Comment Log Display

Thank you for the opportunity to provide comment on behalf of the
members of the Pacific Merchant Shipping Association (PMSA) to the
CARB TRU Preliminary Health Analysis. Our members include ocean
carriers who own or lease and operate TRU gensets and refrigerated
intermodal ocean containers, as well marine terminal operator who
receive, deliver and garage this equipment on behalf of the ocean
carrier.

While we reserve the right to provide further comment on both the
TRU Emissions Inventory and Health Analysis at a later date, our
comment today is in regards to cancer risk assessments put forward
at the October 31 workshop in Sacramento. Specifically, ARB needs
to more clearly demonstrate the validity of assessing cancer risk
at proximities close to emission sources.

The model estimates presented provide for residential exposure
cancer risk levels at proximities as close as 0 meters, with
incremental risk levels provided for subsequent proximities of 10,
25, 50, 75, 100 150, 200 and upwards to 800 meters from source.
Modeling of cancer risk is inherently less accurate at closer
proximities, and previous risk modeling used more distant proximity
metrics of 200 meters or greater. Furthermore, it is inappropriate
to be using Residential Receptor, exposure durations at distances
closer to emission sources than where residential housing is or
would be situated.

We believe that ARB should restrict their modeling to greater
distances to enable more accurate predictions. This is further
supported by ARB guidelines and typical city and county land use
requirements that suggest or stipulate buffer zones greater than
those used in this model.