Disbanded Air Pollution Panel Finds EPA Standards Don’t Protect Public Health
By Gretchen Goldman
The Independent Particulate Matter Review Panel has released their consensus recommendations to the EPA administrator on the National Ambient Air Quality Standards for Particulate Matter. The group of 20 independent experts, that were disbanded by Administrator Wheeler last October and reconvened last week, hosted by the Union of Concerned Scientists, has now made clear that the current particulate pollution standards don't protect public health and welfare.
The Clean Air Scientific Advisory Committee (CASAC) — the remaining seven-person committee that is providing science advice to the EPA on the particulate matter standards — meets this week to discuss their recommendations on whether the current standards are adequate. The letter from the Independent Panel will be the elephant in the room.
The Elephant in the CASAC Meeting
CASAC has already acknowledged that they don't have the expertise to conduct the review but you know who does? The Independent Panel. The Panel has more than double the experts of CASAC, and importantly, it has multiple experts in each of the necessary scientific disciplines critical to ensure a comprehensive, robust review of the science supporting the standards.
As a result, we should watch whether or not CASAC aligns with the panel in their recommendations on the standards. If CASAC doesn't decide this week to make a similar recommendation as the Independent Panel, they'll have to explain why they disagreed with a larger, more experienced, and more diverse set of experts on the topic. In any event, the administrator will have access to both CASAC and the Independent Panel's recommendations when he ultimately makes the decision of where to set particulate pollution standards. The panel's recommendations should hold the administrator's feet to the fire.
The Fine Particulate Matter Standards Don’t Protect Public Health
The standards of greatest interest are the primary PM2.5 standards. These are the standards for particulate matter less than 2.5 micrometers (fine particulate matter) that are designed to protect public health. The panel supported the preliminary conclusions of a Draft EPA Policy Assessment that the current standards aren't requisite to protect public health.
The letter cited new and consistent epidemiological findings, supported by human and animal studies and other studies with natural experiments, as providing "clear and compelling scientific evidence" for tighter standards. Since the last particulate matter review, several new large-scale epidemiological studies provide powerful evidence that particulate matter is causing adverse health outcomes (such as early death, heart attacks, and respiratory stress) at locations and during time periods with concentrations at or below the level of the current standards.
They write, "New and compelling evidence that health effects are occurring in areas that already meet or are well below the current standards." Notably, this evidence cuts across different locations with different study populations, different study designs, and different statistical approaches.
Given the weight of the evidence from new studies across scientific disciplines and consistent with the decision-making process that EPA and its science advisers have used for many years, the panel recommends a particulate matter standard between 8 µg/m3 and 10 µg/m3 for the annual PM2.5 standard (compared to the current standard of 12 µg/m3) and between 25 µg/m3 and 30 µg/m3 for the 24-hour standard (compared to the current standard of 35 µg/m3) to protect public health. These ranges are tighter than those recommended in EPA's Draft Policy Assessment.
Keeping the Current Fine Particulate Matter Standards Ignores the Science
The Independent Panel rejected a potential argument for maintaining the current primary PM2.5 standards. The Draft Policy Assessment offered up an alternative rationale that might be used if the agency were to reject the draft assessment's recommendation to strengthen the standards and maintain the current standards. This alternative rationale explains that such a move would require the administrator to be arbitrarily selective in choosing which new studies to accept and which to toss and to disregard new epidemiologic evidence showing effects at lower levels.
The panel roundly rejected this justification, noting that, "Arguments offered in the draft Policy Assessment for retaining the current standards are not scientifically justified and are specious." This is important because if the administrator fails to strengthen the standards, he'll have to explain (both in court and in the court of public opinion) why he feels such a decision is science-based, as required under the Clean Air Act. And one proposed argument he could use has just been debunked by this expert Panel.
Otherwise, the EPA’s Draft Policy Assessment Is Scientifically Sound
While the Independent Panel critiqued some details of the EPA's Draft Policy Assessment, the panel agreed that the draft science and policy assessments were cohesive and robust and the panel commended the "good faith effort" involved in the policy assessment. Specifically, the panel affirmed the use of EPA's causality framework used in the Integrated Science Assessment they reviewed last year and the Policy Assessment's new use of a hybrid modeling technique that allows for better assessment of risk from particulate matter exposure across the country especially in rural areas.
This diverges from what the seven-member CASAC has said and done around the EPA's assessment of the science and policy. In December, they concluded that the agency's draft science assessment was not a scientific document (it is) and CASAC Chair Dr. Tony Cox has been critical of the agency's causality framework that has been developed with dozens of experts over more than a decade. This view is not shared by the scientific community, and now, not shared by the Independent Panel either.
Other Particulate Pollution Standards Also May Need Revamping
The Independent Panel decided other particulate standards were also inadequate. On PM10, particulate matter less than 10 micrometers, the panel recommended revising this standard downward given that the PM2.5 component would also be tightened and noted several research and monitoring areas that need further work. On the secondary standards, i.e. the standards designed to protect welfare effects, such as visibility, the panel concluded that the standards should be tightened in order to be more protective.
