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Letter Regarding Particulate Monitoring
July 24, 2007
To the Members of the Gallatin City-County Board of Health:
The July 19 presentation made by the Montana Department of Environmental Quality provided some important information about air quality monitoring in the Gallatin Valley. However, it also raised some serious issues that relate to public health in our valley. As members of Montanans Against Toxic Burning (MATB), we are very concerned about the potential health impacts of using waste fuels and feeds in the Holcim Trident cement kiln. We feel that it is critically important to closely monitor air quality, given the DEQ's stated intent to issue an air quality permit to Holcim allowing it to burn more than 1 million tires annually and to continue its use of lead smelter slag as a substitute for iron ore in its cement-making process. To that end, we strongly urge the members of the Board of Health to advocate the following positions.
DEQ should resume PM 10 monitoring at both the Belgrade and Bozeman sites.
- Road dust, mining disturbance, and industrial emissions contribute to PM 10 emissions; all of these are significant factors in Gallatin Valley's air emissions.
- Serious health impacts result from PM 10, not just PM 2.5. DEQ has not provided an adequate justification for ignoring a large spectrum of particulate emissions in the Gallatin Valley.
- DEQ has cited a lack of resources for discontinuing the monitoring of PM 10 in the Gallatin Valley, yet the Department conducted monitoring in much leaner years. Moreover, the Department recently received a significant increase in its operating budget.
DEQ should monitor PM emissions continuously, not just every 3 days.
- Increased, not decreased, monitoring is warranted, since the Gallatin Valley is the fastest growing area of the state, and its air quality is deteriorating, not improving.
- Eight other cities in Montana currently have continuous, not intermittent, monitoring for particulate emissions. Only some of these cities are non-attainment areas for PM. We can find no rule that precludes DEQ from conducting continuous monitoring in an area that is not yet a non-attainment area.
A more appropriate site is needed to accurately measure air quality in Bozeman.
- The new site for Bozeman lies outside city limits.
- The new monitoring station is distant from significant sources of PM pollution within the city of Bozeman.
Without appropriate monitoring, there can be no meaningful enforcement of the federal regulations enacted to protect public health. The current DEQ monitoring regime seems designed to underestimate potential air quality problems in the Gallatin Valley. To protect public health, we must thoroughly gather the appropriate information so that we can craft effective solutions.
Thank you for considering our concerns in this important public health issue.
Sincerely,
Jennifer Swearingen, for Montanans Against Toxic Burning
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