Ashlee Wright

From:

Sent:
To:

Cc:
Subject:
Attachments:

Tricia Dally <

Tuesday, April OS, 2016 2:44 PM
jason@burnettforcarmel.com; Victoria Beach; dallasforcarmel@gmail.com;
ctheis@carmel.ca.us; Ken Talmage Council
Ashlee Wright; PD Weekly Crime report; Mary Duan; PD CarmeiPineCone;
Mkhaei.Watson@coastal.ca.gov
Letter regarding Beach Fires for City Council Meeting on April 5, 2016 with attachments
MBUAPCD Monitor Network Plan 2015001.pdf; July 4 ChartOOl.pdf; Dr Laurie Koteen Air
Quality Memorandum001.pdf; Richard Stedman Letter to CCCOOl.pdf

April 5, 2016
Dear Mayor Burnett and City Council members,
Unfortunately, I cannot attend this evening's City Council meeting , so I would like to submit this letter regarding Carmel
Beach fires for the record.

1would like to state that those of us who support wood beach fires have already expressed our strong desire to reach a
compromise with the City by limiting the number of wood fires on Carmel Beach . We have been repeatedly ignored
despite the fact that the Carmel Beach monitor data does not support a total ban on wood fires.
In fact, 100% of the Carmel Beach monitor data collected prior to the weekend and holiday ban met both the EPA
National Standards and the California State Air Quality Standards established to protect the public health and the
environment.
These standards are based on thousands of epidemiological studies and are updated approximately every 5 years by the
EPA, as new studies are added to the large pool of scientific evidence on health outcomes based on concentration levels
and time exposure to particle pollution.
The current standards were last reviewed and finalized by the EPA in 2012, during the Obama administration. These
standards represent the best science to date, and are far more relevant and specific than generalized studies regarding
harm from wood smoke that those in opposition to wood beach fires have been relying on.
In fact, the EPA and California State standards are also the standards that have been adopted by the Monterey Bay
Unified Air Pollution Control District, of which Richard Stedman is the Pollution Control Officer, and Councilman Talmadge
is a board member. The Monterey Air District's document, "2015 Annual Monitoring Network Plan," states on page 2:
"The ambient air quality standards are limits on air pollutant concentrations. They are set by the California Air Resources
Board (CARS) and the EPA, and they are designed to protect human health and the environment. Based on these
standards, the District monitors the air quality in the NCAAB (North Central Coast Air Basin California). If an area does
not meet the air quality standards. then regulations and control strategies are developed to reduce pollutants.!'
Since the data prior to the ban met both EPA and California Air Quality Standards to protect human health, it was
misleading for public officials to claim that the data showed a "public health crisis," and to make claims that the levels
measured on July 41h would have triggered an evacuation in a wildfire - both of these claims are false based on the data
and EPA documents (please see attached July 4 chart).
In order to find anything to support the City's position for the ban, officials had to look at the data on an hour by hour
basis , and found exactly 8 hours that exceeded the guidelines . However, the guidelines used are not "official" standards
used by the EPA to determine air quality safety, because there is no direct epidemiological evidence to support these
short-term exposures on public health. They are mathematically-derived guidelines designed to help public officials make
contin~ency plans to keep the public safe in an emergency event, such as a wildfire.
Addition ally, the EPA wildfire document used by local officials to substantiate the Carm el Beach fire ban states that even
in a wildfire, " ... the long-term risks from short-term exposures are quite low." Since only 8 hours were found to be of
1

