Action Alert, Please do this before Wednesday!!!

California State OHV Park

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tomjeeps2
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Action Alert, Please do this before Wednesday!!!

Post by tomjeeps2 » Tue Nov 15, 2011 12:15 am

http://cal4wheel.com/action-center
Here is summary information and links:

SUMMARY

The San Luis Obispo Air Pollution Control District (SLO APCD) Board will vote at 9 a.m. Wednesday on whether to adopt a "Fugitive Dust Rule". The APCD avers that PM10 concentrations exceeding the CAAQS 24-hour standard (50 ug/m3) are from off-highway vehicle (OHV) recreation at Oceano Dunes. In the ensuing public media controversy, residents have been inflamed and alarmed stirring them to attend meetings wearing dust masks and blaming all sorts of respiratory illnesses on OHV recreation. In federal terms, PM10 violations only reach "Yellow/Moderate" on the EPA's AQI scale (which is below the "Orange/Unhealthy for Sensitive Groups" category). Oceano Dunes is the ninth most popular state park and received 1.7 million visitors last year.

The proposed Dust Rule 1001 stems from the release of the "Phase 2 Dust Study" released March 2010. This Phase 2 study was authored primarily by air district staff (an air specialist), but one component was completed by Dr. Cahill of the UC Davis Delta Group, and another by Great Basin Unified APCD (Owens Valley).

MAJOR CONCLUSIONS OF THE APCD "PHASE 2 DUST STUDY"

•The primary source of high PM is the open sheet sand dunes on the coast
•Sand dunes subject to OHV activity emit significantly greater PM than "undisturbed" sand sheets under the same wind conditions
•Vegetated dune areas do not emit wind blow particles. The "control site" had significantly higher vegetation coverage than the OHV area.



APCD Phase 2 Particulate Study
(Executive Summary begins on page 7)
http://www.slocleanair.org/pdf/PM2-final_report.pdf


CONFLICTED AND NON-EXPERT PEER REVIEW
An article I wrote detailing peer reviewer issues discovered so far:
http://dunefacts.com/slo-apcd-dust-stud ... incestuous



MAJOR CONTENTIONS REGARDING PHASE 2 DUST STUDY

CONTENTIONS OF DR. WAAGE (PISMO BEACH CITY COUNCIL)

•The study assumes wind speeds measured at the CDF fire station (1-2 miles inland) are representative of wind speeds on the dunes. A new meteorological site installed in the dunes indicates wind speeds are 70% higher than the CDF fire station. Trees and geography interfere with the CDF site.
•The one year study period erroneously used 13-months for comparing PM10 concentrations. The overlapping month was March which is during the windiest period of the year. This flaw resulted in about 25% higher PM10 concentrations when the study compared the 50 highest park attendance days to the 50 lowest park attendance days.
•Different size/shape of sand dunes between OHV area and natural dune "control site" were not considered. Using a simple Gaussian plume dispersion model, one would expect 60% higher PM10 concentrations due to size, shape and distance from the monitoring location used.



CONTENTIONS OF MINE
The dust study asserts OHV activity causes de-vegetation of the dunes and destroys "the natural crust on the dune surface".

•The study presents one single photo and two paragraphs regarding the existence of "crust" (page 82 of the final report). The California Geological Survey writes in their "Evaluation of Phase 2 Dust Study" (see below, page 2), "there is no 'stabilizing crust' in the dunes". When I wrote one study author, the reply was, "I do not consider myself an expert...this question would be best answered by a sand dune morphologist with local expertise." Another author replied, "little is known...it appears to form in the presence of moisture, but when crushed appears to be just sand".
•The study compares only two photos from 1979 and 2005 (page 106 of the final report) to support the de-vegetation claim. In fact, the "re-vegetated" photo presented is an area that was artificially planted by the park.
•I personally found and obtained never before seen aerial photos from 1930, 1939 from a University image library which were used by the California Geological Survey (see below, "Analysis of Wind, Soils and Vegetation Acreage", pages 17-18) to show there is more vegetation now than ever.
•I also personally found documents in the State Archive and 1934 vegetation maps that prove hundreds of acres of invasive dune grass was historically planted to control blowing sand.



CONTENTIONS OF CALIFORNIA GEOLOGICAL SURVEY (CGS)
No geologist participated in the dust study. These comments from state geologists have been mostly disregarded.

Evaluation of Phase 2 Dust Study
http://ohv.parks.ca.gov/pages/25010/fil ... Phase2.pdf

Analysis of Wind, Soils and Vegetation Acreage
http://ohv.parks.ca.gov/pages/25010/fil ... igures.pdf

Additional documents
http://ohv.parks.ca.gov/?page_id=26656


CONTENTIONS OF CALIFORNIA STATE PARKS
Comments on the Draft Rule and documents from the state
http://ohv.parks.ca.gov/?page_id=26918


MY ARTICLES

Air District Failed to Release Raw Study Data (then released encrypted PDF)
http://dunefacts.com/slo-apcd-failed-to ... study-data

Air District Manipulates EPA AQI Air Forecasts
In one of my best presentations to the APCD Board, I reveal a +5.8 point AQI forecast bias. Stunningly, the air district admitted to adding 5 points on purpose.
http://dunefacts.com/nipomo-mesa-air-fo ... anipulated

Getting to the Facts About Dunes' Dust
Historical quotes about blowing dust in 19th century.
http://dunefacts.com/getting-to-the-fac ... dunes-dust
The Country is ran by the few that show up.
They are lead by the even fewer that step up.

http://WWW.TEAMSTEALTH.ORG Noise issue information.
http://WWW.OHMVR.COM Total Off Road Recreation!

Tom Tammone

SLORider
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Location: San Luis Obispo, CA
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Re: Action Alert, Please do this before Wednesday!!!

Post by SLORider » Wed Nov 16, 2011 1:25 pm

THE COMMENT PERIOD FOR THIS IS NOW CLOSED.

The meeting is in progress now. Visit DuneFacts.com for details on the outcome of the vote.

THANKS FOR ALL SUPPORT ON THIS.

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