursors reduces ozone formation – which assumes that ozone levels stop rising because all precursors are used up. No science I have seen yet confirms that or can predict a direct correlation, i.e. reducing precursors by 20% does not reliably reduce ground level ozone by a like amount. An indicator of how elusive ozone remediation is going to be is that concentrations in remote areas of some National Parks are sometimes higher than in downtown Los Angeles.

If vehicle emissions testing is implemented Valley-wide DEQ can generate theoretical Emissions Budget Reductions, and then trade those on-paper emissions reductions for new commercial/industrial emissions permits. Because those reductions are speculative calculations only, and new permits result in very real emissions, we could actually end up with higher pollutant concentrations. Five years ago, when Idaho Power was looking to build a power plant in Middleton, the Idaho Association of Commerce and Industry issued a memorandum in support of the project, and in that memo they stated “there is no air quality problem in the Treasure Valley”, and they were right. It seems that if pollutants come from your exhaust pipe, it’s a bad thing, but if they come from economic growth, they’re okay.

Despite what you hear, highway vehicles are not the big demons of all this. Again, what you hear from the locals doesn’t match the data published by the EPA. For example, all you hear during an inversion is not to drive your cars. Per the EPA, highway vehicles account for less than 1% of PM-2.5 particles in our local air. Highway vehicles also account for less than half of ozone precursor emissions in the latest local inventory. Overall fleet emissions have been drastically reduced in the past 10-15 years, thanks to the demise of carbureted engines and the advent of onboard diagnostic computers, and they continue to decline as engine technology improves. Many of you in Ada County know that the emissions testing tech seldom, if ever, actually tests your exhaust. If your car’s diagnostic computer is hooked up and running, you’re good to go – oh, and we take cash, checks, and credit cards. Highway vehicles, or should I say their owners, are easy targets in all this because we don’t have lawyers and lobbyists.

“We”, whoever “we” is, do not lose federal highway dollars should the Treasure Valley fall to Non-attainment status. Federal Highway Trust Fund dollars are allocated to each state according to a statutory formula and the EPA has no say in how many dollars Idaho gets. A board at ITD then decides how those dollars are spent on highway projects across the State. The process is very competitive, highly political, and can be usurped by the Legislature. Once a project gets high enough up the list and there is money available, the project goes forward. Local project funding generally comes from property tax revenue or bonding. Population growth in the Treasure Valley has actually contributed to us getting more money, in part because we now fall into a different funding classification than we used to. In all of my searching, I could find only one instance during the entire life of environmental regulatory review in the U.S. where the EPA stopped a roadway construction project on air quality grounds. It just doesn’t happen. It’s simply another hoop to jump through to justify regulations and bureaucracy, and another scare tactic that the pro-regulation crowd can try on us.

Air quality Non-attainment does not presage economic gloom and doom. In fact, according to recent data, 13 of 25, and 3 of the top 5, fastest growing Standard Metropolitan Statistical Area economies in the United States are air quality Non-attainment areas. If you were totally dependent on majority-rules statistics, these numbers would seem to mean that dirty air is good for your economy – but sometimes statistics don’t tell the whole story. In this case I think it demonstrates that there is no verifiable cause/effect relationship between air quality and economic health. I will admit that I have not done long term trend research on those lists to see who stays on and who falls off, which might be a better indicator, but I did check several years running and saw little significant change. It’s more like shuffling a deck of cards – the same cards are there, the order changes. Besides, I daresay Micron just cut more jobs in two weeks than our air quality will impact over the next decade.

If we become air quality Non-attainment, what will the EPA do to us? Pretty simple, actually. They don’t really do anything. They drop the hot potato into DEQ’s lap with a mandate to come up with an acceptable plan to remediate the air quality. That remediation plan will include sanctions – like emissions testing your car, vapor recovery systems at gas stations, enforcing open burning regulations, controlling sprawl… Hey, wait a minute! Does that sound familiar? It should. They’re the same actions recommended by the Treasure Valley Air Quality Council, no doubt at the behest of DEQ. The Federal Government always plays well as the Bogeyman, especially here in Idaho. I would also argue that if the Feds were to require us to enact more stringent measures to achieve some improvement, why would we be trying to get away with doing less? Should not the goal be to achieve air quality improvement instead of trying to skirt around it?

There is already case law precedent that says air quality (except in California, where their Air Quality Management Board predates the original federal Clean Air Act) is a federally controlled and governed initiative. Everywhere in the United States a local or state jurisdiction has attempted to implement their own air quality plans and standards different from those codified in federal regulations, those plans and standards have been thrown out. If any jurisdiction attempts to impose sanctions or standards selectively on Treasure Valley residents without us first being in violation of the applicable federal regulations, I have little doubt that the issue will end up in a federal court and the taxpayers can once again pick up the tab.

Could our air be cleaner? Maybe, but not with 600,000 people already in a Valley that is rapidly developing using a blueprint that is a demonstrable failure everywhere it’s been used since WWII. But that blueprint makes all the movers and shakers rich, and isn’t that, after all, the real goal? Never let common sense stand in the way of somebody making a buck.

Okay, so that’s air quality from “the other side”. I’m certainly not coming out in favor of “dirty” air. I, too, can see the brown stuff we have now that we didn’t have ten years ago, and I do think we could do better – but we don’t need more regulations and cost to do it. What we need is a little backbone in hearing rooms, council chambers, and a certain domed building downtown. I’ve been following this saga from the beginning, and perhaps my biggest disappointment is that there appear to be no limits to the misinformation that the people who work for us will shovel onto us in order to get what they want.

Don’t blame Californians or other newcomers for what ails the Treasure Valley. Put the blame where it belongs – squarely on the shoulders of all the self-serving little people who think they’re up to big jobs.

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