concern prior to the ban, of which 4 hours occurred on July 4th, it is obvious that the risk to public health was quite low
even on this more rigorous examination .
In fact, Dr. Laurie Koteen, a research scientist and expert for the Coastal Commission who analyzed the Carmel Beach
monitor data, noted in her memorandum that 98% of the hourly data collected by the beach monitor measured in the
"Good" air quality category, according to EPA guidelines. The EPA states that "Good" air quality represents little to no
threat to anyone, even those in sensitive populations (including the elderly, children, and those with preexisting medical
conditions such as heart and lung disease).
Dr. Koteen noted on page 7 of her report, "In short, the data shows that air quality at the 13th Avenue monitoring station
was almost always in the "Good" air quality category. when the finer-grained hourly average air quality is considered, for
which the EPA does not recommend that any actions are necessary to abate air quality concerns."
While there are legitimate concerns about smoke as a nuisance to some of the residents near Carmel Beach , and
potentially a concern to the health of some sensitive individuals when bonfires are unregulated (such as the 135 fires on
the evening on July 41h), both Dr. Koteen and Mr. Stedman have stated that reducing the number of wood fires should
solve the problem .
In her final conclusion, Dr. Koteen stated on page 9 of her report "I conclude that lim iting the number of beach fires. and
better beach fire management within the allowed beach fire area at Carmel Beach would be a prudent and cautious
approach to help avoid exceeding 'Good' air quality guidelines inland of that area, but that a ban on all such fires is not
supported by the data."
In a letter to the California Coastal Commission on August 18, 2015, Richard Stedman also concluded on page 2 that
"Limiting the number of fires (sic) rings on the beach is a common sense approach that should be effective in addressing
this problem."
Dr. Koteen also confirmed on page 9 of her report that the only air quality exceedance of the National and State standards
was after the weekend and holiday ban was already in place- on the day of the Tassajara Wildfire in Carmel Valley- a
day when beach fires were banned.
It is important for the public to understand that while the Carmel Beach monitor was located very near to Carmel Beach,
the Tassajara wildfire was located over 20 miles away from the Carmel Beach monitor. Looking at the Tassajara wildfire
data as measured by the Carmel Beach monitor could mislead the public to underestimate the severity/danger of the the
Tassajara fire, especially to those in the Carmel Valley area who were evacuated. In fact, the measurements of the
Tassajara wildfire were much higher nearer the fire as measured by the Ford Road Carmel Valley air monitor, which was
still about 10 miles from the wildfire's location.
To date, almost 500 Carmel Beach stakeholders have signed the petition requesting a compromise from the City of
Carmel to include a limited number of wood beach fires in portable pits in their next proposal to the California Coastal
Commission. This is more than twice as many who signed the petition to oppose wood fires.
Reducing the number of wood fires on Carmel Beach to 26, for example, as was proposed in the trial previously approved
by the City in 2015, would have been an 80% reduction in the number of fires that occurred on the Ju ly 4 peak that
caused concern. If emissions from July 4 would have been reduced by 80% as well, air quality would have been in the
"Good" air quality category.
We respectfully ask again that you include a limited number of wood-burning fires, in portable or temporary pits, in your
next proposal to the California Coastal Commission.
Thank you for your time and consideration .
Sincerely,
Tricia Dally
Carmel Valley, CA 93924
Attachments to this email:

Monterey Bay Unified Air Pollution Control District "North Central Coast Air Basin California: 2015 Annual Monitoring
Network Plan," June 30, 2015 (Page 1 & 2 only; full document available online at: http:l/mbuapcd.org/wpcontenVuploads/2015/05/2015 Annual Network Plan. pdf)
Chart of July 4 Carmel Beach Monitor Data and levels that would trigger an evacuation according to the EPA
"Carmel Beach Air Quality Issues" Memorandum by Laurie Koteen, Ph.D., Ecologist, December 9, 2015
Letter from Richard Stedman to Mike Watson of the California Coastal Commission, August 18, 2015

Monterey Bay Unified Air Pollution Control District

North Central Coast Air Basin

California

2015
Annual Moni-toring Network Plan
June 30, 2015

Monterey Bay Unified Air Pollution Control District

24580 Silver Cloud Court
Monterey, California 93940
(831) 647-9411

The Pinnacles site is operated and maintained by the National Parks Service. The District also performs
short-term monitoring and special testing as needed. It also maintains a network consisting of both
mobile and stationary instruments, which include beta 11ttenuation monitors, BAM-1020s and E-BAMs
that are primarily intended for the detection ofPM2.5 from outdoor and residential burning, as well as
wildfrres.

NETWORK DESCRIPTION
Network Plan
The District adopts and submits an Annual Monitoring Network Plan to the EPA Regional Administrator.
This plan provides for the establishment, maintenance, and evolution of an air quality monitoring system.
The Code of Federal Regulations currently requires that this report be submitted to the U.S.
Environmental Protection Agency (U.S. EPA) by July 1 of each year. The geographical scope of this
report consists of Monterey, Santa Cruz, and San Benito counties, which make up the North Central Coast
Air Basin (NCCAB) in California.

General Information

~e am~ien~air g)l~Hty.a~dar:ds areJimi~ on a!!''POllutant c_o~c~ntrati_~ns. !ex e :s,rt.~r the California

Au Resour.ces Board (ARB) and the EPA, and iliey are designed topratect 'huinan1tea1tli ana the
.environment. Based on-tp~e 'S~dards, the Distriet monitors the'<ilrr qUality in the NGAI.m. Jf.an.ar.ea
does not me.et the air quality standards,J:h,~n regulatiop5,.aiid control strategies are .developed to r-educe
,p(.)Hutants. The District collects data on both pollutant and meteorological parameters. The primary
pollutants of concern, from a regulatory and public health perspective, are 03, PM2.5, and PMl 0. Most
sites monitor for multiple pollutants and some sites collect data for other pollutants, such as NO-N02N0x, and CO. Meteorological parameters are monitored at all sites and include atmospheric temperature
monitors (ATM), wind speed average (WSA), and wind direction average (WDA).

Data Use
The air monitoring data collected by the District is used in a number of ways. It is available to various
regulatory agencies, health and environmental researchers, and to the general public; including
environmental groups, businesses, and concerned citizens. This data is reviewed for compliance with the
ambient air quality standards, as well as associated public health and environmental effects and impacts.
The data is submitted to CARB and the EPA, and is published on the District's website, the "AirNow"
website, and in newspapers.

