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HomeMy WebLinkAboutStaff Report 5.A 03/04/2019 Attachment 16ATTACHMENT 16 Evelyn Ellis From: Eric Roberts Sent: Wednesday, January 23, 2019 9:24 AM To: Evelyn Ellis Subject: Fw: Please Vote YES on the Safeway Gas Station FYI Eric Roberts, Planning Technician M -Group Consulting Planning Technician Serving the City of Petaluma 11 English Street, Petaluma, CA 94952 Phone: (707) 778-4317 Hours: Monday -Thursday Bam-Spm, closed Fridays From: Kccoon80@gmall.com <Kccoon80@gmail.com> Sent: Tuesday, January 22, 2019 4:09 PM To: mcdonnell4council@gmail.com Cc: petalumaplanning@ci.petaluma.ca.us Subject: Please Vote YES on the Safeway Gas Station ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. -- Message: I am so ashamed to live in PETALUMA anymore. Not only have you all not listened to the voters you continue to do shady things. We need this gas station badly. All of my family which is about 20 drivers, never put gas in their cars in PETALUMA as it is way to expensive. We save about 30.00 a tankful by filling up in either Novato or Rohnert Park. Then since we are there that is where we are shopping. So tons of tax revenue lost by the city. While 1 was growing up and attended McDowell school there was an Exxon, Phillips 66 and the Chevron in that shopping center. We are all fine. Also the bath tubs are hideous and don't belong at the turning basin. Sincerely, Kathleen Coon Name: Kathleen Coon 16-1 Evelyn Ellis From: Cooper, Claire <ccooper@ci.petalurna.ca.us> Sent: Wednesday, January 23, 2019 10:36 AM To: Crump, Katie; Evelyn Ellis Subject: FW: Safeway From: Ken Wollman <kenw1122@hotmail.com> Sent: Tuesday, January 22, 2019 5:24 PM To: - City Clerk <-CityClerk@ci.petaluma.ca.us> Subject: Safeway ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. --- Please include the following correspondence in the Safeway gas station record. Thank you, Ken Wollman From: Ken Wollman <kenw1122@hotmail.com> Sent: Tuesday, January 22, 2019 9:35 AM To: Kathleen Miller<kathleencmilleroffice@gmail.com> Subject: CAUTION - EXTERNAL EMAIL: Re: Please Vote YES on the Safeway Gas Station Kathy, I have read both sides of the arguments for and against this gas station and believe it has been turned into a political football for no good reason. All studies that have been done, which you all have in your possession show that everything possible has been done by Safeway in good faith, with all studies showing no good reason to prohibit a gas station in that location. I dont personally know if It is some environmental group attempting to obtain some huge settlement in order to allow this to continue dragging on for this amount of time or what. But yes, if the City government is going to continue down this path, I am definitely prepared to see a decline in services; but remember it will be you in the long run who will cause the demise of a once beautiful city. Best regards, Ken Wollman I 16-2 From: Kathleen Miller<kathleencmilleroffice@smail.com> Sent: Monday, January 21, 2019 6:08 PM To: kenw1122@hotmail.com Subject: Re: Please Vote YES on the Safeway Gas Station Ken, If you live in Petaluma, you should be aware that we fund city services like public safety and public works with tax revenue. If you are going to spend all your money outside of Petaluma, I hope you're prepared to see a decline in services. Regards, Kathy Miller On Mon, Jan 21, 2019 at 4:43 PM <kenw11Z2@hotmaii.com> wrote: Message: The current obvious price fixing of gasoline in Petaluma has caused me to purchase my gasoline in Itohnert Park. I have also made a conscious decision, that since our City has taken a stand against the more affordable option of allowing Safeway to build a competitive gas station, I will from now on, make all of my purchases for not only gasoline but groceries and clothing outside of this City. I am ashamed of your actions to date. Name: Ken Wollman 16-3 Evelyn Ellis From: Eric Roberts Sent: Wednesday, January 23, 2019 10:56 AM To: Evelyn Ellis Subject: Fw: Please Vote YES on the Safeway Gas Station FYI Eric Roberts, Planning Technician M -Group Consulting Planning Technician Serving the City of Petaluma 11 English Street, Petaluma, CA 94952 Phone: (707) 778-4317 Hours: Monday -Thursday 8am-Spm, closed Fridays o - From: krevlob@gmail.com <krevlob@gmail.com> Sent: Wednesday, January 23, 201910:55 AM To: mcdonnell4council@gmail.com Cc: petalumaplanning@ci.petaluma.ca.us Subject: Please Vote YES on the Safeway Gas Station ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. -- Message: Why does everyone seem to forget there used to be two gas stations in that shopping center before? Was it okay then because all the students were white? What is wrong with a little competition among fuel stations with the government forcing prices up? Name: Christian Vaughn 16-4 M 1 t� y J R 16-5 U -5Z r V v q � o v � r Cl AA It i -1 1 Ilz s3 y J R 16-5 tn 0 u H 0 u e s a ro "Id o [a -- C • U a� ro a tn M Ln V O �+ Q QQ � bOp U U, 00 f3 �°`;v u 48 rC L v N 4 L3 V ro C v a a lu rL .2p r�o 0 w 44 Or- o z •" r' va 16-6 o U � L7 kA kA i 5 S rn a tj 0 • s �- 16-6 10 I CC= 49 4 16-7 c �J 2. y N ~ 'r z. �- CR s r�_ R' to n a �e. U W, Cy vib 16-7 0 0 u ti L M '} 1 U 4 3 Q m Ql to 3. o o$U x v) P ujZ7U U-. L° P L- N O w E N ''> 09 to al U �C mL w w `; A CL oO w s � � a� � o z m c m o c E.g Q m FL 1 16-8 •�`Xy in Q4 r s t T r en M E -Ci 1Afi 16-8 v o co o m ftoM tz L ad = o to —75 0 0 o U _E U ° a E g u E U, 3 eU a2: v tauCL � CYn C � N w ro V 4 CL b O U CL O Ln Cao O z Iu t� ro o v E. a ¢ u 16-9 s I r I J u 16-9 IV In Ir N �roILI LU � N c d a� us E D 78 y 16-10 Wo 0 �i C7 o a cn .o a� w eai m CL ,o g8v w 82 � cua�i.°c c o 3 Oa a -d B H d C N N U U L G 0 f5 =u 2 pia a P b 16-11 i A • ~ fl l- �^ uwj yy 4J .O d 6 f4 C Q1 �� i{aiI C � V 16-11 V) 0 B � M 1 p cd G G ro E- �� o m m m •a o p°0U u ui �• 013 a ci O O 8� OJ — O G O� Lx���� ' 7 N Ln •� u � ro n- G 3•t�u N N k_ ro � � u ea a y0 0-2 cu cn.0 0 • h w.. 0 CLN 02 v - m >_ c ro° Eu V) A Ql CL 0 0 a 16-12 1•N S/ 4 V C � J v z co S 16-12 V+ M, 0 W VU" $ �h Z,d Rj Qj y m -- �U N IO Cy Oar Q O U zu N L4 U o 0 pp�� L � O �V Q Cep ac rr3 a � O a 3 o cn ni d N O CL U pp� s � N =1 p.0 o a a M, 16-13 y .7- H �Q \ v c.� i lu r z ` d cr-- 16-13 Evelyn Ellis From: Tricia Winsemius <nlalaska@yahoo.com> Sent: Monday, January 28, 2019 5:44 PM To: Evelyn Ellis Subject: I oppose the Safeway gas station Do you city council members of Petaluma, I am writing to you again to state that as a resident of Petaluma I oppose the gas station at Safeway. The block across the street is completely dedicated to children and has been for a very very very long time. This fuel station will not help Petaluma, it will only hurt the children. Why won't Safeway do an environmental impact study?,what's the problem with that ?they stand to make a lot of money by putting In a gas station and you think they could spend just a little bit to make the public feel safer. Again I restate I oppose the Petaluma Safeway gas station. Tricia Winsemius Reduce Reuse Recycle Resalel 16-14 Petaluma City Council DEC 3 2018 11 English Street Petaluma, CA. 94952 CITY CLERK RE; Safeway Gas Station Honored members of the Petaluma City Council and Mellow citizens Petaluma absolutely needs this gas station! It will bring healthy competition to a city exploited by extraordinary high gas prices. The price of gas is always $4.25 to $0.50, occasionally as much as $0.75, more expensive a gallon than in any other area of Sonoma Co., save perhaps Bodega Bay. It is often more expensive than in pricy Marin County. Allow the Safeway gas station and watch the price of gas fall as it siphons customers away from the greedy interests that have dominated the market for years. It is high time that the price gouging is put to 'an end, to the benefit of the Citizens of the great City of Petaluma. IS,, ITIZIRW Mill.t t R.R. Ferrari Petaluma Ca, 16-15 Eve l n Ellis From: Cooper, Claire <ccooper@ci.petaluma.ca.us> Sent: Wednesday, January 30, 2019 7:20 AM To: Evelyn Ellis; Heather Hines Cc: Pascoe, Samantha Subject: FW: Safeway Gas Station From: Kerstin Bandner <kerstin.bandner@gmail.com> Sent: Tuesday, January 29, 2019 9:04 PM To: CityCouncil <CityCouncii@ci.petaluma.ca.us> Subject: Safeway Gas Station ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. --- I can not believe you incompetent idiots would allow this neighborhood to be desecrated by this gas station and the small bit of joy that is the greenspace, baseball diamond area, 2 daycare buildings to be overrun with gas stench, lines of cars, etc. Did you even go and visit the site? Probably not. Are you all getting paid off too, like North Bay Children's Center? You are an embarrassment to the people you swore to serve and protect. You are the grandparent generation, do you know nothing of caring for the younger generation? Do you want your children, your grandchildren, or yourself to live here? No, of course not, because you live in a rich neighborhood, and you dump crap like this in "poor neighborhoods", right? Where poor people live, poor children attend school, and everyone Is just driving through going "somewhere else", poor renters, etc. Well, I live here) Thanks for voting in foul air, noise, cars, tankers, and degrading this neighborhood. Thanks for driving down the value of my house, for putting my life, my families life, and ESPECIALLY my daughter's lives at risk. Thanks for turning our neighborhood into a strip mall DUMP. For a GAS STATION IM I still can't believe it. Kerstin Bandner Evelyn Ellis From: Pascoe, Samantha <SPASCOE@ci.petaluma.ca.us> Sent: Tuesday, February 05, 2019 8:25 AM To: Crump, Katie; Heather Hines; Evelyn Ellis Subject: FW: Letter to Our City Council/Mayor : Opposing Safeway Fuel Station Project Attachments: NGHLetter.pdf Samantha Pascoe, CMC Deputy City Clerk Main 707.778.4360 Direct 707.778.4575 www.cityofpetaIuma.net Hours: Mon —Thurs Sam to Spm, Closed Fridays From: Zahyra Garcia <zahyragarcia@gmail.com> Sent: Monday, February 4, 2019 6:18 PM To: -- City Clerk <CityClerk@ci.petaluma.ca.us> Subject: Letter to Our City Council/Mayor: Opposing Safeway Fuel Station Project ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM.— Hello, We would like to submit our letter for record and hope you consider our stance as concerned members to our community. Warm Regards, Zahyra Garcia Pronouns: SHE/HER Co-chair for Indivisible Petaluma Co-chair for North Bay Orgainzing Project Petaluma Founding Member of North Bay LGBTQ+ Families of Sonoma County 16-17 Petaluma City Council 11 English Street Petaluma, CA 94952 February 401, 2019 Dear Petaluma City Council, We strongly oppose the 16 pump Safeway fuel station in our community. Indivisible Petaluma would like to provide another perspective to why this matters. When we think of racial injustice, we think police brutality or the criminal justice system, but what about our air and water? We should call it out by its name. ;environmental racism. Members in our community have provided you with facts on the following: Ninety-eight percent of McDowell Elementary students are eligible for reduced lunch, and ninety-three percent are students of color. According to the National Institute of Health, people from poor communities and communities of color are disproportionately exposed to elevated air pollution levels. These schools have Petaluma's highest % of ESL students. We have seen this time and time again where pollution and the risk of disasters are assigned to black and brown communities through generations of discrimination and political neglect. Why? Because these are the voices who have much less political clout. "Zip code is the most powerful predictor of health. And oil communities and all zip codes are not created equal."-- Dr. Robert Bullard The power that Safeway holds: to accuse misconduct where there is none, to bully council members into recusing themselves, to threaten the City with litigation, to determine the health and well-being of our community. As elected representatives you have an obligation to ensure that every single one of our community members is granted equal access to quality of life. As you navigate the coming months, we ask you to reflect on the power YOU hold, as City Council members, to do what you know is right. Sincerely, Founder: Kamala Brown Co -Chair: Zahyra Garcia 16-18 Evelyn Eltis From: Pascoe, Samantha <SPASCOE@ci.petaluma.ca.us> Sent: Thursday, February 07, 2019 10:36 AM To: Heather Hines; Evelyn Ellis Cc: Crump, Katie Subject: FW: Safeway Gas Station Samantha Pascoe, CMC Deputy City Clerk Main 707.778.4360 Direct 707.778.4575 www.cityofpetaluma.net Hours: Mon —Thdrs Sam to Spm, Closed Fridays From: Kari Popovic <karipopovic@gmail.com> Sent: Thursday, February 7, 2019 3:59 AM To: City Council <citycouncil@ci.petaluma.ca.us> Subject: RE: Safeway Gas Station ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. --- We all would love to have cheaper gas. But NOT at the price of the health and well-being of our children. Basic common sense says that putting a gas station -- and ESPECIALLY a high-volume gas station -- next to a school is a bad idea. The right amount of money can produce a study that says ANYTHING. Look at the doctor who said our overweight possibly demented President is in great health. But when you ask yourself if you'd want it next to YOUR child's school? Come on, now. Money is paper. Children are our future. Let's just ask Safeway to do the right thing and find somewhere else for their gas station. Kari, Miki, Sasha and Milan Popovic I 16-19 Evelyn Ellis From: Cooper, Claire <ccooper@ci,petaluma.ca.us> Sent: Wednesday, February 13, 2019 7:07 AM To: Evelyn Ellis Cc: Pascoe, Samantha Subjects FW: Safeway gas station -----Original Message ----- From: Elizabeth Keddy <enkeddy@gm'atl.com> Sent: Tuesday, February 12, 2019 8:46 PM To: City Council <citycouncil@ci.petaluma.ca.us> Subject: Safeway gas station ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. Dear Petaluma City Council, I'm writing to request that you deny the permit to Safeway to build a gas station across the street from a preschool and less than the required amount from an elementary school. I don't live close enough for this to directly affect me. My child doesn't go to school there. However, as a Petaluma citizen, I want what's best for everyone in this community. First of all, the science has clearly demonstrated that gas fumes are harmful and have been linked to leukemia. Second, we should be promoting clean energy, not gasoline. Finally, the community around Safeway is lower income and unable to relocate to a different Petaluma neighborhood. These members of our community are some of the most vulnerable - young children, the elderly- and should be protected by the rest of us. Please vote not Sincerely, Elizabeth Keddy 16-20 RII P", From: Cooper, Claire <ccooper@ci.petaluma.ca.us> Sent: Thursday, February 14, 2019 8:59 AM To: Crump, Katie; Evelyn Ellis Cc: Pascoe, Samantha Subject: FW: 100 more people signed "Petaluma City Council: Support Petaluma Safeway Gas Station!" From: mail@changemall.org <mail@changemail.org> Sent: Thursday, February 14, 2019 8:38 AM , To: -- City Clerk <CityClerk@ci.petaluma.ca.us> Subject: 100 more people signed "Petaluma City Council: Support Petaluma Safeway Gas Statlonl" ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. --- x New ew Sigel aturOS Petaluma City Council — This petition addressed to you on Change.org has new activity. See progress and respond to the campaign's supporters. Petaluma City Council: SupportPetaluma Safeway Gas [� Station! F'c; RJOn by E)'LJJ)ta®Ft Fetal f-na Safeway Gas '100 F;r,ppotlem 100 more people signed Rr--CFNT SUPPORTERS Kimberley Freeman Peitaliirna, CA • Jan 27, 2019 I want cheaper gas from Safeway I 16-21 Shellbe Daniels ® S),A(;ran)or i0, GA , Jan 26, 2019 Why not! Barbara Villa ® "C)rtarrl a, CA Jan 26, 2010 I work in Petaluma and this is where I buy gas. We need affordable gas. CI Richard Fontes Petaluma, GA • Jan 2.6, 2019 Because paying So to 6o cents a gallon more then the stations in Cotati is beyond corrupt..paid $3.16 there today Bailey Pontius Petalurna, CA J,3n 25, 2019 Because the price of gas overall will drop by at least 20 cents in Petaluma if this gas station is built. If 50,000 cars a week fill up to gallons that's a savings of $520,000 per year. That's money that can increase local savings and be spent locally. Over half a million per year into Petaluman's pockets. View all 100 supporters CI IANGF ORG FOR DECISION MAKIERS On Change.org, decision makers like you connect directly with people around the world to resolve issues. Respond to let the people petitioning you know you're listening, say whether you agree with their tali to action, or ask them for more information. Learn more. This notification Uris sent to ciryclert; ?ci.faetairrma,ca.us: Phe raddress listedas the (jeci iarr maker Contact by the petition starter. If this, is inr-arr�;ct, please post a response to lot the petition starter know. (3hango,org 5118 Mark( -,:l `3t t 2F399,3. San rfancr r:o, GA 94'10KI-11,10"1, USA 2 16-22 From: Heather Hines Sent: Wednesday, February 20, 2019 11,27 AM To: Evelyn Ellis Subject: FW: Petaluma Safeway Gas Station: Public Opinion Survey Results Attachments: 220-5170 City of Petaluma Development Issue Survey Summary Memo - Final ....pdf Safeway public comment from the applicant. From: Natalie Mattel <Natalie.Mattei@aibertsons.com> Sent: Thursday, February 7, 2019 1:10 PM To: dlynda@fischerforcouncil.com; mcdonnell4council@gmail.com Cc: Teresa Barrett <teresa4petaluma@comcast.net>; Michael Healy (mtheaiy@sbcglobal.net) <mthealy@sbcglobal.net>; Dave King <davekingpcc@gmail.com>; sbrodhun@ci.petaluma.ca.us; Danly, Eric <edanly@ci.petaluma.ca.us>; Heather Hines <hhines@m-group.us>; cityclerk@ci.petaluma.ca.us; Francois, Matthew <MFrancois@rutan.com>; Mark Friedman <mark@fulcrumproperty.com>; Natalie Mattel <Natalie.Mattel @albertsons.com> Subject: Petaluma Safeway Gas Station: Public Opinion Survey Results Dear Council Members Fischer and McDonnell, I hope you both are well. As you may have heard, a number of online polls have circulated over the years to gauge support for the Safeway gas station project. Over the last six months, the Petaluma Argus -Courier has posted two online polls, understandably seeking to drive traffic to their website. But that business interest aside, from a journalistic standpoint, conducting such online polls is highly questionable. The New York Times probably summarized it best: "informal, unscientific "polls" on news sites produce junk data that does not Indicate how the public actually feels, and should not be believed as an Indication of — well, much of anything." With this in mind, Safeway has opted to forego any effort at driving supporters to recent online polls. To the extent you are interested in reviewing credible data on public opinion in Petaluma regarding the project, I've attached a survey of 502 Petaluma residents conducted by the highly reputable polling firm FM3 in late lune 2018. Fulcrum conducted this survey to gather objective data on where Petalumans stood on the Safeway gas station, both before and after hearing balanced arguments for and against the project. As noted below, this poll was sent to Planning Commissioners and City Staff shortly after the survey's completion. As new Council Members, we were unsure if this information had been included in your packets and figured we'd send just in case. As you'll see, a significant majority of residents are aware of this project and support its approval -.even after hearing the alleged project deficiencies put forth by opponents. These voters may not have the time or energy to fill out online polls, participate in social media debates, or attend lengthy public hearings. But they exist, care about this issues, and are looking to City officials for relief, leadership, and resolution. Thank you for your consideration. Please reach out should you have further questions. Natalie Natalie Mattel Senior Real Estate Manager Albertsons Companies 11555 Dublin Canyon Road 1 16-23 Pleasanton, CA 94588 (925) 226-5754 Office 1 (925) 413-4455 Mobile natalie.mattei@safeway.com I Linkedln www.aThertsonscompaniesrealestate.com Begin forwarded message: From: Nick Carter <nickc@Fulcrum proyertv.com> Date: lune 26, 2018 at 12:59:37 PM PDT To: "ginamarie,bp@gmail.com" <ginamarie.bp@small.com>, "richardelacehouselinen.com" <rlchard@I_acehouselinen.com>, "dianaeeomez@gmail.com" <dlanaesomeZ@smail.com>, "a lonsoplanningoet@gmail.com" <alonsoplanninspet@gmail.com>, "held! ba uer2000@gmail.com" <heidibauer2000@&mail.com>, "wolpertta sonic.net" <wolyert@sonic.net>, "mthealy@sbcglobal.net" <mthealy@sbcglobal.net> Cc: "citvclerk@ci.petaluma.ca.us" <citvclerk@cLPetaluma.ca.us>, "citvmgr ci.petaluma.ca.us" <citvmgr ci. etaluma.ca.us>, "HHINES ci. etaluma.ca.us" <HHINESCa@ci.petaluma.ca.us>, "SPASCOE ci.petaluma.ca.us" <SPASCOE@ci;petaluma.ca.us>, "EELLIS@ci.petaluma.ca.us" <EELLIS@ci.petaluma.ca.us>, "Francois, Matthew (MFrancois@rutan.com)" <MFrancois@rutan.com> Subject: Safeway Gas Station Outreach: Public Opinion Survey Results Dear Planning Commissioners, As part of a multi -faceted outreach effort following the May 8th Planning Commission meeting, Washington Square Associates LLC and Fulcrum Property (respectively owner and manager of Washington Square) commissioned a public opinion survey between June 21-24, 2018 of over 500 likely voters in Petaluma regarding the Safeway gas station proposal. The survey was conducted by FM3 Research, one of the most respected, experienced, and independent public policy opinion research firms in the state. Enclosed is a memo prepared by FM3 summarizing the results. As the memo details, public awareness of the Safeway project is very high and a significant majority of respondents consistently support the gas station project. I am available at your convenience should you have any questions. Nick Warning: All e-mail sent to this address will be received by the corporate e-mail system, and is subject to archival and review by someone other than the recipient. This e-mail may contain proprietary information and is intended only for the use of the intended recipient(s). If the reader of this message is not the intended recipient(s), you are notified that you have received this message in error and that any review, dissemination, distribution or copying of this message is strictly prohibited. If you have received this message In error, please notify the sender immediately. 