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Recommendations

Particulate Air Pollution: Recommendations

January 9, 1997

More Protective Health Standards

The Clinton Administration's proposed PM2.5 standard for particulates represents a significant improvement in the status quo. But in order to fully protect the public health, and particularly the health of the most vulnerable individuals in the population, it must be strengthened substantially. By the EPA's own calculations, the proposed rule would reduce premature mortality from airborne particulates by 50 percent, while tens of thousands of premature deaths will continue even after the proposed health standards are met (EPA 1996d).

To better protect public health, the Environmental Working Group supports the annual average PM2.5 standard of 10µg/m3 as recommended by the American Lung Association and the Natural Resources Defense Council. This goal will provide dramatic health benefits when achieved, and puts the agency more squarely in compliance with the basic requirements and intent of the law. To guard against the adverse health effects of peak particulate exposures, we recommend a 24-hour PM2.5 standard of 20µg/m3.

Better Monitoring

The current network of state, local, and national PM monitors does not provide a scientifically representative picture of particulate levels in the air in most major U.S. cities. In spite of this major flaw in the current system, there is no requirement in the proposed rule that additional monitoring be statistically reliable, or that additional monitoring increase the ability of the EPA to target pollution reduction efforts toward highly polluted areas.

To the contrary, the agency's proposed spatial averaging scheme could easily skew monitoring in a manner that creates sacrifice zones, where unsafe air is not cleaned up, but instead is averaged together with cleaner air from somewhere else to create the statistical illusion of clean air within an arbitrary spatial averaging zone. We strongly oppose the used of statistical techniques to hide pollution and avoid cleaning up unsafe air breathed by millions of Americans. Instead, EWG recommends tough health standards that are backed up by a scientifically valid system of airborne particulate monitoring. In most major U.S. cities many more monitoring sites are needed to achieve this goal.

To ensure that representative monitoring occurs, all major particulate polluters, as currently defined by EPA, should be required to contribute to a fund, administered by local air quality officials, that is dedicated to statistically valid particulate monitoring in all metropolitan statistical areas in the United States. Spatial averaging techniques must not be used in any metropolitan region that does not have a representative particulate monitoring network in place.

In addition, we oppose any plan that achieves compliance with the new health standard by:

  • moving existing monitors to cleaner locations,
  • adding monitors only at cleaner locations, and
  • dispersing the pollution source (for example, a bus transfer station) and thus increasing pollution in cleaner areas.

Cleaning Up Hot Spots

The current monitoring system, while not fully representative of local and regional pollution levels, does identify specific locations, or hot spots, where airborne particulates are at unsafe levels. There is no reason to delay pollution reduction measures at these sites yet EPA's proposed changes to monitoring criteria could easily have that effect. Until such time as a representative monitoring system is in place, EWG recommends that the EPA maintain the current rules for monitoring and enforcement where exceeding the standard in one location triggers a violation.

Right to Know

The public has a fundamental right to know about pollution in the air they breathe. EWG's experience in gathering the particulate emissions and monitoring data used in this report shows that the public, and to a significant degree, federal regulators, have no practical way to find out about levels of deadly particulate pollution released in their communities.

We recommend, therefore, that the EPA maintain an up-to-date national database of particulate emissions and ambient concentrations, and that these data be available to the public in a manner consistent with data already widely available in the Toxic Release Inventory.

We further recommend that citizens in polluted communities be given the right to petition for and receive in their communities the monitoring equipment needed to detect particulate and other air pollution, and a timely public notification of monitoring results.