It’s too Dangerous to Breathe Outside in Louisville

LOUISVILLE, KY – The Environmental Protection Agency (EPA) has proposed redesignating Louisville to being in attainment with the 2015 8-hour ozone National Ambient Air Quality Standards (NAAQS), while just this past weekend we saw local government send out an air quality alert for Saturday, June 17. The alert shared that there was ozone pollution forecasted at levels that were unhealthy for sensitive groups. From the alert:

“Sensitive groups include children, older adults, those with lung disease, and others that are active outdoors. Sensitive groups should reduce prolonged or heavy outdoor exertion, take more breaks, and do less intense activities. Others in the general public are less likely to be affected, but should also be aware of symptoms like coughing, shortness of breath, or other respiratory issues.”

EPA issued a proposed rule that would redesignate Louisville to being in attainment, proposing to find that Kentucky has reached attainment and has demonstrated a permanent improvement in air quality. In its proposed rule, EPA said that "there is no information in the record inconsistent with . . . achieving environmental justice for people of color, low-income populations, and Indigenous peoples." 

Louisville ranks in the 89th percentile in EPA's ozone environmental justice index, meaning that only 11% of the country's population has worse environmental justice index values. The rate of asthma morbidity for Black residents of Jefferson County is roughly 2.4 times higher than for White residents. Black children in Kentucky are almost 3 times more likely to have asthma than white and Latino children. In 2022, Louisville ranked among the top five cities in the United States for the highest rate of emergency department visits for asthma (p.12).

“As we get ready for another weekend going into the summer, we cannot ignore the fact that the State is asking the EPA to say Louisville has no harmful air quality problems when it does,” said Sierra Club Kentucky Chair Drew Foley. “Changing Louisville’s EPA ozone designation to "in attainment" would send a message that having days you cannot go outside and enjoy the day is the new normal; we cannot accept that! We must hold those of us responsible for poor air quality to account, and the state should push polluters to curb their pollution for the betterment of Kentucky residents.”

Sierra Club opposed the redesignation and submitted three points to the EPA, arguing that Louisville residents would be further harmed by the redesignation:

• The environmental justice argument described above: Due to the environmental justice impacts of ozone in the Louisville, KY area--specifically, the significant adverse burdens of ozone pollution on Black and low-income residents--EPA should deny the request for redesignation. 
• The Louisville, KY area is not in attainment, because under ordinary mathematical conventions, it is not in attainment for the most recent time period (2020-2022) or any prior time period except 2019-2021. (It's only in attainment for 2020-2022 if you round down from 0.70667 to 0.70, which EPA does.)
• The record has not demonstrated, and cannot demonstrate, a permanent and enforceable reduction in emissions. The increase since the anomalous 2019-2021 time period shows that Louisville’s emissions are on an upward trajectory–not permanently reduced. Further, Kentucky has not demonstrated any connection between emissions reductions in Louisville and federal and state measures, as required by the EPA. And the time period Kentucky uses to demonstrate attainment includes the pandemic. The record indicates that emissions dipped during the pandemic temporarily, and EPA's efforts to rule out the pandemic as a reason for the decrease omit important data (decreased flights) and minimize the importance of other data (decreased use of cars/vehicles and decreases in power plant emissions).