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2014-01-24 120 Citizens Comment on ADEC Proposed AQ Regulations-FinalA comment letter submitted yesterday to the Alaska Department of Environmental Conservation offers recommendations on the agency’s proposed air quality regulations. The comments were signed by 120 individuals, organizations, and businesses.

Read the letter: Comments on ADEC Proposed Air Quality Regulations – 120 signatures – final.pdf

From the comment letter:

“In conclusion, we find the proposed controls to be inadequate for the important task ahead. DEC has failed to consider control measures that are reasonably available, publicly supported, enforceable, sufficient, and viable. Our recommendations by contrast meet the requirements of law and the priorities of public health and the economic future of Fairbanks and North Pole. It is not reasonable to allow a small minority of chronic polluters to continue to undermine the health and economic future of an entire population who all need clean air to breathe.”

2013-12-19 opposing EPA deadline extension for PM2.5 plans - 145 signatures - finalA comment letter submitted today to the Environmental Protection Agency opposes the agency’s proposal to extend the deadline for states to submit PM 2.5 plans. The comments were signed by 145 organizations and individuals.

The comment letter states, “Under EPA’s wrong-headed and unreasonable proposal, states would be allowed a total of five years to submit plans that were required by law within 18 months.”

Read the letter: Comments opposing EPA deadline extension for PM2.5 plans – 145 signatures – final.pdf

UPDATE 12/17/2013: This post has been updated with two more studies, making a total of four pioneering studies on the association between autism and prenatal air pollution exposure.

A child could carry a gene for autism and show no signs of it unless that gene was triggered by exposure to polluted air, according to research led by scientists at the Keck School of Medicine of the University of Southern California.

Our research shows that children with both the risk genotype and exposure to high air pollutant levels were at increased risk of autism spectrum disorder compared to those without the risk genotype and lower air pollution exposure. –Heather E. Volk, PhD, MPH, Assistant Professor of research in preventive medicine and pediatrics at the Keck School of Medicine of USC and principal investigator at The Saban Research Institute of Children’s Hospital Los Angeles, ScienceDaily.com article 12/2/2013

Heather E. Volk, PhD, MPH, and Daniel B. Campbell, PhD

The researchers found air pollution may compromise the healthy functioning of a child’s brain and immune system leading to autism in those who inherited a particular gene.

“This is the first demonstration of a specific interaction between a well-established genetic risk factor and an environmental factor that independently contribute to autism risk. The MET gene variant has been associated with autism in multiple studies, controls expression of MET protein in both the brain and the immune system, and predicts altered brain structure and function,” according to Daniel B. Campbell, PhD, Assistant Professor of psychiatry and the behavioral sciences at the Keck School of Medicine of USC and the study’s senior author. Keck School of Medicine article 12/2/2013

Autism spectrum disorder (ASD) is a lifelong neurodevelopmental disability characterized by problems with social interaction, communication and repetitive behaviors. The US Centers for Disease Control and Prevention estimates that one in 50 children in the United States has an ASD. Forbes 3/20/2013 and Center for Disease Control autism fact sheet 3/20/2013

Previously, health studies have shown significant associations between exposure to fine particulate pollution (PM 2.5) and premature death from heart and lung disease. PM 2.5 pollution can aggravate heart and lung diseases and has been linked to effects including cardiovascular symptoms; cardiac arrhythmias; heart attacks; strokes; blood clots; diabetes; chemical sensitivity; asthma attacks; respiratory infections such as bronchitis and pneumonia; COPD; chronic bronchitis; low birth weight; and reduced IQ.

The study, “Autism spectrum disorder: Interaction of air pollution with the MET receptor tyrosine kinase gene,” was published in the January 2014 edition of Epidemiology, available here.

An earlier study, perhaps the first national study to associate autism with air pollution, was published by the National Institute of Environmental Health Sciences journal Environmental Health Perspectives 8/2013, available here. This NIEHS study was covered by Autism Speaks.

Two related studies:

Becerra T, Wilhelm M, Olsen J, Cockburn M, Ritz B. Ambient Air Pollution and Autism in Los Angeles County, California. Environ Health Perspect 121:380–386 (3/2013). http://ehp.niehs.nih.gov/1205827 [Online 12/18/2012.]

Volk H, Lurmann F, Penfold B, Hertz-Picciotto I, McConnell R. Traffic-Related Air Pollution, Particulate Matter, and Autism. JAMA Psychiatry 2013;70(1):71-77. doi:10.1001/jamapsychiatry.2013.266. http://archpsyc.jamanetwork.com/article.aspx?articleid=1393589 [Online 12/2012.]

Thanks to North Pole Clean Air for publicizing the connection between autism and air pollution and Utah Physicians for a Healthy Environment for sharing the two related studies.

Air Plan Deadline Extension Draws Critics (audio) Alaska Public Radio News, 12/4/2013

We ask: Why is EPA helping the State of Alaska delay clean air for Fairbanks?

Highlights:

There’s pushback on the Environmental Protection Agency’s proposed extension of time for states to develop plans to reduce fine particulate pollution. Clean air advocates are opposed to potential delay in improving air quality in communities suffering with air pollution like Fairbanks.

