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HomeMy WebLinkAboutCOM 0191.006 2016-2018Murashige, Laura From: Maile Lu'uwai <mluuwai@hawaii.rr.com> Sent: Tuesday, April 04, 2017 11:57 AM To: Council Testimony Subject: Public Testimony Res. 135-17 Attachments: KPFA PHHLCA Council Testimony Res. 135-17 .pdf P1 C oWnI c2 CC,bMIO . I q l ��I I Own No. �. Ref. To: Ref® Date �._, Date: April 4, 2017 To: County of Hawai'i County Council Re: Res. 135-17 Urges the Mayor to rescind the "Termination for Convenience" notice to the Contractor, dated February 16, 2017, to best insure that the County's solid waste management goals are achieved. The Keaukaha Pana'ewa Farmer's Association (KPFA) and the Pana'ewa Hawaiian Home Lands Community Association (PHHLCA). are jointly submitting our community opposition to the above -referenced Resolution. The basis for our position is that the County of Hawaii East Hawaii Organics Facility (Facility) cannot be located in our Pana'ewa Community. We understand the community need for the Facility. However, our communities adamantly oppose the current location designated for the Facility. The County must find another site that will not substantially reduce the use of adjacent DHHL trust land and negatively impact our Hawaiian DHHL communities. A revised plan that relocates the Facility is required to address our community concerns The Facility meets at least five significance criteria set forth in Hawaii Administrative Rules Section 11-200-12. Thus, the Facility will significantly impact adjacent Department of Hawaiian Homes Land (DHHL) trust property and existing DHHL homeowners. The Facility meets the following significance criteria set forth in Hawaii Administrative Rules Section 11-200-12: 1. The Facility will curtail the beneficial use _of the DHHL trust land and DHHL homeowner properties. 2. The Facility will substantially affect the economic and social welfare of the Pana'ewa community. 3. The Facility will affect the health of the Pana'ewa community. 4. The Facility will substantially degrade the environmental quality of the Pana'ewa community. 5. The Facility will detrimentally affect the air quality and ambient noises in the Pana'ewa community. FACILITY PROXIMITY The Keaukaha Pana'ewa Farmer's Association (KPFA) represents over 1,000 family members on 285 Pana'ewa Agricultural Lots situated within TMK: 2-1-251 2-1-26 and 2- 2-61. Of those lessees, 70 lessees and their families are in direct proximity to the proposed Facility. These lessees reside on Auwae and Kahaopea Roads. The Pana'ewa Hawaiian Home Lands Community Association (PHHLCA) represents over 1,200 family members living on 311 residential lots. Our homes and properties, as well as undeveloped DHHL properties are within the Facility Impact Zone and will be directly impacted by the smell, dust, dirt and noise from the Facility. This is a significant impact on our community. See Appendix 1 & 2, Pana'ewa DHHL Community Composting Facility Impact Zone. DHHL plans to build homes on the property adjacent to the Facility. The Facility would substantially impact the future beneficial use of the DHHL trust land. In fact, if the Facility is built as stated, DHHL can never build homes on adjacent "subsistence" lots. That is a significant significant impact. The impact of this Facility can be compared to the County's Drag Strip that is located adjacent to DHHL land in Pana'ewa community. The Drag Strip substantially reduced the beneficial future use of adjacent DHHL land for DHHL beneficiaries. After the Drag Strip was built, FHA refused to fund mortgages to build homes on the DHHL property because of Drag Strip activities. Thus, 240 acres of DHHL land cannot be used for -homes for DHHL beneficiaries. This Facility would further reduce the beneficial use of that property. See Appendix 3, Pana'ewa DHHL Community Cumulative Surrounding Uses. Items 8, Dragstrip. The Facility would have the exact same significant and negative impact on DHHL land adjacent to this Project diminishing the property use for future and existing DHHL homeowners as well as impacting homeowners who need FHA funds. The County Council Resolution, as written, clearly dismisses the Facility's impact on DHHL current and future beneficiaries. NOXIOUS SMELL County Council members have claimed that the Facility will not smell. There is no valid basis for this assertion. In fact, our direct experience and data disputes this assertion. Cedar Grove is the parent company of Hawaiian Earth Recycling. They provide the financing and will make all the decisions for their Hawai'i operations including the proposed Pana`ewa Composting Facility. In February 2017, KPFA President Maile Lu'uwai and Vice President Howard Pea visited Cedar Grove's Composting facility in Everett, Washington. According to Ms. Lu'uwai and Mr. Pea, Phase 1 of the composting operations generated a stench that smelled like a pig farm. It smelled like a pig farm despite the temperature at 38°F. - The smell of compost increases in higher temperatures. With Hilo's 73.85°F average temperature and relative humidity from 58% (mildly humid) to 94% (very humid), the noxious smells from the