Report on Fugitive Dust: Detroit Districts 1 and 2

Dust Detroit Districts 1 and 2

Ellison Hersch

Maya Baker

Maria Garcia Reyna

Marco Dominguez

Vishnupriya Napa Ravikumar

Executive Summary

Introduction & Background

This report uses a two-pronged approach including aerial interpretation as well as in person analysis to address fugitive dust emissions and spread in Detroit City Council Districts 1 and 2. Fugitive dust are fine dust particles that are released into the air in a variety of ways and are a major contributor to air pollution. Some of the common sources for fugitive dust stem from unpaved lots with no vegetation, as well as through industrial activities. In this report we address the City of Detroit’s options for fugitive dust mitigation by identifying fugitive dust sites that pose a threat to the environment and are potentially hazardous to the health and wellness of the people of Detroit and recommending possible policy solutions. This report specifically addressed Detroit City Council Districts 1 and 2. These districts are predominantly residential areas that have industrial business corridors around their borders. There are many vacant lots throughout both districts and are often but not always covered in vegetation. We focused primarily on unpaved lots with no vegetation or lots in industrial zones where there are many scrap yards, manufacturing facilities, and recycling plants.

Site Prioritization

Using Google Maps aerial imagery and the Detroit parcel viewer, our team created a list of sites and prioritized them. We initially came up with approximately 150 potential sources for fugitive dust that were compiled into a list. We then visited these potential fugitive dust sites to determine if our aerial interpretation of the site is a source of fugitive dust should they be considered areas of interest. We prioritized the sites by proximity to at-risk populations, children and the elderly; proximity to elementary schools; and acreage, putting more weight on larger sites. The finalized site list included 87 potential sites in 6 clusters, three in each of the two districts.

Case Studies

In order to understand some of the options that the City of Detroit has to mitigate fugitive dust we analyzed and created various case studies for different cities and counties all over the United States. These include Fugitive Dust Prevention in Clark County, Nevada, Local City Ordinances in Cleveland, Ohio, Dust Pollution Ordinances in Dearborn, Michigan, and County Fugitive Dust in Allegheny County, Pennsylvania. We also included a report on the solutions to dust emissions from unpaved surfaces as one of the case studies. We created case studies that offer different perspectives into potential solutions the City of Detroit can either adopt or integrate into their fugitive dust mitigation plans.

Analysis

We initially believed that the sources of fugitive dust would manifest in isolated sites. Ultimately, we found that the majority of the fugitive dust sources were grouped into clusters and were predominantly made up of small sites that when looked at as a group can be the biggest contributors to fugitive dust. Site recommendations have been narrowed down into 4 areas which include the most hazardous fugitive dust sites in Districts 1 and 2 and should be

Executive Summary

prioritized for fugitive dust mitigation. The 4 clusters are the Dale and Fenkell sites, Schoolcraft and Burt sites, M-10 and Livernois sites as well as the 8-mile and Woodward site clusters.

Recommendations

Detroit has numerous options when it comes to dust mitigation policies that could be valuable, the issues arise when thinking about how to tackle the different sources because they can’t all be approached the same way. Recommendations for the City of Detroit include site and policy recommendations. Policy recommendations include the implementation of ground level regulations that would help deter fugitive dust production from both businesses as well as vacant lots. These include the implementation of fines and permits as well as a more aggressive enforcement system.

Implementation

Ultimately, the City of Detroit needs to engage more with all community members including individual property owners, industrial businesses owners, and the general public. This is important because educating these diverse groups on the health effects associated with fugitive dust and the harm that it can have on the environment could mean the difference between a resident doing their part or not. In addition to this, creating the ability to have discussions on the appropriate strategies that could be implemented between all residents and the City of Detroit is important. Using hotlines, online complaint sheets, having and education campaigns, and regularly holding public meetings are all good options that have been effective in other cities in the mitigation of fugitive dust.

Fugitive Dust: A Planning Problem

Fugitive Dust Defined

Fugitive dust, also known as particulate matter, can cause detrimental effects on the health of residents, harm surrounding neighborhoods, and impact the environment. Particulate matter is composed of “solid particles and liquid droplets of various size, shape, and chemical composition that can be suspended in the lower atmosphere for days or even weeks.”1 Fugitive dust is a type of particulate matter and has been found to come from sources such as storage piles, fields, and roadways.2

Sources of Fugitive Dust

There are various sources of particulate matter to consider in Detroit. The main ones tend to be vacant locations such as abandoned industrial sites, dirt roads, brownfield sites, and fires. Particulate matter can also come from active industrial sites and cars. In Detroit, the primary sources of fugitive dust are industrial sites. The majority of the particulates themselves form from a chemical reaction between pollutants in the atmosphere and other common air pollutants including lead, carbon monoxide, sulfur dioxide, and nitrogen dioxide.3

Health Impacts

Whether on their own or combined, these pollutants can lead to serious health impacts. The most common health impacts from fugitive dust are lung and heart related. According to the EPA, “the size of particles is directly linked to their potential for causing health problems. Small particles less than 10 micrometers in diameter pose the greatest problems, because they can get deep into your lungs, and some may even get into your bloodstream.”4 The EPA’s list of health impacts include respiratory symptoms such as coughing, difficulty breathing, irritation of the airways, a decrease in lung function, aggravated asthma, irregular heartbeat, nonfatal heart attack, and premature death in people with lung or heart disease. These symptoms vary in severity and can be life threatening to young people who are developing their lung capacity. People with heart or lung conditions are typically at a higher risk of experiencing these negative effects.

Environmental Implications

Fugitive dust also has environmental implications. Acid rain is a common, damaging side effect of air pollution in general and fugitive dust in particular. Fugitive dust can also increase the acidity of lakes and streams and shift the makeup of nutrients in coasts and rivers. It also reduces nutrients in soil and thus decreases soil fertility, harming forests, agriculture, and ecosystem diversity.

Detroit: District 1 and 2 Demographics

As a city that has fluctuated greatly in terms of population and land use, Detroit and its surrounding municipalities are particularly vulnerable to the detrimental effects of fugitive dust. Here, we will focus specifically on the first two of seven council districts in Detroit. In District 2, the population is concentrated on the east side of the district. The table below helps us better understand the demographics of the area and the number of the vulnerable populations living in the area being affected by fugitive dust.

Figure 1: Map of Detroit City Council Districts

District 1**** District 2****

* U.S. Census Bureau. (2019). DP05 Demographic and Housing Estimates.

**U.S. Census Bureau. (2019). S1901 Income in the past 12 months 02019 inflation-adjusted dollars.

***U.S. Census Bureau. (2020). S1701 Poverty Status in the Past 12 Months

****“Census 2020 and Detroit City Council Districts.” Data Driven Detroit, 2018.

https://datadrivendetroit.org/blog/2021/12/16/census-2020-detroit-city-council-districts/ Figure

With Detroit being a majority minority city, the above table demonstrates that African Americans make up 94.1% and 99% of Districts 1 and 2. This is significantly greater than the overall black population in Detroit which is 77.9%. The percentage of white and Hispanic populations are noticeably smaller in these districts as well.

Residents such as the very young and elderly tend to be more impacted by poor air quality. From the table above, we know that more than 38% of each district is at a greater risk of being impacted by fugitive dust based on age alone. It is also important to consider lung and heart disease. Asthma is one of these. When compared to the U.S.’s largest 18 cities, Detroit has one of the highest rates of asthma in young children who are eleven years old and younger.5 Overall, however, the asthma rates of children in Detroit who are ages 17 and younger are the third largest in the country behind Phoenix and Philadelphia.6 In addition to this, the rate of asthma in Detroit is 12.4% compared to the state of Michigan’s childhood asthma rate of 8.4%.7 The rate of asthma deaths here are twice as high as well.8 The rates of asthma coupled with the high incidence of industrial sites in Detroit point to a very serious health issue.

Brief History of Detroit and Industry

The late 1800s were also important to Detroit as it became more prominent in businesses such as shipbuilding, pharmaceuticals, and railways. Access to resources, including water, iron ore, and coal, also played a significant role. Even Detroit’s population saw massive shifts as it grew from 80,000 in 1870 to 1.5 million in 1930. As of 2019, that number sits at 670,052.9 Detroit,

at its peak, was the fourth largest city in the United States. However, this did not last long as Detroit saw population, industry, and wealth start to decline halfway through the 20th century.10 Changes in competition in various industries, political tensions, and white flight were strong factors in this decline.

In the early 1900s, Detroit was a thriving industrial hub in the United States that financially benefited most people living in the city. A large part of this came from industries utilizing mass production, including the automobile industry. At one point, there were over 120 motor factories in the city alone, in the early 1900s, which only made up a portion of the industries in Detroit.11

Zoning and Development in Districts 1 and 2

The dominant land use of Districts 1 and 2 is residential with some businesses and a significant industrial area. Prior to 1920, there was not much development in the areas that are now Districts 1 and 2. The developments that existed in the more prominent areas of the city at the time had already begun to show patterns of single-family residences that followed the layout of the industrial sites.12 The 1920s and 1930s is where a dramatic increase in development is noticeable. Most of these developments in Districts

When it comes to zoning ordinances, the first one wasn’t passed in Detroit until 1940. Meaning this was passed well into an already-developed city.13 Much of this development was focused on industrial and residential. It was then the 40s and 50s that saw a boom in these two districts as suburbs sprang up at the edges of the city. This soon slowed down drastically. With the decline of Detroit, there was little new development in the 60s and 70s. In addition to this, the 80s and 90s continued to see limited development with the majority being commercial additions.

Currently, commercial corridors can be found wrapped around many residential neighborhoods in these Districts. According to Zone Detroit, “54% of commercially zoned parcels are unbuilt – either vacant or used for parking” and “Auto services buildings (gas stations, dealerships, repair shops, and car washes) are on 8% of commercial parcels”.14 This is important to take into account as they may be sources of fugitive dust in these areas.

Considering the zoning configuration in Districts 1 and 2, the health implications of fugitive dust, and potential source sites, we compiled a set of goals to guide our analysis.

Vision, Goals, Objectives

We envision a Detroit where all residents can enjoy time outside with clean air to breathe.

Goals

This vision can come to fruition with goals to guide the process. These goals demonstrate Detroit’s willingness to address the problem.

» Ensure clean air for all by mitigating fugitive dust.

» Identify sources of fugitive dust in Detroit.

» Create a community-engaged response that distributes information to the public and integrates their feedback to decrease fugitive dust pollution.

» Implement fair regulations that reduce fugitive dust and that can be enforced.

Objectives

These specific, measurable objectives will ensure that Detroit satisfies these goals.

» Provide the City with a list of sites and areas that currently produce fugitive dust in Districts 1 and 2.

» Categorize the most common, unregulated sources of fugitive dust.

» Strategically prioritize mitigation in sites that are closest to vulnerable communities and open recreational spaces.

» Expand the City’s capacity to address fugitive dust with regulations, mitigation efforts (suppressants), and community programs.

» Propose public engagement tools and education materials to spread awareness about health issues related to fugitive dust.

» Suggest how community engagement can assist in the identification and remediation of fugitive dust sites.

Case Studies

To support the City of Detroit, our team has come up with five case studies, looking at fugitive dust programs across the country and mitigation mechanisms. The first four case studies are location specific, specifically looking at Clark County, Nevada; Allegheny County, Pennsylvania; Cleveland, Ohio; and Dearborn, Michigan. These case studies include demographics and information on the area, as well as specific information on their fugitive dust programs and regulations. We then synthesized regulations and compiled lessons learned. Clark County was chosen due to their strict regulations and control of fugitive dust. Allegheny County has a similar type of regulation as Clark County and was chosen because of the recent news reports surrounding Pittsburgh’s fugitive dust problem. Cleveland was chosen because it uses a different regulation type and has a similar history and demographic makeup to Detroit. Dearborn was chosen due to the proximity to Detroit and the news about their recent fugitive dust ordinance. The last case study in this group focuses on mitigation mechanisms. This case study compares and contrasts various dust suppressants, or palliative remedies to fugitive dust. These case studies bring together information that has helped form our recommendations.

1: Clark County, Nevada

This case study reviews Clark County, Nevada’s decades-long journey to curb fugitive dust to aid in recommendations for what will work for the City of Detroit, Michigan. After getting dangerously close to losing federal funding due to elevated dust levels, Clark County started a successful advocacy campaign and introduced strict regulations to limit particulate matter output. Although the desert environment is different from the temperate landscape of Detroit, there are important lessons to be learned on how to change behavior, measure impact, and enforce strict regulations from the Las Vegas area.

Overview and Demographics

Clark County is home to the state’s most populous and famous city, Las Vegas. The county is in a valley surrounded by four mountain ranges and is mostly made up of the Mojave Desert ecosystem. There are multiple national protected parks and wilderness areas. Clark County covers 7% of the state’s land, it holds 74% of the state’s population (see Figure 4).1 The county population was 2,265,461, according to the 2020 census.² Many people may think of the indoor activities Las Vegas has to offer, such as casinos and shows, but the area is also known for outdoor activities like ATV-riding and motor-biking. The largest industries in Clark County are Accommodation and Food Service, Retail Trade, and Arts, Entertainment, & Recreation.³ The tourism industry requires a large population of permanent residents who live in the area all year round.

Las Vegas is growing rapidly, leading to more sprawl or low density development. The addition of sprawl increases the amount of construction, which can increase fugitive dust. However, this new sprawl and construction also allow for the paving of dirt roads, removing one source of fugitive dust. Through regulations, enforcement, and education, Clark County has been able to curb its fugitive dust problem to be below the Environmental Protection Agency’s (EPA) standards.

