Rockland County Conservation Association

P.O. Box 213 - Pomona, NY 10970
Non-Profit Organization - Founded 1930

October 27, 2003 Public Hearing-Nyack, NY Sponsored by: NYS Assemblyman Ryan Karben and Rockland County Legislator Harriet Cornell

	The Need for On-Site Air Monitoring Analysis in Rockland County, New York
Comments:
	The Rockland County Conservation Association (RCCA) has a history of speaking out on issues of importance to the quality of life in Rockland for well over seventy years. The challenges to the quality of air in our community are vast and we have on many occasions brought to the attention of the public and authorities our concerns. The US Environmental Protection Agency (EPA) rates the air that we breathe in Rockland County as being in a "severe" ozone non-attainment area. We are confounded by the lack of on-site air monitoring in Rockland County, by New York State Department of Conservation (DEC). So we wonder, and ask why?

	Clearly a model of every source of emissions within the region would be an impossible task. However, we believe that the assumptions that are used to model our air quality do not truly reflect the total load in order to produce an accurate analysis. Mountans, through an inversion phenomenon trap many of the emissions produced by power plants and vehicle exhaust. Mountains define much of Rockland's boundaries. Several power plants exist and operate and the stream of taillights on the NYS Thruway is infamous to those cutting through the Ramapo Mountains. Given the many known pollution sources and mountains in Rockland the lack of on-site air monitoring is an even greater curiosity to us. So we wonder and ask why?

	Most recently, as an active intervenor in three NYS Article X power plant applications, RCCA expressed overwhelming concern for the additional burden of emissions to our already compromised air shed. As a not-for-profit, entirely volunteer organization we found ourselves in a difficult position of having to raise funds to support a legal fund to support our challenge that the siting of these plants would stress our water and most important our air quality. One of the great challenges was the need to hire experts to testify that the air models used in the applicants proposals were based on inadequate air dispersion models. Oddly enough, they were using NYS DEC air modeling data. We sought experts with renowned prominence such as Dr. George Thurston, Dr. Bruce Egan and Dr. William Snyder, who testified that the data did not truly reflect the conditions in Rockland. So we wonder and ask why?

	Why should the residents of the smallest county in New York State have to challenge their right to breathe clean air? Time and again industry standards compromise air quality. Permitted standards cut short the life expectancy of our most sensitive population, our young and our elders. Power plants built prior to 1977 are grandfathered in and are not required to meet more stringent guidelines. The coal burning Lovett Power Plant in Tomkins Cove is one such facility within Rockland's borders. According to 2001 Rankings reported by the Environmental Defense Scorecard, it ranks within the Dirtiest/Worst facilities in the United States. Orange & Rockland Utilities was recently fined by the NYS Attorney General for failing emissions standards during its operation of the facility. It continues to belch emissions into our lungs and our air quality is not monitored by NYS and so we wonder and ask why?

	On June 27,1990 Betty Hedges, President of RCCA presented comments during the 1-287 Public Hearing in Suffern, NY. Issues raised included concerns for the conflicting information on the impact to the Ramapo River and wetlands, lack of information regarding seismic risk, request for greater review of hazardous waste sites and the inadequate air analysis of the area. In 1991, Betty and her husband Ira along with several other RCCA members, Harry Leigh, Faith Leigh, Malcolm T. Wayne, Elly A. Wayne, and Eleanor Burlingham joined in case No. 91-6072 with The Village of Grand View, The Village of South Nyack, The Village of Tarrytown, The Tappan Zee Preservation Coalition, Inc. and S. Hazard Gillespie seeking to require further review of a 1988 revision to highway interchange 1-287 which was concluded in 1982. The UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT affirmed that... "the impact of the redesigned Interchange on regional traffic patterns will be minimal, they were justified in not explicitly addressing "cumulative" impact of that redesign and essentially independent and unrelated developments upon the possible future addition of a span to the Tappan Zee Bridge."

	Well, we in Rockland know that traffic conditions have changed since 1982 and so has the knowledge and understanding of pollution and resulting adverse health effects. What hasn't changed is the lack of on-site air monitoring in Rockland County. So we wonder and ask why?

	The Tappan Zee corridor is foremost in upcoming development projects. Plans to develop the Stewart Airport into a major air traffic hub will assuredly increase the traffic coming through. Yet further development is being planned without the base knowledge of the cumulative study of our air quality. Credible analysis nets credible results. Yet we in Rockland are averaged in a data bank of similarities. Emission reduction credits are exchanged through the Ozone Transport Assessment Group (OTAG) for a chance at breathing cleaner air. Averaged though it may be. So we wonder and ask why?

	Scientists and health professionals reveal to us that the risk factor of adverse health outcomes increase with exposure to fine particulate matter caused by pollution. Development patterns in Rockland have increased, so too environmental burdens and the incidence of pollution related disease. Thresholds of sustainability are being challenged as evidenced by our near water supply crisis. Increased traffic and development compromise our quality of life. Without accurate base assessments of pollutants to our air shed inappropriate development will prevail. In order for Rockland to sustain the pressures of development the permitting process must be based on accurate assessments. On-site air monitoring is the most basic need to this process.

	Industry standards should never trump moral standards. Air monitors will not ease a child's pain when gasping for air as a result of pollution related asthma but they sure could reveal what pollutants are filling the air. Corrective actions can only be pursued with understanding of the problem. A cumulative emissions inventory of Rockland through air monitoring is long overdue and necessary to facilitate smart growth, in order to address the many development demands.

	Thank you for the opportunity to express our concerns. Dorice Madronero, vice-president Rockland County Conservation Association, Inc.