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3/8/2006

Testimony to U.S. EPA on Proposed Particulate Matter ("Soot") Standards


Testimony for the March 8, 2006 U.S. Environmental Protection Agency Public Hearing Regarding Proposed Particulate Matter Standards (Docket ID No. OAR-2001-0017)

Nathan Willcox, Energy & Clean Air Advocate

PennEnvironment

Good afternoon.  My name is Nathan Willcox, and I am the energy and clean air advocate with PennEnvironment.  PennEnvironment is a statewide non-profit and non-partisan environmental advocacy organization with more than 18,000 citizen members across Pennsylvania.  Thank you for giving me the opportunity to testify today.  I am here to urge you to heed the scientific community and protect public health by substantially strengthening the air quality standards for fine particle soot pollution.

Fine particle soot is the nation’s deadliest air pollutant and one of its most pervasive.  Fine particles can lodge deep in the lungs or even enter the bloodstream, causing serious respiratory and cardiovascular problems such as asthma attacks, heart attacks, lung cancer, and strokes.  These small particles are so dangerous that they cause tens of thousands of premature deaths every year, cutting off the lives of victims by an average of 14 years, according to one EPA estimate.  Combustion sources such as coal-fired power plants and diesel engines are the largest source of fine particles, which can fall close to home or travel thousands of miles through the air.

While air quality has improved in the U.S. since the inception of the Clean Air Act in 1970, by the EPA’s own count 88 million Americans still live in areas with unsafe levels of soot pollution.  In our own recent survey of state environmental agencies, we found that fine particle levels exceeded national air quality standards for soot in nearly half the states, including Pennsylvania.  In fact, in 2004, Pennsylvania ranked 2nd in the nation for the worst annual soot pollution, with Pittsburgh and Philadelphia ranking 2nd and 16th respectively for the worst annual soot pollution among major metropolitan areas.  What this means is that these areas were polluted year round, with sensitive groups such as senior citizens, children with asthma, and people with heart and lung disease suffering the most.

Incredibly, despite the magnitude of the health risks from fine particles, we had no national air quality standards for fine particle soot pollution until 1997.  Today, we are still operating under the same annual and daily standards that the EPA adopted then, standards intended to establish how much soot is safe to breathe on a regular basis and on any one given day.

Unfortunately, the levels at which both the annual and daily standards were set are far too weak to protect public health.  Numerous studies have shown that fine particle exposure, whether long-term or short-term, has devastating health effects even at levels well below the current standards.  And the more we learn about the health effects of soot, the more we realize the severity of the threat.  For instance, a major study published just last November found that the chronic health effects of fine particles are 2-3 times greater than previously believed and that for each increase of 10 micrograms per cubic meter of fine particles in the air, the risk of death from any cause rose by 11-17 percent.

Such knowledge demands action.  And so does the law.  Under the Clean Air Act, the EPA must set air quality standards to protect public health, including the health of sensitive groups, with an adequate margin of safety.  The agency must also review air quality standards every five years to ensure that they reflect the latest scientific knowledge and update the standards as needed.

Last year, both the EPA’s staff scientists and the Clean Air Scientific Advisory Committee, the administration’s independent science advisors on air pollution issues, concluded that the current fine particle standards are too weak to protect public health.  As a result, they recommended that the administration strengthen the standards.  The medical and scientific communities both endorsed the strongest standards within the EPA’s recommended ranges: 12 micrograms per cubic meter for the annual standard and 25 micrograms per cubic meter for the daily standard.

Regrettably, despite having acknowledged that soot pollution is our “most pressing air quality problem,” the administration has chosen to disregard the advice of its own scientific advisors.  In the face of overwhelming evidence of the harmful effects of fine particles, it has proposed no change whatsoever to the annual standard and only a limited reduction in the daily standard—a reduction that will have little impact on public health.  In short, it has opted to largely maintain the status quo, under pressure from power companies and other influential special interests and at the expense of public health.

I am extremely disappointed in the administration’s proposal, which puts politics over science and the law, leaving millions of Americans to suffer the consequences.  But it is not too late to change course.

If the administration is serious about fighting soot pollution, it must adopt strong, health-protective standards.  I urge the administration to heed the science and adopt an annual standard no higher than 12 micrograms per cubic meter and a daily standard no higher than 25 micrograms per cubic meter.  Air quality standards are the foundation for reducing air pollution nationwide, so this decision is one of the most important decisions this administration will make on air pollution issues.

I would also like to take this opportunity to express my dismay over the administration’s efforts to weaken public health and environmental protections against pollution from power plants, the nation’s largest industrial source of air pollution, and other smokestack industries.  These policies will only worsen the impacts of air pollution in Philadelphia and across the country.  I especially urge the administration to abandon its assaults on the New Source Review program, which is critical to cleaning up the many aging power plants that continue to operate without modern pollution controls.

Thank you.