EPA standards are stricter, but still don’t reflect the dangers of pollution
The health consequences of PM2.5 are well documented, and the research clearly shows that there is no safe level of air pollution. The current federal standards are way too high, but the EPA is currently reconsidering lowering them.
If the standard, especially the 24 hour standard, was lowered, it could force Salt Lake County, and Utah as a whole, to do something about the car pollution that is pushing the current limit, reports a Salt Lake Tribune article.
We suggest the EPA make the annual PM2.5 standard 8 ug, and the 24 hr standard 25 ug.
*While the World Health Organization’s suggested standards of 5 ug/m3 is ideal, it is politically and practically unlikely, and very close to what would exist with virtually no human activity.
If we could get 8 ug annually and 25 ug as a 24 hour standard, that would be a real accomplishment.
Public Comments:
Docket ID No. EPA-HQ-OAR-2015-0072, by any of the following means:
Federal eRulemaking Portal:
(preferred method). Follow the online instructions for submitting comments.
Email: a-and-r-Docket@epa.gov
Include the Docket ID No. EPA-HQ-OAR-2015-0072 in the subject line of the message.
Mail:
U.S. Environmental Protection Agency, EPA Docket Center, Air and Radiation Docket, Mail Code 28221T, 1200 Pennsylvania Avenue NW, Washington, DC 20460.
Read the full Tribune article on how the standard will affect Utah here.
Some helpful talking points for public comments:
1. The EPA’s proposal to lower the annual standard from 12 ug/m3 to 9-10 is not good enough. It should be set at 8 ug/m3. EPA’s proposal to leave the 24 hr standard (the one the Wasatch Front violates) unchanged is a dereliction of their duty, and Utah would be left without any benefit at all.
2. Every major medical organization in the country is calling for stricter standards.
3. The EPA’s methodology for reviewing the medical literature and drawing conclusions from it is so extreme, it can only be explained by a default industry bias.
4. The EPA approaches their job as engineers would, demanding an unrealistic level of proof of harm before taking action. Medical care is not engineering. The EPA should approach the creation of national standards just as physicians do when analyzing diagnostic and treatment options. Perfect knowledge is seldom available, so decisions on diagnosis and treatments have to be made with the best available knowledge, weighing the risks and benefits. The best available knowledge and a risks/benefits analysis both compel stricter standards than the EPA is offering.
5. The EPA is legally prohibited from considering the cost of implementing standards.
i.e. their decision can only be made on the science of what it will take to protect public health, not what it costs industry to comply with those standards.
6. The science is clear: not only is there no safe level of exposure, but the relationship between exposure concentration and disease is even stronger at lower doses. That alone means the strictest standards should be achieved.
7. Multiple trends indicate air pollution will be an even greater public health burden in the future.
8. Finally, if you or your family members have experienced any of the adverse health outcomes we outline in detail in our report, be sure to mention it. Stress the fact that the medical research indicates that your family’s health issues are statistically more likely because of the level of air pollution the EPA allows.