EPA Monitoring Requirements

EPA regulations dictate the minimum number of monitoring sites to be established by State and local air
agencies. The District network meets the minimum monitoring requirements for all criteria pollutants
(Tables 1-5). These requirements are based on local Metropolitan Statistical Area (MSA) data, as set
forth in the Code of Federal Regulations, (40 CFR 58). MSAs are part of a classification of geographical
regions developed by the U.S. Census Bureau and include one or more counties, although not all counties
fall within an MSA. For the criteria pollutants, such.as 03, PM2.5, and PMl 0, the required minimum
number of monitoring sites is based on both the population and the pollutant concentration in a MSA.

PM2.5 Measurements of July 4 (1-hr., -8-h~:-;-24-hr.

Avgs~-) v~;s~~ ;M2.;~evels t~a~-~igger-

--- -

--------1

Evacuation during Wildfires (according to 2012 EPA Wildfire Smoke Guide)

I
600.0 . - - - - - - - - - - - - - --

,- - - -

500.0

+----~-------------

400.0

+-------\-----------

300.0

+ - - - - - - - - - - - : : : - - - - - - - - - --
-+-July 4 Highest Level PM2.5- Carmel Beach Monitor

PM2.5 Consider Evacuation of Sensitive Populations

Note: Source of PM2.S Evacuation consideration levels from 2012
Wildfire Smoke- A Guide for Public Heath Officials; see Table 3
Chart, p. 31.

200.0 ; - -- - - - - - - - - - - - - - - - -

100.0

-t--------"'1,.,.------------

1-hr. Avg

8-hr. Avg

24-hr. Avg

July 4 Highest Level PM2.5 - Carmel Beach Monitor

153.0

75.1

28.6

PM2.S - Consider Evacuation of Sensitive Populations

526.0

300.0

250.5

O.O

STAT Of CALIFORNIA-NATURAL RESOURCES AGENCY

EDMUND G. 8RDWN, JR., GOVUNO

CALIFORNIA COASTAL COMMISSION

45 FREMONT STUU, SUITE 2000
SAN FRANCISCO, CA 94105 2219
VOICE (415) 904 5200
FAX ( 415) 904 5400
TOO (4151 597-5115

MEMORANDUM

FROM:

Laurie Koteen, Ph.D., Ecologist

TO:

Mike Watson, Coastal Analyst

SUBJECT:

Carmel Beach Air Quality Issues

DATE:

December 9, 2015

Documents reviewed:

Liberti, A. (1975) Modem methods for air poJiution monitoring. Pure and Applied Chemistry, 44(3), 519-534.
Tao, L. and Harley, RA. (2014) Changes in fine particulate matter measurement methods and ambient
concentrations in California. Atmospheric Environment, 98, 676-684.
Trent, A. (2003) Laboratory evaluation of real-time smoke particulate monitors General Tech. Rep. 03252834-MTDC), USDA Forest Service Technology and Development Program, Missoula, MT: pp 15.
Dockery, D.W. 2009. Health effects of particulate air pollution. Annals ofEpidemiology. 19:257- 263.
Rueckerl, R., A. Schneider, S. Breitner, J. Cyrys, and A. Peters. 2011. Health effects of particulate air
pollution: A review of epidemiological evidence. Inhalation Toxicology. 23:555- 592.
Puett, R.C., J. Schwartz, J.E. Hart, J.D. Yanosky, F.E. Speizer, H. Sub, C.J. Paciorek, L.M. Neas, and F.
Laden. 2008. Chronic particulate exposure, mortality, and coronary heart disease in the nurses' health study.
American Journal ofEpidemiology. 168:1161-1168.
Strak, M., N.A.H. Janssen, K.J. Godri, I. Gosens, I.S. Mudway, F.R. Cassee, E. Lebret, F.J. Kelly, R.M.
Harrison, B. Brunekreef, et al. 2012. Respiratory health effects of airborne particulate matter: The role of
particle size, composition, and oxidative potential-The RAPTES Project. Environmental Health
Perspectives. 120:1183- 1189.
Rueckert, R., A. Schneider, S. Breitner, J. Cyrys, and A. Peters. 2011. Health effects of particulate air
pollution: A review of epidemiological evidence. Inhalation Toxicology 23 :555-592.
Lipsett, M., Materna, B., Stone, S.L., Therriault, S., Blaisdell, R., Cook, J. (2008) Wildfire Smoke: A
Guide for Public Health Officials, U.S. Environmental Protection Agency: pp 53.

