Total air pollution matters

#MiddleburyCT #AirQuality #AirPollution

Illustration 1 shows a circle with a 3-mile long radius within which sit five sources of air pollution: Interstate 84, the Towantic Power Plant, Oxford Airport, an Algonquin natural gas compressor station, and a proposed warehouse complex named Southford Park. Also within that circle are Long Meadow Elementary School and Pomperaug High School.

By RAYMOND PIETRORAZIO AND TERRY MCAULIFFE

For decades, Ray Pietrorazio has been paying attention to Middlebury’s air quality. The licensed combustion specialist and longtime town volunteer first raised his hand in the 1990s when he represented Middlebury as an intervenor before the Connecticut Siting Council during permitting of the Towantic Oxford Power Plant. He didn’t stop the plant. But he put Middlebury on record.

He’s still at it – and in his mid-eighties, he has two things he didn’t have 30 years ago. One is a map showing five air pollution sources – four existing and one proposed – within three miles of two Region 15 schools. The second is the knowledge a gap exists in state and federal protections against air pollution. Regulations govern pollution levels from each individual source; no regulations govern the cumulative pollution level caused by multiple pollution sources.

Illustration 1 shows a circle with a 3-mile long radius within which sits much of the town Middlebury residents live in – or drive through, or send their children to school in.

Inside that circle are five sources of air pollution: Interstate 84, the Towantic Power Plant, Oxford Airport, an Algonquin natural gas compressor station, and a proposed warehouse and logistics complex at Southford Park. Also inside that circle are Long Meadow Elementary School and Pomperaug High School.

Each of the sources is legal. Each is permitted. Each is regulated.

The total (cumulative) amount of air pollution generated by those sources is not regulated. That’s not an accident or an oversight by any single agency. It’s simply the existing system.

Air pollution regulation in Connecticut is divided by source. The state Department of Energy and Environmental Protection handles stationary sources – power plants, compressor stations, permitted facilities. The federal Department of Transportation and the FAA govern highways and airports. The Torrington Area Health District monitors public health. Middlebury’s Planning and Zoning Commission reviews land use. Middlebury’s Conservation Commission watches wetlands and water bodies.

Every permit has an owner. The air those permits allow to be collectively produced has no owner.

Illustration 2 visualizes the regulatory gap between individual air pollution emitters on the left and the total air pollution emitted on the right. Sources on the left are regulated; the much larger cumulative air pollution on the right is not.

Illustration 2 visualizes the regulatory gap between individual air pollution emitters on the left and the total air pollution emitted on the right. Each pollution source on the left is regulated and each contributes to the much larger cumulative air pollution on the right. No agency regulates that cumulative pollution, and that’s the air Middlebury’s schoolchildren breathe.

The authors brought this regulatory gap to DEEP’s attention in March. Connecticut DEEP confirmed this gap exists.

On March 20, 2026, we convened a video conference with two senior DEEP officials (Paul Farrell and Tracy Babbidge), State Rep. William Pizzuto, and a staff member from State Sen. Joan Hartley’s office. Ray presented the case methodically: the overlapping sources, the modeling limitations, the absence of any clear authority for cumulative assessment. The purpose was not to object to Southford Park. Not to accuse anyone of wrongdoing. But to ask a structural question: who is responsible?

Paul Farrell of DEEP was direct. Warehouse-driven truck traffic – diesel engines running in and out all day – falls into a category called “area sources.” The modeling tool used for stationary sources, known as AERMOD, is designed around fixed emission points. A warehouse has no smokestack. Its pollution moves with its trucks.

“That’s definitely a regulatory gap in our programs,” Farrell said.

Tracy Babbidge of DEEP acknowledged the concern as valid and went further. Addressing it, she told the legislators on the call, would require statutory authority – something DEEP does not currently have. “This is not something that DEEP can do with existing authority,” she said.

Rep. Pizzuto noted that constituent complaints about respiratory issues – among children, among older residents – had already prompted a legislative pause on certain warehouse approvals. He confirmed what the illustrations suggest: there is no agency clearly in charge of the cumulative pollution.

The meeting ended without a villain. It ended with a gap – named, acknowledged, and unresolved.

The research supports our concerns. A 2024 study published in “Nature Communications” by Dr. Gaige Kerr, a senior research scientist at George Washington University’s Milken Institute School of Public Health, found that communities near large warehouses face nitrogen dioxide levels roughly 20 percent higher than upwind locations. Nitrogen dioxide is a pollutant directly linked to childhood asthma. Kerr’s study, the first of its kind conducted nationwide, estimated that 15 million people living within one kilometer (.62 miles) of warehouses are exposed to meaningfully elevated pollution levels.
The mechanism is straightforward: trucks generate the pollution. Warehouses generate the trucks. Children nearby and downwind breathe the result.

Local geography also must be considered. Middlebury sits in a valley. On days when there is no wind – when an inversion settles in – pollutants from all those sources do not disperse. They stay. The schools sit in that valley.

Southford Park, if developed as proposed, would add substantially to truck traffic already generated by I-84 and the highways feeding it. Under the current regulatory structure, no agency is required to model that addition against everything else already in the circle.

For comparison: When the Towantic Power Plant was permitted, DEEP required full AERMOD dispersion modeling and offset credits from other sources to compensate for new emissions. That is the standard applied to a single stationary source with a smokestack. For a warehouse complex that could generate more than 1,100 tractor-trailer trips per day at ground level near a school, the current standard is nothing.

Middlebury is not alone. In Brookfield, a proposal to expand a natural gas compressor station – 1,900 feet from Whisconier Middle School – recently exposed the same structural problem from a different angle. Senate Minority Leader Stephen Harding, a Brookfield Republican, called it unacceptable. The town’s Democratic first selectman agreed. The Republican-American editorial board noted in February that Connecticut’s tradition of home rule sits in uncomfortable tension with a regulatory system that limits local influence over state energy decisions. The people most affected, the board observed, deserve a voice.

We are not arguing against development. We are not arguing against warehouses, or power plants, or airports, or the economic activity they represent. We are arguing that somewhere in the architecture of Connecticut’s regulatory system, someone should be responsible for adding it all up – before the permits are issued, not after our children are sick.

That is not a radical position. It is, in fact, a very old one: that government exists to see what individuals cannot see alone.

The question belongs to the legislature, to the agencies, and to the people who live inside that circle on the map. It is not a complicated question. It is not a partisan question. It is not even, at its core, a technical question.

It is this: when every agency watches only its own pollution, who watches the total air pollution?

Raymond Pietrorazio is a Middlebury resident, licensed combustion specialist, and the town’s appointed air quality representative. He represented Middlebury as an intervenor before the Connecticut Siting Council during permitting of the Towantic Oxford Power Plant. Connecticut Combustion Corporation, which he founded in 1977, continues to operate in Middlebury.

Terry McAuliffe is a Middlebury resident and civic volunteer.