The Group Against Smog and Pollution (GASP) on Wednesday sounded the alarm to the Allegheny County Board of Health about a trend that’s emerged over the past few months by Air Quality Program leadership: A disturbing lack of transparency. GASP Executive Director Patrick Campbell addressed the issue in public comments he delivered at the start of the meeting. Here’s what he told them: Good afternoon. I’m Patrick Campbell, executive director of the Group Against Smog and Pollution, an environmental nonprofit working to improve air quality since 1969. GASP staff attends all Allegheny County Health Department air quality-related committee and board meetings, and over the last few months, we’ve noted an unfortunate trend: Air Quality Program leadership largely disregarding the input - and, in some cases, formal recommendations - of the expert volunteers on the Air Pollution Control Advisory Committee it should be relying on for guidance. The past two Air Advisory meetings were dominated by discussion about proposed changes to Article 21 related to the percentage of the Clean Air Fund ACHD can use for operating expenses each year. At these meetings, Air Quality Program leadership proposed increasing the allotment from 5 to as much as 25 percent, telling board members that the additional money was necessary to ensure the department was well-funded. At the most recent meeting, the Air Advisory Committee asked reasonable and responsible questions before voting not to recommend the proposal go to you for public comment consideration today. Questions like: Where is your proposed budget? How did you determine the new percentage? What will this money be used to fund? Can we see your financial projection for the next three years? To our amazement, Air Quality Program leadership was either unable or unwilling to provide answers to those questions. To our dismay, ACHD completely disregarded the Advisory Committee’s recommendation and placed it as an action item on today’s agenda. While GASP is an advocate for a well-funded Air Quality Program - and we believe it needs the additional money - leadership needs to show its work. We hope members of this board will press Air Quality Program leadership for additional information and if they are unable to provide that information, we hope you vote accordingly. Thank you. Fellow environmental advocates also spoke out about ACHD’s proposed Clean Air Fund changes - as did members of the Air Pollution Advisory Committee including Chairman Dan Bricmont, asking the board to reject the request. Following public comment and various reports, ACHD Deputy Director of Environmental Health Geoffrey Rabanowitz presented information on proposed changes to the county’s air pollution control regulations and asked the board to approve them for public comment. Here are the slides he shared detailing those changes: He acknowledged that he placed the action item on the agenda despite the Advisory Committee’s vote not to recommend it for public comment - saying that it reflected a “real sense of urgency.” When it was time for the vote, Board of Health members also expressed their concern over the Advisory Committee’s unanimous rejection of the proposal, as well as the lack of transparency from the department related to the request. After significant debate, members moved to reject the proposal by a vote of 4-3. Editor’s Note: Rabanowitz also shared the Air Quality Program's Major Goals for 2023. Here's what he presented to the board: Miss the meeting? You can access the video here.

UPDATE (Feb. 9, 2022): This case has been appealed to the Pennsylvania Commonweatlth Court. You can read the notice of appeal here. An Allegheny County Health Department (ACHD) administrative hearing officer has dismissed an appeal filed by Ramesh Jain, Vikas Jain, and two companies they control, finding that the parties illegally disposed of asbestos waste generated during the renovation of the former George Westinghouse Research and Technology Park in Churchill Borough. The Jan. 12 order - posted to the ACHD website on Wednesday - directed the parties to pay a $1 million civil penalty by Feb. 11. This decision is the latest and hopefully last in an appeal process has lasted nearly six years. We won’t bore you with every procedural detail, but for anyone concerned with worker health and safety, public health, and air quality in general, the story is unsettling and worth knowing. A Long Time Coming In February 2017, a Churchill Borough building inspector contacted ACHD to report his suspicion that people were removing asbestos-containing material (ACM) from buildings on the Westinghouse site without following strict disposal and safety rules. ACHD inspectors investigated and promptly issued the Jains – Ramesh is Vikas’ father – and their companies an Emergency Enforcement Order demanding they cease all demolition work, prevent anyone from entering the buildings, not alter