This post describes a proposal we have put forward to Washington State legislators Senator Karen Keiser (33rd) and Representative Jesse Johnson (30th). In one sentence, we want an annual report of all key aviation-related emissions for every neighborhood affected by the operations from Sea-Tac Airport. We refer to this proposal as Sea-Tac Airport Annual Air Quality Monitoring (STAAQM) and we define the affected neighborhoods as ‘airport communities’, specifically the rough boundary of Federal Way in the south to Beacon Hill in the north and east from I-5 to west at Puget Sound.
The need and the challenges
Under the National Environmental Protection Act and subsequent legislation, almost every industry is subject to regular and standardized reporting of various pollutants that may affect the surrounding air, water and ground. Each industry or jurisdiction is given a specific list of pollutants to monitor, with a methodology and schedule. This not only allows regulators to make sure that the area in question is safe, it also gathers valuable longitudinal data. It is used to determine how the place is doing over time, how each site ranks compared with their peers in other places and also the ongoing impacts to health and the environment.
Airports like Sea-Tac, however, are not subject to these requirements when it comes to airplane-related emissions. Unlike, for example, automobiles, there are literally no regulations on emissions from commercial aircraft. And State and Federal law says that if there are no regulations, then reporting is unnecessary. And since reporting is not required by the FAA, measurement of various emissions is rarely done–and certainly not in a manner which would allow for comparisons over time.
This creates a serious Catch-22. It is almost impossible to change Federal or State regulations without clear longitudinal data. It is also very difficult to obtain any mitigation without such data. (You can’t just say to governments, “It’s really polluted here, do something!” without the backing of solid scientific evidence that indicates what to do and how to do it.) But with no monitoring requirement in either State or Federal law how can communities ever hope to obtain such data?
The answer is the STAAQM.
Overview of the proposal
Overall, this proposal is meant to replicate a procedure that occurs at almost every other factory and public facility. For example, consider your Water District, which takes water samples four times a year, measuring hundreds of potential hazards and then provides a report to the public.
Put simply, the STAAQM proposal is to outfit two SUVs with off-the-shelf monitoring hardware and then have an analyst drive it around a prescribed route over a series of days during the year capturing air samples. When sampling is complete, the analyst then writes a standard report summarizing the results. This process is then repeated every year using the same protocol. For an idea of how mobile sampling is done, please refer to the UW DEOHS MOV-UP report.
The proposal actually requires two bits of business from the State legislature: A budget proviso and a law.
A budget proviso is a request that the money be included in the State Budget. In this case the ask is from the Capital portion of the budget for the hardware . We are hoping to get this passed in the 2021 Budget.
The ‘law’ piece of the puzzle is also simple, but requires a bit of explanation. Once you get the equipment somebody has to agree to
- Take possession of the gear
- Run the annual study.
The agencies that normally would do this need to be directed to do so by the State under the State Clean Air Act RCW 70.94. Due to COVID-19. Unfortunately, there is no room on the legislative calendar for this until 2022 .
So the game plan is: budget proviso in 2021, then the legislative directive in 2022. This gives us 2021 to purchase the hardware and write the study protocol and then begin monitoring in 2022 immediately after passage of the directive.
Some notes on the gear
This is actually not a new idea. The system is modeled on a mobile system already in used the Bay Area Air Quality Management District (BAAQM). Page 25 has a picture of their equipment which is similar to this proposal. The article demonstrates how far the science has moved from the ‘traditional’ (and very expensive) fixed-site systems to much less expensive mobile systems which are also far more flexible. This is all off-the-shelf kit and in fact, some of the required hardware was already used by UWDEOHS to do the 2018 MOV-UP Study.
Parking the van
The first consideration is to determine the equipment and design the annual study. That work has already been undertaken by the University Of Washington Department Of Environment And Health Sciences (DEOHS), the same team that has conducted almost every major air quality around Sea-Tac Airport for the past twenty years. Their proposal will be the basis for the Budget Proviso this year.
But once you have the gear, you need someone to take possession of it and then actually do the work every year. And they have to be an entity that is not only recognized as unbiased, but also legally obligated to do so with an official direction to do so by the State. The logical first choice is Puget Sound Clean Air Agency (PSCAA) since they are tasked with monitoring and regulating air pollution in our area and are linked to both the State and Federal Environmental Protection Agency.
Paying the dues
And last but not least, any agency like PSCAA will rightly ask where the funding will come from for the annual studies. You can buy all the testing equipment you want and you can even get permission to park it. But no agency will support this proposal without a guarantee of ongoing funding.
The annual study fees would likely not be huge (perhaps $50,000) so funding could come from a shared pool by the airport cities (as has become commonplace with various airport-related projects such as the Clean Air For Kids indoor air quality proposal Rep. Tina Orwall is championing). There are even options for private funding from charitable foundations which have offered to do so in the past.
However, one new option comes from the Federal Aviation Administration Section 190 program starting this Spring, which allows airport communities to apply for grants of up to $2.5 million focusing on mitigation. We have already gotten support from Congressman Adam Smith to further an application from our airport communities. If approved this grant would not only fuel the annual studies, it would also give State lawmakers a further incentive to vote for the initial Budget Proviso (it’s easier to vote for Part I, if you’re confident that Part II is taken care of.)