Wednesday, September 15, 2010

While corporate opponents of clean air are on the march, EPA science advisers endorse tougher national particle soot standards

Some of the big business lobbies are planning today to assail EPA’s proposed toxic pollution standards for industrial boilers. We’ll eagerly await the details, but, with your permission, I would recall several things:

For 40 years we have heard predictions of doom and gloom from business groups every time EPA proposes tougher clean air controls. These predictions are invariably exaggerated. As we heard quite eloquently at yesterday’s 40th anniversary celebration of the Clean Air Act, we have seen steady progress towards cleaner air even as the economy grows. And we also were reminded that clean-air controls have been good for the economy by creating jobs. I also believe EPA has quite a good track record of responding to legitimate criticism, and I have no doubt the agency will make a careful evaluation of these new claims regarding the boiler rule.

Second, EPA has noted that its boiler proposal would have the side benefit of reducing dangerous particle pollution, an action that would translate into less death and disease.

We were reminded of just how important this issue is by a attached letter, just released by EPA’s independent science advisers. As you will recall, the EPA is reviewing the national clean air standards for particle pollution (from coal-burning, diesel engines, industrial boilers, etc.) with a proposal slated for early next year. EPA’s own scientists have concluded that the current standards fail to protect the breathing public.

And now EPA’s science advisers are on record with a strong recommendation on the need for tougher national clean air standards for particles – both the so-called “fine” particles as well as larger “coarse” particles. (Some of you are aware that the farm lobby is already mounting a campaign against the latter, while the former will almost certainly face opposition from the coal-burning electric power industry.) In fact, the science advisers are urging an even tougher “coarse” particle standard than recommended by EPA’s staff.

Here is a link to the letter:$File/EPA-CASAC-10-015-unsigned.pdf

I will excerpt a few parts of the science adviser letter below.

EPA’s independent science advisers have sent a strong and unequivocal signal that current particle soot standards need to be made much tougher. We hope this will give EPA the scientific backbone to do the right thing.

Excerpts from the letter by EPA’s science advisers:

Primary Standards for Fine Particles

"CASAC supports the EPA staff’s conclusion in the Second Draft Policy Assessment that “currently available information clearly calls into question the adequacy of the current standards”. For PM2.5, the current 24-hour primary standard is 35 mg/m3 and the annual standard is 15 mg/m3. EPA staff also conclude that consideration should be given to alternative annual PM2.5 standard levels in the range of 13 – 11 ug/m3, in conjunction with retaining the current 24-hour PM2.5 standard level of 35 mg/m3, and that consideration could also be given to an alternative 24-hour PM2.5 standard level of 30 ug/m3 in conjunction with an annual standard level of 11mg/m3. CASAC concludes that the levels under consideration are supported by the epidemiological and toxicological evidence, as well as by the risk and air quality information compiled in the Integrated Science Assessment (December 2009), Quantitative Health Risk Assessment for Particular Matter (June

2010) and summarized in the Second Draft Policy Assessment. Although there is increasing uncertainty at lower levels, there is no evidence of a threshold (i.e., a level below which there is no risk for adverse health effects). In addition, these combinations of annual/daily levels may not be adequately inclusive. It was not clear why, for example, a daily standard of 30 ug/m3 should only be considered in combination with an annual level of 11 ug/m3. The rationale for the 24-hour/annual combinations proposed for the Administrator’s consideration (and the exclusion of other combinations within the ranges contemplated) should be more clearly explained."

_Primary Standard for Thoracic Coarse Particles

"CASAC recommends that the primary standard for PM10 should be revised downwards. While current evidence is limited, it is sufficient to call into question the level of protection afforded by the current standard (a 24-hour standard of 150 mg/m3)."

"CASAC supports the EPA staff conclusion that it is appropriate to change the PM10 standard to a 98th percentile form because of its higher rate of identifying areas in nonattainment while reducing the rate of misclassification. We do not agree that the available scientific evidence strongly supports the proposed upper bound standard level of 85 ?g/m3. The Second Draft Policy Assessment demonstrates that a 98th percentile level of 85 ?g/m3 would be less stringent as compared to the current standard, protecting a smaller fraction of the population. In fact, on a population basis, results in the Second Draft Policy Assessment demonstrate that a 98th percentile level between 75 and 80

?g/m3 is comparable in the degree of protection afforded to the current PM10 standard. The change in form will lead to changes in levels of stringency across the country, a topic needing further exploration.

While recognizing scientific uncertainties, CASAC supports a lower level to provide enhanced protection, somewhere in the range of 75 – 65 ?g/m3.

We recognize that the Administrator will need to apply the Clean Air Act’s requirement for a “margin of safety” in a context of uncertainty with respect to the health effects of thoracic coarse particles."

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