2008 Letter Air Quality Chapter

17 January 2008

Chair Myers & Commissioners

Planning Commission

City of Santa Barbara

Sent via email to:

Planning Commission Secretary < >

RE: Proposed Updates for the Conservation Element’s Air Quality Chapter1

Dear Chair Myers & Commissioners,

The Citizens Planning Association’s General Plan Update Committee is committed to assisting

the City with a General Plan Update that protects, preserves, and enhances the unique qualities of

Santa Barbara. We’re pleased that our input to date has received positive reception, and we

appreciate this opportunity to provide you with further input at this time.

Two weeks ago, at your January 3rd meeting, our Committee Chair, Sheila Lodge, mentioned our

hope to report on air quality concerns at the Creating a Healthy Community forum on January

19th. Please accept this letter as our contribution to the forum discussion, and as proposed

updates for the Conservation Element’s Air Quality Chapter.

A. Summary Remarks

Clean air may well be the most important natural resource for both human health and planetary

life. We believe that Santa Barbara should do more than it does to protect its limited share of

this precious resource.2

We recommend, therefore, that the Air Quality Chapter of the city's

Conservation Element (first adopted in 1979 and last amended in 1994) be updated both against

the general background of climate change and with the following two particular concerns in

mind:

1. The South Coast's air quality is less thoroughly monitored now than it was between 1988 and

2000.3

2. The number and sophistication of scientific studies demonstrating air pollution's health

impacts have greatly increased in recent years but the implications of new findings -- for

example, about the health risks involved with residing too close to heavy stop-and-go city

traffic -- have not yet been brought to bear on land use decisions.4CPA GPUC, 1/17/08

Re: Proposed Conservation Element Update – Air Quality Chapter

To be sure, the proposed update can build upon the existing document's fine coverage of

numerous topics. These include the topographic and meteorological features that limit Santa

Barbara's "holding capacity" for pollutants and the financial consequences of air pollution

affecting the community. We should also strive to reach the 1994 update's two primary goals:

"Maintain air quality above Federal and State ambient air quality standards" and "Reduce

dependence on the automobile." But at least two additional goals deserve to be considered for

inclusion: "Develop means for site-specific monitoring of air quality in different parts of the

city" and "Coordinate land use policies with site-specific considerations of traffic-generated air

pollution."

B. Further Discussion

In terms of the pollutants for which state and national standards have been established, Santa

Barbara County's over-all air quality is respectable but needs improvement.5

Furthermore, air quality in the county as a whole is one thing; air quality at specific locations is quite another. For

example, our downtown area's officially estimated background cancer risks due to air pollution

are far worse than the corresponding risks in other parts of the county.6

It is easy to see why this should be so. The City of Santa Barbara (along with the City of Goleta

and some adjacent unincorporated areas) is "in the eye of the storm" when it comes to the

combined impact of motorized sea, air, and ground transportation -- three major sources of air

pollution which mainly rely on fossil fuels and produce both green house gasses and toxic

particulate matter.

To be sure, federal or state legislation is needed to set more rigorous emission standards for air

and ground transportation, and international agreements must be reached for lessening the

pollution levels caused by cargo shipping. Yet it is up to local officials

1. to regulate (or at least influence) the kind and amount of traffic affecting local roadways, and

2. to ensure that residential buildings and other sensitive receptor locations like schools,

daycare centers, and nursing homes are sited at a safe distance from freeways and heavily

traveled traffic corridors.

For both kinds of governmental intervention it is essential to have site-specific information about

traffic-related air pollution within the city. At present, however, there is no way to gather

sufficiently accurate detailed information, in part because only one monitoring station operates in

the entire city.

7 Recent research has established clear links between heavy traffic and the health of "sensitive

receptors" (e.g., children, seniors, pulmonary patients) in the population. In particular, numerous

studies have demonstrated the increased probability for the occurrence of both asthma and

retarded lung development in children residing near highways and city arterials. Ways must thus

be found to spot check or reliably estimate the health risks associated with particular city

locations before they are approved for residential development or other sensitive land uses. CPA GPUC, 1/17/08

Re: Proposed Conservation Element Update – Air Quality Chapter

We believe that the city's updated Conservation Element should continue to stress the need for

promoting modes of transportation other than the use of motor vehicles with single occupancy.

