Sunday Commentary: Addressing the Issue of Air Quality at Nishi

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

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About The Author

David Greenwald is the founder, editor, and executive director of the Davis Vanguard. He founded the Vanguard in 2006. David Greenwald moved to Davis in 1996 to attend Graduate School at UC Davis in Political Science. He lives in South Davis with his wife Cecilia Escamilla Greenwald and three children.

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15 thoughts on “Sunday Commentary: Addressing the Issue of Air Quality at Nishi”

  1. Michael Bisch

    “After all, the two biggest issues – the issue of traffic impacts on Richards and the issue of lack of affordable housing – appear to be addressed with the new proposal.”

     

    Not true. The biggest issue remains…Nishi is a development project.

    1. Howard P

      You may be onto something… heard a rumor that there is a CUP in process for a new place of worship in Davis… devoted to the worship of the Goddess, “Stasis”…

      One of the primary tenets of this religion is that, “no matter how terrible things are, any change would be worse.”

      Notably, the dates usually used for worship are on Tuesday and/or Wednesday evenings, with high Holy Days on the first Tuesday after the first Monday, in June and November (disclosed in the application)… the CUP application was leaked to me by a confidential informant, and I need to protect my source(s)…

      1. Tia Will

        Howard

        Some may call that goddess “stasis”. Some may call her “equilibrium” or “balance”. Some may not worship at all but prefer an objective, rational planning approach over ad hoc decision making depending on which way the political/business winds are blowing in the community.

         

  2. Roberta Millstein

    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

    You have no basis for this claim, since not only students (who often take more than 4 yrs to graduate) could live there, but also grad students, postdocs, young professionals, etc.  Anyone, really.  For as long as they pay rent.

    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.

    This is not accurate.  On one of the days, the PMs were high.  But that was not the day of the highest measurement.  Those were the weekend days when the traffic is the worst.  So, we don’t have the worst case scenario.  This is all in the Barnes study, not a “belief.”
    Also, traffic has gotten noticeably worse since 2015, so those “worst-case” days might now be the norm.

    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.

    Right, because the freeway isn’t elevated there (pollutants travel farther) and it’s not directly adjacent to where the freeway goes from 6->3 lanes, causing braking and release of particulates.

    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.”

    For some unknown reason (bias?) you continue to focus only on the cancer risk.  So, let me quote again, as I have done here in comments before, from the Bay Area’s air quality ordinance:

    ” Scientific studies show that exposure to particulate matter from air pollution leads to significant human health problems, including: aggravated asthma; chronic bronchitis; reduced lung function; irregular heartbeat; heart attack; and premature death in people with heart or lung disease. Exposure to air pollutants that are carcinogens can also have significant human health consequences. For example, exposure to diesel exhaust is an established cause of lung cancer.”

    Why do you continue to ignore these other health risks?

    Instead, they believe the baseline increased cancer risk is “approximately 197 in one million.”

    This isn’t what they “believed.”  This is the # they calculated based on a model — not using the measurements that they actually input.  In any case, Bay Area uses 100 as the standard, and we are clearly well about that.

    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.”

    Right — so what goes is their “estimate” if it doesn’t take into account relevant causal factors?

    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?

    We don’t know.  There were so many things left out of the original study that I don’t think we can say what the worst case is.  But we ought to account for all of the health risks (not just cancer) when we do figure it out.

    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.

    You don’t actually know this.

    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.

    Well, from the current study we already know that the PMs change drastically from weekday to weekend.  What we need are values.

    Some preliminary studies have shown that people spend most of their time, when home, indoors.

    With their windows closed?

    Combine that with a very limited time exposure of one to three years, and there is believed to be little risk.

    Believed by whom?  On what basis?  Your reasoning leaves out so many relevant factors that your “belief” is worth nothing.

    I would start with understanding the actual health risks rather than more monitoring.

    We can’t know the actual health risks without more monitoring.

    1. David Greenwald

      Two points Roberta:

      I believe primarily students will live in this apartment complex, but to your point, I think we need to establish what the baseline risk is at given levels (time) of exposure

      That leads to my second point, you mention all of those health risks, what are the quantifiable risks and over what period of time.  I have focused on the cancer risk because we have a number, is there a number for the other risks?

