First of two stories on EPA air pollution monitoring.
Utah physician Brian Moench is worried. There's only anecdotal evidence so far, but Moench maintains that oil and gas drilling in the Uinta Basin that straddles Utah and Colorado is almost certainly causing health problems for residents, including increased infant mortality.
"If you're going to expose a community to increased levels of emissions of diesel and [volatile organic compounds] and particulates and nitrogen oxides, well, it's as plain as the nose on the end of your face that you'll have health consequences," said Moench, the president of Utah Physicians for a Healthy Environment.
Air monitors have shown the basin, which traditionally has elevated levels of airborne dust and soot, doesn't meet federal standards for ozone, a major component of smog. With monitors showing ozone levels as high as those in Los Angeles -- even in winter, when ozone levels are supposed to fall -- many public health advocates are pointing the finger at oil drillers and calling for U.S. EPA enforcement.
But EPA has yet to declare the region out of attainment with federal ozone standards, a designation that would force the state to write a plan to reduce pollution. The reason? Air monitors that have recorded ozone readings in excess of federal limits for three consecutive years don't meet EPA standards and can't be used for enforcement.
And the single monitor in the region that does meet EPA standards hasn't produced the requisite three years of data.
"This wasn't some fly-by-night entity doing monitoring, this was the industry," said Jeremy Nichols, climate and energy director for WildEarth Guardians. "[EPA is] essentially rejecting this because of a label, not because the data is inaccurate. If monitoring is solely going to be in the purview of the government, you're closing off opportunities to learn more and understand air pollution."
Nichols' group has petitioned EPA to consider industry-backed monitors and has separately sued to force the agency to consider the data and put the region in nonattainment status. Court action is expected later this spring (E&ENews PM, Jan. 29).
But the Uinta Basin's plight speaks to a bigger question about EPA air monitoring. Despite a network of more than 3,000 monitors measuring five pollutants and dozens more for research, how much do Americans really know about the air they breathe?
Dick Valentinetti knows full well the importance of air monitors. Before retiring in February, he spent 43 years in various environmental regulatory offices, largely with the Vermont Department of Environmental Conservation, where he helped direct a network of eight monitors that helped assess the state's compliance with a slew of air pollutants, notably ozone.
"I've used this line before, but monitoring is the Rodney Dangerfield of air regulation: It just can't get no respect," said Valentinetti, who also chaired the monitoring subcommittee for the National Association of Clean Air Agencies.
"Everybody thinks about permitting, and people are big on enforcement. But you start talking about monitoring and they just don't think about it as an integral part of the program, even though it's the basis for everything we do."
The network is massive. For the six pollutants for which EPA has National Ambient Air Quality Standards -- carbon monoxide, lead, nitrogen dioxide, ozone, particulates or dust and soot, and sulfur dioxide -- there are 4,327 so-called federal reference monitors nationwide.
The placement of monitors is dictated by locations of people and pollution sources. The network doesn't include monitors for hundreds of toxics, plus separate research networks focusing on rural areas or more difficult pollution indicators and weather patterns.
The monitoring network forms the backbone for all of EPA's Clean Air Act work, from regulatory enforcement to the pollution alerts issued by state and local regulators to warn the public about days when air quality is poor.
The politics behind placement of the monitors may have the sex appeal of a municipal zoning board meeting -- and often the same amount of bureaucracy -- but have massive implications for states, industries and the public.
Moving a monitor a few feet can mean the difference between a state or a city meeting federal air standards or plunging into nonattainment status.
A misplaced monitor in New Haven, for example, left Connecticut on the hook for hefty fines and a web of compliance rules.
Mistakes in calibrating a monitor can render years of data used by doctors, scientists and regulators moot. Turn off the machine for a short time and a pollution spike might go unnoticed. Even a road- or building-construction site that crops up too close to a monitor can lead to elevated pollution readings.
"They're basically the pipeline that lets us know how we're doing, good or bad," said Janice Nolen, assistant vice president of national policy for the American Lung Association.
Nolen's group relies on the data collected from the criteria monitors to form its annual "State of the Air" report card, which offers state-level information on air pollution. But a recent push to make county-level information part of the report has exposed some flaws in EPA's monitoring approach, which largely focuses on dense population areas or pollution-trouble spots.
Of the nation's 3,086 counties, 1,003 had at least one EPA-sanctioned monitor measuring one or more criteria pollutants.
