Tuesday, January 12, 2010

GASP: State Implementation Plan to Clean Up the Liberty-Clairton Area now Available for Public Comment

The Clean Air Act requires the Allegheny County Health Department to create a State Implementation Plan (SIP) to show how it will bring the Liberty-Clairton area (made up of Clairton, Glassport, Liberty, Lincoln, and Port Vue) into compliance with the federal health-based standards for fine particulate matter (PM 2.5).

This SIP is now available for public comment. Let ACHD know you want a strong plan that will clean up our air sooner rather than later. (You may recall that the poor air quality in the Liberty-Clairton area is a big contributor to Pittsburgh's consistently poor national air quality rankings) More information on some shortcomings of the SIP below.

Jan. 14 Public Hearing
The Allegheny County Board of Health will hold a public hearing on Thursday, January 14, 2010, at 6:30 PM at the Clairton Municipal Building, 551 Ravensburg Boulevard, Clairton PA, 15025 (maps and directions)

Oral testimony must be pre-scheduled by calling 412-578-8008 no less than 24 hours in advance of the public hearing. Speakers will be limited to five minutes and should bring a written copy of their comments.

GAST is coordinating a carpool from Squirrel Hill for those who'd like to share a ride to the hearing. If you are interested contact bryan@gasp-pgh.org by Tuesday, Jan. 12th.

Written Comments
ACHD will also accept written comments on the SIP

by email: BOH@achd.net

by mail:
Board of Health,
3333 Forbes Avenue
Pittsburgh, PA 15213

by fax: 412-578-8325.

Please let us know at joe@gasp-pgh.org if you plan to attend the public hearing or submit written comments.

About PM 2.5
PM 2.5 consists of microscopic solid or liquid particles; most of these particles result from the burning of fossil fuels. PM2.5 has been linked to a number of negative health effects including asthma, stroke, heart attack, lung cancer, and premature death.

About the SIP
The Clean Air Act requires ACHD and many other state and local air quality agencies to create SIPs to bring areas where the air is unhealthy into compliance with federal health-based air quality standards. Right now most state and local agencies, ACHD included, are developing SIPs to meet standards for PM 2.5 that were set back in 1997. Based on better data on PM 2.5 effects on human health, EPA established a lower PM 2.5 standard in 2006, but ACHD (along with other state and local air quality agencies) are still working on SIPs to meet the unhealthy 1997 standards. Tell ACHD its SIP must meet the improved 2006 PM 2.5 standards.

The deadline to meet the PM 2.5 standards is April 5, 2010; however, ACHD's draft SIP would make use of every available opportunity to stretch out that deadline. Under ACHD's proposal, their attainment date would be extended 5 years to April 5, 2015, and even then ACHD proposes to make use of another extension provision to allow themselves to wait until April 5, 2016 to provide enough air monitor data for EPA to make a final determination that the PM 2.5 standards have been meet. In other words, 6 years after the standard attainment deadline, ACHD's plan would bring the Liberty-Clairton area into attainment with an air quality standard that is 19 years old and 11 years out of date! Tell ACHD we can't afford to wait until 2016 to breathe clean, healthy air.

It gets worse: To meet even its much-extended deadline, ACHD's air monitors in the Liberty-Clairton area must record its first of 3 consecutive years of data at or below the PM 2.5 standards in the year 2014 at the very latest. But according to ACHD's own numbers, their plan for cleaning up the air in Liberty-Clairton area won't obtain its first year of data at or below the PM 2.5 standards until 2016. After using every trick in the book to extend its SIP due date, ACHD's plan would still be late. Tell ACHD their plan can't just propose a deadline, it has to meet it, too.

In short ACHD's final SIP must:
Aim to meet or exceed the updated 2006 PM 2.5 standards, not the outdated 1997 standards.
Set its attainment deadline as soon as possible, not six years later than the normal attainment deadline.
Actually meet whatever attainment deadline it sets.

More information:
The Liberty Clairton SIP [PDF]
General Particulate Matter Information from EPA
EPA's Clean Air Fine Particle Implementation Rule [PDF] -- a lengthy technical document describing the PM 2.5 SIP requirements

If you have any questions contact GASP's Legal Director, Joe Osborne at joe@gasp-pgh.org
PA Environmental Quality Board seeks comments on controlling particulate matter emissions from outdoor wood-fired boilers (OWBs)
The deadline for submitting comments has been extended until February 12, 2010. GASP will provide talking points in the near future.

A significant and growing source of PM2.5 emissions in Pennsylvania is from OWBs. OWBs, also referred to as outdoor wood-fired furnaces, outdoor wood-burning appliances, or outdoor hydronic heaters, are free-standing fuel-burning devices designed: (1) to burn clean wood or other approved solid fuels; (2) specifically for outdoor installation or installation in structures not normally intended for habitation by humans or domestic animals, such as garages; and (3) to heat building space or water by means of distribution, typically through pipes, of a fluid heated in the device, typically water or a water and antifreeze mixture. OWBs are being sold to heat homes and buildings and to produce domestic hot water.

The emissions, health effects and the nuisance factor created by the use of OWBs are a major concern to the PA DEP. The Northeast States for Coordinated Air Use Management has conducted stack tests on OWBs. Based on the test results, the average PM2.5 emissions from one OWB are equivalent to the emissions from 205 oil furnaces or as many as 8,000 natural gas furnaces. Cumulatively, the smallest OWB has the potential to emit almost 1 1/2 tons of PM every year. Of the estimated 155,000 OWBs sold Nationwide between 1990 and 2005, 95% were sold in 19 states, of which PA is one. Unlike indoor wood stoves that are regulated by the EPA, no Federal standards exist for OWBs and the majority of them are not equipped with pollution controls.

For more information: http://www.pabulletin.com/secure/data/vol39/39-42/1929.html

Written Comments -- interested persons are invited to submit comments, suggestions or objections regarding the proposed regulation to the Environmental Quality Board, P.O. Box 8477, Harrisburg, PA 17105-8477. Comments may also be submitted electronically at BoardatRegComments@state.pa.us. Comments, suggestions or objections must be received by the Board by February 12, 2010.

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