their removal equipment, make that equipment available for further analysis, and provide waste manifests showing where the previously-removed ACM was taken. From this point forward, an incredible amount of administrative hearing procedural maneuvering occurred. It matters, but what matters more are the appalling facts of the case (based on findings in the recent order denying the appeal). To start, there was no permit for the work despite ACHD calculating that more than 160,000 square feet of asbestos-containing floor tile and 10,000 linear feet of amosite had been removed from the site. Per EPA regulations, permits are required for ACM removal in excess of, respectively, 160 square feet and 260 linear feet. ACHD inspectors did not observe “any evidence” of the required safety equipment, materials, postings, practices, and procedures. This includes worksite warning signs, sealing of the work area, and methods to prevent the escape of asbestos. Workers were observed handling ACM without any protective gear. Workers were also directed to place ACM debris in black trash bags and toss them in a pick-up truck to dispose of it in a dumpster located outside of one of Vikas Jain’s residential rental properties. The contents of the dumpster, including sealed trash bags containing ACM, were subsequently taken to a local landfill that was not qualified to receive asbestos-contaminated waste. Finally, in direct defiance of the Emergency Order, the appellants in this case “intentionally switched, concealed, and cleaned off equipment before providing it to ACHD for inspection and testing.” The only procedural note we will share is that one reason this appeal took six years is that in 2019, Vikas Jain pled guilty in federal court to intentionally violating the Clean Air Act. Why Asbestos is Still a Major Air Quality and Public Health Concern & The Local Regs Meant to Protect Both Asbestos is a group of six naturally occurring minerals composed of microscopic bundles of fibers. These fibers are resistant to heat, fire, and chemicals and don’t conduct electricity—all reasons why asbestos was widely used in the building and construction industries for everything from strengthening cement and plastics to insulation, roofing, fireproofing, and sound absorption from the late 1800s until the 1970s, when the federal government began regulating it. While health studies suggested a link between asbestos exposure and pulmonary illnesses as early as the 1930s, it wasn’t formally classified as a human carcinogen until 1987. In 1988, the EPA estimated that asbestos had been used in the construction of more than 750,000 public buildings. When asbestos fibers are inhaled, they may get trapped in the lungs and stay there. Over time, they may accumulate and cause scarring and inflammation, which can affect breathing and lead to serious health problems such as lung cancer and chronic lung disease. Because of its inherent health risks, the Clean Air Act authorized the EPA to establish work practice standards that must be followed to ensure the safe and proper handling and removal of asbestos during renovation work. The Clean Air Act also authorized the EPA to establish disposal requirements for owners/operators who wish to demolish or renovate a facility that has asbestos-containing materials. In Allegheny County, ACHD is the agency responsible for enforcing the EPA requirements and permitting activities where asbestos might be released into the air. ACHD’s webpage includes many resources covering the regulations and health hazards of asbestos. Asbestosis is of particular concern in Allegheny County, where ACHD says the mortality rate is 50 percent higher than the national average. GASP Remains Concerned About Asbestos, Hopeful Jain Case Will Serve as “Cautionary Tale” “What these business owners did was unconscionable - their reckless behavior put not only their own workers but also an unknown number of Allegheny County residents at risk of exposure to asbestos,” GASP Executive Director Patrick Campbell said. “This ruling really is a victory for public health.” He continued: “We hope this case serves as a cautionary tale for businesses tempted to skirt asbestos-abatement regulations put in place to help protect our air quality and the health of both workers and members of the public.” GASP continues to be concerned about the number of asbestos-related enforcement actions in Allegheny County and commends Allegheny County Health Department’s Air Quality Program for its continued attention to this burgeoning public health issue. “An ACHD official told us inspectors can’t write abatement-related enforcement actions fast enough,” Campbell said. “We hope Allegheny County considers this uptick in enforcement activity when budget time comes around. It’s imperative that ACHD has the resources to put a stop to these kinds of bad actors.” Editor’s Note: You can read the 38-page order in its entirety here.