16-24 OPINION I RESEARCH RESEARCH &STRATEGY TO Interested Parties FROM Paul Maslin and Lucia Del Puppo FM3 Research RE: Petaluma Safeway Development Research DATE June 25, 2018 Fairbank, Masiin, Mauilin, Metz & Associates (FM3) completed a survey of 502 likely voters in Petaluma from lune 21-24, 2018.' The survey found that voters are highly familiar with the proposed development of a gas station at the Safeway location in Washington Square in Petaluma and majorities support its construction. The key findings of the survey include: Nearly seven in ten voters have seen, heard, or read about the plan to develop a new gas station in front of the Safeway in Washington Square. Sixty-eight percent of voters say they have heard, seen, or read something about this issue recently and 27 percent say they have heard a great deal. ® A majority of voters supports the project. Fifty-five percent say they support the new gas station project and 29 percent strongly support it. Only 30 percent of voters are opposed to the project and 15 percent are undecided. Figure 1: Initial Support for the Safeway Gas Station Development Next, Safeway is planning on opening a new gas station at their Washington Square shopping center. They have completed the necessary City processes to gain approval for construction of the gas station and, pending approval from the planning commission, will begin building the new station. Do you generally support or oppose allowing a new gas station to be built in this location? 12100 Wilshire Boulevard, Suite 350 j Los Angeles, CA 90025 1999 Harrison St., Suite 2020 ( Oakland, CA 94612 Phone: (310) 828-1183 1 Fax: (310) 453-6562 Phone: (510) 451-95211 Fax: (510) 451.0384 16-25 'Total support 55% -- Strongly support 29% Somewhat support 26% Totalappose 30% Somewhat oppose 7% Strongly oppose 23% Undecided a 5% 12100 Wilshire Boulevard, Suite 350 j Los Angeles, CA 90025 1999 Harrison St., Suite 2020 ( Oakland, CA 94612 Phone: (310) 828-1183 1 Fax: (310) 453-6562 Phone: (510) 451-95211 Fax: (510) 451.0384 16-25 RESEARCH • Nearly three in five agree that the City should allow increased competition and two-thirds say that they are concerned about the rising costs of gas. Fifty-nine percent say that city leaders should do more to allow new gas stations to open to improve competition and 67 percent are concerned about rising gas prices. Additionally, 64 percent of voters disagree with a statement saying that gas prices in Petaluma are reasonable and more than half say that they travel to other cities to purchase gas. Figure 2: Attitudes Toward Gas Stations and Gas Prices in Petaluma am concerned about the !,in cost of gas in Petaluma City leaders should do more to allow new gas stations to open if 59% 34% It will improve competition and reduce gas prices I often travel to other cities10 buy gas because it's too 52% 44% expensive In Petaluma Gas is a major part of my family's budget 48% 51% Gas prices In Petaluma are reasonable and affordable for my 3390 64% family • A plurality of voters agrees that the Safeway gas station will be good for Petaluma. Forty-eight percent of voters say that the new gas station will be good for Petalumans. Only one-quarter of voters think it will be bad for the city. Figure 3: Perception of the Impact of Gas Station Development Anew gas station will be good for Petaluma because'it will; give people more options for purchasing gas, 'leading to added 'convenience and lower prices A new gas station will be bad for Petaluma because it will harm 25% our environment and worsen traffic congestion. Both/Neither/Don't know 27% Page 2 16-26 i , RESEARCH ® After a balanced exchange of the benefits and downsides of a new Safeway gas station, a majority continue to offer support for the project. Survey respondents heard a balanced series of statements in favor of the gas station and criticisms of a new gas station. After hearing this Information, their overall perception did not shift greatly, and a majority continued to support the proposed project (Figure 4). Figure 4: Support for the Safeway Gas Station Development After Information 55% 58% '55% 30% 31% 35% 15% 12% 10% Taken together, this information suggests that Petaluma voters are supportive of constructing a new gas station at the Safeway in Washington Square. Nearly seven in ten have heard of the issue and two -third of voters are worried about gas prices in town. When voters are highly familiar with a local issue, as they are in this instance, the chances of substantial fluidity in voter opinion over time becomes less likely. In fact, a majority is supportive of the project initially and they remain consistently supportive as they learn more about it. Methodology: From June 21-24, 2018, FM3 completed 502 online and telephone interviews (on both landlines and cell phones) with likely November 2018 voters In the City of Petaluma. The margin of sampling error for the study is +/-5.7 at the 95% confidence level; margins of error for population subgroups within the sample will be higher. Due to rounding, not all totals will sum to 100%. Fairbank, Maslin, Maullin, Metz & Associates (FM3 Research or FM3) is a California-based company with offices in los Angeles and Oakland. FM3 has been conducting public policy -oriented opinion research since 1981 on Issues of major economic and social concern, such as health care; education; environmental protection; natural resource conservation and development; transportation; constituent satisfaction with public services and support for policy proposals; budgetary Issues and taxation; land use, growth, and property development; communications technology; energy development; and organizational branding. Page 3 16-27 Evelyn Ellis From: Heather Hines Sent: Wednesday, February 20, 2079 2:09 PM To: Evelyn Ellis Subject: FW: Safeway gas station Public comment for Safeway file. -----Original Message ----- From: Crump, Katie <KCRUMP@ci.petaluma.ca.us> Sent: Wednesday, February 13, 2019 7:40 AM To: Heather Hines <hhines@m-group.us> Subject: FW: Safeway gas station FYI -----Original Message ----- From: Elizabeth Keddy <enkeddy@gmail.com> Sent: Tuesday, February 12, 2019 8:46 PM To: City Council <citycouncil@ci.petaluma.ca.us> Subject: Safeway gas station ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM.--- Dear YSTEM:-- Dear Petaluma City Council, I'm writing to request that you deny the permit to Safeway to build a gas station across the street from a preschool and less than the required amount from an elementary school. I don't live close enough for this to directly affect me. My child doesn't go to school there. However, as a Petaluma citizen, I want what's best for everyone in this community. First of all, the science has clearly demonstrated that gas fumes are harmful and have been linked to leukemia. Second, we should be promoting clean energy, not gasoline. Finally, the community around Safeway is lower income and unable to relocate to a different Petaluma neighborhood. These members of our community are some of the most vulnerable - young children, the elderly- and should be protected by the rest of us. Please vote nol Sincerely, Elizabeth Keddy 16-28 From: Heather Hines Sent: Wednesday, February 20, 2019 11:18 AM To: Evelyn Ellis Subject: FW: Safeway Gas Station Public comment for Safeway file. From: Crump, Katie <KCRLIMP@ci.petal uma.ca.us> Sent: Thursday, February 7, 2019 7:41 AM To: Heather Hines <hhines@m-group.us> Subject: FW: Safeway Gas Station fyi From: Kari Popovic <karloopovic@Rmail.com> Sent: Thursday, February 07, 2019 3:59 AM To: City Council <citycouncil@ci.petaluma.ca.us> Subject: RE: Safeway Gas Station ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. --- We all would love to have cheaper gas. But NOT at the price of the health and well-being of our children. Basic common sense says that putting a gas station -- and ESPECIALLY a high-volume gas station -- next to a school is a bad idea. The right amount of money can produce a study that says ANYTHING. Look at the doctor who said our overweight possibly demented President is in great health. But when you ask yourself if you'd want it next to YOUR child's school? Come on, now. Money is paper. Children are our future. Let's just ask Safeway to do the right thing and find somewhere else for their gas station. Kari, Miki, Sasha and Milan Popovic I 16-29 Evelyn Ellis From: Cathy Teague <teagueca@gmail.com> Sent: Friday, February 22, 2019 11:30 AM To: Evelyn Ellis Subject: Re: FW: Public Notice - Safeway Fuel Center I am in favor of the Safeway gas station. l currently drive to the Safeway in Novato to buy gas because it Is so much cheaper - Catherine Teague 1634 Oneei Petaluma, CA 94954 On Fri, Feb 22, 2019 at 11:09 AM Evelyn Ellis <EEllis@m-erouy.us> wrote: Hello, You are receiving this email because of your interest in a recent project with the City of Petaluma. Attached is a public notice for a City Council meeting on March 4, 2019. You may also provide written comment if you are unable to attend the meeting. See the attachment for details. Evelyn Ellis, Planning Analyst M -Group - Consulting City Planners Serving the City of Petaluma 11 English Street, Petaluma, CA 94952 707.778-4319 eellis@m-eroup.us Hours: Monday -Thursday 8am-5pm, closed Fridays �.r TRY ,OPEN COUNTERFOR INFO % ON :NG PERMITS COSTS 16-30 Evelyn Ellis From: Heather Hines Sent: Friday, February 22, 2019 2:07 PM To: Evelyn Ellis Subject: FW: Opposition to Safeway project Public comment for Safeway -----Original Message ----- From: Jennifer Brazinsky <jbrazinsky@sonic.net> Sent: Friday, February 22, 2019 2:04 PM To: Heather Hines <hhines@m-group.us>; Olivia Ervin <OErvin@m-group.us> Subject: Opposition to Safeway project Hello, I am unable to attend the meeting on 3/4.1 attended the last meeting and was unable to wait to make a comment. I would like to register that I am 100% opposed to the Safeway gas station for many reasons that have already been expressed by others . We already have very poor strategy around traffic and adding this to an already busy intersection is ridiculous. We have PLENTY of gas stations. Why do we need to put this up against a low income preschool? Right next to a field where elementary school kids play all day? It's incredibly poor positioning. Safeway threatening to sue due to opposition tells you much about them. They don't care about this community. They care about profit. If Safeway wants to force their will, find a spot for this gas station that doesn't Impact traffic, and most importantly, young children. As for environmental studies, let's go back to common sense. if you had a choice, would you rather your preschool child be exposed regularly to gas fumes or not? I think we all know the answer. Thank you, Jennifer Brazinsky Jones 16-31 Evelyn Ellis From: S. Herman <jude1248@comcast.net> Sent: Friday, February 22, 2019 4:19 PM To: Evelyn Ellis Subject: Safeway Gas Station and food mart Follow Up Flag: Flag for follow up Flag Status: Flagged Dear M -Group: We also received this notice in the mail today. My husband and I are adamantly opposed to Safeway's gas station in Its proposed location. Should they persist in building one adjacent to Safeway, we will no longer shop at Safeway. I support union workers, but this action would be intolerable, and we will have to boycott them. Best regards, Susan & Ted Herman 127 Sunny Hill Drive Petaluma 94952-4748 16-32 Evelyn Ellis From: Bob Canning <TheWriteGuy@comcast.net> Sent: Friday, February 22, 2019 7A2 PM To: cityclerk@ci.petaluma.ca.us; Evelyn Ellis; teresa4petaluma@comcast.net Subject: NO to Safeway's Gas Station I want to make it clear that I think having a gas station across the street from not only an elementary school but a day care center as well is not only a stupid idea, but potentially dangerous to young children from the gas fumes on a daily basis. Do I really have to remind you that... Gasoline is dangerous for your health because its toxic. Exposure to gasoline, either through physical contact or inhalatlon, can cause health problems. The effects of gasoline poisoning can harm every major organ. Why in the world must Safeway have their gas station at that exact location anyway? They killed off so many businesses by evicting them, now they think they can get away with harming young children, and Petaluma City Council doesn't see the dangers? Greed kills. Safeway has deep pockets and Petaluma has many empty lots around town that they can buy to build their gas station. Why would Petaluma City Council take such a terrible gamble in allowing Safeway to build across from the school and day care center? Five or 10 years down the line, those children may be paying the price for your bad decision with breathing problems and other respiratory issues. If so, get ready to pay for their suffering in Big, Big Bucks. Bob Canning 707-781-3236 i 16-33 Evel r n Ellis From: Heather Hines Sent: Monday, February 25, 2019 4:38 PM To: Evelyn Ellis Subject: FW: Petaluma Safeway Gas Station: Public Opinion Survey Results From: Crump, Katie <KCRUMP@ci.petaluma.ca.us> Sent: Monday, February 25, 2019 8:44 AM To: Heather Hines <hhines@m-group.us> Subject: FW: Petaluma Safeway Gas Station: Public Opinion Survey Results FYI From: Brodhun, Scott Sent: Monday, February 25, 2019 8:41 AM To: Crump, Katie <KCRUMP@ci.getaluma.ca.us> Subject: FW: Petaluma Safeway Gas Station: Public Opinion Survey Results FYI —Safeway comment From: Rebecca Carpenter <rcaroenter 552vahoo.com> Sent: Friday, February 22, 2019 2:04 PM To: dlynda@fischerforcouncil.com; mcdonnell4council@gmail.com Cc: Cc: Teresa Barrett <teresa4petaluma@comcast.net>; Michael Healy <mthealy@sbcglobal.net>; Dave King <davekingpcc@gmail.com>; Brodhun, Scott <SBRODHUN@ci.petaluma.ca.us>; Danly, Eric <edanly@ci.petaluma.ca.us>; -- City Clerk <CitvClerk ci.1etaluma.ca.us> Subject: Petaluma Safeway Gas Station: Public Opinion Survey Results ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. --- Dear Council Members Fischer and McDonnell, In Natalie Mattel's email to you dated February 7, 2019, she implies that the information stated In the FM3 memo regarding their poll conducted in lune 2018 contains "credible data." I'd like to point out that in the June 26 Planning Commission meeting, Commissioner Scott Alonzo noted how flawed the poll results in that memo were. He stated: "I just want to emphasize how bogus this poll Is. We have no idea what all the questions... we have no idea what all the responses were; we don't have the demographic breakdown; we don't have the age breakdown; we don't have the neighborhood breakdown; we don't know how many attempts they had. So, I think to try and jam this down our throats at the eleventh hour... frankly the fact that you waited so long to contract with FM3 and get the poll done isn't a good excuse to not provide us all the data. "I've worked with FM3. They're a great polling firm and they do great work. They have the data. They wouldn't write the memo if they didn't have the full survey cross tabs ready. So, the idea that you won't provide it is very concerning. They have it. They can't write the memo without the full data. I know there are multiple colleagues on the dais with me that are familiar with public opinion polls and the, fact that they wrote a memo without revealing everything behind the data is incredibly misleading to the 16-34 audience here, those at home, and to us up here. So please in the future, don't push this on us. It's not accurate. "We don't know what is behind all these questions. They've come up with "all these people support the project." Ok, tell me where that is in the evidence behind this poll. It's not there. They haven't presented it. And again, these polls are very expensive. They cost anywhere between $25,000 and $35,000 to do a city-wide poli. So, the idea that they're going to spend all this money and not present us all the information is not OK. And it's not... I think it really underscores the challenges that Madame Chair you brought up at the very beginning with the applicant's behavior towards this commission, and to staff, and to the public, where they aren't being transparent about what's going on, and to me that Is incredibly concerning." It seems to me that if anyone is promoting a "highly questionable poll," it is Safeway. Respectfully, Rebecca Carpenter 16-35 Heather Hines From: Eric Roberts Sent: Wednesday, February 27, 2019 8:29 AM To: Heather Hines Cc: Evelyn Ellis Subject: Fw: Please Vote YES on the Safeway Gas Station FYI Eric Roberts, Planning Technician M -Group Consulting Planning Technician Serving the City of Petaluma 11 English Street, Petaluma, CA 94952 Phone: (707) 778-4317 Hours: Monday -Thursday Sam -Spm, closed Fridays 0 From: morlegdmet@aol.com <morlegdmet@aol.com> Sent: Tuesday, February 26, 201910:12 PM To: petalumaplanning@ci.petaluma.ca.us Subject: Please Vote YES on the Safeway Gas Station ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. -- Message: we need itl Name: annie hard I 16-36 Heather Hines From: Eric Roberts Sent: Wednesday, February 27, 2019 8:29 AM To: Heather Hines Cc: Evelyn Ellis Subject: Fw: Please Vote YES on the Safeway Gas Station FYI (Eric Roberts, Planning Technician M -Group Consulting Planning Technician Serving the City of Petaluma 11 English Street, Petaluma, CA 94952 Phone: (707) 778-4317 Hours: Monday -Thursday 8am-Spm, closed Fridays From: hsublow@gmail.com <hsublow@gmail.com> Sent: Tuesday, February 26, 201911:49 PM To: petalumaplanning@ci.petaluma.ca.us Subject: Please Vote YES on the Safeway Gas Station ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. -- Message: lets get this project off the ground and built already. It's about time. Name: Howard Sublow 16-37 ScienceDirect Get Access % Share Export w ' i t Science of The Total Environment Volume 650, Part 2,10 February 2019, Pages 2239-2250 Vent pipe emissions from storage tanks at gas stations: Implications for setback distances Markus Hilpert' A 13, Ana Maria Rule b, 6ernat Adria -Mora', Tedmund Tiberi C M Show more https://doi.org/10.1016/j.scitotenv.2018.09,303 Get rights and content Highlights At gas stations, fuel vapors are released from storage tanks through vent pipes. • We measured vent pipe flow rates and tank pressure at high temporal resolution. • Vent emission factors were >10 tunes higher than previous estimates. Modeling was used to examine exceedance of benzene short-term exposure limits. Abstract At gas stations, fuel vapors are released into the atmosphere from storage tanks through vent pipes. Little is ]mown about when releases occur, their magnitude, and their potential health consequences. Our goals were to quantify vent pipe releases and examine exceedance of short - 16 -38 term exposure limits to benzene around gas stations. At two US gas stations, we measured volumetric vent pipe flow rates and pressure in the storage tank headspace at high temporal resolution for approximately three weeks. Based on the measured vent emission and meteorological data, we performed air dispersion modeling to obtain hourly atmospheric benzene levels. For the two gas stations, average vent emission factors were 0.17 and 0.21kg of gasoline per 1000L dispensed. Modeling suggests that at one gas station, a 1 -hour Reference Exposure Level (REL) for benzene for the general population (8ppb) was exceeded only closer than 50m from the station's center. At the other gas station, the REL was exceeded on two different days and up to 160m from the center, likely due to non-compliant bulls fuel deliveries. A minimum risk level for intermediate duration (>14--364days) benzene exposure (6ppb) was exceeded at the elevation of the vent pipe opening up to 7 and 8m from the two gas stations. Recorded vent emission factors were >10 times higher than estimates used