1
http://
healthandenergy.
com/
soot_
lungs_
and_
heart.
htm
2
An
Association
Between
Fine
Particles
and
Asthma
Emergency
Department
Visits
for
Children
in
Seattle.
Environ
Health
Perspect
107:
489­
493.1999
November
4,
2004
Makeba
Morris,
Branch
Chief
of
Air
Quality
Planning
Linda
Miller,
PM2.5
Coordinator
EPA
Region
III,
3AP21
1650
Arch
St.
Philadelphia,
PA
19107
Dear
Ms.
Morris
and
Ms.
Miller,

On
behalf
of
the
Group
Against
Smog
and
Pollution
(
GASP)
and
the
following
community
leaders
and
representatives
of
environmental,
health
and
civic
organizations
who
have
undersigned
this
letter,
we
respectfully
submit
the
following
concerns
regarding
the
PM2.5
designation
of
Allegheny
County.

We
oppose
the
creation
of
two
additional
non­
attainment
areas
(
i.
e.
the
Liberty
Borough/
Clairton
and
North
Braddock
areas)
within
the
Allegheny
County
non­
attainment
area
for
several
reasons.
While
we
do
recognize
the
severe
PM2.5
problem
in
these
two
smaller
areas,
the
county
as
a
whole
has
serious
air
quality
issues,
including
the
PM2.5
difficulty
that
must
be
addressed
to
protect
the
health
of
local
residents.
The
best
way
to
address
our
region's
PM2.5
crisis
is
to
move
ahead
as
one
non­
attainment
region
aggressively
seeking
attainment,
by
incorporating
control
technologies
on
industries
that
contribute
to
our
PM2.5
problem
and
reducing
emissions
from
transportation
sources.
For
the
following
reasons
we
oppose
the
creation
of
these
two
sub­
non­
attainment
areas:

1.
There
is
no
indication
that
creating
two
additional
non­
attainment
areas
will
improve
the
quality
of
air
in
Allegheny
County
or
the
region.
A
plan
with
separate
designations
will
not
lessen
the
suffering
of
local
asthmatic
children;
it
will
not
decrease
emergency
room
visits
by
the
elderly;
and
it
will
not
enhance
the
lives
of
those
with
respiratory
disease.

Researchers
from
New
York
University
School
of
Medicine
and
Brigham
Young
University
found
that
the
number
of
deaths
from
lung
cancer
increases
by
eight
percent
for
every
10
micrograms
of
fine
particulate
matter
per
cubic
meter.
1
University
of
Washington
investigators
found
exacerbation
of
asthma
evident
even
when
daily
PM2.5
concentrations
were
substantially
below
the
newly
adopted
National
Ambient
Air
Quality
Standard
of
15
µ
g/
m3
annually.
2
GROUP
AGAINST
SMOG
&
POLLUTION,
INC.
PO
Box
5165,
Pittsburgh,
PA
15206
 
Phone
(
412)
441­
6650
More
than
half
of
the
monitors
in
Allegheny
County
had
a
PM2.5
design
value
in
2003
at
or
above
the15
µ
g/
m3
standard,
set
by
the
EPA
in
1997.
The
other
monitors
are
not
far
below
the
standard.
The
PM2.5
standard
of
15
µ
g/
m3
does
not
protect
the
public
from
all
the
harmful
health
effects
caused
by
breathing
in
fine
particulates.
For
these
reasons
we
must
strive
to
bring
all
monitor
readings
as
far
below
the
standard
as
possible,
through
use
of
maximum
achievable
control
technology
at
facilities
that
pollute.
Any
designation
plan
that
will
delay
clean­
up
or
create
even
worse
"
hotspots"
of
pollution
must
be
rejected
for
a
plan
that
will
combatively
battle
poor
air
quality.

