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Archive for the ‘FNSB School District Regs’ Category

Graph - FNSB Logged AQ Complaints per Season 5-16-2011[Update: On Jan 3, 2012, Alaska DEC filed in court against the Straughns for nuisance smoke from their two outdoor wood boilers located across the street from Woodriver Elementary. Follow Case 4FA-13-01205CI on CourtView.]

Borough residents have reported over 500 public smoke pollution complaints since 2008. Yet, there is no record that any agency has ever verified a violation, prosecuted an emitter, or issued a fine for smoke pollution in the FNSB. In 2011, the Alaska Department of Environmental Conservation ordered two local emitters to abate smoke nuisances but has been unable to find a violation of either order. DEC can prosecute violations of AS 46.03, AS 46.14, regulations, and orders but has no statutory authority to write tickets for air pollution.

These are the only nuisance abatement orders ever issued in the Fairbanks area:

Woodriver Elementary School [public record]
DEC Nuisance Abatement Order [enforceable] March 10, 2011 for 58 Trinidad Dr & 5055 Palo Verde Ave, Fairbanks [97KB]
DEC Compliance Letter [unenforceable] April 13, 2009 for 58 Trinidad Dr & 5055 Palo Verde Ave, Fairbanks [47KB]

Steese Highway and Farmer’s Loop [public record]
DEC Nuisance Abatement Order [enforceable] Jan. 26, 2011 for 150 Farmer’s Loop Extension, Fairbanks [42KB]

Following are links to laws, regulations, codes, and policies that could help reduce smoke pollution in Fairbanks and North Pole, Alaska. Emphasis added.

United States

Clean Air Act, as amended 1990
Particulate Matter Standards, Federal standards for PM 2.5 [adopted into state regulation 18 AAC 50.010(B)]
PM 2.5 NAAQS Implementation
EPA PM 2.5 Nonattainment Designation Dec. 2009 for Fairbanks Area
Alaska Governor’s recommendation for designation, Dec. 2007 and supplemental information
Federal Register notice of Fairbanks area PM 2.5 nonattainment designation, effective Dec. 14, 2009, Table 1, p 58696
Federal Register notice of Revisions to Ambient Air Monitoring Regulations, effective December 18, 2006
Network Design Criteria for Ambient Air Quality Monitoring – 40 CFR 58, Appendix D to Part 58 4.7.1(b)(1): “At least one monitoring station is to be sited in a population-oriented area of expected maximum concentration.”

Attainment schedule for Fairbanks area PM 2.5:

Dec 14, 2012 – State Implementation Plan due
Dec 14, 2014 – PM 2.5 attainment deadline
Dec 14, 2019 – final deadline (after all possible extensions)

State of Alaska

State regulation 18 AAC 50.110. Air pollution prohibited:

No person may permit any emission which is injurious to human health or welfare, animal or plant life, or property, or which would unreasonably interfere with the enjoyment of life or property. Eff. 5/26/72

State regulation 18 AAC 50.045. Prohibitions:

(b) A person who owns or operates a stationary source that emits an air pollutant subject to this chapter shall ensure that the stationary source complies with this chapter and any other applicable local, state, or federal law.
(c) A person may not construct, operate, or modify a stationary source that will result in a violation of the applicable emission standards or that will interfere with the attainment or maintenance of ambient air quality standards.

State regulation 18 AAC 50.075. Wood-fired heating device visible emission standards:

(a) A person may not operate a wood-fired heating device in a manner that causes
(1) black smoke; or
(2) visible emissions that exceed 50 percent opacity for more than 15 minutes in any one hour in an area which an air quality advisory is in effect under 18 AAC 50.245.

Testing procedures [6KB] from Alaska Air Quality Control Plan Volume III, Section IV-3, 1983:

Visible emissions of exhaust gases from wood-fired heating devices shall be observed at the point of release to the ambient air regardless of the presence of condensed water vapor. All other conditions specified in Method 9 of Appendix A to 40 CFR 60 shall apply.

State regulation 18 AAC 50.055. Industrial processes and fuel-burning equipment:

(a) Visible emissions, excluding condensed water vapor, from an industrial process or fuel-burning equipment may not reduce visibility through the exhaust effluent by
(1) more than 20 percent averaged over any six consecutive minutes, except as provided in (2) – (9) of this subsection; [applies to waste oil burner]
(9) more than 20 percent for more than three minutes in any one hour for a coal burning boiler…. [Allows three more minutes if coal boiler has DEC operating permit, began operation before August 17, 1971, etc.]

State regulation 18 AAC 50.065. Open burning:

(a) General Requirements. Except when conducting open burning under (g), (h), or (i) of this section, a person conducting open burning shall comply with the limitations of (b) – (f) of this section and shall ensure that

(1) the material is kept as dry as possible through the use of a cover or dry storage;
(2) before igniting the burn, noncombustibles are separated to the greatest extent practicable;
(3) natural or artificially induced draft is present;
(4) to the greatest extent practicable, combustibles are separated from grass or peat layer; and
(5) combustibles are not allowed to smolder.

