APCD dunes study is flawed

November 14, 2011


The Air Pollution Control District has responded to comments concerning the proposed regulation of the Oceano Dunes vehicle riding area which will be considered at the APCD Board meeting this Wednesday. The regulation is based upon an APCD study which found that vehicle activity on the dunes was responsible for additional particulate matter, or PM10, generated as a result of that activity.

One of the criticisms I had of the APCD’s study was the method they used to establish that on days when there was increased vehicle activity, there was an increase in PM10.

The method involved a comparison between a vehicle riding area and a non riding area. The non riding area was used as a control to account for any other factors other than vehicle activity on the results. Fifty highest vehicle activity days were then compared with fifty lowest vehicle activity days.

The study found there was 25 percent more PM10 on the highest use days yet the control did not experience such an increase which gave credence to the results.

However, I pointed out that APCD’s method was flawed since they used almost two months of data for the riding area before the non riding area (control site) monitoring equipment was even in operation. In addition, the study was supposed to be one year long starting April 2008, yet the study included the month of March 2008 without stating so in the study.

The APCD’s response to my criticism was jaw dropping. Instead of admitting that the criticism was valid and that the finding was in error, the staff report states that they did not in fact, need a control site at all and stood by their original finding of increased PM10 with increased vehicle activity.

The problem is this: there are far more visitors to the park during summer months than winter months which means the high vehicle use days will generally occur in the summer months and low use days in the winter months. This would likely inject a strong seasonal bias in the results when comparing high use days with low use days.

A close examination shows this is the case: it was warmer and drier during the high 50 use days which favors more PM10 while it was cooler and wetter during the 50 lowest which favors less PM10. There were eight days when it rained during the 50 lowest use days while there were only a couple of days with trace amounts of rain for the high use days.

The inclusion of that additional month of March 2008 also had a significant effect. Easter occurred on March 23rd which led to more vehicle activity during that period. March is also a windy month which generates more PM10. The net effect is to boost the correlation of PM10 with vehicle activity.

Seasonal variations of PM10 are well known with spring and summer months generally having higher PM10 while winter months the lowest. Instead of finding that vehicle activity causes more PM10, the APCD simple affirmed that there are these seasonal variations.

We need to get the science right if we are going to impose regulations based upon that science. Right now, I do not believe we have the science right.

Ed Waage is a Councilmember of the city of Pismo Beach and represents the city on the APCD Board.

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Ed Waage is a politician, NOT a scientist.

His ‘opinion’ is just that and only that…an opinion; and an incredibly misinformed and narrow one.

Apparently you are not aware Dr. Waage holds a Ph.D. in chemistry and has a good deal of experience in “plume analysis” (downwind travel of pollutants). Dr. Waage also participated on the IAEA team that won a Nobel Peace Prize.

The only science involved with this lunacy is JUNK science. All you supporters need to go get jobs.

What a farce if these people had to stand out at the area in question and montered the site them selves none of this houey would be taking place, but instead they sit in a nice cozy office playing with models on our ( taxpayer ) computers, drawing $100,000 ( taxpayer ) salerys and come up with ideas and propganda to placate the few and justify their jobs, all the whiners are trying to do is get the motor vehicles off the dunes this is being used as an excuse, if the vehiclkes in question are breaking the sand “crust ” then foot traffic and dogs do the same thing so I guess that area should be closed to ALL uses. Show us the proof that people get sick and or die from this, not suposition or may or can I want proof positive.

Mr. Waage demonstrates a basic lack of understanding of the overall methodologies used in the study and the results of the more than 2 million data points collected. The APCD has never contended that the particulate generated by the vehicles themselves produces any significant air pollution. This is a fact intentionally ignored by the naysayers. It’s the fact that they disturb the natural hardened crust that would otherwise form on the dunes if they were not disturbed, which allows the wind to carry a larger proportion of particulates downwind onto the Mesa area; much higher than the natural amount that would otherwise be carried off the dunes by the wind. They recognize particulate would come off the dunes whether there was riding or not. They are only mandated by California State law to regulate that difference between the increased amounts coming off the SVRA vs. the normal amounts that naturally come off undisturbed dune areas (“background levels”).

The APCD unequivocally refuted all Mr. Waage’s “arguments” today at their Board meeting, showed his lack of understanding of the methodology used and how to derive valid conclusions from the data, and left him with his tail between his legs.

