Dear Supervisors and Planning Department:
As I will not be the Great Basin Air Pollution Control Districtí’s Air Pollution Control Officer on December 30, 2014, the date of the rescheduled hearing on the Eastern Sierra ATV Adventure Trails Project, I am submitting these comments on the project for the record.
The Great Basin Unified Air Pollution Control District is the regional government agency that works to protect the people and the environment of Alpine, Mono and Inyo Counties from the harmful effects of air pollution.
As its Air Pollution Control Officer, it is my responsibility to enforce clean air laws to ensure that our people and environment are protected.
These comments from Great Basin regarding the proposed Eastern Sierra ATV Adventure Trails Project address only the potential air quality impacts of the proposed project. Others have or will weigh in on the other positive and negative impacts caused by the proposed project.
As the Air Pollution Control Officer, I have no opinion as to whether or not Inyo County should approve the Adventure Trails Project. My only concern is the project ís the impact on our air quality.
As required by law, Inyo County conducted an analysis of the environmental impacts of the Adventure Trails Project. That analysis identified a number of potentially significant environmental impacts and the project requires mitigation measures to reduce those impacts to less than significant levels.
However, the County’s own analysis concludes that, even with two proposed air quality mitigation measures (reducing speed limits and dust ìknock-offî grates within one-half mile of residences), the Adventure Trails Project will have significant unmitigated impacts to air quality. In fact, air quality is the only resource area that the County’s analysis shows ongoing significant environmental impacts from the project.
When discussing the environmental impacts of air pollution, ìnsignificant environmental impacts actually mean impacts to human health. These are not impacts to plants or animals or cultural resources or soil or water. These are impacts to our most vulnerable residents ór our youngest, our oldest and our sickest residents.
In the 24 years that I have been with Great Basin, we have done so much to reduce air pollution in the Eastern Sierra. We have controlled wood smoke in our communities; we have paved roads and parking lots; we have adopted agricultural practices that reduce air pollution on our farms and ranches; and we have nearly controlled the dust from our dried lakebeds. Yet, we continue to have days in Inyo County when we are exposed to air pollution that exceeds state and federal air quality standards. This air pollution impacts all the communities in Inyo County.
We cannot undo this progress and threaten the health of any of our residents that live on or near the proposed ATV routes by approving a project that has any significant air quality impacts. You probably read the letter in the December 2, 2014 Inyo Register from the California Association of 4-Wheel Drive Clubs supporting the project. It agrees that the project will have significant impacts air quality impacts, but concludes that the air quality issues noted are not in excess of existing air quality issues. This statement is untrue; air pollution is additive ór more air pollution equates to more impacts. These significant impacts cannot be ignored by county decision-makers.
The proposed project will increase local sources of air pollution where people live, work and play. As such, it will have adverse impacts on their health. Unless or until Inyo County modifies the project to reduce all air quality impacts to less than significant levels, I would implore your Board to not approve the project. Direct your staff to work with Great Basin to develop real mitigation measures that reduce all air quality impacts to less than significant levels, even if it means modifying the scope and requirements of the project.
To not do so will mean that you did take all reasonable precautions to protect our health. That would not only be the wrong thing to do, but would also mean that the project will inevitably be doomed through litigation.
Please do the right thing for everyone that breathes. Thank you.
Theodore D. Schade, P.E.
Air Pollution Control Officer