Comments on “Impact of California’s Air Pollution Laws on Black Carbon and their Implications for Direct Radiative Forcing” by R. Bahadur et al.

Using data from the Interagency Monitoring of Protected Visual Environments (IMPROVE) program, Bahadur et al. (2011) report that average fine particulate light absorbing carbon (LAC) concentrations in California decreased by about 50% from 0.46 μg m-3 in 1989 to 0.24 μg m-3 in 2008. They attribute most of the LAC decline in California to reductions in the state’s diesel emissions. These findings are encouraging, but in this comment we call attention to a significant methodological issue that can arise in any long-term trends analysis using IMPROVE data. In the Bahadur et al. analysis, LAC data from eighteen remote monitoring sites were aggregated with data from three urban sites that only operated for 1–8 years. The large absolute decrease of 0.22 μg m-3 they reported in the statewide California average was largely driven by one urban site, South Lake Tahoe (Tahoe), which was dropped from the network in mid-1997. LAC concentrations at Tahoe were an order of magnitude higher than those at nearby Bliss State Park indicative of large local source contributions. The exclusion of the three locally influenced urban sites substantially reduces the magnitude of the decreasing LAC trends shown in Bahadur et al., though this does not necessarily invalidate the paper’s conclusion that LAC is broadly decreasing and diesel emission controls are likely to be responsible for part of this decrease. Control of emissions from wood-burning stoves may also have contributed to decreases in LAC and other particulate compounds; like diesel emission controls, this too is an important regulatory success.