to derive setback distances for gas stations. Setback distances should be revisited to address temporal variability and pollution controls in vent emissions. Graphical abstract AM emnOU1u 4 Download high-res image (811<6) Download full-size image < Previous Next Keywords Gas stations; Benzene emissions; Setback distances; Air pollution modeling; Measurements 16-39 Recommended articles Citing articles (0) © 2018 Elsevier B.V. All rights reserved. ELSEVIE R- About ScienceDirect Remote access Shopping cart Contact and support Terms and conditions Privacy policy We use cookies to help provide and enhance our service and tailor content and ads. By continuing you agree to the use of cookies. Copyright © 2019 Elsevier B.V. or its licensors or contributors. ScienceDirect 0 is a registered trademark of Elsevier B.V. -RELX Group'" 16-40 375 BCAIA ST'REff, Shirr 600 • SAN FRANCISCO CA • 94105 •415,771,6000 • u•inr,baagmJgriv 16-41 Olivia Ervin B A Y A R E A Environmental Planner City of Petaluma AI It QUALITY 11 English Street Petaluma, CA 94952 iV1ANAGi:htlNT RE: Safeway Fuel Center Project — Air District Comments on Health Risk Assessments D 1 5 T R i C T Dear Ms. Ervin, ALAMEDA COUNTY John J. Baulers The Bay Area Air Quality Management District (Air District) submitted comments dated Pauling Russo Culler Stolt Haggerty September 17 2018 to the Cit of Petaluma on the prior Health Risk Assessment HRA P , Y p ' (HRA) Nate Miloy done by Illingworth & Rodkin on the proposed Safeway Fuel Center Project ("project"), CONTRA COSTA COUNTY Pursuant to your recent request, Air District staff have reviewed the MRA conducted by John Glola Phyllis Fox and Ray Kapahi (Fox/Kapahi HRA) and the subsequent October 10, 2018 David hairjsan updated HRA conducted by Illingworth & Rodkin. Karan Mitchell Mark Ross The Air District has several key concerns regarding the Fox/Kapahi HRA, Fox/Kapahi's use MARIN COUNTY of Santa Rosa meteorological data is not appropriate for this project because the wind Katie Rice (vice chair) Patterns are not consistent with the project area. The gasoline dispensing facility benzene emission factor used for the Fox/Kapahi NRA is substantially higher than the Air District's NAPA COUNTY Brad Wagenknechl standard benzene emission factor for gasoline dispensing facilities. The residential SAN FRANCISCO COUNTY exposure assumptions used in the Fox/Kapahi HRA are not consistent with the Air Rafael Mandelmon District's current HRA risk calculation procedures. Hillary Ronan TyroneMayor's (SF Mayor's Appointee) Air District staff find that the October 10 2018 updated HRA conducted b Illingworth & p y g SAN MATEO COUNTY Rodkin is acceptable and has resolved our concerns from the September 17, 2018 letter, David canape The Air District has no further comments on this updated HRA. Carole Groom Doug Kim The project includes a gas station configuration that differs from the configuration",",, SANTA CLARA COUNTY Margaret Abe-Koge t ! approved in the Air District's current Authority to Construct for this gas station. Safeway' Cindy Chavez must apply for Air District permit revisions to ensure that their Air District permit )s G sinks consistent with this described project. Rodd (Secretary) For more information, or if you have any questions, please contact David Vintze, Planning SOLANOCOUNTY Pete Sanchez Manager, at (415) 749.5179 or via email at dvintreR baaamd,gev, or Barry G. Young, James Spering Senior Advanced Projects Advisor, at (415) 749-4721 or via email at SONOMA COUNTY byoung@baagmd,gov, Teresa Sorrell Shidee Zane Sincerely, Jack P. Broadbent EXECUTIVE OFFICERIAPCO r �' Connect with the Damian Breen Bay Area Air District: Deputy Air Pollution Control Officer UP to 375 BCAIA ST'REff, Shirr 600 • SAN FRANCISCO CA • 94105 •415,771,6000 • u•inr,baagmJgriv 16-41 Supplemental Health Risk Results Using Petaluma Wind Data with AERMOD November 30, 2018 Phyllis Fox, PhD, PE and Ray Kapahi, BSC, M. Eng. 16-42 The health risk assessment described in our original report for the proposed Safeway fuel station in Petaluma used the AERMOD dispersion model to determine the dispersion of toxic air contaminants in the vicinity of the proposed gas station. As noted in that report, AERMOD is the recommended dispersion model as it encapsulates the most current dispersion algorithms and environmental parameters such as local wind, land use parameters, and atmospheric stability. However, meteorological and land use data for Petaluma were unavailable in a format consistent with AERMOD, and therefore our analysis relied on data from Santa Rosa. The report discussed the implications for using meteorological data from Santa Rosa and the impact on predicted health risk in the vicinity of the proposed gas station. Specifically, the report noted that winds in Petaluma were aligned more along the East-West direction and therefore, the actual cancer risks would be higher than that predicted using data from Santa Rosa. Following completion of our original report, we have obtained wind data from Petaluma that was used by Safeway's consultant, and substituted that data in the AERMOD model for the Santa Rosa data. The use of Petaluma wind data changes the risk profile in 3 ways: 1) The axis of the risk contours is shifted counter clockwise by about 45 degrees. This means a larger proportion of emissions will be transported towards the daycare centers and the school 2) The maximum residential risk increased by about 25%. 3) The number of residences affected with higher risk is increased. That is, the area within a given risk contour is increased. A side-by-side comparison of the 70 year cancer risk using Santa Rosa vs Petaluma wind data is attached. Risks to children (9 -year exposure) would also experience a higher risk. Substituting 1990 to 1994 Petaluma wind data Into 2013 to 2017 Santa Rosa AERMOD input files is still not the ideal solution since we are relying on atmospheric stability data from Santa Rosa. However, this approach captures the local wind patterns that are the primary driver in transporting TACs to local homes, schools and businesses. As a result, it provides a more refined risk analysis than use of wind data from Santa Rosa. As noted in our comments, the use of Petaluma data would Increase, not decrease, risks to the public. 16-43 L iia 16-44 9Yr Cancer Risk Petaluma data 16-45 I—rc�rh 5ihf.(tr- f""�i�(Y�� y�� I ��.,,df�od,� yvr a � II. ORIGINATION THROUGH POST-CLOSING/ENDORSEMENT D. Appraiser and Property Requirements for Title It Forward and Reverse Mortgages 3. Acceptable Appraisal Reporting Forms and Protocols Lines pass directly over any dwelling, Structure or related property improvement, including pools, spas, or water features. The Appraiser must notify the Mortgagee of the deficiency of MPR or MPS if the dwelling or related property improvements are located within an Basement or if they appear to be located within an unsafe distance of any power line or tower. The Appraiser must note and comment on the effect on marketability resulting from the proximity to such site hazards and nuisances. The Appraiser must also determine if the guidelines for Encroachments apply. (6) Smoke, Fumes and Offensive or Noxious Odors The Appraiser must notify the Mortgagee if excessive smoke, chemical fumes, noxious odors, stagnant ponds or marshes, poor surface drainage or excessive dampness threaten the health and safety of the occupants or the marketability of the Property. The Appraiser must consider the effect of the condition in the valuation of the Property if the conditions exist but do not threaten the occupants or marketability. (7) Stationary Storage Tanks If the subject property line is located within 300 feet of an aboveground or subsurface stationary storage tank with a capacity of 1,000 gallons or more of flammable or explosive material, then the Property is ineligible for FHA insurance, and the Appraiser must notify the Mortgagee of the deficiency of MPR or MPS. This includes domestic and commercial uses as well as automotive service station tanks. iv. Site Conditions (A)Access to Property (1) Definition Adequate Vehicular Access to Property refers to an all-weather road surface over which emergency and typical passenger vehicles can pass at all times. (2) Required Analysis and Reporting The Appraiser must notify the Mortgagee of the deficiency of MPR or MPS if the Property does not have safe pedestrian access and Adequate Vehicular Access from a public street or private street that is protected by a permanent recorded Easement, ownership interest, or is owned and maintained by an HOA. Shared driveways that are not part of an HOA must also meet these requirements. Handbook 4000.1 491 Effective Date: 09/14/20151 Last Revised: 12/30/2016 "Refer to the online version of SF Handbook 4000.1 for specific sections' effective dates 16-46 Heather Hines From: Crump, Katie <KCRUMP@ci.petaluma.ca.us> Sent: Tuesday, February 26, 2019 1:05 PM To: Heather Hines; Danly, Eric; -- City Clerk Subject: FW: comments on proposed gas station at 335 S. McDowell Blvd. Attachments: leukemia, gas station emissions, set back implications.pdf, healthy air healthy brains feb2019, ajph.pdf, asthma incidence, TRAP, McConnell.pdf From: ted Schettler <tschettler@igc.org> Sent: Tuesday, February 26, 2019 1:02 PM To: City Council <citycouncil@ci.petaluma.ca.us> Cc: Ted Schettler <tschettler@igc.org>; 'JoAnn McEachin' <joannmceachin@gmail.com> Subject: comments on proposed gas station at 335 S. McDowell Blvd. ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. --- To the Petaluma City Council: I am Ted Schettler MD, MPH, Science Director of the Science and Environmental Health Network, and resident of Bolinas. I have considerable training and experience in the field of environmental health and particular interest in the impacts of environmental exposures on children's health and development. I have recently learned of the proposal to permit the establishment of a gas station with eight pumps and 16 dispensers at 335 S. McDowell Blvd in Petaluma, approximately 60 feet from a school and daycare center. The California Air Resources Board (CARB) directly addresses the issue of appropriately locating gas stations and quite clearly recommends that a facility of this size should not be located less than 300 feet from a sensitive land use such as a school or daycare center. Moreover, a recent study (attached) concludes that the CARB guidance may not be sufficiently protective. Beyond that, a gas station of this size will certainly increase area traffic and associated air pollution. I am also attaching a recent review of the neurodevelopmental impacts of air pollution and a study of the impacts of traffic related air pollution (at homes and schools) on the incidence of asthma. I encourage you to fully consider the potential impacts of your permitting decision on the health of young children who will be regularly spending substantial portions of their days exposed to emissions associated with the proposed facility. They will almost certainly be at increased risk of a variety of adverse health outcomes. Re -locating the facility or denying the permit would eliminate those increased risks. Respectfully submitted Ted Schettler MD, MPH Science Director Science and Environmental Health Network www.sehn.or 16-48 Science of the Total Environment 650 (2019) 2239-2250 Contents lists available at ScienceDirect Science of the Total Environment E { 1-1"VI);I? journal homepage: www.elsevier,com/locate/scitotenv Vent pipe emissions from storage tanks at gas stations: Check for Implications for setback distances °a'ae- Markus Hilpert a'*, Ana Maria Rule b, Bernat Adria -Mora a, Tedmund Tiberi 2 Deportment of Environmental Health Sciences, Mailman School of Public Health, Columbia University, New York NY 10032, United States of America b Department of Environmental Health and Engineering, Johns Hopkins Bloomberg School of Public Health, Baltimore, MD 21205, United States of America ARID Technologies, Inc, Wheaton, IL 60187, United States ofAmerica HIGHLIGHTS GRAPHICAL ABSTRACT • At gas stations, fuel vapors are released from storage tanks through vent pipes. • We measured vent pipe flow rates and tank pressure at high temporal resolu- tion. • Vent emission factors were >10 times higher than previous estimates. Modeling was used to examine exceed- ance of benzene short-term exposure limits. BTEX emissions \ -- A•R T I C L E I N F O A B S T R A C T Article history: At gas stations, fuel vapors are released into the atmosphere from storage tanks through vent pipes. Little is Received 3 July 2018 known about when releases occur, their magnitude, and their potential health consequences. Our goals were Received in revised form 11 September 2018 to quantify vent pipe releases and examine exceedance of short-term exposure limits to benzene around gas sta- Accepted 23 September 2018 tions. At two US gas stations, we measured volumetric vent pipe flow rates and pressure in the storage tank head - Available online 24 September 2018 space at high temporal resolution for approximately three weeks. Based on the measured vent emission and Editor: Pavlos I(assomenos meteorological data, we performed air dispersion modeling to obtain hourly atmospheric benzene levels. For the two gas stations, average vent emission factors were 0.17 and 0.21 kg of gasoline per 1000 L dispensed. Keywords: Modeling suggests that at one gas station, a 1 -hour Reference Exposure Level (REL) for benzene for the general Gas stations population (8 ppb) was exceeded only closer than 50 m from the station's center. At the other gas station, the Benzene emissions REL was exceeded on two different days and up to 160 m from the center, likely due to non-compliant bulk Setback distances fuel deliveries. A minimum risk level for intermediate duration (>14-364 days) benzene exposure (6 ppb) was Air pollution modeling exceeded at the elevation of the vent pipe opening up to 7 and 8 m from the two gas stations. Recorded vent Measurements emission factors were >10 times higher than estimates used to derive setback distances for gas stations. Setback distances should be revisited to address temporal variability and pollution controls in vent emissions. © 2018 Elsevier B.V. All rights reserved, • Corresponding author at: Department of Environmental Health Sciences, Mailman School of Public Health, Columbia University, 722 West 168th St., New York, NY 10032, United States of America. E-mail address., mh3632@columbia.edu (M. Hilpert). https://doi.org/10.1016/J*.scitotenv.2018.09.303 0048-9697/0 2018 Elsevier B.V. All rights reserved. 16-49 2240 1. Introduction M. Hilpert et at I Science of the Total Environment 650 (2019) 2239-2250 In the US, approximately 143 billion gal (541 billion L) of gasoline were dispensed in 2016 at gas stations (EIA, 2017) resulting in release of unburned fuel to the environment in the form of vapor or liquid (Hilpert et at., 2015). This is a public health concern, as unburned fuel chemicals such as benzene, toluene, ethyl -benzene, and xylenes (BTEX) are harmful to humans (ATSDR, 2004). Benzene is of special concern because it is causally associated with different types of cancer (IARC, 2012). Truck drivers delivering gasoline and workers dispensing fuel have among the highest exposures to fuel releases (IARC, 2012). However, people living near orworking in retail atgas stations, and chil- dren in schools and on playgrounds can also be exposed, with distance to the gas stations significantly affecting exposure levels (Terres et al., 2010; Jo & Oh, 2001; Jo & Moon, 1999; Hajizadeh et al., 2018). A meta- analysis (Infante, 2017) of three case -control studies (Steffen et al., 2004; Brosselin et al., 2009; Harrison et al., 1999) suggests that child- hood leukemia is associated with residential proximity to gas stations. Sources of unburned fuel releases at gas stations include leaks from storage tanks, accidental spills from the nozzles of gas dispensers (Hilpert & Breysse, 2014; Adria -Mora & Hilpert, 2017; Morgester et al., 1992), fugitive vapor emissions through leaky pipes and fittings, vehicle tank vapor releases when refueling, and leaky hoses, all of which can contribute to subsurface and air pollution (Hilpert et al., 2015). Routine fuel releases also occur through vent pipes of fuel storage tanks but are less noticeable because the pipes are typically tall, e.g., 4 m. These vent pipes are put in place to equilibrate pressures in the tanks and can be lo- cated as close as a few meters from residential buildings in dense urban settings (Fig. 1). Unburned fuel can be released from storage tanks into the environ- ment through "working" and "breathing" losses (Yerushalmi & Rastan, 2014). A working loss occurs when liquid is pumped into or out of a tank. For a storage tank, this can happen when it is refilled from a tanker truck or when fuel is dispensed to refuel vehicles (Statistics Canada, 2009) if the pressure in the storage tank exceeds the relief pressure of the pressure/vacuum (P/V) valve (EPA, 2008). P/V valve threshold pres- sures are typically set to around +3 and —8 in. of water column (iwc) (7.5 and —20 hPa). However, P/V valves are not always used, particu- larly in cold climates, as valves may fail under cold weather conditions (Statistics Canada, 2009). Breathing losses occur when no liquid is pumped into or out of a tank because of vapor expansion and contraction due to temperature and barometric pressure changes or because pressure in the storage Fig. 1. The three vent pipes (enclosed by the red ellipse) on the right side of the convenience stare of a gas station are <10 no away from the residential building. tank may increase when fuel in the tank evaporates (Yerushalmi & Rastan, 2014; EPA, 2008). Although delayed or redirected by the P/V valve, breathing emissions can be significant and represent an environ- mental and health concern (Yerushalmi & Rastan, 2014).. Stage I vapor recovery systems, put in place to prevent working losses while delivering fuel to a station, collect the vapors displaced while loading a storage tank, redirecting them into the delivery truck. Stage 11 vapor recovery systems minimize working losses while deliver- ing gas from the storage tank to the customer's car. During Stage 11 vapor recovery, gasoline vapors can be released through the vent pipe, if the sum of the flow rates of the returned volume and of the fuel evaporating within the storage tank is greater than the volume of liquid gasoline dis- pensed (Statistics Canada, 2009). We refer to this scenario as pressure while dispensing (PWD). In theory, a properly designed Stage II vapor recovery system should not have working losses, although in practice this is not typically the case (McEntire, 2000). Regulations on setback distances for gas stations are based on life- time cancer risk estimates. Several studies have assessed benzene can- cer risk near gas stations (Atabi & Mirzahosseini, 2013; Correa et al., 2012; Cruz et al., 2007; Edokpolo et al., 2015; Edokpolo et al., 2014; Karakitsios et al., 2007). Based on cancer risk estimations, the California Air Resources Board (CARB) recommended that schools, day cares, and other sensitive land uses should not be located within 300 ft. (91 m) of a large gas station (defined as a facility with an annual sales volume of 3.6 million gal = 13.6 million L or greater) (CalEPA/CARB, 2005). This CARB recommendation has not been adopted by all US states, and within states setback distances can depend on local government. Nota- bly, CARB regulations do not account for short term exposure limits and health effects. An important limitation of existing regulations is the use of average gasoline emission rates estimated in the 90s that do not con- sider excursions (CAPCOA, 1997), The main objective of this study is to evaluate fuel vapor releases through vent pipes of storage tanks at gas stations based on vent emis- sion measurements conducted at two gas stations in the US in 2009 and 2015, including the characterization of excursions at a high temporal resolution (--minutes) and meteorological conditions at an hourly tem- poral resolution. In addition, we performed hourly simulations of atmo- spheric transport of emitted fuel vapors to inform regulations on setback distances between gas stations and adjacent sensitive land uses by comparing modeled benzene concentrations to four 60 -min benzene exposure limits: an acute Reference Exposure Level (REL) for infrequent (once per month or less) exposure (WHO, 2010) and Emergency Response Planning Guidelines ERPG-1, ERPG-2 and ERPG- 3 (AIHA, 2016). Finally we compared simulated benzene levels to a Min- imal Risk Level (MRL) for benzene for intermediate exposure duration (14 to 364 days) (ATSDR, 2018) because that duration window includes our duration of data collection. See Table I for the various benzene ex- posure limits and issuing agencies. 2. Methods Although we provide SI unit conversions, we report some measures in English engineering units (ft, gal, and Ib) as regulatory agencies such as CARB use these units. 