EPA’s failure to regulate ultrafine particulate emissions producing cancer soup of urban air

The ambient air you and I are breathing is more dirty and more dangerous with every passing year. Transportation system emissions from combustion of gasoline and diesel increase in proportion to the number of vehicles on the road and the gallons of fuel being burned. The chart below records the gasoline sales per day in Kentucky coming in at more than 800,000 gallons.

In the 5 county KIPDA area including Jefferson County I roughly estimated (based on 2030 anticipated 33 million reported miles traveled per day) we’ll use 2.2 million gallons of gasoline combusted each day.  Multiplied  times $ 3.60/ gallon = $ 7.92 million dollars per day on fuel  = $ 55.44 million per week on the high end. We spend four times as much on fuel as on Metro government services per week. (Total Metro Government services costs $ 12.8 million per week; thats  $ 1.82 million per day  (total 2013-2014 budget of $ 666,463,200). Based on those calculations residents and businesses spend at least = $ 2.9 billion per year in the KIPDA area on transportation fuels.

Obviously a powerful market that will be defended by its operators at all costs and will wield political influence at every turn in our American system of democracy. That political influence has captured the EPA which is sitting on its hands and refusing to go forward with necessary UFP emissions standards because the transportation engineers and gasoline dealers can’t take the hit, and are refusing to convert to the next generation of hydrogen or electric vehicles that don’t spew cancer soup but which would drastically reduce fuel sales.

A low emissions light rail system that reduced 10% of the fuel market would subtract $ 290 million per year from the

KIPDA dealers pockets and would be opposed in political forums if it ever came close to a vote. Opposition to light rail is more about protecting $ 290 million dollars in fuel sales or a 10% share of the market than on any rational argument against lowering emissions and providing transit options.

A recent study by the transportation sector funded - HEI Review Panel on Ultrafine Particles, titled Understanding the Health Effects of Ambient Ultrafine Particles, reviewed 42 articles published since 1997 and  issued a, ‘more research needed’ assessment of UFP health impacts.

“The unique physical properties of UFPs, their interactions with tissues and cells, their potential for translocation beyond the lung—have led scientists to expect that UFPs may have specific or enhanced toxicity relative to other particle size fractions and may contribute to effects beyond the respiratory system. However, the considerable body of research that has been conducted has not provided a definitive answer to this question.”

PM 10 big particulate                                                        

5 large PM 10 particulates in a cubic centimeter of air that is otherwise clean. EPA regulates and limits ambient air concentrations of large PM 10 emissions particulates.  Newer diesel engines remove large emissions particulates using high pressure fuel injection technology and ignition timing computer controls. Exhaust filters capture larger particulates. The technology is hyped as ‘clean diesel.’

Ultrafine particulate cancer soup

The combustion emissions carbon and organic carbon particulates don’t disappear, they are  ‘downsized’ into ultrafine particulates  which are not detected by current EPA mandated testing procedures. Ignition timing and ultra-high pressure fuel injection engine designs are producing ultrafine or ‘nucleation mode’ particulates. The result is a cancer soup of below detection limit UFP.

My seat of the pants estimates  (please correct me)

1 million KIPDA area vehicles with a replacement rate of 10% per year = 100,000 new vehicle sales per year.  Estimate 100,000 vehicles cost average of $ 18,000 each =  $ 1.8 billion of vehicles sold per year in KIPDA town. Light rail alternatives that reduce vehicle sales are not politically favored.

Low emissions light rail that  reduces 10% of the vehicle market would be opposed in political forums if it ever came to a vote. The entrenched transportation market elites are making huge profits off the present cancer soup systems and are fielding and electing political candidates at the local and state level that are 'correct' on these issues (conservative, anti-environmental)  The fuel and vehicle market makers have plenty of funds to PURCHASE democracy. Those politicians appoint and control the regulatory agencies who have slowed the advance of regulation based on present scientific understanding of emissions impact to a crawl. EPA has spent millions on UFP research since the 1990s, but no regulations have been promulgated to set NAAQS standards.

