By: Rachel Meyer, Ohio River Valley Coordinator, Moms Clean Air Force
Date: February 22, 2023
About: Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2015-0072
To: Environmental Protection Agency
My name is Rachel Meyer, and I am the Ohio River Valley Field Coordinator for Moms Clean Air Force, an organization of over 1.5 million people committed to protecting children’s health from the impacts of climate change and air pollution. Thank you for the opportunity to testify about the proposed particle pollution standards.
I am grateful that the EPA is looking at improving the annual standard, and I ask you to go a step further. I am asking the EPA to follow the science and set a more health protective standard for soot of 8 micrograms per cubic meter for the annual standard and 25 micrograms per cubic meter for the daily standard. Both long-term and short-term exposure to soot pollution affects our lungs, hearts, brains, and other body systems and can cause premature death, hospitalizations, and emergency room visits for respiratory and cardiovascular illness.
I live in Southwestern Pennsylvania, where there is an ethane cracker plant manufacturing plastic. This plant alone is permitted to emit up to 163.7 tons of PM 2.5 annually and is on track to exceed that amount just as it has already exceeded its annual limits for both VOCs and NOx emissions. Before this plant even became operational, our region was ranked as the 14th worst for year-round particle pollution by the American Lung Association.
I have asthma. Probably not surprisingly, I was diagnosed after living in Oakland and San Francisco, California, which the ALA has ranked as the 4th most polluted area for both year-round and short-term particle pollution. Here in the Pittsburgh region, I have continued to have problems with my asthma. While it cannot be said for sure whether particle pollution caused it, studies show that soot can aggravate asthma.
The ethane cracker plant is newly operational but has already had multiple flaring events during which thick black smoke billows from flames hundreds of feet high. These events go on for hours, often lasting through the night. Besides worrying about the long-term consequences of being exposed to the high levels of particulate matter in my region day after day, I worry about the consequences of the short-term high levels of exposure. Our region was already ranked the 22nd worst for short-term particle pollution cities by the American Lung Association before the ethane cracker plastic factory was operational.
Spikes in daily soot pollution can result in acute health impacts during or soon after a day of poor air quality, such as asthma attacks and hospitalization for respiratory and cardiovascular disease. On days when the plant is flaring, I hesitate to go outside out of concern that I might have an asthma attack but mostly out of concern for my three-year-old daughter. Children are more vulnerable to air pollution. What makes me most upset is the fear of worsening my three-year-old daughter’s chances of developing healthy lungs. The 24-hour standard must be strengthened to protect children and families like mine.
Strengthening the annual standard matters too: an annual standard of 8 micrograms per cubic meter could prevent 46,000 emergency department visits for pediatric asthma each year. (Analysis of PM2.5-Related Health Burdens Under Current and Alternative NAAQS, Industrial Economics)
I am urging the EPA to set a more protective standard for soot of 8 micrograms per cubic meter for the annual standard and 25 micrograms per cubic meter for the daily standard. Stronger standards for both annual and daily limits are necessary to protect our health. Thank you.