2.1. Sites Data for this study were obtained from vent release measurements conducted at two gas stations as part of technical assistance to the gas stations to quantify fuel vapor losses through the vent pipes of their storage tanks. A motivation for conducting the measurements was to perform a cost -benefit analysis to compare the economic losses due to the lost fuel versus the cost of technologies that reduce the emissions. The exact location of the two gas stations is not revealed for confidenti- ality reasons. The gas station managers and staff who authorized the 16-50 M. Hilpert et al /Science of the Total Environment 650 (2019) 2239-2250 2241 Table 1 Benzene exposure limits, to which we compared simulation results, For unit conversion, we assumed a temperature of 25 °C, i.e., I ppm = 3194 pg/m3 (CAPCOA, 1997). Agency Name Value (ppb) Value (pg/m3) Exposure duration California Office of Environmental Health Hazard Assessment (OEHHA) REL 8 26 1 h American Industrial Hygiene Association (AIHA) ERPG-1 50 159,700 1 h AIHA ERPG-2 150 479,100 1 h AIHA ERPG-3 1000 3,194,000 1 h Agency for Toxic Substances and Disease Registry (ATSDR) MRL 6 19 14 to 364 days ERPG = Emergency Response Planning Guidelines. The primary focus of ERPGs is to provide guidelines for short-term exposures to airborne concentrations of acutely toxic, high-priority chemicals. collection and analysis of these data have not been involved in the cur- rent manuscript. The firstgas station, "GS -MW," was located in the US Midwest and is a 24-hour operation. The study was conducted from December 2014 to January 2015 for 20 full days, and fuel sales Vsares were about 450,000 gal (1.7 million Q per month. Fuel deliveries to the gas station usually took place during the nighttime. The second gas station, "GS -NW," was lo- cated on the US Northwest coast and closed at night. Hours of operation were between 6:00 am and 9:30 pm on weekdays and between 7 am and 7 pm on weekends. That study was conducted in October 2009 for 18 full days, and fuel sales were Vsares 700,000 gal (2.6 million L) per month. Both gas stations are considered to be high-volume, because they dispense >3.6 million gal of gasoline (both regular and premium) per year (CalEPA/CARB, 2005), and fuel was stored in underground storage tanks (USTs), which is typical in the US. Both gas stations had Stage 11 vapor recovery installed using the vacuum -assist method. In that method, gasoline vapors, which would be ejected into the atmosphere as a working loss during refueling of customer vehicle tanks, are col- lected at the vehicle/nozzle interface by a vacuum purnp. The recovered vapors are then directed via a coaxial hose back into the combined stor- age tank ullage (head space) of the gas station. Stage I vapor recovery was also used at both gas stations during fuel deliveries. Both sites had a 3 -inch diameter (7.5 cm) single above -grade vent pipe with below - grade manifold that connected the vent lines from several USTs; the cracking pressures of the P/V valves were set to +3 and —8 iwc (+7.5 and —20 hPa). 2.2. Vent emission measurements To quantify evaporative fuel releases through the vent pipe of a stor- age tank, the volumetric flow of the mixture of gasoline vapor and air was measured in the vent pipe. A dry gas diaphragm flow meter (American Meter Company, Model AC -250) was used. For each cubic foot (28 Q of gas flowing through the meter, a digital pulse was gener- ated. Every minute, the number of pulses was read out and stored to- gether with date and time on a data logger. Gas flow meters were obtained from a distributor calibrated and equipped with temperature compensation and a pulse meter. To determine the time -dependent volumetric flow rate Q(t) of the gasoline vapor/air mixture through the vent pipe, the time series of measured flow volumes were integrated over an averaging period (15 or 60 min) and divided by the duration of that period. Le., Q(t) is given by the number of pulses registered by the gas flow meter in a time window multiplied by i cubic foot and divided by the averaging time. The 15 -minute averaging time was chosen to visualize time - dependent data, while the 60 -minute averaging time was chosen be- cause air pollution simulations were performed at that resolution. Gas pressure p in the ullage of the storage tank was measured to as- sess vent emission patterns. For instance, releases can occur when the pressure exceeds the cracking pressure of the P/V valve in the vent pipe (the dry gas flow meter was fitted with a P/V valve on the outlet). Pressure was measured with a differential pressure sensor (Cerabar PMC 41, Endress + Hauser) every 4 s, and 2 -minute average values were stored. The sensor range was scaled from —15 to +15 iwc (-37 to +37 hPa), with a full scale accuracy of 0.20%. We also obtained 15 - and 60 -minute averaged tank pressure data p(t) where averages repre- sent the means of the 2 -minute average pressure measurements taken during each time window. 2.3. Descriptive analysis For the 60 -minute flow rate, we calculated medians and inter quar- tile ranges (IQRs). To illustrate diurnal fluctuations in vapor emissions, we created box plots for the 60 -minute flow rate distribution that oc- curred during each hour of the day. Spearman correlation coefficients between the time series for pressure and flow rate were calculated to evaluate whether pressure can be used to infer vent emissions. To estimate the mass flow rate of gasoline rho, that is released through the vent pipe in the form of a mixture of gasoline vapors and fresh air, we assumed, following the protocol of a study by the California Air Pollution Control Officers Association (CAPCOA) that assessed risks from fuel emissions from gas station (Appendix D-2 (CAPCOA, 1997)), that the density of gasoline vapors in this mixture is given bypg (v) = 0.3 x 65 Ib / 379 0 = 0.824 kg/m3, i.e., the molar percentages of gaso- line and air were 30% and 70%, respectively. Then the volumetric flow rate Qcan be converted into a mass flow rate of the vaporized gasoline: ritga� = P(v) Q (1) To arrive at vent emission factors, we first calculated the mean volu- metric flow rate Q, and then the mean mass flow rate rhgos - pg� Q. From the latter, one can calculate the vent emission factor EFvent= mgas/Vaales (2) For EF„e„t, CARB uses units of pounds of emitted gasoline vapors (also called total organic gases (TOG)) per 1000 gal dispensed, or more briefly lb/kgal where lcgal stands for kilogallons. As we were not able to measure benzene levels in the tank ullage, we assumed like the CAPCOA study (Section C) that the density of the mix- ture of gasoline vapors and fresh air was p,,,;.°7 =1.05 lb/ft3 = 1.682 kg/0 and that the emitted gasoline vapor/air mixture contained 0.3% of benzene by weight (CAPCOA, 1997). Therefore, the mass flow rate of benzene through the vent pipe was estimated as follows: mbeia = 0.003 plmIx Q (3) 2.4. Air pollution modeling We used the AERMOD Modeling System developed by the US Envi- ronmental Protection Agency (EPA) to model the dispersion of benzene vapors released into the environment through vent pipes of fuel storage tanks and from other sources (Cimorelli et al., 2005). AERMOD simu- lates atmospheric pollutant transport at a 1 -hour temporal resolution. 3D polar grids were created with the gas station in the origin and poten- tial receptors at different radial distances (up to 170 m) and angles (10° 16-51 2242 M. Hilpeit et at I Science of the Total Environment 650 (2019) 2239-2250 increments). The grids were placed at the ground level (z = 0 m), in the breathing zone (z = 2 m), and at the 2nd floor level (z = 4 m) where the vent pipe emissions were assumed to occur. The topography was simplified for modeling purposes consistent with the CAPCOA study (CAPCOA, 1997), i.e., the terrain was assumed to be flat with no build- ings present. Vent pipe emissions were modeled as a capped point source. Chemical reactions of benzene were not modeled, as residence times of atmospheric benzene are on the order of hours or even days (ATSDR, 2007), i.e, much longer than the travel time of benzene vapors across the 340-m diameter model domain. For the period of time when vent emission measurements were made, we obtained meteorological data at a 1 -hour temporal resolution that are representative for the geographic locations of the two gas sta- tions. Table SI -1 provides descriptive statistics of that data. The time se- ries were used in AERMOD to model the transport of benzene in the temporally varying turbulent atmosphere. We also used the 1 -hour av- erage time series of benzene emission rates (Eq. (3)) as an input into AERMOD. To evaluate at each grid point whether OEHHA's acute REL or AIMS ERPG levels were exceeded at least once, we determined maximum 1 - hour average benzene concentrations that were simulated for about three weeks. To evaluate how often the OEHHA REL was exceeded at each grid point in the breathing zone, we created plots indicating the number of exceedances and the day when the maximum benzene level was observed. To facilitate comparison to published benzene measurements around gas stations, we determined for each simulated radial distance from a gas station the mean of the average concentrations simulated for each ten degree increment on the radius around the gas station. 3. Results: vent releases 3.1. Times series of tank pressure and flow rate Fig. 2 shows the time -series data for the volumetric flow rate Qof the gasoline vapor/air mixture through the vent pipe and tank pressure p that we collected at the two gas stations. At GS -MW, little vapor was typically released in the late night and in the very early morning, while releases were generally much higher during the daytime and eve- nings, presumably when more fuel was dispensed (Fig. 2a). Occasion- ally, no vapor releases occurred for several hours. While we do not have access to time of fuel delivery records, field visits indicate that time periods with no releases coincide with fuel deliveries. For instance, fuel delivery likely occurred on January 6 at 7 pm (see Fig. 3a; an ampli- fication of data shown in Fig. 2a). As a result, the UST pressure dropped by about 10 hPa, far below the cracking pressure of the PN valve. The decreased gas pressure in the ullage increased until the cracking pres- sure of the PN valve was reached. A very small vapor release (--2 L/min) was observed briefly on the next day at 2 am. The vapor flow rate becomes relatively large again, -12 L/min, only after 6 am, i.e., 11 h after fuel delivery. Fig. 3b amplifies a major vapor release at GS -MW. The UST pressure significantly exceeded the cracking pressure of the PN valve and rose rapidly up to 37 hPa, which coincides with vapors being released at a high flow rate (15 -min average) of about 470 L/min. At GS -NW, vapor releases followed a quite different pattern (Fig. 2b). Contrary to GS -MW, vapor releases occurred in a cyclical pattern, and tended to be higher in the late night and in the very early morning when the gas station was closed. 3.2. Statistics of vapor emissions The average volumetric flow rate Q through the vent pipe for the en- tire period of time during which measurements were taken was Q = 7.9 L/min for GS -MW and Q = 15.4 L/min for GS -NW, which is consistent with the higher sales volume Vswes of GS -NW. These emis- sions'consist of a mixture of gasoline vapors and air. Using Eq. (1), the volumetric flow rates were converted into average mass flow rates of gasoline: mg, = 0.39 kg/h for GS -MW and mga, = 0.76 kg/h for GS - NW. Using Eq. (2), we determined a vent emission factor EFVP1t= 0.17 kg per 1000 L = 1.4 lb/kgal for GS -MW and EF,e„t= 0.21 kg per 1000 L = 1.7 Ib/kgal for GS -NW. The medians (IQRs) for the 60 -minute averaged flow rate Q (L/min) were 6.1 (1.9,10.9) for GS -MW and 16.0 (12.7,18.4) for GS -NW. For GS - MW, the mean is larger than the median, indicating a more skewed dis- tribution of flow rates when compared to GS -NW. Also the first quartile is much lower than the median for GS -MW, indicating that there are pe- riods of time during which little emissions occurred. Conversely, GS - NW was releasing emissions more consistently. Fig. 4a shows boxplots illustrating the distribution of flow rate Qfor each hour of the day at GS -MW. Less vapor was released between 10 pm and 4 am, even though the gas station was in operation, albeit at lower activity levels. The flow rate Q at GS -NW (Fig. 4b) had fewer- outliers, and the highest outlier was an order of magnitude lower than the highest one at GS -MW. Emissions were highest between 1 and 3 am, when the gas station was closed. The Spearman correlation coefficients between tank pressure p and vent flow rate Q were r = 0.58 for GS -MW and r = 0.85 for GS -NW. Thus, vent releases are moderately and strongly correlated with tank pressure, respectively. Table 2 summarizes statistical properties of vent emissions at the two gas stations. 4. Results: air pollution modeling 4.1. Emission sources and rates Vent pipe emissions of benzene were modeled at a 1 -hour temporal resolution as described in Section 2.4. However, they are not the sole source of gasoline emissions at gas stations. Accidental spills from noz- zles regularly occur near the dispensers, "refueling losses" can occur when gasoline vapors are released from the vehicle tank during refueling due to the rising liquid levels in the tanks, fuel vapors are re- leased from permeable dispensing hoses, and "fugitive" or leakage emissions occur with driving force derived from storage tank pressure. In Section A of Supporting material, we detail how these other emission sources were modeled. Table 3 summarizes estimated mean emission rates. Note that the vent pipe losses are much greater than other losses. 4.2. Predicted benzene levels Fig. 5 shows for both gas stations and at each grid point the maxi- mum 1 -hour average benzene concentration observed during the simu- lated periods in time. Benzene levels depend significantly on elevation within a 50 -meter radius around the centers of the gas stations. Close to the centers of the gas stations, benzene levels are higher at the 4-m elevation and at ground level due to vent pipe emissions, which repre- sent the largest emission source (Table 3). Further than 50 m away from the center, the vertical concentration differences become less obvi- ous due to dispersion causing vertical mixing of benzene vapors. At GS -MW, the 1 -hour acute REL of 26 µg/m3 was exceeded 160 m away from the center of the gas station, at the location (x = 158 m, y = 28 m) both at ground level and in the breathing zone. At grid points with a distance >50 m from the center of the gas station, the REL was exceeded at most once (Fig. SI -1a). How- ever, the exceedance at different grid points did not occur on the same day (Fig. SI -1b). Within the 20 days during the measure- ment campaign, exceedances occurred on the 4th and 13th of January. At GS -NW, the furthest REL exceedance occurred at 50 m from the center of the gas station at the grid point (x = —38 m, y = 32 in) as 16-52 (a) 0 o 0 0 o 0 o 0 0 on 0 rn o rn m 0 0 m o 40 - m 0 on o 0 0 N N I 1 o N o N 0 0 0 0 N N N N o 0 N N 0 N 0 N 0 0 N N 0 N i 0 N 0 N b Q O E L O� Ti L L Fi Ti O O O 9 I 5 O B O L L O U O 30- 0 r, Ti Q In nr' rfi m o N N rN� N N N N N ccccbbbb N N Fig. 7- Time series of ullage pressure (left ordinate) and volumetric flow rate Q(right ordinate) for (a) GS -MW and (b) GS -NW. Horizontal fick marks indicate midnights. The vertical dashed and thick solid gray lines enclose weekends. 20-a 20- a CL10 - I t 0 I I I i 10 N O N C N N N O O 0 N N N C C C N 0 N C N 0 N C N N N N 0 0 0 0 N N N N G C C C N O N C N N N N N a O O O O N N N N N C C C C N O N C N N N N O O O O N N N N C C C C m O m m m 6 m o m O m m m o o O m m m m m N 7 7en,- m m m CII o N N (b) 14 12 10 a e CL 6 4 2 0 600 400 300 c E 200 d 100 0 3 z 0 e 50 d 40 0 N b 30 .S 200 10 0 m m rn m rn rn m m rn m m 0 o 0 o 0 0 o 0 o 0 0 on 0 rn o rn m 0 0 m o m 0 m 0 on o 0 0 N N 0 N o N o N 0 0 0 0 N N N N o 0 N N 0 N 0 N 0 0 N N 0 N 0 N 0 N 0 N b Q O E L O� Ti L L Fi Ti O O O 9 L U 9 O 5 O B O L L O U O ii O r, Ti Q In nr' rfi m o N N rN� N N N N N ccccbbbb N N Fig. 7- Time series of ullage pressure (left ordinate) and volumetric flow rate Q(right ordinate) for (a) GS -MW and (b) GS -NW. Horizontal fick marks indicate midnights. The vertical dashed and thick solid gray lines enclose weekends. a 16-53 2244 6 6 ro L 4 d 2 0 -2 c c (a) 40 30 20 d 10 0 M. Hilpert et al. / Science of the Total Environment 650 (2019) 2239-2250 N d N pt N � � 14 12 10 a E 6 4 C7 2 0 0 C 'N-- 500 400 300 E 200 ` a 100 0 C O O c N W N CO N Fig, 3. Amplifications of time series data (15 -minute averages) for GS -MW. (a) Tank pressure p became negative after fuel delivery. Asa result, vent emission ceased for several hours. (b) A major vapor release (burst) likely occurred when the cracking pressure of the PN valve was significantly exceeded at around 9 pm during a non-compliant bulk fuel delivery. 200 150 I 100 50 gqBe����g�n% nR�1 Q, of� N c? T q O r 00 9 O N c2 V' O r2O N N N N N 6 O_ N_ _m 4 6 m h c0 m ON c7 r r r r r r N N N N (a) Hour of the Day 30- 25 0 25 T T m I I I s I c 20 I I T I T T T I I T I I � 15 1 1 1 1 i I ' 1 0310 1 1 1 1# 1 1 1 L3 x I I I I l l 5 I l I l l l l l u 0 N c? I <D r O O Oc7 N 72 O r N O) O N o7 d' O r N CO 't M c0 f- CO T N N N NN m 0 N r d' «7 c0 r a1 m 0 N CC OM N N (b) Hour of the Day Fig. 4. Distribution ofvent emissions Qobseived for each hour of the day at (a) GS -MW (inseitshows the IQRs of Q] and (b) GS -NW gas stations. In (a), outliers make it difficult to recognize variations in median hourly emissions. We therefore plotted in the inset only the IQRs. Boxes indicate median and IQ)t, whiskers values within 1.5 the IQR, and asterisks outliers. 16-54 M. Hilpert et at / Science of the Total Environment 650 (2019) 2239-2250 Table 2 Summary of gas station characteristics and vent emissions. 2245 GS -Mw GS -NW Units Sales volume Veo e, 450,000 700,000 gal/month Volumetric flow rates 0.65 Refueling 0.41 (of gasoline vapor/air mixture) Hose permeation 0.06 0.10 MeanQ 7.9 15.4 L/min Median (IQR) of 60 -min average 6.1 (1.9, 10.9) 16.0 (12.7, 18.4) L/min Maximum of 60 -min average 250 32.1 L/min Vent emission factor EFwnt 1.4 1.7 Ib/kgal Mass flow rates of gasoline (w/o air) Mean m8W 0.39 0.76 kg/h Maximum of 60 -min average 12.3 1.6 kg/h Correlation coefficient Between Q and p 0.58 0.85 - shown in Fig. SI -2a. At a distance of 40 m, the REL was exceeded three times at one grid point (260° angle), and at 35 m four tithes at two grid points (250° and 260° angles) (Fig. SI -2b). At a distance of 20 m, the RELwas exceeded at 30 (out of36) grid points, and on nine different days. Average benzene levels are shown in Fig. 6 for both gas stations. The MRL is exceeded at the elevation of the vent pipe opening, z = 4 m, up to 7 m away from for GS -MW and up to 8 m from GS -NW. Fig. 7 shows the average benzene concentration as a function of distance at an eleva- tion of 2 m. Close to the center, benzene levels first increase and then decrease. 5. Discussion 5.1. Vent emission factors We present unique data on vent emissions from USTs at two gas sta- tions. Emissions can be compared to vent losses assumed by CAPCOA (CAPCOA, 1997). For a gas station with Stage I and 11 vapor recovery tech- nology and a PN valve on the vent pipe of the UST (Scenario 6B), the CAPCOA study assumed loading losses of 0.084 and breathing losses of 0.025 Ib/kgal dispensed. The total loss of gasoline through the vent pipe is the sum of the two and amounts to a vent emission factor EFvent= 0.109 lb/kgal. Based on actual measurements in two fully functioning US gas stations, we obtained EFvent values of 1 A Ib/(gal for GS -MW and 1.71b/kgal for GS -NW, more than one order of magnitude higher than the CAPCOA estimate. While the difference between our measurements and the CAPCOA estimates may appear surprising, it is important to con- sider that the CAPCOA estimates are based on relatively few measure- ments and some unsupported assumptions (Aerovironment, 1994), particularly with regard to uncontrolled emissions due to equipment fail- ures or defects (Appendix A-5 (CAPCOA, 1997)). 