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E-M:/ Smog report (and some thoughts on "ozone action days")

Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>


There is no Ozone Action Day in Michigan today, but unhealthy
air pollution is in fact occurring in parts of
the state.

At 6 PM, Flint, New Haven, Detroit 7 mile road,
are showing ozone levels over the 85 PPB level of the
new health standard.   By the time the day is over,
Warren, Oak Park will probably show 8 hour averages
over 85 PPB

On the west side of the state, several air monitors
are showing 8 hour concentrations around 80 PPB ...
someone under the level of the standard.

MDEQ AQD has released this statement on its website:

"When atmospheric conditions are such
that either widespread ozone eight-hour
averages greater than 85 ppb or one-hour
averages greater than 125 ppb are
anticipated, the Air Quality Division (AQD) and it's Clean Air
Coalition partners (http://www.wmcac.org/ and 
http://www.semcog.org/ozoneaction/) issue
an Ozone Action Day declaration. The AQD then
continually tracks the one and eight-hour
ozone levels observed in the state and
reports them graphically. However, care must
be exercised when interpreting these graphs. Monitored values
above the one and eight-hour benchmarks does not
necessarily mean that the National Ambient Air Quality
Standards (NAAQS) established by the United
States Environmental Protection Agency have been violated.
Because the ozone NAAQS are statistical in nature1,2,
three years of monitored values must be analyzed before
that determination can be made.

Users who are interested in relating specific ozone
levels to health effects are directed to the AQD's Air Quality
Index (AQI). The AQI, a normalized representation of
the eight-hour ozone and other pollutant benchmarks, is
available for 23 sites in Michigan via


    1.EPA's eight-hour NAAQS for ozone is violated when the three year 
average of the 4th highest daily maximum eight-hour average concentrations 
observed during a year at a given monitor is greater than 0.08 ppm (i.e., 
85 ppb). however, the 8-hour ozone naaqs is not operational. EPA must 
promulgate new rules for an 8-hour naaqs to comply with court remands.

     2.EPA's one-hour NAAQS for ozone is violated when the 4th highest 
daily maximum one-hour concentration over the past three years at a given 
monitor is greater than 0.12 ppm (i.e., 125 ppb)."

Although from a regulatory standpoint, there is little
to quibble about with the above statement.   But from
a public health, public notice and public health
prevention standpoint, the entire MDEQ/SEMCOG approach
to smog leaves a lot to be desired.

Without even considering the Engler/Harding litigation
against the revised EPA health standard....  The first
problem with the MDEQ/SEMCOG approach to "ozone action
days" is that the most fundamental and primary purpose
of this "awareness" program is avoidance of Clean Air
Act non-attainment designations rather than public health

The primary message is focused on trying to get emission
cutbacks and there is very little emphasis on warning
the public that they are presently being subjected to
unhealthy air pollution.   While getting emission cutbacks and
the public "doing their part" to control air pollution
is undoubtedly good, it is far more important to tell the
public that their health can be harmed by air pollution
and that sensitive groups in the population must take measures
to avoid smog exposure.

Unfornately, the Engler/Harding/MDEQ litigation against
the EPA health standards means that MDEQ management doesn't have
"clean hands" when it comes to warning the public about
the health dangers of smog exposure.  It would be the
ultimate in agency cognitive dissonance for MDEQ management to take
the position in public announcements that smog is harming
the public's health while having previously litigated all the way
to the Supreme Court that the public should be allowed to be
exposed to such air pollution with no consequences.

Exposure to ozone causes public health impacts as a result of
a short term pulmonary inflamatory response.   The form of
the standard....the three year average of the fourth highest
8 hour average per year.... is more an artifact of politics than
and an effort by EPA to weakest the standard before promulgation
to limit the number of future non-attainment areas
than a statement based on biological effect.  Public health
protection cannot wait for a three year consideration air pollution
monitoring statistics in dealing with a pollutant with acute
exposure respiratory health consequences.

The consequences of this kind of failure to warn the public
is inevitable asthmatic attacks and hospitalizations for
respiratory disease patients.

Although incorporation of 8 hour averages was an important public
health-based response in making the standards more stringent, strict
reliance on 8 hour monitoring protocals before sensitive individuals
take action to protect themselves from smog is a mistake (if they
ever find out they are being exposed -- unlikely with current MDEQ

For example, if you wait until you hear that an 8 hour average is
exceeded on a daily smog incident when ozone starts increasing
about 11 AM to 1 PM and builds through the afternoon, it will be 5-7
PM when those 8 hour averages are finally showing numbers above 85
PPB.   By 5-7 PM, most hourly ozone concentrations will usually be on
the decline (unless you live in NW Michigan...).   As a result, reliance
on the air quality index, which relies on the 8 hour ozone average among
other factors, is next to useless in avoiding smog exposures occurring
in the afternoon.

This brings me to a couple of other criticisms of "ozone action days."....

Because "ozone action days" is focused primarily on getting emission
reductions out of the public and avoiding non-attainment designations 
rather than warning the public they are being exposed to unhealthy air 
pollution, it is "urban-centric" and "Grand Rapids, Muskegon, Holland"- 
centric and "South east Michigan" centric.

When Berrien county gets heavy air pollution transport from Chicago,
there is no public health ozone awareness program from MDEQ in those 
communities....same from NW Michigan and the Michigan's Thumb.
Since there is no emphasis on telling the public they are being exposed
to heavy air pollution that is a hazard to health it then becomes
easy to write off whole portions of the state that are not seen as
important to getting emission reductions to avoid non-attainment

This brings me to my final point.  You can review the 3 year average of
the fourth highest annual 8 hour average for nearly all of the
air quality monitors in Michigan for the year 2000 (because we're not
yet through 2001) at


What this data shows for years 1998-2000 is that the majority (all but 3) 
of the air quality monitors in the state of Michigan are showing 3 year 
(4th highest) averages which are 80 ppb or more (standard is 85 
ppb).  Eleven sites are showing what would be legal violations if the new 
health standard was fully in effect.  Eleven more sites are showing 3 year 
averages of the 4th highest annual 8 hour average just ever so slightly 
under the the level of the standard (80-84 ppb).

This all means that Michigan has serious problems with smog/ozone at
many sites.   Michigan citizens deserve to have environmental health
monitoring agencies tell them clearly that the air is unhealthy to
breathe.   While a number of dedicated, middle management people in
the MDEQ Air Quality Division are doing an excellent job of delivering
up means of accessing air quality data in near-real time, this is
only half of the needed communication task related to public health
prevention and education as to the health effects of ozone.  Until
MDEQ upper management and the Engler administration "come clean" on
the issue of ozone exposure and public health, the public's health
will continue to be jeapardized because of lack of adequate warning
of actual human exposures to ozone in the Great Lakes state.

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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