A January ruling in a suit filed by the Natural Resources Defense Council requires the EPA enforce smoke regulations under more a stringent part of the Clean Air Act. Last month, the agency proposed giving states more time, until Dec. 14, 2014, to get attainment plans in.

Earthjustice attorney Colin O’Brien: ‘They’ve looked at a court decision–which said EPA you’re doing this wrong, the deadline is supposed to be earlier not later–and EPA has responded by giving an extension of time.’

The State of Alaska failed to meet the original deadline 2012 and is working to get a plan for cleaning up Fairbanks’ air in by next summer.

Plans won’t be going into place until just prior to EPA pollution reduction threshholds which take effect in 2015.

O’Brien: ‘It’s hard to imagine that the attainment deadline will actually be met.’ O’Brien adds there’s a lot at risk: ‘The health and welfare in those communities like Fairbanks where the air pollution levels are dangerous.’

Related post: EPA Proposes More Delays for Fairbanks, Possibly til 2024

New air pollution rules proposed by the State of Alaska Department of Environmental Conservation are too weak to protect your health or the economy.

58 comments have been submitted on the proposed air pollution regulations for the Fairbanks PM2.5 nonattainment area. WOW! 30 in the past week! Compare w/ 56 comments submitted by residents from Liberty-Clairton, Pennsylvania on their PM2.5 attainment plan. Way to roll! More comments than a community of 1.2 million! Keep it up!

TAKE BACK OUR AIR:

Cut and paste these snazzy, new comments. Use your own words as much as possible…

First,

Set the PM2.5 trigger for Air Alerts to 35 micrograms per cubic meter or lower. The state has proposed to set the trigger at 56 micrograms per cubic meter. Nonattainment violations start at 35 micrograms per cubic meter. The trigger needs to be no higher than 35 to help prevent violations. Alaska must not be the only state in the nation with a trigger higher than 35. Juneau, AK uses 30, Washington State uses 25 and 35, Sacramento, CA uses 31 and 35, and Utah nonattainment areas use 25.

Hospitalization for heart attacks, lung ailments, and strokes increase at levels above 20 micrograms per cubic meter. A lower number better protects health. FNSB 11/29/2012, p 11. Scientific evidence and medical harm support a trigger of 20 micrograms per cubic meter. A level of 56 is cruel because it gives no protection to sensitive groups such as people with heart or lung problems, diabetics, elders, children, and developing fetuses.

Add section for public notification of Air Alerts. Establish “check before you burn” website, email notifications, toll-free phone number, and other media outlets. Air pollution can continue to increase after an announcement of unsafe levels of air pollution depending on how well the order is communicated and public response.

[Personalize it -- Say how much air pollution has cost YOU financially. Were you hospitalized? Did you miss work? Were you prescribed medicines? Did you buy an air filtration system? Say so; specify your financial cost.]

PASTE your comment in Form Field #5: https://dec.alaska.gov/Applications/Air/airtoolsweb/FormalComments
IMPORTANT: CHECK
the “fiscal impacts” box.
ATTACH supporting documents to show how much air pollution has cost you financially.

Second,

The proposed regulations need to include an exemption for essential residential heating during a temporary power outage and where a solid fuel-fired heating device is the sole source of heat. Exempt devices must be registered by a cut-off date and upgraded when the property is sold. A exemption for essential residential heating is standard in other states including California, Washington, Nevada, and Utah.

A new definition should be included for “essential heating” to provide for residential heating needs that are absolutely necessary.

PASTE your comment in Form Field #8: https://dec.alaska.gov/Applications/Air/airtoolsweb/FormalComments IMPORTANT: CHECK the “fiscal impacts” box.
ATTACH supporting documents to show how much air pollution has cost you financially.

CLICK “Submit Comments” at bottom of form to submit both comments.

The state will email a copy of your comments to you. Please forward a copy to: cleanairfairbanks@gmail.com

FORWARD this message to a friend because we need help to take back our air.

Thank you.

More:

If you prefer to submit all your comments at one time, download, edit, and send Word DOC on this post: Take Action: Comment for Clean Air on Draft State Rules. Post also has links to the proposed and current regulations.

Will Alaska DEC listen? If you specify what air pollution has cost you and you check the “fiscal impact” box, DEC must listen. To get their ear, specify dollar amounts (estimates are better than no numbers) and attach supporting documentation. State law requires agencies to “pay special attention to the cost to private persons.” AS 44.62.210.

Fairbanks Bowl, PM2.5 Pollution Accumulates under Inversion, 11/20/2013 3:43 pm

Fairbanks Bowl, PM2.5 Pollution Accumulates under Inversion, 11/20/2013 3:43 pm

Fairbanks and North Pole air pollution was worst in the nation again yesterday.

If you’re looking for Beijing-grade air pollution, save the airfare. Yesterday, you could find air nearly as dirty in North Pole, Alaska.

