By: Vanessa Lynch, Pennsylvania State Coordinator, Moms Clean Air Force
Date: February 21, 2023
About: Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2015-0072
To: Environmental Protection Agency
My name is Vanessa Lynch, and I am a State Coordinator for Moms Clean Air Force in Pennsylvania. I live in Pittsburgh, Pennsylvania, which is located in Allegheny County. While I appreciate EPA’s consideration of more protective soot safeguards, I am also here today urging EPA to 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.
Allegheny County had been a fine particle pollution nonattainment area for many years. Although much work has been done to clean up our air, the Clairton Coke Works, Edgar Thomson Steel Works, and now the Shell petrochemical plant are all major contributors to our poor air quality. Allegheny County is in the top 2% of cancer risks due to air pollution in the country. The legacy of sustained industrial air pollution has had lasting impacts for our families.
While I am thankful EPA has taken some steps to make its soot rule more protective than it was previously, the lack of change on the 24-hour standard is particularly concerning. As southwest Pennsylvania seems doggedly determined to create a petrochemical hub in the Ohio River Valley, those of us who live here know two things: (1) Burning more fossil fuels will create even more health risks to frontline communities. (2) Our climate goals cannot carry the burden of continued negligence around air pollution. To not even propose a change in the 24-hour standard disregards the frontline experiences of so many families who can’t breathe the air in their own neighborhood because of high pollution days and weather inversions in our river valley.
With the Liberty air monitor reaching as high as 51 µg/m3 on numerous occasions in 2021, the 24-hour standard cannot be ignored. According to the American Lung Association, communities of color, like those near the Clairton Coke Works in Pennsylvania, are disproportionately exposed to higher-than-average levels of soot. 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. For these communities, EPA’s proposal won’t adequately address disparities in soot-related health impacts. EPA’s independent expert science advisors recommended standards stronger than what the agency has proposed.
I am urging EPA to 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. Pennsylvania is one of the top 10 states for deaths from particle pollution per capita in the US. Soot standards present a real opportunity to impact the lives of Pennsylvania families if we seize this moment for bold action.