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Honorable Dean Florez, Chair
Senate Select Committee on Air Pollution in the Central Valley
California State Senate
Sacramento, California February 15, 2006
Re: Hearing regarding proposed EPA changes to coarse particulate
regulations
On behalf of the 15,000 members of the Mono Lake Committee, a 28-year-old,
non-profit organization dedicated to the protection and restoration of
Mono Lake, I urge you to mount a strong campaign to stop EPA’s proposed
changes to its coarse particulate regulations.
EPA’s proposed regulation changes will damage public health, the local
economy, and hard-won political solutions to real air quality problems in
California.
Significant dust storms originate on the exposed lakebed of Mono Lake. The
lakebed exposure is a result of decades of excessive water diversions to
the City of Los Angeles. Great Basin Unified Air Pollution Control
District data showed a statistical average of about 3.2 exceedences per
year for the period 1988 to 1992, resulting in the Mono Basin being
designated a non-attainment area by EPA in 1993.
Since 2000, the highest annual 24-hour PM10 values have ranged from 987 to
10,500 micrograms per cubic meter at Mono Lake, far in excess of the 150
μg/m3 standard. The Mono Basin is currently classified as “Moderate”
non-attainment. Virtually all violations of standards can be attributed to
wind-blown dust that originated from the exposed lakebed of Mono Lake.
In 1994, the State Water Resources Control Board implemented a management
plan for the Lake based, in part, on the need to resolve this air quality
problem. In fact, until now EPA has considered the Mono Lake dust problem
to be significant enough that EPA might need to step in and create a
federal attainment plan.
I want to emphasize that Mono Lake is a case study of the damage EPA’s
rule change will cause in California. We had a significant air quality
problem. An answer was found—12 years ago. All parties to the matter,
including Los Angeles, agreed to the plan. The solution is being
implemented. These proposed rules will unravel all that, potentially
reopen legal dispute, potentially jeopardize the management of Mono Lake,
and certainly endanger the health of Mono Basin residents and visitors.
Let me share four specific concerns:
First, dust storms from the exposed bed of Mono Lake have been measured at
up to 10,500 micrograms per cubic meter, exceeding the current standard
many times over.
Local residents have testified of significant dust exposure. Notably,
before the State Water Board, one resident testified about a major storm
in May 1993: “It was as dusty in the house as out of the house. You
couldn't see probably 15 feet with a flashlight. That's how we noticed it.
We were putting up plastic, and we had a light out and stuff. You look
down the living room and it just had a beam of dust and you could taste
it. It was just everywhere.” Under EPA’s proposal, such events would be
subject to no federal regulation.
Second, these dust storms contain minerals that are inherently harmful,
including: arsenic, cadmium, nickel, and sulfate salts.
Third, the notion that rural residents are second class citizens, not
entitled to clean air protection is a major concern and has been discussed
by others. Let me note an irony: while indeed the population of Mono
County is small, its economy is tourism based, attracting hundreds of
thousands of visitors each year. 300,000 people visited Mono Lake alone
last year. Shouldn’t the heath of these visitors—whose numbers exceed the
rural/urban threshold proposed by EPA—also be of concern?
Lastly, this rule is potentially economically devastating for the
community at Mono Lake. Mono Lake is an international tourist destination
and a cornerstone of the local tourism-based economy. This has
particularly become the case since the implementation of long-term
protection for the lake in 1994, including the plan to bring air quality
into compliance. To abandon clean air goals for the Mono Basin is to send
a direct message to tourists that their heath may be endangered by
visiting our area. Of course, this fear will be even further amplified by
the Owens Lake dust storms.
In summary the Mono Lake Committee believes that the proposed rule changes
are hazardous to human health and economically damaging, and destructive
of the successful solutions that have been forged for the long established
air quality problem at Mono Lake.
Thank you for your concern about this very important issue.
Frances Spivy-Weber
Executive Director, Policy
Mono Lake Committee
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