(b)  Black Smoke Prohibited. Except for firefighter training conducted under (h) or (i) of this section, open burning of asphalts, rubber products, plastics, tars, oils, oily wastes, contaminated oil cleanup materials, or other materials in a way that gives off black smoke is prohibited without written department approval. …

(2) the person who conducts open burning shall establish reasonable procedures to minimize adverse environmental effects and limit the amount of smoke generated; and

(c) Toxic and Acid Gases and Particulate Matter Prohibited. Open burning or incineration of pesticides, halogenated organic compounds, cyanic compounds, or polyurethane products in a way that gives off toxic or acidic gases or particulate matter is prohibited.
d) Adverse Effects Prohibited. Open burning of putrescible garbage, animal carcasses, or petroleum-based materials, including materials contaminated with petroleum or petroleum derivatives, is prohibited if it causes odor or black smoke that has an adverse effect on nearby persons or property.
(e) Air Quality Advisory. Open burning is prohibited in an area if the department declares an air quality advisory under 18 AAC 50.245, stating that burning is not permitted in that area for that day. This advisory will be based on a determination that there is or is likely to be inadequate air ventilation to maintain the standards set by 18 AAC 50.010. The department will make reasonable efforts to ensure that the advisory is broadcast on local radio or television.
(f) Wood Smoke Control Areas. Open burning is prohibited between November 1 and March 31 in a wood smoke control area identified in 18 AAC 50.025(b). [Mendenhall Valley area of Juneau is only area so designated.]

State law AS 09.10.070 Actions for torts, for injury to personal property, for certain statutory liabilities, and against peace officers and coroners to be brought in two years.

(a) Except as otherwise provided by law, a person may not bring an action (1) for libel, slander, assault, battery, seduction, or false imprisonment, (2) for personal injury or death, or injury to the rights of another not arising on contract and not specifically provided otherwise; (3) for taking, detaining, or injuring personal property, including an action for its specific recovery; (4) upon a statute for a forfeiture or penalty to the state; or (5) upon a liability created by statute, other than a penalty or forfeiture; unless the action is commenced within two years of the accrual of the cause of action.

State law AS 44.62.250.  Emergency regulations.

A regulation or order of repeal may be adopted as an emergency regulation or order of repeal if a state agency makes a written finding, including a statement of the facts that constitute the emergency, that the adoption of the regulation or order of repeal is necessary for the immediate preservation of the public peace, health, safety, or general welfare. The requirements of AS 44.62.040(c), 44.62.060, and 44.62.190 – 44.62.215 do not apply to the initial adoption of emergency regulations; however, upon adoption of an emergency regulation the adopting agency shall immediately submit a copy of it to the lieutenant governor for filing and for publication in the Alaska Administrative Register, and within five days after filing by the lieutenant governor the agency shall give notice of the adoption in accordance with AS 44.62.190(a). Failure to give the required notice by the end of the 10th day automatically repeals the regulation.

State law AS 46.03.710. Pollution Prohibited:

A person may not pollute or add to the pollution of the air, land, subsurface land, or water of the state.

State law AS 46.03.790. Criminal penalties:

(a) Except as provided in (d) of this section, a person is guilty of a class A misdemeanor if the person with criminal negligence
(1) violates a provision of this chapter, AS 46.04, AS 46.09, or AS 46.14, a regulation or order of the department, or a permit, approval, or acceptance, or a term or condition of a permit, approval, or acceptance issued under this chapter, AS 46.04, AS 46.09, or AS 46.14;
(c) Each day on which a violation described in this section occurs is considered a separate violation.

State law AS 12.55.035. Fines:

(a) Upon conviction of an offense, a defendant may be sentenced to pay a fine as authorized in this section or as otherwise authorized by law.
(b) Upon conviction of an offense, a defendant who is not an organization may be sentenced to pay, unless otherwise specified in the provision of law defining the offense, a fine of no more than

(5) $10,000 for a class A misdemeanor;

State law AS 46.03.810. Air and land nuisances:

(a) A person is guilty of creating or maintaining a nuisance if the person

(1) places or deposits upon a lot, street, beach, or premises, or upon or anywhere within 200 feet of a public highway, any garbage, offal, dead animals, or any other matter or thing that would be obnoxious or cause the spread of disease or in any way endanger the health of the community;
(2) allows to be placed or deposited upon any premises owned by the person or under the person’s control garbage, offal, dead animals, or any other matter or thing that would be obnoxious or offensive to the public or that would produce, aggravate, or cause the spread of disease or in any way endanger the health of the community.