52. Pressure measurements Tank tillage pressure p was moderately to strongly positively cor- related with vent flow rate Q, likely because exceedance of the crack- ing pressure of the PN valve causes a vent release. Thus pressure Table 3 Mean benzene emission rates tbb,, for the two gas stations. Emission source Benzene emissions (mg/s) Gas station GS -MW GS -NW Vent pipe 0.80 1.55 Spillage 0.39 0.65 Refueling 0.41 0.69 Hose permeation 0.06 0.10 Total 1.67 2.90 measurements can be used to infer vent releases. Real-time detec- tion of equipment failures and leaks via so-called in -station diagnos- tics systems is based on our observed correlations between p and Q. 5.3. Diur nal fluctuations in vent emissions Diurnal vent emissions were quite different at the two gas stations. At GS -MW, a 24-hour operation, vent emissions were high during the daytime, presumably due to PWD. Emissions ceased at night, likely be- cause less gasoline was dispensed and fuel deliveries with relatively cool product were frequent. Evaporative losses could also have been lower at night because the cooler delivered fuel would cause slight con- traction of the liquid phase with corresponding growth in the tillage vol- ume while at the same time lowering the vapor pressure of gasoline in the UST. At GS -NW, vent pipe releases occurred most of the time, during the daytime when fuel was dispensed (PWD) and at night when the gas sta- tion was closed. Vent releases were higher when the gas station was closed, suggesting that during the day -time Stage II vapor recovery re- sulted in the injection of vapors into the storage tank that were not completely equilibrated with the liquid gasoline. During night-time, the gradual equilibration of unsaturated air in the uilage of the UST with gasoline vapors could then have caused exceedance of the cracking pressure of the PN valve and consequently vapor release. It seems counterintuitive that less nighttime emissions occurred at the gas sta- tion where fuel was dispensed. However, while fuel is being dispensed, the outgoing liquid creates additional uilage volume, and depending on excess air ingestion rate, a negative pressure could result that lowers vent pipe emissions. Dispensing fuel to customer vehicles and the associated Stage 11 vapor recovery system interact with vent emissions and can even cause vent emission during PWD, because the vacuum -assist method can negatively interfere with Onboard Refueling Vapor Recovery (ORVR) installed in customer vehicles (EPA, 2004). However, Stage Il vapor recovery is not obsolete. It can be used in conjunction with ORVR to minimize exposure of gas station customers and workers to benzene due to working losses (Cruz -Nunez et al., 2003), particularly when customer vehicles are not equipped with ORVR (e.g., older vehi- cles, boats, motorcycles) or small volume gasoline containers are refueled. Enhanced Stage 11 vapor recovery technology can significantly reduce vapor emissions both at the nozzle and from UST vent pipes (CARB, 2013). 5.4. Fuel deliveries and accidental vent releases Based on observations and interpretation of time series of the tank pressure data, it is likely that the peals vent emissions (e.g., Fig. 3b) were partly due to non-compliant bulk fuel drops where the Stage I vapor recovery system either was not correctly hooked up by the deliv- ery driver or to hardware problems with piping and/or valves. This 16-55 2246 M. Hilpelt et al. / Science of the Total Environment 650 (2019) 2239-2250 GS -MW GS -NW C N 11 N O 11 N 150 100 50 0 -50 -100 -150 150 100 50 0 -50 -100 -150 150 100 50 0 -50 -100 -150 •_— 200 150 180 9 . 160 100 140 50 120 100 0 so -50 60 40 -100 20 -150 0 — - -150 -100 -50 0 50 100 150 -150 -100 -50 0 50 100 150 200 150 180 160 100 140 50 120 100 0 80 -50 60 40 -100 20 -150 0 -150 -100 -50 0 50 100 150 -150 -100 -50 0 50 100 150 200 150 180 160 100 140 50 120 100 0 80 50 60 40 -100 20 -150 0 -150 -100 -50 0 50 100 150 -150 -100 -50 0 50 100 150 50 45 40 35 30 25 20 15 10 5 0 50 45 40 35 30 25 20 15 10 5 0 50 45 40 »y 35 30 25 20 15 10 5 0 Fig. 5. Modeled maximum benzene concentrations for GS -MW and GS -NW at three different elevations z. The x- and y-axes indicate horizontal coordinates in meters. The color indicates benzene levels in units of W°/m3. Left column: time series of benzene emission rates were used. Right column: average benzene emission rate was used in the modeling. The white isoline indicates OEHHNs acute REL of 26 pg/m3 = 8 ppb. conjecture is consistent with typical US storage tank volumes (10,000 assumed working loss of 38,000 L. This could be due to a fuel delivery, to 30,000 gal). Assuming that Phase I vapor recovery did not work at all which involved dropping fuel from multiple compartments of a tanker and that 10,000 gal (38,000 L) of fuel were delivered, the working loss truck, with the vapor return hose not being correctly hooked up for (volume of gasoline vapor/air mixture released to the atmosphere only some of the emptied compartments. through the vent pipe) is 38,000 L. It is also reasonable to assume that At GS -MW, UST pressure decreased after fuel delivery (causing vent delivery lasted less than I h. According to Table 2, the maximum hourly emissions to cease for several hours) during the climatic conditions flow rate through the vent pipe was 250 L/min at GS -MW, which would prevalent during the observation period, behavior not observed at GS - result in a maximum cumulative vapor release of 15,000 L within this NW. In practice, it is possible to observe both positive and negative pres- hour. The measured maximum cumulative release underestimates the sure excursions, even during the same fuel delivery (when multiple fuel 16-56 E d' iI N E N 11 N M. Hilpertet at / Science of the Total Environment 650 (2019) 2239-2250 GS -MW GS -NW 50 40 30 20 10 0 -10 li l IjlioVll�I���,uG,�lill'lijl,ll�ll y of lil�r',Yi IjY� ��y f 11111° 20 V�liIIIIIIIII�' VIII -30- -40 -50._.__._..._.__..,._.._....,._,__�.__,___-. -50 -40 -30 -20 -10 0 10 20 30 40 50 50 40 30 20 10 0 -t0 li l rii y of lil�r',Yi IjY� ��y f 11111° -20 -30 -40 -50 -50 -40 -30 -20 -10 0 10 20 30 40 50 50 — — 40 30 20 10 0 -10 i -20 .30 -40 -50 -50 -40 -30 -20 -10 0 10 20 30 40 50 5 4.5 4 3.5 3 2.5 2 1.5 1 0.5 0 5 4,5 4 3.5 3 2.5 2 1.5 1 0.5 0 Fj 4.5 4 3.5 3 2.5 2 1.5 1 0.5 0 2247 Fig. 6. Modeled average benzene concentrations for GS -MW and GS -NW at three different elevations z. The x- and y-axes indicate horizontal coordinates in meters. The color indicates benzene levels in pg/m3 and the white isoline the MRL of 19 pg/m3 = 6 ppb. compartments of tanker trucks are unloaded), when Stage I vapor re- covery is in place (personal observation by TT). 5.5. Exceedance of 1 -hour exposure limits AERMOD air pollution modeling suggests that at GS -MW the ]- hour acute REL was exceeded at one grid point 160 m (525 ft) from the center of the gas station once in 20 days (Fig. 5), This distance is larger than the 300 -ft (91 m) setback distance recommended by CARB for large gasoline dispensing facility (CalEPA/CARB, 2005). Assuming the gas station's fence line is <225 ft. (69 m) from its cen- ter (where the vent pipe was assumed to be located), our study shows that sensitive land uses at a distance further than 300 ft from the fence line of the gas station would represent a health con- cern despite compliance with the CARB guidelines because of non- compliance with the acute REL. 16-57 2248 3.5 3 m E m 2.5 M. Hilpett et aL I Science of the Total Environment 650 (2019) 2239-2250 GS -MW GS -NW 20 40 60 80 100 120 140 160 Distance from center of gas station (m) Fig. 7. Mean benzene concentrations as a function of distance from the center of the gas stations. At any location further than 50 m from the gas station's center, the REL was exceeded at most once during the 20 -day measurement cam- paign (Fig. SI -1a). However, exceedance occurred at several locations, and on two different days (Fig. SI -1b). E.g., at a distance of 120 m from the center, the REL was exceeded at three grid points, and the number of grid points increased with closer proximity to the gas station. This suggests that it was not just a single worst-case scenario or a single ac- cidental vapor release that led to REL exceedance; rather exceedance may occur more frequently than is anticipated. Prevalent wind direc- tions during the measurement campaign explained the directional pat- terns of exceedances (see the wind rose in Fig. SI -3a). At GS -NW, despite its higher sales volume, the REL was exceeded only closer than 50 m from the gas station's center. However, exceed- ance occurred much more frequently (Fig. SI -2), likely because of the higher sales volume of GS -NW. Again, the wind rose for GS -NW (Fig. SI -3b) explains spatial patterns of REL exceedance. None of AIHA's three ERPG levels were exceeded, meaning that indi- viduals, except perhaps sensitive members of the public, would not have experienced more than mild, transient adverse health effects. 5.6. Average benzene levels The initial increase in average benzene levels when moving away from the gas stations' centers (Fig. 7) is likely due to the vent emissions (at4 m) which represent the largest benzene source, and which require a certain transport distance until they reach the 2-m level through dis- persion. Further away from the gas station, benzene levels are higher for GS -NW than for GS -MW likely because of the higher sales volume of GS - NW. However, close to the center, benzene levels are higher at GS -MW. This can be attributed to the higher wind speeds at GS -NW (Table SI -1), which result in greater initial dilution of emitted pollutants in the in- coming airstream and also in greater subsequent pollutant dispersion. Modeled average benzene concentrations are generally lower (-10 Ng/m3 or less) than those measured in the surroundings of gas stations, likely because our simulations do not account for traffic -related air pol- lution (TRAP). For instance, a study published by the Canadian petro- leum industry found average benzene concentrations of 146 and 461 ppb (466 and 1473 pg/1113) at the gas station property boundary in summer and winter, respectively (Akland, 1993), values orders of magnitudes higher than ours. A South Korean study examined outdoor and indoor benzene concentrations at numerous residences within 30 m and between 60 and 100 m of gas stations and found median out- door benzene concentrations of 9.9 and 6.0 µg/m3, respectively (Jo & Moon, 1999), while we simulated benzene levels on the order of I µg/ m3 (Fig. 7). In a study on atmospheric BTEX levels in an urban area in Iran, the three highest BTEX levels were measured near gas stations (-150 m away); the measured benzene levels (64 ± 36, 31 f 28, 52 f 26 pg/m3) were again much higher than ours simulated at that dis- tance, likely due to TRAP. Our modeled average benzene levels at a dis- tance of about 50 m are on the same order as background benzene levels of 1.0 µg/m3 that were measured in 2010 in the National Air Toxics Trend Sites (NATTS) network of 27 stations located in most major urban areas in the US (Strum & Scheffe, 2016). However, our modeled levels at a distance of 170 m were 0.07 at GS -MW and 0.12 at GS -NW, a non -negligible addition to urban background levels. At both gas stations, the MRL was exceeded at the level of the vent pipe opening in the vicinity of the gas stations, up to 7 m away from the vent pipe at GS -MW and 8 m at GS -NW. Therefore there might be an appreciable risk of adverse noncancer health effects for individuals living at the 2nd -floor level relatively close to high-volume gas stations such as GS -MW and GS -NW. 5.7. Limitations A limitation of our study is that data were collected only in fall and winter. Results cannot be easily extrapolated to other seasons, because vent pipe emissions are seasonally dependent, e.g., due to seasonally de- pendent gasoline formulations and meteorological conditions. How- ever, modeled exceedance of the OEHHA acute REL in the winter season is already of concern, because that REL was developed for once per month or less exposures. Another limitation is that we did not directly measure benzene levels in the vent pipe, and instead made assumptions about vapor com- position that were also made in the CAPCOA study (CAPCOA, 1997) of gas station emissions. In practice it may be difficult to obtain permission from gas station owners to measure benzene levels directly. In part because we did not want to reveal the locations of the gas stations, we did not use site-specific topography information in the air dispersion modeling and instead assumed flat terrain. While this simpli- fication results in less accurate air pollution predictions for the two sites, using a "generic" gas station is perhaps more representative of other gas station sites, and is consistentwith an approach used in a previous study (CAPCOA, 1997). Finally, our study did not predict benzene levels in indoor environ- ments. Even though indoor air pollution levels may substantially differ from outdoor levels due to indoor sources (e.g., smoking, photocopying) (EI-Hashemy & Ali, 2018), our study can still inform exposure levels in indoor environments as outdoor sources may be the main contributors to indoor air pollution, e.g., in buildings situated in urban areas and close to industrial zones or streets with heavy traffic Qones,1999). This is rel- evant to workers and customers in C -stores or other fast-food/gasoline station combination facilities. 6. Conclusions Our study is to the best of our knowledge the first one to (1) report hourly vent emission data for gasoline storage tanks in the peer- reviewed literature and (2) use these data in hourly simulations of at- mospheric benzene vapor transport. This allowed us to examine poten- tial exceedance of short-term exposure limits for benzene. Prior studies including CAPCOA's (CAPCOA, 1997) could not do so as average emis- sion rates were used (only meteorological data was used at an hourly resolution). Our findings support the need to revisit setback distances for gas sta- tions, which are based on >2 -decade old estimates of vent emissions (Aerovironment,1994). Also, CARB setback distances are based on a bi- nary decision, related to whether the gasoline sales volume Vsales is >3.6 million gal per year. Our data support, however, that setback 16-58 M. Hilpert et at. / Science of the Total Environment 650 (2019) 2239-2250 distances should be a continuous function of sales volume Vsales and also include the type of controls installed at the facility. Setback distances should also address health outcomes other than cancer. OEHHA's acute REL for benzene could be used to inform setback distances as it ac- counts for non -cancer adverse health effects of benzene and its metab- olites (Budroe, 2014). ATSDR's MRL could also be considered since it is a health -based limit. We note that CARB recommended their setback distances in 2005, presumably assuming pollution prevention technology yielding a 90% reduction in benzene emissions (CalEPA/CARB, 2005). Since then, CARB further promoted use of second -generation vapor recovery tech- nology (Enhanced Vapor Recovery, EVR) to reduce emissions further. EVR includes technology that is supposed to prevent fuel vapors in overpressurized tanks from being expelled into the atmosphere (CARB, 2017). To that end, "bladder tanks" have been proposed, into which the gasoline vapor/air mixture is directed as the pressure in the combined ullage space of the storage tank increases, and from which the mixture is redirected into the fuel storage tanks if the ullage pres- sure becomes negative (when fuel is dispensed). The challenge with such a system is to ensure that the bladder tank capacity is not exceeded by the fuel evaporation rate. Alternatively, fuel vapor release can be re- duced by processing the fuel/air mixture through either a semi- permeable membrane which selectively exhausts clean air and returns enriched fuel vapor (Semenova, 2004) or an activated carbon filter which adsorbs hydrocarbons (and water vapor) and exhausts air into the atmosphere, or by combusting the fuel/air mixture which would otherwise be released through the P/V valve. Therefore, current CARB setback distances might be adequate for gas stations in California but less so for the other 49 US states, and other countries -depending on pollution prevention technology requirements. The larger areal extent of modeled REL exceedance at GS -MW is due to "accidental" releases of gasoline vapors. Even though regulations ap- pear generally not to be driven by accidental releases, at GS -NW such releases likely led on two different days to REL exceedances at distances beyond CARB's recommended setback distances. Policies should ad- dress accidental fuel vapor releases that depending on pollution preven- tion technology (here Stage I vapor recovery) and its proper functioning can occur on a frequent basis (twice at GS -MW within about three weeks). In future work, potential exceedance of other shorter -term exposure limits should be examined, e.g„ the 15 -minute short-term exposure limits (STELs) and the 8 -hour time -weighted averages (TWAs) used for occupational exposures. Adcnowledgements This work was supported by NIH grant P30 ES009089 and the Envi- ronment, Energy, Sustainability and Health Institute at Johns Hopkins University. Competing financial interest declaration TT directs a company (ARID), which develops technologies for re- ducing fuel emissions from gasoline -handling operations. AMR, BAM and MH have no conflicts of interests to declare. Appendix A. Supplementary data Supplementary data to this article can be found online at https://doi. org/10.1016/j.scitotenv.2018.09.303. 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(Eds.), Pro- ceedings of the 8th International Symposium on Heating, Ventilation and Air Condi- tioning. Indoor and Outdoor Environment Vol, 1. Springer Berlin Heidelberg, Berlin, Heidelberg, pp. 13-21. 16-60 lthy ir, Healthy Brains: Advancing Air a. Pollution o: •z .j Protect Children's Health Evidence is growing on the adverse neurodevelopmental effects of exposure to combus- tion -related air pollution. Project TENDR (Targeting En- vironmental Neurodevelopmental Risks), a unique collaboration of leading scientists, health pro- fessionals, and children's and envi- ronmental health advocates, has identified combustion -related air pollutants as critical targets for action to protect healthy brain development. We present policy recom- mendations for maintaining and strengthening federal en- vironmental health protections, advancing state and local ac- tions, and supporting scientific research to inform effective strategies for reducing children's exposures to combustion -related air pollution. Such actions not only would improve children's neurological development but also would have the important co -benefit of climate change mitigation and further improve- ments in other health conditions. (Am J Public Health. Published online ahead of print February 21, 2019: e1 -e5. doi:10.2105/AJPH. 2018.304902) Devon C. Payne -Sturges, D&H, Melanie A. Marty, PhD, Frederica Perera, DrPH, PhD, Mark D. Miller, MD, 11aureen Swanson, MPA, Kristie Ellickson, PhD, Deborah A, Cory-Slechta, PhD, Bente Ritz, MD, PhD, Joint Balntes, MD, Laura Anderko, RN, PAD, Evelyn O. Talbott, DrPH, Robert Gould, MD, and Irva Hertz-Picciotto, PAD, MPH hildren are exposed pre- natally and in early child- hood to multiple environmental stressors that can adversely af- fect their cognitive abilities, academic performance and con- sequent educational trajectories, adult health, wealth, and social status. 1,2 Project TENDR (Tar- geting Environmental Neuro- developmental Risks), a unique collaboration ofleading scientists, health professionals, and chil- dren's and environmental health advocates, points to growing scientific evidence linking ex- posure to toxic chemicals during early brain development with brain disorders and calls on individuals, industries, and policymakers to reduce these exposures.3 Developmental dis- abilities, such as learning disabil- ities, developmental delays, autism, and attention -deficit/ hyperactivity disorder (ADHD), affect one in six children in the United States, and the rate of these disorders is rising.4 The estimated annual cost (medical care, lost economic productivity) of environmentally mediated neurodevelopmental disorders in US children is $74.3 billion.5 Evidence linking combustion - related air pollution with adverse neurodevelopment is mounting. Sources of these pollutants in- clude fossil fuel burning for power generation and trans- portation, wildfires, and burning of agricultural waste. Project TENDR identified these air pollutants—polycyclic aromatic hydrocarbons, nitrogen dioxide, fine particulate matter (PM2.5, including ultrafine particulate matter [UFP]; <_ 100 nm), and other pollutants for which ni- trogen dioxide and PM2.5 are markers—as exemplary targets for action. The purpose of this commentary is to present Proj- ect TENDR's reconunendations to reduce combustion -related air pollutant emissions to protect healthy brain development. NEURODEVELOPMENTAL EFFECTS OF AIR POLLUTION Air pollution exposure has been linked with preterm birth and low birth weight,6'7 known risk factors for many neurodevelopmental disorders in children.8'9 A growing body of human studies associate exposure to combustion -related air pol- lutants (PM2.5, polycyclic aro- matic hydrocarbons, nitrogen dioxide, black carbon) with ad- verse effects on brain develop- ment, including deficits in intelligence, memory, and be- havior. 10-12 Polycyclic aromatic hydrocarbons, a component of PM2.5, have been associated with developmental delay; reduced IQ; symptoms of anxiety, de- pression, and inattention 13; ADHD; and reduced size of brain regions important for pro- cessing information and impulse control. 