History of the Program

In 1993, the Environmental Protection Agency (EPA) designated Las Vegas and the surrounding Clark County as a serious nonattainment area for PM-10 (inhalable materials with a diameter of 10 micrometers or smaller).⁴ This designation costs the state millions of dollars in lost federal highway funds and could have lead to a federal takeover of local clean-air programs. To prevent this loss, Clark County officials worked to reduce dust levels through permit and inspection programs, regulations, a public education campaign, and a dust-complaint hotline. Twenty-one years later, Clark County received a clear-air designation from the EPA.⁵

The desert environment and expansive low density development in Clark County created a fugitive dust problem from the large areas of unpaved roads. Along with cars and large trucks, outdoor tourist activities like four-wheeling and motor-bike activities break up the top layer of desert crust and release silt and particulate matter into the air. One of the first actions Clark

Figure 4: Map of Clark County

1: Clark County, Nevada

County took in the early 2000s to address its air quality problem was paving the most popular dirt roads (any road that logged 150 vehicle trips per day or more).⁶ Construction was causing the other major fugitive dust problem, accounting for 37% of the particulate matter in the area (see Figure 5).⁷ Clark County then required construction site employees to take dust control classes. These classes were followed up with compliance inspections at construction sites, as well as at vacant lots. Stringent regulations were codified.

The introduction of regulations in 2001 focused on contractors and developers. In 2003, the regulations were broadened to regulate commercial landowners of one or more acres. The regulations have also been adapted to provide clarity and to include new federal definitions and requirements. These regulations are specifically designed to regulate fugitive dust from open areas and vacant lots (Section 90); unpaved roads, unpaved alleys, and unpaved easement roads (Section 91); unpaved parking lots and storage areas (Section 92); paved roads and street sweeping equipment (Section 93); and construction activities (Section 94).⁸ These regulations have addressed many of the problems facing the county and were aided by the public advocacy campaign that accompanied the process.

In 2003, Clark County started a multi-media advertising campaign starring a character named Dusty the Dusthole. The campaign included television, radio, billboards, and newspaper advertising. In the television advertisements, Dusty was seen driving his large pickup truck around traffic on unpaved shoulders and through vacant unpaved lots kicking up dust and creating clouds behind him.⁹ These advertisements not only shamed these behaviors, but discussed why the dust and particulate matter could be detrimental to people’s health and specifically the health of vulnerable populations (elderly and children). The ad concluded with “The dust we raise is the dust we breathe.”10 Dusty the Dusthole became a household name and meme in the early 2000s. His face could be seen on billboards, as seen in Figure 6, and the

Figure 5: Fugitive Dust Sources by Percentage Source: Las Vegas Review Journal

1: Clark County, Nevada

actor made public appearances in character to spread awareness. This campaign assisted in the imposition of stricter regulations and gave the public more context for why the county was addressing the problem.

Synopsis of Regulations

The regulations address unpaved streets, vacant lots, parking lots, and storage areas (including auto and salvage), as well as paved streets and construction activities. There are separate sections with various control measures, stabilization standards, and test methods depending on the type of surface. Most of the control measures include paving the area or applying and maintaining gravel or other dust suppressants. The standards attempt to manage the opacity of the dust and reduce the amount of silt that is released into the air. Depending on the type of area, there will be different levels of regulation. These different areas also require different tests to measure if the standards are being met and if the control measures are working. These tests attempt to measure how much dust will come up when a steel ball is dropped, how much of an area is covered with non-erodible elements, the threshold friction velocity of the soil, the percent opacity of the fugitive dust, or the silt content.11 The table below shows a summary of Clark County’s fugitive dust regulations.

Section of Code: Applicability Area Control Measures

Section 90: Fugitive Dust from Open Areas and Vacant Lots12

Open areas and vacant lots larger than 5,000 square feet and distrubed–by motor vehicles or material dumping

• Prevent motor vehicle trespassing

• Apply and maintain surface gravel or dust palliatives

• Apply other approved control mechanism

Stabilization Standards

• Visible crust must be established

• Ground must have a percent cover of 20% or greater for non-erodible elements

Test Methods

• Soil Crust Determination (Drop Ball Test)

• Rock Test Method

• Determination of Threshold Friction Velocity (TFV)

Figure 6: Dusty the Dusthole Billboard

1: Clark County, Nevada

Section 91: Fugitive Dust from Unpaved Roads, Unpaved Alleys, and Unpaved Easement Roads13

Section 92: Fugitive Dust from Unpaved Parking Lots and Storage Areas14

Unpaved roads, unpaved alleys, and unpaved easement roads–does not apply to non-commercial and non-institutional private driveways, horse trails, hiking paths, bicycle paths, or similar non-vehicular paths

• Pave

• Apply dust palliatives

• Apply and maintain an alternative control measure

• Effectively implemented when stabilization observations do not exceed 20% opacity and do not equal or exceed 0.33 oz/ft^2 silt loading, or do not exceed 6% silt content

Unpaved parking lots and storage areas: automobile impound yards, wrecking yards, automobile dismantling yards, salvage yards, material handling yards, equestrian staging facilities, and storage yards

• Prohibit new unpaved parking lots or storage areas after Jan 1, 2003 (some exemptions)

• Pave

• Apply dust palliatives

• Apply dust palliatives to vehicle travel lanes within

• Apply and maintain an alternative control measure

Section 93: Fugitive Dust from Paved Roads and Street Sweeping Equipment15

Paved roads and paved alleys–does not apply to non-commercial and non-institutional private driveways

• New construction of paved roads must have 4 feet of shoulder on each side, paved or stabilized with a dust palliative or gravel

• If the road has more than 3,000 vehicles per day after March 1, 2003, then it needs 8 feet of stabilized shoulder

• There must also be street cleaning equipment requirements and restrictions

Section 94: Permitting and Dust Control for Construction Activities16

All construction activities that disturb or have the potential to disturb soils that emit particulate matter: land clearing, maintenance, and land cleanup using machinery; soil and rock excavation or removal, hauling, crushing or screening; filling, compacting, stockpiling and grading; explosive blasting; demolition; implosion; abrasive blasting; concrete, stone, and tile cutting; mechanized trenching; operation of motorized machinery; staging areas

• Prior to engaging in any construction activities, property owner must obtain a dust control permit, including a dust mitigation plan

• Non compliance will result in a Corrective Action Order

• Any project with 50 or more acres must have a Dust Control Monitor (requires classes)

• Superintendents, project developers, and supervisors must take Dust Control Classes

• Effectively implemented when stabilization observations do not exceed 20% opacity and do not equal or exceed 0.33 oz/ft^2 silt loading, or do not exceed 8% silt content

• No dust plume can cross a property line

• Opacity Test Method

• Silt Content Test Method

• Opacity Test Method

• Silt Content Test Method

• Effectively implemented when stabilization observations do not exceed 20% opacity and do not equal or exceed 0.33 oz/ ft^2 silt loading (except for gravel), or do not exceed 6% silt content

• Opacity Test Method

• Silt Loading Test Method

• Gravel Depth and Silt Content Test Method

• Soil must be maintained at a sufficiently damp condition to prevent loose grains from becoming dislodged

• Soil shall be crusted over with water

• Soil shall be covered with clean gravel or treated with suppressant

• Stockpiles cannot be over 8 feet

• Construction sites must employ Best Available Control Measures (BACM)

• There shall be different standards for wind condition emissions

• Visual determination of opacity of emission from sources of visible emissions

• Time average method

• Intermittent emissions method

• Instantaneous method

• Soil Crust Determination (Drop Ball Test)

Figure 7: Table of Clark County Fugitive Dust Regulations

1: Clark County, Nevada

Lessons Learned

Clark County has some of the strictest fugitive dust regulations in the country. Clark County’s starting point to address the issue was much more dire than Detroit’s because of the desert atmosphere and abundance of unpaved roads. However, there are still lessons to be learned from Clark County.

• Address unpaved areas. While Detroit has fewer unpaved roads, the City could address the unpaved vacant lots, auto and salvage yards, unpaved shoulders, and construction issues. The City of Detroit could prioritize paving city-owned sites and incentivizing property owners to pave their own lots. In industrial areas, these unpaved areas are driven over by large, heavy vehicles that disturb and release more fugitive dust into the air. While paving is the best mechanism to reduce fugitive dust levels, the city could also use suppressants and dust palliatives to unpaved areas.

• Adopt strict regulations. The various control measures, stabilization standards, and test methods listed in Clark County’s code can be used as a guide to form Detroit’s new fugitive dust ordinance. These strict regulations provide multiple standards that could be introduced in Detroit, depending on how stringent the city hopes to make future regulations. The Clark County regulations include multiple tests that could be introduced, even if the stabilization standards are lowered to fit Detroit’s environment. The construction code could also be adjusted in Detroit to assist with curbing dust from demolitions and new development.

• Educate the public. Detroit may also decide that it could benefit from a public education and awareness campaign explaining the health hazards of fugitive dust. The City may find this to be helpful for all residents or to a targeted group, like construction workers or owners of salvage yards. This campaign could also be accompanied by classes on fugitive dust control, offered by the City. Another way to engage residents is to introduce a hotline for people to report fugitive dust problems. This could be a part of the public education campaign to ensure that residents know what to look for. Education on the issues connected to fugitive dust help residents understand the importance of introducing new, stricter laws. While the landscapes may look different, Detroit still has much to learn from Clark County.

1: Clark County, Nevada

Endnotes

1. Jeff Waddoups, “Clark County Profile,” Las Vegas Metropolitan Area community Indicators, (UNV, Las Vegas), https://cber.unlv.edu/publications/Demographics.pdf.

2. “U.S. Census Bureau Quickfacts: Clark County, Nevada.” Accessed March 23, 2022. https://www.census.gov/ quickfacts/fact/table/clarkcountynevada/PST045221.

3. “Clark County, NV.” Data USA. Accessed March 22, 2022. https://datausa.io/profile/geo/clark-countynv/#economy.

4. Catherine MacDougall, Gregory DeSart, Robert Thomsen, Alan Chamberlain, and Troy Hildreth. “Evaluating Soil by Particulate Emission Potential.” Accessed March 23, 2022. https://gaftp.epa.gov/air/nei/ei_ conference/EI10/fugdust/macdougall.pdf.

5. “Vegas Area Poised to Get EPA Clean-Air Designation this Month.” Sunday Gazette - Mail, Oct 05, 2014. https://proxy.lib.umich.edu/login?url=https://www.proquest.com/newspapers/vegas-area-poised-get-epaclean-air-designation/docview/1588781495/se-2?accountid=14667.

6. Keith Rogers. “$150,000 AD Blitz Tries to Settle Dust: Campaign Enlists Public in Cutting Pollution.” Las Vegas Review Journal, May 12, 2004. https://web.archive.org/web/20120324101913/http://www. reviewjournal.com/lvrj_home/2004/May-12-Wed-2004/news/23861369.html.

7. Ibid.

8. Clark County, NV. Accessed March 23, 2022. https://www.clarkcountynv.gov/government/departments/ environment_and_sustainability/compliance/current_rules_and_regulations.php.

9. “‘Dusty the Dusthole’ Ads Begin.” Las Vegas Sun, September 25, 2003.https://lasvegassun.com/news/2003/ sep/25/dusty-the-dusthole-ads-begin/.

10. Ibid.

11. Clark County, NV. Accessed March 23, 2022. https://www.clarkcountynv.gov/government/departments/ environment_and_sustainability/compliance/current_rules_and_regulations.php.

12. “Section 90: Fugitive Dust from Open Areas and Vacant Lots .” Clark County Current Rules and Regulations. Accessed March 23, 2022. https://files.clarkcountynv.gov/clarknv/Environmental%20Sustainability/ Current%20Rules%20and%20Regulations/SECT90%2001-21-20.pdf?t=1598389097547&t=1598389097547.

13. “Section 91: Fugitive Dust from Unpaved Roads, Unpaved Alleys, and Unpaved Easement Roads.” Clark County Current Rules and Regulations. Accessed March 23, 2022. https://files.clarkcountynv.gov/ clarknv/Environmental%20Sustainability/Current%20Rules%20and%20Regulations/SECT91_04-15-14. pdf?t=1647554878807&t=1647554878807

14. “Section 92: Fugitive Dust from Unpaved Parking Lots and Storage Areas.” Clark County Current Rules and Regulations. Accessed March 23, 2022. https://files.clarkcountynv.gov/clarknv/ Environmental%20Sustainability/Current%20Rules%20and%20Regulations/SECT92_04_15_14. pdf?t=1647554878807&t=1647554878807

15. “Section 93: Fugitive Dust from Paved Roads and Street Sweeping Equipment.” Clark County Current Rules and Regulations. Accessed March 23, 2022. https://files.clarkcountynv.gov/clarknv/ Environmental%20Sustainability/Current%20Rules%20and%20Regulations/SECT93%2001-21-20. pdf?t=1647554878807&t=1647554878807

16. “Section 94: Permitting and Dust Control for Construction Activities.” Clark County Current Rules and Regulations. Accessed March 23, 2022. https://files.clarkcountynv.gov/clarknv/ Environmental%20Sustainability/Current%20Rules%20and%20Regulations/SECT94%2001-21-20. pdf?t=1647554878807&t=1647554878807

2: Allegheny County, Pennsylvania Overview

In 1999, the EPA amended the National Ambient Air Quality Standards. Since this time, Allegheny County never met these standards, until 2020.¹ This improvement has been attributed to the Allegheny County Health Department, among other groups, for its changes around research, violations, civil penalties, and programs. However, these improvements are just the beginning. In 2020, the same year these standards were finally met, the American Lung Association published the 2020 State of the Air Report stating that “Pittsburgh-New Castle-Weirton metro area ranked as the 8th most polluted for year-round average levels of fine particle pollution”.² This made it clear that accomplishing their goals in terms of quality air is still a work in progress, and there is still much to be done.

Demographics

Allegheny County has a population of 1,218,380 people. Table 1 below shows the demographics broken down by age groups likely to be most affected by fugitive dust as well as ethnic and racial background. It is important to note going down the table, except for the Hispanic or Latino percentage, every other category included appears to be very similar to one another. Both Allegheny and Pennsylvania are pretty close in demographic distribution to one another.