(b) A person who neglects or refuses to abate the nuisance upon order of an officer of the Department of Environmental Conservation is guilty of a misdemeanor and is punishable as provided in AS 46.03.790. In addition to this punishment, the court shall assess damages against the defendant for the expenses of abating the nuisance.

State law AS 46.03.820. Emergency powers:

(a) When the department finds, after investigation, that a person is causing, engaging in, or maintaining a condition or activity that, in the judgment of its commissioner presents an imminent or present danger to the health or welfare of the people of the state or would result in or be likely to result in irreversible or irreparable damage to the natural resources or environment, and it appears to be prejudicial to the interests of the people of the state to delay action until an opportunity for a hearing can be provided, the department may, without prior hearing, order that person by notice to discontinue, abate, or alleviate the condition or activity. The proscribed condition or activity shall be immediately discontinued, abated, or alleviated.

State law AS 46.14.410. Inadequacy of local program:

(a) If a municipality or a local air quality district has an approved local air quality control program under AS 46.14.400 and the department determines that the program is being implemented in a manner that fails to meet the terms of the cooperative agreement or is otherwise being inappropriately administered, the department shall give written notice setting out its determination to the municipality or local air quality district. Within 45 days after giving written notice, the department shall conduct a public hearing on the matter. The hearing shall be recorded by any means that ensures an accurate record.

Cooperative Agreement, ADEC and FNSB MOU for Air Pollution Control, Jan. 22, 2010:

IV.  Area Source Control Programs
The Borough and DEC recognize that many small stationary pollution emission sources have the potential to collectively impact air quality. These small sources are categorized as area sources by EPA and DEC and may be regulated by local, state, or federal rules, but are not typically permitted by the DEC Air Permit program. They include, but are not limited to, the following types of sources: solid fuel-fired heating devices, commercial and residential space heating, small sources that fall below permitting thresholds, and fugitive dust sources. The Borough will take the lead in developing and implementing local control programs to address pollution from area sources…. [page 2]
V.  Complaint Response
As indicated above [see image in MOU], both DEC and the Borough will be responsible for assessing whether or not an air quality complaint received by the respective agency is a violation of either Borough or State regulations. Once it is determined whether or not either, or both, State or Borough regulations are being violated, or have been violated, the appropriate agency will take the lead role in enforcement action.
VII.  Air Quality Planning
The Borough will:
Implement PM 2.5 strategies to attain the standard that are shown to be reasonable and cost effective;
Take the lead in collaboratively developing with DEC a PM 2.5 attainment plan to bring Fairbanks into attainment with the national ambient air quality standard.

Fairbanks North Star Borough

Prohibited acts and requirements of Chapter 8.21 repealed by Assembly vote following voter approval of Proposition 3 October 2, 2012.
Air Pollution Chapter 8.04, the entire open burning section, was repealed by Assembly vote 1/24/2013, citing Prop 3.

Borough Chapter 8.21.030 Voluntary replacement and repair program. [see full chapter]

Borough Powers Chapter 1.02:

1.02.040 Conferred areawide powers.
A. The borough by ordinance exercises the following powers on an areawide basis:
3. Provides air pollution control in accordance with AS 46.03, May 14, 1970.

1.02.060 Conferred nonareawide powers.
B. The borough may by ordinance exercise the following powers on a nonareawide basis:
4. Provide air pollution control in accordance with AS 46.03;

Borough Chapter 2.48.120 Powers and duties [of the Air Pollution Control Commission]:

D. The commission shall review proposed revisions of regulations or other criteria related to the air quality program and make recommendations to the administration. The commission shall hold public hearings for the purpose of receiving testimony.
E. On request of the borough mayor, the commission may fully investigate nuisances, health hazards and other harmful effects related to or caused by air pollution.
F. The commission shall develop comprehensive plans for the prevention, abatement, and control of air pollution in the borough. Such plans may include recommendations on subjects including, but not limited to, transportation control measures, zoning, taxation, research, and public relations.
G. The commission shall act as a hearing board on appeals on matters relating to the air quality program.

Borough Chapter 2.52.010 Pollution control officer [see Ordinance Footnote, below]:

The director of the department of environmental services, or such other person as the mayor shall designate, shall perform the duties of the pollution control officer. The officer shall be directly responsible to the borough mayor for the implementation of policies and programs instituted pursuant to law for the control of air and solid waste pollution and disposal within the borough.
Ordinance Footnote:
For statutory provisions authorizing municipalities to regulate air pollution control, see AS 29.35 [likely AS 29.35.055]; for provisions setting minimum standards for borough air pollution control programs, see AS 46.03. [more likely AS 46.14.400-410]

Borough Chapter 2.52.020 Responsibilities:

A. The officer shall have the responsibility of investigation to further the purposes specified above, including but not limited to the following:
1. Investigation of citizen complaints;
2. Such investigation as the pollution control commission or borough mayor may direct; and
3. Authority to inspect equipment, structures, and operations and to make measurements on private property at reasonable hours and with proper notice to the occupant of the premises.
B. The officer shall conduct such surveys and research as is necessary to assist the pollution control commission in the drafting of regulations and ordinances.
C. The officer shall to the extent practicable encourage the voluntary cooperation by persons and affected groups to achieve the purposes specified above, or regulations pursuant thereto.
D. The officer has the authority to issue citations to alleged violators of sections of this code relating to control of air and solid waste pollution and disposal, requiring the alleged violators to appear in a court of law.
E. All zoning changes within the borough shall be brought to the attention of the officer by the borough planning director prior to the time notice is given for any public planning commission hearing. If the officer feels that the proposed zoning change will affect the air quality of the borough, he shall issue a report to the planning commission and pollution control commission. The report may recommend approval, modification or disapproval of the proposed zoning change in the interest of maintaining or enhancing the air quality of the borough.
F. The officer shall seek voluntary cooperation of citizens, but has the authority to secure judicial search warrants for conducting routine or area inspection with regard to air pollution of any particular place, dwelling, structure, premises, or vehicle.

Fairbanks North Star Borough School District:

Guidelines for Student Activities in Adverse Conditions [Admin Reg 945] and Outside Elementary Recess [Policy 946] [173KB]

City of Fairbanks

Fairbanks City Code Article VI 34-201 & 34-202 Hydronic heaters:

No hydronic heater may be installed inside the City of Fairbanks after June 8, 2009, without a permit issued by the City of Fairbanks. No permit shall be issued until standards are adopted by the Fairbanks City Council.

Fairbanks Municipal Code Article IV 34-106 Report of pollution conditions:

When the city engineer shall find facilities for disposal of sewage, wastewater or other liquids, or waste gases on premises within the city which do not comply with section 10-136, adoption of the Uniform Plumbing Code, or a failure to use facilities that contaminate or pollute or tend to contaminate or pollute the air, a flowing stream, a standing body of water, groundwater, or the ground to such an extent as to endanger human life or health, a report of such findings shall be made for the files of the state department of environmental conservation and copies of said report shall be distributed to the mayor.

City of North Pole

North Pole Municipal Code 8.04 Nuisances:

8.04.060 Dense Smoke.
It is unlawful for any person to permit the emission of any smoke from any source whatever of a density equal to or greater than that density described as No. 2 on the Ringlemann Chart, published by the United States Bureau of Mines. The emission of such smoke is declared to be a public nuisance and may be summarily abated as provided in this chapter. (Prior code §12-9)

8.04.070 Soot, cinders, noxious acids, fumes and gases.
It is unlawful for any person to permit or cause to escape any soot, cinders, noxious acids, fumes or gases in such place or manner as to be detrimental to any person or to the public or to endanger the health, comfort and safety of any such person or the public, or in such a manner as to cause or have a tendency to cause injury or damage to property or business. The escape of such matter is declared to be a public nuisance, and may be summarily abated as provided in this chapter. (Prior code §12-10)

North Pole Municipal Code 12.24.210 Violations Deemed A Public Nuisance:

A. In addition to the enforcement processes and penalties provided, any condition caused or permitted to exist in violation of any of the provisions of this Ordinance is a threat to public health, safety, and welfare, and is declared and deemed a nuisance, and may be summarily abated or restored at the violator’s expense, and/or a civil action to abate may be taken to enjoin or otherwise compel the cessation of such nuisance.
B. It is the duty of the mayor or his designee receiving information or obtaining knowledge of the existence of anything or things declared to be nuisances in this chapter to notify the person committing, creating, keeping or maintaining the same to remove or cause the same to be removed within twenty-four hours, or such other reasonable times may be determined by the city official after such notice has been duly given; and if the same is not removed by such person within the time prescribed in the notice, it shall be the duty of the mayor or his designee to remove or cause to be removed such nuisance or nuisances and all costs and expenses of such removal shall be paid by the persons committing, creating, keeping or maintaining such nuisance or nuisances. A person violating the provisions of this chapter may be punished by a fine of not more than $200 (two hundred dollars) per violation in addition to any costs and expenses for removal of the nuisance.

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Dermot Cole published on his FDNM blog, Neighborhood maps show elevated pollution near schools 3/10/2011.
 
