CAB Comment on DEP’s smog plan

Comments on DEP smog plan to the Pennsylvania Environmental Quality Board by Thomas Y. Au, President of the Clean Air Board, May 29, 2014

Summer will soon be here and that can mean high levels of pollutants in our air, specifically ozone and small particles, commonly known as smog. Meteorologists declare “Air Quality Action” days when they project that weather conditions are conducive for unhealthy air pollution. In 2012, an extremely hot year, the Pennsylvania Department of Environmental Protection (DEP) called eleven “action days” for the Susquehanna Valley due to high concentrations of ozone. In 2013, DEP called four action days in the Susquehanna Valley due to ozone.

We should heed those warnings. Recent scientific studies conclude that short-term exposure to unhealthy air pollution can have significant adverse effects on pregnant women, children, the elderly, and even the general population–especially those with pre-existing conditions such as asthma. There is increasing scientific evidence that exposure to ozone can lead to neurological disorders. Short term symptoms resulting from breathing high levels of ozone and fine particulate include chest pain, coughing, nausea, throat irritation, and congestion. These pollutants also aggravate 
bronchitis, heart disease, emphysema, and asthma—and can increase risks of stroke. Children, senior citizens, and those with asthma or other respiratory problems are urged to limit outdoor activities during action days.

Air Quality Action days are often declared when there is little wind and when the amount of ozone or particles in stagnant air are projected to exceed federal health standards. Smog is caused when chemicals including nitrogen oxides react in sunlight, forming ground-level ozone. Coal fired power plants are the single largest source of smog-causing pollutants in Pennsylvania. While nearly all of the state’s largest coal plants have the technology to reduce nitrogen oxides, many do not use the available technology. The Clean Air Act requires that existing sources of emissions which contribute to the ozone problem install reasonably available control technology. Reasonably available control technology (RACT) is defined as the lowest emission limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility. Accordingly, RACT determinations must set limits as rigorous as could be met through use of feasible control technology.

The proposed regulation does not set reasonably available control technology for Pennsylvania coal plants anywhere close to the what can be achieved through control technology. Most of Pennsylvania coal plants have highly effective NOx emission controls installed, such as Selective Catalytic Reduction (“SCR”) and low NOx burners. However, in the emission limits proposed, the RACT NOx emission limit for a coal-fired boiler would be an extremely permissive range of between 0.45 lbs/MMBtu and 0.20 lbs/MMBtu. See Proposed 25 Pa. Code § 121.97(g)(1)(v)-(vi). These limits are far higher than recent emissions history and higher than RACT limits set in nearby states. The Sierra Club has submitted detailed information to the Department to document this point. (Sierra Club letter, Jan. 17, 2014)

This proposed limit is not only based on technology inferior to that already in place at nearly all coal-fired power plants in Pennsylvania, but is also significantly more permissive than what those facilities are capable of achieving. In fact, under the averaging rule proposed the coal plants would not need to achieve these limits during ozone action days. See Proposed 25 Pa. Code § 129.98(a). This is like bypassing your catalytic converter in your car to save a few pennies.

The most serious health risks from ozone are associated with high energy demand days when the non-SCR units are almost certain to be operating. Therefore it is imperative that these units be capable of curtailing their NOx emissions on these days so that they comply with emission limits consistent with the installation and operation of reasonably available emission technology found elsewhere in this region.

We continue to suffer from high ozone days during the summer. Air quality in Pennsylvania continues to violate national ambient air quality standards. To achieve compliance with the 2008 8-hour ozone NAAQS, reductions from all major sectors — in-state stationary sources, in-state mobile sources, and out-of-state stationary sources — are essential. This proposed regulation needs to be revised to achieve real reductions in smog causing pollutants.

Your comments on this proposal can be submitted directly to the Environmental Quality Board by June 30, 2014.

Online Comments

Comments, including the one page summary, may be submitted to the EQB by accessing the EQB’s Online Public Comment System at:

Note regarding the online system: If an acknowledgement of comments submitted online is not received by the sender within two business days, the comments should be re-sent to the EQB to ensure receipt.

Written Comments

Written comments and summaries can also be mailed to Environmental Quality Board, P.O. Box 8477, Harrisburg, PA 17105-8477.

All comments must be received by the EQB on or before the close of the public comment period.

Support clean burning wood-heaters

Less wood smoke means healthier air

The U.S. Environmental Protection Agency (EPA) has proposed new limits on harmful air pollution from new wood-burning devices. These devices, such as boilers, furnaces, and stoves, can subject a neighborhood to dangerous air pollution. Wood smoke, which contains soot, carbon monoxide, and other toxic air pollutants, can trigger asthma attacks, cause cancer, and even cut short lives.

