Archive for the ‘Federal PM 2.5 Nonattainment’ Category

Business Insider 7/3/2014

The US Air Force recently released its final study to add at least two squadrons of F-35As to Eielson Air Force Base (FDNM 2/27/2016). The decision, to base the jets at Eielson, was reached by ignoring its air pollution impact on the severely polluted PM2.5 nonattainment area.

According to the study, increased air operations at Eielson will add 17 tons of PM2.5 per year to the nonattainment area (F-35 Operational Beddown EIS, p 4-38). However, because the increased contribution is less than 100 tons, under EPA rules it is de minimis, and does not trigger a conformity determination or cause a significant impact. 17 tons is a vast underestimate because increased air pollution from housing additional service members and construction workers in the nonattainment area were not considered.

Air Force Times 10/26/2015

Beset by technical problems, the F-35A Lightning II by Lockheed Martin is the most complex and most expensive weapons system in history. The F-35 has over 24 million lines of code, more than any other US or allied jet in history. A single F-35A costs $148 million, making the cost of 48 F-35As (24 per squadron) $7.1 billion.

A pilot’s helmet, with a host of flaws such as jitter and poor night vision, costs $400,000.

Russia Insider 1/30/2016

The cost of the F-35 program is nearly $400 billion for 2,457 planes and, to maintain and operate over its lifetime, will cost nearly $1 trillion. (Current estimates are $1.2 trillion.) Senator John McCain said the F-35 program has been “both a scandal and a tragedy.”

Big money attracts supporters. Overlooking concerns about cost and operational malfunctions, the Alaska Delegation announced the Eielson F-35s will trigger an “economic boom for Interior Alaska” (Press Release 2/26/16).

Even Democratic presidential contender Senator Bernie Sanders who campaigns on voting against the Iraq war, nonetheless supported the F-35 and succeeded in basing 18 F-35 jets at the city airport in Burlington, VT.

The Daily Beast 2/8/2016

Fairbanks has the highest PM2.5 concentrations in the nation, measured by the 24-hour design value from 2012-2014 (PM2.5 Design Values, EPA 8/19/2015, Table 5, 31-Z). By June 2016, EPA will designate the nonattainment area as “serious” which will initiate a requirement for best available control measures” to reduce PM2.5. Adding new sources, no matter how popular, worsens the harm to health.

But, when the Air Force brings in its stable of high-dollar war machines, they’ll operate above and outside “best available” air pollution controls. The Air Force will contribute to their host community’s severe air pollution, requiring more stringent controls on non-exempt emitters. So, there you have it: When it’s about Fairbanks’ air quality, count on the most expensive weapons system in world history being just de minimis.

[Click on image to open article source.]


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Preliminary data from EPA shows Fairbanks, AK likely had the highest daily PM2.5 in the nation during 2012 to 2014.

On May 1, EPA will finalize sampling data for 2014. 2012 and 2013 have already been finalized. A three-year average is used to calculate nonattainment.

Fairbanks data from air pollution monitor sites, operated by the Fairbanks North Star Borough, are provided to the State of Alaska and submitted to EPA. A review of final and preliminary EPA data show that the three-year average of Fairbanks daily PM2.5 for 2012 to 2014 will be double that of Bakersfield, CA. EPA currently lists Bakersfield as having the highest daily PM2.5 for 2011 to 2013.

Table: 98th Percentile 24-hour PM2.5 2012-2014, preliminary

*EPA to finalize 2014 monitor data May 1, 2015.
Monitor Location, Site ID 2012 2013 2014* 3-year Average*
Hurst Rd, FNSB, 020900035 158.4 121.6 138 139
Bakersfield, Kern, 060290014 56.4 71.8 80 69

In fact, the astonishingly high monitor concentrations recorded at the Hurst Road residential neighborhood in 2012 and 2013 make it mathematically impossible for Bakersfield to hold on to its #1 ranking as worst 24-hour PM2.5 polluted community in the US. Bakersfield, get ready to move over for Fairbanks.

Data Sources:


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Key question still being overlooked:

Would an ordinance weaker than state regulations (including the final SIP) risk termination of the local control program and state funding per AS 46.14.400, AS 46.14.410, and 18 AAC 50.015?

Instead of addressing this question, coverage in the Fairbanks Daily News-Miner is limited to reporting on opinions from three North Pole City Council members. North Pole leaders offer differing opinions on borough air quality plan 2/26/2015.

Link  to previous post: Assembly Proposal for Weak Controls Risks Termination of Local Control

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During recent public hearings on development of a new air quality ordinance, 2015-01, there was no mention that the new ordinance needed to be at least as stringent as the new plan approved by the State or the Borough risks losing local control.

The Assembly went so far as to amend into the draft ordinance a control zone, in effect shrinking the boundaries of the designated PM2.5 nonattainment area by removing the northern third of the nonattainment area. The revised control zone excludes part or all of Chena Ridge, Sheep Creek, Goldstream, Fox, and Gilmore Dome neighborhoods, view proposed “Air Quality Control Zone” map. Not only is there no data to support shrinking the nonattainment area, to do so violates State and Federal law. The idea that air quality must be a compromise seems to have thrown the Assembly off track. Like it or not, long-delayed deadlines and controls take effect Feb. 28, 2015. Opportunities to develop a local plan were squandered years ago. The Assembly holds only these options: follow the State program, strengthen it, or get out of the way. Weakening controls established by the State risks termination of local control and funding granted to the Borough for the program.