proposed Pana`ewa Composting Facility will permeate our homes and our entire community and reduce the use and value of undeveloped DHHL beneficiary land. The Pudget Sound Clean Air Agency (PSCAA) regulates air quality in Washington PSCAA received over 6,775 odor complaints against Cedar Grove's composting facilities between 2010 and September 2015. According to the PSCAA, Cedar Grove has gotten more complaints than any other Washington State company since 2007. In 1999, Cedar Grove was settled a multimillion lawsuit based on the "revolting" odors from their facilities. In 2011, Cedar Grove spokesman Laird Harris stated that it invested millions to control smells at its plants. In 2017, Cedar Grove operations continue to smell. However, Cedar Grove continues to blame other businesses and sources for the smell. The PSCAA issued 39 Notice of Violations/Written Warnings against Cedar Grove between 2010 and 2014 for odor and operations violations. The PSCAA issued 16 Civil Penalties against Cedar Grove between 2010 and 2013 totaling $216,000 in fines. On July 14, 2011, Cedar Grove was issued a penalty for $119,000 arising out of odor complaints for both of its facilities in Marysville and Everett. In 2014, the PSCAA released a $453,000 study finding that electronic odor monitoring devices detected smells from compost and two waste water treatment plants. However, the study also found that nearly all unpleasant odor reports by volunteers were directed at compost from Cedar Grove. See Appendix 4, Community Odor Monitoring Project Summary, January 23, 2014. Cedar Grove threatened to sue PSCAA for the study's findings that stated while there were three sources of order in the area, most of the volunteers smelled Cedar Grove's compost. Cedar Grove stated that "It's really hard to argue that we can trust the regular nose over scientific data". In other words, Cedar Grove believes electronic monitoring devices should be trusted over human noses. In 2013, two lawsuits were filed against Cedar Grove stating that its off-site emissions of noxious odor resulted in a nuisance for nearby homeowners in Marysville and Everett. The nearest home to Cedar Grove's Everett composting facility is 1 mile. The nearest home to Cedar Grove's Maryville composting facility the nearest home is 1.2 miles. In contrast, the nearest home to Cedar Grove's proposed Pana`ewa Facility is 1000 square feet. Most of our agricultural and residential Hawaiian Community is within a 1000 feet to three mile radius of the Facility. NOISE The County claims that current industrial noise "will drown operational noise" from the Facility's tractors, chippers, sorters and other large equipment and trucks on the property and waste is `covered' so dust and vector issues are mitigated. The premise that current industrial noise will drown the noise from this Facility is absurd. First, the Facility is located much closer to the DHHL homes and the Hawaiian community than existing industrial activities. Second and most importantly, in addition to the closer proximity of the Facility, the Facility is substantially significant in size, scope and protected activity as compared to current industrial uses. Moreover, uncovered waste and surplus compost material from this Facility will be stacked in 12 foot heaps throughout the site. The Facility will substantially add to the noise and smell to the surrounding region directly and significantly impacting the noise level and air quality for DHHL homeowners. That is a significant impact for DHHL homeowners adjacent to and downwind from the Facility. All references to Facility noise and smell has been minimized by members of the County Council and its impact on the nearby Hawaiian community is not addressed at all. TRAFFIC The Travel Impact Study in the Facility's Environmental Assessment fails to address traffic impacts throughout our community. Two main highly used roads that will serve as main corridor roads to the Facility run through our communities: Railroad Avenue and Puainako Street. Other artery roads that weave into our communities to access Railroad Avenue are also highly used during peak traffic periods and are also largely ignored by the study. If you currently travel to the Kanoelehua/Leilani Street and the Railroad/Leilani Street intersections during peak travel periods, the congestion is already evident. With the addition of this Facility, the EA's Traffic Impact Analysis states that the resultant Higher - Level C and Level D traffic impacts are "acceptable. The Higher -Level C traffic impact results in higher congestion levels and Level D results in longer delays at these intersections. This is a significant impact if those who live and commute in the Pana Iewa community. CUMULATIVE IMPACTS OF SURROUNDING USES / MISUSE OF THE SMA PROCESS There has been a critical fail on the part of the County and County Council in not addressing how this Facility is another nail in the coffin of surrounding industrial uses in our community. See Appendix 3, Pana'ewa DHHL Community Cumulative Surrounding Uses. The incremental placement of industrial and non-agricultural facilities on properties adjacent to our