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Read MoreThe email address for the Department of Health, division of Air Management Services is DPHAMS_Service_Requests@Phila.Gov
Click here for previously posted notes and comment points
Many thanks to all who wrote emails, and/or testified or attended the Health Department’s virtual Public Hearing on July 27th, 2023! We also thank Health Commissioner Bettegole and Deputy Commissioner Raval-Nelson for convening the hearing and inviting written testimonies and comments from the public up until August 31st. We are still waiting for a response to comments.
*AMS grants air contamination permits and enforces them. They also monitor ambient air quality in some sections of the city, (but not ours). Dr. Kassahun Sellassie is director.
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Our Comments were based on these documents: Amendments to AMR VI AMR VI Technical Guidelines. Health Risk Assessment Technical Support for AMR VI.
Useful vocabulary~
AMS (Air Management Services): the division of the Philadelphia Health Department which approves, denies, and enforces “air contamination permits,” provides notice to the public, conducts public hearings, and manages ambient air monitoring to measure air quality across the city.
Air Contamination Permit: written contract that gives permission to pollute the air, subject to federal, state and municipal codes, (also called air permit or air pollution permit).
Air Management Regulations rules for Philadelphia that can be created and amended by the Air Pollution Control Board and/or City Council. They must follow federal and state codes but are permitted to exceed their stringency, unless State law prohibits it.
Air Pollution Control Board: 7 Mayoral appointees and the Health Commissioner oversee AMS, can propose amendments to regulations and new regulations.
CHP Combined Heat and Power Plant (fuel burning)
Criteria Air Pollutants: 6 air pollutants for which legally acceptable levels of exposure can be determined and for which ambient air quality standards has been set : carbon monoxide (CO), ground level ozone (O3) nitrogen oxides (NOx, sulfur oxides (SOx), particulate matter (PM 10 and PM 2.5) and lead (Pb). Emissions of criteria pollutants are measured in tons/year.
EPA Environmental Protection Agency, the federal agency that enforces federal environmental laws, including The Clean Air Act
HAPS (Hazardous Air Pollutants). Highly poisonous materials in the air. Small exposures are known to cause cancer and central nervous system diseases. Examples: benzene, carbon tetrachloride, formaldehyde, lead, asbestos. (HAPS are also called TACS- Toxic Air Contaminants)
Major Source (of pollution): A large source of pollution, as determined by EPA limits on criteria pollutants. Local examples include the former PES refinery, Vicinity Energy plants, Grays Ferry Cogeneration plants, Excelon plants, the PGW LNG plant at Port Richmond.
Minor Source (of pollution): A source of pollution with criteria pollution emissions less than the threshold for a major source
PA DEP Pennsylvania Department of Environmental Protection
Synthetic Minor Source (of pollution) A facility that uses equipment capable of emitting a major source of pollution, but agrees to keep annual criteria emissions under minor thresholds.
TACS (Toxic Air Contaminants) Highly poisonous materials in the air. Small exposures known to cause cancer and central nervous system diseases. Examples: benzene, carbon tetrachloride, formaldehyde, lead, asbestos. Also called HAPS (Hazardous Air Pollutants.)
Title V: Major Source
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The appeal to SEPTA’s Air Contamination permit process began December 2017. In November 2019 the Board of Licenses and Inspections Review (BLIR) sided with “The City” (Air Management Services,) and against the appeal. This appeal was a combination of an appeal brought by NAGP, and one by Center for Returning Citizens (TCRC) in collaboration with 350 Philadelphia. Later, NAGP appealed the BLIR’s decision to the Philadelphia Court of Common Pleas. We withdrew that appeal after we concluded that our attorneys had little chance of winning. A loss would have set a negative precedent for the basis of our appeal: the PA Constitutional Environmental Rights Amendment. Soon after we withdrew the case, SEPTA started up the gas plant.
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