A Demand for Strong Air Quality Standards

With so much national attention focused on the pandemic, the White House took advantage of the opportunity to quietly launch another attack on public health by EPA. With the current EPA administrator being a former coal industry lobbyist, unfortunately, we are hardly surprised.

The Clean Air Act requires the EPA to re-evaluate air quality standards every five years, and revise those standards to reflect updated science. Yesterday, ignoring all that science, the EPA refused to make our national air quality standards any stricter.

The annual standard for PM2.5 remains at 12 ug/m3, and the 24 hr standard remains at 35 ug/m3, a level that was set way back in 2006. The latter is particularly egregious because that means our winter inversions will be brushed off as no real threat to public health. This is all the more galling given the recent research that shows air pollution makes people more likely to die from the COVID-19 infection.

UPHE joins many other organizations in condemning the EPA’s clear priority of maximizing profits for polluting industries. “If there ever was a moment for all Americans, regardless of political persuasion, to demand the Trump EPA stop gutting the nation’s air quality standards and finally place a premium on public health protection, it’s now.”

 We thank all of you who posted comments with the EPA about their proposal to eviscerate the science about air pollution. Below are UPHE’s comments:

Representing 450 physicians and 3,000 members of the lay public, Utah Physicians for a Healthy Environment wish to comment on the proposed change in the way EPA evaluates scientific research. For 13 years we have carefully searched the medical literature for research on air pollution. The conclusions we have drawn and research we have evaluated to reach those conclusions are in the attached document, organized according to organ systems and disease categories.

The message from thousands of studies done throughout the world is that air pollution contributes significantly to four of the five leading causes of death, and precipitates almost as many diseases as smoking cigarettes. In fact, given the number of people that smoke, and the fact that virtually everyone ends up breathing air pollution, the later is, overall, a larger public health hazard.

Furthermore, this research clearly establishes that there is no safe level of air pollution. Every bit of it, even at levels far below the current standards for PM2.5 and ozone, is hazardous, and increases community mortality rates. More specifically, particulate air pollution increases community mortality about 1% for every 1 ug/m3 of chronic PM2.5 exposure. The mortality precipitated by ozone is somewhat less, but important nonetheless.

A recent study of 4.5 million US veterans found that 99% of the deaths related to air pollution occur in populations where the air pollution levels meet the EPA’s current standards.

“It is well established that both ozone and particulate pollution cause lung disease, heart disease, neurologic and psychiatric disorders, poor pregnancy outcomes, impaired fetal development, still births, and birth defects, virtually every type of cancer, endocrine disorders like type II diabetes, reduced kidney function, arthritis, immunosuppression, and increased vulnerability to a wide variety of infections.

To disqualify the type of research targeted by this proposal would be scientifically indefensible, inappropriate, and only serves to undermine the clean air standards which are already too weak and should be strengthened. This proposal seems to be a cynical capitulation to the demands of industry and manufacturers, rather than a gesture intended to increase transparency, fine tune the science, or more accurately address your mandate, which is to protect public health.

We urge to unequivocally reject this proposal.

Dr. Brian Moench
President, Utah Physicians for a Healthy Environment