notice of public hearing. part one of two.

["Dena Marchant" <dena@aha.com>]

Visionaries,

I was asked to forward this to this list:

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Rationale for lower action level
For the Idaho Department of Environmental Quality
Rules Hearing

Urgent notification of public hearing:
May 8 Coeur d'Alene 6:30 p.m. for location contact 208-769-1422 Regional
office
May 9 Lewiston Red Lion Hotel (Port #3)  621 21st St  6:30 p.m.
May 24 IDEQ 1410 N Hilton Boise, conference room B
May 29 IDEQ 1410 N Hilton Boise Conference Room B

Or submit comments in writing to this address
Make sure all comments are sent by May 26 to Tim Teater.
Tim Teater
Air Toxics Program Analyst
Idaho Department of Environmental Quality
1410 N. Hilton
Boise ID  83706-1255

Tteater@deq.state.id.us
208-373-0457

The proposal for Idaho to set an "emergency action level" of 100 ug/m3 of PM
2.5 is dangerous because this level does not protect public health.

For citizens who wish to make public oral comment or written comment, please
make sure to include the following points in your testimony, always keeping
in mind that comments which address themselves to the proposed rule itself
will have a better chance of being included:

1.  The rule itself does not protect public health. Having an "action level"
of 100 ug/m3 (that's 100 micrograms of PM 2.5 particulates in a cubic meter)
will most certainly cause large levels of hospitalization, and perhaps
additional deaths.  It is not based on the scientific research which shows
that ill effects in sensitive populations (i.e, the elderly, or people with
heart conditions, emphysema, cystic fibrosis or asthma) begin in the range
of 20-40 ug/m3.  (See the explanation below concerning how the WA Dept
Ecology came up with the action level to protect human health during
mediated talks)

2. The rule does not address effective enforcement of a burn ban.  How will
the state ensure that people are complying with the ban, and what penalties
will there be for violations? How will enforcement occur, and what kind of
staffing will it take? Are overflights planned to monitor compliance by air?
Are local fire districts expected to do this work?  Experience in Washington
state shows that even with a permit system in place, there are numerous
growers who burn anyway and get away with it. Enforcement is only as
effective as the staffing and commitment to enforcement, and ultimately, the
commitment to public health.

3.  The rule does not make any provision for putting out fires that already
have started when the action level is reached.  Experience shows that most
fires are not capable of being extinguished once set in motion. Growers do
not have the capability of stopping field burns in progress, therefore the
levels of PM 2.5 pollution will continue to rise once that 100 ug/m3 limit
has been attained.  Will the state of Idaho stop burning before reaching the
100ug/m3 limit knowing that burns already in progress will raise the level
even higher?

4.  The rule does not address the level of exposure to toxic substances in
smoke from agricultural burning. For information on the specific toxics,
please visit our website, www.fieldburning.com and click on the "scientific
research" link, or go directly to:
http://users.pullman.com/gora/fieldburning/toxic.html
This will show you all the toxics and what they do to us. Many carcinogens,
mutagens and tumorogenic substances are contained in field burning smoke.
The rule makes no provision for monitoring this.

5.  The rule does not take into account that there are few monitors (3-4 in
the affected region) and the exposure to smoke near the edge of a fire is
significantly higher than the exposure at the monitor site.  How will the
proposed rule guarantee that state wide exposure to this hazardous smoke
will not exceed levels protective of human health?  It takes time for smoke
to travel to a monitor. In our experience, we observe fires starting in the
south and smoke travelling north, and this effect means that huge fires
which are started early will have the most likely effect of filling the
airshed.  This provides an incentive for growers to light up all at once,
and when the monitors reach the action level, there is nothing which can be
done to remove the ambient smoke, (now at harmful levels) from the air.  Far
better for planning purposes would be a permitting system by which the state
would decide how much acreage could be burned in a given day, and to permit
specific plots for those burns. Anyone who burned without the state permit
would be subject to a significant penalty.

6. The proposed areas for "protection" are not contiguous; That is, on the
maps provided, it appears that the Palouse/Prarie region is not connected in
any way to the North Idaho region.  From experience we know this entire
region is usually blanketed in smoke so thick that citizens have been unable
to drive on Hwy 195. The rule needs to take into account that smoke
generated in one "region" also affects the other region.