L.Koteen Memorandum toM. Watson regarding Carmel Beach Air Quality Issues, Dec. 9, 2015
Fires on Cannel Beach are Established Policy
The City of Carmel-by-the-Sea has historically allowed the public to establish frres on Carmel Beach.
Beach fires are identified as a part the City's cultural identity and the beach's recreational utility in the
City's LCP, with the time when fires are permitted and the appropriate locations detailed (see,for
example, LUP Policy 04-10, LUP Policy P4-57, and IP Sections 17.20.20.D and E). Beach fires are
already limited in carmei-i0ili~ area.souti1(;i lOiiiAvenue,or ab.o ut.oiie.ihiid:.o rti\e bW:ii."-Beach .tires
are not allowed on the other roughly two-thirds of the beach, so the issues discussed herein do not pertain
to the whole of Carmel Beach, but rather only to the southernmost third of the beach. In response to
concerns raised regarding smoke and other issues associated with these beach fires in this southernmost
area, an air quality monitoring station was established by the Monterey Bay Unified Air Pollution Control
District (MBUAPCD) at a private residence at the comer of 13ch Avenue and Scenic Drive, just inland of
Carmel Beach. The specific purpose of the air quality monitoring station is to measure particulate matter
concentrations in the 2.5 micro-meter diameter range (PM 2.5) 1, as particulate matter in this size class is
commonly associated with smoke2 In addition, and also in response to concerns raised, the City recently
instituted a new moratorium on beach fires within the allowed beach frre area from Friday through
Sunday and on all holidays; beach frres are still allowed in the beach frre area Monday through Thursday,
if these days do not fall on a holiday. Beach fires are not allowed on the northern two-thirds of Carmel
Beach per the LCP.
High concentrations of PM 2.5 are harmful to human health
Several decades of research have documented strong correlations between elevated particulate emissions
(PM I0 and PM 2.5) and a wide range of adverse health outcomes. These include increased rates of
pulmonary and cardiovascular morbidity and mortality, adverse reproductive outcomes, and possible
3
neurological effects Adverse health outcomes have been found to be associated with short-term acute
exposures to high particulate concentrations. Long-term health impacts can also result from sustained
exposure to elevated particulate levels~ and result in premature death rates in locations where they occur.
Particularly vulnerable populations include children, those with chronic ailments, such as asthma or
cardiovascular disease, and the elderly5 High concentrations of particulate matter are also associated
with reduced visibility, and can fonn haze when sunlight encounters tiny pollution particles.
1
PM 2.5 are particulate emissions with an aerodynamic diameter of 2.5 11m or less. Aerodynamic diameter is the
diameter of an idealized particle that bas the same aerodynamic properties as a given particle, but which is spherical
in shape. I 11M = 1o~ m.

"Particulate Matter," U.S. Environmental Protection Agency, http://www3.epa.gov/pm/

Dockety, D.W. 2009. Health effects of particulate air pollution. Annals of Epidemiology. 19:257-263.
Rueckert, R., A. Schneider, S. Breitner, J. Cyrys, and A. Peters. 20 II . Health effects of particulate air pollution: A
review of epidemiological evidence. Inhalation Toxicology. 23:555-592.

Puett, RC., J. Schwartz, J.E. Hart, J.D. Yanosky, F.E. Speizer, H. Sub, CJ. Paciorek, L.M. Neas, and F. Laden. 2008.
Chronic particulate exposure, mortality, and coronary heart disease in the nurses' health study. American Jownal of
Epidemiology. 168:1161-1168.

Strak, M., N.A.H. Janssen, K.J. Godri, I. Gosens, I.S. Mudway, F.R Cassee, E. Lebret, F.J. Kelly, R.M. Harrison, B.
Brunekreef, et a!. 2012. Respiratory health effects of airborne particulate matter: The role of particle size,
composition, and oxidative potential-The RAPTES Project. Environmental Health Perspectives. 120:1183-1189.
5
Rueckert, R., A. Schneider, S. Breitner, J. Cyrys, and A. Peters. 2011. Health effects of particulate air pollution: A
review of epidemiological evidence. Inhalation Toxicology 23:555--592.

L.Koteen Memorandum toM. Watson regarding Cannel Beach Air Quality Issues, Dec. 9, 2015

The standard procedure for evaluating whether particulate matter'concentrations are at levels harmful to human
health is to rely on those standards established by the state and federal Environmental Protection Agencies
(EPA) under the State and Federal Clean Air Acts. The Clean Air Act standards for PM 2.5 appear in Table 1.

---Table 1: siateand NationaTAmbient Air Quality Standards forParticulate MatterT

.. - . - ~,----california Ambient
QuiiltY -~-- National Primarv~ Ambient Air QualitY-- :
,
Standards for PM 2.5
Standards for PM 2.5
:
-- _T ___ __ .. - - - - - - - - - - - - - - --T
- ------ --- ------ - - - - - ----

AJr

Annual i
I
--- -- .. -r-24
_H_~~rs ___.

12 ~.m-~

12 ~.m-3

'
I

-1 -

_______________ ________ L

_ _ ----- ________ . ___ .. __ ----

* Standards for 24-hour PM 2.5 are not explicitly set by the California Air Resources Board. Instead, the
California Air Resources Board references the National Air Quality Standards
# This unit is micrograms per cubic meter.

In addition to these Clean Air Act standards, the EPA puts out the following guidelines for public health
officials, Table 1, to provide the public with infonnation about the health risks associated with ambient
PM 2.5 concentrations. These guidelines are sometimes referred to as the Air Quality Index, or AQI.
(See Table 2 on next page.)

