December 26, 1994

David Howekamp, Director, Air and Toxics Division

United States Environmental Protection Agency, Region IX

75 Hawthorne Street

San Francisco, California 94105

Re: Ozone Attainment Status for the San Francisco Bay Area

Dear Sir:

The application of the San Francisco Bay Area for designation as an ozone attainment area should be rejected, for the following reasons:

The purpose of the Clean Air Act is to protect the health of U. S. residents, by keeping the air free of harmful chemicals. This is obviously a distant goal that will never be achieved, especially if we slack off our efforts whenever we get close to the goal. The granting of "attainment" status militates against achieving that goal, by reducing funding and giving people the false impression that our air quality no longer poses a threat to our health. In fact, your own research has shown that there is no safe level for ozone! The granting of attainment status is obviously a political goal sought by business interests, and is inimical to our health. Neither the law, nor common sense, require you to grant such status.

Granting (federal) attainment status puts the influence of the federal government in opposition to the interests of the residents of California, who have already declared their wish (in the California Clean Air Act) to reach a stricter standard. What right does the federal government have to deter its citizens from reaching for whatever healthful goal they choose? (However, by failing to impose sanctions on highway construction in California, you have already shown that you don't really care about air quality, but prefer to worry about politics and economics, which are not your mandate.)

Considering the narrow margin by which we reached our ozone goal, it is clear that we made it only because of particular meteorological conditions that transport our air pollutants into the Sacramento, Lake Tahoe, and San Joaquin air basins, contributing to their failure to reach attainment. Slacking off in the Bay Area is extremely unfair to people living in those other areas.

Predictions from the Bay Area Air Quality Management District are that motor vehicle traffic will continue to increase faster than the population growth, well into the next century. This means that we can expect any current air quality gains to be wiped out soon. There is a lower limit to motor vehicle emissions (partly due to auto manufacturers' recalcitrance), but there is no upper limit to VMT.

If you look carefully at the Air Quality Plan proposed by the Bay Area Air Quality Management District, you will see that six of the so-called "Transportation Control Measures" will actually have the effect of increasing air pollution!: (7) we should not be promoting ferries, because they are far more polluting than buses, trains, and bicycles; (8) expanding freeways will obviously encourage increases in VMT, and, hence, in the long run, more pollution; (11) TOS simply adds to the subsidy to the automobile (e.g. free tow trucks roaming the freeways looking for someone to tow!), and does nothing to reduce or discourage motor vehicle use; (12) traffic signal synchronization has never been scientifically demonstrated to reduce air pollution, in spite of what its proponents say (it encourages long-distance driving, just as highway construction does); (18) gas taxes are only beneficial when the proceeds are not used to build more facilities for motor vehicles; ours are used to expand freeways and bridges!; (19) similarly, the "market-based" measures are often used to subsidize more auto use, rather than to discourage it. These are six good reasons why the Bay Area will retrograde in the future.


Michael J. Vandeman, Ph.D.