Here’s the full message Clean Air Fairbanks sent to principals of the schools in the mapped neighborhoods.
———-forwarded message ———-
From: Clean Air Fairbanks <cleanairfairbanks@gmail.com>
Date: Thu, Mar 10, 2011 at 1:32 PM
Subject: Schools in or near PM 2.5 concentrations
To: Brian Powell – Nordale Principal <matthew.powell@k12northstar.org>, rosita.wilburn@k12northstar.org, Rich Smith – NP Middle Principal <richard.smith@k12northstar.org>, Bridget Lewis – NP High Principal <bridget.lewis@k12northstar.org>, “\”Michael Angaiak – Ticasuk Brown Principal” <michael.angaiak@k12northstar.org>, Dan File – Badger Road Principal <dan.file@k12northstar.org>, Annie Keep-Barnes – Star of the North Principal <annie.keep_barnes@k12northstar.org>, Jeff Mann – Woodriver Principal <jeffrey.mann@k12northstar.org>, John Carlson – Watershed Charter Principal <johncarlson@gci.net>
Cc: Superintendent Pete Lewis <pete.lewis@k12northstar.org>, sharon.tuttle@k12northstar.org, Bill Bailey – School District <bill.bailey@k12northstar.org>, Dr Jim Conner – FNSB Air Quality Specialist <jconner@fnsb.us>
Dear Principals,
 
In case you haven’t seen the map of your school and fine particulate pollution in that area, please visit the following links: 
 
 
 
 
This is not a complete set of maps for our community.
 
If you have questions, contact Dr Jim Conner – FNSB Air Quality Specialist <jconner@fnsb.us> 459-1325, Cassie Kirk – Div of Public Health Epidemiology <cassandra.kirk@alaska.gov> 907-269-6560, or Maureen Kauleinamoku – School District Nurse Coordinator maureen.kauleinamoku@k12northstar.org 452-2000 x 253.
 
Even with the arrival of spring, please take precautions to determine the safety air quality during recess and athletic practices and competitions.
 
The School District Administrative Regulation on Adverse Air 960.1, page 35, appears not to have been revised to account for the unavailability of 1-hour PM 2.5 pollution concentrations for the whole area or for most of your schools. Only 24-hour levels from the downtown monitor are posted: Air Quality Index. Real-time hourly monitoring may be available on-line at Live Air Quality Data — FNSB AQ Monitoring from the North Pole Elementary and may also be useful to evaluate PM 2.5 concentrations at nearby NP Middle and NP High. It may be possible to request the Borough bring the instrumented “sniffer” vehicle to your school or assess indoor air conditions with a handheld device. The downtown monitor does not reflect emissions from sources near your schools. Sub-daily peak exposures are more strongly associated with health impacts than 24-hour averages. For 1-hour and 24-hour average exposure cautionary statements from EPA, review: Judging Particulate Levels in Your Area.
 
The recent installation of the filtration system at Woodriver appears not to have been effective at keeping concentrated smoke from affecting the health of employees inside the school. See: Woodriver Smoked Out Again, March 9, 2011. This morning I received another report about smoke inside the Woodriver.
 
To protect children, especially children with health conditions including bronchitis, asthma, or heart conditions, it is vital to assess air quality inside and outside your school and consult with a health professional about appropriate precautions. I recommend Ms. Kirk or Ms. Kauleinamoku. All children are extremely vulnerable as their lungs are still developing and can be permanently harmed by air pollution. Children with health conditions are at special risk.
  
https://cleanairfairbanks.wordpress.com
 
“If our children are in danger, the future of our community is at risk.” 
 
 

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Update: Hourly PM 2.5 monitoring reports from the Fairbanks North Star Borough for North Pole are now viewable online. Read the post: “New Hourly AQ Reports Show Santa in Smoke Trouble.”

Newly revised School District regulation 960.1 allows healthy children to play outside at recess until particulate levels reach 176 micrograms per cubic meter. This “guideline” appears to be based on one-hour particulate levels. However, one-hour levels are not currently available to parents, nurses, principals, or even the Superintendent.

The revised regulation lowers the guideline from 200 micrograms per cubic meter to 176. For the previous version and chart of the regulations, view Clean Air Fairbanks’ earlier post on School District Regs on Unhealthy Particulate Levels. Progress, true, but not nearly enough for our children.

The only PM 2.5 numbers available for principals and school nurses are 24-hour averages. They are the same numbers available to you: FNSB’s Air Quality Index. During episodes of air quality concern, this site is updated by the Borough once a day on weekdays only.

If principals wait to see 176 micrograms before cancelling outdoor recess or athletic activities based on the only numbers available, these 24-hour levels, children may be exercising vigorously until AQI concentrations reach VERY UNHEALTHY. This is especially dangerous if no special regard is taken to protect children with health conditions such as bronchitis, asthma, or heart problems.

View Judging Particulate Levels in Your Area to better understand the levels, categories, and cautionary statements.

Contact the School Board to request regulation 960.1 be revised again to:

  1. Use the 24-hour column, not the 1-hr column, as it is the only number available,
  2. Initiate action to protect healthy children at UNHEALTHY FOR SENSITIVE GROUPS levels (35.5-55.4 µg) not waiting until UNHEALTHY (55.5-150.4 µg) or VERY UNHEALTHY (150.5-250.4 µg), and
  3. To protect health-compromised children, consider extra precautions at MODERATE levels (15.5-35.4 µg).