Particulate Matter Overview, http://www.arb.ca.gov/researchlaags/caags/pm/pm.htm

The EPA sets both primary and secondary ambient air quality standards for PM 2.5. The primary standard is a
health based standard , whereas the secondary standard is a ''Welfare" based standard concerning environmental
impacts. Because the City's actions are concerned with air quality/health impacts relating to beach fires, the primary
health-based standard is relevant here.
8

Setting the daily mean as a threshold value is an approximation here. To see if the actual standard is met, one must
have 3 years of data and follow procedures outlined in 40 CFR Part SO, Appendix N to Part 50 - Interpretation of the
National Ambient Air Quality Standards for PM2.5, https://www.Jaw.comell.edulcfr/text/40/part-SO/appendixN.
The method detailed in this appendix allows for occasional daily concentrations greater than 3Sj!g.m3
9

Ibid.

L.Koteen Memorandum toM. Watson regarding Cannel Beach Air Quality Issues, Dec. 9, 2015

Data Exploration of Air Quality in the Vicinity of Beach Fire Area at Carmel Beach
To detennine whether or not a moratorium on beach fires within the allowed beach fire area at the
southern third of Carmel Beach is sound policy that will reduce the likelihood of banning human health, I
analyzed available data from several sources. The goals of this data analysis were to answer the
following questions:

I. Do exceedances of national and state air quality standards and public health guidelines for
PM 2.5 occur in the vicinity of the allowed beach fire area at Cannel Beach?
2. If exceedances of PM 2.5 standards and guidelines do occur in that area, is the PM source of
those exceedance episodes attributable to beach fires from the beach fire area?

I used the following data to answer the above questions:

PM2.5 data
This data was provided to me by the MBUAPCD from the air quality monitoring station that was installed
at the 13th Avenue and Scenic Drive location, Figure l. This location is within the local airshed of the
beach fire portion of Carmel Beach. The data extends from May 21,2015 through October 19,2015, and
contains hourly, eight-hour and twenty-four hour average measurements, which I evaluated for
10

Air Quality Index Basics, btto://aimow.gov/index.cfin?action=agibasics.aqi

11
Wildfire Smoke: A Guide for Public Health Professionals, bttp://www.arb.ca.gov/clllpaltoolkitldata-tomes/wildfire-smoke-guide.pdf

L.Koteen Memorandum toM. Watson regarding Carmel Beach Air Quality Issues, Dec. 9, 2015
conformance to air quality standards and guidelines. The District used an ~BAM sensor to measure PM
2.5 concentrations. E-BAM sensors rely upon a beta attenuation teclmology. According to this method,
ambient air is drawn through the E-BAM sensor at a specified flow rate and particulates are captured by a
filter tape in the sensor core. Beta radiation is emitted through the tape both before and after PM 2.5 mass
collection, and the ratio of beta radiation that is attenuated before and after particle collection is used to
determine the particle mass 12 The accuracy of this measurement relies on thorough mixing of ambient
air. When systematically compared to a reference sampler, E-BAM sensors were found to be accurate,
but to overestimate PM 2.5 concentrations by 13.5% on average in a 2003 study. However, the
technology may have improved in the interim 13

Beach Fire data

Data on the number of fires within the beach fire area at Carmel Beach were provided by the City of
Carmel-by-the-Sea based on its observations for five weekends spanning a time period from June 27,
2015 through July 26, 2015. I used this data to evaluate the relationship between the number offrres and
the PM 2.5 concentrations at the 13th Avenue monitoring station 14 The City provided beach fire number
data both for the 7:00p.m. time frame as well as the 8:30p.m. time frame. I used the 7:00p.m. data for
my analysis based on the assumption that a "sea breeze" was most likely to be still active at that time,
leading to readings at the monitoring station location that would reflect the effects of beach fire smoke 1s.
At coastal locations an on-shore breeze usually develops during the day based on air circulation patterns
established by temperature differences between the land and water (land temperature > water
temperature). As the sun sets, the temperature differences grow smaller or are reversed, and the sea
breeze is typically quieted. Therefore, PM 2.5 measurements at the location of the sensor are likely to
best reflect smoke produced on the beach during times when the sea breeze is active 16

Meteorological Data
I used available meteorological data to evaluate wind speed and wind direction during episodes when
higher PM 2.5 concentrations were recorded by the monitoring sensor in order to understand the source of
particulate matter for these episodes. Meteorological data were recorded at the location of the 13th
12
Liberti, A. (1975) Modem methods for air pollution monitoring. Pure and Applied Chemistry, 44(3), 519-534,
Tao, L. and Harley, R.A. (2014) Changes in fine particulate matter measurement methods and ambient
concentrations in California. Atmospheric Environment, 98, 676-684.
13

Trent, A. (2003) Laboratory evaluation of real-time smoke particulate monitors General Tech. Rep. 0325-2834MTDC), USDA Forest Service Technology and Development Program, Missoula, MT: pp lS.
14

The 13th Avenue monitor cannot distinguish between PM 2.5 from beach fires versus other potential sources (e.g.,
residential fireplaces and barbeques, vehicular exhaust, etc.), so it is not possible to measure the correlation
explicitly due to beach fires. This analysis generally presumes all PM 2.5 to be from beach fires as a cautionary and
conservative approach. However, there clearly is a need for more advanced monitoring data of this type to be able to
conclusively establish relationships between smoke on the beach and inland PM 2.5 concentrations.
15
ibid (with respect to beach fire smoke versus other potential PM 2.5 sources). In addition, the 13th Avenue
monitor was not able to collect high quality meteorological data, so this is a proxy for what might be reasonably
inferred in this regard (see also 'Meteorological Data' discussion that follows).
' 6 Ibid (need for

more advanced monitoring data (related to the effect ofdifferent sources and wind patterns, etc.) to
be able to draw effective conclusions).

