
PennEnvironment Testimony to the PA DEP on PM 2.5 National Ambient Air Quality Standard
We encourage PA-DEP to err on the side of caution and make designation of nonattainment areas as broad as possible.

January 21, 2025
Re: Designation Recommendations For The 2024 Primary Annual Fine Particulate Matter (Pm2.5) National Ambient Air Quality Standard
Dear Secretary Shirley:
On behalf of PennEnvironment Research & Policy Center I submit the following testimony on the above-referenced proposal.
PennEnvironment affirms the report’s assessment of the public health risks of fine particulate matter: premature mortality, aggravation of respiratory and cardiovascular disease, lung disease, decreased lung function, asthma attacks, increases in respiratory symptoms like coughing and difficult or painful breathing, chronic bronchitis, and certain cardiovascular problems such as heart attacks and cardiac arrhythmia.
Additional environmental impacts from fine particulate matter include haze, visibility impairment, acid rain formation, fish kills/algae blooms in waterways, soil nutrient depletion, and damage to forests.
Given the significant negative impact, we encourage PA-DEP to err on the side of caution and make designation of nonattainment areas as broad as possible.
PennEnvironment supports the designation of five counties, Allegheny, Dauphin, Lancaster, Philadelphia, and York, as nonattainment areas.
Yet at the same time, the monitoring data shows additional sites that are at or just below the NAAQS of 9.0 micrograms per cubic meter. This includes Butler, Westmoreland, and Cambria counties. We urge PA-DEP to include these counties as non-attainment designations given the significant air pollution problems facing them. Given that Pm2.5 is unsafe at any level, it is critical that Butler, Westmoreland, and Cambria counties with significantly high levels of Pm2.5 receive the same safeguards and those currently in the proposal for nonattainment.
It’s important to measure the air quality in the multiple counties that directly border nonattainment counties. PennEnvironment requests that PA-DEP establish monitoring of PM2.5 levels in counties neighboring nonattainment counties such as Butler and Westmoreland counties (next to Allegheny County), and Lehigh and Bucks Counties (next to Montgomery and Philadelphia counties).
Lastly, for the remainder of the “unclassifiable/attainment,” we request that PA-DEP clarify whether this means there are no monitors or data at all in these areas, and if that’s the case, how it intends to measure air quality in these counties. We request that PA-DEP establish monitoring of PM2.5 levels throughout the commonwealth.
Thank you for the opportunity to testify on this matter.
Sincerely,
Wanda Wilson, Western PA Advocate
PennEnvironment Research & Policy Center
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Wanda Wilson
Western Pennsylvania Advocate, PennEnvironment Research & Policy Center
Wanda mobilizes coalitions, engages officials, and reaches out to citizens on PennEnvironment's campaigns and priority issues in Pittsburgh and throughout Western Pennsylvania. Wanda lives in Pittsburgh with her husband and daughter enjoying the local theatre scene, her e-bike, reading, and cooking for family and friends.