Contact your School District members & the Superintendent:

If you prefer, ask Sharon Tuttle, Executive Assistant to the Superintendent, to forward your message to the School Board sharon.tuttle@k12northstar.org 452-2000 x 401

Background:

School District regulations cannot advise waiting to cancel recess, athletic practice, or athletic competitions until levels are VERY UNHEALTHY. Healthy children are considered members of the “sensitive groups” category. To provide adequate protection for healthy children, precautions need to be taken at UNHEALTHY FOR SENSITIVE GROUPS particulate levels, or lower. Children with health conditions such as bronchitis, asthma, or heart problems are considered “unusually sensitive” to PM 2.5 pollution and may need extra precautions even at MODERATE particulate levels.

Listen to KUAC’s radio news story 12/14/2010 on the School District’s decision to revise the guidelines from 200 to 176 micrograms/cubic meter and the district’s challenge to ensure indoor air is clean.

The FDNM covered the same decision, overlooking that 1-hour PM 2.5 levels are unavailable, “Fairbanks school district tightens air quality restrictions for recess, practices” 12/15/2010.

Many, many people do not understand the need to protect themselves from high particulate levels. Clean Air Fairbanks observed a team of young runners from UAF, wearing reflective vests for safety, yet exercising in unhealthy, smoke-choked air. Principals, school nurses, and coaches aren’t trained or prepared in any way to make informed decisions on how to best protect individuals under their responsibility from elevated PM 2.5. These are the individuals we’re counting on to protect our children.

When PM 2.5 levels are high, children are often kept in from recess because of the cold so indoor air may be the greater concern. During inside recess children typically run around inside the school building. Yet, we’ve seen no data to show indoor air is any cleaner than outside air on days with high PM 2.5. Typical ventilation systems exchange inside “dirty” air for “cleaner” outside air. During PM 2.5 pollution events, those ventilation systems draw particulates into the school bldg and spread it throughout halls, classrooms, and gyms, just as has happened in smoke-impacted homes across the borough.

Recess and outside athletic activities promote physical and social development and are linked to academic success. Clearly, air quality data relevant to each school would empower principals to make informed decisions for our children.

Yet, cost estimates have not been made available for 1) installing monitors near schools to collect 1-hour particulate levels, 2) updating reporting of Borough data so real-time reports are available to principals and the public, 3) conducting an indoor air sampling study at district schools during UNHEALTHY FOR SENSITIVE GROUPS particulate levels, or 4) if justified by the indoor air quality study or other data, installing indoor air filtration at about 30 district schools.

Controlling PM 2.5 pollution at its source is necessary for the future of our community and cost-effective. A handful of smoky OWBs and coal burners in one neighborhood may result in millions of dollars in additional health care expenses, absentee days from work or school, lower property values, indoor air filtration, etc. And that is for just one school. Our School District has 7,000 students under its care. Controlling PM 2.5 pollution is every resident and taxpayer’s concern and needs to be addressed at every level, from the individual on up.

When our children are in danger, the future of our community is at risk.

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In Fairbanks on Dec. 2, 2010 at  the downtown monitor (675 7th Ave), the 24-hour average for PM 2.5 pollution reached a high for the winter of 60.7 micrograms per cubic meter, code red UNHEALTHY. The next day, the 24-hour average dropped to 28.5 micrograms, making the Air Quality Index code yellow MODERATE and meeting the state and federal 24-hr average standard of 35 micrograms. For the current update, view the FNSB’s Air Quality Index.

To assist in evaluating the meaning of the numbers and your risk, see Judging Particulate Levels in Your Area. The air quality index levels and categories were established by EPA to protect public health. The Borough is required to provide these reports on a daily basis. View this report on Guidelines for Reporting of Daily Air Quality prepared by EPA in 2006. To convert 24-hr microgram concentration into the category, color code, and overall AQI level, use the AIRNow calculator: concentration to AQI. Knowledge is power.

Every child is included in the “SENSITIVE GROUPS” category. Children with heart or lung conditions are “unusually sensitive” to PM 2.5 pollution and may need extra precautions even at MODERATE particulate levels.

Local Air quality was UNHEALTHY on Dec. 2, 2010. Clean Air Fairbanks was informed of one child tearing up as she was going into school because of the smoke in front of her elementary school on 12/2/2010. Why are we allowing smoke to break the Golden Heart of Fairbanks? The FDNM published this article on the UNHEALTHY category alert, “Inversion spurs air quality alert for Fairbanks” 12/2/2010. The borough asked residents to voluntarily cease wood and coal burning, yet this request was not widely disseminated on other media sources such as by radio.