L.Koteen Memorandum toM. Watson regarding Carmel Beach Air Quality Issues, Dec. 9, 2015

Avenue air quality monitoring station. However, those data were generally of poor quality due to
difficulties in finding a suitable setup location for the meteorological sensors. The quality of wind data
will suffer when it is placed behind a physical barrier, as was the case at the 13th Avenue monitoring
station. PM 2.5 data may suffer as well, but in this case it probably reflects the local air quality fairly
well. Although the sensor is quite near to the beach, it is at a sufficient distance that the air should be
well-mixed by tbet~e it reaches the sensor;
this
assumption 1 1~ The .MBUAPCD did
provide me with reliable meteorological data from a Pacific Grove location as provided by the California
Irrigation Management Information System network (CIMIS) 18 CIMIS is a network of weather stations
arrayed across California where numerous meteorological variables are recorded on an hourly basis. The
location of the Pacific Grove sensor has the benefit of being located along the coast, but it is in a
somewhat different orientation than Carmel Beach. In addition, the Pacific Grove sensor is located
substantially to the north of Carmel Beach, and in an area that is more directly exposed to the
predominant northwest winds, whereas Carmel Beach is located within Carmel Bay where the headlands
of the Bay may change wind dynamics as compared to the Pacific Grove sensor, Figure 2. Therefore, I
viewed these wind data as representative overall, but by no means identical to the meteorological
conditions that occur at Carmel Beach.

aiiliough

is an

Analysis of Air Quality Standards and Guidelines in relation to PM 2.5 readings in the Carmel
Beach Fire Area Airshed
To answer the question of whether federal air quality standards were exceeded, or whether state public
health guidelines showed problematic air quality inland of the beach frre area during the study period, I
graphed the one-hour and the twenty-four hour average data from the 13lh Avenue monitoring station to
correspond with the guidelines listed in Table 2. These appear in Figures 3 and 4 respectively.
Although the one-hour data are important and informative, the twenty-four hour data are the only data for
which enforceable Clean Air Act standards exist. Therefore, I relied solely on the twenty-four hour data
to detennine if an air quality exceedance occurred. According to the 24-hour data, daily standards for PM
2.5 were exceeded one time, on September 20, 2015, Figure 4, (but see footnote 8 which establishes that
this is a conservative interpretation of the Clean Air Act Standard, and that three years are required to
actually establish if a violation has occurred). I do not attribute this exceedance to beach frre smoke,
however, because it occurred on a Sunday when the City was enforcing its beach frre moratorium.
Turning to the hourly data, Figure 3, we see that readings at the 13th Avenue monitoring station were
predominantly in the " Good" air quality category almost all of the time 19 We also see several data points
that exceeded recommended guidelines for one to three hour concentrations. By "exceeding
recommended guidelines," J am distinguishing between exceedances of state and federal standards, which
represents non-compliance with the Clean Air Act, and exceedance of the guidelines detailed in Table 2
above, which puts air quality conditions outside of a set of recommendations for public health officials to
guide their response under different particulate matter concentrations. Under these EPA guidelines, PM
17

Ibid (note that the sensor cannot distinguish between different potential sources).

18

California Irrigation Management lnfonnation System (CJMIS), http://www.cimis.water.ca.gov/

19

See Table 2 above. Per EPA guidelines, the "Good" category means "Air quality is considered satisfactory, and
air pollution poses little or no risk."

L.Koteen Memorandum toM. Watson regarding Carmel Beach Air Quality Issues, Dec. 9, 2015