Nov. 20, 2013, 24-hour average PM2.5 and hourly range:

North Pole, Alaska, US - UNHEALTHY, 71 micrograms/cubic meter, range 32 to 116
>> Source: FNSB North Pole Fire Station on Alaska DEC Air Monitoring Network
How to use Alaska DEC Air Monitoring Network Real-time Monitoring

Beijing, ChinaUNHEALTHY, 77.6 micrograms/cubic meter, range 19 – 144
>> Source: Beijing Air Twitter Feed

Other monitors on Nov. 20, 2013:

  • Watershed School, Fairbanks, US – UNHEALTHY FOR SENSITIVE GROUPS, 50 micrograms/cubic meter, range 24 to 108
  • FNSB Administrative Building, Fairbanks, US – MODERATE, 35 micrograms/cubic meter, range 17 – 49
  • Tulare, San Joaquin Valley, California, US – MODERATE, 28 micrograms/cubic meter, range 8 to 45 (Highest in US other than the three monitoring sites in Fairbanks North Star Borough.)

Making sense of the numbers: EPA Air Quality Index Chart, 2013

Update 11/22/2013: If Fairbanks is classified as “serious,” the attainment date with all possible extensions will be 2024, not 2020 as originally stated. The post below has been corrected. Thank you to our alert reader for catching the error. When health has no voice or value, delay is here to stay.

How is it “good news” that the State may further delay filing the PM2.5 attainment pla

The shifting deadline is good news because missing the deadline could come with serious sanctions against the state. The federal government could yank highway funds and impose sanctions on any new power plants built in areas that don’t meet the EPA’s clean air standards.” Cindy Heil with Alaska DEC Air Quality Division explained the delay in finalizing the state attainment plan was because DEC expected the deadline to slip. According to Ms Heil, “We’re looking to meet this one.” Alaska gets a break on late air quality plan FDNM 11/20/2013.

Isn’t it a human tragedy wrapped in incompetence rolled up with denial?

Or, is it business as usual and just another dirty air day in Fairbanks and North Pole?

>> Link: ADEC Air Quality Advisory Fairbanks North Pole area UNHEALTHY for SENSITIVE GROUPS becoming UNHEALTHY valid Nov 19 4:00PM to Nov 22 2013 4:00PM

For the day so far at 2:00 pm, the Watershed School monitor in Fairbanks recorded a PM2.5 average of 47 micrograms/cubic meter and the North Pole Fire Station recorded 89. For now, downtown Fairbanks is an oasis of better air. 30 was recorded at the downtown FNSB Administrative Building, the only site tracked by EPA. Nonattainment is over 35 micrograms/cubic meter for a 24-hour average.

EPA’s proposed extension risks the health and lives of people with asthma and COPD, heart disease and atrial fibrillation, diabetics, elders, children, developing fetuses, even healthy adults and athletes. We oppose this unnecessary, bureaucratic delay that abandons an entire community with no regard to health consequences.

New Deadlines under Proposed SIP Extension

If finalized, the State Implementation Plan (SIP) will be due Dec. 31, 2014. Eight areas (including Fairbanks) in five states are affected.

The attainment deadline would be Dec 14, 2015, rather than Dec 14, 2014. Attainment is determined from the three-year average of design values for 2012, 2013, 2014 of 35 or below. [By comparison, the 2010-2012 average for Fairbanks was 46. Only two areas in the nation, San Joaquin, CA and Logan, UT, recorded higher values during the same period.] Design value readings are taken every third day by the FNSB Administrative Building monitor in downtown Fairbanks and do not include higher concentrations recorded in North Pole or at the Watershed School.

The proposed rulemaking establishes all eight areas as “moderate.” EPA may reclassify areas as “serious” in two ways: 1) 18 months after a state misses the Dec 31, 2014 SIP deadline or 2) 6 months after a state misses the Dec 14, 2015 attainment deadline.

“Moderate” areas may be eligible for two extensions of no longer than one year each if “the State has complied with all requirements and commitments pertaining to the area in the applicable implementation plan; and there is not more than one exceedance of the 24-hour standard during the preceding year.” 42 USC § 7513(d). Therefore, the attainment date for “moderate” areas with all possible extensions would be 2017.

Areas classified “serious” get more time to meet attainment. The attainment date for Fairbanks would become Dec 14, 2019 if so designated.

Further, “serious” areas may get up to five years of extensions if certain conditions are met including “the State demonstrates to the satisfaction of the Administrator that the plan for that area includes the most stringent measures that are included in the implementation plan of any State or are achieved in practice in any State, and can feasibly be implemented in the area.” 42 USC § 7513(e). Therefore, the attainment date for “serious” areas with all possible extensions would be 2024.

>> Link to Federal Register notice, public comment period ends 12/23/2013: https://www.federalregister.gov/articles/2013/11/21/2013-27992/identification-of-nonattainment-classification-and-deadlines-for-submission-of-state-implementation

Related Posts:

EPA Scraps Implementation Guidance for 2006 PM 2.5 Rule

How EPA’s Design Values Exclude Air Pollution Days

Fairbanks Air: More Dangerous Than You Think – Wickersham’s Conscience

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