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November 8, 2002
An Open Letter to Vallejo Residents and Residents of Surrounding, Downwind Communities
Dear Fellow Vallejoans/Neighbors,
I am very concerned about the proposal to bring an LNG terminal (the first on the west coast), a natural gas power plant, a natural gas pipeline, and unsightly transmission lines to Vallejo. Although I have many concerns about the proposed project, I would like to focus this letter on air quality issues.
Bechtel and Shell, the proponents of the LNG project, have been recently submitting full-page ads in the Times-Herald and Vallejonews.com, and sending out glossy mailings implying that an LNG facility would actually "Clear the Air" in Vallejo. Nothing could be further from the truth. These companies are trying to pull the wool over the eyes of the citizens and leaders of Vallejo, and downwind Solano County communties. As an environmental scientist, I would like to set the record straight, and provide the truth about air quality issues, air quality "pollution offsets", and other issues.
What is the Current Air Quality in Solano County and the City of Vallejo?
- According to the United States Environmental Protection Agency (U.S. EPA), the current air quality in Solano County and the City of Vallejo is in the dirtiest/worst 10 percent of the country for carbon monoxide, PM-10 (particulate matter of size 10 microns or less), PM-2.5 (less than 2.5 microns), and volatile organic compounds (in other words, 90 percent of the country has better air quality).
- The air quality in Solano County and Vallejo is also in the dirtiest 20 percent of the country for Nitrogen Oxides (Nox), and Sulfur Dioxide (SO2) emissions (i.e., 80 percent of the country has better air quality for these pollutants).
- These pollutants are the same ones that Bechtel and
Shell facilities would add to Vallejo and downwind communities, should the proposed LNG facilities be built.
- According to the U.S. EPA "Scorecard" for Solano County (developed from the extensive Air Toxics Hot Spots Program and the Toxics Release Inventory), our air at this time is already very dangerous to community health.
- According to the study, at least 390,352 people in Solano County already face a cancer risk more than 100 times the goals set by the federal Clean Air Act (CAA), and 11,198 people in Solano County face a cancer risk more than 1000 times the goals set by the CAA. The CAA was established to protect the public from health impacts to excessive exposure to chemicals. Exposures above recommended CAA levels are considered likely to cause human health impacts.
- Approximately 93 percent of the air cancer risk in Solano County is from mobile sources (e.g., cars and trucks on Highway 80, 37, and other highways). About 6 percent of the current air cancer risk is from area sources (e.g., gas stations, dry cleaners), and 1.3 percent of the air cancer risk is from "point" sources, such as industry.
- The No. 1 air pollutant contributing to excessive cancer risk in Solano County is diesel emissions from trucks and cars on the freeway. Diesel emissions have been listed as a cancer-causing agent by the California-EPA (Cal-EPA) and the U.S. EPA.
- As the Solano County population has rapidly expanded in recent years, freeway traffic has increased significantly, further exacerbating the air quality issues and concomitant health impacts in our community.
- As a result of the high level of cancer-causing and toxic chemicals in our air, Solano County currently has an extraordinarily high respiratory illness rate. This is not an unseen or perceived risk, rather, we see the adverse health effects exhibited, especially in residents of Vallejo and Dixon. Current asthma rates for Vallejo, for example, are 16 percent in children and 14 percent in adults, while the state average is 8.8 percent. These startling rates of respiratory illness have prompted the American Lung Association to conduct a study on the citizens of Vallejo (and Dixon), and air quality issues related to these illnesses.
Consideration of Solano County and Vallejo's current air quality is key for the decision-making about the health and safety risk associated with the proposed LNG facility. This information provides insight into the "Background" level of toxins in our county, and in our communities. As our air quality worsens, we will continue to see more health problems in our county, particularly in African Americans, children, elderly, immune-deficient, and people with heart problems.
What Contaminants will be Added to our "Background" Air Quality if the LNG Facility is Built?
According to Bechtel representatives (City Council meeting, August 20, 2002), if a 900-megawatt natural gas power plant is built in Vallejo, the following air emissions of criteria pollutants should be expected each year for the life of the facility:
- 201.9 tons of Nitrogen Oxides (403,800 pounds)
- 876.3 tons of Carbon Monoxide (1,752,600 pounds)
- 41.7 tons of Volatile Organic Compounds such as Benzene (a known human carcinogen), Hydrocarbons (many known to cause cancer), and Reactive/Precursor Compounds (83,400 pounds)
- 129.6 tons of PM-10 (very detrimental to health, as these particulates readily lodge in the lungs and cause toxic effects; 259,200 pounds)
- 18.3 tons of Sulfur Dioxide (a criteria pollutant that causes acid rain; 36,600 pounds).
These levels of contamination consider only the proposed power plant, and do not consider the transport ships, LNG offloading, regasification facility, dredging, pipelines, trucking, and/or accidents at the facility.
Bechtel and Shell Say They Will use Pollution "Offsets" - Won't These Help the Air Quality in Vallejo and Solano County?
The proposed facility will further degrade the air quality in Vallejo, Solano County, and surrounding, downwind communities. The assertion that pollution "offsets" or "credits" will be used to "clear the air" is misleading and false. In fact, nothing could be further from the truth.