Editor's Note: This blog has been updated to include a link to GASP's formal written comments. GASP joined residents and fellow environmental advocates at a public hearing Wednesday to demand the Allegheny County Health Department (ACHD) create a comprehensive compliance schedule for U.S. Steel's Clairton Coke Works facility. You can get the skinny on the hearing regarding portions of the Clairton Coke Works' Title V operating permit on our blog here. Here are the comments that GASP Executive Director Patrick Campbell presented: Good evening. My name is Patrick Campbell - I am the executive director of the Group Against Smog and Pollution (GASP), a nonprofit organization working to improve our regional air quality since 1969. U.S. Steel’s Clairton Coke Works emits myriad harmful pollutants - from fine particulate matter and carbon monoxide to hydrogen sulfide, nitrogen oxides, sulfur dioxide, and benzene. The facility is the largest coke plant in North America and - as residents know all too well - is a major source of air pollution with a troubling history of noncompliance with air quality regulations. Despite this, the amended Title V operating permit Allegheny County Health Department (ACHD) issued to U.S. Steel for its Clairton Coke Works facility still does not include a proper compliance schedule for these emissions. Such a comprehensive compliance schedule is necessary and would help stem emissions violations at the Clairton Coke Works - violations that ACHD said are regular and ongoing. In an Oct 20, 2023, letter from ACHD to U.S. Steel, the department states: “ACHD regularly inspects and observes violations of . . . charging, traveling, door areas, charging ports, offtake piping, pushing, combustion stacks, soaking, and miscellaneous topside emissions.” The department added, “[t]hose violations have been ongoing for years and continue to occur.” While the permit now includes more work practices and a smattering of OSHA regs, they do not supplement the permit record as EPA demanded. The compliance schedule must include stick-and-carrot milestones and benchmarks. There must be deadlines and consequences for missing them. And the penalties for not meeting these benchmarks need to be lost production for U.S. Steel, not additional fines. Because despite a high-profile settlement agreement in 2019 between ACHD and U.S. Steel intended to get the Clairton facility back into compliance with air quality regulations, the company has since racked up millions more in emissions-related fines. The sad truth is that while ACHD and U.S. Steel duke these issues out in legal filings, the emissions violations in Clairton persist, impacting residents’ health and quality of life. The time to hold U.S. Steel accountable is now and the way to do it is to amend the Clairton Coke Works’ Title V permit to include a proper compliance schedule. Thank you.

GASP on Wednesday afternoon presented testimony at a public hearing in Natrona Heights held by Allegheny County Health Department to solicit comments on a draft Title V permit it issued to ATI. We also submitted formal technical comments that you can read here. Here are the comments our Executive Director Patrick Campbell presented about the Brackenridge-based polluter: Good afternoon. My name is Patrick Campbell, I am the executive director of the Group Against Smog and Pollution (GASP), a nonprofit organization working to improve our regional air quality since 1969. ATI’s steelmaking operations in Brackenridge have been a major source of air pollution in Allegheny County for decades, and it’s long past time for the Allegheny County Health Department (ACHD) to issue a strong Title V permit that assures the facility complies with air quality regulations. Unfortunately, the draft Title V operation permit issued by ACHD is lacking - especially regarding testing, monitoring, and recordkeeping requirements. The permit establishes annual and pounds-per-hour emission limits for the Electric Arc Furnaces’ emissions of total particulate matter and other hazardous air pollutants. However, it only requires a performance test to be run every five years to determine compliance with those emission limits and collect certain information about each heat processed during that performance test. We want to stress that a performance test that is conducted only once every five years is, by itself, in no way sufficient to assure compliance with annual and hourly emission limits. Moreover, it does not appear from the permit that ATI is required to collect data regarding certain heats conducted in the ordinary course of business that could be compared to similar data collected during the performance test to determine compliance with those annual and hourly emission limits. Without that data, it is not clear to GASP how ACHD can assure ATI is complying with the annual and hourly emission limits outlined in the permit. GASP believes ACHD must revise the permit to require ATI to establish operating limits based on parameters developed during the performance test and record and report data regarding those parameters for each heat. That data could then be compared to the parameters developed during the performance test and enable ACHD to determine and assure ATI’s compliance with all applicable emission limits. Thank you.

The state Department of Environmental Protection (DEP) has received $3 million from the EPA to develop a Priority Climate Action Plan focused on reducing emissions in the Commonwealth’s industrial sector - and they are seeking input from the public. Upon completing that plan, DEP will then be eligible to apply for up to $500 million to implement it. DEP’s plan will focus on a statewide industrial decarbonization grant program, known as Reducing Industrial Sector Emissions in Pennsylvania (RISE PA), that will provide funding for industries to reduce carbon and benefit the health and safety of surrounding communities. DEP is seeking funding for RISE PA from the Climate Pollution Reduction Grants (CPRG) through the Inflation Reduction Act (IRA). According to the 2023 Pennsylvania Greenhouse Gas Inventory Report, the industrial sector is the highest greenhouse gas (GHG) emitting sector, accounting for just over 30 percent of Pennsylvania’s total GHG emissions. DEP is also looking for input from industry, academia, community-based organizations, and other interested stakeholders on issues related to the design and implementation of RISE PA. The department said in a release that it is specifically interested in receiving input on program design, size, scope, scale, and award structure as well as the potential outputs and metrics, including emissions reductions and community benefits. If DEP receives CPRG funding for RISE PA, prospective projects would need to satisfy the following proposed criteria: Benefit (and not negatively impact) low-income and disadvantaged communities Achieve GHG emission reductions that are long-lasting and certain Incorporate high labor standards, emphasize job quality, and support equitable workforce development DEP is requesting responses to 10 questions to inform the development of program solicitation guidelines for RISE PA. Those questions, and additional information about the Department’s general goals and objectives for RISE PA program development, can be found here. But please be aware that the deadline to submit information is coming up fast: Those who wish to weigh in must do so by e-mail to RA-EP-CPRG@pa.gov no later than Monday, Jan. 22.

