February 3, 2009

 

 

 

Mr. Roderick Bremby

Secretary of Health and Environment

Kansas Department of Health and Environment

Curtis Office Building

Suite 540

1000 SW Jackson Street

Topeka, Kansas 66612

 

RE:   EPA’s consideration of ozone non-attainment designations that might include Lawrence and Douglas County, Kansas.

 

Dear Secretary Bremby:

 

The City of Lawrence and Douglas County have become aware that the Kansas Department of Health and Environment (KDHE) Bureau of Air Quality has recommended to the U.S. Environmental Protection Agency (EPA) that Douglas County should not be a part of the Kansas City non-attainment region.

 

Our staff has studied the eleven factors used by the EPA for determining a modification of an air quality boundary. The City of Lawrence and Douglas County agree with the KDHE recommendation that Douglas County is not a significant contributor to Kansas City’s air quality problem. We agree with KDHE that it would be inappropriate at this time to include the City of Lawrence and Douglas County in any possible 8-hour ozone non-attainment area within the Kansas City regional area primarily for the following reasons:

 

  1. Documented Ozone Monitoring: Ozone monitoring at the City of Lawrence Airport, located north of Lawrence, between 2004 through 2006, documented that our ozone levels were below the EPA limit of 75 parts per billion (ppb). The air quality monitor was removed in 2006 because of State budget issues.

 

      2.   Power Plant Equipment Upgrade: The Westar Energy Center, located north of Lawrence, is in the process of upgrading their air pollution control equipment which will significantly reduce nitrogen oxide and subsequent ozone levels. The Westar Energy Center is the only major point-source facility in Douglas County.

 

      3.   Documented Wind Directions:  Wind direction data from the City of Lawrence Municipal Airport, located north of Lawrence, documents that the vast majority of wind direction within Douglas County is blowing from south to north. Only a minimal amount of wind was documented blowing towards the Kansas City Region from Douglas County in 2008.

 

As a community, we are mindful of the need to be proactive in addressing air quality issues.  We consider it appropriate to take responsible actions through voluntary measures. In fact, public and private sector entities within the community have already voluntarily implemented the following measures:

 

      1.   School Bus emission reduction: The Lawrence USD 497 School District has voluntarily equipped their 90 school bus diesel-powered fleet with emission reducing equipment.         

 

  1. Maximums set on idling: The City of Lawrence has implemented an anti-idling policy that covers all City owned vehicles.

 

  1. Planned coordination/enhancement of publicly operated transit systems: The University of Kansas and the City of Lawrence Transit system are actively working to create an enhanced, more efficient bus system which would promote increased ridership and decrease air pollutants from private passenger vehicles. As part of a November 2008 sales tax ballot question, the City committed to exploring the use of alternative fuels for the transit system.

 

  1. Zarco 66 Earth Friendly Fuels:  Zarco 66 fuel station, located at 2005 Iowa street, Lawrence, Kansas, has received a Green Energy Gateway award for making the first earth-friendly fuel station in the country a reality. The fuel station sells E-85 and ethanol blended gasoline and Bio-diesel fuel blends.

 

At the request of the Douglas County Commission, a Lawrence-Douglas County Air Quality Advisory Committee was formed in 2000 to help approach this issue from a preventive-maintenance perspective. The committee continues to work today to ensure compliance with the EPA’s air quality rules and regulations.

 

We respectfully request that you continue to support Douglas County and the City of Lawrence’s position that Douglas County not be included in any 8-hour ozone non-attainment designation area within the Kansas City region.

 

Respectfully,

 

 

 

 

 

Charles Jones, Chair                                                                      Michael Dever, Mayor

Douglas County Commission                                                       City of Lawrence

 

 

 

cc: Tom Gross, KDHE

cc:  John Askew, EPA

cc: Lawrence-Douglas County Health Board