Archive for the ‘FNSB Air Quality Program’ Category

What you don’t know about Fairbanks’ air can hurt you.

When calling air alerts, the Borough considers only hourly PM2.5 measured at two monitors: the NCore at the FNSB Administration Building in downtown Fairbanks and the North Pole Fire Station on Hurst Road. Fairbanks monitors showing higher PM2.5 than downtown Fairbanks are ignored, then removed. In fact, every other PM2.5 monitor is ignored, regardless how high it reads.

When reporting air pollution to the public, FNSB and ADEC must stop cherry-picking monitor data to ignore neighborhoods with high PM2.5.

How can you speak up? Write an email:

  • Air agencies must stop ignoring Fairbanks monitors that have higher readings than the NCore monitor in downtown Fairbanks.
  • The Borough must stop removing monitors from Fairbanks and North Pole neighborhoods that show high PM2.5.
  • Tell them how air pollution has harmed you.

Send your email to:
FNSB Assembly assembly@co.fairbanks.ak.us
Mayor Karl Kassel mayor@fnsb.us
Kathleen Hook – APCC Chair khook@doyonutilities.com
Governor Bill Walker bill.walker@alaska.gov
Commissioner Larry Hartig – DEC larry.hartig@alaska.gov
Commissioner Valerie Davidson – DHSS davidson@alaska.gov
Commissioner Gary Folger – DPS gary.folger@alaska.gov
Administrator Dennis McLerran r10administrator-mclerran@epa.gov
Please send a copy to cleanairfairbanks@gmail.com

How does of ignoring monitors harm health in Fairbanks?

The NP Fire Station PM2.5 monitor frequently records levels categorized by EPA as “Unhealthy,” triggering numerous Stage 2 and Stage 3 burning requirements. From Jan 1 to Feb 11, 2016 for North Pole, agencies declared seven Stage 2 and eleven Stage 3 air alerts. When people know the air is polluted, they have a chance to take action.

During the same period for Fairbanks, agencies declared five Stage 2 and no Stage 3 air alerts. The NCore monitor at the Borough Admin Building in downtown Fairbanks uncommonly records elevated PM2.5 (mainly when North Pole Coffee Roasting Co discharges its putrid plume). Alerts are based on 24-hour averages, hiding higher hourly emission spikes.

What monitors should have been considered?

The Chena Pump monitor has recorded PM2.5 categorized as “Unhealthy for Sensitive Groups.” Monitors at Hamilton Acres and the Watershed School recorded Unhealthy but were removed by the Borough. The Dixon Road, North Pole monitor recorded PM2.5 higher than the NP Fire Station but was removed by the Borough.

How is my health harmed when monitors showing higher PM2.5 are ignored? 

When people don’t know their air is polluted, they have no chance to take change their behavior. When no Air Alert has been declared, residents don’t know schools and playgrounds may be unsafe or that breathing is life endangering. Athletic training and competitions are held not knowing high PM2.5 readings were ignored. Residents on the ridges or from out of town don’t know when the air is unsafe or when they need to stay away from Fairbanks. Solid fuel users keep burning because they don’t know health-based PM2.5 limits were exceeded.

Which agency ignores monitors?

Both. Borough Air Quality Forecast and ADEC Air Quality Advisories/ Episodes websites reflect data from only two monitors in the borough.

What are Stage 2 and Stage 3 heating device restrictions?

Stage 2: “Burning is permitted in all EPA-certified solid fuel burning appliances, and EPA Phase II qualified hydronic heaters with an annual average emission rating of 2.5 grams or less, masonry heaters, pellet fuel burning appliances, cook stoves, and fireplaces. No fuel source may be added to the combustions [sic] chamber or firebox of any solid fuel burning appliance or waste oil burning appliance not listed above.” Detailed description.

Stage 3: “No fuel source may be added to the combustions [sic] chamber or firebox of any solid fuel burning appliances, masonry heaters, pellet fuel burning appliances, cook stoves, fireplaces, or waste oil burning appliances.” Detailed description.

Are the agencies following the law?

No. A Stage 2 air alert is “implemented when concentrations exceed or are forecasted to exceed 35 µg/m3” and a Stage 3 air alert is “implemented when concentrations exceed or are forecasted to exceed 55 µg/m3” (FNSB Code 8.21.040 E).

