Today, EPA proposed updated National Ambient Air Quality Standards (NAAQS) for particulate matter of 2.5 micrometers in diameter or smaller (“PM2.5” or fine particle pollution). Particulate matter kills thousands of people every year, and today’s announcement is an important step forward that will have enormous benefits for the American public.
EPA followed the science and the law with today’s proposal to tighten clean air standards for the tiniest and most dangerous particles. EPA is proposing to lower standards for particulate matter to between 12 and 13 micrograms per cubic meter. The agency is also taking “public comment on alternative annual standard levels down to 11 μg/m3,” a level that is even more protective of health.
The agency has not yet released its Regulatory Impact Analysis that estimates lives saved, but a report prepared by health and environmental groups used EPA data to estimate these figures. According to this report, an annual standard set at 12 to 13 micrograms per cubic meter could avoid up to an estimated (fig. 1) 8,190 to 15,000 premature deaths annually. A standard set at 11 micrograms per cubic meter could save up to an estimated 27,300 lives per year.
Today’s announcement follows EPA’s staff scientist recommendations that “consideration  be given to revising the current annual PM2.5 standard level of 15 μg/m3 (micrograms per cubic meter) to a level within the range of 13 to 11 μg/m3." Even though EPA is proposing a standard of 12 or 13, importantly the agency is also soliciting comments on the more protective level of 11 micrograms per cubic meter. NRDC, the American Lung Association, and many other health and environmental groups support setting the annual standard for PM2.5 at 11 micrograms per cubic meter. Again, this standard is estimated to save up to 27,300 lives per year.
PM2.5, or “fine particles,” are approximately 1/30th the average width of a human hair, and are so small that they can penetrate deep into the lungs and blood stream and cause a variety of serious health impacts, including:
- increased respiratory symptoms, such as irritation of the airways, coughing, or difficulty breathing;
- decreased lung function;
- aggravated asthma;
- development of chronic bronchitis;
- irregular heartbeat;
- nonfatal heart attacks; and
- premature death in people with heart or lung disease.
In fact, EPA has announced that for particle pollution of this size, the “scientific literature provides no evidence of a threshold below which health effects associated with exposure to fine particles – including premature death – would not occur.” (my emphasis added).
One other important feature of today’s proposal is a new requirement for PM2.5 “monitoring along heavily traveled roads in large urban areas. . . . EPA is proposing to require near-roadway PM2.5 monitoring at one location in each urban area . . . with a population of 1 million or more.” As the agency rightly notes, “[p]ollution can be higher along these roads as a result of emissions from cars, and from heavy duty diesel trucks and buses." While “EPA is not proposing to increase the size of the national PM2.5 monitoring network, which consists of about 900 monitors,” the agency nonetheless “anticipates that states would be able to relocate existing monitors (about 52 total) to meet the near-roadway requirement.”
This is a significant improvement that begins to correct a longstanding dirty little secret of Clean Air Act implementation: the many millions of Americans who live near highways are not being protected against dangerous air pollution because a combination of federal and state policy and practice has led to virtually no air pollution monitors being placed near highways. It’s the “don’t ask, don’t tell” scandal of clean air practice that the Obama administration began to rectify in 2010 when it updated the nitrogen dioxide air quality standards and started to require a modest network of near-highway monitors. Today’s proposal advances that progress by requiring monitoring for more harmful PM2.5 pollution.
But industry lobbyists and their friends in Congress have resorted to predictably shameless (and repetitive) tactics in an attempt to undercut these milestone health standards. Industry lobbyists for the American Petroleum Institute mounted a fierce (yet ultimately unsuccessful) last minute lobbying campaign to sway the administration. Big Oil is unbelievably questioning the “cause and effect” (6/15/12) between particulate matter and health effects ( see here why this is wrong).
API also urged the administration to keep the unprotective standard of 15 micrograms per cubic meter as an option in the proposal. Similarly, just last week, House Republicans on the Energy and Commerce committee sent a letter to EPA echoing these sentiments and asking the Administrator to consider retaining current standards for PM2.5. These politicians claimed that the “scientific evidence… continues to be characterized by critical uncertainties.”
In a rebuke to the industry lobbying and political appeals, today’s proposal does not even solicit comment on 14 or 15 micrograms per cubic meter. Standards at these levels would be unprotective and unlawful.
Today’s decision was necessary because the science demands more protective PM2.5 standards. Here's why:
The current annual standard of 15 micrograms per cubic meter was set in 1997. EPA last examined the scientific literature on PM2.5 in 2006, when the Bush EPA defied the scientific evidence and kept standards for PM2.5 at a level that was not protective of public health. At the time, the Clean Air Science Advisory Committee (CASAC) recommended that EPA set annual standards for PM2.5 at 13 to 14 micrograms per cubic meter and daily standards at 35 micrograms per cubic meter. Instead, EPA proposed an annual standard of 15 micrograms per cubic meter and a daily standard at 35.
Disregarding public outcry and strongly worded letters from CASAC noting that the annual standard did not reflect the advice of that scientific body, the Bush Administration adopted final standards maintaining the annual standard at 15 micrograms per cubic meter. Public health groups immediately challenged this decision in court.
In 2009, the federal court invalidated the annual PM2.5 standard of 15 and sent it back to EPA, because EPA failed to sufficiently explain how the Bush Administration standards protected public health with an adequate margin of safety, as the Clean Air Act requires. The court directed the agency to address this and other issues in their next review of PM2.5 standards, scheduled for 2011.
Since that time, EPA has continued to study the science on PM2.5. Both EPA’s scientists and the independent CASAC support the conclusion that “the currently available information clearly calls into question the adequacy of the current standards and that consideration should be given to revising the suite of standards to provide increased public health protection.” As noted previously, EPA’s staff scientists and the independent CASAC recommended an annual PM2.5 standard “within the range of 13 to 11 μg/m3.”
And that brings us to today. EPA has rejected the unprotective standards of 14 and 15 and proposed a range between 12 and 13 micrograms per cubic meter. This could avoid up to an estimated 8,190 to 15,000 premature deaths annually. But a standard set at 11 would even more closely follow the science and the advice of EPA staff and CASAC scientific advisors, and could save up to 27,300 lives every year.
EPA deserves thanks for following the science and the law, and standing their ground against relentless attacks by Big Oil and their friends in Congress.
Today’s proposed standards go a long way towards strengthening health protections that were woefully inadequate. All Americans can breathe easier knowing that they will be exposed to less deadly particle pollution that can cause asthma attacks, heart attacks, and even premature death.