Demographics Table

Table Sources:

* U.S. Census Bureau. (2020 ACS 5-Year Estimates Data Profiles). DP05 Demographic and Housing Estimates.

**U.S. Census Bureau. (2020 ACS 5-Year Estimates Data Profiles). S1901 Income in the past 12 months (in 2020 inflation-adjusted dollars).

*** U.S. Census Bureau. (2019). DP05 Demographic and Housing Estimates.

**** U.S. Census Bureau. (2019). S1901 Income in the past 12 months 02019 inflation-adjusted dollars.

Figure 8: Demographics Table of Allegheny County Comparison

2: Allegheny County, Pennsylvania History of Allegheny

As mentioned previously, Allegheny County has struggled more than most in terms of fugitive dust and general air? pollution. Having been a major industrial power in the United States and an early industrially-focused city a leading power in the industrial revolution, it has since taken longer to meet EPA’s standards. Pittsburgh, in particular, became the center of the steel industry and although it was great in terms of growing the region and providing a livelihood for thousands, it left behind many challenges in air quality.

Synopsis of Regulations

From the 1999 amendment, when the air quality standards were set to now have involved iterations of rules and regulations in the county the Allegheny County Health Department. Many of these can be found in the “County of Allegheny, Pennsylvania, Ordinance No. 16782, and Allegheny County Health Department Rules and Regulations, Article XXI Air Pollution Control.”

In Part H Reporting, Testing, and Monitoring, there is a section that goes into further detail on how this takes fugitive dust into account. They mention methods such as “ambient test procedures approved by the Department which are in accordance with, or equivalent to, the test procedures set forth in Part G of this Article”.⁵ Here, ambient tests are important because they are one method of testing the concentration of particulate matter in the environment that people are breathing in. This data can be used to ensure that the levels of particulate matter are at a safe level. In addition to this they are a way to create tangible goals and measurements that the county hopes to reach in order to lessen the impact on its population.

Part I §2109.08 goes into detail on the Allegheny County Air Pollution Control Fund & Air Quality Fund.⁶ This particular section has two subsections, revised and amended in 2009 and 2021. Subsection c explains that funds can only go to “develop and administer the County’s air pollution control program other than those portions of the program required by Title V of the Clean Air Act” and it prohibits funds from going to air pollution sources. This further encourages the reduction of pollution and introduces incentives. Subsection e establishes the “Allegheny County Air Quality Fund” in order to develop and administer the County’s air pollution control program required by Title V of the Clean Air Act.⁷

Another section of Part I, §2109.09, describes the Allegheny County Clean Air Fund.⁸ This section is also one that has been amended recently. It explains what the funds should specifically be used for and two in particular that stand out are “health effects studies and surveys concerning air pollution” and “public education concerning air pollution.”

Overall, Allegheny has allocated funds for a wide variety of tools and resources that will help improve the air quality and it has created stricter regulations, violations, and penalties within these rules and regulations.

2: Allegheny County, Pennsylvania Challenges and Solutions

Violations

Challenge: One problem that came up with the Allegheny County Health Department and the EPA was that the U.S. Steel’s Edgar Thomson Works in Braddock had a series of violations and illegal visible emissions.⁹ The steel plant was found to have numerous violations over the course of a year and a half, and in August 2020 local organizations brought a petition to the Health Department demanding information on the plant and what was being done.10

Solution: The EPA and Allegheny County Health Department imposed Notice of Violation on the steel plant and more information was shared with the county’s residents.

Health Department Programs

Challenge: The Allegheny County Health Department has seen some of the worst air quality and particulate matter concentrations in the United States.

Solution: The Allegheny County Health Department has been working to create programs that improve the air quality. They have been working towards increasing regulations for coke oven emissions. They have also acquired a “$5.7 million Targeted Airshed Grant to purchase seven electric buses for the Port Authority of Allegheny County”.11 These buses are intended to begin running by the end of 2022 as a way to reduce fossil fuel emissions while also benefiting the public transportation of the region.12 EPA grants have been particularly helpful role in increasing the funds and resources available to Allegheny County.

Another helpful project working with the community is the Breathe Project. This project brings many different organizations together toward improving air quality together by providing data and tools ranging from maps of Nitrogen Dioxide to breathe meters, cameras, and fracking activities.13 If Detroit was to implement something similar to this and tailor it to their needs, this could be used as an educational and research tool to see which areas have the highest concentration of fugitive dust.

Figure 9: Breather Project PM Concentration Map

2: Allegheny County, Pennsylvania

Lessons Learned

One of the greatest takeaways from this case study is that it is possible to work towards and eventually achieve a level of air quality that is safe for even our more vulnerable populations. It is a matter of hard work, patience, and time. Allegheny County has seen some of the worst levels of air quality in the United States, including particulate matter. Yet, they have to begin to achieve a series of goals that will lead to better health outcomes for its residents.

While there is much work to be done, they have shown that changes in civil penalties, violations, and increased programs and education can create the improvement in air quality they are seeking. They are potential solutions that Detroit can take into account to better the air quality that is resulting from particulate matter.

Endnotes

1. Machosky, Michael, et al. “For the First Time, Allegheny County Meets Federal Air Quality Standards at All Eight Air Monitors.” NEXTpittsburgh. January 28, 2021.

2. Ibid.

3. U.S. Census Bureau. (2020 ACS 5-Year Estimates Data Profiles). DP05 Demographic and Housing Estimates.

4. U.S. Census Bureau. (2020 ACS 5-Year Estimates Data Profiles). DP05 Demographic and Housing Estimates.

5. County of Allegheny, Pennsylvania, Ordinance No. 16782, and Allegheny County Health Department Rules and Regulations, Article XXI Air Pollution Control. September 15, 2021.

6. County of Allegheny, Pennsylvania, Ordinance No. 16782, and Allegheny County Health Department Rules and Regulations, Article XXI Air Pollution Control. Part I §2109.08

7. County of Allegheny, Pennsylvania, Ordinance No. 16782, and Allegheny County Health Department Rules and Regulations, Article XXI Air Pollution Control. Part I §2109.08

8. County of Allegheny, Pennsylvania, Ordinance No. 16782, and Allegheny County Health Department Rules and Regulations, Article XXI Air Pollution Control. Part I §2109.09

9. Ibid.

10. Watchdog Report: No Official Explanation for Emissions Issues at U.S. Steel’s Edgar Thomson Plant despite Known Violations & Compliance Plan Promises: Group against Smog and Pollution.” Pgh.org.

11. Ibid.

12. EPA Grants $5.7 Million to Support Electric Buses in Allegheny County.” Bus. June 4, 2021.

13. “Pollution Map.” Breathe Project, https://breatheproject.org/pollution-map/.

3: Cleveland, Ohio

Introduction

In this particular case study, we will take a look at the City of Cleveland, Ohio to assess how and what Detroit can learn from Cleveland’s efforts to mitigate air pollution. This case study should serve as a reference to the City of Detroit on the possible strategies and future program implementation that can improve fugitive dust in the city. Both Cleveland and Detroit are major cities in their states, were once major industrial cities, have experienced population loss in recent years, and have large minority populations.

Overview

Considering that the city of Cleveland has dealt with a similar situation that Detroit is currently dealing with in regard to the problematic effects of fugitive dust, we have determined that an appropriate comparison between the local air permits in Cleveland local ordinances can be of use for the City of Detroit. Post Industrial Cities like Detroit and Cleveland face challenges when dealing with issues such as fugitive dust and air pollution in general. The purpose of this case study is to demonstrate that there are cities in the United States with similar air problems like Detroit and the City of Cleveland, Ohio has pollution levels that are very close to those of Detroit; partly due to their similarities in a number of areas including demographics and history.

Demographics Compared

Unfortunately, Cleveland has been experiencing population loss much like Detroit. It is important to consider that fugitive dust and other types of air pollution have the biggest effect on young people, children, and the elderly so we should include data on the percentages of each from both Detroit and Cleveland. Both cities share a similar demographic composition including racial makeup as well as having decreasing populations and age distribution.

Figure 10: Table Case Study Demographics Comparison

3: Cleveland, Ohio

Table Sources:

U.S. Census Bureau Quickfacts: Detroit City, Michigan¹

U.S. Census Bureau Quickfacts: Michigan²

U.S. Census Bureau Quickfacts: Cleveland City, Ohio³

U.S. Census Bureau Quickfacts: Ohio⁴

U.S. Census Bureau Quickfacts: United States⁵

Another consideration is the racial makeup of both cities because oftentimes disadvantaged communities and people of color have more health problems associated with the air quality in the areas where they live.

History

The City of Cleveland first started enacting local ordinances in the 1880s due to rising air pollution from industrial smoke. Cleveland was one of the first American cities to create an environmental mitigation office and enact an ordinance to address air pollution. Cleveland was one of the first cities in the United States to create a smoke department to reduce smoke emissions that were caused from coal burning in order to improve the air quality for its residents.⁶ There is no doubt that the City of Cleveland has historically enacted policies ahead of its time.

• Smoke Ordinances of 1882: Some of the first air pollution ordinances of its kind in the country.

• Educational Campaign of 1900: Informed the general public about air pollution prevention

• Ordinance no.41.586, 1903: Created to mitigate black smoke production.

• City Ordinance of 1908: Cleveland got rid of the majority of its industrial furnaces.

• Air Pollution Control Division of 1947: Was responsible for measuring and regulating air pollutants.

• The Clean Air Act: First federal legislation regarding air pollution control

• 1970 Amendment: Federal and State regulations began to limit the number of emissions for stationary and mobile sources.

• 1977 Amendment: Established major permit requirements in accordance with the NAAQS

• 1990 Amendment: Expanded and modified on the 1977 Amendment.

Summary of Regulations

In accordance with Title V, Chapters 257 of the Codified Ordinance,of the City of Cleveland any modification or installation of air containment source or control equipment within the City limits must go through an application and approval process as well as submitting two sets of plans and must precisely explain specifications of what is to be installed and how it will affect the air quality and must be be approved by the Commissioner.⁷ This goes to show the

3: Cleveland, Ohio

thoroughness that Cleveland is willing to commit, in order to improve air quality in the city. The local ordinance requires facilities to obtain a permit to install, modify, and a permit to operate any air contaminant source within the City of Cleveland. An owner or operator is required to apply for a permit prior to commencing installation and must renew the permit on a regular basis. In Title V Chapter 259 of the Codified Ordinance, the City of Cleveland requires a renewal process for any type of air pollution source that exceeds three years. The renewal process is similar to that of the modification and installation process.⁸ These ordinances put a cap on the amount of air pollution that can be produced from both stationary and mobile sources. Some of the steps taken in Cleveland include a 24/7 phone line and an online complaint sheet about air quality concerns as well as heavy fines for those who do not comply.

State entities also have a large effect on the actions that are happening in Cleveland. Another consideration is Ohio’s state regulations that the City of Cleveland must comply with. State entities like the Ohio Environmental Protection Agency (OEPA) have also been responsible for the implementation and ultimately the success that the City of Cleveland has been experiencing. We see in the Ohio’s 2019 Annual Sulfur Dioxide (SO2) Emissions Review that even though some sulfur dioxide emissions have been rising from the years 2012 to 2018 these sulfur emission levels have still not exceeded the amounts allowed in the state of Ohio. In addition the amount of coal burned has also gone down significantly since 2012.⁹ These examples of air quality improvements can be attributed to stricter policies and a larger effort by state and local governments to improve air quality, regardless of their heavy reliance on coal powered energy sources. 10 This shows us that even if a place as heavily reliant on coal for its energy like Ohio can implement a cap on coal use and show some improvement in air quality then there is no reason why a City like Detroit cant use stricter laws to mitigate fugitive dust.

Lessons Learned

Considering that both the post industrial cities of Detroit and Cleveland have similar demographics and histories, we believe that the City of Cleveland can be used as a good example of the actions that can be taken to improve air quality in Detroit, by learning from Cleveland’s more proactive approach to air pollution mitigation. By looking into the City of Cleveland’s steps to mitigate air pollution, we can identify some necessary actions for Detroit. While local ordinances are key, they must also work alongside state entities as Cleveland has done with the Ohio EPA. By examining case studies from various cities and counties across the United States with similar air pollution problems we can analyze and assess the overlapping issues.