      1. Roberta Millstein

        I would like that information as well.  At one point, I thought I might pore through all of the peer-reviewed literature that Dr. Cahill has provided and try to determine those numbers.  But that is a huge undertaking.  I may still do it, if I can find the time, but I also think that it shouldn’t be incumbent on me to get those numbers.  The City should be seeking out that information to make sure that we are not building something that harms the health of its citizens.
         

        But again, I’d reiterate that the Bay Area legistators found all of the risks to be signficant.

        1. David Greenwald

          Fair enough for the most part.  The only point I would add is that the 200 per 1 million risk is deemed to be significant, which is fine, but it does to my thinking reduce the significance of the significant label (so to speak).

    2. Richard McCann

      Roberta, all of the populations you list as potential tenants are the most likely to be highly transient with short tenancies in Nishi. On the other hand, the health risk studies assume 30 to 70 year exposures, 24 hours per day. The risk comparisons are not commensurate–they need to be adjusted for the relative risk of different resident populations.

      As for “open windows,” yes, most people stay inside with closed windows. But even further, this transient population is most likely to reside their during the fall to spring when its cooler and the windows are much more likely to be closed in any case.

      As to the suggestion that an office park be put there instead, I can’t imagine how that’s going to change the health risk in a positive way. Almost all students are over 18 and therefore legally have the same adult status as the office park employees. And many of those employees will be only a few years older. Is there some bright line division that I’m missing?

      Finally, Eileen Samitz is proposing that UCD build on two parcels just on the other side of I-80, one placed between 80 and the railroad at the intersection of 113. Doesn’t that seem to be identical with air quality health risk?

      1. Roberta Millstein

        Roberta, all of the populations you list as potential tenants are the most likely to be highly transient with short tenancies in Nishi.

        What is your evidence for this claim?  As a “young professional” in the Bay Area, I live in my first apartment for 9 years.  Moving is a pain in the neck and there can be various penalities for moving.

        On the other hand, the health risk studies assume 30 to 70 year exposures, 24 hours per day.

        It depends on which health conditions you are talking about.  This is not true for, e.g., lung conditions, and it is not true for people who already have health conditions (and young people may have these without knowing it), and it is not true for pregnant women.

        The risk comparisons are not commensurate–they need to be adjusted for the relative risk of different resident populations.

        We need to have a standard by which we say, “this is not acceptable.”  We should not say that because people are already exposed to risks we should expose them to even more risks.  We can do better than that.

        As for “open windows,” yes, most people stay inside with closed windows.

        Really?  What climate do you live in??

        But even further, this transient population is most likely to reside their during the fall to spring when its cooler and the windows are much more likely to be closed in any case.

        Again, what climate are you in?  Our windows are open every night, and often open during the day in the spring and fall.

        As to the suggestion that an office park be put there instead, I can’t imagine how that’s going to change the health risk in a positive way. Almost all students are over 18 and therefore legally have the same adult status as the office park employees. And many of those employees will be only a few years older. Is there some bright line division that I’m missing?

        That is not “my suggestion.”  I think the risks would be fewer, given time spent there and given that offices tend not to have windows that open at all, but I have not advocated for an office park.

        Finally, Eileen Samitz is proposing that UCD build on two parcels just on the other side of I-80, one placed between 80 and the railroad at the intersection of 113. Doesn’t that seem to be identical with air quality health risk?

        Sorry, why are we talking about Eileen’s views here?  In any case, as I have said repeatedly, there are characteristics that make Nishi particularly dangerous from an air quality point of view — it is directly adjacent to where the lanes go from 6 to 3, so there is often braking in that area, releasing fine particulates; the freeway is elevated there; and the land is bowl-shaped, so that particulates will get trapped during inversion.

  3. Todd Edelman

    Some preliminary studies have shown that people spend most of their time, when home, indoors. 

    Yes, those open windows… and also the gardens right next to the 80.

    much cleaner indoors than a lot of the existing structures along Olive Drive.

    Developer makes deal to equip everything else on Olive with filtration?

     

     

    1. Howard P

      Give even one miniscule reason why the Nishi, or any other developer, should

      equip everything else on Olive with filtration

      Why don’t you finance that?  By same logic, you should consider that a moral imperative!

      1. Tia Will

        Roberta

        I fully respect your desire to rely on best evidence to support your concerns. I also respect your desire to provide a safe environment as I share that goal. There are some areas in which I believe that you are over playing your hand to your own detriment unless you are willing to accept unsubstantiated fears along with your legitimate claims.