community via the SMA process is a clear violation of state land use laws. AN OFFER TO WORK TOGETHER DISMISED In February 2017, when KPFA President Maile Lu'uwai and Vice President Howard Pea visited Cedar Grove's Composting facility in Everett, Washington, they made an offer to work with Cedar Grove representatives. At a meeting, Ms. Lu'uwai told Cedar Grove representatives that her community was willing to work with and support Cedar Grove's contract with the County of Hawai'i if Cedar Grove would agree to move the location to another site that was not near a residential community. Cedar Grove officials did not respond to this offer during the meeting. The only response Ms. Lu'uwai received was from Hawaiian Earth Recycling Vice President of Operations Mark Cummings who told Ms. Lu'uwai later in the day that "things may not go your way". COMMUNITY MARGINILZAITON The marginalization of our community is not only evident in the land use decisions by the County, it is also inherent in how some Council members have misspoke about our understanding of composting and Environmental Justice. The continued discriminatory decision making in East Hawai'i of locating industrial and waste facilities adjacent and close to DHHL homeowners and DHHL land and the practice of placing the primary burden and cumulative impact of these facilities on Hawaiian homesteaders must stop. As stated previously, the Facility meets the at least five significance criteria set forth in Hawaii Administrative Rules Section 11-200-12. Thus, as EIS is required. More importantly, there are legal ramifications for the continued cumulative misuse of the SMA process to build facilities like the Composting Facility on land not zone for industrial use. Thus stated, the Keaukaha Pana`ewa Farmer's Association (KPFA) and. the Pana`ewa Hawaiian Home Lands Community Association (PHHLCA) are jointly submitting our community opposition Resolution Res. 135-17, as currently written. Maile Lu`uwai President Keaukaha Pana` ewa Farmers Association Bill Brown President Pana` ewa Hawaiian Home Lands Community Association PANA`EWA DHHL COMMUNITY COMPOSTING FACILITY IMPACT ZONE No. of Lots Acres LEGE [1N Agricultural Lots 285 13615 Planning Area Residential Lots 311 114reg " Panaewa (Agricultural) Unencumbered 6 1,027 Panaewa (Residential) (Future Res/Ag Lots) 33152 Wa iakea PANA`EWA DHHL COMMUNITY CUMULATIVE SURROUNDING USES "Item 7- Is the County Mass Transit Base Yard and Maintenance Facility. The 5 -acre Base Yard serves as a parking lot for up to 55 Hele On buses and has a 26,000 square foot Facility with maintenance bays, an automated bus wash, a fueling station and office. Our community was not aware of the Environmental Assessment that was issued in 2015. The facility was completed in 2016. SUMMARY - COMMUNITY ODOR MONITORING pscIeanair.Org Puget Sound Clean Air Agency COMMUNITY ODOR MONITORING PROJECT PUGET SOUND CLEAN AIR AGENCY - UNDERSTANDINGS & RESULTS January 23, 2014 INTRODUCTION/PURPOSE The Puget Sound Clean Air Agency (the Agency) initiated a community odor monitoring project in the Everett/Marysville area to gain more information about odors in those communities with the intention that it may support possible solutions to those challenges. The integrated community odor monitoring program was established with the assistance of Odotech, Inc. (Odotech) as the contracted consultant for the project. This program was intended to provide real time information about the various odors in the community, assist the community with learning more about the odors they experience, and provide information to facilities about their odor emissions so they can respond appropriately to reduce emissions. The project has been completed and Odotech has provided its final Annual Report to document the data collected along with its interpretation of what that data means. In addition to the Odotech report, the Agency is providing this summary of understandings that the Agency has reached through the continuous involvement in managing the project, reviewing the data, and considering Odotech's final report. EXECUTIVE SUMMARY Key understandings (to date) reached by the Agency: • This project was innovative and pushed both the Agency staff and Odotech to stretch to maximize the benefits that could be realized from the technology. • The preliminary audit of odor sources in the study area was complete and identified the relative importance of each source to the odor experience in the community. • The monitoring/modeling system for the project, and as reported by Odotech, indicated that there are three significant odor sources that can contribute impacts in the community —the wastewater treatment plants in Everett and Marysville, and Cedar Grove Composting, • The monitoring showed significant periods of calm wind conditions during the study and those calm conditions are difficult to reliably model for predicting offsite impacts. • The odor observations provided by the community members participating in the study were primarily (although not exclusively) identified as "composting" and "fresh waste". • The continuous odor monitoring and modeling system used for the project