3: Cleveland, Ohio

Endnotes

1. U.S. Census Bureau Quickfacts: Detroit City, Michigan. Accessed March 20,202, https://www.census.gov/ quickfacts/fact/table/detroitcitymichigan/PST045221

2. U.S. Census Bureau Quickfacts: Michigan. Accessed March 20,2022, https://www.census.gov/quickfacts/ fact/table/MI/PST045221

3. U.S. Census Bureau Quickfacts: Cleveland City, Ohio. Accessed March 20,2022 https://www.census.gov/ quickfacts/fact/table/clevelandcityohio/PST045221

4. U.S. Census Bureau Quickfacts: Ohio. Accessed March 20,2022, https://www.census.gov/quickfacts/fact/ table/OH/PST045221

5. U.S. Census Bureau Quickfacts: United States. Accessed March 20,2022, https://www.census.gov/ quickfacts/fact/table/US/PST045221

6. Wittlinger, Edward. “Air Quality - Permitting.” Air Quality - History, Accessed March 20, 2022, https:// clevelandhealth.org/programs/air/history

7. American Legal Publishing Corporation: “Chapter 257 - Installation and Modification Permits.” Accessed March 22, 2022 CHAPTER 257 - INSTALLATION AND MODIFICATION PERMITS (amlegal.com)

8. American Legal Publishing Corporation: “Chapter 259 - Operation Permits and Variances.” Accessed March 22, 2022 CHAPTER 259 - OPERATION PERMITS AND VARIANCES (amlegal.com)

9. State of Ohio Environmental Protection Agency Division of Air Pollution Control: Ohio’s 2019 Annual Sulfur Dioxide (SO2) Emissions Review. Accessed March 21, 2022 https://epa.ohio.gov/static/Portals/27/sip/ SO2/2019_SO2_annual_emissions_final.pdf

10. Ohio Environmental Council, 21 Apr. 2021, “Organizations Launch Cleveland Comprehensive Environmental Policy Platform.” https://theoec.org/publications/clevelandenviropolicyplatform

4: Dearborn, Michigan

Introduction

The purpose of this case study is to examine the dust ordinance introduced in the City Charter of the City of Dearborn in detail. This case study is an attempt to understand what Detroit can learn from Dearborn. Detroit and Dearborn have different demographics, but their industrial history and nature make it worthwhile to compare dust ordinances in both cities. The Detroit City Council passed an ordinance amendment on October 31, 2017. Chapter 22 of the City Code regulates the storage of bulk solid materials. The 2019 Recodification of the City Code moved this ordinance to Chapter 42: Solid Waste and Illegal Dumping.¹ The Detroit ordinance was passed as a reaction to the dangerous dark cloud of dust that blew along the Detroit River between Windsor, Canada, and Detroit which was formed from massive piles of petroleum coke from storage along the banks of the Detroit River.² This case study briefly compares the two to identify key takeaways. Detroit’s City website details a step-by-step guide to obtaining a general/alternate compliance certificate of operation and is comparatively more user friendly in comparison to Dearborn’s city website and ordinance procedures.³

Overview and Demographics

The City of Dearborn is located in Wayne County, southeastern Michigan, U.S. (Figure 11). It is adjacent to Detroit on the north and east and lies on the River Rouge (Figures 12 and 13). It is the birthplace of Henry Ford and is well-known for being the headquarters of research, engineering, and manufacturing of the Ford Motor Company.⁴

Dearborn, Michigan, has a population of 94,701 as of 2019.⁵ “As of the 2010 census, the racialethnic composition was 89.1% Whites, 4.0% black or African-American, 0.2% Native American, 1.7% Asian, 0.2% Non-Hispanics of some other race, 4.0% reporting two or more races and 3.4% Hispanic or Latino.”⁶ 41.7% categorized as “White” in the Census collection data were of Arab ancestry.⁷

With the building of the Ford Motor Company River Rouge Assembly Plant in 1917, industrial development began and continued with related automotive industries. Adjacent parts of the city consolidated with Dearborn in 1928.⁸ Dearborn’s history with the industrial revolution and its close proximity to industries makes it highly prone to dust-related problems with respect to the ways in which sites are put to use carelessly, which resulted in the creation of the Dust Ordinance.

History of the Program

Dearborn is an industrial city which makes it prone to fugitive dust. Its dust ordinance was made to address the challenges of dust pollution. The City of Dearborn’s Dust Ordinance is part of the Dearborn’s Code of Ordinances and City Charter, which “serves as a framework for the City’s operations and laws.”⁹

Situated near extensive industrial properties in Dearborn, Melvindale, and Detroit, residents in the South End of Dearborn have been particularly affected by air pollution. “We care deeply about our residents and are working as much as we can to reduce pollution to the extent possible,” said City Council President Susan Dabaja.

4: Dearborn, Michigan

She spearheaded the initiative to develop the ordinance. “We want to ensure all of our residents have a high quality of life.”10

The draft of the ordinance was prepared with the help of the Dearborn residents. It was led by Mayor O’Reilly.” The ordinance was unanimously approved on Aug. 25 2020.11

“The most recent City Charter was adopted Nov. 6, 2007, after two years of work by the City Charter Commission.”11 The City of Dearborn City Charter and Code of Ordinances consists of 20 Chapters detailing several important issues ranging from the City’s Boundaries, and General Municipal Powers, to what’s relevant for this case study: the details on the dust ordinance in Sec. 13-5.3 (Dust control; paved, partially paved, unpaved, and storage lots).12

Synopsis of Regulations

Sec. 13-5.3 of the City Charter and Code of Ordinance details dust control protocols for the City of Dearborn. “The purpose of this section is to regulate commercial parking and storage lots, including transportation to, from, and within these lots, in order to minimize the proliferation of dust, debris, odors, vapors, smoke, and vehicle track-out in the City.”13

The City has designed the ordinance to address nuisance activities associated with commercial parking and storage lots, including transportation, as they have the potential to create or contribute to the dust, debris, odors, vapors, smoke, and vehicle-track-out. These cause negative impacts on residents and property. They pose major health hazards associated with inhaling fugitive dust, debris, odors, vapor, and smoke which lead to various illnesses. It also affects the enjoyment of the property and tends to depreciate the value of properties near these lots. Sec. 13-5.3 prescribes reasonable regulations to minimize dust, debris, odors, etc. from commercial parking and storage lots and applies to any owner or renter that manages the property including transportation to and from the property.14 The contents of Sec 13-5.3 is discussed below.

The City has introduced severe penalties for failure to correct a violation. If there is a failure to correct a violation within 3 days of the issuance of a notice, it is punishable by a civil fine of $1,000 plus costs imposed by the court. There is an increased fine for repeat violations of Sec. 135.3. A repeat violation refers to a violation committed within 90 days of an admission occurring on the same property. The increased penalty is $2,500 plus the costs imposed by the court. The violation accounts as a misdemeanor if there is a fourth violation that occurs within a 12-month period.15

This ordinance is applicable to all communities which fall within the city as identified in the Community Boundaries map in Figure 14.

Lessons Learned

• The sites need to be continuously monitored to prevent and identify defaulters. One of the main challenges is to monitor sites prone to generating fugitive dust and tracking the source of such dust once generated. Ordinances such as the one instituted by the City of Dearborn are a starting point in creating awareness among citizens in being more careful with their use and design of difficult sites (such as commercial parking and storage lots) and limiting the number of violations.

4: Dearborn, Michigan

• Resources which point owners, renters, and transportation staff to possible remedies. Detroit’s City Website does a better job than Dearborn’s, of pointing citizens to resources to understand and apply the ordinances. Amendments to the Dearborn ordinance mention requirements which point owners, renters, and transportation staff to possible remedies to limit dust pollution such as the installation of rumble strips and having trucks pass through a wheel wash station. However, this section on possible remedies for Detroit may be elaborated further to make the most of the City’s power as a regulatory and prevention authority.16

• As part of the city’s larger effort, public education about fugitive dust could go a long way in helping prevent dust pollution in the city. Detroit’s City website, although already good, could further point readers to resources that shed light on fugitive dust and its hazards instead of leaving this task to the individual property owners. There seems to be a general lack of awareness about fugitive dust among citizens which could be alleviated by way of pointing to recommended resources via the city website or through organized informational community activities conducted in the communities.

• Fine collection, research on fugitive dust and ways to spread awareness and preventive measures for owners and renters. Also, the fines collected which are used for environmental projects maintained by the City may well be put to use to conduct research on fugitive dust and ways to spread awareness on preventive measures among owners and renters of sites that are potential sources of fugitive dust.

Figures

Figure 11: Map of Dearborn

Figure 12: Map of Detroit and its adjacency to Dearborn

Figure 13: Map of Dearborn and its adjacency to Detroit

Figure 14: Map of Communities in Dearborn that the ordinance applies to

4: Dearborn, Michigan

Endnotes

1. https://detroitmi.gov/departments/buildings-safety-engineering-and-environmental-department/bseeddivisions/envir onmental-affairs/bulk-solid-materials-storage

2. https://www.greatlakeslaw.org/blog/2017/11/detroit-enacts-new-ordinance-to-protect-residents-fromdust-pollution.h tml#:~:text=Chicago’s%20regulations%20do%20not%20set,as%20the%20reportable%20 action%20level. Detroit Enacts New Ordinance to Protect Residents From Dust Pollution

3. https://www.greatlakeslaw.org/blog/2017/11/detroit-enacts-new-ordinance-to-protect-residents-fromdust-pollution.h tml#:~:text=Chicago’s%20regulations%20do%20not%20set,as%20the%20reportable%20 action%20level. Detroit Enacts New Ordinance to Protect Residents From Dust Pollution

4. https://detroitmi.gov/departments/buildings-safety-engineering-and-environmental-department/bseeddivisions/envir onmental-affairs/bulk-solid-materials-storage Bulk Solid Materials Storage

5. https://www.britannica.com/place/Dearborn

6. Google.com

7. Dearborn (city) QuickFacts from the US Census Bureau”. census.gov. Archived from the original on 2014-0104.

8. Data Access and Dissemination Systems (DADS). “American FactFinder – Results”. census.gov. Archived from the original on 2020-02-12.

9. https://www.britannica.com/place/Dearborn

10. http://cityofdearborn.org/ City of Dearborn website

11. Ibid.

12. Ibid.

13. https://codelibrary.amlegal.com/codes/dearborn/latest/dearborn_mi/0-0-0-1 City of Dearborn City Charter and Code of Ordinances

14. Ibid.

15. https://codelibrary.amlegal.com/codes/dearborn/latest/dearborn_mi/0-0-0-1 City of Dearborn City Charter and Code of Ordinances, Sec. 13-5.3 (a)

16. Ibid.

17. https://codelibrary.amlegal.com/codes/dearborn/latest/dearborn_mi/0-0-0-1 City of Dearborn City Charter and Code of Ordinances, Sec. 13-5.3 (f)

18. https://cityofdearborn.org/news-and-events/city-news/2215-dust-pollution-ordinance-amended-toincrease-enforcem ent-and-fines

5: Mitigating Dust Emission from Unpaved Surfaces

Introduction

There are many different sources of fugitive dust, and each source requires different mitigation strategies. Unpaved surfaces can be a significant contributing factor to fugitive dust production. Unpaved surfaces are a common sight in many cities, and the dust from them can be difficult to contain especially when large areas of land are unpaved and uncovered. When unpaved lots are vacant and their owners are frequently absent, it becomes more difficult to ensure that dust is being properly contained. This case study will outline three main strategies for dust suppression on unpaved lots: porous and non-porous asphalt paving, watering, and calcium chloride application. Less common chemical dust suppressants will also be briefly discussed. Knowing these strategies allows us to understand practical solutions that property owners may need to take in order to reduce their dust production.

Fugitive Dust and Unpaved Surfaces

In urban areas, unpaved lots, either vacant and unused or actively trafficked, have a high risk of producing fugitive dust. The Michigan Department of Environmental Quality lists unpaved parking lots and unpaved roads as fugitive dust generating activities.¹ In Clark County, Nevada unpaved lots of over 5,000 square feet (¼ acre) are required to take steps to reduce dust output.² Vegetated vacant lots do not produce fugitive dust; but in commercial and industrial areas unpaved lots are often covered in dirt, gravel, and degraded concrete or asphalt which all create dusty conditions. Such lots are a frequent sight in the City of Detroit and regulating the dust production from lots more strictly might reduce the amount of particulate matter released into the atmosphere. There are a number of dust control methods for unpaved surfaces that are available to the owners of such lots so that their property does not contribute to particulate matter levels. The specific prices of every option will not be provided in this paper, as companies do not provide these prices to the public, but their relative costs to one another will be discussed.

Solution 1: Porous and Non-Porous Asphalt

A straightforward way of preventing dust from unpaved lots is to pave them. This is primarily an option for unpaved lots that are used frequently for parking and vehicle access. The most common pavement for parking lots and driveways is asphalt, also known as blacktop. Blacktop is composed of two main ingredients: aggregates and liquid asphalt.³ Aggregates are coarse material like gravel, crushed rock, and sand. Liquid asphalt is the viscous glue that holds these aggregates together, hardening to form solid pavement. A major benefit of keeping lots unpaved is that they do not require stormwater infrastructure. In order to pave lots without installing additional stormwater management systems, porous asphalt may be a good choice. Porous asphalt includes wider gaps between the aggregate, allowing water to flow through the surface and into the ground. Figure 15 shows a cross-section of porous asphalt. Both porous and nonporous asphalt almost completely eliminate fugitive dust production with standard upkeep. All asphalt requires upkeep to prevent dust from forming out of broken or deteriorated surfaces. Standard asphalt requires professional resealing every three to five years. Asphalt often cracks and deteriorates from frequent use and moisture accumulation, which can create breaks and holes in asphalt. Resealing binds the asphalt back together after years of wear.4 Porous asphalt

5: Mitigating Dust Emission from Unpaved Surfaces

should not be resealed, but power-washing or vacuuming helps to prevent clogging in the spaces between aggregate. Porous asphalt does not accumulate moisture in the same way, and can experience far less cracking from temperature changes. Ideally, this cleaning should be done twice per year, and significant dirt accumulation or piles should be cleared or reduced right away.⁵

The up-front cost of asphalt paving is the highest of any other option provided in this paper, but it is also the most permanent solution. Porous asphalt on its own tends to be slightly more expensive than non-porous asphalt. However, according to the Detroit Water & Sewerage Department, the cost can be off-set by reducing or even eliminating the need to install stormwater management systems.⁶ Porous asphalt has a lifespan of up to 20 years with cleaning alone, while non-porous asphalt must be resealed every five years to have a similar or longer lifespan.⁷ Both types of asphalt are recyclable: old asphalt is often reprocessed and made into fresh asphalt. Asphalt pavement may be a great choice for actively trafficked lots in order to avoid excess dust production.

Solution 2: Water

Moisture allows the particles of an unpaved lot to stick together, thus preventing dust from being produced. Watering of unpaved surfaces is the oldest and most common dust suppression technique. The standard method for watering is the use of water tanks with spray systems to evenly distribute water. Application is relatively simple, and water tends to be easily accessible on-site at most industrial and commercial locations.