14 Other studies have linked roadway proximity, 15 traffic -related PM, 16 elemental carbon, or nitrogen dioxide 17 to decreased cognitive function, ABOUT THE AUTHORS Devon C. Payne -Sturges is with the Maryland Institute for Applied Environmental Health, University of Maryland School of Public Health, College Park. Melanie A. Marty is with the Department of Environmental Toxicology, University of California, Davis. Frederica Perera is with the Columbia Centerfor Children's Environmental Health, Columbia University, New York, NY. Mark D. Miller and John Balmes are with the Division of Occupational Environmental Medicine, University of California, San Francisco. Maureen Swanson is with the Learning Disabilities Association of America, Pittsburgh, PA. Kristie Ellickson is with the Minnesota State Pollution Control Agency, Saint Paul. Deborah A. Cory-Slechta is with the University of Rochester Medical Center, Rochester, NY. Bente Ritz is with the Fielding School of Public Health, University of California, Los Angeles. Laura Anderko is with the School of Nursing and Health Studies, Georgetown University, Washington, DC. Evelyn O. Talbott is with the School of Public Health, University of Pittsburgh, Pittsburgh. Robert Gould is with the School of Medicine, University of California, San Francisco. Irva Hertz-Picciotto is with the Department of Public Health Sciences, School of Medicine; the MIND Institute; and the Children's Center fo Environmental Health, University of California, Davis. Correspoudennce should be sent to Devon C. Payne-Sthuges, DrJaH, MPH, Avlaryland hutitute farApplied Euvironnhenntal Health, University ofAlaryland Sdhool ofPublicl4ealtlh, 2234L SPH, 255 Valley Dr, College Park, AID 20742 le -mail: dpsl ct umd.edu). Reprints can be ordered at http://tiiiii,.ajpli.org by clicking the `Reprints" link. This article was accepted November 24, 2018. doi: 10.2105/AJPH.2018.304902 Published online ahead of print February 21, 2019 AJPH Payne -Sturges et of Peer Reviewed Commentary el 16-61 including deficits in memory and attention. The effect of poly- cyclic aromatic hydrocarbon exposures during fetal develop- ment on cognitive and behavioral outcomes is magnified by mate- rial hardship or maternal de- moralization. 18 Low-income communities are thus dispro- portionately exposed and uniquely vulnerable because of family and community economic hardship. Increasing evidence links prenatal exposure to traffic -related air pollutants 19 and PM,., 20 to autism spectrum disorder. Laboratory studies provide support for the neurotoxic effects of exposure to air pollutants. In price, prenatal exposures to fine and ultrafine particles caused enlarged lateral ventricles, an early and excessive myelination pattern, an increase in the size of the corpus callosum (the bridge connecting the two brain hemi- spheres), and a decrease in the hippocampal area (involved in emotional regulation, spatial navigation, and memory).21 Prenatal diesel exhaust exposure produced inflammation in fetal brain, decreased activity, in- creased anxiety, and brain microglial activation (indicating a pathological process) in males as adults .22 Prenatal diesel exhaust exposure in mice reduced loco- motor activity and altered levels of neurotransinitters (dopamine, norepinephrine) in a region - specific manner. 23 Chronic exposure of young adult mice to UFP produced depressive -like behaviors and impaired spatial learning and memory. 24 In a series of studies, postnatal UFP exposures of mice produced a pattern of de- velopmental neurotoxicity no- tably similar to the hypothesized mechanistic underpinnings of autism spectrum disorder. Both sexes exposed during early postnatal life, a period considered equivalent to the human third trimester, to concentrated am- bient UFP showed disrupted development of the corpus cal- losum and persistent elevation of brain glutamate levels—an ex- citatory neurotransmitter—with effects more pronounced in males and persistent through adulthood. UFP is likely the most toxic fraction of particulate air pollution and once inhaled can migrate to the central nervous system via the nasal cavity, cir- culating blood, or sensory nerves found in the gastrointestinal tract. 25 Exposures in these studies were at levels consistent with high -traffic areas of major US cities and thus highly relevant. Although specific autism spec- trum disorder -defining behav- iors were not examined in this series of studies, impaired learn- ing and short-term memory and increased impulsivity were observed.26 Potential cellular mechanisms responsible for air pollution - induced neurological damage include persistent glial activa- tion with concomitant neuroinflammation and oxidative stress. 22,27 29 The fundings in controlled laboratory studies are consistent with and provide mechanistic evidence for air pollutant effects on neuro- cognitive and neurobehavioral outcomes observed in humans. RECOMMENDATIONS Managing ambient air quality in the United States requires a joint effort between the federal and state governments as outlined in the Clean Air Act (1970; amended 1990; 42 USC §7401-7671q [2017]). After passage of the Clean Air Act, levels of six common air pollut- ants—PM, ozone, lead, carbon monoxide, oxides of nitrogen and sulfur (known as criteria air pollutants)—and numerous other toxic pollutants dramati- cally declined while the US economy grew. 30,31 Yet chil- dren and pregnant women across the United States are still ex- posed to air pollution levels above current standards, 32 Regulatory actions to reduce air pollution, specifically PM, ozone, and nitrogen oxide, were spurred by abundant evi- dence linking air pollution to cardiovascular and respira- tory disease, including premature mortality. Given the growing scientific evidence of neuro- developmental effects, we must continue to pursue reductions in air pollution not only to reduce cardiovascular and respiratory disease but also to improve children's neurodevelopment. The composition ofpollutants differs somewhat by combustion source, but it is far more effective to focus on reducing exposure to combustion -related pollutants as a group rather than to address them one by one. Reducing combustion -related emissions would have the important co -benefit of reducing green- house gases. Climate change is increasing the frequency and intensity of wildfires, which cause short-term, high-level ex- posure to combustion -related pollutants, and is predicted to increase ozone concentrations during warns inonths of the year and increase combustion -related air pollution from increased en- ergy production for air condi- tioning. Exposure to excessive ambient heat increases risk for premature delivery, 33 itself a risk factor for developmental delay. Given the disproportionate ef- fects of air pollution and climate change on children, Project TENDR recommends the fol- lowing actions. Maintain and Strengthen Health Protections Recoamremiatiou 1: The US Errviromnerrtal Protection Agency (EPA) should give greater con- sideration to the evidence on the effects of air pollutants on neuro- development when setting stan- dards.for combustion -related air pollutants and when assessing the f,ll cost of the health effects of air polhrtion, The EPA sets the National Ambient Air Quality Standards (NAAQS) for the criteria air pollutants, which include PM, and other combustion -related air pollut- ants. These standards are the driving force for reducing ex- posure to the criteria air pol- lutants in the United States. As part of the standard setting process, the EPA conducts a cost -benefit assessment. The EPA prefers to base the NAAQS and accompanying cost -benefit assessment on the health out- comes that they determine are causally associated with expo- sure (e.g., mortality in adults for PM2.$) Because the effects on de- veloping brains can involve large lifelong costs to the individual, families, and society, the EPA should develop an assessment of the health and economic cost of neurodevelopmental disorders associated with PM, nitrogen oxide, and other combustion - related air pollutants, even if the evidence is limited for a particular pollutant. The benefits of re- ducing exposure and thus de- creasing neurodevelopmental disorders should be incorporated into the cost -benefit assessment for the corresponding NAAQS. Current P11N1 NAAQS review. The EPA has released its draft Integrated Science Assessment on the health effects ofPM2.5, which could lead to revisions of the NAAQS.34 The draft Integrated e2 Commentary Peer Reviewed Payne -Sturges et at. AJPH Published online ahead of print February 21, 2019 16-62 Science Assessment includes a re- view of scientific data on neuro- developmental health outcomes and describes the effects on the nervous system as "likely to be causal" for UFP based on strong evidence in animals of neurotoxi- city and altered neurodevelop- ment and for PM2.5 based on both animal and human studies. It is critical that the EPA in- clude the health and economic cost of neurodevelopmental ef- fects in the cost -benefit assess- ment for the PM2.5 NAAQS. Recommendation 2: Strengthen and enforce federal firel efficient), stmrdards. The 2017 to 2025 Light -Duty Vehicle Greenhouse Gas Emission Standards and Cor- porate Average Fuel Economy Standards issued by the EPA and the National Highway Traffic Safety Administration reduce greenhouse gas emissions and im- prove fuel economy. When fully implemented, the fuel economy of new vehicles will increase from an average of about 25 miles per gallon today to about 36 miles per gallon—that means in excess of 2000 fewer gallons of gas burned over a typical vehicle lifetime and lower exhaust emissions. These standards are expected to reduce exposures to combustion -related air pollutants linked to neuro- developmental hamr.35 Despite the public health benefits, these standards are un- der threat36 and may be delayed or rolled back. These public health protections should be maintained, if not strengthened. Advance State and Local Actions Reconunendation 3: Promote and advance clean merg), policies that reduce reliance ou fossil fuels, including coal, combusted for energy generation and transportation. Many states have programs in place to move toward renewable fuels for electricity generation. 37 New York has instituted pro- grams to obtain 50% of electricity generation from renewable sources by 2030; Washington, DC, and Oregon must meet that standard by 2032 and 2040, re- spectively.37-39 Hawaii and Cal- ifornia have a goal of 100% renewable energy for electricity generation by 2045. These pro- grams increase the share of energy generation from noncombustion sources, reduce air pollutant and greenhouse gas emissions, and push technology innovation. As states with strong programs in- crease electricity from renewable sources, other states could learn from those successes. State and local governments should move toward alternatives to fossil fuels for transportation. New regional transportation plans should include zero -emission transportation technologies for passenger vehicles and goods movement (e.g., within ports and rail yards and to distribution cen- ters). Although major automakers are now producing electric and fuel cell vehicles, supporting in- fiastructure is lagging. Policies that support construction of charging and hydrogen fueling stations (for fuel cells) are greatly needed. Dramatic reductions in trans- portation sources of air pollution are feasible and can be accelerated with public policies, as evidenced by reductions in air pollution in California from transportation sources.4o Recommendation 4: Tmget existing large sources of combustion -related airpollntants for emissions reductions, dramatically reduchtg exposures in neighboring cminmtlities. State and regional agencies should develop best practices to guide efforts across the United States toward re- ducing combustion -related pol- lutants from large sources near residential neighborhoods, such as major roadways, ports, and rail yards. 41 Regional planning ef- forts involving community par- ticipants, university investigators, pollution control agencies, and industry and union representa- tives have resulted in enussions reductions from the ports of Los Angeles and Long Beach, Cal- ifornia. Recommendations in- cluded replacement of older polluting trucks, clean and zero -emission truck technologies (e.g., all -electric, liquefied natu- ral gas, and hydrogen fuel cell trucks), retrofitting older trucks with pollution controls, and managing traffic routes. 42 The New Jersey Department of Environmental Protection worked with a community ad- visory group and local industries to produce emissions inventories and assess health risk around Camden, New Jersey, an area with large industries, a port, and major roadways in close prox- imity to residences.43 Risk re- duction activities followed, including applying PM control technologies, rerouting truck traffic away from residential areas, implementing diesel idling re- strictions, and planting vegeta- tion in dusty areas. Recon nimclatim S: Regional air pollutim control agencies across the United States should restrict pernlitthrg nen, somres of conrbustior-related air pollutants iii close prorinrity to residential meas acid other sensitive receptors. Siting high -pollution sources near neighborhoods often affects communities with the fewest resources that are already heavily burdened, particularly commu- nities of color. This long - documented practice gave rise to the call for environmental justice. 44 Land use and siting guidelines would be one approach states could implement to avoid poor land use choices. The California ,C4i11i l _-iii Air Resources Board's land use guidelines recommend against locating new residences, schools, day care centers, and playgrounds near sources of combustion - related air pollutants, such as freeways, busy roads, facilities with heavy truck traffic, or downwind of large ports or rail yards.45 The adoption of such guidelines in all states would re- duce exposures of pregnant women and children to combustion -related pollutants. Expand Research to Inform Policies Reconuuerrdatiorr 6: Eapaud air monitoring near locations ii liere children spend time. Near -source monitoring of combustion - related pollutants is important to accurately characterize commu- nity exposure and identify highly affected communities. Federal funds, such as EPA's Community Air Toxics Monitoring grants, are needed to support such efforts at the state and local level. Model community-based approaches exist or are under development. Examples include UFP moni- toring efforts at Seattle -Tacoma International Airport to address community concerns and pro- vide much-needed local data on UFP concentrations." New California legislation (AB617) mandates community -level monitoring of toxic pollutants in disadvantaged communities throughout the state. More information on expo- sures and sources will lead to better and more cost-efficient air pollution reduction strategies. Recoaurreudation 7: Expand research on effectiveness of strategies to Ilntigate exposures neat" large sources of comhnstion-related air pollution that could gide irnple- ruentatim in neighborhoods close to such sources. Highways, neigh- borhoods, and schools are in close Published online ahead of print February 21, 2019 AJPH Payne -Sturges eta(. Peer Reviewed Commentary e3 16-63 proximity to one another in our nation's cities, resulting in ex- posures of pregnant women and children to combustion -related air pollutants. Mitigation mea- sures that can reduce such ex- posures are needed. This is particularly important for low- income families and underserved racial/ethnic groups that dispro- portionately reside near major roadways and other sources of air pollution. 47 Various promising measures include indoor air filtration, placement of build- ing air intake away from sources of air pollution, and vegetative or physical barriers between roadways and residences or schools. Some evidence indicates that these measures are effective, 48,49 but more research into optimiz- ing such measures is needed. Furthermore, policies that im- plement effective measures and reduce community exposures to combustion -related air pollutants must be developed. Recoinruettdation S: Increase research on the human health effects of ultrafim particles. Evidence in animals indicates that the ultra - fine fraction of airborne PM is associated with serious adverse health effects, including neuro- logical effects. Human studies to date also have found associa- tions, 50,5 1 but the lack of a monitoring network for UFP in the United States is hindering health effects research that could inform policy decisions. Efforts are needed at the fed- eral level to develop a UFP monitoring network. This would facilitate studies of the neuro- developmental health effects of UFP exposures during pregnancy and childhood. Furthermore, funding is needed to support prospective epidemiological studies in birth or pregnancy cohorts to elucidate further the effects of UFP (and other combustion -related air pollu- tion) on neurodevelopment. CONCLUSIONS Public health policies that reduce combustion -related air pollution will improve not only cardiovascular and respiratory function but also neuro- development. This can lead to fewer children with neuro- developmental disorders, less special education spending re- quired, and more people par- ticipating fully in society across their life spans. Reduction of exposure to combustion -related air pollution will provide the cognitive resilience to mitigate neurodegenerative disorders during aging, including Alz- heimer's disease. 52,53 Finally, policies that reduce fossil fuel - based energy generation and transportation will reduce greenhouse gas emissions and mitigate the health effects of climate change. AJPH CONTRIBUTORS D. C. Payne -Sturges conceptualized and supervised the analysis and led the writing of the article. M.A. Marty contributed to the analysis and assisted with the writing of the article. F. Perera identified literature and assisted with the writing of the article. M.D. Miller, K. Ellickson, and J. Baines provided guidance on policy recom- mendations and edits. D. A. Cory-Slechta, B. Ritz, L. Anderko, E. O. Talbott, and R. Gould contributed to the literature sum- mary. M. Swanson and I. Hertz-Picciotto, as co -conveners of Project TENDR (Targeting Environmental Neuro- developmental Risks), provided overall guidance on policy recommendations. ACKNOWLEDGMENTS This work was supported by Project TENDR (Targeting Environmental Neurodevelopmental Risks), which has received grants from John Merck Fund, Ceres Trust Fund, Passport Foundation, Pediatric Epilepsy Research Foundation, and the National Institute of Environ- mental Health Sciences (R13ES026504). D. C. P. -S. is supported by the National Institute of Environmental Health Sci- ences (award KOIES028266). Note. The content of this article is solely the responsibility of the authors and does not necessarily represent the official views of the funding agencies. CONFLICTS OF INTEREST The authors have no conflicts ofinterest to disclose. REFERENCES 1. Evans GW, English K. The environ- ment of poverty: multiple stressor expo- sure, psychophysiological stress, and socioemotional adjustment. 