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Re: RE: E-M:/ Benzonia: Worst air quality in the US on Monday



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Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
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At 11:40 AM 05/03/2001 -0400, Elliott Levinsohn wrote:


>Although Benzie County received a failing grade by the American Lung
>Association's "State of the Air: 2001" report for number of days with high
>ozone concentrations in unhealthy ranges (by US EPA's Air Quality Index)
>during the years 1997-1999, they were not one of the worst counties in the
>nation plagued by high ozone concentrations nor were they in "violation" of
>the new health-based 8-hour ozone standard which has not been implemented by
>the EPA to date.

huh??

This response to Murray's response requires its own response.

First, I don't understand what purpose Levinson/ALAM would have in
arguing the point that there is no "violation" of legal standards
for national ambient air quality standards for ozone at the Benzonia
monitoring site [never figured out why they call it Frankfort when
the maps show the monitor to be in Benzonia].

While it may be true that there has not yet been formal redesignations
of Michigan regions to non-attainment and there are no implementation
plans for attainment, these facts make no difference to the lungs of
NW Michigan residents who must breathe the ozone measured by the
air quality monitors.  As far as human lungs in NW Michigan are concerned,
(the thing that matters to all breathers, including ALAM) any distinction 
that there is no formal legal violation yet of the Clean Air Act NAAQS is a
distinction without a difference.

When children in NW Michigan and other locations have their lungs assaulted
with high concentrations of ozone in contaminated air, the inflamatory 
response of those children's lungs does not depend on whether EPA has 
published redesignations, whether the three year average of the 4th highest 
8 hour average has crossed the standard or other mundane regulatory artifacts.

Even EPA admits they chose the form of legal compliance with the
standard not for health reasons but to "...provide greater
stability in the standard for businesses and communities by requiring more 
"bad air" days before an area is found to be out of attainment."

What is unique about the results of the Benzonia monitor is to
observe the length of time that many ozone episodes cause
air quality to be degraded.  While Benzonia may not have the
absolute highest ozone concentrations, what does occur here is
a threat to public health.   At Benzonia and to some extent at Scottville, 
the amount of time that the public is exposed to monitored ozone 
concentrations over the level of the standard
during the worst smog episodes is far longer than any other place
in Michigan.   During the worst episodes it is not uncommon for
Benzonia to show monitored ozone concentrations over 85 ppb from
about 3 pm in the afternoon all the way to 1 AM in the morning
the next day.

This condition is probably an artifact of the long range transport
regime over Lake Michigan from Chicago, unique in the United States.

This finally brings me to the matter of whether Benzonia would be
in violation of the EPA standard if it was in full effectiveness.
The answer to that question is YES!   The data is available at:

http://www.deq.state.mi.us/aqd/eval/amu/003yravg.html

This data shows that the three year average of the fourth highest
8 hour average for Franfort (Benzonia) for the period 1997-1999,
the period mentioned by ALAM, is 0.088 (standard is 0.085).  For
the period 1998-2000, the average is higher, 0.089

The Benzonia 1998-2000 3 year average is higher than the corresponding
average for Berrien County (coloma...although prior 3 year averages
were higher than Benzonia at this site), Cassopolis, Otisville,
Grand Rapids, Warren, Port Huron, East 7 Mile in Detroit, and many other
Michigan monitoring sites.

As far as last Monday's smog episode, I'll stand on my statement
that the data showed that Benzonia on that day was the only site
in the United States (for which monitor data is available at 
www.epa.gov/airnow) that showed an excursion over the health standards.

...quod erat demonstratum....


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Alex J. Sagady & Associates        Email:  ajs@sagady.com

Environmental Enforcement, Permits/Technical Review, Public Policy and
Communications on Air, Water and Waste Issues
and Community Environmental Protection

PO Box 39  East Lansing, MI  48826-0039
(517) 332-6971 (voice); (517) 332-8987 (fax)
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