Construction Industry Air Quality Coalition response to Union of Concerned Scientists’ Publication “Digging Up Trouble”
The Construction Industry Air Quality Coalition represents thousands of construction companies and hundreds of thousands of construction workers in the state of California.
We are surprised and disappointed at the report entitled “Digging Up Trouble” recently released by the Union of Concerned Scientists. The document was clearly designed solely to grab media headlines and it will not withstand the close scrutiny of any objective review.
This contrived report would lead the uninformed reader to believe that proximity to a construction site is dangerous to ones health and that is simply not the case. The document provided no new science and was not the result of any independent research by the authors. This report also contradicts the organization’s comments to ARB in August 2005 where they indicated that construction would achieve the California Air Resources Board’ goal of an 85% reduction in particulate matter (PM) emissions without further regulation.
The report attempts to link premature deaths in California with exposure to construction equipment emissions. Without any causal links, the authors assigned construction emissions to an arbitrary number of respiratory-related deaths in California, and extrapolated data from that unfounded connection. In fact, more people in Los Angeles die from gunshot wounds than exposure to emissions from construction equipment if we believe the report.
The Union of Concerned Scientists made several erroneous assumptions in compiling their report. They assumed:
- That all construction projects they reviewed involved the use of heavy-duty off-road construction equipment
- That construction emissions are a significant contributor to existing levels of NOx and PM
- That exposure to construction site emissions lasts a sufficient number of years to have a health impact
- That mere proximity to a construction site is sufficient exposure to cause a health risk
- That deaths from all respiratory illness in California can be assigned to a specific emissions source and activity.
None of those are true. There is no scientific basis for their conclusion.
The sources of information cited in the report are various staff reports and some research documents dating back five and ten years. None of these documents concluded, or support the conclusion, that proximity to a construction site is dangerous to ones health. In fact, the statewide inventory of NOx and PM emissions attributable to construction activities today is only about 10% and declining.
The report also fails to take into account the recent changes in diesel fuel formulation which has reduced PM emissions nor does it recognize the massive voluntary reductions of NOx and PM implemented by the construction industry with the Carl Moyer program. That program has reduced PM by 100 tons and NOx by over 3,000 tons annually. It is the largest voluntary reduction in emissions in California history.
It is unfortunate that the Union of Concerned Scientists would use their unbiased-sounding name to create public hysteria where no threat exists. The Construction Industry is committed to reducing emissions from construction equipment. We have worked closely with the California Air Resources Board, the South Coast Air Quality Management District and the California Legislature for the last 17 years to achieve that goal.
The report by the Union of Concerned Scientists report has contributed nothing positive to advance the goal of cleaning up our air.