The EPA has announced a proposal to strengthen Clean Air Act standards for large facilities that burn municipal solid waste. If finalized, the updated standards would reduce emissions of nine pollutants - including smog- and soot-forming sulfur dioxide and nitrogen oxides - by approximately 14,000 tons per year, improving air quality for overburdened communities living near these facilities. These proposed standards reflect current technologies available to control pollution cost-effectively, EPA said in a release. Here’s what you need to know: The proposed standards would apply to 57 facilities with 152 units that can combust more than 250 tons per day of municipal solid waste. Not-so-fun fact: Nearly 4 million Americans live within three miles of these large facilities, which are disproportionately located in low-income communities and communities of color. The proposal supports ongoing efforts to protect overburdened communities from harmful pollution and is likely to reduce existing disproportionate and adverse effects on communities with environmental justice concerns. The proposed standards are based on emission levels achieved by the best controlled and lower-emitting sources and limit emissions of nine pollutants: particulate matter, sulfur dioxide, hydrogen chloride, nitrogen oxides, carbon monoxide, lead, cadmium, mercury, and dioxins/furans. Why is EPA taking this action? The Clean Air Act requires EPA to evaluate these standards every five years to take into account developments in pollution control technologies and techniques. EPA last revised these standards in 2006. And the agency lauded the expected benefits: The estimated benefits of this action far outweigh the expected pollution control costs. After accounting for compliance costs of the rule, EPA estimated the net present value of health benefits from the proposed rule, due to reductions in particulate matter and ozone alone, to be up to $14 billion over 20 years. Reductions of mercury, lead, and other hazardous air pollutants required by the proposal are expected to result in additional unquantified economic and public health benefits. EPA believes this action is also likely to advance environmental justice by reducing existing disproportionate and adverse effects on overburdened communities. EPA will accept comments on the proposal for 60 days after publication in the Federal Register. Until then, you can read more information on the proposal and upcoming webinar for large municipal waste combustors.

More than one-third of the food produced in the United States is never eaten, wasting the resources used to produce, transport, process, and distribute it – and much of it is sent to landfills, where it breaks down and generates methane, a powerful greenhouse gas. So says two newly released reports from the U.S. Environmental Protection Agency (EPA) quantifying methane emissions from landfilled food waste and emphasizing the importance of reducing the amount of food that is wasted and managing its disposal in more environmentally friendly ways. In response to these findings, EPA is releasing an update to its Food Recovery Hierarchy, a tool to help decision makers, such as state and local governments, understand the best options for managing food waste in terms of environmental impacts. The release of the new ranking – called the Wasted Food Scale – marks the first update since the 1990s, reflecting more recent technological advances and changes in operational practices. EPA's research confirms that preventing food from being wasted in the first place, or source reduction, is still the most environmentally beneficial approach. The research announced today represents the first time EPA has quantified methane emissions from landfilling. This novel work published modeled estimates of annual methane emissions released into the atmosphere from landfilled food waste, giving a cost of landfilling food waste in terms of the impact on climate change. EPA conducted an analysis to estimate annual methane emissions from landfilled food waste from 1990 to 2020 and found that while total emissions from municipal solid waste (MSW) landfills are decreasing, methane emissions from landfilled food waste are increasing. These estimates indicate that diverting food waste from landfills is an effective way to reduce methane emissions, a powerful greenhouse gas, from MSW landfills. EPA reports being released today include: • "From Field to Bin: The Environmental Impacts of U.S. Food Waste Management Pathways," which examines the environmental impacts of disposing of food waste. This report synthesizes the latest science on the environmental impacts of how food waste is commonly managed in the U.S. This report completes the analysis that began in the 2021 companion report, "From Farm to Kitchen: The Environmental Impacts of U.S. Food Waste ," which analyzed the environmental footprint of food waste in the farm to consumer supply chain. • "Quantifying Methane Emissions from Landfilled Food Waste" represents the first time EPA has published modeled estimates of annual methane emissions released into the atmosphere from landfilled food waste. More food reaches MSW landfills than any other material, but its contribution to landfill methane emissions has not been previously quantified. Editor’s Note: GASP remains concerned about the intersection of food waste and air pollution and wants to share some resources for local folks to take meaningful action. First, the EPA has resources where you can learn more about preventing wasted food at home. We highly recommend folks who are concerned about food waste check out local nonprofit 412 Food Rescue. And check out our blog for some other ways to stave off food waste.

