Letter to Governors -- May 1, 2003

FROM: American Lung Association of Virginia * Audubon Naturalist Society * Chesapeake Bay Foundation * Coalition for Smarter Growth * Earthjustice * Environmental Defense * Fairfax Coalition for Smarter Growth * Friends of the Earth * Norbeck Conservation Society * Piedmont Environmental Council *

Sierra Club * Sugarloaf Citizens Association * Sustainable Montgomery * Washington Area Bicyclist Association

May 1, 2003

Mayor Anthony Williams
John A. Wilson Building
1350 Pennsylvania Avenue, NW
Washington, DC 20004
Fax:  (202) 727-6561

Dear Governor Warner, Governor Ehrlich and Mayor Williams:

We are pleased to hear of your commitment for producing a plan to improve air quality in the Washington area by 2005, and we offer several suggestions. As you know, the air in the Washington, D.C. area is very unhealthy, with 9 Code Red and 27 Code Orange days last summer. This pollution has a major impact on public health, contributing to 130,000 asthma attacks and 2,400 hospital visits every summer, as well as worsening quality of life for children and adults who are forced to stay indoors on polluted days or risk health problems. We need to address these health problems by reducing air pollution as quickly as possible.

The Metropolitan Washington Air Quality Committee (MWAQC) is currently writing a new Severe-Area State Implementation Plan (SIP) to meet Clean Air Act requirements for attaining the one-hour ozone standard by 2005. We are concerned that the new SIP will not sufficiently reduce pollution to meet the one-hour standard, and that it will not contain enforceable measures to reduce emissions from transportation sources.

The new Mobile 6 air quality model has demonstrated that air pollution from vehicles is far worse than previously assumed, adding an additional 50 tons per day of nitrogen oxides (NOx) to our air in 2005 (NOx is one of the pollutants that forms ozone pollution). Yet rather than adopting concrete measures to reduce this additional 50 tons to ensure we meet clean air standards, MWAQC appears likely to simply increase the pollution budget for 2005. We believe this is a dangerous and short-sighted action. Under the Clean Air Act, the region is allowed only an average of one Code Red day per year for 2003, 2004, and 2005; yet we had 9 Code Red days in 2002. Assuming we can meet the standard without major pollution reduction measures is unrealistic. We urge you to direct your air quality staff to include control measures in the SIP to offset this excess 50 tons of NOx. State and local governments must also strive to attain standards earlier than 2005 if at all possible.

We also urge you to include enforceable measures to reduce emissions from transportation sources in the new SIP. Cars and trucks are responsible for about 45% of NOx emissions and about 30% of Volatile Organic Compound (VOC) emissions. State and local governments have an important role to play in reducing emissions from vehicles through improved transportation and land-use planning. Some of the transportation measures that we have urged MWAQC to adopt include: a regional parking impact fee on employers, with exemptions for companies offering transit benefits or parking cash-out; bicycle and pedestrian improvements; exclusive bus lanes; expanded Commuter Choice outreach; and any transit projects that are not conformity-exempt. We are particularly concerned that fleet expansion projects planned by Metro (such as bus or rail car purchases) be included in the SIP as Transportation Control Measures so their funding can be protected in the event of a conformity lapse.

We are disappointed that MWAQC appears unlikely to include transportation measures in the SIP. While some may claim there is no funding available for new clean air transportation measures, we disagree. Some of the proposed measures, such as the parking impact fee, would actually raise revenue. Furthermore, transportation funds programmed for road expansion projects that would worsen air pollution (such as widening I-66, widening I-270, and building the Western Transportation Corridor, Potomac River Crossing, and Inter-County Connector) could be shifted to clean air transportation projects.

While we applaud your call for a new air quality plan, we also find it ironic that you are simultaneously calling for a new Potomac River crossing. A new river crossing would worsen our dirty air by causing more sprawl development and more driving. A better way to improve transportation and air quality in the region is a firm commitment to smarter land-use policies and increased funding for public transportation.

In your efforts to improve air quality, we also urge you to address emissions from new and old power plants in Washington, D.C. and the surrounding area. The older coal- and oil- fired power plants in the area are a major source of NOx pollution, and should be required to install the latest pollution control technology. In addition, emissions from power plants in Virginia and Maryland outside the Washington, D.C. Non-attainment area must be addressed. For example, there are nine proposed or recently approved power plants in Northern Virginia, just outside the Non-attainment boundary. Several new power plants have also been proposed in Maryland. With all of these proposed sources, authorities are not requiring corresponding emissions reductions from existing sources (offsets) or use of the most effective pollution control technologies (Lowest Achievable Emission Rate). Pollution from these plants will impact the Washington region’s air quality, and must be addressed in a regional solution.

cc: The Honorable W. Tayloe Murphy, Jr., Virginia Secretary of Natural Resources

Donald Wambsgans, Program Manager, DC Department of Health

Lynn Y. Buhl, Maryland Acting Secretary of the Environment

Dan Tangherlini, Director, D.C. Department of Transportation
Robert L. Flanagan, Maryland Transportation Secretary

Jim Sydnor, Virginia Department of Environmental Quality

Michelle Pourciau, Deputy Director, D.C. Department of Transportation

Marsha Kaiser, Maryland Department of Transportation

Thomas Farley, Virginia Department of Transportation

The Honorable James Moran

Phil Mendelson, Chair, Metropolitan Washington Air Quality Committee

Peter Shapiro, Chair, Transportation Planning Board

Maryland Allows VDOT to Draft New Bridge Study