On the surface, it might appear that Nishi version 2.0 will have a much easier time of passing than its predecessor. After all, the two biggest issues – the issue of traffic impacts on Richards Boulevard and the issue of lack of affordable housing – appear to be addressed with the new proposal.
The question is how important the issue of air quality – raised during the last proposal – will be for this project.
That is a tough call because there are clearly some unresolved issues, however, between mitigation and shifting the housing from for-sale housing, which would mean long-term residence, to student rental, which means that people will probably live there less than three years – which would seem to reduce exposure to potential air born hazards. But this hasn’t been enough to quell critics of the project.
Last week at the Natural Resources Commission meeting, the commission made recommendations of additional air quality monitoring along with disclosure to residents of the risks.
Critics have pointed to the fact that the previous testing only looked at 10 days, with the belief that they did not look at the days when the particulate matter was high. They also point to the fact that the testing was done at Olive Drive, which was not near the area where residents would be living and therefore data collected there might be unrepresentative.
Other the other hand, the EIR notes, “Long-term exposure to this concentration of diesel PM corresponds to an incremental cancer risk level of 235 in one million above the background level of cancer risk from TACs in the region for residential receptors.”
The EIR continues, “It’s important to note that the data collected during the measurement period are not necessarily representative of annual average pollutant concentration levels or the levels of long-term, multi-year exposure that would be experienced by residents on the project site but are considered to represent higher concentration levels that may be experienced during a year.”
Instead, they believe the baseline increased cancer risk is “approximately 197 in one million.” And explain, “Differences in these two estimates may be because of a number of factors including the meteorology that existed during the 10-day measurement, the potential for ‘linear enhancement’ because the wind direction is often aligned with the orientation of this segment of I-80, the fact that a nearby portion of I-80 is elevated which can result in the highest diesel PM concentrations being further from the freeway than for at-grade segments, and that vehicles often experience congestion along this segment of I-80 thereby generating more emissions than free-flowing traffic.”
So where does that leave us?
I have maintained from the start that the risk factor levels cited, while significant, represent low level risks, especially when compared to lifetime exposure levels. The critics believe that the testing understated the actual level of particulate matter, but I think the first step is not more testing but rather a better understanding of what the actual upper baseline risk actually is.
In other words, if we are simply moving the needle from 197 in one million risk to 150 in one million risk, perhaps we can save the trouble of doing more testing and simply create an interval of risk.
Bottom line, what is the worst case scenario – what’s the health risk if the air quality is much worse than we believe it is at the Nishi site?
Remember too, a lot of the risks are established over a lifetime of exposure, and here we are primarily talking a year, possibly two to three years of exposure.
Second, and I know there is some reluctance to do this, but it seems feasible to do another limited study, on site, over a 10- to 20-day period, making sure to have both weekday and weekend days to see if the particulate matter level changes drastically and whether that would impact the previous assessment.
Some preliminary studies have shown that people spend most of their time, when home, indoors. Remember, for the most part these are apartments without exterior landscapes or yards. The belief is that the new buildings, even with no air filters, will be much cleaner indoors than a lot of the existing structures along Olive Drive. Adding filtration systems will make the air even better.
Combine that with a very limited time exposure of one to three years, and there is believed to be little risk.
To me, if we are going to examine the risk, additional testing is less important than understanding the impact of particulate matter exposure on health and understanding how the duration of exposure plays a role in that.
It is hard to know exactly how deeply this concern comes into play. Will people vote against a project based simply on their concerns about air quality on the site?
A couple of letters to the editor recently come into play.
One suggests: “Please let us not be so morally impoverished as to subject many of our sparkling bright university students 24 hours a day to harmful polluted air at the Interstate 80 braking curve, potentially causing them lifelong allergies, or worse, by constructing beautiful new ‘gingerbread’ apartments at the Nishi site.
“It’s no secret that dying of chronic lung disease is one of the worst ways to go. Surely, our well-educated community will not be willing to jeopardize the health of these very talented students.”
Another states: “(The) sponsors of the Nishi project totally ignored those of us voters who opposed their first try on the basis of air quality on their narrow property. Their new proposal ‘is all about housing, as R&D and office space elements have been eliminated’ (from the new proposal). Housing! Where children will daily breathe in foul and brain-harmful air!
“This narrow property still sits downwind of Interstate 80, exactly where traffic daily slows to a crawl amid idling fumes, and the railroad where diesel-powered engines must slow down. Would you daily expose your 2-year-old’s brain to those toxins — just by inhaling them?
“Offices for research (etc.) would involve people 18 years and older, who can don air masks if they want to. Why not plan Nishi for them?”
There is still a lot of work that can be done to address these concerns and the developers are on notice to take this issue seriously, as it might be the only real barrier at this point to passage. But again, I would start with understanding the actual health risks rather than more monitoring.
—David M. Greenwald reporting