        1. “since not only students (who often take more than 4 yrs to graduate) could live there, but also grad students, postdocs, young professionals, etc.  Anyone, really.  For as long as they pay rent.”

        To assess how much of a factor this is, we would need two pieces of information that we do not and will not have. 1. The average length of time spent in similarly located, similar housing types and what effect disclosure ( which I favor) would have. 2. The length of time necessary at a similar location to see the statistical increase in each condition of concern. We will not have these necessary pieces of information, so speculation one way or the other is just that, speculation.

        2.”Those were the weekend days when the traffic is the worst.  So, we don’t have the worst case scenario.”

        We actually do not know that. With only a 10 day sampling we don’t know whether a longer sampling period during differing times of the year would result in better or worse findings than in the limited sampling.

        3. “With their windows closed?”

        In Davis, during much of the year when the temperatures rise into the 90s and higher, yes, with their windows closed.

        Other points that your concerns do not address:

        1. How much of the worsening traffic is due to an increased need to commute ?

        2. How much reduction might there be in these particulates with less driving of single vehicles which might be provided by increased housing near the university ?

        3. While looking at health risks, maybe we should also consider traffic safety and other risks of driving such as its impact on a sedentary lifestyle with increased obesity, Type II diabetes, cardiovascular disease. Public health should never be reduced to looking at a single statistical parameter.

  4. Roberta Millstein

    Tia,

    1. “since not only students (who often take more than 4 yrs to graduate) could live there, but also grad students, postdocs, young professionals, etc.  Anyone, really.  For as long as they pay rent.”
    To assess how much of a factor this is, we would need two pieces of information that we do not and will not have. 1. The average length of time spent in similarly located, similar housing types and what effect disclosure ( which I favor) would have. 2. The length of time necessary at a similar location to see the statistical increase in each condition of concern. We will not have these necessary pieces of information, so speculation one way or the other is just that, speculation.

    In making statement #1, I am responding to those (such as David and Richard) who say we need not worry about health impacts because people will only be living for a short time.  I agree with you that we don’t know the “average length of time spent in similarly located, similar housing types and what effect disclosure would have”.  So, proponents of Nishi shouldn’t go around making statements that they do know how long people will be living there.  As for disclosure (which I also favor), SF has tried it but also has no data about whether it actually works — whether people are keeping their windows closed.  As for the length of time necessary for each of the health conditions, right, we don’t know those numbers precisely (and probably never will) but there is evidence for short-term effects and not just long term, as David has been claiming.

    2.”Those were the weekend days when the traffic is the worst.  So, we don’t have the worst case scenario.”
    We actually do not know that. With only a 10 day sampling we don’t know whether a longer sampling period during differing times of the year would result in better or worse findings than in the limited sampling.

    Well, as you know I agree with you that we need more sampling throughout the year.  But it is pretty striking that on a clear air day the particulates would spike exactly when the traffic does.  Of course, we’d have more confidence about that with more data.  But given that the particulates were high on a “bad” air day and high on a “good” air day with braking, logic dictates that we need to take measurements on bad air quality days with traffic to see the worst case scenario.  If that’s not what the data show, then we’ll have to revise our hypotheses.  As always.

    3. “With their windows closed?”
    In Davis, during much of the year when the temperatures rise into the 90s and higher, yes, with their windows closed.

    Not in the evening and at night.

    Other points that your concerns do not address:
    1. How much of the worsening traffic is due to an increased need to commute ?

    The worst traffic is Thurs and Friday evenings, with Wed and Sat not being great either (you can confirm this on Google Maps) — so that looks like Tahoe traffic to me.  If it were commuting traffic it would be the same every weeknight.

    2. How much reduction might there be in these particulates with less driving of single vehicles which might be provided by increased housing near the university ?

    Given my response to #2 — not much.  (I would also instruct commuters to head north on 113, not fight their way up I-80).

    3. While looking at health risks, maybe we should also consider traffic safety and other risks of driving such as its impact on a sedentary lifestyle with increased obesity, Type II diabetes, cardiovascular disease. Public health should never be reduced to looking at a single statistical parameter.

    I’m all for that.  But when study after study shows worse health outcomes for people who live near interstates, and when we have mechanisms for those outcomes (e.g., effects of particulates on lungs) we need to pay attention.  And if we have reason to think our freeway is worse than others (and we have some reason — again, we need more testing which is why I have been advocating for that since before the last vote), then we should pay attention and make decisions accordingly.

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