By: Brooke Petry, Pennsylvania State Coordinator, Moms Clean Air Force
Date: May 16, 2023
About: Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2022-0730-0001
To: Environmental Protection Agency
Thank you for the opportunity to testify. My name is Brooke Petry. I am a State Coordinator for Moms Clean Air Force, and I live in Philadelphia with my family. I strongly support the proposed chemical manufacturing rule and call on EPA to finalize the most protective and comprehensive standards possible.
There are 2 facilities in Pennsylvania that will be covered by the EPA’s proposed rule. One of them, AdvanSix Inc, is located here in Philadelphia, about 7 miles from my front door. The compliance status for AdvanSix is listed at “High Priority Violation”—and the facility was out of compliance for 11 of the last 12 quarters.
The petrochemical industry creates a signiﬁcant climate-warming greenhouse gas pollution while simultaneously releasing a host of toxic pollution known to impact health. As a person with asthma, and as the parent of an asthmatic child, the real impact of polluted air is truly never far from my mind. There is no fear quite like watching your child struggle to breathe and knowing that you may not be able to help them.
Children are especially vulnerable to petrochemical air pollution since their bodies are still developing, and because children breathe in more air for their size than adults. Breathing in more air can mean breathing in more air pollution.
Knowing that, I want you to picture the area where the noncompliant AdvanSix facility is located. Within one mile, you’ll find a rec center, 2 playgrounds, and 4 schools. Think about what these children are breathing into their little lungs on their walks to and from school or while playing at the park with friends. Add to that the fact that the childhood asthma rate in Philadelphia is a staggering 21%. Children living near this facility need the EPA to propose and enforce the strongest possible protections so they have a fair chance at a healthy life.
The AdvanSix facility, like many of its kind, is located where the majority of the residents are people of color and low wealth. In the shadow of I-95 and having borne a disproportionate burden of pollution for generations, this community is deserving of strong protection from the hazardous chemicals being spewed into their air.
I support EPA’s first ever efforts to analyze air toxics risks at the community level that consider the cumulative toxic emissions of nearby polluters, and I encourage the EPA to link the findings in the community risk assessment more directly to the regulatory requirements in the rule.
The EPA must also use the latest, most advanced monitoring technology available to protect communities, and every facility covered by these rules should have fenceline monitors as a requirement. Specifically, we support the implementation of precedent-setting fenceline monitoring for six toxic air pollutants, and we encourage EPA to lower detection limits and lower the action levels at the fenceline to be more protective of people’s health.
With ever strengthening storms like Hurricane Ida impacting our city, I fully support the removal of exemptions for all startup, shut down, and malfunction episodes at these facilities so that companies no longer get a free pass to pollute during maintenance operations, hurricanes, and other events.
We need enhanced leak detection and repair protocols for all hazardous chemicals across all covered facilities. EPA needs to revise the leak standards for all toxic chemicals at all facilities to meaningfully protect the health of families and communities.
Petrochemical manufacturing is one of the heaviest polluting industrial sectors in the country. I strongly support the proposed chemical manufacturing rule and call on EPA to finalize the most robust and comprehensive standards to reduce air pollution from petrochemical facilities that are harming people’s health and heating the climate.