Wood smoke can pollute a neighborhood and can travel miles away. That means people who live nearby and far away can suffer from inhaling wood smoke. Strong standards will help ensure that new wood burning devices are much cleaner and do not further pollute our air. EPA needs to adopt these long-overdue standards to protect our health and our neighborhoods from harmful wood smoke-related air pollutants.

To send a comment to EPA, click on the American Lung Association link:

Is our Air Quality getting better or worse?

Join the discussion on the latest State of the Air report.  Kevin Stewart, Director of Environmental Health at the American Lung Association, will discuss ALA findings in the 2012 State of the Air report.

Please join us at the Second Presbyterian Church, 528 Garland Drive, Carlisle, on May 3, at 7 pm.

Clean Air Board Community Meeting

The Clean Air Board will hold a community meeting on Aug. 5, 7 pm

Kevin Stewart, representing the American Lung Association of the Mid-Atlantic, will speak on the “State of Our Air – where we have been; where we are; and where we are going?”

Second Presbyterian Church, 528 Garland Drive, Carlisle, PA  17013

Harrisburg region gets another bad grade for air quality: Patriot News

April 28, 2010: Patriot News

Harrisburg region gets another bad grade for air quality

by David Wenner

The Harrisburg region has received another poor grade regarding air quality. The Harrisburg-Carlisle-Lebanon region ranks as the 22nd worst in the nation for short-term particle pollution in the American Lung Association’s annual “State of the Air” report.

Although the area’s air improved slightly, its ranking was slightly worse than in the previous report, when it ranked 24th worst. Particle pollution, known as soot, involves microscopic particles from sources such as cars and trucks, coal-fired power plants, construction sites and tilled fields. It can cause lung irritation for normal people and severe problems for people with lung conditions such as asthma, emphysema, bronchitis and heart disease.

The region has long registered high levels of both particle and ozone pollution, causing groups such as the Clean Air Board of Central Pennsylvania to wage an ongoing push for policies aimed at reducing the problem. Much of the problem is attributed to its concentration of trucking and the presence of Interstate 81 and several other high-volume highways. There’s also the coal-fired power plant on Brunner Island near York Haven.

“I think there has been slight improvement over the years,” said Tom Au, president of the Clean Air Board. He noted a law that prevents truckers from idling their rigs during rest periods will take affect next month, impacting a major source of local air pollution.

You can search local air quality grades by zip code, and send messages to federal elected officials, at Information about the “State of the Air” report can be found at

Air Quality From Bad to Worse: Sentinel News

May 3, 2007: Sentinel News

Air Quality From Bad to Worse

by Jessica Bruni


For months, members of the Clean Air Board have spoken to the community in horrified tones about the Carlisle area’s ranking as the 24th most polluted metropolitan area in the nation regarding fine particulate matter.

Well, the area no longer ranks at 24. It’s now at No. 14.

On Tuesday, the American Lung Association released its 2007 list of best and worst cities for air quality standards. Moving up the ladder from No. 24 to No. 14 in the category of metropolitan area “most polluted by short-term particle pollution” was the Harrisburg-Carlisle-Lebanon area.

People, truck, traffic affect quality

However, Kevin Stewart, director of environmental health for the American Lung Association, said, there’s little doubt the influx of people, trucks and traffic into the area has had a negative effect on air quality. For the record, the Carlisle area had 44 bad air days over a three-year period while Dauphin County had 38. Both, Stewart said, were enough to qualify the areas to make the ALA’s bad air list.

The Carlisle area also has the unlucky distinction of being located upwind from the Baltimore Washington corridor — meaning all the pollution from that congested area travels here. At the same time, the area also draws in down winds from the west, bringing in pollution from the rest of Pennsylvania, Virginia and beyond.

“All of those sources together are what has created the air pollution problems that we observe here,” Stewart said.

Area’s Latest Ranking Doesn’t Surprise Asthma Sufferers: Patriot News

May 3, 2007: Patriot News

Wind Blows Polluted Air Our Way: Area’s latest ranking doesn’t surprise asthma sufferers (Archive Fee Required)

by Ford Turner

Blow up a big balloon, then try to keep your mouth in place and let all the air shoot back into your lungs.

That is what an asthma attack feels like, Carol Crupi says. And as she learned this week, asthma sufferers in the midstate might be more susceptible to attacks than those who live elsewhere.

A report from the American Lung Association ranked Cumberland and Dauphin counties among the 25 worst places in the nation in terms of short-term particle air pollution.


Get every new post delivered to your Inbox.

Join 46 other followers