Human Mortality, Pollution Sources, and the Case for Tougher Clean Air Standards
Particulate Air Pollution
Human Mortality, Pollution Sources, and the Case for Tougher Clean Air Standards
On Nov. 27, 1996, the Clinton Administration proposed new regulations to clean up an especially deadly form of air pollution--tiny particles that penetrate deep into human lungs, claiming the lives of more than 64,000 Americans every year (EPA 1993, NRDC 1996). The rule also proposes new standards for ground-level ozone, an issue which is not addressed in this study.
The Clinton Administration proposal represents an important step in protecting public health from particulate air pollution. According to EPA (EPA 1996d), "If finalized as proposed, the new standard would:
- Cut premature deaths linked with particulate air pollution by 50%, or approximately 20,000 deaths; with acid rain controls currently underway, an additional 20,000 deaths will be avoided;
- Reduce aggravated asthma episodes by more than a quarter million cases each year;
- Reduce incidence of acute childhood respiratory problems by more than a quarter million occurrences each year, including aggravated coughing and painful breathing;
- Reduce chronic bronchitis by an estimated 60,000 cases each year;
- Reduce hospital admissions due to respiratory problems by 9,000 each year, as well as reduce emergency room visits and overall childhood illnesses in general;
- Cut haze and visibility problems by as much as 77% in some areas, such as national parks."
Before the rule was even announced virtually every major oil company, power utility and steel manufacturer in the nation had banded together as the "Air Quality Standards Coalition," with the avowed goal of killing the new clean air rule.
The administration proposal is supported "by an overwhelming majority of independent scientists who reviewed the standard for EPA, based on 86 new health studies that indicate the need for a stronger standard," according to the agency. The polluter coalition has dismissed this EPA review and gone on the attack.
Congressional opponents of the rule may seek to block it, using a new law designed to protect small business, or through a legislative rider. Air quality will also be a major issue in this year's reauthorization of the multi-billion dollar transportation law (the Intermodal Surface Transportation Efficiency Act, ISTEA).
The Need for Public Comment
Release of the proposed rule marked the beginning of a public comment period where "EPA will seek broad public comment on its recommended approach and on the need for any changes to the particulate matter [and ozone] proposal." (EPA 1996d).
The premise of this study is that the public has a right to know, and an obligation to comment on, the public health strengths and shortcomings of the particulate pollution proposal. Questions about how much particulate pollution will be reduced, how much illness will be prevented, and how many lives will be saved, ultimately are moral and political questions that demand broad public awareness and input.
This report supports the Clinton administration's goal of reducing health risks from particulate pollution. Our analysis, however, makes clear that several aspects of the proposal, notably its monitoring provisions, should be strengthened, and we support lower limits on particulate pollution in order to save even more lives.
Now it's time for the American people to make their views known to Washington. Will the polluters win? Or will Americans get cleaner air, live longer lives, and cut the nation's annual medical bill by between $50 billion and $100 billion per year?
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.
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.
Comments on EPA's Proposed Air Quality Standards (1996)
On November 27, 1996, the Environmental Protection Agency proposed new regulations for fine particulate matter (PM2.5) and ground-level ozone. We appreciate the opportunity to provide you with our comments on these proposals. While the majority of these comments focus on the standard for fine particulate matter, our comments on monitoring requirements address the ozone standards as well.
We believe that these proposals represent a critical step forward in protecting public health from air pollution. According to the Agency, the proposed particulate standards would avoid approximately 20,000 premature deaths, and dramatically reduce cases of asthma, bronchitis, and other respiratory problems. Our analysis confirms the Agency's contention that reductions in particulate matter will result in increased longevity; however, our estimates, like those of NRDC, suggest that a slightly stronger particulate standard would prevent a greater number of premature deaths, closer to the 70,000 that EPA originally suggested occur due to particulates.
