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BOARD OF DIRECTORS June 1, 2015

Rev. Mark Johnston


President
Administrator Heather McTeer Toney
Nelson Brooke Sam Nunn Atlanta Federal Center
Vice President 61 Forsyth Street SW

Atlanta, GA 30303-8960
Sarah Mills Nee
Secretary
RE: Request for next generation air monitoring to gather data, empower citizens
Dr. Erin Thacker and improve public health for northern Birmingham communities
Treasurer
Dear Administrator McTeer Toney,
William Blackerby

Dr. Stacie Propst GASP is encouraged by EPA’s decision to include northern Birmingham commu-
Executive Director nities as a priority in the new Making a Visible Difference in Communities (MVD)
program. The program’s goals of “coordinating technical assistance” and “pur-
suing environmental improvements” will enhance economic opportunities and
quality of life for Birmingham residents.

In order to fulfill the goals of the MVD program, and the goals of the North Bir-
mingham Community Coalition (NBCC), of which GASP is a resource partner,
the ambient air quality in the communities must be improved.

Empowering Birmingham residents to collect data through the growing citizen


science movement is an ideal opportunity for EPA to make a visible difference
in the community. As Administrator Gina McCarthy recently stated, “commu-
nity-based air monitoring projects like this one (Newark’s project) make public
health a priority and pay multiple dividends. We not only gain valuable informa-
tion, we also help community members gain the skills and experience they need to
conduct citizen science projects in their communities to better protect their fami-
lies.”

Utilizing Next Generation technologies, GASP strongly encourages EPA’s Region


4 to seek resources from EPA headquarters and lead the development of a pilot
citizen air monitoring project in Birmingham. Fortunately, EPA has successfully
launched citizen air monitoring projects in the following communities:
• Houston/Galveston Citizen Air Monitoring Project
• Newark’s Community Air Pollution Project
• South Bronx Environmental Health Study
In addition to implementing a citizen air monitoring project, we request for EPA’s Region 4 (with
resources from EPA headquarters) and the Jefferson County Department of Health (JCDH) to
take the following action to improve air quality and public health:
• Incorporate mandatory fenceline monitoring to accurately assess emissions from ABC
Coke and Walter Coke, the county’s largest polluters and named PRPs.
• Implement demonstration projects similar to EPA’s Village Green Project, a park bench
with solar powered air monitoring station on its roof.
• Move forward on EPA’s TRI Community Engagement Program to identify pollution pre-
vention opportunities.
It has been established that the ambient air quality in northern Birmingham communities is un-
healthy despite claims from local regulatory agencies to the contrary. Examples around the coun-
try prove that localized hot spots for chemical exposures to both particulates and toxic pollution
exist for communities living in close proximity to large polluting entities. Evidence of North
Birmingham’s poor air quality include:
• EPA’s 2013 North Birmingham Air Toxics Risk Assessment revealed carcinogenic air con-
taminants present in the ambient air cause a risk to public health. These include Benzene,
Naphthalene, and Arsenic which each present a cancer risk exceeding JCDH regulations -
1.0E-05 (1 in 100,000) and a cumulative cancer risk from multiple air toxic contaminants
that exceeds 1.0E-04 (1 in 10,000).
• In 2014, the Agency for Toxic Substances and Disease Registry (ATSDR) released, Pub-
lic Health Assessment, Evaluation of Air Exposures in Communities Adjacent to the 35th
Avenue Superfund site in Birmingham, Alabama. The agency concluded that short term
exposures in the past and current long term exposures to particulate matter could result in
harmful effects for sensitive populations, i.e., children, the elderly and those with health
issues.
• In 2014, an NIH funded study by University of Alabama at Birmingham (UAB) research-
ers, Spatiotemporal association between birth outcomes and coke production and steel
making facilities in Alabama, USA: a cross-sectional study, reveals emissions of air con-
taminants within 5km of north Birmingham’s industrial center correlates to increased risk
of infant low birth weight and pre-term births.
• EPA’s Risk-Screening Environmental Indicators demonstrates that ABC Coke and Walter
Coke are the two “highest risk toxic air polluters” for Jefferson County.
• Community residents have expressed repeatedly, for decades, concerns regarding the soot
covering their homes, frequent foul odors, and exposures to toxic chemicals. The youth
focus group conducted for the Georgia Tech HIA stated that the neighborhood pool (Ma-
clin Park) is covered with soot, turning the water black in the summer.
• In the HRS Documentation Record, the EPA states that “[a]ir is the primary source of
deposition within the 35th Avenue site [area of observed contamination] from smoke-
stacks and windblown particles from process fires and other stockpiled material.”
Thank you for your consideration. We look forward to working with EPA, residents and other
partners collaboratively to improve the air quality and truly make a visible difference in north
Birmingham communities.

Sincerely,

Kirsten Bryant
Outreach Director

c:
Anita Davis
Administrator Gina McCarthy
Velveta Golightly-Howell, EPA Office of Civil Rights
North Birmingham Community Coalition Members
Birmingham City Councilors
Mayor William Bell
Representative Terri Sewell
Dr. Mark Wilson
Beverly Banister

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