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
1
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.
2
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
3
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."
4
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."
5
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.
6
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
7
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."
8
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.)
9
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.