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Consultant's report,
citing sources, indicates:
Discrepancies and Dangers Underestimated in Publicity around Proposed 100th
Street Bus Stop
From a quick read through the DEA and the associated "Documentation of Satisfaction of the Categorical Exclusion Criteria of the US DOT/FTA":
Both are predicated on the assumed reduction in number of buses from 149
to 144 (present use to projected use) actually assigned to the depot
(see Pages ES-3 of the report and page 7 of the CEC document).
Nowhere do they justify the assumption that 1 standard bus equals 1 articulated
bus on an equivalent emissions basis. That may be the case, particularly
if the articulated buses use advanced emissions control technology, but
they don't justify that assumption.
Elsewhere they use the term "Standard Bus equivalents (SBE)",
wherein one articulated bus equals 1.5 standard buses. By that measure,
the usage for the 100th street station goes up from 149 to 190 (see Table
2 of the report). Your web site says 199 articulated buses, or 300
SBEs. Personnel at the depot admit that the depot would be home
to 200 buses. If nailed down, such a scale of the projected bus usage can undercut
the entire DEA and the "Satisfaction of the CEC"
In any event, the key measure they use to justify the fact that the depot
is exempt from the requirements of NEPA is the number of buses "assigned
to the depot". That may (and likely does not) have much to do
with the number of buses actually using the depot for one reason or another
on a daily basis.
On the air quality front, the DEA addresses only the impact on CO (carbon
monoxide), and is totally silent on the issue of Particulate Matter (PM).
On the health effects, you could be
buried you with the scientific evidence and studies on the subject.
Perhaps the best place for you to start for your present purposes is here:
California is always way ahead of the rest of the country on these issues.
From that web site, you might select the following attached files:
These are fact sheets that anyone can read, so they're useful for distribution.
The California Air Resources Board (CARB) Scientific Review Panel (SRP)
summarized the potential health effects in a document that is full of info
on the health effects of PMs, as well as
hydrocarbons absorbed on the carbon particle surfaces:
Findings of the Scientific Review Panel on the Report on Diesel Exhaust
This is a relatively easy (though somewhat scary) read. You'll
find the SRP report here (attached):
It comments on and endorses as "good science" the CARB's finding with
respect to diesel engine PMs:
All this led to CA's Diesel Risk Reduction Program (DRRP):, which
has a ton more info (main report attached, without all Appendices,
which are available on the website link below:
Note that the SRP report identifies both the California Reference
Exposure Level and the USEPA Chronic Inhalation Reference Concentration
for PMs at 5.0 micrograms per cubic meter, the average CA outdoor exposure
at 2.2, and indoor at 1.5. Compare those values to the Table
4 values for midtown Manhattan of 148 (max in 24 hour period) and 45 (annual
average), and you get some idea of what you're living in. And that's
without a diesel bus depot next door. Which is why the engine technology
they are using to limit PMs (and absorbed PAHs and other hydrocarbons) as
well as the filters they are using on the depot exhaust fans are both critical
items, not addressed anywhere in the DEA except by "motherhood" statements
such as "it won't be any worse than it is now because the number of buses
will decrease from 149 to 144".
There's a ton of info on the same topics on the US OSHA and EPA web sites,
but maybe the stuff above and attached is enough for immediate use, particularly
the CA SRP report.
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