Subject: Docket ID No. EPA-HQ-OAR-2001-0017 & EPA-HQ-OAR-2004-0018

Dear Administrator Johnson,

I am writing regarding Docket ID Numbers EPA-HQ-OAR-2001-0017 and EPA-HQ-OAR-2004-0018. I am concerned that the Environmental Protection Agency's proposed annual standards for particulate matter will not adequately protect human health.

More than 2,000 peer-reviewed studies link fine particulate matter (PM 2.5) to heart disease, respiratory ailments, and premature death. After reviewing the best available science, EPA scientists and the Clean Air Scientific Advisory Committee recommended that the annual PM 2.5 standard be strengthened to prevent illness and save lives. Yet the EPA proposal keeps the previous annual standard in place.

The Clean Air Act requires the EPA to use the best available science to determine acceptable levels of particulate pollution. I urge you to revise the proposed PM 2.5 standard to reflect the advice and recommendations of the science advisory committee and agency scientists. I also encourage you to effectively monitor all particulate matter pollution in urban and rural areas to help inform critical research into the consequences of this pollution. It is imperative that the EPA creates standards that ensure clean air and protect human health.

Sincerely,

What's At Stake?

New Air Pollution Rules Threaten Public Health

Fine particulate matter (or PM 2.5) consists of particles less than 2.5 micrometers in diameter, or about one third the diameter of a human hair. Sources of PM 2.5 pollution include agricultural activity, vehicle exhaust, and emissions from coal-fired power plants.

PM 2.5 has a profound effect on public health. It can easily become trapped in the human body and can have negative consequences for a person’s health. Over 2,000 peer-reviewed studies published since the current PM 2.5 standards went into effect in 1997 link fine particle pollution to strokes, heart disease, respiratory ailments, and premature death.

For example, one study showed that for each decrease of 1 microgram of soot per cubic meter of air, death rates from respiratory and cardiovascular diseases decrease by 3 percent. The EPA estimates that PM 2.5 kills 20,000 people and hospitalizes many more each year.

It is important that fine particulate matter standards are low enough to prevent these severe negative health effects.

Last year, the EPA’s Clean Air Scientific Advisory Committee (CASAC) recommended fine particulate standards with a maximum daily limit between 30 and 35 micrograms and an average annual limit between 13 and 14 micrograms. While the EPA’s new proposal lowers the maximum daily standards from 65 to 35 micrograms, the proposal leaves the average annual standard at 15 micrograms. According to the CASAC scientists, the average annual limit has a much more significant effect on public health.

A study funded by the EPA and the National Institutes of Health published in the Journal of the American Medical Association in March concluded that even an exposure level of 13.4 micrograms of PM 2.5 would put 11.5 million elderly Americans at increased risk of cardiovascular and respiratory disease. "These findings provide compelling evidence that fine particle concentrations well below the national standard are harmful to the cardiovascular and respiratory health of our elderly citizens," said National Institute of Environmental Health Sciences Director David A. Schwartz.

The proposed standard does little to reduce the burden of death and disease from fine particle pollution. The number of people protected by the proposed standards increases by a mere 15 percent (from 56 million to 65 million). Meanwhile, more than 165 million people live in areas with PM 2.5 levels above levels research shows can adversely affect health.

Scientists Speak Out: EPA Misrepresented Scientific Research
By releasing this proposal the EPA is ignoring the recommendations of CASAC and its own staff scientists. It is highly unusual for the agency to disregard this committee’s advice.

In an unprecedented move, CASAC wrote a letter to the EPA Administrator Stephen Johnson to re-explain the science behind their recommendations and to urge him to reconsider the proposed standards. A second scientific advisory committee, the Children’s Health Protection Advisory Committee, has also written a letter to the EPA administrator claiming that the proposed standards do not adequately protect public health.

Furthermore, CASAC members alleged that the EPA had "twisted" or "misrepresented" the panel’s recommendations on a number of issues related to the proposed standards. According to the Los Angeles Times, committee member and epidemiologist Bart Ostro charged that "the EPA had incorporated 'last-minute opinions and edits' by the White House Office of Management and Budget that 'circumvented the entire peer review process.'" Ostro also said that the White House changes were "very close to some of the letters written by some of the trade associations."

The Philadelphia Inquirer also weighed in on this issue: "reports have surfaced showing that the White House worked to cast doubt on the scientific need for tougher standards, making dozens of changes to the EPA's draft standards before the policy was made public. For instance, the White House removed a sentence from the policy stating that the air-quality standards 'may have a substantial impact on the life expectancy of the U.S. population.'"

The EPA Considered Industry Costs, Not Health Effects
The Clean Air Act requires the Environmental Protection Agency to provide PM 2.5 standards that protect human health based on the best available science, particularly the health of "vulnerable groups" including children and the elderly. When considering safe levels of pollution in the air that we breathe, the EPA is only allowed to consider health effects. Nothing else can be considered, including economic, or even environmental, effects. According to its own scientific advisors, the EPA did not use the best available public health science in proposing the new standards. 

Furthermore, an EPA analysis recently made public by Greenwire—a newsletter that reports on energy and environmental topics—shows that an annual limit of 14 micrograms per cubic meter would result in high costs to industry. According to public health researchers at Harvard, limiting annual PM 2.5 pollution to the recommended average of 14 micrograms would save an estimated 9,000 lives per year. 

Dr. Phillip Hopke and Dr. Bernard Goldstein, both members of CASAC, have warned that the EPA’s standards open up the agency to lawsuits by not setting the standard based on the best available science.

Rural Areas and Some Industry Exempted
A second proposed rule would set standards for a larger air pollutant—course particulate matter. But these standard would only apply in urban centers. This effectively exempts smaller towns and rural areas with populations under 100,000 from monitoring. 

In addition, under the rule, the EPA wouldn’t monitor particulate matter levels in non-urban areas. In a letter to Stephen Johnson, CASAC again urged the EPA to keep monitoring particulate matter pollution in both rural and urban areas to help inform critical future research in this area.

Furthermore, the standards would not apply to all mining and agricultural operations—major beneficiaries of a relaxed rule.

A Pattern of Political Interference in Science
In this case, the White House Office of Management and Budget stepped in to distort the science behind the health effects of fine particulate matter. This case is yet another example of where political appointees have seemingly misused science for political reasons.

Disregard for and misuse of science has proven to be a problem at the Environmental Protection Agency—on issues like mercury pollution and climate change—and at other federal government agencies that depend on independent scientific information to protect our health, safety, and environment.

We depend on our government to protect public health based on the best available scientific information. The new particulate matter standards should be substantially revised to reflect this.

This action alert is part of the UCS Scientific Integrity Program, which works to improve the way in which science informs federal policy making. For more information about the program, visit http://www.ucsusa.org/scientific_integrity.