June 24, 2016
Docket ID No. EPA-HQ-OAR-2015-0486
Clean Air Watch, a national not-for-profit clean air watchdog organization, sincerely appreciates the opportunity to comment on the proposed Revision to the Near-road Nitrogen Dioxide Minimum Monitoring Requirements, which was published in the Federal Register on May 16, 2016 (81 Fed. Reg. 30224).
Clean Air Watch respectfully opposes EPA’s proposal to remove the requirement for near-road NO2 monitoring stations in Core Based Statistical Areas (CBSAs) having populations between 500,000 and 1,000,000 persons.
EPA argues that since monitored levels at larger cities have not exceeded its 2010 NO2 ambient air standard, that there is no problem and thus no need to look for it.
This is a specious argument for the following reasons:
EPA set an extraordinarily weak annual standard in 2010. It was at the very weakest level acceptable to EPA’s science advisers.
EPA science advisors on NO2
By contrast, groups including Clean Air Watch, the Natural Resources Defense Council, Environmental Defense Fund and the American Lung Association argued in favor of a tougher short-term standard of 50 parts per billion, which the EPA previously had discussed.
See Health and environmental experts on NO2
and Clean Air Watch on NO2
EPA’s own data shows that many areas have violated a theoretical standard of 50 despite the very limited monitoring to date. See at EPA-HQ-OAR-2015-0486-0002
Even though EPA’s monitoring scheme has been very limited to date, EPA’s own analysis shows that a theoretical standard of 50 has been violated at many sites: not just bigger metropolitan areas such as Los Angeles, Denver and New York, but also smaller cities including Cincinnati, Indianapolis, Milwaukee, Providence, Hartford, Nashville, Buffalo, and Birmingham. Numerous other areas had short-term concentrations approaching a level of 50.
More recent science shows that NO2 is more dangerous at lower levels than acknowledged in 2010. As EPA’s Integrated Science Assessment (ISA) for NO2 recently noted:
The major findings from this ISA about NO2 exposure and health effects and related uncertainties are summarized below.
• Evidence for asthma attacks supports a causal relationship between short-term NO2 exposure and respiratory effects. Evidence for development of asthma supports a likely to be causal relationship between long-term NO2 exposure and respiratory effects. These are stronger conclusions than those determined in the 2008 ISA for Oxides of Nitrogen.
• There is more uncertainty as to whether short-term or long-term NO2 exposure is related to cardiovascular effects, diabetes, reproductive and developmental effects, total mortality, and cancer.
• People with asthma, children, and older adults are at increased risk for NO2- related health effects.
• People living or spending time near or on roads, low socioeconomic status populations, and nonwhite populations may have increased NO2 exposure.
• The first year of data from the U.S. near-road monitoring network indicate that near-road sites tend to have higher NO2 concentrations on average but do not always have the highest 1-hour NO2 concentration within an urban area.
• Epidemiologic studies link asthma attacks and asthma development to NO2 measures that appeared to well represent exposure, including personal measures and concentrations where participants live or spend a lot of time.
• No specific NO2 averaging time, duration, or age of exposure is more strongly associated with asthma attacks or asthma development. It is not clear whether there is an exposure concentration below which effects do not occur.
The ISA can be found at EPA science assessment of NO2
We believe the science now could well argue in favor of a new standard even tougher than 50 — a standard that could be violated in smaller communities — if EPA’s initial plan to monitor for that pollution remains in place.
EPA Would Be Breaking a Promise Made in 2010
When EPA made its 2010 decision, Clean Air Watch was critical, in part because EPA then had scaled back the number of proposed new monitors following a White House meeting. See at http://www.nytimes.com/gwire/2010/01/28/28greenwire-final-no2-rule-cuts-back-on-roadside-monitors-45648.html
In response, the then-EPA Assistant Administrator for Air and Radiation, Gina McCarthy, called Clean Air Watch to complain — arguing that the rule was better than we gave EPA credit, precisely because there would be so many new roadside monitors going into place.
So, if EPA scraps the bulk of its much-vaunted monitoring plan now, it would be breaking a promise made by then-Assistant Administrator McCarthy.