can provide a source an indication that they may be creating odor impacts offsite. However, it cannot establish the actual odor concentration at any offsite location at any specific time. • The initial data review suggests that the meteorological conditions in the area may have more influence on the variable impacts in the community rather than variable emissions from any particular source. Page 1 of 7 w January 23, 2014 L WHAT WE LEARNED FROM THE PROJECT A. Monitoring Technology 1. Source a -nose performance is most clearly representative for concentration data The e -nose operations installed to monitor odorous emissions from assigned source operations were direct measurements collected continuously. These a -noses were conditioned and calibrated specifically for the source they were assigned to monitor. Once the calibration was complete, there were no additional adjustments or assumptions applied to these measurements. If the calibration for each device is accurate and e - nose operational conditions are stable and consistent with performance expectations identified by Odotech, then the source odor measurements are the most directly representative and reliable. 2. Accuracy of emission and modeled concentration data is less reliable than concentration data E -nose concentration data collected, along with the meteorological data, were used to estimate the emission rate for the assigned process area(s). These process areas included in the study were primarily area sources, representing ground level sources that cover large surface areas. The estimated emission rate values were combined with meteorological data to predict odor concentrations outside the source property. Both of these estimates (emission rate and offsite concentrations) rely on computational models that are based on a range of assumptions. Layered assumptions in these modeling approaches provide information of less certainty than direct measurements. 3. Meteorological data fills information gaps alone that dispersion modeling does not address well The meteorological data collected at the two different sites to support the project provided new insights into the complexity and interrelation of the local conditions. Even during periods where the dispersion models were not predicting offsite impacts, the meteorology showed recurring patterns that could suggest what was happening without modeled impacts or observations. Subtle differences between simultaneous data collected at the two project meteorological stations indicate that it would be difficult for observations of odors in the community to be confirmed or invalidated by the meteorological data of one station alone. 4. Ambient a -noses can sense ambient odor levels Prior to installing of a -noses in the community as ambient monitors, there were concerns that these a -noses would not sense ambient odor concentrations. The past use of a -noses by Odotech has primarily been to monitor source strength level concentrations. Much of the concentrations predicted by the Odowatch system were less than the expected detection/quantification levels of an a -nose in ambient service. The ambient e - noses installed in a non -calibrated OdoCheck mode of operation did see recordable values. These recorded values varied, sometimes significantly when compared to the average or baseline values (see II.A.2 below for further understandings about ambient e -noses). B. Sources 1. The relative magnitude and potential for odor emissions and impacts were thoroughly evaluated during the audit portion of the project The audit portion of the project completed a comprehensive evaluation of a full range of potential odor sources in the study area. This audit placed the various sources and their relative potential to contribute to odor impacts in the area. The sources that were recommended to have a -nose technology installed for the study represented the most significant sources from this mix. Sources identified in the audit were included in the study modeling, even if they were not considered significant contributors to the community's experience. Page 2 of 7 January 23, 2014 2. Air samples analyzed for odor strength were collected, from a number of the sources surveyed Air samples were collected (and analyzed for odors) from some of the sources included in the preliminary audit. The results of these sampling efforts were included in the deliverable documents for the study. Moreover, these sampling results were also used to refine the emission factors assigned to the sampled sources in the system dispersion modeling. 