We need to protect our air quality at all costs 

August 22, 2022

Dear Director Rolband and the Air Pollution Control Board,

The Air Pollution Prevention Episode regulations are fundamental to Virginia's implementation of the Clean Air Act. These regulations are a key part of how Virginia meets the National Ambient Air Quality Standards, and are critical safeguards for public health and welfare. These regulations should not be weakened in any way. To do so would public health and the environment at risk.

Respectfully,

Nate Benforado

Senior Attorney

Southern Environmental Law Center

To Rachael Harrell and the Air Pollution Control Board, 

A study by scientists from the Environmental Protection Agency (EPA) published in the American Journal of Public Health found that facilities emitting dangerous particulate air pollution disproportionately impact low-income communities and communities of color.

After assessing particulate matter emissions from facilities in a nationwide study -- and the characteristics of the communities at the highest risk of health consequences due to exposure to it -- the study found that communities living below the poverty line have a 35% higher burden from particulate matter emissions than the overall population. Non-whites had a 28%  higher health burden and African Americans, specifically, had a 54% higher burden than the overall population. For these reasons, the Air Pollution Prevention Episode regulation is key to retaining cleaner air and better health for communities in Virginia. 

The Air Pollution Prevention Episode regulations should be retained and strengthened where possible through priority on health impacts to human beings. This regulation is necessary for the protection of public health, safety, and welfare.

The  Air Pollution Prevention Episode regulations are fundamental to Virginia’s implementation of the Clean Air Act. This regulation is a key part of how Virginia meets the National Ambient Air Quality Standards, and are critical safeguards for public health and welfare. They should not be weakened in any way. To do so, would put public health and the environment at risk. 

There are many possibilities  for strengthening the regulations for impacted communities. We recommend as part of The Air Pollution Prevention Episode regulations the incorporation of tools such as EPA's new EJ Screening Tool, or other similar tools, to be utilized to analyze the impacts to BIPOC communities and low-income communities.

Thank you,

Ann Creasy

Conservation Program Manager

Sierra Club Virginia Chapter