2.
The
DEP
has
described
the
Liberty
Borough,
Clairton
and
North
Braddock
vicinities
as
having
unique,
local
PM2.5
problems
that
will
require
the
development
of
highly
particular
local
solutions
in
addition
to
regional
controls
applied
throughout
the
area
to
control
the
PM2.5
problem.
We
do
not
disagree
that
a
combination
of
regional
controls
and
specific
local
solutions
will
be
necessary
to
lower
PM2.5
in
Allegheny
and
surrounding
counties.
However,
it
is
not
clear
that
a
special
non­
attainment
area
will
result
in
the
facilities
in
these
areas,
(
i.
e.
Clairton
Coke
in
the
Liberty
Borough/
Clairton
area
and
Edgar
Thomson
Work
in
the
North
Braddock
area)
lowering
their
pollution
sooner
than
if
they
were
designated
in
non­
attainment
with
the
rest
of
the
county.
It
is
not
discernible
what
the
full
effects
of
isolating
these
facilities
and
the
communities
surrounding
them
will
do.
Which
differing
types
of
strategies,
if
any,
the
Allegheny
County
Health
Department,
the
primary
air
quality
enforcement
agency,
will
apply
to
clean
up
these
other
non­
attainment
areas
is
also
not
apparent.
We
do
not
want
to
set­
up
a
situation
that
allows
Clairton
Coke
and
Edgar
Thomson
to
receive
extensions
or
modifications
to
their
requirements
if
they
fail
to
meet
attainment
by
the
deadline,
while
Allegheny
County
and/
or
the
region
are
placed
in
attainment
status.
The
air
quality
situation
in
the
Liberty/
Clairton
and
Braddock
areas
is
so
dire
that
delaying
clean­
up
of
fine
particles
for
any
longer
will
be
to
the
detriment
of
not
only
residents
of
those
areas,
but
to
the
entire
county
and
surrounding
counties
downwind
of
these
areas.

3.
Environmental
Justice
issues
 
The
populations
of
Braddock
and
Liberty/
Clairton
have
already
suffered
serious
health
hazards
from
the
local
facilities.
We
do
not
support
a
designation
that
will
cause
further
environmental
or
economic
harm
to
these
areas.
A
PM2.5
designation
plan
that
separates
out
the
most
polluted
areas
and
labels
these
areas
as
the
"
black
sheep"
of
the
county
will
only
increase
the
environmental
and
economic
hardships
that
already
exist
in
these
areas.
We
do
not
want
to
see
a
situation
created
where
economic
downturns,
increased
health
care
costs
due
to
exposure
to
PM2.5,
and
decreased
quality
of
life
is
perpetuated.
The
most
promising
designation
plan
will
take
all
Allegheny
County
communities
into
account,
and
will
especially
look
for
ways
to
protect
our
most
vulnerable
populations:
children,
elderly,
those
with
respiratory
and/
or
cardiac
problems,
and
those
who
have
grown
up
in
environments
with
poor
air
quality.

4.
During
inversions
air
quality
will
not
only
be
poor
in
the
Clairton/
Liberty
and
Braddock
areas
but
also
in
the
surrounding
towns,
which
receive
pollution
from
these
areas.
GASP
receives
intermittent
odor/
air
quality
complaints
from
those
living
outside
Liberty/
Clairton
and
Braddock,
including
Westmoreland
county
residents,
who
receive
air
pollution
from
these
proposed
sub­
designation
areas.
Additionally
we
know
that
PM2.5
travels
long
distances.
The
imaginary
bubbles
placed
around
the
Clairton/
Liberty
and
Braddock
areas
will
not
encapsulate
pollution;
the
PM2.5
will
travel
to
areas
like
McKeesport,
which
is
sandwiched
between
both
areas.
When
the
other
areas
of
Allegheny
County
reach
attainment
there
will
certainly
still
be
days
of
acute
air
pollution
wafting
over
from
the
remaining
non­
attainment
areas.