- Should the facility be built, it is correct that pollution "offsets" or "credits" would be required by the Bay Area Air Quality Management District (BAAQMD; the regulatory agency responsible for air quality permitting in the Bay Area). With pollution credits, if a company builds a facility that will increase air pollution, they must offset the additional air pollution in some other place within the 9 counties in the Bay Area.
- As the data discussed above indicate, only 1.3 percent of Solano County's current air quality concerns are associated with industry, and in fact, virtually all of these facilities are downwind of Vallejo. This means that it is very likely that neither Vallejo nor Solano County will be the recipient of the "cleaner air" in any pollution offset swap. In other words, perhaps San Jose or Burlingame will gain cleaner air, while Vallejo and downwind communities will bear the brunt of the additional air pollution, on top of our already excessive and unhealthy air pollution.
What is the Bottom Line?
- Should the proposed LNG facility be built, Vallejo and downwind Solano County communities will experience a worsening of air quality and smog.
- Should the proposed facilities be built, there will be very different air quality issues for Vallejo than for downwind communities. In fact, downwind communities will suffer much worse from air contaminants than Vallejo.
- Because the contaminants from the proposed power plant will be released approximately 145 feet above ground surface, they will not likely make an appreciable difference in the ("nose level") air quality of Vallejo. Rather, air quality issues in Vallejo will primarily be increased as a result of diesel truck traffic for the facility (10+ percent increase in truck traffic), proposed pipeline/turnaround dredging activities (diesel engines), LNG tankers/carriers (three times per week, 14-20 hours offloading, likely diesel engines), and power plant emissions. As indicated previously, diesel emissions have been listed as a cancer-causing agent by the U.S. EPA and the Cal-EPA.
- Because the pollutants from the proposed power plant will be released approximately 145 feet above ground surface, the pollutants will not likely reach ground level for approximately 20-30 miles, depending on weather patterns and climatic conditions. On low wind days, particulates emitted from the facility (i.e., PM-10 and PM 2.5) will settle closer to the source (LNG facility). In our more commonly windy weather, pollution would be carried further downwind. According to Mr. Jim Leahy, Bechtel Corporation, the most significant air pollution impacts will be approximately 30 miles downwind of the proposed facility (Vallejo City Council Meeting of August 20, 2002). As a result, the most severe increase in air pollution ("nose level") and smog will most likely occur in/around Vacaville and Dixon.
- The proposed facilities will emit toxins that will affect all downwind/Solano County communities with respirable particulates (PM-10), smog, respiratory irritants, chemicals that cause acid rain and global warming, and cancer-causing chemicals.
- As the air quality worsens, Solano County, Vallejo, and downwind community members will experience increased respiratory illness and other ailments associated with the air pollution (U.S. EPA, BAAQMD, Cal-EPA, Centers for Disease Control and Prevention, American Medical Association, American Lung Association).
- Solano County currently has several major freeways (e.g., Hwy 80, 780, 680, 37, 29), all of which contribute significantly to our air pollution. It is predicted that Solano County will be the fastest growing county in California in the next 25 years. It is highly unlikely that traffic on any of these freeways will be reduced in the future, and in fact, according to the Solano Transportation Improvement Authority, it is highly likely that Solano County freeways will be expanded and traffic will increase, contributing even more "Background" toxic pollution to Vallejo and downwind Solano County citizens.
- "Background" levels of air pollutants in Solano County/Vallejo already exceed levels considered "safe" by the U.S. EPA, the California EPA, the BAAQMD, and other health experts by up to 1000 times. In other words, Vallejo and Solano County are already in a non-attainment zone for air quality.
- Adding additional source(s) of air pollutants will further increase Solano County's/Vallejo's exceedences of levels considered "safe" by health experts, and will further increase exceedences of air quality regulations.
- Air pollution "offsets" will not help Solano County, the city of Vallejo, and/or downwind communities, since industrial pollution is "traded" with other industrial pollution (not freeways, for example).
- Allowing the proposed LNG/natural gas facilities in the city of Vallejo would not be healthy for the citizens of Vallejo and the downwind citizens of Solano County, and will very likely significantly increase respiratory illness, other illnesses such as cancer, and healthcare costs in our communities, especially for children and the elderly.
In light of all of the available information, why would our city leaders choose to consider bringing another toxic source into Vallejo that would further exacerbate our already challenging air quality and community health issues (i.e., the LNG facility)?
I know that as a community member, you are very interested in reducing our current air quality exceedences, and protecting Solano County and Vallejo community members from further insult in the future.
Please contact the Mayor of Vallejo (707-648-4377: fax 707-649-3479), Vallejo City Council members (707-648-4575), the Vallejo Fire Chief, and members of the Vallejo LNG Health and Safety Subcommittee (707-651-7186; fax 707-645-5289) to let your concerns be known. Tell them in no uncertain terms that we do not want the proposed LNG facilities in our community, and that we have significant concerns about our neighbors downwind.
ir pollution doesn't stop at the city boundaries. Please let us consider ALL of the potential impacts from the proposed LNG facilities.
Thank you for caring about y/our community, and all the communities downwind of the proposed project.
Sincerely,
Gayle Edmisten Watkin
Vallejo
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