[StBernard] suflur dioxide issue

[Westley Annis]

Some of you may already be familiar with St Bernard Parish's air quality and pollution control issues.
 
Well, here are some comments from another area of the country that is also nonattainment for sulfur dioxide.
A lot of what this group states is also true here at home.  
 
http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2012-0233-0232 <http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2012-0233-0232> 
 
 
March 15, 2013
 
Docket ID No. EPA-HQ-OAR-2112-0233
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On behalf of the Board of Directors of Clean Air Muscatine, Inc. (CLAM), I would like to comment on the U.S. Environmental Protection Agency’s recommendation that Muscatine County be designated “nonattainment” for the one-hour sulfur dioxide (SO2) National Ambient Air Quality Standards.
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CLAM is a non-profit membership corporation established for the purpose of promoting a cleaner environment in Muscatine County.  With more than 100 members, a primary focus of CLAM’s efforts has been to bring public attention to, and to support effective remediation of, the very poor air quality in our community that adversely affects the health of our citizens and the economic vitality of our region.
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To that end, we are supportive of effective regulatory action, based on sound public health and scientific research, aimed to clean our air.  We know that excessive SO2 emissions deprive healthy people of their ability to live their lives as actively as they might wish. We know that such emissions pose real threats to the health, particularly that of our most vulnerable citizens:  children, the elderly, and those with chronic respiratory health conditions.  We note with special concern that a large share of the scientific data supporting the nonattainment designation—including some of the very highest SO2 concentration levels--come from monitors located in a city park filled with picnic tables and children’s playground equipment.
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We also know that excessive SO2 emissions impede a community’s ability to enjoy economic progress.  New businesses and vital workers with skill sets for tomorrow’s industries, if given a choice, will choose to live and to work in communities where the air quality does not impede their enjoyment of life and threaten their health and the health of their families.  Businesses that are looking for a place to locate or to expand will be deterred from locating in a community that has failed to assure all citizens access to a clean, healthy environment.
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The non-attainment designation by the USEPA is a wake-up call that when it comes to poor air quality, Muscatine has become an outlier nationally.
 
The excessive SO2 emissions that have fouled our air appear to be primarily the unfortunate result of outdated and careless industrial practices by the owners of a few businesses—and we urge your agency to take every reasonable measure to make those businesses conform to the law and to use proven industrial practices and technologies that, if implemented, will allow vast improvements to our air quality. 
 
While CLAM strongly believes that we all have a role to play in improving the quality of our air, it is also the case that these few local industries, in particular, have been so abusive to our air as to place unfortunate financial and regulatory burdens on the rest of us—such as those that will result from the nonattainment status proposed by your agency. In the short term, according to the U.S. Chamber of Commerce, non-attainment status for Muscatine will likely cause a loss of federal highway dollars, an increase of local fuel costs, a more rigorous regulatory oversight and permitting processes, and mandatory emissions offsetting. 
 
The burdens to borne by the nonattainment designation do not outweigh the burdens already imposed by the excess emissions from these few local industries, however. CLAM therefore supports such designation, and sees no viable alternative to a county-wide designation.  While the S02 readings are highest in the neighborhoods surrounding the worst offenders of our air quality laws, air is not stagnant and it moves to cover all citizens who reside in our county.  Importantly, if we are to change behaviors that result in the pollution of our air, we need the care, concern and public support for these changes that will most strongly result if the entire county, and not just a part of the City of Muscatine, is designated as nonattainment.
 
For these reasons, we support the USEPA’s proposal and wish for its continued firm and effective enforcement of our air quality laws.
 
 
Respectfully submitted,
 
Sandra Stanley
President, Board of Directors
Clean Air Muscatine, Inc.
PMB 126
2807 University Drive
Muscatine, IA 52761
563-607-0852
cleanairmuscatine at gmail.com