Item 11: CAPCOG Air Quality Plan

Consider approval of Resolution 2021-102R, approving a commitment to support the CAPCOG Clean Air Coalition’s Proposed Regional PM2.5 Emission Reduction and Planning Measures for the Austin-Round Rock-Georgetown MSA Regional Air Quality Plan; and declaring an effective date.

Why is the City not embracing more of the suggested changes?
I understand some of these categories do not apply to the City, but surely we have businesses in town that might need regulation of these activities. Shouldn't the City consider policies that limit their impact on our community? Isn't that sorta what this is asking us to do?

Identifies road and other construction as factors, what are the current enforcement levels for poorly maintained construction sites that fail to mitigate their dust? Also, considering the length of time for the Victory Gardens road construction and all the dust they had to breathe for an extended period of time, should we consider air monitors around City projects to ensure we are not creating unhealthy living conditions? Could we consider similar regulations for private businesses as well?

Since these PM2.5 air pollution include exhaust fumes, does this affect our airport expansion and our potential to monitor quality there? Not only the construction exhaust, but the future increased traffic as well.

Response provided by Sabas Avila, Interim Director of Public Works:
This is the first year that the Capital Area Council of Governments (CAPCOG) and Clean Air Coalition (CAC) have requested proactive, voluntary PM2.5 reduction measures from member agencies. CAPCOG and CAC understand that PM2.5 reduction measures may take time to implement. For this reason, CAPCOG and CAC are not requesting specific regulations or programs at this time. Rather, CAPCOG and CAC are requesting general commitments from Table 1 that can be included in the regional air-quality plan update to show proactive reduction steps.

Particulate matter is defined as fine particles such as dust, dirt, or soot. Particulate matter is generally derived from “non-point” or “area” sources such as construction sites, unpaved roads, or fires. Particulate matter is generally not derived from combustion engines or combustion facilities.

The City of San Marcos already employs several existing ordinances and procedures that can be utilized as enforcement measures to control dust and dirt from private contractors and City projects including:

• Construction Notes (see page 4, note 2 under Erosion Control Notes)
  • http://www.sanmarcostx.gov/DocumentCenter/View/861/Construction-Notes-PDF
• Standard Specifications
  • http://www.sanmarcostx.gov/Document...-Austin-and-TXDOT-Standard-Specifications-PDF
• Municipal Separate Storm Sewer System (MS4) Ordinance for Pollutant Discharges from construction activities
  • Section 01500
• City enforcement of State Texas Pollution Discharge Elimination Systems (TPDES) discharges from construction activities

Nationally, the enforcement of dust reduction and enforcement strategies are traditionally performed on a best management practices approach. That is, particulate generating activities are expected to use best management practices - dust control/sediment migration reduction measures. Not using these measures on a construction site can easily be determined and acted upon. Attempting to set a numeric air standard, measure air quality, assert a cause and effect relationship and successfully enforce against a contractor accordingly is problematic and not recommended at this time from a practical and legal perspective. The Sustainability Committee may be the best forum to further discuss management and enforcement strategies for both public projects and private businesses.

As mentioned above, particulate matter is generally not derived from combustion engines or combustion facilities. Subsequently, aircrafts and airport traffic would not be primary sources of particulate matter.