2.5 concentrations reached levels "Unhealthy for Sensitive Groups" during six individual hours in the
months of May through early July. In addition, on July 41h, a day in which recreationists lit 75 and 135
fires (by 7 p.m. and 8:30p.m. respectively) 20, PM 2.5 concentrations rose into the ''Unhealthy" category
for two hours as measured at the 13r.b Avenue monitoring station. Across the entire five-month hourly
dataset, air quality conditions for PM 2.5 fell into the "Good" category 98.0% of the time, into the
"Moderate" category 1.8% of the time, into the "Unhealthy for Sensitive Individuals" category 0.17% of
the time and into the "Unhealthy" category 0.055% of the time 21 Iro~hort, the aata shows thal air qua1ity
.at the 13"' Avenue Ji'lbnitor:in~ station was almost al;w:ay.s in the "'Good" atr_quali9i categocy., when thj::.
finer-grJlined boUI<ly, ~v.erag~ 11ir quality is consjder.ed, fGJ which the fjJ) do~ not r.eco.mmend that ~ny
actions arc nec.ess~ to abate air quality concerns (see Table 2). Air quality only entered into the
"Unhealthy" categories eight times (about 0.23% of the data points), one time of which exceeded Clean
Air Act standards during a time when there were no beach fires. In Figure 4, we see the single
aforementioned 24-hour data point where PM 2.5 exceeded the recommended guidelines for 24-hour
concentrations (during a time when the City enforced a prohibition on all beach fires).
A comparison of Figures 3 and 4 is also informative. The finer-grained hourly data, Figure 3, indicates
that eight hours of high PM 2.5 concentrations fell in the "Unhealthy for Sensitive Individuals" and
''Unhealthy" categories on weekends before the moratorium was implemented. However, the coarsergrained, 24-hour averaged data, graphed in Figure 4, reveals that large fluctuations in PM 2.5 readings
occurred both pre- and post-moratoriwn, with PM 2.5 concentrations indicating "Moderate" air quality
conditions evident throughout the dataset. The period from approximately August 14"', 2015 through
October Ism, 2015, for example, is a period of large fluctuations in PM 2.5 concentrations, with no
apparent pattern of high or low values associated with weekends or weekdays. These observations
emphasize that a multi-source analysis combined with meteorological data would be required to
understand, and potentially improve, our understanding of particulate matter concentrations in this region.
Further, a focus solely on beach fires at Carmel Beach as a means of improving PM 2.5 concentrations in
Carmel-by-the-Sea, will be a partial solution at best, given that there are many other factors that can
contribute to PM 2.5 concentrations, incJuding wood fires in residential frreplaces, vehicle exhaust,
backyard barbecues, etc.
Analysis of the Correlation between Beach Fire Occurrence and PM 2.S Concentration
To determine if the source of the relatively higher PM 2.5 concentrations at the 13111 Avenue monitoring
station can be attributed to fires within the beach frre area on Carmel Beach (Question 2, above), I
followed two approaches. For the first approach, I graphed the 24-hour data for the time period preceding
the moratoriwn on beach frres (i.e., for the time period from May 21, 2015 through August 2, 2015),
FigureS. I then identified all the weekends in this time period (Friday through Sunday). If PM 2.5
concentrations exceeded 12 Jlg.m-3 during any portion of those weekends (i.e., if concentrations exceeded
state guidelines for "Good" PM 2.5 conditions), I drew a shaded box around those weekends to separate

20

Data provided by the City of Carmel-by-the-Sea.

21

These percentages sum to 100.025% due to a slight rounding error.

L.Koteen Memorandum toM. Watson regarding Carmel Beach Air Quality Issues, Dec. 9, 2015
them visually from the larger dataset22 I followed this procedure on the assumption that more visitors are
likely to be recreating on the beach on weekends, especially into the everrings23 Therefore, if relatively
higher PM 2.5 concentrations at the 13th Avenue monitoring station were found to correspond with those
weekend dates, I considered it safe for the purposes of this analysis to attribute those conditions to the
higher number of beach fires within the beach fire area during that time. As is evident in FigureS, the
majority of the relatively high PM 2.5 episodes over this time period did occur on weekends, with the
exception of June 15th- 181\ (Monday through Thursday), July 28th and 291\ (Tuesday and Wednesday),
and a few additional points leading into or out of the weekend time periods highlighted on the graph.
During these highlighted, weekend time periods and the other times identified, air quality entered the
"Moderate" zone for PM 2.5. From the "Moderate" air quality conditions that occurred on July 28th and
29th, and from a few periods visible later in the dataset after the moratorium was imposed (roughly August
14th - September II th), Figure 4, when PM 2.5 concentrations were again relatively high, it is clear that
factors other than fires on Carmel Beach also contribute to the measured PM 2.5 concentrations at the 13th
Avenue monitoring station. As indicated earlier, more robust data collection would be required to be able
to differentiate among different potential contributors affecting PM concentrations, including not only in
relation to sources, but other related and critical data (e.g., meteorological data, beach fire number and
location data, etc.).
For the second part of this analysis, I used a linear regression approach as a means to evaluate the
correlation between the City's fire data (i.e. the number of fires that occurred at 7:00p.m. across five
weekends, as estimated by the City) and the PM 2.5 data from the 13th Avenue morritoring station. The
results of this analysis appear in Figure 6. In this approach, the r-squared value, or the square of the
correlation coefficient, establishes the strength of the relationship between the number of fires on these
five weekends and PM 2.5 data, with a value of one indicating perfect correlation between the variables
and a value of zero indicating no correlation. I found an r-squared value of 0.65, indicating a relatively
strong correlation between the number of fires on these weekends and PM 2.5. That is to say that
approximately 65% ofthe relatively high PM 2.5 concentrations can be explained by the number of beach
fires on these five weekends, whereas the remaining 35% do not. However, and in addition to issues
previously noted regarding the nature of the data set, a few additional caveats must be applied to this
analysis. First, the dataset is very short, and includes data from five weekends only, and during time
periods when wind conditions were assumed to be pushing smoke inland. A longer dataset along with
baseline and comparative data would likely give a truer picture of the actual relationship between the
number of fires and PM 2.5. The relationship is also strongly influenced by the one point at the high end
of the number of fires (i.e., on July 4th when there were 75 reported fires at 7:00PM, with a corresponding
PM 2.5 concentration of 148 li&m-3} 24 If this point is removed from the dataset, the r-squared value falls
to 0.21, which is a much weaker correlation. That being said, it appears from the larger analysis that the
22

There were four weekends during this period where air quality remained in the "Good" range for the entire
weekend (i.e. May 29-31, July 10-12, July 24-26 and July 31- August 2).

