Concerns Reference Materials

Complete consideration of the Costco Special Exception application involves analysis of a great deal of reference material that we (and others) have accumulated over the nearly three years that this controversial project (the mega gas station proposed for Westfield Wgeaton Mall) has been under consideration.

Although many of the references cited below are relevant to several different topics, we have chosen to group them under the headings of the 'CONCERNS' listed on the page of that name on our website. Within each such section, published articles are listed by publication date (in reverse chronological order), while Websites are listed roughly in the order that we believe puts the most useful at the top of the list.


New Court Ruling - On January 4, 2013, the US Court of Appeals for the District of Columbia issued a new and important ruling on the PM 2.5 regulations. While the case is complex, the bottom line is that EPA must review, revise and reissue its rules on fine particulates. This is one more piece of evidence in a growing chain that Costco cannot meet the burden of proving that its proposed station will not endanger the health, safety and welfare of neighbors, employees and customers.

E.P.A. Sets a Lower Limit for Soot Particles in the Air - This New York Times article (14 December 2012) includes the following: 'The E.P.A. based its action on health studies that found that exposure to fine particles in this case measuring 2.5 micrometers in diameter brought a marked increase in heart and lung disease, acute asthma attacks and early death. Older people, adults with heart and lung ailments and children are particularly susceptible to the ill effects.'

The impact of BTEX emissions from gas stations into the atmosphere - Published in 2012, this study (done in Brazil) shows the risks from benzene, toluene, ethyl benzene, and xylene in emissions from standard size gas stations are a significant risk to people as far away as 500 feet from the stations.

EPA Proposes Clean Air Standards for Harmful Soot - This article appeared in June, 2012 and provides some hope for action that would protect our health and our environment.

Scientists Increasingly Link Vehicle Exhaust With Brain-Cell Damage, Higher Rates of Autism - Go here to read a Wall Street Journal article (November 2011) on the health risks associated with high levels of automobile exhaust due to traffic jams and cars idling.

The Environmental Protection Agency's Community-Focused Exposure and Risk Screening Tool (C-FERST) and Its Potential Use for Environmental Justice Efforts - Published in 2011, this article discusses a systematic method for assessing risk, from any environmental source, to a community.

Particulate Matter Air Pollution and Cardiovascular Disease: An Update to the Scientific Statement From the American Heart Association - This article appeared in the May, 2010 on-line issue of the journal Circulation.

Public Health Statement for Benzene - Go here to read an August, 2007 report on the toxic effects of the benzene found in automobile exhausts.

'The concentration of VOCs near the gasoline stations without vapor recovery systems are about 7.3 times higher than those around the gasoline stations having the recovery systems'. - So concludes a Chinese research study published in 2006. (VOCs are volatile organic compounds - like benzene.) This raises the question of what type of recovery will be in place around the proposed Costco mega station and how well it can address the much larger environmental load than that which existed in the situation studied by the Chinese researchers.

The California Air Pollution Control Officers Association Toxics Committee Report - This 1997 report is a comprehensive analysis of the steps that must be taken to reduce levels of toxic volatiles, like benzene, escaping from gas station tanks, pumps, etc. NOTE: This article (like the Chinese study cited above) does not address the exhaust from cars waiting, with engines idling, to fuel-up; nor does it (or the Chinese study) cover non-volatile pollutants (like the microfine particles that recent EPA rulings - cited at the top of this listing - address) which cause health risks other than, or in addition to, those caused by VOCs.

AIR QUALITY AND LAND USE HANDBOOK: A COMMUNITY HEALTH PERSPECTIVE - In 2005 the California Environmental Protection Agency of the California Air Resources Board published this document, which is still used by many locales to guide judgements as to air quality risks connected with various land use policies. We urge you to look at the Summary and the specific recommendations. In particular, this study is most often used to justify decisions (such as the one made when Montgomery County Council passed the modified version of ZTA 12-07) to require a buffer zone of 300 feet between large gas stations and 'sensitive land uses'. What is not usually recognized is that the gas station that Costco proposes to site in Westfield Wheaton Mall is a mega gas station (some use the term hyper gas station): it will be dispensing nearly 4 times as much gas as what this California study defined as a large gas station. That is why the original version of ZTA 12-07 stipulated a 1000 foot buffer and why citizen activists were so disappointed when the Council capitulated to Costco's (and the County Executive's) pressure and reduced the buffer zone to only 300 feet.

Ambient Air Pollution: Health Hazards to Children - This article, published in the journal Pediatrics in 2004, recognized the danger to health - especially of children - posed by particulate air pollutants. It is a sad commentary on our decision-making processes that only now, after a decade of accumulating evidence, has the EPA issued more adequate regulatory guidlines on soot (a term often used to include microfine particles and other particulate pollutants). We urge you to, at a minimum, read the abstract at the beginning of this article.


Traffic Impact Analysis - This is a useful, and readable, explanation of what is involved in analyzing the impact - on traffic/congestion - of any given land use. Such analyses are complex and subject to multiple 'conclusions'. But consider this: once a decision is made to allow a particular land use (such as Costco's proposed mega gas station), if that decision is a 'mistake', it is nearly impossible to 'fix' the mistake!

Projected Congestion if Costco's Mega Gas Station Is Allowed to Open - download a PowerPoint presentation (text and pictures) explaining how the proposed siting and mode of operation of the gas station will create a great deal of congestion within the Mall, and how the effects of that congestion will impact the neighborhood.


A Web of Waivers and Exemptions Threatens Wheaton's Green Forested Buffer - The Audubon Naturalist Society blogged (January, 2012) its strong objection to the exemption granted Costco by a County establishment determined to have the mega gas station proposal go forward.

Anti-idling Regulations - Numerous studies have recognized the problems inherent in situations where cars/trucks idle for significant periods of time, thus spewing out increased levels of exhausts/pollutants. This site gives an overview of existing anti-idling regulations. A careful examination of such regulations reveals that they are too lenient and/or almost unenforceable.


Montgomery County Noise Control Rules and Procedures - Have you ever tried to get the County to enforce these rules?

Noise Pollution Clearinghouse - A general source for information on definitions of noise pollution, EPA regulations, etc.



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Last modified: Sunday, February 3, 2013