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Peer Reviewed Commentary e5 16-65 Research I Children's llea[ih .r Childhood Incident Asthma and Traffic -Related Air Pollution at Home and School Rob McConnell,' Talat Islam,' Ketan Shankardass,2 Michael Jerrett,3 Fred Lurmann,4 Frank Gilliland,' Jim Gauderman,I Ed Avol, I Nino Kunz1i,5 Ling Yao,6 John Peters,I and Kiros Berhane1 'University of Southern California, Los Angeles, California, USA; 2St. Michael's Hospital, Toronto, Ontario, Canada; 3University of California, Berkeley, California, USA; 4Sonoma Technology, Inc, Petaluma, California, USA; 5Swiss Tropical and Public Health Institute, Basel and University of Basel, Switzerland; 6United Health Group, City of Hope Hospital Medical Center, Los Angeles, California, USA BACKGROUND: Traffic -related air pollution has been associated with adverse cardiorespiratory effects, including increased asthma prevalence. However, there has been little study of effects of traf- fic exposure at school on new-onset asthma. OBJECTIVES: We evaluated the relationship of new-onset asthma with traffic -related pollution near homes and schools. METHODS: Parent -reported physician diagnosis of new-onset asthma (n = 120) was identified during 3 years of follow-up of a cohort of 2,497 kindergarten and first -grade children who were asthma- and wheezing -free at study entry into the Southern California Children's Health Study. We assessed traffic -related pollution exposure based on a line source dispersion model of traffic volume, distance from home and school, and local meteorology. Regional ambient ozone, nitrogen dioxide (NO2), and particulate matter were measured continuously at one central site monitor in each of 13 study communities. Hazard ratios (HRs) for new-onset asthma were scaled to the range of ambient central site pollutants and to the residential interquartile range for each traffic exposure metric. RESULTS: Asthma risk increased with modeled traffic -related pollution exposure from roadways near homes [HR 1.51; 95% confidence interval (CI), 1.25-1.821 and near schools (HR 1.45; 95% CI, 1.06-1.98). Ambient NO2 measured at a central site in each community was also associated with increased risk (HR 2.18; 95% CI, 1.18-4.01). In models with both NO2 and modeled traffic expo- sures, there were independent associations of asthma with traffic -related pollution at school and home, whereas the estimate for NO2 was attenuated (HR 1.37; 95% Cl, 0.69-2.71). CONCLUSIONS: Traffic -related pollution exposure at school and homes may both contribute to the development of asthma. KEY WORDS: air pollution, asthma, child, epidemiology, vehicular traffic. Environ Health Perspect 118:1021-1026 (2010). doi:10.1289/ehp.0901232 (Online 6 April 2010] The role of air pollution in the development of new-onset asthma remains controversial, and the contribution of this environmental risk fac- tor to the pandemic remains unclear (Eder et al. 2006; Sarnat and Holguin 2007). Although increasing evidence indicates that living near heavy traffic is associated with increased rates of asthma, some well-designed studies have found only weak or no associations (Heinrich and Wichmann 2004; Oftedal et al. 2009). These inconsistencies may reflect incom- plete assessment of exposures to traffic in the microenvironments in which children spend most of their time. Exposure at locations other than home, especially at school where children spend a large proportion of waking hours and may engage in physicall activity that would increase the ventilation rate and dose of inhaled pollutants, may have strong influences on occurrence of asthma. However, few stud- ies have examined the effect of traffic -related pollution at schools on asthma rates among children. Two cross-sectional Dutch studies that examined this question reported higher rates of respiratory symptoms among children in schools near roadways with heavy traffic, especially truck traffic Qanssen et al. 2003; van Vliet et al. 1997). A northern California study found that schools downwind from busy freeways had higher concentrations of oxides of nitrogen (NQ,) and higher asthma prevalence rates (Kim et al. 2004). However, in a subse- quent analysis of these same data, the effect of school exposure was attenuated and no longer significant after adjusting for modeled residen- tial traffic -related exposure (Kim et al. 2008). Nitrogen dioxide (NO2) is routinely measured at regulatory monitoring stations. However, these measurements reflect both background regional concentrations and local sources near the stations. Some studies have assessed local exposure to traffic -related pollu- tion using measured NO2 (or NOx) as surro- gate for the complex mixture of traffic -related pollutants that occurs in close proximity to roadways (Brauer et al. 2007; Gauderman et al. 2005; Jerrett et al. 2008; Kim et al. 20041- Kramer 004;Kramer et al. 2000; Nordling et al. 2008). NO2 can feasibly be measured at a large num- ber of locations, and it has been widely used as a proxy for the mixture of traffic -related pol- lutants that vary markedly depending on dis- tance from roadways, season, wind speed, and wind direction. However, the mixture of pol- lutants in close proximity to roadways includes transition metals and organic aerosols, which are more plausible causes of asthma than NO2 (Li et al. 2003). Environmental Health Perspectives • VOLUME 118 I NUMBER 7 I July 2010 The Southern California Children's Health Study (CHS) was designed to investigate the chronic effects of air pollution on respiratory health. Previous analyses have found associa- tions of asthma with residential distance to major roads and modeled and measured pol- lutant markers for intracommunity variation in exposure to traffic (Gauderman et al. 2005; Jerrett et al. 2008; McConnell et al. 2006; Salam et al. 2007b) and with regional pollut- ants in susceptible children (Islam et al. 2008; McConnell et al. 2002). In the current analy- sis, a prospective, longitudinal evaluation of new cases of asthma has allowed assessment of exposure before the development of asthma in an ongoing cohort of school children recruited in kindergarten and first grade, an age at which physician -diagnosed asthma becomes reliable and valid (Martinez et al. 1995). Exposure to traffic -related pollutants has been estimated at participating schools and at residences. In addition, NO2, ozone (03), and particulate matter < 10 pm (PMIO) and < 2.5 µm in aero- dynamic diameter (PM2.5) have been measured continuously during the lifetime of most study participants at a location in each community representative of exposure in the neighbor- hoods where children live (Kunzli et al. 2003; McConnell et al. 2006). This design allowed examination of the joint effects of traffic -related pollution exposure at school and home and of regional measured pollution at community Address correspondence to R McConnell, Department of Preventive Medicine, USC Keck School of Medicine, 1540 Alcazar St., CHP 236, Los Angeles, CA 90033 USA. Telephone: (323) 442-1096. Fax: (323) 442-3272. E-mail: rmcconne@usc.edu Supplemental Material is available online (doi: 10. 1289/ehp.0901232 via http://dx.doi.orgl). E. Rappaport and J. Manila managed data, and B. Penfold assigned exposures estimated from resi- dential traffic. R. Ma, R.T. Burnett, and E. Hughes assisted with the development and implementation of the random effects program. This study was supported by National Institutes of Health grants 5P30ES007048, 5POIES009581, 5 POIFS011627, 1ROIES016535, 5ROIES014447, 5RO3ES014046, and 5RO1HL61768; U.S. Environmental Protection Agency grants R826708, RD831861, R831845, and R82735201; the South Coast Air Quality Management District, and the Hastings Foundation. F.L. is employed by Sonoma Technology, Inc, (Petaluma, CA). The other authors declare they have no actual or potential competing interests. Received 22 July 2009; accepted 22 March 2010. 1021 16-66 7 .✓ 7 McConnell et al. monitors. We hypothesized that exposure at school and home both contribute to the risk of new-onset asthma. Methods Study population. Characteristics of this cohort have been described previously (McConnell et al. 2006), Briefly, 5,349 children attend- ing kindergarten and first grade were enrolled into a new CHS cohort during the 2002-2003 school year from 45 schools in 13 communities. Communities were selected to represent the range and mixture of regional particulate pol- lutants, NO2, and 03 in southern California. Table 1. Characteristics of participants at study entry and incidence of asthma on follow-up. Characteristic 171M Cases IRb(95%CI) Age at entry (years) <6 496 (20) 22 17.0 (11.2-25.9) 6 1,178 (47) 58 19.0 (14.7-24.6) > 6 823 (33) 40 18.9 (13.9-25.8) Race/ethnicity Hispanic white 1,380 (55) 59 16.8 (13.0-21.7) Non -Hispanic white 905 (36) 45 18.9 (14.0-25.2) African American 77(3.1) 6 33.9 (15.2-75.4) Asian 97(3.9) 8 30.8 (15.4-61.5) Other/unknown 38(l.5) 2 22.7 (5.7-90.8) Sex Female 1,307 (52) 62 18.2 (14.2-23.3) Male 1,190 (48) 58 19.2 (14.8-24.8) History of allergy Yes 764 (34) 56 28.7 (22.1-37.4) No 1,508 (66) 50 12.8 (6.7-24.4) Play team sport Yes 918 (39) 47 19.7 (14.8-26.2) No 1,463 (61) 67 17.9 (9.2-34.5) Parental history of asthma Yes 389 (17) 31 31.3 (22.0-44.6) No 1,899 (83) 76 15.4 (7.2-33.3) Maternal smoking during pregnancy Yes 156 (6.3) 11 27.9 (15.55-50.5) No 2,308 (93.7) 107 18.0 (5.4-60.3) Secondhand smoke Yes 164 (6.7) 7 17.0 (8.1-35.6) No 2,281 (93.3) 110 18.7 (4.1-84.0) Mildew Yes 532 (22) 29 21.1 (14.7-30.4) No 1,911 (78) 85 17.3 (7.9-37.9) Pests in home Yes 1,603 (67) 75 18.1 (14.4-22.7) No 777 (33) 36 18.2 (9.7-33.9) Dogs in home Yes 730 (30) 30 15.7 (11.0-22.4) No 1,706 (70) 86 19.7 (9.1-42.8) Cats in home Yes 462 (19) 17 14.0 (8.7-22.5) No 1,972 (81) 98 19.4 (7.2-52.2) Indoor NO2 source Yes 1,799 (73) 88 18.8 (15.3-23.2) No 675 (27) 31 18.3 (9.9-33.9) Wildfire exposure° Yes 251 (12) 16 24.6(15.1-40.1) No 1,764 (88) 79 17.3 (6.2-48.2) Health insurance Yes 2,135 (88) 106 19.2 (15.9-23.3) No 300 (12) 10 13.1 (5.7-30.3) Household income (US$) s 14,999 329 (14) 16 19.5 (11.9-31.8) 15,000-49,999 714 (31) 38 21.1 (15.4-29.0) > 50,000 1,292 (55) 57 16.6 (12.8-21.6) Parental education Less than high school 508 (21) 23 17.9 (11.9-26.9) At least high school 452 (19) 20 17.5 (11.3-27.1) Some college 850 (36) 47 20.0 (14.9-26.9) College and above 560 (24) 24 13.9 (9.1-21.3) Total 2,497 120 18.7 (15.6-22.3) 'Numbers may not add up to 2,497 in some subgroups because of missing data. bCrude incidence (IR) rate per 1,000 person-years. 'Occurred in 2003 during first year of follow-up Parents provided informed consent and com- pleted a baseline and yearly questionnaire with information about demographic character- istics, respiratory illness, and risk factors for asthma at study entry. Children with a history of physician -diagnosed asthma at study entry (n = 715, 13.4%) were excluded from this follow-up, because the focus was on risks for incident asthma. To ensure that the study pop- ulation was free of any previously undiagnosed asthma, we then also excluded children with a history of wheeze (n = 868, 16.2%) and addi- tional children with missing information about wheeze, or missing or a "don't know" answer about asthma (n = 394, 7.4%). These exclu- sions resulted in a total of 3,372 children clas- sified as disease free at baseline. We excluded another 340 children with no residential traffic information because home address could not be geocoded [disproportionately from a single community, as described in the Supplemental Material (doi:10.1289/ehp.0901232)] and another 535 children who did not participate in any of the annual follow-up questionnaires. The final sample included 2,497 children. New-onset asthma and covanlates. Children with physician -diagnosed asthma reported on a yearly questionnaire during 3 years of follow-up were defined to have new-onset asthma. Children missing questionnaires in any year continued to contribute person -time to the models until they answered yes (at which time they were censored) or were lost to fol- low-up. The date of new onset of asthma could not be precisely defined. Therefore, the date of onset was assigned to the midpoint of the interval between the date of the questionnaire when asthma diagnosis was first reported and the date of the previous questionnaire reporting asthma status, and this date was used for esti- mating follow-up time in all statistical analyses. Sociodemographic characteristics, exposure to cigarette and wildfire smoke, health insurance, housing characteristics, history of allergy, and parental asthma were assessed by questionnaire [see Supplemental Material (doi:10.1289/ ehp.0901232) for details]. Community ambient air pollution inea- surements. Ambient levels of 03, NO2, PMto, and PM2.5 were measured continuously dur- ing follow-up at a central site monitor in each community, as described in the Supplemental Material (doi:10.1289/ehp.0901232) and in previous reports (Peters et al. 1999). Because there is marked diurnal variation in 03 and exposure occurs largely between 1000 and 1800 hours, this average was used in all analy- ses. Average temperature and relative humid- ity were also obtained during follow-up from measurements at the monitoring stations. Local traf c -related pollutant exposure. Exposure to traffic -related pollution was esti- mated using methods described previously (McConnell et al, 2006), and several metrics 1022 VOLUME 118 I NUMBER 7 I July 2O1 O • Environmental Health Perspectives 16-67 of local traffic related exposure were compiled. Participant residence and school addresses were geocoded, and we estimated distances to the nearest freeway or other highways or arterial roads and traffic density within 150 in of each child's residence and school. Concentrations of pollutants from local vehicle emissions at homes and schools were estimated separately from freeway and nonfreeway sources, using a line source dispersion model of the incremental contribution by these nearby sources to oxides of nitrogen above the regional background levels (Benson 1989). The modeled annual concentration estimates (parts per billion) were based on distance to roadways, vehicle counts, vehicle NO. emission rates, wind speed and direction, and height of the mixing layer in each community. However, these modeled expo- sures reflect the mixture of multiple pollutants from nearby traffic, and the high correlation of pollutants in the mixture precludes identifying the effect of any specific pollutant in the mix- ture, as described in the Supplemental Material (doi:10.1289/ehp.0901232). For brevity, these modeled exposures will be referred to as traffic - related pollutants (TRP). An estimate of com- bined school and home exposure to traffic was made by weighting the estimates by approxi- mate time at school (35 hr weekly, or 21%) and assigning the remaining 79% of time to the home. Health effect estimates based on models in which the contribution of school to the com- bined exposure was reduced to 16% to account for a lack of school exposure during summer recess were very similar (data not shown). Statistical methods. We fitted a multilevel Cox proportional hazards model that allows for assessment of residual variation in time to asthma onset and also for clustering of chil- dren around schools and communities (Ma et al. 2003). Letting ui and u j denote com- munity- and school (within community) -level random effects, with u.. assumed to be positive and independent conditional on ui, we fit the following model: h#1 (t) = ho,(t) zuj exp(RX,yl + STZ;jr), [11 where, for the lth subject in the ith com- munity, and jth school, h..Xt) is the hazard function at age t, ho(t) is tKe baseline hazard function in stratum s (defined by age at study entry and sex), Xyl is a traffic pollution expo- sure metric, and Zyl are other individual cova- riates, such as secondhand smoke exposure, pets in the home, and other possible con- founders. All models included race/ethnicity. The model allowed for joint evaluation of the effects of exposure to traffic -related pollutants at homes and at schools and to ambient pollutants measured at commu- nity central sites, with effects scaled to the interquartile range (IQR) for each metric of residential exposure (e.g., for TRP from the Childhood incident asthma and traffic -related air pollution line source dispersion model) and to the total range across the 13 communities, respectively. Traffic exposure at homes and school were correlated. Therefore, in models including both exposures, home traffic estimates were deviated from the corresponding school met- ric to minimize the chance of collinearity and allow for valid independent effect estimates (for example, r -square for school with deviated home TRP were < 0.38 for freeway, nonfree- way, and total TRP). Although the school - specific estimates of exposure were of primary interest, models including the average resi- dential exposure corresponding to each school (and residential exposures deviated from this average) were also fitted [see Supplemental Material (doi:10.1289/ehp.0901232) for details]. Potential confounders were evalu- ated one at a time, based on whether the esti- mates for the pollutant associations changed by > 10%. We assessed heterogeneity of traf- fic pollution effects by level of community central site regional pollutant measurements by comparing nested models using a partial likelihood ratio test with and without inter- action terms. We examined any potential nonlinearity in the exposure -response rela- tionship using cubic spline terms, piecewise polynomials joined smoothly at a number of break points (Hastie and Tibshirani 1990), for the exposure terms and comparing the nested models using a partial likelihood ratio test. All analyses were conducted using soft- ware designed to run within R software (R Development Core Team, Vienna, Austria) for implementing random effects Cox propor- tional hazards models (Krewski et al. 2009; Ma et al. 2003). All hypotheses were tested assuming a 0.05 significance level and a two- sided alternative hypothesis. Results Most of the 2,497 disease-free children included in this analysis were < 6 years of age (range, 4.8-9.0 years) at study entry (Table 1). There were 120 new cases of asthma, resulting in an incidence rate of approximately 18.7 cases per 1,000 person-years (based on 6,434 person- years of follow-up). Rates did not differ by age at study entry or sex. About half the children were Hispanic whites, and they had the low- est rates of asthma (16.8/1,000 person years), whereas African Americans had the highest rate (33.9/1,000 person-years), but this was based on only six cases. Substantially higher rates were also observed for children with history of allergy, parental history of asthma, and mater- nal smoking during pregnancy. Both residential and school TRP met- rics had a wide range with skewed distribu- tions (Table 2). For example, the mean and median for nonfreeway residential TRP were 7.3 and 6.1 ppb, respectively, and the IQR was 8.0 ppb, with a total range from 0.08 to a maximum of 55.1 ppb. A few homes and schools had very low freeway TRP (largely in a single community that has no freeways). There was ?_ 3 -fold variation in the multiyear average NO2, PM10, and PM2,5 from the lowest to highest pollution community for measure- ments at the central site monitors. 03 levels varied by 2 -fold. The associations of new-onset asthma were strongest with nonfreeway TRP. The haz- ard ratio (HR) at homes was 1.51; 95% con- fidence interval (CI), 1.25-1.81; p < 0.001 Table 2. Distribution of annual average residential traffic -modeled pollution and of community central site measurements, Table 3. Association between new-onset asthma and modeled exposure at home and school. Traffic -related exposures Mean Median IOR Minimum Maximum Range Residential traffic (ppb) NonfreewayTRP 7.3 6.1 8 0.08 55.1 55 Freeway TRP 11.1 7.3 13 < 0.0001 134.5 134.5 Total TRP 18.4 14.6 20.9 0.23 144.1 143.9 School traffic (ppb) NonfreewayTRP 6.1 5.9 5.9 0.3 19.7 19.4 Freeway TRP 10.9 8.2 15.2 < 0.0001 39.9 39.9 Total TRP 17 11.9 18.5 0.7 51.4 50.7 Central -site measurements NO2 (ppb) 20.4 21.8 12.8 8.7 32.3 23.6 PM10 (pg/m31 35.5 34 11.7 17.6 61.5 43.9 PM2.5 (pg/m3) 13.9 15.1 9.7 6.3 23.7 17.4 1000-1800 hours 03 (ppb) 44.6 43.6 11.1 29.5 59.8 30.3 Table 3. Association between new-onset asthma and modeled exposure at home and school. Traffic -related exposures Home HR° (95% Cl) Nonfreeway TRP 1.51 (1.25 -1.8l) - Freeway TRP 1.12 (0.95-1.31) Total TRP 1.32 (1.08-1.61)** School HRb(95%a Cl) Combined' HR°(95%o Q 1.45 (1.06-1.98) 1.61 (1.29-2.00)* 1.08 (0.86-1.34) 1.12 (0.94-1.35) 1.20 (0.91-1.58) 1.34 (1.07-1.68) 'Scaled to the IQR at homes for each metric (from Table 2). 6HR (95% Cl, adjusted for race/ethnicity and for baseline hazards strata of age at study entry and sex) with random effects for community and school.'Combined weighted for time at home and school. *p <0.001. **p <0.01. Environmental Health Perspectives . VOLUME 118 I NUMBER 7 July 2010 1023 16-68 N McConnell et al. (Table 3). The HR for exposure at schools was almost as large as for residential exposure (HR = 1.45; 95% CI, 1.06-1.98), and the combined average exposure weighted for time at school and home had a slightly stronger association (HR = 1.61; 95% Cl, 1.29-2.00). These associations were not confounded by any of the covariates in Table 1 or by com- munity relative humidity, which we have previously found to confound TRP exposure (Jerrett et al. 2008). There also were no sig- nificant interactions of either residential or school nonfreeway TRP with sex, allergy, or parental history of asthma, which we have previously shown modified effects of traffic exposure (McConnell et al. 2006). Similar effect sizes were observed in sensitivity analy- ses restricted to lifetime residents at the same address, analyses excluding children diagnosed in the first year of follow-up and excluding children who changed schools during the follow-up period. There was little evidence of nonlinearity in the exposure -response rela- tionship based on sensitivity analyses compar- ing the fit of a smoothed cubic spline model of asthma with a linear model (p -value > 0.80) for the partial likelihood ratio test for models with 3 and 5 knots compared with the linear model. Weaker associations were observed with total TRP at homes (HR = 1.32; 95% CI, 1.08-1.61) and school (HR = 1.20; 95% Cl, 0.91-1.58). There were weaker and non- significant associations with TRP modeled from freeways. Nonfreeway TRP was mod- erately to strongly correlated with freeway TRP at homes (R = 0.64) and at schools [R = 0.70; Supplemental Material, Table E-1, (doi:10.1289/ehp.0901232)]. However, in models co -adjusted for freeway and nonfree- way TRP, the nonfreeway effect estimates for school and home were similar to the unadjusted estimates. Of the regional community central -site pollutants, NO2 was associated with more than double the risk of new-onset asthma (HR = 2.17; 95% CI, 1.18-4.00;,p = 0.01) over the range of exposure (23.6 ppb) across the 13 study communities (Table 4). In a model with NO2, school and residential nonfreeway TRP exposure, the estimate for NO2 was attenuated (HR = 1.37; 95% CI, 0.69-2.71; Table 5). Table 4. Association of new-onset asthma with community central site pollutant measurements. Pollutant HR' (95% Cl) NO2 2.17 (1.18-4.00) PM10 1.35 (0.64-2.85) PM2.5 1.66 (0.91-3.05) 03 0.76 (0.38-1.54) IN (95% Cl) across the range of exposure in the13 com- munities (23.6 ppb for NO2, 43.9 pg/m3 PM10, 17.4 pg/m3 PM2,5, and 30.3 ppb for 1000-1800 hours 03), adjusted for race/ethnicity and for baseline hazards strata of age at study entry and sex with random effects for community and school. 