3. Odowatch systems were installed or operational on most of the significant odor sources in the study area (Marysville WWTP and Granite Construction being the exceptions) E -nose technology was installed at the Everett WWTP, Lake Stevens WWTP, and CEMEX asphalt plant. This was in addition to the a -noses previously installed by Cedar Grove at their site. E -noses were also recommended for the Marysville WWTP and Granite Construction asphalt plant, but the Agency was unable to reach agreements with these two sources to participate in the study. The installed a -noses and recommended a -nose installations represented the most significant and possibly variable sources of odor emissions in the study area. 4. Every source identified in the survey as a potential source of odors was characterized and included in the Odowatch modeling, even if assigned emission rates were used The odor study did not leave a significant odor source out of the study consideration. For sources that chose not to cooperate with the study effort, emission rates were assigned for the dispersion modeling efforts based on previous experience. Other sources for which odor sampling was completed were included in the dispersion modeling profile, too. No identified odor source was left out of the study analysis. 5. Other than the asphalt plant, the monitored source odor concentrations do not exhibit a great deal of variability. When the recorded odor concentrations did change significantly from the average level, these changes tended to be of very short duration Source emissions monitored by a -noses showed a general lack of variability over time. When notable changes in odor concentrations were recorded for specific sources or process areas within a source, these changes were usually of short duration (hours rather than a whole day). These shorter term concentration increases (and related estimated emission rates) were also not found on a consistently recurring basis. The one exception to this would be CEMEX, as the source was not operational on every day during the study period. C. Observations Page 3 of 7 January 2, 2014 4. Observations included various other descriptions In addition to the comments in I.C.3 above, the observation records also identified other odors in the study area (e.g. sewage, biogas, asphalt). These observations, beyond composting and fresh waste were limited. What this indicates is that the trained observers were able to distinguish between odors and would report those odors observed when they filed reports. D. Overall Dispersion modeling appears to under predict actual impacts offsite from sources Odotech indicated that published studies by others indicate that an odor level that represents the "annoyance threshold" is 5 OU/m3 (i.e. for unpleasant odors, the annoyance threshold is 5 times the perception threshold of 1 0U/ m). Comparing that information with the large number of observations characterizing the observed odors as "unpleasant" or "very unpleasant", most of them do not correspond directly to OdoWatch° modeled concentrations that indicate impacts of 5 OU/m3, or greater. The same phenomenon was observed by Agency project staff— clear composting odors were experienced in the study area and a review of the OdoWatch° results following the field visit did not show corresponding levels of impact to match those observations. 2. Meteorological conditions appear to have the greatest influence on impacts experienced rather than source odor emission variability Based on a general lack of source odor concentration variability, which affects the predicted odor emission rates (see 1.B.5 above), the odor impacts (both observed and modeled) follow meteorological trends more closely. The peak odor impacts identified in the study have not been linked to any specific fluctuations of odor emission rates at the source. 3. A significant amount of time during the study was characterized as "calm" winds. These calm periods do not work well with standard dispersion modeling The study revealed a significant amount of time where the meteorological data would be characterized as "calm" and that this type of condition makes it difficult to characterize impacts with a dispersion model during these calm periods. Odotech reported greater than 63% of the Cedar Grove meteorological data and greater than 54% of the Marysville meteorological data would be classified as "calm". Odotech further identified that 94% of the observations recorded during the study period occurred during "calm" meteorological periods. 4. OdoWatch° system can provide sources an indication that they may be creating odor impacts offsite. However, it cannot establish the actual odor concentration at any offsite location at any specific time. The OdoWatch® system provides information about odor emissions and possible migration of those odors offsite. Odotech concluded that many of the odor observations were supported, in some manner, by actual model results or model indications of impacts in that direction. The combined factors identified in I.D.1 and I.D.3 support the conclusion that the dispersion modeling included in the OdoWatch® system cannot establish a reliable odor concentration at a specific offsite location at any specific time. Stated differently, if an odor sample were collected (and sent to an odor, panel for analysis) at the location and time an odor observation were made, it would be difficult to have that result match the dispersion modeling predicted value. 