How do we determine a level that's protective of human health?

During mediation in April to August of 2000 with the Wheat Growers
Association and the Washington State Department of Ecology, experts
researched the most scientifically based rationale for setting an action
level which would be protective of human health, and this is what they
found:

Ecology is proposing an IAL of 25ug/m3 PM2.5 averaged over two hours.
Consistent with this action level and the estimation method outlined in our
recent draft of the settlement document, the radius of the SSMZs is 9 miles
(15 km).   The purge out period would last until air quality levels return
to normal for the particular location and season where the IAL (interim
action level) was reached.

Because the IAL is not an ambient standard, such as the National Ambient Air
Quality Standards (NAAQS), it is appropriate to consider a range of factors
that influence the determination of an action level and its relationship to
burning cereal grain stubble in Eastern Washington.  The selection of the
IAL takes into account the existing background concentrations of the
pollutant in the area; the relationship between the ambient monitors
measuring ambient concentrations and the exposed individuals, existing state
policy related to curtailment of other types of burning, and the most recent
health studies.  The IAL we propose is a pollution level that falls outside
the normal variation we see at our more rural (Pullman, Colfax) monitoring
sites. Data from city center Spokane monitoring sites because they are well
away from most ag burning and highly influenced by local sources of
pollution other than ag burning would be applied judiciously to making
burn/no-burn calls.

Brief Rationale:
The action level will be measured as PM 2.5:  PM2.5 measurement tools and
data are available, there is health based data related to PM2.5 exposure and
PM2.5 is a reasonable surrogate for the content of ag smoke.

The averaging time for the action level will be 2 hours:  Two hour averaging
smooths out normal/natural spatial and temporal variability in the ambient
data due to background and sampler fluctuations, it minimizes the
possibility that 15 minute aberrant spikes (reliability) in TEOM data would
artificially trigger a no-burn call, and its short enough that burning could
be called off before significant pollution from smoke intrusion occurs.

Several factors were considered to arrive at an action level of 25ug/m3
averaged over 2 hours:

(1)Background concentrations: The IAL must be above the normal variation or
background levels of air quality. Review of Washington data shows background
fluctuates seasonally and spatially and can range from 5-20ug/m3. It is not
practical to curtail burning at pollution levels below existing background
levels, as this may unfairly curtail burning when other sources may
contribute to a regional air pollution problem.  As a result, the IAL should
not be lower than 20 ug/m3.

(2)The health effects data contained in the most recent epidemiological
studies: These studies give the most recent and best picture of what
short-term exposure to PM2.5 does to human health. Though there is
uncertainty, results from the health studies suggest that negative health
effects occur in sensitive individuals from short term exposures in the
range of 20 - 40ug/m3. Taking into account more qualitative factors such as
ambient monitors potentially not located at the point of maximum
concentration and the suggestion of health effects at possibly lower levels,
we picked an IAL at the lower end of this range.

(3)Consistency with other outdoor burning policy:
Woodstoves and outdoor burning other than agricultural are shut off when
short term (2-4 hour)air quality levels reach 40% of the 24 hour federal
PM10 standard. Although under court challenge on constitutional grounds, EPA
has promulgated a 24 hour PM2.5 standard of 65ug/m3. 40% of 65ug/m3 = 26
ug/m3.

(4)Consistency with EPAs Air Quality Index: The index describes good air
quality as PM 2.5 readings up to 20ug/m3. 25ug/m3 puts us above the level
that EPA considers good air quality.

Address all comments to:
Tim Teater
Air Toxics Program Analyst
Idaho Department of Environmental Quality
1410 N. Hilton
Boise ID  83706-1255

Tteater@deq.state.id.us
208-373-0457

The website for the proposed rule is this:
http://www2.state.id.us/adm/adminrules/rules/IDAPA58/58INDEX.HTM
This will take you to a site, and click on the first item in the list, which
is air pollution rules. This will download an adobe acrobat reader (which
took about 4-6 minutes!) and then you have to go to pg. 108 in the reader,
and begin reading at Section 550, air pollution emergency rules) if you want
to read the rule itself.