The proposal noted that it was supported "by an overwhelming majority of independent scientists who reviewed the standard for EPA, based on 86 new health studies that indicate the need for a stronger standard." Our review of docket materials confirms that this is indeed the case.
Consistent with this overwhelming body of evidence, the Environmental Working Group fully supports the establishment of new, stricter standards for ozone and fine particulates. However, in order to fully protect public health consistent with the intent of the Clean Air Act, the science argues for even stronger standards for both particulates and ozone. Specifically, the Agency should make the following improvements to the proposal:
- Abolish proposals for "spatial averaging" that will allow polluted areas to come into compliance by adding more monitors while doing nothing to clean the air.
- Establish more stringent standards that provide greater public health benefits.
- Ensure that there is no "backsliding" from current air quality conditions. Areas which currently have low PM 2.5 and ozone levels should be required to maintain those levels, and should not be allowed to "pollute up to the standard". And areas which are currently not in compliance should be brought into compliance simply because of changes in monitoring requirements.
- Drop provisions that weaken current proposed standards by basing compliance with the annual standard on the 98th percentile. Instead, compliance should be based on a single exceedance.
- Fulfill the public's right to know when their air does not meet basic safety standards.
We continue to support EPA's efforts to strengthen standards for ozone and particulate matter. These proposals respond to extraordinarily strong science showing that current standards are inadequate. However, we believe that our proposed changes would improve the regulations and improve your effort to more fully protect public health.
The proposal recommends a new monitoring initiative, spatial averaging. This new scheme is likely to create "sacrifice zones" where polluted air in yet undefined spatial averaging zones could be "cleaned up" simply by averaging pollution levels from new monitors placed in adjacent communities with cleaner air. If not modified, spatial averaging will very likely undermine the otherwise significant health protections that the new rule is designed to achieve. Worse, the proposal would subvert current policy whereby a violation at a single monitoring location is enough to trigger air quality improvements for the entire region. The agency has not provided an adequate scientific or public health rationale for reversing the present conservative, risk averse, enforcement procedures.
Two analyses illustrate how spatial averaging, as proposed by the agency, could serve primarily to hide existing pollution hot spots, instead of cleaning them up. EWG analyzed data from AIRS including the state and local air monitoring stations (SLAMS) and the national air monitoring stations (NAMS) for the 490 counties across the country with valid PM monitoring data for a three year period between 1993 and 1995. We then examined the impact of spatial averaging at the county level in two different ways. County boundaries were chosen because EPA's proposal suggests that county boundaries might delineate spatial averaging zones under the new rule. Regardless of the specifics of the spatial averaging zone boundary, the results of the following analyses hold true. It is the content of the proposal, not the nature of the boundary that creates the potential for sacrifice zones.
The first analysis searched for counties with more than one PM monitor, where the three-year average for at least one monitoring site exceeded the proposed annual PM2.5 standard, but the average from all the monitors was below 15 µg/m3. Under current rules, if one monitor exceeds the standard, the entire region must clean up its air. Under the EPA spatial averaging proposal, if one monitor exceeds the standard, these results can be averaged with lower pollution levels in a clean part of the county to bring the whole county or spatial averaging zone into "attainment".
We identified 35 counties that contain these potential "sacrifice zones" (Appendix 1). If the county boundary defined the spatial averaging zone, residents in these polluted areas would continue breathing unhealthy air because some other part of the county has cleaner air, and no remedy would be initiated.
EPA has suggested that the proposed 24 hour standard would serve as a backstop, and protect these counties against potential "sacrifice zones." Yet none of these counties would trigger an enforcement action under the proposed 24 hour PM2.5 standard of 50µg/m3, calculated at the 98th percentile.
EWG does not oppose spatial averaging as a concept. But both monitoring and spatial averaging must done in a way that is scientifically and statistically valid. The goal of any averaging technique must be to demarcate areas with unsafe levels of pollution and clean them up, not merely to make them appear clean through statistical artifact.