And even in areas whose air is closely watched, the very nature of a stationary monitor, coupled with the fear of being put into nonattainment status, means the readings may not give the most accurate picture of the air being breathed by people who live near expressways, chemical plants or industrial sites.
"We've got one of the most robust monitoring networks in the world," said Chet Wayland, director of EPA's air quality assessment division. "You obviously can't put a monitor in everybody's backyard -- they're sophisticated, they require maintenance, they're expensive."
But, Wayland added, the agency is looking to face those challenges head-on, including its recent effort to study pollution near the busiest roads.
And with growing public interest in the air people are breathing, the agency is even looking to someday integrate pollution readings from hand-held monitors, a potential sea change that could turn individual citizens into monitors and give a real-life air quality map.
More to learn
The placement of a new monitor can take months, if not years, requiring the cooperation of a large number of people, ranging from federal scientists to landscapers.
Under EPA rules, states are required to deploy a minimum number of monitors that meet federal standards for each of the six criteria pollutants.
For regional pollutants like ozone and particulate matter, monitors are focused around population areas where they are likely to appear with additional monitors required elsewhere in the state to give a broader picture.
Monitors for CO2, NO2 and lead are generally placed near industrial facilities or other industrial sources and the surrounding areas. The exact number of monitors in a city or state varies by population and sources -- Washington, D.C., for example, has five, while New York state has 54 (17 in New York City alone).
The federal requirements are reviewed on five-year cycles, when the Clean Air Act dictates that EPA review each NAAQS, while the state monitoring networks are reviewed annually.
States pick monitor locations that are then subject to public comment and review by the federal government. And states will have mobile monitors on hand for shorter-term studies.
Federal grants help cover the cost of some monitors (roughly a third of the $228 million EPA gave to states for air quality management in fiscal 2013 was for monitors), but states are still responsible for some of the cost, which can run tens of thousands of dollars. Simply purchasing and maintaining the monitors and sending filters to be tested by outside labs can run as much as 40 percent of a state air agency's annual budget.
That doesn't preclude states, industry groups, researchers or even private citizens from putting out their own monitors. Only ones that meet EPA standards can be used for regulatory purposes; state officials said it makes no sense to install a monitor that wouldn't comply with federal standards.
Spotlight on oil and gas fields
The Uinta Basin has become a rallying point for the environmentalists and public health groups urging a crackdown on petroleum-industry emissions.
EPA has worked with oil and gas companies to begin collecting data on ozone in the basin, but Nichols said those monitors aren't meeting EPA standards and the data can't be used for enforcement. Monitors in the region haven't collected enough data -- states must show violations for three years before regulators can crack down -- and so enforcement hasn't kicked in.
"EPA knows that judgment day is coming, it's not a matter of if but when," WildEarth Guardians' Nichols said. "The monitoring system is good, but it could be better. At this point, it's moving beyond monitoring to actually doing."
There are also monitoring issues in the Eagle Ford Shale, a 20,000-square-mile oil field in Texas that has just five regulatory models within its borders, despite elevated ozone readings in nearby San Antonio.
Concerns about industry-run monitors within the boundaries of the Eagle Ford have also led to questions about pollution levels associated with the oil development (EnergyWire, Jan. 15).
It's a problem Colorado is trying to tackle head-on, striking a deal with environmental groups and industry last fall for a set of hydraulic fracturing rules that will include monitoring for volatile organic compounds (VOCs) and methane.
A national map of EPA monitoring of criteria pollutants shows a clear story -- the population-dense coasts, large cities and traditional industrial tracts have the lion's share of monitors.
Sparsely populated states like South Dakota, Nebraska, Kansas and even Nevada have large monitoring gaps.
The gaps are there by design. EPA is trying to measure air pollution in areas where people live and work and wants to track potentially large sources of pollution. Why spend $400,000 installing a monitor in a swath of Nebraska rarely visited by people?
But, Nolen said, those network gaps could be masking pollution problems that the country doesn't know about. It would have been unheard of a decade ago to expect ozone pollution in Utah in the winter; now it appears to be the norm.
"It always surprises me how many counties don't have them," Nolen said. "They were defined originally because that's where the problems are, but what about all these areas that don't have monitors? The more we learn, the more we learn that we need more information."
