BAAQMD Monitoring Data Summary

ALSO SEE: Health Risks in Dispute

• Nickel levels averaged 12 ng/m3, above the level that is a significant cancer risk according to the World Health Organization. The EPA Reference Concentration (RfC) for manganese is 0.00005 mg/m3 based on impairment of neurobehavioral function in humans. This is equivalent to a concentration of 0.050 micrograms per cubic meter, or 50 nanograms per cubic meter.
• The Air District measured 24-hour manganese concentrations on 32 different occasions from 31 December 2007 to 29 June 2008. On 8 occasions, the 24-hour manganese concentration exceeded the EPA RfC of 50 nanograms per cubic meter.
• The Air District measured 24-hour formaldehyde concentrations on 56 different occasions from 14 December 2007 to 27 October 2008.The arithmetic mean for ambient levels of formaldehyde was 1.63 micrograms per cubic meter. This concentration is more than twice the concentration that might result in a one-in-a-hundred thousand increased chance of developing cancer. This level of cancer risk is considered a serious regulatory matter by most environmental and public health agencies.
• According to the data it provided, the Air District measured 24-hour benzene concentrations on 56 different occasions from 1 January 2008 to 8 November 2008. The arithmetic mean for ambient levels of benzene was 0.73 micrograms per cubic meter. This concentration is more than the concentration that might result in a one-in-a-million increased chance of developing cancer. This level of cancer risk should also be a significant regulatory concern.
  
• Mn and Ni levels were strongly correlated with iron levels (correlation coefficients > 0.8). Formaldehyde levels were moderately correlated with iron levels (correlation coefficient of 0.69).

Source: Global Community Monitor
Denny Larson, Executive Director, Global Community Monitor
PO Box 1784, El Cerrito, CA 94530

On March 13, 2008, the San Francisco Bay Area Air Quality Management District staff reviewed and affirmed the "data and Standard Operating Procedures" for the community's West Berkeley Air Monitoring Project. Now more than a year later, the District's director, Jack Broadbent, has decided to lash out at our citizen science project. His actions are an attempt to discredit the community's results and more importantly, to shield the District from growing concerns (both locally and nationally) over Pacific Steel Casting emission levels. The recent data analysis (See above) offered by Global Community Monitoring (GCM) of the District's own air monitor (at Sixth and Camelia Streets) has only reaffirmed the finding of the Community's Monitoring Project. Once again, the Air District is allowing the politics surrounding the monitoring of west Berkeley industrial emissions to be used to stonewall the truth about West Berkeley's unhealthy air quality. Shame on the Air District and Berkeley's Mayor Tom Bates!

February 26, 2009
Mayor Tom Bates
City of Berkeley 2180 Milvia Street, 5th Floor Berkeley, CA 94704

Re: Global Community Monitoring Air Monitoring Project in West Berkeley

Dear Mayor Bates,

This letter is to review the Bay Area Air Quality Management District's (Air District) recent experience with a grant awarded by the Air District to Global Community Monitoring (GCM), led by Mr. Denny Larson.

The Air District has a longstanding commitment to collaborate with communities on air quality issues. We value community groups as key partners in educating the public and in improving air quality in the Bay Area. The Air District funds and coordinates collaborative air quality projects through eight resource teams throughout the Bay Area and in the past year has provided close to $400,000 in support of community-based activities. The grant awarded by the Air District to GCM for an air monitoring project in West Berkeley was awarded in this collaborative spirit.

Our recent experience with Mr. Larson's work through this grant has taught us that as stewards of public trust and public resources, we must be cautious when moving forward with community-based projects, just as we must be careful with any project paid for with Air District funds. It is our duty to ensure that results are technically reliable and do not result in public misinformation. Over the course of GCM's project in West Berkeley, our staff discovered serious technical deficiencies in Mr. Larsen's work. Based on our own expertise in air quality monitoring, data analysis, and risk assessment, we have concluded that Mr. Larsen's findings are not technically valid and have resulted in misinformation provided to the public. Some of the Air District staffs concerns are listed in an attachment to this letter.

Air District staff alerted Mr. Larsen of these deficiencies during the course of the project. Unfortunately, Mr. Larsen chose to release his erroneous findings to the public nonetheless, and did so without Air District review or consent, both conditions of the grant award. Regrettably, the community was further misled through a statement released by Mr. Larsen on the monitoring project which he mischaracterized as a joint statement from the Air District and GCM.

We are disappointed that the Air Monitoring Program in West Berkeley conducted by GCM resulted in poor quality work and unnecessary public consternation. As stewards of public funds, we feel it would be irresponsible for the Air District to fund further projects by Global Community Monitoring or Mr. Larsen.

Despite this setback, we continue to believe that working with communities on air quality issues is of critical importance. Our staff will continue to pursue collaborative efforts with interested Bay Area residents and community groups, with the aim of improving air quality and public health for all Bay Area residents.

If you have any questions regarding this issue, please contact Jean Roggenkamp at 415-749-4646.

Attachment: Deficiencies Identified in GCM Air Monitoring Project

ATTACHMENT Deficiencies Identified in GCM Air Monitoring Project as claimed by BAAQMD GCM did not submit a complete monitoring plan for Air District approval prior to commencement of monitoring, as required by the grant agreement. GCM failed to properly perform quality control per the grant agreement. GCM did not designate fixed monitoring locations, moved monitoring locations, and did not operate monitors on a regular schedule. In order to use monitored concentrations to develop risk estimates, monitors must remain in a fixed location for at least one year, in accordance with accepted scientific practice. Because 0CM moved their monitor often, no data was collected at any location for at least one year. GCM's worksheets submitted to the Air District had data errors. Worksheets had mathematical errors that were identified and corrected by Air District staff, and returned to the grantee. However, similar errors continued to occur in subsequent worksheets submitted by GCM. GCM released information to the public without Air District review or approval, in violation of the grant agreement. The information contained errors and drew inappropriate conclusions. For example, because data was not collected for an entire year at a single location, GCM's comparison of the data to chronic risk values was inappropriate. GCM publicly released an altered version a statement previously approved by the Air District, mischaracterizing it to the public as a joint statement about the monitoring project