There are significant drawbacks to water as a dust palliative. The primary concern is that water usually requires frequent application. According to the Alaska Division of Air Quality, when applied alone, “[water] provides a short-term reduction in dust.”⁸ Water evaporates, especially on a surface without tree cover, such as a large lot. Water typically evaporates within a few hours, depending on the temperature. Water is often considered an inexpensive option, but when it must be applied frequently, costs accumulate quickly. During periods of drought, when dust conditions are worst, water becomes a less viable option for dust control. Different chemical methods have become more widely used to reduce the amount of water needed to keep dust down. They are discussed in the following two sections.

Figure 15: Typical porous pavement cross section, National Asphalt Pavement Association, 2018.

5: Mitigating Dust Emission from Unpaved Surfaces

Solution 3: Calcium Chloride

Calcium chloride (CaCl2)is hygroscopic, meaning that it absorbs moisture from the air around it. Hygroscopic materials draw moisture to unpaved surfaces and, importantly, help the surface retain the moisture for longer periods. Calcium chloride is one of the most common hygroscopic dust suppressants, and is also used as a de-icer. The surface must be bladed and watered before and after the solution is applied. Calcium chloride should be applied once per year on lots with limited traffic, or twice if the area is highly trafficked.⁹

Calcium chloride is less toxic than many hygroscopic dust suppression products, but it can have some environmental impacts.When properly applied, it should not pose a threat to the water table. If it is not applied correctly, or if there is heavy rainfall before the calcium chloride has set, it can leach into ground and surface water. Calcium chloride is not harmful to humans, plants, or animals in small amounts. It can be corrosive to steel in direct and prolonged contact, in most circumstances the effect is minimal.

Solution 4: Other Chemical Dust Palliatives

Many other commonly used commercial products are sold as dust palliatives. Nearly all of them work through some combination of hygroscopicity and agglomeration. Agglomeration is the bonding of dust particles together, which prevents dust formation by weighing the particles down.10 The two strategies are demonstrated in Figure 16. Many products use a combination of organic and synthetic materials. One of the most common products is lignin sulfonate (L.S.), which is a byproduct of the paper-making process. There are additional commercial products with formulas that often use L.S. and similar compounds as ingredients. Soy-based products have become more common in recent years for suppression as well. In the state of Michigan, lignosulfonate products, vegetable by-products, and resin stabilizers are agglomerates that may be used for dust suppression without a permit.11

Figure 16: Schematic of dust suppression mechanisms: (a) hygroscopicity and (b) agglomeration. Parvej et al., 2021

5: Mitigating Dust Emission from Unpaved Surfaces

Vendors do not usually share the cost of installation for these products, so the prices are not readily available to the public. Costs vary by the size of the lot, the location of the lot, and the price of labor, as well as market forces. A detailed study in the academic journal Sustainability, concluded that organically derived dust suppressants had a much lower risk of ecological damage than chloride-based suppressants but were relatively similar in their effectiveness.12 These products are becoming increasingly common, and are often offered by the same companies which offer calcium chloride treatment.

Conclusions

The owner of an unpaved lot should consider the types of use and frequency of use on their lot. If it is financially feasible, lots that encounter frequent traffic from vehicles would most readily benefit from being completely paved. However, if the cost of pavement is too high, or design factors influence the choice to remain unpaved, chemical dust suppressants of some kind should be used. Water is often used on construction sites because the surfaces being treated will eventually be paved or covered in some other ways. As a permanent solution, applying water could become quite costly in both money and time. Organic and inorganic dust suppression chemicals require annual or twice annual application and are a good option for those who prefer to keep their lots unpaved.

It is important that property owners understand the consequences of dust emission in their communities and are given adequate resources to mitigate the nuisance. Some of the sources provided at the end of this paper go into more detail on different options and can provide a great deal of detail for those who are interested. Companies that offer deicing services also often provide dust control solutions, so owners can use their regular vendors for other routine maintenance. The owners of large unpaved lots should reach out to companies that provide dust management services to understand the costs and benefits of each option for their own needs. Ultimately, individual circumstances dictate the exact best dust mitigation strategies, but it is important to know that there are a wide variety of options available.

5: Mitigating Dust Emission from Unpaved Surfaces

Endnotes

1. Michigan Department of Environmental Quality, Managing Fugitive Dust, (Lansing, 2016), pg. 2, https:// www.michigan.gov/documents/deq/deq-ead-caap-genpub-FugDustMan_313656_7.pdf.

2. Clark County Air Quality Regulations § 92, 2014.

3. Kenneth O’Reilly, Asphalt: A History (Lincoln: University of Nebraska Press, 2021), pg. 3.

4. Home Advisor, “Extend the life of your driveway with regular resealing,” Detroit News, May 10, 2018.

5. Cahill Associates Environmental Consultants, Porous Pavement Operation and Maintenance Protocol (San Diego), https://www.sandiegocounty.gov/reusable_components/images/dgs/Documents/Grants_Prop40_ AppendIII_.pdf.

6. National Asphalt Pavement Association, Porous Asphalt Pavements (Lanham, MD, 2018), https://www.paasphalt.org/images/PDF/PS-33_Porous_Asphalt_Pavements.pdf.

7. Detroit Water & Sewerage Department, Drainage Program Guide (Detroit, MI, 2018), pg. 1, https:// detroitmi.gov/sites/detroitmi.localhost/files/2019-06/DCCP%20Site%20App%20-%20Permeable%20 Pavement_WEB.pdf.

8. Alaska Department of Environmental Conservation Division of Air Quality, Top Ten Dust Control Techniques, (Juneau, AK), https://dec.alaska.gov/air/anpms/dust/control-techniques-list#main.

9. Leo Caouette, Application Methods: Calcium Chloride as a Dust Suppressant (Hopec Enterprises Ltd, St. Paul, Alberta).

10. Subbir Parvej et al., “Fugitive Dust Suppression in Unpaved Roads: State of the Art Research Review,” Sustainability 2021, 13, 2399, pg. 3, https://doi.org/10.3390/su13042399.

11. Michigan Department of Environmental Quality, Guidelines for Selecting Dust Suppressants to Control Dust and Prevent Soil Erosion, (Lansing, MI, 2014), pg. 1, https://www.michigan.gov/documents/deq/dnreoppca-factsheet-dustsuppressants_310381_7.pdf.

12. Ibid.

Summary of Key Documents

Michigan Dept of Environmental Quality – Managing Fugitive Dust: A Guide for Compliance with the Air Regulatory Requirements for Particulate Matter Generation15

“Managing Fugitive Dust - A Guide for Compliance with the Air Regulatory Requirements for Particulate Matter Generation,” created by the Michigan Department of Environmental Quality, is a comprehensive document outlining what fugitive dust is, the major sources of fugitive dust, fugitive dust control programs, clarifications on fines payment for businesses producing fugitive dust, and other key resources necessary to both become aware and combat fugitive dust in Michigan. Below are key takeaways from the document.

The document chiefly focuses on the federal and state statutes and rules that apply to the minimization of fugitive dust from two sources: industrial sources and transportation maintenance activities in Michigan. Fugitive dust is described by Michigan statutes (R 336.1106(k) of the Michigan Air Pollution Control Rules) as “particulate matter which is generated from indoor processes, activities, or operations and which is emitted into the outer air through building openings and general exhaust ventilation, except stacks. The term also means particulate matter which is emitted into the outer air from outdoor processes, activities or operations due to the forces of the wind or human activity.” Most importantly, emissions discharged from building stacks and by products of open burning are not fugitive dust.

The composition of fugitive dust: comprised mainly of soil materials such as oxides of silicon, aluminium, calcium, and iron, but also contain sea salt, pollen, spores, and so on. Particulate matter with a diameter of 10 microns or less (PM10) and particulate matter with a diameter of 2.5 microns or less in size (PM2.5) are the most common regulated forms of particulate matter. PM10 is made up of substances such as dirt and is typically bigger and less damaging than PM2.5, which is created by physical or chemical changes in pollutant gases. Despite the fact that most fugitive dust particles are bigger than 10 microns in diameter (the average human hair is 70 microns in diameter), they all have the potential to settle swiftly on the ground and harm human health or the environment. The document further explains the types of activities that generate fugitive dust. All activities have the potential to produce fugitive dust, but agricultural, mining, construction, manufacturing, transportation and utilities, wholesale/retail trade, and service industries are the most common sources of frequent and high amounts of dust particles. Figure 17 lists some of the most typical sources and activities that can produce considerable amounts of fugitive dust.

Summary of Key Documents

Air pollution is defined as any amount of dust production. Excessive dust, for example, can harm plant life and lower agricultural and animal output by contaminating them with its chemical makeup. Dust particles generated by the wind can erode precious topsoil and contribute to the soiling and staining of personal goods, resulting in monetary expenditures for cleanup. In places where fugitive dust production is a recognized concern, constant soiling can have a negative impact on property and land values. Fugitive dust, like any other form of air pollution, can be hazardous to one’s health. Small particles (2.5 microns or less in diameter) can readily be inhaled and go to the deepest portions of the lungs, causing irritation of the nose and throat, respiratory disorders such as bronchitis, lung damage, and asthma, and even early death in sensitive people. Fugitive dust can also limit visibility (i.e., haze) to the point that it can cause catastrophic injury or death in moving vehicles or work site equipment mishaps.

Figure 17: Table 1 of Fugitive Dust Generating Archives

Summary of Key Documents

Section 3.0 Permitting, major source designation, and fugitive dust Air permitting is the process through which regulatory bodies compile all relevant federal and state regulations for a source of air pollution into a single legally binding document. Understanding the air permits requirements is the first step in determining which activities need compliance with air quality standards.

Section 3.1 The permit to install Permit to install or New Source Review (NSR) is a regulatory operation related to air pollution management. Prior to the installation, building, reconstruction, relocation, or modification of equipment that emits air pollutants, a person must acquire a Permit to Install under R 336.1201 of the Michigan Air Pollution Control Rules. There are various state statutes that exclude minor sources of air pollution from having to get air pollution control licenses.

The following are some of the key features of the Michigan Permit to Install program:

• A state license to release air pollutants into the ambient air is known as a Permit to Install.

• Compliance with permit restrictions helps to increase the degree of protection offered to both public health and the environment at a facility.

• The applicant will know whether federal and state laws apply to the equipment covered by the permit when the permitting procedure is completed.

• The Permit to Install’s operating conditions limit a facility’s ability to produce air pollutants.

• There are no charges for acquiring a Permit to Install.

• A Permit to Install has no expiration date and does not require renewal.

The Permit Section of the Michigan Department of Environmental Quality’s Air Quality Division (AQD) oversees the Permit to Install program (MDEQ).

The document also details out ways to measure opacity: “the greater the concentration of fugitive dust, the greater the opacity designation.” It also details out some methods to measure opacity. The section on fugitive dust control programs defines what a control program is. “It is an operating program that is designed to significantly reduce the fugitive dust emissions to the lowest level that a particular source is capable of achieving by the application of control technology that is reasonably available, based on technological and economic feasibility.” Control programs may be required by public act or state rule, the document explains the differences between both.

Table 3 explains spraying requirements for fugitive dust sources.

Summary of Key Documents

Figure 18: Table 3 of Spraying Requirements For Fugitive Dust sources

Summary of Key Documents

Bulk Materials Ordinance - Detroit

This ordinance by the City of Detroit is an amendment of chapter 22 of the 1984 Detroit City code. The amendment provides for additional definities to the “Handling of Solid Waste and Prevention of Illegal Dumping.”

Implementation and Compliance: “The storage and transportation of bulk solid materials is regulated, including but not limited to asphalt millings and carbonaceous bulk solid materials such as petroleum coke, including loading and unloading. Excessive fugitive dust from bulk solid material is advised to be avoided. Advice is given to firms who manufacture or store petroleum coke and other bulk solid materials on how to do it correctly. A procedure is created for deviations from certain sections of Article V following notice, public hearing, and opportunity for public discussion. A timetable for implementation is given. A fund is established. Procedures for enforcing the rules and sanctions are in place.”

The document primarily aims to avoid excessive fugitive dust from bulk storage facilities. It also details the use of industrial sites and their emergent problems.

The escape of fugitive dust from an otherwise authorized collection of bulk solid material, especially when it exceeds the opacity limit set and specified in MCL 324.5524(2) is deemed unlawful and is subject to fines and penalties.16 Article V: Bulk Solid Materials defines several things including the scope of the article itself, which is to minimize the proliferation of fugitive dust due to its potential to collect in residents’ homes and vehicles. It is formulated to protect residents from health hazards and promote the health, safety, and wellbeing of neighboring communities. Inhaling fugitive dust causes pulmonary inflammation and fibrosis apart from causing disturbance as a visual nuisance and blight within the city of Detroit and along its waterways.17 The article aims to minimize emissions of fugitive dust from a list of factors and applies to any owner or renter, who may be responsible for these activities: Storage; On-site transporting or handling; Loading; Unloading; Stockpiling; Processing of bulk solid materials.

The ordinance details out the definition of bulk solid material as useful to this text and is concerned with bulk storages with a potential for fugitive dust and an accumulation in an amount of 50 cubic yards or more at a time. Some such examples may be the storage of the following18:

» Asphalt millings

» Ores

» Iron and steel slag

» Gravel

» Sand

» Limestone

» Carbonaceous material

Summary of Key Documents

And it does not include the following:

» Salt

» Grains

» Commercial solid waste

» Garbage

» Materials stored at nurseries, garden centers, and farm supply stores

The ordinance describes Chemical stabilizer as a chemical dust suppressant that is not unlawful to use and that meets the specifications set by federal, state, and local agencies. The ordinance also provides a description of fugitive dust and opacity:

» “Fugitive dust means any solid particulate matter that becomes airborne by natural or human- made activities. excluding engine combustion exhaust and particulate matter emitted from a properly permitted exhaust stack equipped with a pollution control device.”19

» “Opacity means the highest degree to which visibility of a background (e.g., blue sky) is reduced by fugitive dust, expressed as a percentage where 0% represents no interference by fugitive dust and 100% represents zero visibility due to complete interference by fugitive dust.”20

An incident with PM10 level of 150 micrograms per cubic meter or more measured constitutes a “reportable action level”.21 The ordinance also defines wind screens as the use of structures to deflect wind away from storage facilities to avoid producing fugitive dust.