The improvement of sidewalks, bike paths, and street lighting, as well the offering of various

incentives for ride sharers and bus riders, should indeed remain an integral part of our efforts to

improve air quality. We also believe, however, that strong added language is needed to caution

against land use decisions which place dense residential developments near freeways or too close

to our most heavily traveled surface streets without (a) improved site-specific monitoring of

current conditions and (b) reliable forecasts of the resulting public health risks in the locations

under consideration.

The siting of dense residential developments downtown and along traffic corridors has

sometimes been advocated on the assumption that increasing urban density (unlike increasing

suburban sprawl) might decrease air pollution. The validity of that assumption has not been

proven.

8 Furthermore, most advocates of urban densification tend to overlook the complex

relationship between population density and traffic-generated air pollution.

9 Consider two examples:

(1) It may be true that the typical household located in a higher density area generates fewer

trips than the number of trips that would be generated by the same household if it were

located in a lower density area. BUT: The denser area would generate more trips by dint of

being inhabited by more households, and the first and last miles of the additional trips (as

well as many "cold starts" of automobile engines) would be concentrated within the dense

area itself. The resulting congested traffic would especially impact public health in densely

populated areas where, due to the presence of taller buildings and the absence of sufficiently

generous setbacks, air pollution takes longer to dissipate.

(2) It may also be true that people living in a high density area will often rely on alternative

modes of transportation, especially if walking and biking are made safe and public transportation

is provided in numerous directions and with convenient frequency. BUT: People who live

and/or work in a densely populated area are exposed to its polluted air even as they try to derive

health benefits from the outdoor exercise afforded by biking or walking. While such exercise

may help to diminish the health risks posed by excessive weight gain and obesity, the benefits

are often coupled with the respiratory and cardiovascular harm done by air pollution.10

In the light of the foregoing considerations, we urge that the updated Air Quality chapter of the

Conservation Element

(1) address both the pertinent advantages and disadvantages of further increasing the residential

density in areas of heavy traffic, and

(2) insist that any such increase in density be made contingent on adequate air quality

monitoring of the sites proposed for high-density residential development.

C. ConclusionCPA GPUC, 1/17/08

Re: Proposed Conservation Element Update – Air Quality Chapter

As mentioned and justified above, we propose that two new goals relating to air quality be added

to the city's Conservation Element:

Goal #3: Develop means for site-specific monitoring of air quality in different parts of the city,

and Goal #4: Coordinate land use policies with site-specific considerations of traffic-generated air

pollution.

If encouraged by the response of city planners and the public to this recommendation, we will

amplify the two new goals into a proposed set of policies and implementation strategies

comparable to the policies and implementation strategies associated with the two existing goals

of the Conservation Element's chapter on Air Quality.

Thank you for your thoughtful consideration of this input.

Sincerely,

Naomi Kovacs

Executive Director

Encl. Exhibit A: Selected abstracts since mid-2005 on traffic, air pollution, and public health

CC: Santa Barbara City Council

Dave Gustafson, Director, Community Development Department

Bettie Weiss, City Planner

John Ledbetter, Principal Planner

Jan Hubbell, Senior Planner

Terry Dressler, Director, SB County Air Pollution Control District

NOTES

Acknowledgements: Much of the information referenced below is derived from the Santa Barbara

County Air Pollution Control District's excellent website at <>. We are

particularly indebted to the agency's director Terry Dressler who gave a presentation to CPA's

Comprehensive Planning Committee on August 27, 2007, and sent numerous e-mail responses to our

questions both before and after that date. Mr. Dressler's e-mails excerpted below were cc'd to Mayor