The AQI is measured at the downtown BAM site and has been recorded as GOOD at times when neighborhood air quality was HAZARDOUS. Air quality may be much worse than the downtown site if one or more wood or coal acute smoke sources are nearby.

Newly revised School District regulation 960.1 allows healthy children to play outside at recess until particulate levels reach 176 micrograms/cubic meter. If this “guideline” is based on 24-hour particulate levels, it is much too high. If it is based on one-hour particulate levels, those measurements are not currently available to parents, nurses, principals, or even the Superintendent.

Listen to KUAC’s radio news story 12/14/2010 on the School District’s decision to revise the guidelines from 200 to 176 micrograms/cubic meter and the district’s challenge to ensure indoor air is clean.

The FDNM covered the same story, also neglecting to notice that if principals wait for 176 micrograms to take action based on the only numbers available, 24-hr averages, children may be playing outside until concentrations reach VERY UNHEALTHY.  Read the article, “Fairbanks school district tightens air quality restrictions for recess, practices” 12/15/2010. View Judging Particulate Levels in Your Area to better understand the levels, categories, and cautionary statements.
 
How can school nurses and principals know the air quality near schools to determine whether any child, especially health-compromised children, should play outside at recess or compete inside at athletic events? How can our children be protected when information needed to gauge exposure levels is not even available?

When our children are in danger, our community’s future is at risk.

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On behalf of students and staff at Randy Smith Middle, Watershed Charter, Woodriver Elementary, and throughout the district, 10 parents testified to the FNSB School Board Tuesday, 10/19/2010 to request action to protect children and staff in district schools. They supported improving air filtration inside the schools and requested help in urging Alaska DEC to enforce existing regulations against violators of 18 AAC 50.110.

Read Dermot Cole’s FDNM: “Parents ask school board to address air pollution at Woodriver” 10/19/2010.

Listen to the audio of the 10/19/2010 testimony to the school board. (Testimony begins 11:40 into the recording.) 

Five of the parents described impacts that smoke had caused themselves, their children, or both. A School District employee at Woodriver testified seeing smoke in the halls 1 to 3 days a week &  about her son’s chronic bronchitis infections. As part of her job, she is required to accompany the children on bus and recess duty and related the complaints from the children about the smoke. She described her own health ordeal, including the loss of hearing in one ear due to a chronic sinus infection, likely need for surgery, and low blood oxygen levels  which Dr (Richard) Raugust had diagnosed as belonging to those of a smoker. But the district employee explained, she’s an aerobic instructor & never smoked, just breathed the air at work.

A mother of a son with asthma at Woodriver spoke about how important recess is to every child’s social and learning development but expressed dismay that her son often couldn’t be allowed to go outside with the other kids due to smoke in the playground. She wanted the air quality to be safe and healthy at school, inside and out.

A North Pole father with two young boys said he may have to move in order to prevent further attacks of severe bronchitis like his sons both had last winter. He installed filters in his own home “as they should in the schools” and asked the district to “force the state to move on it.” He said current school MERV 3 filtration needed to be raised to HEPA.

The mother of a 9-year-old daughter at Woodriver made careful note of the fact that children are especially sensitive to air pollution and urged the district to be “proactive” and have the air monitored inside the schools.

Jerry Norum, former school district teacher, Assembly member, and City Council member, thanked the school board for their interest in the issue. He reminded them the district is the tenant of the borough buildings. He said, “The winds have changed direction. And I won’t say we’re in a state of confusion; its a state of reassessment.” Mr. Norum described his own bout of breathing difficulties caused by local air pollution. He said fixing the problem “takes breaking the inertia.”

A local nurse and mother of two children with reactive airway issues urged the school board to actively track lung problems, educate students about air pollution causes & effects, and highlighted that resources are available to help nonattainment areas. She supported better air filtration for the schools if an assessment showed it would effectively control the smoke pollution. She answered a question about Randy Smith, saying that it too has problems.

A Watershed mother held up a visual representation showing relative scale of emissions from an outdoor wood boiler (OWB) vs other sources of residential heating. She testified that OWBs emit 72 grams per hour of particle pollution. She also testified that she’d reviewed air quality data collected at Watershed using the RAMs trailer which showed 48% of the days measured were above EPA’s catagory of “unhealthy for sensitive groups” and that 65% of the winter days measured at the downtown station were “unhealthy for sensitive groups.” She asked the school board to recognize that all children are in the “sensitive groups” category. She referred to the FMH retroactive public health study 8/2010 showing significant increased rates of hospitalization during episodes of higher pollution in the community.



After the testimony, school board members questioned Superintendent Pete Lewis, new to town and the district this year. Superintendent Lewis agreed to get back to the board with proposals.