2.2 million gallons of fuel combusted each day in 5 county KIPDA area  times $ 2.88/ gallon price from refiners to resalers = $ 6,336,000 per day cost to dealers.  $ 7.92 - $ 6.33 = about $ 1.6 million per day profit on fuel sales in KIPDA area or $ 580 million profit per year for the people selling us gas at retail. Just 1% of those profits pooled is $ 5.8 million to spend on public relations and political contributions in the KIPDA area.

Cars cost KIPDA area residents about $ 6 billion per year to fuel, drive, replace and insure but not including repairs, parking costs, speeding tickets.

The transportation system costs too much, to an increasing number of lower middle class and impoverished familes, wastes too much fuel on discretionary trips for low priority errands, and the cancer soup emissions exceed the capacity of the airshed to store the pollution without climate change effects.

We are in the throes of opening our eyes to the reality that the combustion fuel transportation system has to transform to a low or no emissions mobility plan. Market titans are not ready to abandon the cancer soup system that is filling their pockets.  

IPCC Climate Change Chart

Bridges Consultant traffic demand numbers

The TOD Time of Day model output was used to provide a system‐wide comparison of the alternatives"

CDM Smith forecasted for the 5 county KIPDA area a daily vehicle miles traveled in 2030 of 33 million vehicle miles traveled each day. That would be more than a million vehicles driving somewhat less than 30 miles every day.

33 million miles divided by 15 miles per gallon gives 2.2 million gallons of gasoline combusted each day.  That means every day in KIPDA town in 2030 we fill up 3.5 Olympic-sized swimming pools with fuel and set fire to them.

We do this in order to commute to work at the Big Box Warehouse for less than a living wage, or go to Grease Burger to buy a double cheese burger with bacon--important trips.  When people have a car in the driveway, they use it rather than walking two blocks.

Millions of such trips per day causing release of huge amounts of combustion emissions in the KIPDA area day after day. Not counting the emissions from jet aircraft engines at the Worldport that can equal 500 vehicles for each take off and landing cycle. 

This mind boggling excess and poisonous waste that is killing us and our environment is strenuously defended  as ‘good business’ and vast public funds are appropriated to support and rebuild its infrastructure  year after year. We are merely one such community following the same pattern out of millions globally. Henry Ford was such a stupid 'get,' to paraphrase the Beatles.

630,000 gallons of water fit in an Olympic-size swimming pool. 

See, the Steer Davies and Gleave Traffic Group 

Louisville-Southern Indiana Ohio River Bridges Traffic & Revenue Study  Final Report  August 30, 2013

Total Louisville Bridge crossings 2010 were  226,700 per day  Total crossings 2012 were  224,300 per day--a drop of 2,400 cars per day all crossings from 2010 to 2012-- a 1.05 % decline in 2 years.

Exposure to urban cancer soup UFP - you are what you breathe

A study from 2009 in London collected samples of urban air as people walked and biked along busy traffic routes. The peer reviewed journal article reported that traffic emissions were the source of high levels of ultrafine particulate exposure. The chart above shows that a typical cubic centimeter of air a pedestrian breathes can contain a range of from 36 thousand to 87 thousand ultrafine particulates along sidewalk routes. The highest samples collected were from bus passenger exposure that ranged between 70 thousand to 140 thousand UFP per cubic centimeter of air.  Walking showed the lowest exposure in the study. Vehicle passengers and drivers are in the direct path of UFP emissions traveling in roadways. The ultrafine particulate soup coats the lung tissue with cancer causing chemicals on particles so small they cross the cell membranes and enter the blood stream.

“For the ultrafine particle counts, the mode of transport was the fixed factor variable, and wind speed, temperature, and traffic flow were the covariates. There was a significant difference in ultrafine particle count levels experienced on the different modes of transport after controlling for the covariates. Mode of transport was the strongest determinant,

followed by traffic count, temperature,and wind speed, which explained respectively approximately 13, 12, and 6% of the variability in ultrafine levels.