5. OdoWatch® system is unable to provide reliable evidence that an odor event identified by an observer is not being created by -the source being monitored This conclusion is related to the Agency understandings identified in I.D.4 above. Stated differently, the OdoWatch® system is unable to prove the "negative" and does not reliably negate reported observer experiences through the dispersion modeling results for any given period of time. The approach can indicate possible odor impacts but is unable to reliably demonstrate that there was no impact. Page 4 of 7 January 23, 2014 6. OdoWatch® system data provided information and insight on what may be happening in the region relative to odors at times when no observations were made The study did provide a significant amount of information during periods when no observations were reported. No data collected during the study was compared to complaints received by the Agency and only the qualified observer data was reviewed relative to the monitoring systems. Prior to the study, the absence of or a reduced level of complaints received by the Agency was the only indicator of potential impacts and persistence. The OdoWatch® system provided insights to potential impacts within the community even though odor observations were not available. Patterns of meteorological data and source emissions suggest periods of possible impacts. 7. During the study period, general meteorological data suggested calm winds on a north -south axis during late evenings through early morning periods, and that more active winds are on an approximate east -west axis during daylight hours. These general trends regarding the meteorological data are supportive of the overall conclusions regarding the relationship between odor observations and the source emissions. it helps one understand the timing of odor observations and the conditions that can lead to an odor impact. These comments are generalized as the wind rose data shown in the Odotech report for the two stations included in the study show related, but different wind profiles. 8. The odor impacts observed or predicted in the study area have been attributed to three sources 01 10. The Odotech report identified that the largest predicted odor impacts were from the Everett Wastewater Treatment Plant (WWTP), the Marysville WWTP, and Cedar Grove Composting. The dispersion modeling results are consistent with the preliminary audit report, which identified these three sites as potentially important odor sources in the community. However, the observation data collected indicated that composting and fresh waste were the predominately experienced odors. Since the observations did identify other odor types (albeit in limited numbers), it is clear that other odors are present. The primary reasons for the difference between the observed odors and the predicted odor impacts are not clearly understood at this time. Page 5 of 7 t 11. Everett and Marysville WWTP were identified as significant sources of odor in the study area, based on the OdoWatch® dispersion modeling analysis. However, the lack of wastewater related odor observations does not provide as strong a support for that conclusion, in comparison to composting. Odotech identifies these two wastewater treatment plants, along with Cedar Grove, as the three most significant sources of odor in the study area. However, it is unclear why the dispersion modeling analysis for the treatment plants are not more readily supported by the observer reports. Odotech's final report summarizes the number of modeled values greater than 2 OU/m3 and 5 OU/m3 (see Tables 4-8 and 4-9, respectively). There may be a number of combined factors which might explain this significant difference between the modeled results and observations in the community, but it will require more detailed analysis of the data to identify those factors and assess their influence on the results. II. WHAT WE DID NOT LEARN FROM THE PROJECT A. Monitoring Technology 1. We do not have a full understanding of the meteorological effects on odor dispersion and impacts because: o Significant periods of calm wind conditions existed during the study period, which makes reliable dispersion modeling more difficult o Limited resources for the study provided for two sets of meteorological data to be available for the OdoWatch® system operations. Compromising assumptions were necessary to use those data sets for multiple sites The amount of calm wind conditions during the study period was significant and Odotech clearly identified the challenges to the dispersion modeling analysis under those conditions. When these calm conditions exist, the source's odor emissions do not stop and the potential to have accumulated odors which can move in different directions after leaving any source is not readily simulated with the dispersion modeling technology used for the project. Additionally, the limitations of two meteorological monitoring systems to support the dispersion modeling aspect of the study illustrated some of the complexities of the localized conditions. Those two data sets suggested that additional meteorological data may havebeen more helpful to clarify the meteorology throughout the study area. However, even if every a -nose monitored site had its own onsite meteorological data to support the dispersion modeling analysis, the dispersion models would still not have explained the full impacts of calm conditions or the behavior of plumes farther away from the site boundaries. 