Waage urges council to reject dunes study
October 31, 2011
A Pismo Beach city councilman wants his colleagues to agree on Tuesday to ask the San Luis Obispo County air-quality board to reject a proposed rule to regulate fugitive dust emissions at the Oceano Dunes State Vehicular Recreation Park.
The San Luis Obispo County Air Pollution Control District (APCD) created a study last year that shows a link between off-road vehicle use on the dunes and unhealthy air pollution levels downwind from the dunes on the Nipomo Mesa.
However, Councilman Ed Waage, who is considering challenging Adam Hill in the upcoming District 3 supervisorial race, agrees with state park officials who claim the study is inaccurate and should be invalidated. Board members of the APCD, comprised of members of the San Luis Obispo County Board of Supervisors and representatives from the county’s seven cities, agreed to support the study.
In a letter obtained by CalCoastNews, Waage argues that flaws in the APCD study need to be addressed before the board adopts rules based on the study.
For example, according to Waage, the APCD study assumes that wind speeds measured at the California Department of Forestry fire station are representative of wind speeds at the dunes.
During the past year, state parks has been measuring wind speeds at the dunes and reports speeds 70 percent higher then those measured at the fire station by the APCD. Waage notes in his letter that the fire station stands behind several rows of tall trees.
“Higher wind speeds will have a significant effect on some of the conclusions of the study so it is imperative that the more recent data on wind speeds be used to reevaluate those conclusions,” Waage wrote.
The APCD also conducted the PM10 pollution level study at the fire station which sets on Highway 1 in Oceano. Waage, who has a Ph.D. in chemistry, criticizes the APCD for failing to consider the effect auto emissions had on the higher pollution counts it found at the fire station.
“A comparison of PM10 measurements during the morning commute at 7 a.m. shows higher levels of PM10 on weekdays than weekends,” Waage wrote in the letter. “Since there is more commute traffic on weekdays, this result is an indication that there is a contribution to measured PM10 from vehicle traffic.”
In addition, Waage notes that the APCD proposed year-long study added in an additional month. He says that March and April are windy months which will results in higher PM10 so the selection of an additional March will skew the results.
“Using this flawed approach, the Study found about 25 percent higher PM10 on the 50 highest use days compared to the lowest 50 days,” Waage said. “This 25 percent value was used extensively in public presentations by APCD staff.”
Last week, the Oceano Community Services District Board voted 4-0 to send a letter to the APCD Board opposing the proposed rules that place fines on the state for not improving air quality at the dunes.
The APCD Board is slated to vote on the proposed rule on Nov. 16.
Proposed letter to the chair of the APCD: