Docket No.
EPA-HQ-OAR-2005-0172
Environmental
Protection Agency Philadelphia
Hearing on Ozone Pollution Standards
August 30, 2007
Testimony of Nathan
Willcox, Energy & Clean Air Advocate with PennEnvironment
Good morning. My name
is Nathan Willcox, and I am the Energy & Clean Air Advocate for PennEnvironment. PennEnvironment is a non-profit and
non-partisan environmental advocacy organization with roughly 15,000 citizen
members across Pennsylvania. Thank you for giving me the opportunity to
testify today on the Environmental Protection Agency’s (EPA) proposal to revise
the national air quality standard for ozone “smog” pollution.
PennEnvironment is pleased that EPA is taking a step toward
cleaner air for Pennsylvania and
the entire country by proposing to strengthen the national air quality standard
for ozone. Unfortunately, EPA’s proposal
falls short of the ozone standard its own scientific advisors said is necessary
to protect public health, and its proposal leaves open the possibility of not
strengthening the ozone standards at all.
Ozone is a powerful pollutant that can burn our lungs and
airways, causing health effects ranging from coughing and wheezing to asthma
attacks and even premature death. Children, teenagers, senior citizens, and
people with lung disease are particularly vulnerable to the health effects of
ozone. New epidemiological and clinical
studies show the health impacts of breathing ozone at levels lower than the
current ambient air quality standard. In
fact, clinical studies of otherwise healthy adults have found decreased lung
function, increased respiratory symptoms, inflammation, and increased
susceptibility to respiratory infection at or below the current standard of
0.08 parts per million.
Locally, ozone pollution is a problem that the Philadelphia
area knows all too well. Most recently,
the American Lung Association ranked the Philadelphia
metropolitan area as being the 12th worst nationwide for ozone
pollution, in its 2007 State of the Air
report. The report also gave grades of
‘F’ for ozone pollution levels to Philadelphia,
Bucks, Chester, Delaware
and Montgomery counties, as well as
nine other counties across Pennsylvania. Cleary, this is a problem that hits too close
to home in Philadelphia.
The independent Clean Air Scientific Advisory Committee
reviewed a 2,000 page summary of the scientific research of the health impacts
of ozone and unanimously concluded that the current ozone standard is not
adequate to protect human health.
Under the Clean Air Act, air quality
standards must be set at levels that protect public health, including that of
sensitive populations, with an adequate margin of safety. As a result, the Clean Air Scientific
Advisory Committee recommended setting a new ozone standard in the range of
0.060 to 0.070 parts per million.
EPA’s proposal to strengthen the standard to within a range
of 0.070 parts per million to 0.075 is therefore weaker than what the agency’s
scientific advisors say is necessary to protect public health. While stronger than the current ozone
standard, the proposal fails to protect public health with an adequate margin
of safety. In effect, EPA’s proposed
standards would protect millions of Americans but would continue to leave
millions more—particularly those with lung disease or who are otherwise
sensitive to air pollution—exposed to the harmful effects of dirty air.
Alarmingly, the new EPA proposal also leaves the door open
to retaining the current ozone standard.
Scientists and even EPA Administrator Johnson have said that the current
standard is not good enough to protect public health. One has to wonder why that option is even still
on the table. One possible factor is
that in the weeks leading up to the
release of EPA’s proposal, representatives for the electric utilities, chemical
industry, oil companies, and the automakers organized high-level meetings with
Bush administration officials to discuss the new ozone standards.
Every American—and every Pennsylvanian—deserves to breathe
clean air. EPA should reject industry pressure to retain the current standard and
instead adopt an ozone standard of 0.060 parts per million, consistent with the
recommendations of its scientific advisors.
Thank you again for this opportunity to speak to you today.
