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.