Sustainable Pittsburgh
Policy Recommendations for Transition Teams
April, 2000
ALLEGHENY COUNTY HEALTH DEPARTMENT
Overview
The Allegheny County Health Department (ACHD) is responsible for public health, the monitoring and control of environmental hazards including air pollution and monitoring and enforcement of clean water regulations. The department's role in dealing with air and water pollution is the area where it has the greatest impact on sustainable development in the county. The Department is also involved in water and wastewater regulation, in particular the separation of storm and sanitary sewers and wastewater planning.
Air permitting and water regulations have a critical influence on sustainable development. Allegheny County has numerous previously developed industrial properties that are potentially attractive sites for redevelopment and reuse by business and industry in lieu of previously undeveloped sites at other locations. Potentially, these previously developed sites within Allegheny County have the needed infrastructure, are integrated into the community and present an opportunity to grow the local economy while minimizing the sprawl normally associated with industrial development. In fact these sites represent an opportunity to reverse sprawl while promoting industrial growth. The previously developed and now inactive or underdeveloped properties are a significant asset for the county. However, development of these previously used properties, especially for industrial use, normally requires two things under the control of the ACHD: air permits and water/wastewater services. Air pollution regulation is the area where the ACHD has the greatest impact.
Air Regulation. ACHD handles air permitting within Allegheny County for stationary emission sources. This category includes industrial furnaces, incinerators, boilers and other industrial equipment. The County has its own specific Air Quality regulations. In surrounding counties and the rest of the state, with the exception of Philadelphia, air permitting and air quality regulation is handled by the Pennsylvania Department of Environmental Protection. In many larger industrial areas across the country, a similar situation with air quality regulation conducted locally appears to exist. However, at many of these locations, while permitting is conducted locally, regulations are developed at the state and federal level.
Local control of the regulatory and permitting process can hinder or help sustainable development in Allegheny County as it relates to the redevelopment of formerly used industrial property. Several factors should be considered in determining whether air quality regulation and permitting at the local level is preferable to transferring this function to the state, as is done in surrounding counties.
Local knowledge: Handling air pollution regulation and control at the local level allows enables information specific to the county to be considered more dominantly than would occur with state or regional control. Local knowledge includes an understanding of the local environment as well as local pollution problems.
Topography, climate, demographics, and the distribution of current industrial sources, are all factors in to be considered in air pollution modeling and regulation. An understanding of these factors can result in more appropriate regulation and technical solutions to local problems. In this regard, ACHD 's local air monitoring network and experience in dealing with past modeling and permit evaluations is a potential benefit in evaluating new permit applications by industries seeking to redevelop industrial sites.
Knowledge of local pollution problems was important in local air-quality regulation in the past, and may be so again in the future. Historically, Allegheny County had air pollution problems that were specific to the industries located in the county. For example, at one time approximately 40% of the coke production in the country was located in the county, along with the pollution problems specific to this industry. The county was a leader in dealing with pollution problems associated with a local industrial base that differed from that found in other areas. However, air pollution problems have evolved from a local issue to a regional one. Currently, ozone and other regional problems are the focus of air pollution control. These problems are more appropriate to state and even regional regulation rather than local. Future air-pollution problems that are likely to require a local focus include fine particulates and air toxics.
Public Involvement: A local air-quality bureau and local regulations provides a greater opportunity for public involvement in resolving air quality problems. At its best, local involvement can mean public participation, education and ultimately an informed consensus to arrive at a sound technical solution that is acceptable to the citizens of the county. At its worst, it provides an opportunity for a vocal minority to influence technical and regulatory decisions. Local public participation in the regulatory process can be a significant challenge to industries seeking to redevelop former industrial sites.
Local Assistance: A local air-quality bureau provides a local contact that could assist prospective developers through the air permitting process. Because county regulations differ from state regulations, some local assistance is preferable. Alternately, assistance offered to industry at the state level, such as through ENVIROHELP, is not directly applicable to Allegheny County.
Flexibility: A local air-quality bureau and local regulations may allow greater flexibility in dealing with air quality problems. While some flexibility is possible, it is largely in the potential to use local knowledge in dealing with prospective or existing industries in to arrive at innovative solutions to offset emissions. Regulatory flexibility is limited by the need to meet or exceed state and federal standards. Thus, in practice, local regulations may be more restrictive than those at other locales, but are not less stringent and generally are not more accommodating.
Cost: The cost of having a local air-quality bureau for regulation and permitting appears to be a modest net cost to the county. The exact cost varies from year to year depending upon grants, fees, and other funding received from outside sources. If a local air-quality bureau promotes redevelopment within the county, then a moderate cost for administering the program may be justified. In assessing whether to continue regulating air quality at the local level is desirable, a detailed accounting of the actual cost of the air quality program in the county should be considered.
CONCLUSION
Air Quality: There are three possible roles the county can play:
Continue to conduct air quality permitting and regulation on a local level if the local program with local knowledge, local sensitivity and local accessibility can promote redevelopment of unused properties.
If a local permitting and control process is desirable, but having local regulations is unnecessary, then adopt the state regulations and continue local administration of the program.
If a local air-quality bureau is determined to be unreceptive to industrial development, unable to assist because of political pressures or an unnecessary cost to the county, then transfer air permitting to the state, and consider replacing the bureau with an entity that will assist developers with air permitting procedures.
Water and Wastewater: The County's potential impact on redevelopment in the area of water and wastewater planning and control is not as direct as in air regulation, but it has considerable influence on industrial development:
Availability of water and sewers is vital to most industries. In the past, industrial wastewater discharges were often directly to waterways and regulated by the state. Increasingly, industrial discharges are to sewage treatment plants and are regulated by the county through the local sewer authorities. In this role of regulating local sewage works, the county can play a role in facilitating local industrial redevelopment by providing regulatory and technical assistance.
The county can also play a role in solving the combined sewer overflow problem. In the next several years, considerable dollars and effort will be spent to upgrade and modify existing sewers and sewage facilities. The cost of upgrading sewers serving existing sites may be about the same as constructing new ones to undeveloped sites. However, since existing sewers will be upgraded, consideration to accommodating future redevelopment should be included. Thus, dollars spent to meet current requirements can be a potential advantage to encourage future redevelopment to existing unused sites as well.
The ACHD's role as a regulator can also serve as a resource to promote industrial redevelopment while at the same time protecting public health and the environment. From the standpoint of sustainable development, the Department should assure its activities in the areas of water and wastewater include efforts to encourage industrial redevelopment.