Wednesday, June 2, 2010

Doing my homework

At the end of the last Portland Air Toxics Solution (PATS) Advisory Committee meeting, a woman who had waited patiently in the visitors gallery through the 6 –hr meeting, stood up to address the room.  The public is allowed to attend the meetings, but speaking and asking questions for anyone other than committee members is restricted.  She must have felt strongly about what she wanted to say.

She introduced herself as Kate McCutcheon, the environmental manager at Blue Heron Paper.  The Oregon City company has a mixed record of environmental compliance, incurring fines in the last 10-15 years for air and water infractions.

While Ms. McCutcheon was addressing the room, I did get the strange feeling she was directing her comments at me. Making eye contact, she said, “any one who questions the air toxic benchmarks hasn’t done their homework.”

The air toxic benchmarks or ABC’s (ambient benchmark concentrations) are the metrics introduced by DEQ as the framework that PATS will be utilizing to measure air toxic reductions.  Since most if not all of the air toxics being discussed exceed the benchmarks, it is reasonable to assume that getting them below those benchmark levels will mean a reduction of toxic air pollution in the metro air shed.

But it does not necessarily mean that the air quality will be safe, or vulnerable populations within the metro air shed, like our children, will be safeguarded from adverse health effects due to exposure to toxic air pollution.  This is because the ABCs are annualized average concentrations of air toxics that do not reflect the risk of exposure to spikes and toxic hot spots, like those people who live near large industrial sources of toxic emissions or in low income housing along freeway corridors. And as individual concentrations they do not address the synergistic effect of these toxics are when mixed together.

Unfortunately, Ms. McCutcheon, I have done my homework.  And this leads me to realize that the benchmarks will not address what I, and hundreds of parents have come to realize about the dangers lurking in the Portland air: industrial pollution contaminates the airshed of every school in the Portland area, every one –except one- of which ranks in the nation’s worst 30% of schools at risk.  In fact, 65 schools rank among the worst 10% in the nation due to proximity to large sources of toxic air pollution.  The worst of these schools, including seven in Northwest Portland and three campuses in North Portland, list manganese as the air toxic of most concern.  Yet we are told that the Portland area and the polluters that emit this neurotoxin are already in attainment of the newer stricter manganese benchmark.

And I am not the only one to have done the homework assignment.  Over 40 concerned citizens who recently attended the Air Toxics Benchmark Hearing on May 18th  came to address the same concerns: do these benchmarks adequately safeguard public health from the hazards of air toxics, especially spikes in emissions that at times have been recorded in fenceline monitoring to exceed the benchmark by 300x, yet would not be reflected in an annualized average.

At the same hearing, Commissioner Williamson said what most have come to suspect:  “when it comes to large sources of industrial pollution, the best remedy has been direct negotiation between neighbors and the company through a good neighbor agreement.” In other words, the state won’t help you, you are on your own to address the issue of spikes and toxic hot spots. He unfortunately offered no insight as to how a community gets leverage against industry, which has the backing of well-funded powerful lobbyists, and which operates within a state regulatory framework that has allowed the proliferation of sacrificial zones of toxic hot spots, by adopting metrics and calculations that ensure compliance of permitted air emissions limits by relegating them unenforceable.

While I acknowledge that there is a solid body of science behind the benchmarks, the problem was in the question, not the answer.  The Air Toxics Science Advisory Committee (ATSAC) was not asked to determine what is the safe level of the neurotoxin manganese exposure to children, which as scientists Dr. Brodsky (OHSU), Dr. Carmen (Texas Air Commission, and Lone Star Sierra Club), and Maye Thompson, PhD (Oregon Physicians for Social Responsibility) would say is zero to minimal.  Instead they were only asked if the science supported the reduction from current benchmark to the lower one. 

We need to reframe the question.  What health metric can be used to inform the regulatory process?  Anything that maintains the status quo is not genuine, and threatens to provide a false pretense to the regulated community that they are compliant and do no harm.  The status quo says that almost every Portland school is at danger due to toxic air pollution.  The status quo says that Multnomah county, and Oregon, lead the nation in excess rates of cancer due to toxic air pollution.  Nobody should be allowed to put dangerous air toxics in our common domain, and claim that they are not part of the problem.

This Thursday, June 3rd is the next meeting of the PATS advisory committee.  DEQ has scheduled three hours to discuss the benchmarks.  Ms. McCutcheon can be assured that I, and others, will have questions. 


  1. Thank you for doing your homework, for paying attention, and for representing Portland communities. In addition to the state, I believe the City of Portland and Multnomah County should bear some accountability for protecting citizens.

  2. Thank you for voicing our concern and frustration, and our very real fear for our children and ourselves.

  3. Thanks to both of you, and all the others, who have been willing in the last 12 months to write a few letters and send the emails. We are having an impact.