23

Note that this is an assumption for the purposes of this memo only. Obviously, the conditions that lead to more
versus Jess use of the beach are complicated and more difficult to model. The use of the beach is driven by much
more than just whether the days fall on Friday through Sunday (e.g., temperature and weather patterns and
conditions, daylight hours, surf and swells, school and holiday patterns, local and regional events, etc.).
24

At 8:30PM, the number of fires reported was 13 5, with PM 2.5 readings of 153 ~g.m'3

L.Koteen Memorandum toM. Watson regarding Carmel Beach Air Quality Issues, Dec. 9, 2015
number of fires on Carmel Beach likely influence the particulate matter concentrations at the l31b Avenue
monitoring station.

Source of high PM 2.S in September

In addition to the above analyses, I also sought to identify the source of the exceedance episode that
occurred on September 20u., 2015-, as this was the one time the data shows that the'24-hour federal air
quality standard was exceeded. Due to the moratorium on weekend fires at that time, it appears clear that
beach fires could not be implicated in the exceedance. However, because PM 2.5 concentrations are
frequently associated with smoke, I looked at the catalogue of large-scale fires being monitored by Cal
Fire 25 to see if any fires coincided with the dates in question. I found that two fires in the Carmel Beach
vicinity corresponded with these dates, and more than likely explain the high PM 2.5 concentration
readings on this date. These were the Tassajara frre, a frre that burned l ,086 acres from September 19th
through September 27u., and the Laureles fire, which burned from September 19tb through September 21s1
and consumed 95 acres, Figure 7.
Conclusions
.
TG c0n'O'Jude, and to answer the questi0ns posed ab:ON,e_. y,es; ~ne ex:c~ence efiihCJt:leanLA1li Aet14-hoJ1T
PM 2<5 standards dt(l occur. over thefive-mon!Jt-time-peried examin"<1. However, that-ex:ce..ooan~
ooounred opa S:\lnj)Ay wh~n tht!lbea'Cli fit.e mot-fit . ri\lro w.as n place liD~ llier.e were ne btaoh fires, Thus,
this exceedance was due to,.P.M 2.5 sources other than beach frres. 'This exceedance instead appct-arsrto
l]la e15een assoeia(ed wiili the Iilrge fir-es tltat"ooc\ll'fed inflfu . of"tannel Beaeh..al~J!g Htgh"Way 08 at that
time, and was definitely not associated with .fires on ar.me1 BeaCli: Eight other instances of relatively
high PM 2.5 concentrations did occur on weekends in late May through July, with six hours that fell into
the "Unhealthy for Sensitive Groups" range and two hours in the "Unhealthy" range. These instances
occurred when there were also larger numbers of fires on Carmel Beach on those dates. However, these
instances were limited to a total of 0. I 7% of the study period in the "Unhealthy for Sensitive Groups"
range, and 0.055% of the study period in the "Unhealthy" range. The remainder of the data show that air
quality remained in the "Moderate" range 1.8% of the time and in the "Good" range for 98% of the time.
At this time, collection of a larger dataset of particulate matter concentrations is warranted to assess
whether annual PM 2.5 standards are exceeded, and to what degree such exceedances might be correlated
to beach frres. An attempt to identify other sources of PM 2.5 would also be prudent from a public health
standpoint, as the data record clearly indicates that PM 2.5 is generated from sources unrelated to beach
fires (i.e., chimney smoke, backyard barbeques, vehicle emissions, industrial processes, etc.). The
collection of high quality meteorological data in conjunction with the air quality dataset would also be
helpful for interpretation of the potential sources of high particulate matter, as would further data on the
number of fires that occur each day, including on days when documentation confums that no fires
occurred. Base on thts analo/s-ts, 1 cGn'Cl\lde that limitijjg tfie n11Mb:e1'1lflteacb fires~ an(! ttea; beae~ fire
ftna,nagement within the.allaw~ Oe'a~'D 'fir.e 8.fea at CamttJ Beach w0utd be a prodenl~.d caulious
appr_eacb to bet}' avoi4 eK~'l:iing ''G@(}d" air quaJity.guidelines inland o'fthat lll!ea, but that a ban:.on 4.11
l!CbfJre.S 'is. ttGt SU_RP.erted by the Qata.

25

http://calfire.ca.gov/index
9

L.Koteen Memorandum toM. Watson regarding Cannel Beach Air Quality Issues, Dec. 9, 2015

Figure I. Location of the 13 Avenue air quality monitoring station

10

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L.Koteen Memorandum toM. Watson regarding Carmel Beach Air Quality Issues, Dec. 9, 2015

Weather Station Location

Figure 2. Location of the Pacific Grove weather station relative to Cannel Beach

11

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