Last year, EPA told states it would be turning a network of 90 research monitors known as CASTNET (Clean Air Status and Trends Network) that had been used to track pollutants in largely rural areas into regulatory ones. States were left scrambling to adapt to the change, and at least one -- Kansas -- took its monitor offline, despite its use for researchers looking at ozone in the prairie (Greenwire, April 30, 2013).
What's more, said Valentinetti, the retired Vermont regulator, the traditional network layout may be leaving resources where they're no longer needed.
"How many monitors do you really need to tell us we have an ozone problem?" said Valentinetti, whose state spent years coming into compliance with ozone standards. "Should you spend resources on that? Or are you better off trying to understand what's really happening everywhere in terms of air pollution?"
In discussions with EPA through his work with the National Association of Clean Air Agencies, Valentinetti said a major issue for state agencies was seeking an "offramp" for monitors that had outlived their purpose and could be moved elsewhere. While consistency is necessary to spot long-term trends, he said a full network isn't necessary for that.
"It can be tough, though. These things are like chocolate ice cream -- if you've never had it, you won't miss it," he said. "But once you get one, you want it forever. There's been a lot accomplished in the last few years, but the monitoring part of the program isn't exactly driving this bus."
Push for roadway monitors
The big issue for regulatory agencies trying to get a complete assessment of regional air quality is where monitors are placed.
Even monitors placed hundreds of feet away from busy roads and several stories in the air may not yield the fullest picture of air quality for commuters.
That point was driven home to New Jersey environmentalist Bill Wolfe by, of all things, the Bridgegate scandal that has embroiled Gov. Chris Christie's (R) second term. Wolfe was curious to see the pollution impact of the three-day lane closures on the George Washington Bridge last September, when idling vehicles and unseasonable heat produced ideal conditions for ground-level ozone.
But Wolfe found that a particulate monitor -- located about 10 miles away in Jersey City -- had been turned off, which EPA later attributed to a system malfunction.
A letter from EPA Region 2 Administrator Judith Enck to Wolfe's group, New Jersey Public Employees for Environmental Responsibility, clarified that states are not required to submit data from 100 percent of days (but must have data for at least 75 percent of the year), so there was no violation from the shutdown.
A monitor located closer to the bridge at the Fort Lee library, about 1 mile southwest, was operational and several monitors in the area did not reveal any rules violations, EPA added. But that answer, Wolfe said, only raised more questions.
"I'm looking at this station and it's on the roof of a fire station, 10 miles from the bridge. The question becomes, is it accurately reflecting human exposure?" said Wolfe, who had previously worked for EPA and the New Jersey Department of Environmental Protection. "I'm thinking of that James Taylor song, 'Up on the Roof.'"
That's a question advocates have been asking for a long time. City roads and highways with heavy traffic can mean high concentrations of pollutants from exhaust, including particulate matter, linked to asthma, respiratory problems and heart disease. According to a study published in the journal Transportation Research Part D: Transport and Environment, nearly 20 percent of the nation's population lives within 500 meters of a high-volume road, areas that largely are not being monitored (Greenwire, Oct. 7, 2013).
EPA is requiring more than 100 cities to install near-road monitors to measure pollutants, starting with NO2, by 2017 (Greenwire will explore the near-roadway program in a future installment). But any push to explore new areas comes with an inherent conflict: A state doesn't want to push for more monitors in areas that might display high volumes of pollutants.
The roadway program is already being challenged by business groups, which say states that violate air standards thanks to traffic will end up issuing plans that will hurt industries already cracking down on pollution.
It's a conflict that continues to dog the monitoring program -- there's a desire for more complete data, but states face a disincentive to seek out areas of high pollution because it might put them into nonattainment status. Indeed, Valentinetti said "different mindsets" on what monitors were good for would constantly dog conversations with EPA.
"There's a conflict that's out there with EPA's interpretation of the Clean Air Act," he said. "You've got to consider that state and local agencies want to know what's happening and what's causing these issues, not just attainment or nonattainment."
But EPA's Wayland said that, at least from his perspective, there's no conflict. EPA's sole goal was getting the "highest quality data," and recently those data are showing declining levels of pollutants.
"In my mind, more data is always good," Wayland said. "The bottom line is that the monitoring data ... is the ground truth. It represents what the people are actually breathing."
Tomorrow: monitoring near roads, in parks and under your shirt.
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