CONSAD Research Corporation

Economic Development

Environmental Analysis

Economic Consequences of the Proposed Liberty Borough Area Particulate Matter Nonattainment Reclassification

The U.S. Environmental Protection Agency (EPA), on September 19, 1995, proposed to find that the Liberty Borough, Pennsylvania area -- comprising the City of Clairton and the Boroughs of Glassport, Port Vue, Liberty, and Lincoln -- had not attained the national ambient air quality standard (NAAQS) for particulate matter of nominal aerodynamic diameter smaller than 10 micrometers (PM-10) by the Clean Air Act mandated attainment date (of no later than December 31, 1994) for moderate nonattainment areas (Federal Register, Vol. 60, No. 181, p. 48439). This finding was based on three years of air monitoring data (from 1992 to 1994) that do not reflect the full implementation of controls (by December 1, 1994) specified in the Allegheny County PM-10 State Implementation Plan (SIP) designed to achieve attainment. Moreover, the nonattainment designation is solely a result of air monitoring exceedences at only one of 10 monitors (i.e., the Lincoln High-Volume monitor) whose findings, interpretation, and siting have been the subject of much controversy.

In particular, this study examines the economic consequences of EPA's proposed action on both the businesses and the communities expected to be affected. This study was been performed in response to EPA's request for public comment with this proposed action to reclassify the Liberty Borough area as a serious nonattainment area for PM-10, including comment as to whether there are any mitigating facts or extenuating circumstances that it should consider in its review.

The findings of this study strongly indicate that the EPA is misleading in its statement that the additional burdens imposed by this proposed reclassification do not, in-and-of-themselves, impose any new requirements on any sectors of the economy (including small businesses) or on local communities, because its actions must occur by operation of the law (and the resulting requirements are automatically triggered by the reclassification). Indeed, reclassifying the Liberty Borough nonattainment area from moderate to serious will result in a variety of onerous requirements including:

• The need for a second state implementation plan (SIP) revision, when over five years and $1.5 million were spent by Allegheny County on the first SIP revision.
• An increased call for more stringent, more costly PM-10 control measures (BACM vs. RACM) for some existing facilities, when current measures have not been given the chance to work and show their impact.
• The redefinition of a "major source" (from 100 to 70 tons per year), potentially imposing new requirements on other existing facilities that were not previously major sources.
• The need to define additional "contingency" measures to assure attainment.
• More stringent, more costly burdens on new firms desiring to locate in or near the nonattainment area.
• The imposition of highway funding sanctions if deadlines are not met.

As a result of these requirements, it is estimated that a variety of adverse impacts could occur.

These impacts would most likely include:

• A substantial amount of employment directly at risk as a result of the additional PM-10 control measures that would likely be imposed with:
• more than 2,700 jobs directly affected, many seriously,
• more than 90 percent in manufacturing facilities, and
• over 1,900 jobs in the five community nonattainment area representing 45 percent of all jobs in this area.

• A larger amount of employment indirectly at risk with:
• 5,500 to 8,200 jobs indirectly impacted, primarily elsewhere in Allegheny County, Southwestern Pennsylvania, and the surrounding region, and
• many of these jobs likely to be in small businesses.

• Several hundred thousands of dollars in unfunded costs for municipal governments, on an annual basis, for:
• a new SIP for the nonattainment area, and
• road sweeping controls to reduce road dust.

• Severe constraints for increased economic development in the nonattainment and surrounding areas with:
• increased difficulties for existing facilities to expand operations,
• missed opportunities for attracting new businesses,
• missed opportunities for improvements to the local and regional highway systems, especially if federal funding sanctions are imposed, and
• make-or-break financial burden for the affected communities which are already economically disadvantaged and faced with high unemployment.

In conclusion, the controversy concerning the interpretation of data from (and the siting of) the Lincoln High-Volume monitor, the lack of air monitoring data for a three year period of time reflecting full implementation of the PM-10 SIP, and, most importantly, the prospective, adverse, economic impacts should the nonattainment area be reclassified from moderate to serious, are all "mitigating facts or extenuating circumstances" that deserve careful consideration by EPA in its decision-making process towards a final determination of whether the Liberty Borough PM-10 nonattainment area should reclassified. Without such a review, the economic survival of the five communities comprising the Liberty Borough nonattainment area, as well as many other communities in Allegheny County and throughout Southwestern Pennsylvania, could be, unnecessarily, severely jeopardized, with no certainty that the protection of public health would be improved.

If you would like a full copy of the CONSAD Particulate Matter Study, please feel free to e-mail a request to CONSAD

© CONSAD Research Corporation, 1999
UPDATE: 09/10/99