2. Ambient a -nose recorded concentration events do not necessary relate closely to other data collected. Odotech reached this conclusion and we agree with it. What we did not learn is what capability the ambient e - noses may have had if they were calibrated to any of the emissions from the significant odor sources included in the study. We understand that the ambient a -nose installation was not Odotech's original recommendation. However, installing them in an OdoCheck survey mode reduced the chances of improving this source/event relationship. The installation was experimental, but it is unclear if any further work in this area of inquiry could proceed without the concurrence and interest by Odotech. B. Sources 1. We were.unable to collect site specific samples or collect continuous a -nose data for the Marysville WWTP and Granite Construction. Thus, the actual emission levels and variability of the odor emission rates from those sites could not be evaluated This is unfortunate, especially for the Marysville WWTP. With the conclusion that it is one of the three significant odor sources in the study area, the lack of sampling data or a -nose data for the site prevents further Page 6 of 7 analysis to discern further understanding of the differences between the dispersion modeling results and the observer records. Of the three facilities identified to have the potential for regional odor impact, the lack of facility specific sampling at Marysville WWTP makes the data related to this facility the least certain of the three sites. 2. We were unable to collect a full year of a -nose data, since the OdoWatch® system was activated in March 2013 and operated through November 2013 The Odotech report indicated that a full year of monitoring data was collected during a study that started in September 2012 and ended in November 2013. It is important to clarify that the odor committee started their efforts in the fall of 2012, but the a -noses and OdoWatch° systems were not completely installed and operational until March 2013. There were challenges during the initial phase of the study to obtain agreements with the various participants and to get the systems installed and operationally functional. The study was completed in November because the Agency decided that the a -nose monitoring and OdoWatch® analyses had covered the most important periods of time relative to odors in the study area (spring, summer, fall). 3. Periods of notably different or increased odor emission conditions at the sources did not lead to any assessments of the operational reasons for the change The study did not collect much in the way of operational information which would identify changes in operations associated with emission increases. This note is balanced with the general impression that emission changes/increases are not readily correlated with the changes in modeled impacts offsite (see I.B.5 above). We also do not have information regarding how (or if) the participating OdoWatch° monitored sources accessed or used the data for their site. They did have access to that information during the study period. C. Observations 1. We did not have the number of observers or geographic distribution for them that we had originally hoped to include We greatly value the efforts and contributions by the volunteer odor observer committee members. There are a few areas which may have benefited with some additional observer presence, especially since a comparison of the modeling results to the observer data has proved useful to the study. It is understood that circumstances external to the study may have affected the interest or willingness to participate in the study. 2. No conclusions can be drawn from any specific time regarding the absence of an observation No speculation is possible regarding any period of time when observations were not available. The observer committee members were volunteers and the information they provided to the study was valuable. However, the absence of an observation at any point in time is cannot be assigned any significance. III. WHAT COULD STILL BE LEARNED THROUGH FURTHER WORK There is a large amount of data collected during the project and the Agency continues to review the details to identify further discerning facts from that volume of data. However, the one area of inquiry that would probably help us the most to understand odor impacts in the community beyond the study results presented would be an analysis of the calm wind conditions. Evaluating additional dispersion modeling techniques may provide a better characterization of the calm wind odor plume behavior and if technically appropriate, apply that selected alternative dispersion model to a selected period of the study data. Since the calm wind conditions were a significant portion of the study period (greater than 54% of the total monitored time) and the standard dispersion model has difficulty characterizing plume profiles in these calm conditions, a better understanding of what may be happening during such a significant period of time would be appropriate. Page 7 of 7