1024 However, the adjusted associations of asthma with nonfreeway TRP at homes (HR = 1.46) and schools (HR = 1.45) in Table 5 were very similar to the unadjusted effect estimates (HR = 1.51 and 1.45, respectively, shown in Table 3). In sensitivity analyses, a similar pat- tern of attenuation of regional NO2 effect esti- mates was observed in models weighted for time at school and home (results not shown), and in models adjusted for total (freeway plus nonfreeway) TRP exposure at school and home [Supplemental Material, Table E-2 (doi:10.1289/ehp.0901232)]. There were nei- ther statistically significant interactions of cen- tral site pollutants with residential TRP nor any consistent patterns suggestive of different effects in high and low regional pollutant com- munities (results not shown), We have previ- ously shown that 03 modified the association of team sports participation with new-onset asthma in an older cohort (McConnell et al. 2002), but there was neither a main effect of sports nor confounding or effect modification of effects of residential TRP or ambient central monitor pollutant exposure. Distance to freeways and other major roads and traffic volume on those roads have been used in other studies as independent predictors of traffic exposure, so we examined the dis- tribution [Supplemental Material, Table E-3 (doi:10.1289/ehp.0901232)] and correla- tions of these metrics (Supplemental Material, Table E-1) and the association at school and home with asthma (Supplemental Material, Tables E-4 and E-5). In general, these exposure metrics were weakly to moderately correlated with the TRP metrics but were not consistently associated with asthma in our data set. Discussion The study is unique in its prospective assess- ment of the relationship of new-onset child- hood asthma to community regional air pollution and near -source traffic -related exposure at home and in a large number of schools. The results indicate that associations of asthma with traffic -related pollution from nearby sources at schools were independent of estimated effects of exposures at homes, and these effects were of similar size over a range of exposure common in Southern California. Evidence of a school effect comparable with that associated with the much larger amount of time spent at home could potentially be explained by physical education and other exercise at school that may increase ventila- tion rate and dose of pollutants to the lungs and thereby increase the risk associated with exposure. Traffic -related pollutant levels may also be considerably higher during the morn- ing hours, when children are arriving at school, especially during temperature inversions that occur largely in the winter months when chil- dren are attending school (Kim et al. 2002; Ning et al. 2007). It is possible that school exposure may have reflected time spent in other locations in the child's neighborhood rather than school -specific exposure, and this possibil- ity merits further investigation. However, time at school during the school year accounts for more than one-third of all waking hours, and in this age group it is likely that most of the child's remaining nonschool time was spent at home (Xue et al. 2004). The increased risk associated with TRP could not be explained by confounders commonly associated with asthma or by ambient NO2 or other currently regulated regional pollutants measured at the central -site monitoring stations. These results strengthen an emerging body of evidence from both toxicologic and epidemiologic studies that air pollutants from nearby traffic contribute to the development of asthma (Salam et al. 2008). NO2 measured at community monitor- ing stations has been associated with wheeze prevalence in an older CHS cohort (Peters et al. 1999) and with increased risk of asthma incidence in a Japanese cohort (Shima et al. 2002). We have recently reported associations of both incident and prevalent asthma with ambient residential NO2 measured outside homes of a relatively small sample of children from another CHS cohort in many of the same communities, but NO2 in that study was a marker for intracommunity variation in the mixture of TRPS (Gauderman et al. 2005; Jerrett et al. 2008). Other studies also indicate that associations of respiratory dis- ease with intracommunity variation in NO2 reflect the effects of other TRP rather than NO2 (Kramer et al. 2000). A study that meas- ured NO2 and NO, in central neighborhood Table 5. Mutually adjusted associations of new-onset asthma with community central site pollutant measurements and nonfreeway TRP at home and school.' 'Mutually adjusted across each row (i.e., effect of each community pollutant was examined separately in a model including both home and school TRP). "HR (95% Cl) for central -site pollutants scaled across the range of exposure in the 13 communities (23.6 ppb for NO2, 43.9 pg/m3 PM10, 17.4 pg/m3 PM25, and 30.3 ppb for 1000-1800 hours 03); household nonfreeway TRP was deviated from school, scaled to the IQR for home exposure (8 ppb from Table 2). *p < 0.01. VOLUME 1181 NUMBER 7 I July 2010 • Environmental Health Perspectives 16-69 HRb (95% Cl) for ambient HRb (95% Cl) for home TRP, HRb (95% Cl) for school Central site pollutant, adjusted for adjusted for school TRP TRP, adjusted for home TRP pollutant TRP at home and school and ambient pollutant and ambient pollutant NO2 1.37 (0.69-2.71) 1.46 (1.16-1.84)* 1.45 (1.03-2.06) PM10 1.40 (0.62-3.17) 1.46 (1.16-1.85)* 1.53 (1.10-2.12)* PM2.5 1.30 (0.66-2.56) 1.48 (1.19-1.85)* 1.49 (1.07-2.08) 03 1.01 (0.49-2.11) 1.50 (1.20-1.86)* 1.54 (1.10-2.14)* 'Mutually adjusted across each row (i.e., effect of each community pollutant was examined separately in a model including both home and school TRP). "HR (95% Cl) for central -site pollutants scaled across the range of exposure in the 13 communities (23.6 ppb for NO2, 43.9 pg/m3 PM10, 17.4 pg/m3 PM25, and 30.3 ppb for 1000-1800 hours 03); household nonfreeway TRP was deviated from school, scaled to the IQR for home exposure (8 ppb from Table 2). *p < 0.01. VOLUME 1181 NUMBER 7 I July 2010 • Environmental Health Perspectives 16-69 locations found that associations with asthma were attenuated by adjustment for modeled residential traffic exposure (Kim et al. 2004, 2008). In the current study, the attenuated association between asthma and NO2 con- tinuously measured at the community moni- tor in models with adjustment for TRP also suggests that NO2 was not causally related to asthma. However, interpretation of this result is not clear because exposure measured at the community monitor may have misclassified exposures of children in parts of the com- munity with significant local sources of NO2. We did not find evidence for main effects of regional 03 and PM with asthma, consistent with results from previous analyses in older CHS cohorts, although we have previously shown that 03 modified the effect of outdoor exercise in a genetically susceptible subgroup (Islam et al. 2009; McConnell et al. 2002). Associations with asthma were significant for TRP exposure estimates modeled from local nonfreeway roadway proximity, traffic volume, and meteorology. There was little evi- dence for an effect of major roadway proxim- ity alone, for traffic density, or for pollution from freeways. The absence of a freeway TRP effect suggests that causal pollutants may be highly reactive, resulting in steep spatial gradi- ents from freeway sources and little exposure at the longer distances of homes and schools to freeways compared with distance to other major roads [Supplemental Material, Table E-3 (doi:10.1289/ehp.0901232)]. Several previ- ous studies have found that the largest gradi- ents in traffic -related pollutants occur within 150 in from roadways (Gilbert et al. 2003, Zhu et al. 2002), and variability has often been best explained by traffic volume within 300 in (Briggs et al. 2000; Gilbert et al. 2003; Ross et al. 2006). High-volume traffic on secondary roads may also produce pollutants resulting from frequent stops and accelerations, which have been found to be associated with asthma symptoms (Ryan et al. 2005). However, in an older cohort from some of these same commu- nities, we observed associations of freeway -mod- eled exposures and residential freeway proximity with respiratory outcomes (Gauderman et al. 2005, 2007). Different traffic metric associa- tions with respiratory health may have been due to variation in the distribution of freeway and nonfreeway traffic around homes in the dif- ferent cohorts and the relatively small number of children living near freeways (< 7% within 150 in in the current cohort). It is also possible that the accuracy of exposure models for the freeway and nonfreeway sources varied in the two cohorts or that the greater mobility of older children resulted in health effects associated with spending time in areas such as parks in close proximity to freeways near homes. An important distinction between the TRP and simpler traffic metrics is the r Childhood incident asthma and traffic -related air pollution Elm inclusion of meteorology (average annual wind speed and direction and height of the mixing layer) in addition to proximity and volume. Traffic density alone [Supplemental Material, Table E-4 (doi:10.1289/ ehp.0901232)] and proximity to a major roadway (Supplemental Material, Tables E-4 and E-5) had weaker positive associations with incident asthma that were not statisti- cally significant. Therefore, inconsistent find- ings in some of the (largely cross-sectional) studies that have evaluated associations with asthma (Heinrich and Wichmann 2004) may reflect the failure to account for the impact of meteorology on exposure. We have recently measured NOX at > 900 locations in these communities. Approximately two thirds of the within -community variability in NO, was explained by TRP, a substantially higher amount of variation than was explained by any other traffic metric (unpublished data). We have also previously observed that both TRP and residential traffic proximity were associated with increased asthma prevalence in this cohort (McConnell et al. 2006). The prospective design is a strength of this study. In other prospective studies of birth cohorts in Sweden and the Netherlands, mod- eled traffic -related pollutants, including NO), and/or PM2.5, were associated with incidence of wheeze and atopy (Nordling et al. 2008) and doctor -diagnosed asthma (Brauer et al. 2007) in children < 5 years of age, when the diagnosis of asthma may be difficult to distin- guish from transient wheeze not predictive of asthma. As these cohorts mature, the relation- ship to asthma is likely to become more clear. For example, associations between PM2.5 light absorption, roadway proximity, and asthmatic bronchitis and atopy were found in a study of two German birth cohorts that followed some children to 6 years of age (Morgenstern et al. 2008). Associations with allergic symptoms in these cohorts were less robust at an earlier age (Gehring et al. 2002). Other recent results from prospective studies of birth cohorts (Gehring et al. 2009) and of children (Shima et al. 2002) followed to older ages have gener- ally shown positive associations between mark- ers of residential TRP and asthma, although a recent Norwegian study found no association with modeled exposure at the birth address of a large cohort of children (Oftedal et al. 2009). Genetic studies examining pathways likely to mediate effects of air pollution also strengthen the causal inference that traffic -related pollut- ants may cause asthma. We have shown else- where that the risk of asthma associated with traffic exposure and with traffic -related ambi- ent PM was modified in a predictable way by functional gene variants in pathways associ- ated with asthma, including inflammation and airway remodeling (Salam et al. 2007a) and oxidative stress (Islam et al. 2008; Salam et al. 2007b). In another analysis of the data from this cohort, we have shown that the estimated effect of TRP was modified by socioeconomic status and psychosocial stress (Shankardass et al. 2009). There are some limitations to these data. Our conservative estimates of TRP for the center of school buildings are likely to under- estimate the exposure of students in build- ings closer to the roadways, especially during dropoff and pickup of students at the begin- ning and end of the school day. The impact of this underestimate of exposure on the assess- ment of health effects is not clear, although in general it might be expected that this exposure misclassification would be nondifferential with respect to asthma and would result in underes- timation of the effect of traffic exposure. Other limitations include the relatively short (3 -year) period of follow-up and the retrospective ques- tionnaire assessment of early -life risk factors, as this was not a pregnancy cohort. Our cohort excluded children who left the community before school entry and who had asthma or wheeze at study entry. However, our cohort allowed us to examine risk factors in school children, an age during which there has been little study of new-onset asthma. Asthma is a clinical syndrome with no sensitive and specific diagnostic test avail- able to confirm clinical assessments. Because of the clinical nature of the assessment, the reported physician diagnosis of asthma we used has been recommended and widely used as a method to classify asthma status in epide- miologic studies, although this approach has limitations (Asher et al. 1995; Burr 1992). If misclassification of true asthma based on this approach were random with respect to exposure to air pollution, then the observed associations would be likely to have under- estimated the effect of exposure. Bias could explain our results if asthma misclassification were related also to exposure. This could occur if exposure were associated with access to care and differences in practice among physicians that have the potential to influence asthma diagnosis (Samet 1987). However, adjustment for factors that mediate access to care including family income, parental education, and having medical insurance did not alter our results, indicating that confounding due to differen- tial access to care was unlikely to explain these findings. The validity of questionnaire -reported physician diagnosis has also been established in a subset of CHS participants (Salam et al. 2007a). In addition, any child with a history of wheezing at study entry was excluded from the analysis, so it is unlikely that the exacerba- tion of undiagnosed prevalent asthma by traffic explained these associations. Loss to follow-up could also potentially result in bias because of selection. Sociodemographic characteristics varied between the analysis cohort and children Environmental Health Perspectives • VOLUME 118 I NUMBER 7 I July 2010 1025 16-70 f w w McConnell et al. not contributing to the analysis because of loss to follow-up or missing or poorly matched geocodes for addresses precluding estimation of residential exposure [Supplemental Material, Table E-6 (doi:10.1289/ehp.0901232)]. Hispanic children were less likely than non - Hispanic white children to be included in the follow-up analysis, as were children without insurance and with lower parental education and income. However, adjusting for these fac- tors had little impact on the pattern of observed effects. In addition, there was little difference between exposure to nonfreeway TRP in the study sample (7.3 ppb) and in the group not included because of loss to follow-up (7.6 ppb). Therefore, it is unlikely that selection bias due to loss to follow-up explained our results. Conclusions An estimated 6.2 million children have asthma in the United States, making it the most com- mon chronic disease in childhood (Moorman et al. 2007), and rates have increased mark- edly in developed countries over the past several decades (Braman 2006). Morbidity results in impaired quality of life for the affected child and other family members, in increased use of health services, and in school absences that have large social and economic costs (Wang et al. 2005). Our results indicate that children exposed to higher levels of traffic -related air pol- lution at school and home are at increased risk of developing asthma. Almost 10% of public schools in California are located within 150 m of roadways with > 25,000 vehicles daily (Green et al. 2004). Students in urban areas in eastern U.S. cities are even more likely than children in Los Angeles to attend schools near major high- ways (Appatova et al. 2008). 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J Air Waste Manag Assoc 52(9):1032-1042. 1026 VOLUME 1181 NUMBER 7 I July 2010 • Environmental Health Perspectives 16-71 Heather Hines From: Eric Roberts Sent: Wednesday, February 27, 2019 8:29 AM To: Heather Hines Cc: Evelyn Ellis Subject: Fw: Please Vote YES on the Safeway Gas Station Eric Roberts, Planning Technician M -Group Consulting Planning Technician Serving the City of Petaluma 11 English Street, Petaluma, CA 94952 Phone: (707) 778-4317 Hours: Monday -Thursday 8am-5pm, closed Fridays From: hsublow@gmail.com <hsublow@gmail.com> Sent: Tuesday, February 26, 2019 11:49 PM To: petalumaplanning@ci.petaluma.ca.us Subject: Please Vote YES on the Safeway Gas Station ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. -- Message: lets get this project off the ground and built already. It's about time. Name: Howard Sublow 16-72 Heather Hines From: Eric Roberts Sent: Wednesday, February 27, 2019 8:29 AM To: Heather Hines Cc: Evelyn Ellis Subject: Fw: Please Vote YES on the Safeway Gas Station FYI Eric Roberts, Planning Technician M -Group Consulting Planning Technician Serving the City of Petaluma 11 English Street, Petaluma, CA 94952 Phone: (707) 778-4317 Hours: Monday -Thursday 8am-5pm, closed Fridays F From: morlegdmet@aol.com <morlegdmet@aol.com> Sent: Tuesday, February 26, 2019 10:12 PM To: petalumaplanning@ci.petaluma.ca.us Subject: Please Vote YES on the Safeway Gas Station ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. -- Message: we need it! Name: annie hard 16-73 Heather Hines From: Eric Roberts Sent: Wednesday, February 27, 2019 4:56 PM To: Heather Hines Cc: Evelyn Ellis Subject: Fw: Please Vote YES on the Safeway Gas Station FYI Eric Roberts, Planning Technician M -Group Consulting Planning Technician Serving the City of Petaluma 11 English Street, Petaluma, CA 94952 Phone: (707) 778-4317 Hours: Monday -Thursday 8am-5pm, closed Fridays From: Conniecriderl0@gmail.com <Conniecriderl0@gmail.com> Sent: Wednesday, February 27, 2019 4:02 PM To: petalumaplanning@ci.petaluma.ca.us Subject: Please Vote YES on the Safeway Gas Station Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. -- Message: I am so tired of planning trips to COSTCO to avoid having to pay the higher gas prices of Petaluma. And incidental, I usually do all my weekly shoppin, while I am up there, just so i don't feel like I have wasted gas. That's dollars I would normally be spending in Petalma. Name: Connie Crider 16-74 Heather Hines From: Cooper, Claire <ccooper@ci.petaluma.ca.us> Sent: Thursday, February 28, 2019 8:04 AM To: Crump, Katie; Heather Hines Cc: -- City Clerk Subject: FW: Please Vote YES on the Safeway Gas Station Claire Cooper, CMC, City Clerk City of Petaluma, California 11 English Street I Petaluma, CA 94952 2:707.778.4360 1 FAX: 707.778.4554 Email: cityclerk@ci.petaluma.ca.us Web: cityofpetaluma.net City Business Hours: Monday — Thursday, 8:00 a.m. — 5:00 p.m. Closed Fridays Learn fr=om yesterday, live for today, Hope for tomorrow. The important thing is not to stop questioning. — Albert Einstein (Mardi 14, 18 79 —April 18, 1955) City of Petaluma records, including emails, are subject to the California Public Records Act. Unless exemptions apply, this email, any attachments and any replies are subject to disclosure on request, and neither the sender nor any recipients should have any expectation of privacy regarding the contents of such communications. From: segaultney@comcast.net <segaultney@comcast.net> Sent: Thursday, February 28, 2019 6:33 AM To: mcdonnell4council@gmail.com Cc: -- City Clerk <CityClerk@ci.petaluma.ca.us> Subject:.Please Vote YES on the Safeway Gas Station ---Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAIL SYSTEM. --- Message: I SUPPORT the construction of the Safeway Gas Station in Petaluma. I am tired of having to get gas in Rohnert Park or Santa Rosa. — Steve Gaultney Name: Steve Gaultney 16-75