By Gretchen Goldman, Union of Concerned Scientists
The Trump Administration is set to ignore science and risk your health on an air pollution rule that will affect millions of people in the US. EPA Administrator Wheeler is going against EPA scientists and against the recommendations of an independent 20-member panel of experts (whom the administration disbanded but UCS hosted to meet anyway). By June 29, we need the voices of scientists and members of the public to tell the EPA and the Trump Administration that our particulate matter (PM) standards must protect public health, as the Clean Air Act requires. Here’s a list of top points it would be useful to make in public comments.
Note: A public comment doesn’t have to be long! Everyone is spread thin these days so even a short comment is tremendously helpful. It is even helpful to note within the comment that you could have provided more analysis and detail if the comment period had been longer and not occurred during a pandemic with stay-at-home orders, childcare challenges, limited access to technology, and the other unique circumstances that are making it harder for all of us to devote full attention to agency rulemaking right now.
Retaining the current PM standards harms public health
EPA staff scientists and the Independent Particulate Matter Review Panel concluded that the current standards for particulate matter are inadequate to protect public health. Particulate matter is a microscopic mixture of solid particles and liquid droplets. Fine particulate matter, or PM2.5, is especially harmful to our health because it gets deeper into the lungs and harms our respiratory and cardiovascular systems. Increasing evidence shows that people are experiencing sickness and deathat fine particulate matter levels at or below the current standards. Evidence shows that some groups, such as the elderly and those with respiratory illnesses, are at greater risk of health harms from particulate matter. And research in several areas has shown that communities of color and low-income communities are exposed to greater levels of harmful particulate pollution than whiter, affluent areas (See Houston and Delaware examples). We need to remind Administrator Wheeler that maintaining the current standards ignores this science and will contribute to sickness and death for thousands of people in the US every year.
The process was rigged
Time and again, the Trump Administration unraveled the process that has ensured we have science-based and health-protective air pollution standards for decades. The administration disbanded the Particulate Matter Review Panel, removed independent scientists from the Clean Air Scientific Advisory Committee, eliminated drafts of scientific documents, cut out public comment opportunities, and jammed the process through in half the time it normally takes to assess the science and policy issues of a national air quality standard. As a consequence, the administration is trying to get the result that they wanted: standards that fail to protect the public. We need to make clear that this was not a legitimate process and the EPA needs to listen to experts on particulate matter and health.
Listen to the Independent Particulate Matter Review Panel
Given the Administrator deprived the nation of a science-based process that would lead to health-protective standards, the administration should listen to the Independent Particulate Matter Review Panel. The 20-member group met and developed recommendations despite EPA leadership that didn’t want to hear from them. This is the last chance for the EPA to do the right thing in this process. Join me in asking the administration to set standards in line with the recommendations of the Independent Panel:
- A primary annual PM2.5 standard between 8 µg/m3 and 10 µg/m3 (compared to the current standard of 12 µg/m3)
- A primary 24-hour PM2.5 standard between 25 µg/m3 and 30 µg/m3 (compared to the current standard of 35 µg/m3)
- A primary PM10 that is tightened in line with PM2.5 standards and addressing several research and monitoring areas needs.
- Secondary standards tightened to address visibility concerns and other welfare effects.
This issue is urgent
Particulate matter is associated with tens of thousands of deaths in the US every single year. The same conditions that make people more vulnerable to health harms from particulate matter also make COVID riskier for people. Further, emerging evidence suggests a link between air pollution exposure and the likelihood of death from COVID-19. But we can take steps now to help protect people from the air pollution that worsens the impact of other illnesses. We need Administrator Wheeler to set particulate matter standards that follow the science and protect public health. Importantly, it is not simply a policy delay if Administrator Wheeler keeps the current standard.Failing to take action now locks the US into weaker air pollution protections for years to come. Because National Ambient Air Quality Standards set deadlines and obligations for cities, states, and companies years in advance, kicking the can down the road has public health consequences far into the future.
Now is the time to listen to independent scientists and protect the public. Join me in submitting your own public comment, as a scientist or concerned member of the public, by June 29. The nation’s health depends on it.