Editor's Note: GASP, Clean Air Council, Environmental Integrity Project, and PennFuture on Thursday jointly issued the following press release (!!!). Stay tuned, more to come from GASP on what this all means. Spoiler: It's a big deal. Environmental Groups Win EPA’s Objection to U.S. Steel Clairton’s Air Pollution Permit Environmental Protection Agency sides with Environmental Integrity Project, PennFuture, Clean Air Council, and Group Against Smog and Pollution and objects to U.S Steel Clairton’s Title V permit as it was not in compliance with the Clean Air Act. In a move that will help protect Mon Valley residents from the emission of harmful air pollutants, the Environmental Protection Agency (EPA) sided with environmental groups by issuing an order objecting to an air quality permit issued to U.S. Steel’s Clairton Coke Works by the Allegheny County Health Department (ACHD) in November 2022 on the basis that it was not in compliance with the Clean Air Act. In March, environmental groups submitted two petitions to the EPA requesting it object to the Title V Air Quality permit granted to U.S. Steel Clairton by the ACHD. In the petition from the Environmental Integrity Project (EIP), PennFuture, and Clean Air Council, the groups argued that the Title V permit did not include monitoring and testing requirements sufficient to assure compliance with multiple air quality emissions limitations for multiple emissions sources. The petition from the Group Against Smog and Pollution (GASP) argued that the Title V permit failed to include a compliance schedule which is required by the Clean Air Act when a facility is out of compliance with emission standards at the time of the permit issuance. EIP, PennFuture, and Clean Air Council had sent a notice of intent to sue EPA on July 11 for EPA’s failure to take action on their March petition to object to the permit, and EIP filed a lawsuit in federal court on behalf of these three groups on Sept. 13. On Sept. 18, the EPA issued an order granting almost all of the petitioners’ claims related to testing, monitoring, and reporting requirements and GASP’s claim regarding a compliance schedule, objecting to the Clairton Title V permit on those grounds. In its order, EPA requires ACHD to revise the permit and/or permit record in accordance with its decision. The U.S. Steel’s Clairton Coke Works is the largest coke plant in North America and a significant source of air pollution in Allegheny County. It also has a history of noncompliance with environmental regulations. Pollutants of concern emitted by the facility include particulate matter, carbon monoxide, volatile organic compounds, nitrogen oxides, sulfur dioxide, and several hazardous air pollutants, including benzene. “EPA’s objection to this Title V permit will require ACHD to ensure that the permit has air quality monitoring and testing requirements sufficient to demonstrate that U.S. Steel Clairton operates in compliance with its emission limits,” said Angela Kilbert, senior attorney for PennFuture. “Air quality issues are an ongoing public health problem in Allegheny County and ensuring that industry polluters are operating within their permit limits is critical to protecting our health and environment.” “For far too long, Allegheny County residents have deserved clean air but been denied it,”said Joseph Otis Minott, executive director and chief counsel of Clean Air Council. “We are grateful to EPA for granting these petitions to minimize harmful industrial pollution.” “This is a long-overdue win for local residents, who can see that environmental groups and now EPA are stepping up to stop polluters like U.S. Steel from being able to continue operating with lax permits,” said Lisa Hallowell, senior attorney with EIP. “We hope ACHD acts quickly to make the changes to Clairton's permit so U.S. Steel can be held accountable to air pollution laws.” “We're pleased that EPA granted our petition and agreed that ACHD must develop a compliance schedule for its Clairton Coke Works facility and we hope the measures required by that compliance schedule finally bring the facility into compliance with the Clean Air Act," said John Baillie, senior attorney at GASP. "More than anything we hope the end result is improved air quality for the Mon Valley and beyond - residents have suffered long enough from emissions issues and air pollution events at that plant. We're glad EPA agrees that enough is enough." This order is a win against an inadequate, unprotective, and unlawful Title V permit and represents another critical step in the fight against harmful emissions from major polluters in Allegheny County. ABOUT US: Clean Air Council is an environmental health advocacy organization fighting for everyone’s right to a healthy environment. Protecting people’s health from the harmful impacts of pollution has always been the Council’s primary