As one of the public speakers at the meeting observed, Mr. Waage gets a free pass here and at his presentations to the Pismo & Grover Beach city councils to basically say whatever he wants with nobody else reviewing his fallacious reasoning or incorrect conclusions, as do none of the related blogged stories here on CCN. It’s a shame that CCN and many of the commenters here have relied on Ed Waage and Kevin Rice’s comments (slorider & Dunefacts.com to name a few of his commenter profiles) for a (biased) understanding of what the study concluded, rather than reading the study themselves or consulting directly with the APCD in an objective fashion, like a professional reporter would do.

If you care to see the actual truth, and not the bogus claims perpetuated by the many articles and biased uninformed comments regurgitated here at CCN, I encourage you to watch the APCD’s entire Board meeting for yourself. If you only want to watch the part where Waage’s arguments are completely refuted, it starts at 3:43:00. If you’re not interested in the actual facts and valid science behind the study and its conclusions, then nobody can help you.


Notes on Mr. Waage, the Science Guy! Thank-you! I need this! I want to learn this:

To Prove: Increased Vehicle Use (on the Beach or elsewhere,) causes an Increase in Particulate Matter (PM10) (aka, air pollution.)

Given: APCD wants to increase its control over “vehicle activity on the dunes.” To justify this, (and to justify fines for violations,) APCD made a “study” of air pollution on the dunes. The study concludes that increased vehicle use on the dunes increases air pollution.

The APCD’s conclusion “increased vehicles on the dunes causes more pollution in the air” was based on the following procedures to test their hypothesis:

The study compared two different areas of the beach.

One was a vehicle riding area.

The other was a non-vehicle riding area. (The “control area.”)

The third area was the freeway 101. (Or maybe they didn’t use any other area where there are vehicles being driven, but not on the beach….?)

The 50 highest vehicle days were compared with the 50 lowest vehicle activity days across the board, in all three areas.

The study found there was 25 percent more PM10 “on the highest use days” in the areas where there was vehicle use, but not in the beach area where vehicles were not used.

Problems With The Study:

They did not use the same time period during which they monitored the area of the beach where vehicles are used, as when they monitored the area of the beach where vehicles are not used. This is because:

1. The monitoring equipment in the non-vehicular was not yet installed during the two months of OHV monitoring.

2. Someone intended to committ fraud in order to assess fines without evidence of any violation, while asserting the violation “under color of law.”

Other Problems with the Study: Factors not taken into account which would affect the amount of particulates in the air during any given period of time, regardless of which area was being monitored:

Air Temperature


Precipitation or Rain


A Third Problem with the Study:

It was supposed to start in April and last a year, but it actually included 13 months instead of 12. This “artificially” boosted the amount of particulate matter in the air on any given month because they divided the total air pollution by 12 months instead of 13. This proves:

1. The APCD is even more mathematically challenged then I am.

2. They are way the Hell overpaid if they have trouble counting to 20.

They did tend to prove,however, that increased vehicle use any where, at any time, increases PM10.

That I get.

$100,000.00 bucks for Larry Allen, I don’t get.

New Problem!

How much will it cost to get rid of him? Your ball, Katcho!

Final Problem with the APCD study:

It did not take into account that vehicle use increases in the area of study during the summer, and on holidays. Therefore, it did not consider that the results of the study may be ignoring the fact that pollution may increase due to factors other than driving on the beach.

Flaw in Waage’s analysis:

Waage seems to be saying that:

Because of an increase in the number of vehicles in the area during the holidays and summer, there will be an increase in PM10 (air pollution,) EVEN IF the number of vehicles ON THE BEACH stayed the same.




This fact is a GIVEN, and does not disprove the theory that increased vehicle use on the beach increases particulate matter even in the non-vehicular areas.

However! If the study is correct, even with increased vehicle usage everywhere, there will be lower levels of particulate matter in the areas where vehicles are not driven.

But! There COULD be more air pollution in the non-vehicular areas because the wind blew it off 101, and it didn’t come from OHV.

Conclusion: Study = bullsheeeet

APCD=Intentional Fraud OR WASTE + ABUSE

Where’s a FED when you need one?!

I don’t understand why they wouldn’t test both sites on the exact same days? It seems to me that the only way to compare oranges to oranges is if you start with a bag full of oranges in the first place.

And the state Air Resources Board/Cal-EPA have a maximum limit for PM-10s, which I believe is something like 50 parts per million. Does the OHV park exceed that limit? How often?

The APCD obviously wants to issue a permit that it can then use to fine State Parks when the PM-10 levels exceed the permit limits.