The second analysis examines the potential effect of additional monitors within counties as spatial averaging zones. According to the EPA proposal, new monitors within spatial averaging zones are encouraged. These monitors must be placed near populated areas, but they are not required to be placed in "hot spots" where the pollution is the worst, nor are they required to be placed systematically in such a way that provides a representative picture of pollution within the spatial averaging zone. Without major revisions, this proposal will create a strong incentive to place new monitors in cleaner locations to lower "average" pollution levels in the spatial zone -- again creating a lower number but doing nothing to clean the air. The purpose of more monitoring must be to better define polluted areas, not to create the statistical illusion of clean air.
To demonstrate how additional monitoring might be used to avoid pollution reduction via averaging, we analyzed the AIRS data for counties with just one monitoring site, where particulate levels at that site exceed the proposed annual PM2.5 standard. Our analysis revealed 40 counties with a total population of 5.5 million, each with just one monitoring site, where particulate levels currently exceed the proposed annual PM2.5 standard by less than 2.5µg/m3. In any of these 40 counties, compliance with the annual standard could be achieved easily by adding just one monitor at a less polluted location, rather than actually reducing pollution levels at the polluted site (Appendix 2). While this would technically comply with the standard in writing, residents at the more polluted monitoring site would be given no relief from air pollution that is above the health standard allowed by EPA.
An even more worrisome element of the proposal would allow independent parties to construct "special purpose monitors", with the promise that data showing poor air quality will not be used for regulatory purposes. Under the EPA proposal, if the data from these special monitors bring an area into a violation of the PM2.5 health standard, there is a three-year moratorium on the use of such data. If the data bring an area into compliance, however, there is no similar explicit moratorium on use of the information. While the draft rule does not specifically state that these data will be used, the absence of a prohibition on its use creates the strong supposition that only data that would moderate regulatory burdens from these special monitors will be used in the regulatory process. As drafted, this loophole provides major polluters with a risk-free incentive to set up monitors in clean areas of spatial monitoring zones, as it simultaneously eviscerates any independent efforts to monitor air where it is the most polluted. Any potential for such a double standard must be eliminated from the final rule.
Even if the same rule applies to both high and low measurements, allowing random siting of monitors by either private or government entities does not serve the purpose of protecting public health. Unless monitors are either sited uniformly and systematically, or sited at "worst-case" locations, the monitoring program will be little more than random guesswork, and clearly would not represent "good science" by any account. This problem needs to be addressed in the rule.
We strongly oppose the used of statistical techniques to hide pollution and to 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 air monitoring. In most major U.S. cities many more monitoring sites are needed to achieve this goal. If it can not be met, then the worst cases need to be addressed, not statistically averaged.
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 allows areas to achieves compliance with the new health standard by:
- moving existing monitors to cleaner locations,
- adding monitors only at cleaner locations, and
- moving the pollution source (for example, a bus transfer station) and thus increasing pollution in cleaner areas.
Until such time as a representative monitoring system is in place, EWG strongly recommends that the EPA maintain the current rules for monitoring and enforcement where exceeding the standard in one location triggers a violation.
The proposed PM2.5 standard for particulate matter 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 particulate 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. Similarly, the proposed ozone standard must also be strengthened.
To better protect public health, the Environmental Working Group supports an annual average PM2.5 standard of 10 µg/m3. To guard against the adverse health effects of peak particulate exposures, we recommend a 24-hour PM2.5 standard of 18µg/m3. In addition, we support a stricter eight-hour ozone standard of 0.07 ppm. These goals will provide dramatic health benefits when achieved, and puts the agency more squarely in compliance with the basic requirements and intent of the law.