Properties may receive a compliance certificate post inspection of site and measures taken to prevent fugitive dust.22 The owner of the property should submit to the Buildings, Safety Engineering, and Environmental Department (BSEED) an application for certification of operation in the property. If BSEED finds that a set of dust control requirements as a condition for the facility to operate increases the facility’s compliance to prevention of fugitive dust, it may impose these requirements on the property. BSEED consults with the health department, and the water and sewerage department before it issues a certificate of operation to the site. 23

Change in facility operations need to be notified to BSEED at least 30 days before such changes ensue. The BSEED director needs to be notified of changes and an application to amend certification needs to be submitted. This commences the process to submit a revised fugitive dust plan to establish BSEED’s satisfaction that the expansion or change in operation of the facility is compliant with the existing fugitive dust plan.24

A Fugitive Dust Plan is a mandatory requirement of any facility that stores bulk materials and falls into the definition of a bulk storage unit as defined in the ordinance.25

More details on the Fugitive Dust Plan:

Summary of Key Documents

» It is mandatory that every owner or operator of a facility submit and follow a fugitive dust plan and any amendments need to be notified to BSEED from time to time.

» Contents of the fugitive dust plan

• Name and address of the facility and of the owner or operator

• Site map with the following information

◊ Facility boundaries

◊ Buildings, Roadways and transportation corridors

◊ Location of all floor drains, storm drains, and storm water outfalls

◊ Potential emission points at site

◊ Locations of control devices

• Description of the facility’s operations

• Description of truck routes

• Calculation showing the facility’s maximum total indoor and outdoor bulk solid material storage capacity

• Description of control measures

• Dust monitoring plans with following descriptions:

◊ Placement, operation, maintenance of the PM10 monitors

◊ Schedule and plan for quarterly testing to ensure compliance with the prohibition on fugitive dust as described in the article

» Conducted by trained professional

» Conducted in a range of weather conditions

• Contingency plan describing owner’s or operator’s response activities when PM10 exceeds the reportable action level

• Fact sheet or executive summary of the fugitive dust plan which may also be posted on the city’s website

The document also details out steps to ensure fugitive dust monitoring, wind monitoring, conveyors and transfer points, transport, vehicle covering and other dust control, vehicle leaking, truck loading and unloading, Railcar loading and unloading, vessel loading and unloading, roadway cleaning, spilled material, record keeping, and inspections, to name a few.26

The majority of the sites that pose the greatest threat to public and environmental health are primarily on the southern borders of Districts 1 and 2. These areas include most of the industrial manufacturing and unpaved large lots. While ground truthing our original list of sites, we used specific criteria to determine which of these areas pose the largest contributors to fugitive dust in the City of Detroit. This criteria included: vacancy, paved or unpaved lots, materials on lots, severity of visible dust, as well as the size of the lot.

Methodology

In order to determine the sources of fugitive dust in Districts 1 and 2, we started by focusing on the industrial and commercial areas. We used Google Maps satellite imagery and Google Street View to identify any sites that appeared to be potential fugitive dust sources. In addition to examining all commercial and industrial zoning in the districts, we looked along major thoroughfares. Initially, we were concerned about demolished residential lots being sources of fugitive dust, but we found that most of them were vegetated with grass and weeds, and were unlikely to produce dust, but some were included on our initial list. Once we compiled a large list of potential sites, we used the City of Detroit’s Parcel Viewer to collect information on sites’ size, vacancy status, and official use.

After this list was compiled, we moved on to conduct ground-truthing to narrow our list of suspected dust sources. We created a checklist in advance of the trip and used it when visiting each site. We looked at the vacancy status, visible pavement, material on lots, and any visible fugitive dust emissions. We did not visit any of the residential sites, because we did not expect them to be significant sources to prioritize, and were too numerous to reasonably ground-truth within our timeframe. From our ground-truthing, we were able to compile a shorter list of fugitive dust sources.

Vacancy

An important factor to take into consideration is whether or not the lot is vacant. If a lot is empty it may be more likely that it can be a source of fugitive dust because it means the difference between an area that has attention being paid to it. For example, if a lot has an active business present it means that there will possibly be a certain amount of attention that must be paid to it. This is due to the fact that usually if the lot in question is absent of people no one will tend to the dust being emitted from it.

Paved or Unpaved Lot

If a lot is unpaved it has the potential to be a higher source of fugitive dust. Open spaces are very present throughout district 1 and 2 however, they are largely covered in vegetation and therefore do not pose as large of a threat as a source of fugitive air pollution as opposed to those that are unpaved and have no vegetation. Another issue even with paved lots may be that they are not taken care of properly because of their vacancy which ultimately leads to the pavement cracking and although they are technically paved they still become a source of dust. The Michigan Department of Environmental Quality directly links unpaved lots and roads as fugitive dust sources. In places like Clark County, Nevada unpaved lots with a square footage of over 5,000 are forced to address fugitive dust, this is important because in Detroit many lots are of this size.

Materials on Lots

Empty lots, scrap yards, and other types of industrial lots often have piles of materials that are exposed out in the open. The types of materials that were seen in Districts 1 and 2 that were are those typically used in the process of making concrete which includes cement and aggregate materials like small pebbles and sand which have the potential to be a source for fine dust particles. Recyclable materials, wood piles, and garbage were also frequently seen. All of these types of materials can pose a huge health risk to those who either live or work in the area.

Severity of Visible Active Dust Emission

Ultimately, if the dust emitted from a lot is visible it means that the amount of dust is probably very high. Fortunately, the amount of dust that was visibly emitted from these lots in the ground truthing portion of our analysis was either very low or none. One of our trips occurred ona weekend after it had rained the day before, decreasing the likelihood of seeing any dust and particularly dust from active businesses. This does not mean that the fugitive dust problem doesn’t exist in these districts, it was just not apparent on our multiple trips to Districts 1 and 2. Some scrap yards and industrial use lots used a type of closed fence that was made from either brick or propped up sheet metal that may have been placed for privacy reasons or to keep dust in the area.

We have mapped the parcels and have identified distinct zones where sources are concentrated. Six zones are identified, three in each district. The zones will be discussed in greater detail in this section.

District 1

Dale & Fenkell

The Dale & Fenkell area is a short stretch of industrial uses along Dale St, North of Fenkell Ave and South of Redford Cemetery, in the northwest corner of the Brightmoor neighborhood. The parcels in this area are zoned as M2 (Restricted Industrial) and M4 (Intensive Industrial). The block west of Dale is split by the border between Detroit and Redford Charter Township. Most of the potential sources of fugitive dust on Dale are from unpaved lots trafficked by heavy vehicles, as well as piles of scrap materials.

On the West side of Dale, it appears that vacant lots on the Detroit side of the block are being used for storage by businesses located on the Redford Charter side of the block. From initial study it seems that some of these lots are owned by the Redford businesses behind them, but some may be using the lots for storage without permission. These lots are mostly surrounded by high fences with little visibility within. They seem to contain a variety of miscellaneous materials, including wood, metal, plaster, and broken concrete. The businesses on Telegraph Rd within Redford Charter include auto body shops, a recycling center, and tool & die shop. On the east side of Dale, many of the businesses’ back lots are owned by Detroit Parks and Recreation, and are directly adjacent to Rouge Valley Parkway, which runs along the Rouge River.

These lots are fenced off by the businesses adjacent to them, and are unpaved. Because they are used for access by large semi trucks, these unpaved lots may be concerning sources of dust. This street also hosts several cement companies which transport and store cement. These companies seem to be adequately storing these materials, so they are not concerning sources of fugitive dust.The large stretch of parks with heavily concentrated tree cover may reduce the spread of fugitive dust from these sites.

Figure 19:Map of Dale and Fenkell Sites

Schoolcraft & Burt

The parcels in this area are mostly zoned as M2 (Restricted Industrial) and M4 (Intensive Industrial). This area is in the southeast corner of the Brightmoor neighborhood. There are a number of smaller lots surrounding one very large lot, a warehouse used by a number of businesses. The other larger parcel is listed because of its unpaved lot with truck access. Many of the smaller lots appear to be unused. In this area, sources of fugitive dust concern business activities occurring on the lots as well as unpaved lots in the area. Most of the unpaved sections of land are vegetated or very small, so this issue is less of a concern on most of the parcels. However, there are a few unpaved access roads and lots which appear to be heavily trafficked by trucks and machinery. Additionally, a number of businesses appear to do their work in open areas, with the potential for fugitive dust to be produced.

Figure 20:Map of Schoolcraft and Burt Sites

Greenfield & Schoolcraft

There are a few large fugitive dust sites along Greenfield road, particularly in the area south of Schoolcraft and north of I-96. An additional parcel on Southfield road is included in this section. The parcels in this area are zoned as M4, permitted for intensive industrial use. They are heavily trafficked by semi-trucks and machinery. Such activities being directly adjacent to Interstate 96 can lead to dust production by vehicles entering and exiting the area. The large lot on the West side of Greenfield is a legally registered scrapyard, and contains very large mounds (more than 20 feet tall) of dirt, sand, and broken concrete. The remaining parcels are large unpaved lots used for storage containers and vehicles. Some of these unpaved lots also contained large mounds of rubble, dirt, and scrap materials.

Figure 21:Map of Greenfield and Schoolcraft Sites

Inventory District 2

Meyer and Lyndon Sites

The fugitive dust sites in this area are concentrated around the intersection of Lyndon and Meyers road, in the Bethune Community Neighborhood. Lyndon street serves as a border between District 2 and District 7, and only the District 2 sites are considered for this report. There is a large cluster of industrial uses in this area, most of the parcels are zoned as M4 (intensive industrial). This area includes a number of scrap and storage lots, many of which are unpaved or have extremely damaged and dusty lots. These lots were observed to be slightly hazy less than 12 hours after a rainfall. Some of the lots also seemed to be used for illegal dumping of scrap, rubble, and tires.

Butzel Playfield at the northeast corner of Lyndon and Meyers is directly across from this large cluster of industrial uses as well as more south of Lyndon. Butzel Playfield includes a baseball diamond, running track, play equipment, tennis and basketball courts, and a large open field. Sawyer Playground is another park with play equipment, basketball courts, walking paths, and a field, near the corner of Lyndon and Schaefer Highway. The proximity of these parks to dustgenerating sites is concerning as it likely reduces the air quality in an area used for outdoor activities, and may impede enjoyment of these newly renovated parks.

Figure 22:Map of Meyer and Lyndon Sites

M-10 & Livernois

There is a long diagonal stretch of fugitive dust source sites in and around the triangular area between Livernois, M-10, and Davison street. This area is capped by Council District 7 to the West and Highland Park to the East. Parcels run along a former railroad track. The area is within the Dexter-Fenkell and Oakland Boulevard neighborhoods. All of the parcels in this area are zoned M4, for intensive industrial use. The uses are primarily for auto parts and scrap storage. The main concern for fugitive dust production on these parcels are very large unpaved lots with frequent vehicle traffic, as well as scrap storage, both legal and illegal. The proximity to M-10 also creates concerns over dust being tracked in and out of the area by semitrucks.

Salsinger Playfield is a large open field which currently does not have very much activity or built-in amenities. As of now it may be a source of fugitive dust as it was observed to include piles of dumped garbage and scrap. If the playfield were to be used as a park or invested in by the city in the future, it would be in close proximity to a cluster of dust-producing businesses.

Figure 23:Map of M-10 and Livernois Sites

8-Mile & Woodward (Former State Fairgrounds)

The former State Fairgrounds has long been a potential source of fugitive dust due to the dilapidated paved lots and pervasive dumping. However, early in the creation of this report, the State Fairgrounds were purchased and slated for redevelopment. In the short-term, concerns may still exist regarding fugitive dust creation from demolition and construction on this site. The Phase II section of the project would presumably continue to be a potential source of fugitive dust over the next few years. However, this area is much less of a concern now than when it was initially considered. Adjacent to the Fairgrounds site is a single large unpaved lot that was identified as a source of fugitive dust, and is not currently slated for development along with the State Fairgrounds.

Figure 24:Map of8-Mile and woodward Sites (State Fairgrounds)

Site Prioritization

After our ground truthing efforts, we were able to narrow down our list of potential sites. Seeing the sites gave us a new perspective that could not be gained from Google Maps aerial imagery. With our narrowed sites, we could start to determine how much of a potential risk these sites could be to some of the most vulnerable people in the City of Detroit, including children and the elderly. We started to prioritize sites by their size, distance to schools, and proximity to vulnerable populations.

Size of Lot

The 87 sites chosen within Districts 1 and 2 vary in size. The smallest of the group measures at 0.05 acres (2178 square feet) and the largest at 84.46 acres (3679077.6 square feet). The average size of these sites is 3.34 acres (145490.4 square feet). The vast majority of these sites fall under 7 acres, as seen in Figure 25. Due to the clustering of these sites, it is difficult to prioritize only by the size of the site without understanding the context of the area.

The largest site is known for being the former Michigan State Fair Ground. Throughout this project the site has seen construction of an Amazon warehouse and the demolition of the historic Michigan State Fair Coliseum. This 84 acre site will soon also see construction of a new transit center. While this area may only be a temporary site of fugitive dust, it is important to see the ways in which vacancy and construction can affect fugitive dust production.

