Summit County Citizens Voice

Air quality, environmental justice sections unfinished

The EPA says the environmental justice section of CDOT's I-70 plan needs beefing up.

By Bob Berwyn

SUMMIT COUNTY — The EPA this month weighed in on a draft plan for I-70 improvements, concluding that the environmental study omitted some important information about environmental justice, as well as  localized air quality impacts from tailpipe emissions, tabbed as “mobile source air toxics” in agency jargon. Read the EPA comment letter here, or in the Scribd.com window at the end of this story.

The comments aren’t a red light, or even a speed bump, just a reminder that all aspects need to be considered in project of this magnitude.

The Colorado Department of Transportation recognized the issue in the draft programmatic environmental impact statement for the I-70 plan,especially in the Vail Valley and between Silverthorne and Idaho Springs, where topography and heavy traffic combine to concentrate pollutants, including ultrafine particulates, black carbon, oxides of nitrogen and carbon monoxide. Click here to read a story about the draft plan.

A significant amount of research suggest that people living within 200 meters (about 600 feet) of highways run an increased risk of developing asthma, as well as reduced lung function in children. Research also suggests an increased risk for pulmonary and cardiac mortality for people exposed to highway pollution on a regular basis.

As a result, the EPA is calling for more site-specific studies in subsequent tier 2 evaluations, as the highway department plans on=the-ground projects like interchange improvements or new lanes.

Another glaring hole is the lack of any monitoring whatsoever for particulates in the project corridor. Commenting on the 2003 version of the I-70 plan, the EPA recommended ambient air quality monitoring in the corridor before construction in order to develop some baseline data. At issue are the standards for PM10 and PM 25, referring to two different size thresholds for particulates. Those fine particulates generally don’t come from tailpipe emissions but from re-entrained road dust, according to the EPA.

The EPA also expressed concern about potential impacts to water quality, especially with regard to the plan to use a Colorado general stormwater construction permit for stormwater discharge. According to the EPA, that level of permitting won’t adequately protect aquatic resources in the I-70 corridor. Instead, the agency called for site-specific permitting for larger projects that may contribute to a violation of water quality standards.

The EPA also restated its concerns about impacts to streams that are already listed as impaired. The federal agency wants a CDOT commitment that the project won’t do additional damage to streams that are already hard-hit by traction sand and other impacts.

And in keeping with a stronger emphasis on environmental justice, the EPA said CDOT’s I-70 study “does not adequately address low-income and minority populations for the purpose of analysis of programmatic alternatives.”

Environmental justice addresses the issue of whether low-income and minority populations carry a disproportionate share of the environmental impacts associated with a project. To use a specific example related to air quality issues, the question the agency has to ask is whether the low-income residents in Dillon Valley, for example, will take a big hit in air quality impacts as a result of I-70 improvements without having a chance to comment on the draft study.

The EPA comment letter specifically singles out Gypsum, Avon, Dillon, Silver Plume and the Lawson/Downieville/Dumont areas as having minority communities that should have been identified in the draft study. The EPA acknowledged that CDOT has done significant outreach, but points out that the draft study defers identification of minority communities to the Tier 2 analysis “making it more difficult to discuss details of potential (environmental justice) impacts at the PEIS stage …”

Learn more about the EPA and environmental justice by reading these two Summit Voice stories:

Environmental justice in the Rocky Mountains

EPA wants input on environmental justice plan

Links to all the CDOT documents are online here.

http://www.scribd.com/doc/43487836/EPA-Comments-on-I-70

Filed under: air quality, Environment, I-70, Summit County Colorado, transportation Tagged: | air quallity, CDOT, Colorado Department of Transportation, Environmental justice, EPA, I-70, Particulate, Summit County, Summit County Colorado, Summit County News, transportation, United States Environmental Protection Agency