The study found personal exposure could be lowered by traveling on  roads with less traffic.

Kauer et al, Determinants of Personal Exposure to PM2.5, Ultrafine Particle Counts, and CO in a Transport Microenvironment,

VOL. 43, NO. 13, 2009 / ENVIRONMENTAL SCIENCE & TECHNOLOGY 

Cancer Soup from vehicles

Mutagens from combustion emissions are widely distributed regionally according to a peer reviewed study-- Pedersen et al, Human Cell Mutagens in Respirable

Airborne Particles from the Northeastern United States.  Quantification of Mutagens and Other Organic Compounds. Environ. Sci. Technol. 2005, 39, 9547-9560

“Human exposure to respirable airborne particles (<2.5 ím in aerodynamic diameter; PM2.5) is associated with increased risks of cardiopulmonary and lung cancer mortality.”  [T]he finding that unsubstituted-PAHs and oxy-PAHs are important mutagens in the RO, KS, and QB samples suggests that combustion emissions, many of which contain high levels of PAHs(54-56), are significant sources of mutagens in PM2.5, and that their distribution is similar across the entire region.”

National transportation policy setting the course for climate catastrophe

A cabal of state governors, state transportation officials, investment banking interests, transportation engineers, suppliers, manufacturers and labor interests amounting to an all but unstoppable bi-partisan lobbying force is set to draft the next funding legislation for highway infrastructure.

Continuing a series of meetings to set objectives, on November 21, these groups will meet in The Liaison Capitol Hill Hotel Metropolitan Ballroom in Washington DC in a program titled:

National Transportation Infrastructure Summit to Address Threats to U.S. Economy Including Congestion, Unreliability and Funding

As spelled out in a September 25 meeting of the Senate Committee of the Environment & Public Works, chaired by California Senator Barbara Boxer, the objective is to find “sustainable funding” for the Highway Trust Fund, the federal piggy bank that provides billions of dollars in financing for state and bi-state transportation related projects across the country. The Highway Trust Fund has been operating in the red, spending $ 14 billion more annually than it accumulates in revenues from gasoline taxes. The Trust Fund has had bailouts from the General Fund to the tune of some $ 55 billion dollars and needs another $ 100 billion for the next five years.

The cry to raise national revenues to put the Trust Fund in the black is supported by the fear that decaying national infrastructure is putting the driving public at risk. One in four of the nations bridges is functionally obsolete, Boxer said.  What is not being voiced in the bi-partisan pow-wow is the collision course of national transportation policy with limits to carbon emissions globally.

The self interested marketplace forces, the transportation -industrial complex (TIC) knows that it has the political power to get legislators to approve massive funding for the Trust Fund that provides huge revenues into state highway projects. This is a massive jobs project that has two troubling aspects. First, transparency. Major projects that go through the federal funding NEPA process are getting fast track changes to the NEPA law that will be coming forward in the funding bill. Measures that weaken NEPA obscure both the disclosure of actual environmental impacts and the true cost of projects. Public-private partnerships using federal fund guarantees bloat into longterm toll financed mega projects that commit rich and poor alike to daily fees to use the transportation system. The once ‘freeway’ will become a ‘tollway’ with annually increasing toll fees. In Louisville, Kentucky, the tolled two bridges project will feature annual increases in toll fees for at least the next 46 years and a bloated Tolling Authority of bureaucrats that costs as much as a new bridge itself.

Democrat Barbara Boxer

The massive funding in the Trust Fund bill will be diverted --much of it--into the pockets of bankers and financiers, who convert paid-for projects into longterm revenue funds for bureaucratic fee collection authorities that produce nothing except bills and penalty fee collection. The major infrastructure being built is a rentier class that rents out our national transportation infrastructure to us. No one is calling for full transparency and comparison of costs in the Barbara Boxer Trust Fund project.

Second, Global Climate Change.

