At the August 10 Air Quality Technical Advisory Committee meeting DEP will be reviewing its position and make a recommendation on how it plans to proceed with issues surrounding the EPA’s designation of 22 counties as nonattainment areas for PM 2.5.

September 1 is the deadline for DEP’s response to the proposed designations.

DEP has disagreed with EPA’s recommendation of at least six of the 22 counties EPA included in its designation and is expected to submit comments suggesting they be changed.

This discussion is important because to meet the new standard additional controls on sulfur dioxide, ammonia, nitrogen oxide and volatile organic compounds may be needed, although the precise degree of control has not yet been established.

The counties DEP recommended were: Allegheny, Beaver, Delaware, Berks, Cambria, Chester, Cumberland, Dauphin, Lancaster, Philadelphia, Washington, Westmoreland and York. EPA added Armstrong, Butler, Greene, Indiana, Lawrence and Mercer.

DEP has raised other concerns with the designations. DEP argues EPA did not fully disclose and subject to public review the entire process they were using to make the designations, included areas in Pennsylvania for reasons other than air quality concerns directly in those counties and did not factor in regional emission reduction strategies.

PM 2.5 pollution in Pennsylvania is also heavily influenced by pollution coming in from other states on particulate matter, just like ozone pollution. So what happens in other states has a big impact here.

The Southwestern Pennsylvania Growth Alliance, a regional economic development group in Western Pennsylvania, has weighed in on this issue as well, saying in a letter to DEP—

“The Growth Alliance strongly supports efforts to improve air quality in southwestern Pennsylvania. However, most of the monitors in southwestern Pennsylvania that exceed national standards do so by only small amounts, and this is likely due to pollution from other states, not from our region.

“Recent studies at Carnegie Mellon University show that 80% of PM 2.5 in southwestern Pennsylvania is coming from sources outside of our region. Moreover, the only area in southwestern Pennsylvania that is significantly exceeding the standard is the Monongahela Valley, due to a unique combination of local emissions, conditions, and monitor placement.”

The Growth Alliance recommended a separate nonattainment area for southern Allegheny County and to remove Armstrong, Butler, Greene, Indiana, and Lawrence counties. They also suggest Beaver, Washington, and Westmoreland, and the portion of Allegheny County outside of the Monongahela Valley, should not be designated as nonattainment, but should be designated as ‘overwhelming transport’ or ‘transitional’ areas.

In addition, the Growth Alliance recommends EPA, “move aggressively to adopt and implement national regulations to address transport. The current deadline means that more than a decade will pass before such controls are in place, yet EPA is proposing that local areas come into attainment within five years.”

EPA hopes to finalize the designations in November, followed in 2005 by finalizing the rule telling states how they must go about developing plans to achieve the standard. States must then submit the plans in 2008 after extensive inventory and modeling work.

Also on the advisory committee’s agenda is an update on a variety of clean air programs (8-hour ozone pollution standard, regional haze, mercury reduction requirements, a regional multi-pollutant strategy with the Northeast Ozone Transport Commission to coordinate the requirements of various air programs), a proposed air quality enforcement policy, review of New Source Review options and a discussion of DEP’s air permit streamlining project.

7/30/2004