When monitors show 24-hr concentrations over 30 µg/m3, 20% opacity limits, “shall be initiated at a 24-hour average concentration of 30 μg/m3 based on a 24-hr rolling average of the 1-hr BAM measurements” (SIP III.D.5.11-6). “BAM” monitors are the Borough’s real-time, hourly monitors. 20% opacity limits have never been publicized when 24-hr concentrations exceeded 30 µg/m3. (FNSB NOASH waivers do not apply to state opacity limits.)

Further, ADEC and FNSB “will declare” a PM-2.5 air quality advisory “if, in its judgment,” conditions exist that “might threaten public health” 18 AAC 50.246(b). PM2.5 threatens heath when 24-hr levels exceed 35.5 µg/m3, the Air Alert level set in the Alaska State Implementation Plan (SIP III.D.5.11-4).

It is not “judgment,” but bias, to call air alerts for North Pole while ignoring monitors with high PM2.5 in Fairbanks.

Which agency is at fault?

Both. The state delegated responsibility on area sources to the Borough (ADEC-FNSB MOU for Air Pollution Control 2010). Yet, both must follow the laws and regulations. The Clean Air Act “states that the SIP must provide necessary assurances that, where the State has relied on a local government for the implementation of any plan provision, the State has responsibility for ensuring adequate implementation of such plan provisions” (SIP III.D.5.12-1).



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Has FNSB issued its first air quality fine?

CAF will post the address when confirmation is received.

Map to Kellum Street near Raven Landing: https://goo.gl/maps/5nYYr3XfFF12
Fine may be $100 (violation of visible emissions standard, 1st offense) or $500 (emissions crossing property lines, 1st offense) depending on section of code was violated.

Fri, 02/05/2016 – 20:10 –mfussell NewsCenter 11

The Fairbanks North Star Borough is issuing its first citation for an air quality violation, nearly a year after a program to monitor pollution was put in place.

“It either just happened recently, or it will happen first thing tomorrow morning,” Jim Williams, the Chief of Staff for FNSB Mayor Karl Kassel, said at a Borough Assembly meeting Thursday.

Williams said the Kassel Administration reached out to the Kellum Street individual being cited at least ten times since October.

He adds Mayor Karl Kassel wanted to be the first to make the call to take action.

“[Kassel] will continue to make the decision on fines to make sure that property owner have every single opportunity to be heard,” Williams said. “That specific property owner didn’t want anything to do with the borough.”

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Visit links below for monitor PM2.5 data. Two monitors now online.

NM-1 CCA Neighborhood Monitor T24951 – Hamilton Acres, Fairbanks, AK  Start Date: 12/21/2015, Lat, Long: 64.846884 -147.678081

CCA Hamilton Acres Neighb Monitor

NM-2 CCA Neighborhood Monitor T24954 Borough Admin Center, Fairbanks, AK  Start date: 2/25/2016 (was collocated with NM-1 from 2/9 to 2/25/2016)

Monitors operated by: Citizens for Clean Air
Equipment: Met One Neighborhood Monitor

Help Citizens for Clean Air move as fast to purchase and install monitors in hot zones, by supporting the CCA Monitoring Project – click button below:

Donate button image

To donate by mail, send check to:
CCA Monitoring Project
607 Old Steese Hwy Ste B PMB 118
Fairbanks, AK 99701-3163
Please note on your check “Monitoring Project.”

Citizens for Clean Air is raising money to purchase monitors to improve PM2.5 pollution monitoring and protect health and safety. Donations are tax deductible to the extent allowed by law. Donors can give any amount. For more information, contact Patrice Lee: patricelee3294@gmail.com, 907-799-9580

Met One manufactures the BAM 1020, approved in 2008 as a Federal equivalent method by EPA. Thousands of BAM 1020 continuous PM2.5 monitors are in use, including at the US Embassy in Beijing and visible here: AQICN World. FNSB has five BAM 1020s online, see Real-Time Monitoring. The Met One Neighborhood Monitor is a new and inexpensive PM2.5 sensor that monitors PM2.5 at 15-minute increments and makes data available immediately on the “Cloud.”

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Please visit Citizens for Clean Air-No on Proposition 1 on Facebook:


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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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