The TIC members are overwhelmingly about protecting the market share of automobile manufacturers and dealers and their national gasoline appetite that consumes (and burns) some 360 mIllion gallons of gasoline per day. The federal Energy Information Agency says:  In 2011, the United States consumed about 134 billion gallons of gasoline, a daily average of about 367.08 million gallons.  Burning a gallon of gasoline with 10% ethanol produces about 17.68 pounds of CO2.

The 2013 Warsaw Climate Change Conference now underway in Poland is citing the urgent need for countries to enact policies that consider and adapt to the potential for global climate catastrophe caused by human transportation and power emissions. No Highway Trust funding legislation should go forward without an integrated climate change adaptation scheme that cuts out annual combustion of 134 billion gallons of gasoline substantially over the life of the funding measure. It is national suicide to pledge billions of bloated federally backed financing to the national highway system that is spinning up killer tornados, catastrophic storm surges and ultimate climate change catastrophe for the near term profits of the auto industry and fuel markets.

The crisis makes the U.S. Highway Trust fund legislation a pivotal, potentially fatal, policy decision. Right now all that is on the table is “sustainable funding” not a “sustainable planet.”

One logo missing in the Move Louisville consultation

On January 13, 2014 in the TARC headquarters at Union Station on Broadway, the City of Louisville  hosted a public consultation process to introduce the agenda and some waypoints on the path to producing a transportation project plan for Louisville. As explained by the Mayor’s representative, Patti Claire, the public map marking process would produce some priority projects to be submitted to KIPDA for inclusion in the TIP-Transportation Improvement Program list of state and federal funded projects.

At the front of the slide presentation, the consultant introduced some fuzzy concepts underlying project selection such as ‘connectivity’ and sustainability. There was no discussion of automobile numbers in the community or projection of numbers of vehicles by decade. The future of transportation in the community has a lot to do with whether car dealers continue to sell tens of thousands of vehicles per year to add to the local fleet. One slide did predict that the urban core would lose 20,000 residents and the outside Gene Snyder highway area would gain 170,000 by 2050. That urban sprawl style of development could only be based on automobile fleet expansion.

The City did not include concepts of social justice  as a basis for planning or maps showing the striking pattern of race and class segregation in Louisville. In response to a question the consultant said they had been hearing a lot of input that one part of the city was unemployed and needed transportation to another part where the jobs were.

The approach in the slide presentation was lacking in a lot of the gritty details of Louisville’s actual transportation context. Bits of insight came out through several audience questions. For instance upon questioning as to why FORD Motor Company was not participating in the Move Louisville  consultation, Claire said they were in discussions with FORD in another segment of the TIP preparation devoted to freightways.

The major corporate shipping and manufacturing businesses are meeting separately to get the future of transportation in Louisville they want. The public is walled out of that discussion.

In that other discussion, the trucking operations may be getting the things they are seeking such as multi-million dollar public funded road projects that serve freight connectivity purposes and suck up federal funds that would be available for public transit projects.

Public transit in the form of a light rail project was high on the list of a number of attendees. The excavation of buried streetcar rails and reconstruction of a streetcar line was mentioned by several speakers. The consultant seemed to place all these ideas in the same pot on an equal basis without relating them to the social justice aspects or greenhouse gas emissions of various modes. A great service would be done by describing the operating life emissions of a streetcar line versus a busy street full of cars in a particular corridor.  

The city has been admitting that this listening project has produced numerous calls for establishment of a light rail or streetcar line. But such ideas have been smothered in the cradle before. Louisville is the home of one of FORD Motor Companies major car and truck manufacturing centers. Its doubtful that local political leaders will advance a light rail mode that conflicts with FORD’s Future of Mobility concepts. Those include science fiction concepts of connected ‘smart cars’ that organize themselves into tight packed ‘trains’ moving as one down concrete tollways.

A consultation with reality is overdue. Continued expansion of automobile culture will give us a post apocalyptic future of food riots, war and famine for the many and fortress enclaves for the few.

TARC Headquarters Union Station

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