goal. Environmental Integrity Project is a nonprofit organization dedicated to enforcing environmental laws and strengthening policy to protect public health and the environment. Group Against Smog and Pollution (GASP) non-profit in Southwestern Pennsylvania working for a healthy, sustainable environment. Founded in 1969, GASP has been a diligent watchdog, educator, litigator, and policy-maker on many environmental issues, with a focus on air quality in the Pittsburgh region. PennFuture is a member-supported, statewide environmental advocacy nonprofit and watchdog fighting against potential threats to PA's clean air, pure water, and healthy climate. Since 1998, PennFuture has combined legislative advocacy and legal enforcement at the local, state, and federal levels, educational outreach, and civic engagement support for just and equitable environmental outcomes that improve the quality of life for all Pennsylvanians. PennFuture has stood at the forefront of major environmental milestones in Pennsylvania as a bold and vigilant defender of communities against pollution and environmentally harmful policies. ###

From left to right, are: Yvonne Sorovacu, Protect PT; Paul Dille, CREATE Lab; Nathan Deron, EHP; Ned Mulcahy, GASP. Members of GASP, CREATE Lab, Environmental Health Project, and Protect PT recently got their first look at new air monitoring technology that the groups will be deploying over the coming months in various locations as part of EPA grants the groups received. The equipment – called an S-Pod – is capable of reporting levels of volatile organic compounds (VOCs) in the air through the use of a photoionization detection (PID) sensor. For those of us who aren’t air quality nerds: An additional and very important feature is that these units let users take samples of the air for further analysis when VOC levels get bad. Best of all, these little machines work wirelessly and remotely. From left to right: Nathan Deron, EHP, with solar panel, Yvonne Sorovacu, Protect PT, with summa canister, Ana Hoffman, CREATE Lab, with S-Pod, Ned Mulcahy, GASP, also with summa canister. The parts pictured here with a few of the soon-to-be experts belong to our friends at Allegheny County Clean Air Now (ACCAN) and will be deployed soon as part of the work they are doing outside the aforementioned EPA grants. While the parts were in CREATE Lab’s actual lab, we got a chance to plug everything in, run through a few set-up tasks, and the like. Thanks to ACCAN for letting us learn. Thanks to Jacob and Jason at Sensit, for helping us work through a few technical details. Thanks to the EPA for funding and immense effort in creating and fine-tuning the underlying technology over the years. Editor’s Note: We will keep you posted as the monitoring project progresses. In the meantime, you can get all the details on the EPA-funded program here.

The comment period is now over. Thanks to all who submitted a comment. You can read GASP's formal comments here. If you follow local air quality issues, then you probably know that the Allegheny County Health Department (ACHD) is our local air quality regulator and operates a network of air quality monitors. What you might not know is that every year, the ACHD must publish an air quality network monitoring plan that provides a detailed description of how and where air pollution is monitored throughout the county. These annual reports are required by the U.S. Environmental Protection Agency (EPA) and provide information such as the specific location of each monitoring station, monitoring methods, monitoring objectives, frequency of sampling, pollutants measured, and any planned changes to the network. Right now, ACHD is seeking public comment on its 2024 Air Quality Network Monitoring Plan through Dec. 1, so GASP wanted to provide a breakdown of what’s new and notable in the report and how - and why - you should consider speaking out. Where, What, When, and Why Does ACHD Monitor? ACHD operates nine monitoring sites to meet the core objectives for all monitoring networks across the country: Provide air pollution data to the general public in a timely manner; Support compliance with ambient air quality standards and emissions strategy development; and Support for air pollution research studies. The complexity of the sites and the pollutants they measure vary by the sites’ objectives, with a site in Glassport monitoring a single pollutant – PM10 – and ACHD’s primary site in the City of Pittsburgh monitoring dozens of pollutants. The monitoring site locations are established to meet certain objectives. For example, there is a near-road site along the Parkway East set up expressly to monitor pollutants from mobile sources and other sites that have changed over time to detect the highest levels or background levels of certain pollutants. Many sites now monitor continuously as technology and internet