Figure 25:Map of Fugitive Dust Sites by Acerage

Schools

Of the site clusters, some are much closer to schools than others. Figure 26 below shows each public elementary-middle school servicing Districts 1 and 2. The sites are color coded by the closest school. The closest site is less than a quarter mile from an elementary school, exactly 0.22 miles. So while close by, depending on the level of fugitive dust production, there may not be an easily identifiable direct impact. The furthest site is 2.72 miles from the closest school to the site. Based on proximity to schools, the Schoolcraft and Burt sites, the M-10 and Livernois sites, and 8-Mile and Woodward sites should be prioritized for mitigation. School proximity is important because of the presence of children with developing lungs and the amount of time they spend outside while at school.

Vulnerable Populations

Another way to look at these sites and who is affected by them is to see the sites situated in a visualization of the vulnerable populations. These populations include children and the elderly. For the purposes of this project, children are considered ages 14 and younger and the elderly population consists of ages 65 and older. All population data comes from the 2020 American

Figure 26:Map of Fugitive Dust Sites by Closest Elementary Schools

Community Survey data sets produced by the United States Census. This investigation shows us where children live and spend their time when they are not in school. It is also important to see where the elderly live because many are home bound and do not have mobility to spend time in other areas.

Air quality ultimately has a huge impact on the health of those who live in the city. Those most at risk are usually small children and the elderly. Children are particularly vulnerable to air pollution and fugitive dust because they breathe at faster rates than adults do. Since they are still growing they tend to eat more, drink more water, and breathe more on a pound for pound basis. In Figure 27 we see that children from ages of 0-14 years old are predominantly located in close proximity to fugitive dust sites located in the southwestern, southern, southeastern and northeastern sections of Districts 1 and 2. We can concur that there is a strong correlation between where most of the young children in District 1 and 2 live and the primary sources for fugitive sites.

Another important demographic in the City of Detroit is the elderly population which consists of those ages 65 and above. We have created a map (Figure 28) that shows us where the elderly live in Districts 1 and 2 by census tract. Even though the fugitive dust site and the locations where the elderly are not as correlated like it is in the case of the children ages 0-14, the fact still remains that the elderly live close to fugitive dust sites. The elderly tend to live more in the central sections of Districts 1 and 2, but there are still areas where there is a high elderly population close to fugitive dust sites.

Figure 27:Map of Fugitive Dust Sites and Distribution of Population ages 0-14

Figure 29 uses bivariate symbology to show areas where the highest percentages of children and elderly populations live by census tract. The darkest colored census tracts represent the highest percentage of both elderly and children. For context, the census tract with the smallest number of children has 7% and the maximum percentage of children in any of these census tracts is 35%. For the elderly distribution, the smallest percentage is 4% and the highest percentage of elderly population is 40%. Within these two districts, almost all of the relevant clusters are contained within census tracts that have high percentages of children and not elderly populations. This demonstrates that the school analysis holds weight. In addition, the Dale and Fenkell sites should be prioritized because of the proximity to a high percentage of children while not being not near a school.

Figure 28:Map of Fugitive Dust Sites and Distribution of Population ages 65+

Figure 29:Map of Fugitive Dust Sites and Distribution of Vulnerable Populations

Policy Options

Within Districts 1 and 2 there are clusters of sites contributing to the fugitive dust problem. These sites are generally located along transit corridors and former industrial hubs. Most of the sites within these clusters have businesses related to automobiles, construction, and bulk storage. The rest of these sites are vacant unpaved lots. This split in types of sites require different strategies to curb fugitive dust. There are also different policy options depending on the resources the City has to offer and use on mitigation efforts. The City’s first step will be to decide if it wants to regulate based on the ground level specifics of a site or to regulate the active emission of fugitive dust.

Ground Level Regulations

In attempting to address fugitive dust concerns, Detroit may want to take a broad approach to address all land that is producing fugitive dust. This could include all open areas, unpaved lots (vacant or not), unpaved roads, unpaved parking lots, and other areas as the city sees fit. Some municipalities require the open area or lot to be larger than 5,000 feet before the regulations kick in. Depending on the type of site, the city could introduce legislation that requires or incentivizes owners to pave their lots. The next best options would be to require or incentivize the application and maintenance of gravel, dust palliatives, or other control mechanisms. Along with this control measure there must be a stabilization standard that sets a limit for the amount of dust that can travel off of the property and the opacity at the site. In Clark County, Nevada these stabilization standards require a site to not exceed 20% opacity and not equal or exceed 0.33 oz/ ft^2 silt loading, or not exceed between 6-8% silt content depending on the type of site. Detroit could impose a strict regulation at the onset or start with an incremental approach to address fugitive dust. These types of regulations also require testing, usually done by environmental engineers or other staff with specific training. Depending on the type of regulation and testing needed, engineers and staff would be required to to be trained in the Drop Ball Test, Rock Test Method, Determination of Threshold Friction Velocity (TFV), Opacity Test Method, and Silt Content Test Method. Even starting with one test like the opacity test method will start the city on a path to curbing fugitive dust.

Active Business/Lot Permits

Another approach to regulation would be to require dust producing businesses to acquire a permit. In Cleveland, businesses must acquire a local air permit to install, modify, or operate any air polluting facility. This type of permit could include stabilization standards that are more easily testable like those set in Alleghany County where dust cannot be visible at or beyond the property line of the source, have an opacity of 20% or more for more than three minutes in any sixty-minute period, or have an opacity of 60% or more at any time. This type of permitting would theoretically help the city put a cap on the amount of fugitive dust produced. However, this type of regulation would not capture the dust coming from the unpaved vacant lots. Some of the unpaved lots in Districts 1 and 2 have some industrial work or scrap work being done on the premises, which would require permits. The owners of the abandoned lots would most likely not seek permits and still produce fugitive dust. The City could also regulate the use of trucks or other heavy machinery on these unpaved lots not using dust palliatives.

Policy Options

Fines

There are a few takeaways that we have learned from the multiple case studies examined from various parts of the country. One of the takeaways is that in order to keep individuals and other entities like businesses from contributing to air pollution it is important to implement some type of fine like it is in the city of Dearbon’s Section 13-5.3 whose repetition ultimately leads to an increase in cost to the offender. In Alleghany County, fines collected through enforcement of fugitive dust policies are put into the Alleghany County Air Pollution Control Fund and Air Quality Fund. These funds are used to study health effects of fugitive dust, create public education campaigns, and pay for the fugitive dust enforcement program.

Community Engagement & Education

Monitoring and deciding who is to blame for how much fugitive dust is being emitted is very difficult to implement and keep track of. One way to keep note of emissions is through Community engagement and education. Hotlines and online complaint forms can be an important tool that the city of Detroit can use in order for its citizens to express their concerns for their health and well being as well as environmental justice. Places like Cleveland, Ohio as well as Clark County, Nevada have been using this strategy and have been seeing benefits. Making it known that these tools are available and making it as easy and quick as possible is key for community involvement. Community engagement may be one of the most important tools that is used in order to locate and therefore address fugitive dust. This can be especially useful in cities where there may be a lack of funding like Detroit. Partnerships with community organizations or local groups who live in areas that are at most risk who understand that they will ultimately be affected by fugitive dust could be a good option. This serves as a good incentive for community engagement because people who are aware that their well being is at risk may be more likely to become engaged or involved in participation. In order for this to work, more public awareness and education is an absolute must.

Recommendations

Following the analysis, prioritization, and policy options, we have compiled recommendations related specifically to what we have seen in Districts 1 and 2. We have also consolidated the policy options to what we recommend Detroit should look at when crafting their own policy. Lastly, we have recommendations for next steps in community engagement and public outreach.

Site Recommendations

After culling through sites on google maps and then through site visits, we have found which areas should be prioritized in the City’s mitigation efforts. Using size, proximity to school, and vulnerable population density, the following clusters of sites should be prioritized (not listed in any particular order):

• Dale and Fenkell Sites

• Schoolcraft and Burt Sites

• M-10 and Livernois Sites

• 8-Mile and Woodward sites

Our original expectation was to submit specific sites that we believed should require immediate remediation by the city. However, instead we found that within Districts 1 and 2 many of our sites were grouped into clusters. Instead of having a couple of very large sites, we instead found groups of smaller parcels that should be prioritized. From these clusters we then narrowed it down depending on what areas were close to schools and in areas with higher density of vulnerable populations. These four clusters could be generally addressed by introduction of policy regulating unpaved lots.

Policy Recommendations

Our policy recommendation is based on our case study work and understanding of the sites within Districts 1 and 2. We understand that sites in other Detroit Council Districts may require a different approach. These recommendations are also made under the assumption that the Building, Safety Engineering, and Environmental Department (BSEED) will have the resources to enforce.

We recommend ground level regulations. These regulations will capture the fugitive dust being produced by both active businesses and vacant lots. This policy should build off of Detroit’s Bulk Storage Ordinance definitions and intent while also broadening it. New policy should create standards that regulate how much fugitive dust is allowed to be produced by these vacant and industrial/auto/scrap facilities. Our recommendation is based on the success of the Clark County, Nevada regulations. Creating stabilization standards and control methods creates a framework that businesses and owners can understand clearly. The multiple tests and exact stabilization standards used in Clark County may be excessive for these districts. Detroit could incrementally work towards these higher standards or could follow the Alleghany County standards. Alleghany County focuses on opacity of 20% or more for more than three minutes in any sixty-minute period, or an opacity of 60% or more at any time. Opacity training is easily available to BSEED staff and other city employees. Opacity testing is not the most precise test and can be affected by weather conditions.

Recommendations

We also recommend creating an enforcement structure that includes fines that are then collected into a fund to be used for more air quality control mechanisms. The fine structure could include increasing amounts depending on the number of violations and time between violations.

Next Steps

We believe that the next steps for site remediation and policy should include community engagement. Residents should be a part of the prioritization process. Their local knowledge could help shape the prioritization scheme and provide feedback to help narrow sites for remediation. It could also be useful to hold public meetings within the districts to allow for residents to express their concerns about fugitive dust or about the regulations. This aspect could be organized by the Detroit Department of Neighborhoods (DONS).

There should be both targeted communication and engagement of owners of industrial property and vacant lots, as well as a more general public education campaign. Depending on the city’s budget, a public education campaign could include television advertisements, radio placements, billboards, social media, and mailed out flyers. Other communities around the country have found success in educating the public about the health concerns related to fugitive dust and then opening up hotlines and online complaint sheets to allow residents to inform the city about areas emitting pollution. Community engagement can enhance the overall fugitive dust programs.

References

References Cited

1. University of Michigan Capstone Project Team. “Breathing Easier in Southwest Detroit: Mitigating Fugitive Dust with Vegetation”. April 2008. Retrieved February 20, 2022, 7-8

2. “Fugitive Dust.” October 2016. Accessed February 24th, 2022.

3. “Particulate Matter (PM) Pollution.” EPA. Environmental Protection Agency, July 14, 2021. https://www. epa.gov/pm-pollution.

4. “Health and Environmental Effects of Particulate Matter (PM).” EPA. Environmental Protection Agency, May 26, 2021. https://www.epa.gov/pm-pollution/health-and-environmental-effects-particulate-matter-pm.

5. Bouffard, K. “Hardships boost asthma rate for Detroit kids”. The Detroit News. March 9, 2016. Retrieved February 20, 2022. https://www.detroitnews.com/story/news/special-reports/2015/12/09/trauma-fuelsdetroit-asthma-rate/77004430/

6. Bouffard, K. “Hardships boost asthma rate for Detroit kids”. The Detroit News. March 9, 2016. Retrieved February 20, 2022. https://www.detroitnews.com/story/news/special-reports/2015/12/09/trauma-fuelsdetroit-asthma-rate/77004430/

7. Bouffard, K. “Hardships boost asthma rate for Detroit kids”. The Detroit News. March 9, 2016. Retrieved February 20, 2022. https://www.detroitnews.com/story/news/special-reports/2015/12/09/trauma-fuelsdetroit-asthma-rate/77004430/

8. Wasilevich, Elizabeth. “Epidemiology of Asthma in Michigan Chapter 12: Detroit ...” Accessed February 24, 2022. https://www.michigan.gov/documents/mdch/14_Ch12_Detroit_Epicenter_of_Asthma_276687_7. pdf.

9. Thompson, Karl. “The Rise and Fall of Detroit.” ReviseSociology. September 20, 2017. Retrieved April 7, 2022. https://revisesociology.com/2017/09/20/rise-fall-detroit-industrialisation/.

10. U.S. Census Bureau. (2019). DP05 Demographic and Housing Estimates.

11. Thompson, Karl. “The Rise and Fall of Detroit.” ReviseSociology. September 20, 2017. Retrieved April 7, 2022. https://revisesociology.com/2017/09/20/rise-fall-detroit-industrialisation/.

12. “Mapping Analysis: Zone Detroit.” Zone Detroit | A Zoning Update for the City’s Resurgence. October 12, 2020. https://zonedetroit.com/2019/01/09/mapping-analysis/.

13. “Mapping Analysis: Zone Detroit.” Zone Detroit | A Zoning Update for the City’s Resurgence. October 12, 2020. https://zonedetroit.com/2019/01/09/mapping-analysis/.

14. “Mapping Analysis: Zone Detroit.” Zone Detroit | A Zoning Update for the City’s Resurgence. October 12, 2020.https://zonedetroit.com/wp-content/uploads/2019/01/2018-12-12_Analysis-Presentation_reduced_ clean_FINAL.pdf

15. “Managing Fugitive Dust,” Michigan Department of Environmental Quality,” https://www.michigan.gov/ documents/deq/deq-ead-caap-genpub-FugDustMan_313656_7.pdf 16.

References

23. Bulk Materials Ordinance, City of Detroit, pp. 27.

24. Bulk Materials Ordinance, City of Detroit, pp. 28.

25. Bulk Materials Ordinance, City of Detroit, pp. 29.

26. Bulk Materials Ordinance, City of Detroit, pp. 32-39.

Bibliography

Alaska Department of Environmental Conservation. “What are Dust Palliatives?” Accessed March 2022. URL: https://dec.alaska.gov/air/anpms/dust/palliatives/.