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Update to Post – School district improved guidelines 11/2010, but not nearly enough protection for children: Newly revised School District regulation 960.1 allows healthy children to play outside at recess until particulate levels reach 176 micrograms/cubic meter. If this “guideline” is based on 24-hour particulate levels, it is much too high. If it is based on one-hour particulate levels, those measurements are not currently available to parents, nurses, principals, or even the Superintendent.

Listen to KUAC’s radio news story 12/14/2010 on the School District’s decision to revise the guidelines from 200 to 176 micrograms/cubic meter and the district’s challenge to ensure indoor air is clean.

960.1 was updated 11/2010, noted above. FNSB School District has regulations and guidelines for activities during unhealthy particulate levels, called Administrative Regulations 960.1 Guidelines for Student Activity in Adverse Conditions. These regulations are as follows:

A. Air Quality

1. The health and safety of students must be considered when particulate levels reach unhealthy levels due to smoke and forest fires, vehicle emissions, or volcanic eruptions. The school district shall rely upon the Fairbanks North Star Borough (FNSB) Air Quality Program standards to guide decision-making.

2. Guidelines for Activities in Adverse Air Quality Conditions

Particulate Levels Elementary Recess or Other Outdoor Activity Athletic Practices Athletic Competitions
a. 100-199 micrograms per cubic meter Reduce prolonged or heavy exertion Be aware of potential health dangers. Allow extra recovery time for athletes. Have extra water available. Have cell phone available. Be aware of potential health dangers. Allow extra recovery time for athletes. Have extra water available. Have cell phone available.
b. 200-300 micrograms per cubic meter Move indoors. Move all practices indoors. Student athletes with asthma or other respiratory disorders should be informed and have medications available. Allowed outdoors with extra precautions. Student athletes with asthma or other respiratory disorders should be informed and have medications available.
c. Above 300 micrograms per cubic meter Cancel or move indoors. Postpone or cancel. Postpone Postpone or cancel.

3. The district will consult with FNSB Air Quality personnel and make decisions concerning competitions scheduled for Friday by 9:00 p.m. on Wednesday night and by 9:00 p.m. on Thursday evening for competitions scheduled on the weekend.

4. Principals and activity coordinators will be notified via fax and email if the air quality warrants cancellation of recess, field trips, athletic practices or competitions, or other outdoor activities.

Please notice the particulate levels which trigger School District action: 100 to 199 micrograms/cubic meter of air. The FNSB Air Quality Index and especially Judging Particulate Levels in Your Area chart may be used to compare to the guidelines with recommendations for the various groups. It is not clear whether the school district guidelines chart refers to one hour PM 2.5 levels, 24-hour levels, or EPA’s Air Quality Index Values. (Convert PM 2.5 pollution concentration to AIQ values at AIRNow.) With the most lenient average (one hour particulate levels), 100 micrograms/cubic meter falls within the “Unhealthy for Sensitive Groups” category, which includes all children. If the 24-hour levels are used, 100 micrograms/cubic meter falls within the “Unhealthy” category.

Questions Parents and Grandparents Want Answered:

  1. Are these guidelines sufficient to protect children? Every healthy child is included in the “sensitive groups” category. Children with lung problems, such as asthma, or heart problems are at even greater risk from PM 2.5.
  2. According to the Air Quality Index chart, the “Unhealthy for Sensitive Groups” category starts at 35.5 micrograms/cubic meter of air. Why are children being let out to recess at higher levels?
  3. Recess and exercise are vital for child development and learning. What can be done to safeguard recess so children can exercise without risking permanent damage?
  4. According to Jim Conner, FNSB Air Quality Specialist, air quality at the schools “can be as bad inside as out.” Canceling outdoor recess in favor of indoor recess, if in smoke-filled gyms or halls, is not sufficient. What is being done to safeguard students & staff inside the school building?
  5. Would the School District conduct a feasibility study for installing HEPA filtration for schools where ambient levels of outdoor PM 2.5 pollution are in excess of 35.5 micrograms/cubic meter of air?
  6. The School District collects forms from students who require an inhaler to control their asthma. How many students at each school have submitted these forms and has this number grown over the past 4 years?
  7. Why are our children being allowed to be exposed to particulates at such high levels? Many studies show that children are more susceptible to elevated particulate levels because they breathe more air per body weight than adults, they tend to be active, they mouth-breathe when active (i.e., crying), and their lungs are still developing. An additional concern is that their immune and brain defenses are not fully formed. Dr. Lori Verbrugge, Alaska Division of Public Health, cited over 20 separate studies that consistently showed a 6–17% increase in relative mortality with each 10 μg/m3 of long-term particulate exposure. Dr. Verbrugge said the available data showed there is increased mortality with short-term exposure to PM 2.5 concentrations that are less than 20 μg/m3, which is considerably below the “health-based” 24-hour standard of 35 μg/m3. [Don’t miss the full summary of the FNSB symposium presentation by Dr. Verbrugge, 2009]

 

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