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Subject: Philadelphia 2015 Ozone
Please hold a public hearing in the evening in Philadelphia regarding the Pennsylvania Department of Environmental Protection’s (DEP) proposed revision to the State Implementation Plan required by the U.S. Environmental Protection Agency because of the region’s nonattainment status related to the EPA’s 2015 Ozone National Ambient Air Quality Standard (NAAQS).
Philadelphians deserve a chance to make their voices heard regarding potential air pollution reductions. Philadelphia has the region’s largest population as well as the largest asthmatic population who are uniquely vulnerable to ground-level-ozone pollution. Philadelphia additionally leads the state in orange and red ground-level-ozone “action days”.
It is concerning that in 2022, EPA downgraded the Philadelphia region’s ozone nonattainment status from “marginal” to “moderate”. Because of this, the entire region has already missed the January 2023 compliance deadline related to the EPA’s 2015 Ozone NAAQS. Therefore, DEP’s statement, “that the Philadelphia Area can be expected to attain the 2015 Ozone NAAQS by 2023” is completely unfounded, particularly given that Philadelphia has already experienced a “red” ozone action day this summer where it was dangerous for all city residents to breathe.
Because of transportation’s significant impact on the region’s air pollution and the fact that the 5-county air quality region is also served by the Southeastern Pennsylvania Transportation Authority (SEPTA) while including many walkable communities and the regional Circuit Trails network, there is a unique opportunity to expand public transportation, bicycling, and walking infrastructure to benefit area residents and significantly reduce air pollution from the transportation sector, which is the largest source of smog-causing nitrogen oxides (NOx) in the region. Improved walkability via infrastructure funding for counties and municipalities would promote the use of public transportation and reduce personal vehicle trips.
DEP’s current proposal to allocate average daily ozone season emission limits to each permitted facility in the nonattainment area is inadequate to reduce the region’s air pollution because it does not address on road transportation emissions, the largest source of NOx in the region by far at approximately 46%. DEP must work with the Pennsylvania Department of Transportation to reduce highway spending and reallocate funds to improve public transportation, biking and walking infrastructure.
Compared to volatile organic compound (VOC) emissions that also contribute to smog-formation, DEP itself has concluded that, compared to VOCs, “NOx emission control strategies will continue to be effective in reducing ozone levels in future years.” Additionally, DEP also admits that, “In the Philadelphia Area, no measurements for non-methane VOC have been collected since 2006,” which suggests that any attempted accounting of VOC emissions is unreliable. DEP should focus on reducing NOx pollution from mobile sources and if anything should reduce the major source threshold for industrial sources of NOx and VOCs from 25 tons per year (TPY) to 10 TPY. This would reduce air pollution at greater levels than DEP’s proposal to allocate average daily ozone season emission limits while being less of an administrative burden than that proposal.
Increased funding for public transportation and pedestrian infrastructure would have immense benefits for Philadelphians and residents of the 5-county area while being the most significant action available to reduce ground-level-ozone formation. Please allow Philadelphians an opportunity to express their needs for improved public health.
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