American Legal Publishing Corporation: “Chapter 257 - Installation and Modification Permits.” Accessed March 22, 2022 CHAPTER 257 - INSTALLATION AND MODIFICATION PERMITS (amlegal.com)

American Legal Publishing Corporation: “Chapter 259 - Operation Permits and Variances.” Accessed March 22, 2022 CHAPTER 259 - OPERATION PERMITS AND VARIANCES (amlegal.com)

Barnes, David and Billy Connor. “Managing Dust on Unpaved Roads and Airports.” Sponsored by Alaska Department of Transportaton Research, Development, and Technology Transfer. Published October 2014. Accessed March 2022.

Bouffard, K. “Hardships boost asthma rate for Detroit kids”. The Detroit News. March 9, 2016. Retrieved February 20, 2022. https://www.detroitnews.com/story/news/special-reports/2015/12/09/trauma-fuels-detroit-asthmarate/77004430/

Bulk Materials Ordinance, City of Detroit, pp. 13.

Cahill Associates Environmental Consultants. “Porous Pavement Operation and Maintenance Protocol.” Prepared for County of San Diego Department of General Services, 2019. Accessed March 2022. URL: https://www. sandiegocounty.gov/reusable_components/images/dgs/Documents/Grants_Prop40_AppendIII_.pdf.

Clark County, NV. Accessed March 23, 2022. https://www.clarkcountynv.gov/government/departments/ environment_and_sustainability/compliance/current_rules_and_regulations.php.

“Clark County, NV.” Data USA. Accessed March 22, 2022. https://datausa.io/profile/geo/clark-county-nv/#economy.

County of Allegheny, Pennsylvania, Ordinance No. 16782, and Allegheny County Health Department Rules and Regulations, Article XXI Air Pollution Control. September 15, 2021.

Data Access and Dissemination Systems (DADS). “American FactFinder – Results”. census.gov. Archived from the original on 2020-02-12.

“Dearborn (city) QuickFacts from the US Census Bureau”. census.gov. Archived from the original on 2014-01-04.

“Detroit Enacts New Ordinance to Protect Residents From Dust Pollution.” Great Lakes Law Blog. https://www. greatlakeslaw.org/blog/2017/11/detroit-enacts-new-ordinance-to-protect-residents-from-dust-pollution.h tml#:~:text=Chicago’s%20regulations%20do%20not%20set,as%20the%20reportable%20action%20level.

Detroit Water & Sewage Department. “Green Stormwater Infrastructure (GSI) Best Management Practice: Permeable Pavement.” Drainage Program Guide, May 2018. URL: https://detroitmi.gov/sites/detroitmi.localhost/ files/2019-06/DCCP%20Site%20App%20-%20Permeable%20Pavement_WEB.pdf.

References

“‘Dusty the Dusthole’ Ads Begin.” Las Vegas Sun, September 25, 2003. https://lasvegassun.com/news/2003/sep/25/dusty-the-dusthole-ads-begin/.

Environmental Protection Agency. “Particulate Matter (PM) Basics.” URL: https://www.epa.gov/pm-pollution/ particulate-matter-pm-basics#effects.

EPA Grants $5.7 Million to Support Electric Buses in Allegheny County.” Bus. June 4, 2021. https://bus-news.com/epa-grants-5-7-million-to-support-electric-buses-in-allegheny-county/. (accessed March 26, 2022).

Ferguson, John H., H. Willard Downs, and Donald L. Pfost. “Fugitive Dust: Nonpoint Sources.” MU Extension, October 1999. Accessed March 2022. URL: https://extension.missouri.edu/publications/g1885. “Fugitive Dust.” October 2016. Accessed February 24th, 2022.

“Health and Environmental Effects of Particulate Matter (PM).” EPA. Environmental Protection Agency, May 26, 2021. https://www.epa.gov/pm-pollution/health-and-environmental-effects-particulate-matter-pm.

MacDougall, Catherine, DeSart, Gregory, Thomsen, Robert, Chamberlain, Alan, and Troy Hildreth. “Evaluating Soil by Particulate Emission Potential.” Accessed March 23, 2022. https://gaftp.epa.gov/air/nei/ei_conference/EI10/fugdust/macdougall.pdf.

Machosky, Michael, et al. “For the First Time, Allegheny County Meets Federal Air Quality Standards at All Eight Air Monitors.” NEXTpittsburgh. January 28, 2021.

https://nextpittsburgh.com/latest-news/for-the-first-time-allegheny-county-meets-federal-air-qualitystandards-at-all eight-air-monitors/. (accessed March 26, 2022).

“Managing Fugitive Dust,” Michigan Department of Environmental Quality,” https://www.michigan.gov/ documents/deq/deq-ead-caap-genpub-FugDustMan_313656_7.pdf

“Mapping Analysis: Zone Detroit.” Zone Detroit | A Zoning Update for the City’s Resurgence. October 12, 2020. https://zonedetroit.com/2019/01/09/mapping-analysis/.

Michigan Department of Environmental Quality. “Managing Fugitive Dust.” Published March, 2016. Accessed March 2022. URL: https://www.michigan.gov/documents/deq/deq-ead-caap-genpub-FugDustMan_313656_7. pdf.

Michigan Department of Environmental Quality. “Guidelines for Selecting Dust Suppressants to Control Dust and Prevent Soil Erosion.” Published 2014. Accessed March 2022. URL: https://www.michigan.gov/documents/deq/ dnre-oppca-factsheet-dustsuppressants_310381_7.pdf.

National Asphalt Pavement Association. “Porous Asphalt Pavements.” Published 2018. Accessed March 2022. URL: https://www.pa-asphalt.org/images/PDF/PS-33_Porous_Asphalt_Pavements.pdf.

Ohio Environmental Council, 21 Apr. 2021, “Organizations Launch Cleveland Comprehensive Environmental Policy Platform.” https://theoec.org/publications/clevelandenviropolicyplatform

Parvej, Subbir, Dayakar L. Naik, Hizb Ullah Sajid, Ravi Kiran, Ying Huang, and Nidhi Thanki. “Fugitive Dust Suppression in Unpaved Roads: State of the Art Research Review.” Sustainability 2021, 13, 2399. URL: https:// doi.org/10.3390/su13042399.

References

“Particulate Matter (PM) Pollution.” EPA. Environmental Protection Agency, July 14, 2021. https://www.epa.gov/ pm-pollution.

“Pollution Map.” Breathe Project, https://breatheproject.org/pollution-map/. (accessed March 26, 2022). Rogers, Keith. “$150,000 AD Blitz Tries to Settle Dust: Campaign Enlists Public in Cutting Pollution.” Las Vegas Review Journal, May 12, 2004. https://web.archive.org/web/20120324101913/http://www.reviewjournal.com/ lvrj_home/2004/May-12-Wed-2004/news/23861369.html.

“Section 90: Fugitive Dust from Open Areas and Vacant Lots .” Clark County Current Rules and Regulations. Accessed March 23, 2022. https://files.clarkcountynv.gov/clarknv/Environmental%20Sustainability/Current%20 Rules%20and%20Regulations/SECT90%2001-21-20.pdf?t=1598389097547&t=1598389097547.

“Section 91: Fugitive Dust from Unpaved Roads, Unpaved Alleys, and Unpaved Easement Roads.” Clark County Current Rules and Regulations. Accessed March 23, 2022. https://files.clarkcountynv.gov/ clarknv/Environmental%20Sustainability/Current%20Rules%20and%20Regulations/SECT91_04-15-14. pdf?t=1647554878807&t=1647554878807

“Section 92: Fugitive Dust from Unpaved Parking Lots and Storage Areas.” Clark County Current Rules and Regulations. Accessed March 23, 2022. https://files.clarkcountynv.gov/clarknv/Environmental%20Sustainability/ Current%20Rules%20and%20Regulations/SECT92_04_15_14.pdf?t=1647554878807&t=1647554878807

“Section 93: Fugitive Dust from Paved Roads and Street Sweeping Equipment.” Clark County Current Rules and Regulations. Accessed March 23, 2022. https://files.clarkcountynv.gov/clarknv/Environmental%20Sustainability/ Current%20Rules%20and%20Regulations/SECT93%2001-21-20.pdf?t=1647554878807&t=1647554878807

“Section 94: Permitting and Dust Control for Construction Activities.” Clark County Current Rules and Regulations. Accessed March 23, 2022. https://files.clarkcountynv.gov/clarknv/Environmental%20Sustainability/Current%20 Rules%20and%20Regulations/SECT94%2001-21-20.pdf?t=1647554878807&t=1647554878807

State of Ohio Environmental Protection Agency Division of Air Pollution Control: Ohio’s 2019 Annual Sulfur Dioxide (SO2) Emissions Review. Accessed March 21, 2022 https://epa.ohio.gov/static/Portals/27/sip/SO2/2019_SO2_ annual_emissions_final.pdf

Thompson, Karl. “The Rise and Fall of Detroit.” ReviseSociology. September 20, 2017. Retrieved April 7, 2022. https://revisesociology.com/2017/09/20/rise-fall-detroit-industrialisation/.

University of Michigan Capstone Project Team. “Breathing Easier in Southwest Detroit: Mitigating Fugitive Dust with Vegetation”. April 2008. Retrieved February 20, 2022, 7-8

U.S. Census Bureau. (2020 ACS 5-Year Estimates Data Profiles). DP05 Demographic and Housing Estimates.

U.S. Census Bureau. (2020 ACS 5-Year Estimates Data Profiles). S1901 Income in the past 12 months (in 2020 inflation-adjusted dollars).

“U.S. Census Bureau Quickfacts: Clark County, Nevada.” Accessed March 23, 2022. https://www.census.gov/quickfacts/fact/table/clarkcountynevada/PST045221.

U.S. Census Bureau Quickfacts: Cleveland City, Ohio. Accessed March 20,2022 https://www.census.gov/ quickfacts/fact/table/clevelandcityohio/PST045221

U.S. Census Bureau Quickfacts: Detroit City, Michigan. Accessed March 20,2022

https://www.census.gov/quickfacts/fact/table/detroitcitymichigan/PST045221

U.S. Census Bureau Quickfacts: Michigan. Accessed March 20,2022

https://www.census.gov/quickfacts/fact/table/MI/PST045221

U.S. Census Bureau Quickfacts: Ohio. Accessed March 20,2022

https://www.census.gov/quickfacts/fact/table/OH/PST045221

U.S. Census Bureau Quickfacts: United States. Accessed March 20,2022

https://www.census.gov/quickfacts/fact/table/US/PST045221

U.S. Salt. “Calcium Chloride.” Accessed March 2022. URL: https://ussalt.com/info/ice-melters/calcium-chloride/. “Vegas Area Poised to Get EPA Clean-Air Designation this Month.” Sunday Gazette - Mail, Oct 05, 2014.

https://proxy.lib.umich.edu/login?url=https://www.proquest.com/newspapers/vegas-area-poised-get-epaclean-air-designation/docview/1588781495/se-2?accountid=14667.

Waddoups, Jeff. “Clark County Profile,” Las Vegas Metropolitan Area community Indicators. (UNV, Las Vegas). https://cber.unlv.edu/publications/Demographics.pdf.

Wasilevich, Elizabeth. “Epidemiology of Asthma in Michigan Chapter 12: Detroit ...” Accessed February 24, 2022. https://www.michigan.gov/documents/mdch/14_Ch12_Detroit_Epicenter_of_Asthma_276687_7.pdf.

Watchdog Report: No Official Explanation for Emissions Issues at U.S. Steel’s Edgar Thomson Plant despite Known Violations & Compliance Plan Promises: Group against Smog and Pollution.” Pgh.org, https://gasp-pgh.org/2020/07/09/watchdog-report-no-official-explanation-for-emissions-issues-at-u-s-steelsedgar-tomson-plant-despite-known-violations-compliance-plan-promises/. (accessed March 26, 2022).

Wittlinger, Edward. “Air Quality - Permitting.” Air Quality - History, Accessed March 20, 2022, https:// clevelandhealth.org/programs/air/history

Sites in Clusters

Sites in Clusters, Continued

Site Visit Notes

Please see images from site visits below as examples of the types of sites and unpaved areas we have discussed in this report.

Our Team

Ellison Hersch is pursuing a Master of Urban and Regional Planning and Juris Doctorate at the University of Michigan. She previously worked at Bilzin Sumberg, a Miami law firm, as a project assistant working on land use and government relations cases. She is interested in community development, transportation, and land use. She has a B.A. in Government and Latin American Studies from Smith College.

Marco Dominguez is pursuing a Master of Urban and Regional Planning at the University of Michigan. He is currently working for Geode Environmental, a Southern California based Environmental planning firm. His interests are in land use, real estate development, zoning, and housing issues. He received his B.A. in Economics from the California State University, San Marcos.

Maria Garcia Reyna is pursuing a Master of Urban and Regional Planning at the University of Michigan. She is interested in community development, transportation, and land use. She has a B.S. in Architecture and Environment Minor from the University of Michigan.

Maya Baker is pursuing a Master of Urban and Regional Planning at the University of Michigan. They previously worked for Aligned Planning, a consulting firm in Grand Rapids, Michigan. Their focus is on housing, real estate development, and policy. They have a B.A. in Sociology from DePaul University.

Vishnupriya Napa Ravikumar is pursuing a dual Master’s degree in Urban and Regional Planning, and Urban Design. She is also pursuing the Urban Informatics Certificate. She previously worked with Chennai Resilience Centre, a unit of the Arienne Arsht Rockefeller Foundation Resilience Centre, and Global Resilient Cities, in Chennai, India. She is also involved with an urban tech project that has recently won two grants from ArtsEngine. She is passionate about urban technology, collaborative planning, and interdisciplinary research. She has a Bachelor of Architecture degree from Anna University, Chennai, India.