connectivity have advanced, but not all pollutants can be monitored in real-time. Ch-ch-ch-ch-changes In the 76-page plan, ACHD detailed monitoring additions since the publication of its 2023 Air Quality Network Monitoring Plan. They include: • Moving the Avalon monitoring station to the Avalon Elementary School • Reconfiguring the Liberty site roof and replacing the continuous PM2.5 and PM10 monitors at that site • Adding aerosol chemical speciation monitoring for organics, sulfate, nitrate, ammonium, and chloride to the Lawrenceville site • Adding continuous PM10 metals monitor to the Lawrenceville site The Plan also lays out updates ACHD anticipates it will complete in the next 18 months, which include: • Addition of continuous PM2.5 monitoring at the South Fayette and Harrison sites • Addition of meteorology (wind speed & direction) sensors at the Avalon site • Addition of meteorology sensing as well as hydrogen sulfide (H2S) and sulfur dioxide (SO2) monitoring at the Clairton site • Addition of True NO2 monitoring at the Liberty site • Addition of a ceilometer to the Mon Valley to measure the mixing layer height of the atmosphere • Movement of Lawrenceville monitoring station – the department’s primary and most comprehesive monitoring site – to the Chateau Neighborhood in Pittsburgh’s North Side. As GASP reported previously, closing the Lawrenceville site did not strike us as a well-reasoned decision, but the relocation is moving ahead. One bright spot is that ACHD is proposing to operate a new monitoring station within two miles of the existing Lawrenceville station “to capture a similar airshed to what is being monitored now at the NCore site for long-term comparison to the new Chateau NCore site.” Cheers and Jeers for This Year’s Plan Technically speaking, and regarding the pollutants that ACHD will be monitoring, GASP has nothing but cheers for the plan. The network is expanding, new monitors are being deployed, and more pollutants are being measured. In addition, ACHD is currently field-testing low-cost sensors for potential use as supplemental monitoring in environmental justice communities throughout the county. After field testing of Purple Air PA-II-FLEX sensors, ACHD will provide the monitored area with correction factors to properly calibrate citizen-owned sensors to the closest continuous regulatory PM2.5 monitor. This is a great idea. But a jeer is necessary when it comes to ACHD meeting objective #1 for monitoring networks: Providing air pollution data to the general public. To be clear, ACHD publishes air quality data hourly, and the Air Quality Program website displays PM2.5 data based on rolling averages, but the department’s refusal to promote and share the EPA’s NowCast AQI – particularly during the wildfire smoke episodes this past summer – deeply concerns us. The core issue with ACHD’s approach is that a rolling average is not the same thing as a current condition. In other words, “we’ve averaged 0.14 inches of rain over the past 24 hours” is not a reasonable or sane answer to the simple question, “Is it raining outside now?” It is reasonable and sane for the public to want actual, current air quality conditions, and the EPA’s AirNow platform delivers. It displays hourly data from thousands of monitors across the country and – more importantly – AirNow calculates its NowCast AQI values to be responsive to rapidly changing air quality conditions and to caution people in time for them to reduce their exposure to pollutants. With that in mind, consider those days last summer when air quality locally was in the very unhealthy range. ACHD outreach encouraged the public to, “[s]tay up to date on current air quality conditions by visiting the department’s online dashboard,” which – as we noted above – does not report current conditions. “There appears to be a troubling disconnect between the quality of the data ACHD captures and the department’s curious approach to sharing and interpreting that data for the public’s benefit,” GASP staff attorney Ned Mulcahy said. “EPA regulations define the AQI as ‘a tool that simplifies reporting air quality to the general public.’ ACHD is both complicating the air quality reporting and failing to promote a tool meant to protect public health.” How and Why to Submit a Public Comment GASP will be submitting formal comments on the plan this Friday. If you’d like to echo our sentiments above or raise other concerns about how air quality is monitored in Allegheny County, submitting a formal public comment is simple. You can email them to ACHD’s David D. Good at David.Good@alleghenycounty.us or mail them to: 301 39th Street, Building 7, Pittsburgh, PA 15201. For more information, there is also an online meeting, Wednesday, Nov. 29, of the Air Quality Program Advisory Committee’s Air Monitoring Subcommittee where a discussion of the monitoring plan is on the agenda.