New regulations must ensure that there is no "backsliding". Thus, in addition to setting new stricter standards, EPA should retain or strengthen both the current one hour ozone standard, and the existing PM10 standard. In addition, areas which currently have low PM 2.5 and ozone levels should be required to maintain those levels, and should not be allowed to "pollute up to the standard". Furthermore, communities which do not meet current standards should not be brought into compliance by loopholes in monitoring requirements (use of spatial averaging, special monitors, or 98th percentile compliance monitoring) -- these communities should at least be required to clean the air to current standards.
Under existing regulations, compliance with the 24-hour particulate standard is based upon the 99th percentile, meaning that communities are allowed to exceed the standard for one full week every two years. The new standards would make this regime even less strict, basing compliance upon the 98th percentile meaning that communities could exceed the standard for two full weeks every year. There is no public health basis for using either the 98th or 99th percentile. Numerous studies clearly indicate that exposure for short periods of time cause dramatic health impacts. There is no justification for allowing communities to breath such polluted air for even one full week every year. The proposed regulations must be based upon a single exceedance of the standard. Our analysis of the AIRS database indicates that an additional 27.6 million people would be protected if standards were based upon a single exceedance rather than the 98th percentile.
The public has a fundamental right to know about pollution in the air they breathe. EWG's experience in gathering emissions and monitoring data from the AIRS database shows that the public often has no practical way to find out about pollutant releases in their communities.
We recommend, therefore, that the EPA renew it's efforts to maintain the AIRS database, or a similar up-to-date national database of emissions and ambient air quality, and that these data be available to the public in a manner similar to that used for 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. Where monitors are operated, the public should be given timely notification of monitoring results.
- Jefferson County, Alabama
- Talladega County, Alabama
- Cochise County, Arizona
- Pima County, Arizona
- San Luis Obispo County, California
- San Miguel County, Colorado
- Fairfield County, Connecticut
- Dade County, Florida
- Hillsborough County, Florida
- Nez Perce County, Idaho
- Rock Island County, Illinois
- Allen County, Indiana
- Saint Joseph County, Indiana
- Linn County, Iowa
- Penobscot County, Maine
- Allegany County, Maryland
- Baltimore County, Maryland
- Hampden County, Massachusetts
- Kent County, Michigan
- Hennepin County, Minnesota
- Coos County, New Hampshire
- Middlesex County, New Jersey
- Bernalillo County, New Mexico
- Bronx County, New York
- Monroe County, New York
- Onondaga County, New York
- Richmond County, New York
- Buncombe County, North Carolina
- Forsyth County, North Carolina
- Mecklenburg County, North Carolina
- Trumbull County, Ohio
- Northampton County, Pennsylvania
- Georgetown County, South Carolina
- Harris County, Texas
- Kanawha County, West Virginia
- Jefferson County, Alabama
- Etowah County, Alabama
- Washington County, Georgia
- Canyon County, Idaho
- Macon County, Illinois
- Johnson County, Kansas
- Sherman County, Kansas
- Floyd County, Kentucky
- Madison County, Kentucky
- Marshall County, Kentucky
- Whitley County, Kentucky
- Garrett County, Maryland
- Washington County, Maryland
- Calhoun County, Michigan
- Lancaster County, Nebraska
- Otoe County, Nebraska
- Mercer County, New Jersey
- Warren County, New Jersey
- Mitchell County, North Carolina
- Noble County, Ohio
- Ottawa County, Ohio
- Richland County, Ohio
- Carter County, Oklahoma
- Comanche County, Oklahoma
- Kay County, Oklahoma
- Mayes County, Oklahoma
- Blair County, Pennsylvania
- Bucks County, Pennsylvania
- Cambria County, Pennsylvania
- Delaware County, Pennsylvania
- Lackawanna County, Pennsylvania
- Lycoming County, Pennsylvania
- Montgomery County, Pennsylvania
- Grand County, Utah
- Bristol City, Virginia
- Covington City, Virginia
- Fayette County, West Virginia
- Ohio County, West Virginia
- Putnam County, West Virginia
- Wayne County, West Virginia
- Wood County, West Virginia