Marty Blum and Council Member Roger Horton who were instrumental in initiating the most valuable

contact between Mr. Dressler and CPA.

is a good source of information about what some other cities are doing to "curb

global warming, save taxpayer dollars, and create healthier cities." CPA GPUC, 1/17/08

Re: Proposed Conservation Element Update – Air Quality Chapter

Page 5 of 6

For details, see e-mail of 9/6/2007 from Mr. Terry Dressler, Air Pollution Control Officer, Santa

Barbara County Air Pollution Control District (APCD): "The California Air Resources Board (ARB)

monitored for toxic air contaminants at the Carrillo Street ambient air monitoring site between 1988 and

2000, when that station was closed because ARB lost their lease. The monitoring was conducted as part

of a wide network throughout California. When the current air monitoring station was established at the

Canon Perdido Street site, ARB did not install air toxics monitoring. We have not been informed as to

why ARB has chosen to cease monitoring for air toxics in Santa Barbara. In the monitoring conducted

from 1988-2000, the following toxic air contaminants were monitored: acetaldehyde; benzene; 1,2

butadiene; carbon tetrachloride; chlorobenzene; chloroform; meta-Dichlorobenzene; orthoDichlorobenzene;

para-Dichlorobenzene; ethyl benzene; ethylene dibromide; ethylene dichloride;

formaldehyde; methyl chloroform; methyl ethyl ketone; methyl tertiary-butyl ether; methylene chloride;

perchloroethylene; styrene; toluene; trichloroethylene; meta-xylene; meta/para-xylene; ortho-xylene;

para-xylene; benzo(a)pyrene; benzo(b)fluoranthene; benzo(g,h,i)perylene; benzo(k)fluoranthene;

dibenz(a,h)anthracene; indeno(1,2,3-cd)pyrene; aluminum; antimony; arsenic; barium; beryllium;

bromine; cadmium; calcium; chlorine; chromium; cobalt; copper; hexavalent chromium; iron; lead;

manganese; mercury; molybdenum; nickel; phosphorus; potassium; rubidium; selenium; silicon;

strontium; sulfur; tin; titanium; uranium; vanadium; yttrium;zinc; zirconium."

See another Dressler e-mail, dated 8/10/2007: "Currently the APCD and most local air pollution

control districts use the California Air Resources Board's Air Quality and Land Use Handbook: A

Community Health Perspective (April 2005) in advising jurisdictions on local land use decisions." A

sampling of pertinent research abstracts, too recent to be considered in the Handbook, is provided in

Exhibit A (separately submitted). One of the studies cited there, "Traffic, Susceptibility, and Childhood

Asthma" by Rob McConnell et al. (Environmental Health Perspectives, May 2006), is directly relevant to

the question whether Santa Barbara should site new residential developments within 75 meters (about 82

yards) of traffic corridors because (1) the study's pool of 5,341 children included a group from the city of

Santa Barbara, and (2) residential proximity not only to freeways but also to other "major roads" (i.e.,

surface arterials) was included in the examined data. According to the article's Abstract (p. 766):

"residence within 75 m from a major road was associated with an increased risk of lifetime asthma,

prevalent asthma, and wheeze," and "the higher risk of asthma near a major road decreased to background

rates[only] at 150-200 m from the road."

According to the Santa Barbara County Air Pollution Control District's website (under Air Quality click

on Attainment Class): "Santa Barbara County is considered in attainment of the federal eight-hour ozone

standard, and in attainment of the state one-hour ozone standard. We do not meet the state eight-hour

ozone standard or the state standard for particulate matter less than ten microns in diameter (PM10); we

do meet the federal PM10 standard. There is not yet enough data to determine our attainment status for

either the federal standard for particulate matter less than 2.5 microns in diameter (PM2.5) or the state

PM2.5 standard, although we will likely be in attainment for the federal 2.5 standard.