Legal substantiation:

  1. The latest version of ordinance 2015-01 appears to include an error in the “whereas” statements. The last statement on page 2 refers to “draft regulations” issued by DEC that are “intended to be part of the State Implementation Plan as required by the EPA.” The regulations issued by DEC are no longer in “draft” form. They are FINAL regulations that have been fully adopted by DEC (and signed by the Lieutenant Governor) and they constitute state regulatory law beginning Feb. 28, 2015. DEC’s website makes plain that the regulations are final.
  2. The draft Borough ordinance also notes on page 2 that the Borough has been authorized by DEC to operate an air quality control program “in lieu of and consistent with the State’s air quality program.” This is accurate, although the key word is “CONSISTENT.” Any local air quality control program must operate in a manner that is “consistent” with DEC requirements. This is specified in the statutory provision that allows for the existence of the Borough’s local air quality control program. Per AS 46.14.400(a): “With the approval of the department, a municipality may establish and administer within its jurisdiction a local air quality control program that operates in lieu of and is consistent with all or part of the department’s air quality program as established under this chapter.” (emphasis added).
  3. By Alaska statute, to be “consistent,” the Borough’s local air quality control program MUST implement DEC regulations. This is specified in AS 46.14.400(f):  “A municipality or a local air quality district administering a program under this section shall administer its local air quality control program according to this chapter, regulations adopted under those sections, and its cooperative agreement under (d) of this section.” (emphasis added).
  4. The only exception to the statutory requirement that a local air quality control program administer state regulations is for “more stringent” local requirements, which may be adopted with DEC approval. See AS 46.14.400(f).
  5. A local air quality control program may only operate if approved by DEC. See AS 46.14.400(a). If a local air quality control program is NOT administered in a manner that is consistent with legal requirements, DEC can revoke approval and terminate the program. See AS 46.14.410.
  6. The boundaries of the nonattainment area are set by EPA, whose delineation constitutes federal regulatory law. The boundaries of the nonattainment area are further codified in DEC’s regulations, which incorporate by reference the delineation of the EPA administrator.  See 18 AAC 50.015.
  7. In light of the foregoing, it would be UNLAWFUL, DISRUPTIVE, and ultimately POINTLESS for the Borough to adopt less restrictive air quality regulations.

Additional points:

  • Because state law requirements govern no matter what the Borough decides, inconsistent local measures risk unnecessary confusion and the potential that residents might face enforcement consequences for violation of state regulations—which they must obey no matter what the Borough says. (NOTE: Page 4 of the DEC-Borough MOU specifies that a violation of a DEC regulation will be handled by DEC.) Adoption of inconsistent local regulations risks termination of the Borough’s local air quality control program by DEC and funding provided for this program by state and federal agencies.
  • The adoption of inconsistent regulations by the Borough—and the attendant confusion and uncertainty about the extent to which state regulations are in force—likely would undermine the chances that EPA will approve the SIP submitted by DEC in January. If DEC’s SIP submission is not approved by EPA, the clock will start running on potential sanctions for Fairbanks, including stricter permit requirements for new major source, the loss of highway funds, and imposition of restrictions by EPA.

Note on Data Gap: In 2008, Mayor Jim Whitaker requested a time extension on the nonattainment boundary decision, insisting it was not “to delay addressing the problem,” but to resolve the “significant gaps” in the data used to set the nonattainment boundary. Link to source. (Whitaker is now chief of staff for Governor Bill Walker.) CAF encourages readers who are data driven to review the data used in 2008 to successfully press EPA to shrink the size of the nonattainment area. Link to ADEC nonattainment documents.

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North Pole’s extreme levels of air pollution will count, finally.

Beginning in 2015, data from this site (North Pole Fire) will be used for calculating the design value for the nonattainment area. While we will not have a precise design value until May 2015, the ADEC and the Borough will need to factor these data into their attainment planning efforts. EPA letter to CAF 11/19/2014

Beginning in 2015, FNSB PM2.5 nonattainment will be calculated from nearby North Pole, the area of expected maximum concentration, rather than downtown Fairbanks.

The 2011 to 2013 24-hour design value for Fairbanks was 45, fourth highest in the nation. Data source. 35 is the state and federal standard for PM2.5 24-hour average.

When finalized, the new 24-hour design value may be approximately three times higher than the old. The North Pole Fire monitoring station was established March 2012 (3288 Hurst Rd, 99705). The station’s 98th percentile for 2012 and 2013 was 158 and 122 µg/m3. For the first half of 2014, it was 156. Data source. North Pole may also exceed the annual PM2.5 standard of 12.

Source apportionment studies have identified over 80% of winter PM2.5 in North Pole is from wood smoke. 2012 study 81.2%, 2013 study 85.5%.

This change of the source of air monitoring data is essential for those who have to breathe the unhealthy air in North Pole and other neighborhoods with highly polluted air. Using the Fairbanks site to measure attainment, reaching attainment would be a relatively easy goal, and if this goal were reached, North Pole and other areas would still be highly polluted. By changing the measuring location to North Pole, attainment will not be reached until all Fairbanks and North Pole neighborhoods have cleaner air.

We look to local and state leaders to initiate emergency action to reduce PM2.5 emissions, accurately advise the public of current air conditions, and ensure public safety especially for sensitive populations including children and elders.

Prolonging air pollution is not a solution. Delay causes more medical harm including disability and premature death.

Design value is the three-year average of the 98th percentile value. An area is in violation of the NAAQS when the design value is greater than the 24-hour NAAQS for PM2.5, which is currently set at 35 µg/m3.

The annual standard for PM2.5, set by the NAAQS using a three-year average of annual concentrations, is currently 12 µg/m3.

98th Percentile is the daily value out of a year of PM2.5 monitoring data below which 98 percent of all daily values fall.

To protect health, Clean Air Act regulations require nonattainment to be calculated from “an area of expected maximum concentration.” 40 CFR §58 Appendix D 4.7.1(1).

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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

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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?


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

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