5.
The
entire
scope
of
health
and
environmental
effects
from
PM2.5
are
not
fully
known,
and
this
is
the
first
time
designations
are
being
formulated.
The
concept
of
a
smaller
non­
attainment
area
within
a
larger
non­
attainment
county
and
region
is
unprecedented.
The
EPA
should
err
on
the
side
of
caution,
on
the
side
of
human
health
and
on
the
side
of
the
environment.
Because
we
are
still
learning
the
effects
of
exposure
to
poor
air
quality
EPA
should
act
in
a
preemptive
manner.
It
is
better
to
loosen
restrictions
after
reaching
lower
levels
of
PM2.5,
than
to
institute
a
mechanism
that
has
the
potential
of
not
quickly
or
adequately
addressing
the
current
air
pollution
problems.
6.
Southwestern
Pennsylvania
has
endured
decades
of
pollution
emitted
from
area
facilities,
particularly
coalfired
power
plants.
These
stationary
sources
of
pollution
contribute
substantially
to
the
level
of
PM2.5
in
their
individual
counties
and
regionally,
putting
hundreds
of
thousands
of
unsuspecting
individuals
at
risk
of
serious
health
problems,
even
when
they
live
miles
from
a
facility.
For
this
reason,
EPA
should
maintain
its
original
proposed
list
of
counties
to
be
designated
as
non­
attainment.
By
including
Armstrong,
Butler,
Greene,
Indiana
and
Lawrence
counties
in
the
regional
non­
attainment
area,
the
region
will
be
forced
to
address
its
air
quality
as
a
whole
and
move
towards
attainment
more
quickly.
Excluding
these
counties
will
serve
only
to
place
restrictions,
and,
consequently,
blame,
on
part
of
the
problem.
EPA
should
address
the
region's
air
quality
as
a
whole,
rather
than
acting
as
though
fixing
part
of
the
problem
will
protect
the
entire
region's
air
and
population.
EPA's
own
regulations
state
that
non­
attainment
areas
are
those
areas
with
air
quality
levels
exceeding
the
standards,
plus
nearby
areas
contributing
to
such
violations.

We
sincerely
hope
you
will
take
into
account
all
of
these
considerations
when
making
a
final
determination
on
the
designation
of
attainment
and
non­
attainment
for
PM2.5
in
Allegheny
and
surrounding
counties.
It
is
imperative
that
the
air
in
southwestern
Pennsylvania
be
cleaned
up;
for
the
health
of
our
children,
the
future
economic
viability
of
the
region,
and
the
preservation
of
the
local
environment.

Sincerely,

Rachel
Filippini
Executive
Director
Group
Against
Smog
&
Pollution,
Inc.
(
GASP)

John
Hanger
President
and
CEO
Citizens
for
Pennsylvania's
Future
(
PennFuture)

Steffi
Domike
Coordinator
The
Collaborative
on
Health
and
the
Environment
in
Pennsylvania
(
CHE­
Penn)

Myron
Arnowitt
Western
PA
Director
Clean
Water
Action
Robbie
Ali,
MD,
MPH,
MPPM
Director
Center
for
Healthy
Environments
and
Communities,
University
of
Pittsburgh
Graduate
School
of
Public
Health
Fred
Brown
Interim
Executive
Director
Pittsburgh
Transportation
Equity
Project
Tom
Wolper
Chair
of
the
Sierra
Club
Allegheny
Group
Devra
Davis,
MD
Author
of
"
When
Smoke
Ran
Like
Water:
Tales
of
Environmental
Deception
and
the
Battle
Against
Pollution"

Mike
Ewall
Founder
Energy
Justice
Network
Lisa
Graves
Marcucci
President
Jefferson
Action
Group,
Inc.

Kevin
Stewart
Director
of
Environmental
Health
American
Lung
Association
of
Pennsylvania
David
Hughes
Executive
Director
Citizen
Power
Beverly
Braverman
Executive
Director
Mountain
Watershed
Association
Youghiogheny
Riverkeeper