According to the same website (under Air Quality click on Air Toxics > Significant Risk Facilities >

Putting Risk into Perspective): "Among the largest contributors of air toxics are cars and trucks. […] The

estimated background cancer risks due to air pollution for some selected areas of Santa Barbara County

are as follows:

Downtown Santa Barbara: 223 cancer cases per million

Santa Maria: 98 cancer cases per million

Gaviota: 47 cancer cases per million

Lompoc: 40 cancer cases per million" CPA GPUC, 1/17/08

Re: Proposed Conservation Element Update – Air Quality Chapter

Page 6 of 6

This situation is a long-standing cause for concern. For some reason, the website version of the existing

General Plan's Conservation Element only lists goals and policies but not the numerous implementation

strategies relating to air quality. Please note, however, that Implementation Strategy 4.4 reads:

"Encourage cooperation between City and County jurisdictions to develop additional air quality stations

to obtain better information regarding air quality" (City of Santa Barbara General Plan Update 2030:

Conditions, Trends, and Issues, August 2005, p.188 of 350). Given the high cost of installing and

operating fully-fledged monitoring stations, such alternatives as the ad-hoc monitoring of key pollutants

at selected locations might, and ought to, be explored especially because APCD's monitoring stations

indicate higher degrees of pollution in urbanized areas but offer no significant details about the kind of

pollution involved. See Mr. Dressler's e-mail of October 19, 2007: "Our monitoring equipment does not

measure the toxicity of particulates; it measures the concentration of particulates in the air. On an annual

average basis, we measure slightly higher concentrations of PM10 in our more urbanized areas. We only

measure PM2.5 in Santa Maria and Santa Barbara and we measure slightly higher concentrations of

PM2.5 in Santa Barbara."

See Mr. Dressler's presentation of August 27, 2007, to CPA's Comprehensive Planning Committee:

"To date, circulation analyses have failed to demonstrate that increased urban density, achieved by socalled

smart growth principles, has really reduced car and truck traffic (except when density approaches

Manhattan-type levels and is coupled with excellent public transportation)." Quoted from the minutes of

the meeting, kindly edited and approved by the author. It is also noteworthy that a recent expert study of

the subject states as the very first sentence of its abstract: "The debate concerning the impacts of urban

land use density on travel in general, and on residential vehicle use and fuel consumption in particular,

lacks reliable quantitative evidence." See Thomas F. Golob and David Brownstone, "The Impact of

Residential Density on Vehicle Usage and Energy Consumption" (Working Paper UCI-ITS-WP-05-1,

Institute of Transportation Studies, University of California Irvine, February 18, 2005.)

By contrast, some discerning critics of sprawl are aware that exchanging sprawl for urban densification

could yield "paradoxical" results: "On a regional scale, less driving would lead to less pollution, an

improvement that would be especially marked for regional-scale pollutants such as ozone. But on a very

localized scale -- alongside a street in a particular neighborhood -- greater traffic density could increase

exposure to pollutants, especially locally scaled pollutants such as particulate matter and air toxics."

Howard Frumkin, Lawrence Frank, and Richard Jackson, Urban Sprawl and Public Health: Designing,

Planning, and Building for Healthy Communities (Washington D.C.: Island Press, 2004), p.77. The

following quote from the same book (p.76) indicates the need for rigorous site-specific monitoring of air

quality in Santa Barbara: "Investigators in several countries carefully measured pollutant levels alongside

streets and in homes to determine the exposures associated with traffic. One study, in Amsterdam, found

that people who live near busy streets (defined as carrying more than 10,000 vehicles per day) were

exposed to two-to-threefold higher levels of 'black smoke' (a measure of particulate matter), NOx, and

carbon monoxide, compared to people who lived near a less busy street." To compare: Upper State Street

carries more than 30,000 vehicles per day.

10 See, for instance, Christopher C. Daigle et al, "Ultrafine Particle Deposition in Humans during Rest and

Exercise," Inhalation Toxicology (2003), 15:539-552, and J.E.Sharman et al, "Cardiovascular

Implications of Exposure to Traffic Air Pollution during Exercise," Q J Med (2004) 97:637-643.