State Parks will just increase user fees to cover potential fines. And both agencies will be happy — state parks will keep its gold mine going, APCD will get more monies to spend on their own salaries — but it’ll be the Dunes users who pay with cash and the Nipomo Mesa residents who pay with health consequences.

Does anyone REALLY think the state is going to close down the Oceano Dunes?

Does anyone really believe the APCD has the authority to close it down? After all, they’ve never closed down the oil refinery on the Nipomo Mesa and it’s the biggest single source of air pollution in SLO County.

Does anyone believe this one study is sufficient evidence to force closure of the dunes should this end up in court?

I see all this as a bunch of saber rattling by APCD. You watch, the APCD and State Parks will reach a “settlement” wherein the Dunes is allowed to stay open, a minimal amount of work/money will go into things like these hay bales, and the state will just take its chances and pay fines on days the PM-10 is too high.

That’s the same situation the Regional Water Board has with CMC and its sewer plant, which keeps spilling into Chorro Creek every winter. CMC gets a “fine” of thousands of dollars, RWQCB pats itself on the back, CMC takes a few lumps and the taxpayers have their pockets picked some more, as bureaucrats shuffle OUR money from one pocket to another keeping a little for themselves each time.

HOLD ON THERE. There is a problem with your logic, it makes too much sense. Lets not get everybody confused.

What’s the most important thing here? Reducing PM10 levels. Which the recent testing in the SVRA has proved can be done via vegetation &/or straw bales.

Related questions occur to me:

1) Does Mr. Waage dispute that vehicle use increases PM10 levels?

2) What is the value of the error(s) that Mr. Waage asserts which could have been generated by what he feels is the flawed testing?

3) Is this error(s) significant in the context of the overall conclusion of the report?

And lastly, a question which I’d assume nearly everyone following this issue would have burning in their minds:

4) If the recent straw bale testing in the dunes demonstrates that those levels can be reduced, why aren’t the people responsible and concerned (APCD, State Parks, Friends of Dunes, Sierra Club, etc) just getting out there in the dunes and solving the problem? Why is a “rule” necessary? Whatever happened to a “handshake?”

To start with your last question, IMO the state has tried to work with the APCD. They seem to be willing to bend over backwards for the APCD.

I’m not Waage, and I’m not a huge fan of Waage but I’ll pretend like I’m him as I don’t believe he’ll come here to answer your questions. So from what I know of Waage, this is how I believe he’d answer your questions.

1) I don’t believe he would make a judgement on whether vehicle use increases PM. Waage is a black and white kinda guy, rarely do you hear him must give an opinion. He might say, ‘there’s not enough data to show if there is elevated PM due to vehicles’.

2) If I understand your question correctly, Waage might say that the state will have to shell out hundreds of thousands of dollars perhaps even millions to mitigate an issue that hasn’t been proven to be caused by OHVs. In turn the state might just say we’re starting to lose money, we’re out of here and therefore a good portion of the Five Cities businesses will dry up and blow away with the sand. Plus actions caused by this study could open the door to future litigation.

3) Yes, absolutely. For example one of the main issues that I’ve heard him discuss is that a huge part of the issue is the measurement of wind speed on the dunes. If the wind is heavier on the dunes then the surrounding area then of course there will be more PM released into the air. Many people feel that area is a wind tunnel and if you look at the topography of the area you can see that it is just that. But the instruments that were used to measure the wind speed weren’t actually down wind in the dunes. The devise they used for measurements of the actual OHV area was actually located at the fire station. If you are familiar with Oceano then you would understand that the fire station is behind trees, buildings and the paved roads. So the report is claiming that it’s not any more windy on the dunes then other areas that they tested so it must be the vehicles that are kicking up the dirt. All old timers from this area will tell you that it’s more windy in the dune area then surrounding areas and if you look at an areal map you can see how between the geograpy (hills and the bay) that would make sense.

4) Back to #4, this is me not Waage. Why would you want to harness a unique natural environment like that? The wind is supposed to blow sand, the mesa was part of the dunes. If you build by an airport then don’t complain about the planes. That being said, I believe the state has offered to do the hay bale thing but I believe that the Coastal Commish might has a say in that. Plus I think they want to make sure that it will actually serve a purpose. Also, you know how these things are, when you introduce something to a wildlife area you might cause other issues. I don’t know, perhaps the red fox won’t be able to go down and eat the plovers eggs if there’s hay bales there???

Larry you and your 250k salary can’t figure out how to do this right? What a waste. I wish you and your staff would just pack up and leave.