Last month I wrote about a series of public teleconferences on additional charge questions from the Environmental Protection Agency, as it continues to reconsider the 2008 ozone standard. The evidence from more than 1,700 peer-reviewed scientific reports is clear (and continues to be reinforced with new science) in demonstrating that our current ozone standard is not protective enough of human health, and we at EDF continue to advocate for a strengthening of the standard. Just this week, during the second public teleconference in this series, I reinforced our position with formal comments.
Here are highlights from my testimony, with a few additions:
The Science is Sound
We appreciate the continued dedication of the CASAC (Clean Air Scientific Advisory Committee) during the course of the 2008 ozone review through the present. To this day, as it continues to answer additional charge questions, the committee has not waivered in its opinion regarding the standard. CASAC remains strong, and has issued multiple statements indicating that the current ozone standard is unacceptable with regard to protecting human health. New research, including recent reports demonstrating significant increase in pulmonary inflammation in healthy individuals exposed to 60 ppb ozone, and clear evidence linking respiratory mortality with ozone exposure in a single pollutant model, serve to confirm this opinion and highlights the immediate need for a more health-protective standard. In other words, the science is sound.
Need for an Adequate Margin of Safety
In addressing reconsideration charge question #1 from the Administrator regarding the requirement to protect human health with an adequate margin of safety, EPA is said to consider such factors as the nature and severity of the health effects involved, the size of the at-risk population(s), and the kind and degree of the uncertainties that must be addressed.
I would like to highlight some of these factors:
- First, the nature and severity of the health effects involved: It is hard to imagine health effects any more severe than death or those that affect a person’s ability to breathe, especially that of a small child who has to be rushed to the emergency room.
- Second, the size of the at-risk population: Nearly 34.1 million Americans have been diagnosed with asthma during their lifetimes and estimates predict that number will grow by more than 100 million by 2025. Nearly 12 million people suffer from chronic obstructive pulmonary disease (COPD), a disease that causes serious, long-term disability and kills more than 120,000 Americans each year. Additionally, there are nearly 75 million children in this country and almost 37 million Americans aged 65 and over. As these Baby Boomers mature, this older population, more sensitive to the effects of air pollution, will represent 20% of the total U.S. population. While this is not an exhaustive list of those at increased risk from the harms of ozone, it should be clear that we should no longer refer to this collective group as a subpopulation.
- Finally, the degree of uncertainties that must be addressed: Evidence continues to demonstrate effects in healthy people at exposures as low or lower than 60 ppb. Thus, if any inclusion of uncertainty is part of the decision making process, then EPA is obliged to adopt a standard even more protective than the one recommended by CASAC.
Environmental Protections are Not a Job Killer
While we hear quite often from industry that environmental regulations are a job killer, the historical evidence doesn’t support it. Just this week, The Christian Science Monitor published a piece, quoting Dale Jorgenson, a Harvard University economist: Spokespeople for coal and other industries reliant on fossil fuels “are simply presenting a point of view intended to affect legislation,” he says. “They think Congress cares about jobs most right now, so they are coming up with stories about huge job losses they think will resonate. I wouldn’t say there is any academically respectable support for that view.” And Texas itself has made the case that GDP has gone up even as ozone controls strategies have been adopted, resulting in cleaner air across the state. Why is it so hard to understand that innovation (like the type used to develop cleaner technologies) has been and continues to be the key to this country’s success?
Serious Health Implications with Further Delay
Environmental protection is a health issue, not a political one. Public health officials have endorsed CASAC recommendations, with many even advocating for the lower end of the proposed range, a 60 ppb standard:
- The American Academy of Pediatrics
- American Medical Association
- American College of Chest Physicians
- American Public Health Association
- American Thoracic Society
- More than 100 leading independent air quality scientists and physicians
EPA should not be swayed by industry pressures. The science is clear. We urge EPA not to delay adoption of a more health protective standard as it needlessly threatens the health of millions of Americans who are at increased risk for life-threatening diseases.