Dear Friend, The City of Philadelphia has a serious problem with mobile source pollution. The Air Monitoring Network Plan offers a unique opportunity for the City of Philadelphia to assess how well it is addressing mobile source pollution. Air Management Services (AMS), is tasked with monitoring air pollution in the City of Philadelphia. One of the 3 main objectives of AMS’s air monitoring network is to, “Support compliance with ambient air quality standards and emissions strategy development.” The City of Philadelphia is currently out of attainment for federal ambient air quality standards for ground-level-ozone (smog) and particulate matter 2.5 (soot) pollution. Any attempt to attain and maintain the federal air quality standards in Philadelphia must include an increased reduction of air pollution from the transportation sector. Motor vehicles produce 60% of Philadelphia’s total air pollution. A Boston University study concluded that from 1990 to 2017, greenhouse gas emissions in Philadelphia from cars and trucks increased 22%, far outpacing the city’s population growth. Transportation pollution is currently regulated through a series of mostly federal regulations dealing with automobile efficiency standards and emission standards. However, in the 1970s the city’s Air Pollution Control Board first adopted “Air Management Regulation 10” to regulate pollution from Complex Sources. The regulation defines a Complex Source as a, “facility, building, structure or installation, or combination thereof which emits, or in connection with which secondary or adjunctive activity is conducted which may emit, an air pollutant for which there is a National Ambient Air Quality Standard.” The regulation applies mostly to increased transportation pollution related to these complex sources. Historically, the regulation has been narrowly applied to large parking garages at sites like Temple University and Thomas Jefferson University, but the regulation is written broadly and should be applied to apply to any “New or modified Complex Sources that are projected by the Department to generate peak rate traffic in excess of 100 motor vehicles per hour; 25 diesel buses per hour; or 12 heavy duty diesel vehicles per hour.” With the proposed building of several large warehouse and shipping facilities across Philadelphia amid already increasing transportation pollution, AMS should start applying the Complex Source Permit Review to all applicable sites in the City. Mobile sources (compared to stationary sources) are the dominant source of smog-causing nitrogen oxide (NOx) air pollution in the city, according to the U.S. Environmental Protection Agency’s most recent National Emission Inventory. NOx reacts with heat in the atmosphere to form ground-level-ozone, commonly known as smog. Philadelphia is in nonattaiment for all federal standards for asthma-inducing ground-level-ozone pollution and increased transportation pollution will push the city further into nonattainment and negatively impact public health. Please click here to tell AMS to apply its Complex Source Air Permit to all applicable complex sources, especially transportation and shipping hubs in the city. | |
Joseph Otis Minott, Esq.
Executive Director and Chief Counsel | |