The Panel Condemns the EPA’s Broken Process
The Independent Panel's deliberations, demands for further research, and unanswered questions highlight how broken the EPA process is. In a normal review cycle, the panel would have had the opportunity to talk with agency scientists directly. The EPA staff would then have considered their comments and revised the Integrated Science Assessment in response to the committee and panel's suggestions. But because the administrator disbanded the panel and abbreviated the process, there was no opportunity for such dialogue and refinement of the agency's science assessment before policy decisions were discussed. But alas, the panel had to make do with what was available to them and CASAC does too.
Fortunately for CASAC, an Independent Panel has already done their job, and they are free (and encouraged) to run with it, especially given the long list of ways that EPA Administrator Wheeler has damaged the ambient air pollution review process.
Listen and watch this week as CASAC discusses the same questions that the Independent Panel did last week. If CASAC comes to different conclusions than the larger, more experienced, and more diverse Independent Panel, we should ask why.
You can raise these questions yourself and demand that the administrator follow the panel's recommendations, by providing written or oral public comments at a future CASAC meeting and commenting on the docket for the particulate matter rule-making. I'll be providing public comments this afternoon urging CASAC to follow the advice of the Independent Panel and commenting on the EPA's problematic process and drawing attention to that elephant in the room.
Gretchen Goldman is the research director at the Center for Science and Democracy.
Reposted with permission from our media associate Union of Concerned Scientists.
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In celebration of Earth Day, a star-studded cast is giving fans a rare glimpse into the secret lives of some of the planet's most majestic animals: whales. In "Secrets of the Whales," a four-part documentary series by renowned National Geographic Photographer and Explorer Brian Skerry and Executive Producer James Cameron, viewers plunge deep into the lives and worlds of five different whale species.
<span style="display:block;position:relative;padding-top:56.25%;" class="rm-shortcode" data-rm-shortcode-id="b102b19b2719f50272ab718c44703dd0"><iframe lazy-loadable="true" src="https://www.youtube.com/embed/xOySOlB78dM?rel=0" width="100%" height="auto" frameborder="0" scrolling="no" style="position:absolute;top:0;left:0;width:100%;height:100%;"></iframe></span>
Herring are a primary food source for Norway's orcas. Luis Lamar / National Geographic for Disney+
Belugas are extremely social creatures with a varied vocal range. Peter Kragh / National Geographic for Disney+
A Southern Right whales is pictured in the accompanying book, "Secrets of the Whales." Brian Skerry / National Geographic
The coronavirus has isolated many of us in our homes this year. We've been forced to slow down a little, maybe looking out our windows, becoming more in tune with the rhythms of our yards. Perhaps we've begun to notice more, like the birds hopping around in the bushes out back, wondering (maybe for the first time) what they are.
A Coeligena helianthea hummingbird is photographed during a birdwatching trail at the Monserrate hill in Bogota on November 11, 2020. Colombia is the country with the largest bird diversity in the world, home to about 1,934 different bird species, a fifth of the total known. JUAN BARRETO / AFP / Getty Images
1. Choosing the Right Binoculars<p>Binoculars are a relatively indispensable tool for most birders – but, for those just starting out, it might not yet be worth the several-hundred-dollar investment. If you aren't able to scour the attics of friends or borrow a pair from a fellow bird watcher, some local birding and naturalist groups have <a href="https://vashonaudubon.org/all-about-vashon-birds/binoculars-check-out/" target="_blank">binocular loaning programs</a> for members, allowing you to plan ahead for a day (or week) of birding.</p><p>When you're ready to take the plunge, choosing a pair or binoculars should take some careful deliberation based on your needs and preferences; some <a href="https://www.birdwatchersdigest.com/bwdsite/explore/optics/top-10-tips-buying-binoculars-bird-watching.php" target="_blank">major considerations</a> might include size, ease of use, <a href="https://www.rei.com/learn/expert-advice/binoculars.html" target="_blank" rel="noopener noreferrer">magnification</a>, and price. While professional binoculars can easily run north of $1,000, there are plenty of perfectly suitable entry-level binoculars under $200. You might not get the perfect precision and clarity of more elite models, but a less expensive pair will allow you to strengthen your birding skills while deciding if you're interested in investing in a premium pair.</p><p>For a budget-friendly option, check out resale options on eBay, Facebook marketplace, or neighborhood yard sales: you might find a nicer pair whose retail price isn't within your budget.</p>
2. Know What Birds Are in Your Area<p>When I began to pay more attention to the birds just outside my apartment building, I started to learn what species have always been around me: European starlings, house sparrows, blue jays, black capped chickadees, and the occasional red-bellied woodpecker. They had always been there, but I hadn't ever taken the time to identify them. Once you learn to <a href="https://www.audubon.org/news/get-know-these-20-common-birds_" target="_blank" rel="noopener noreferrer">recognize common birds</a> in your area, you'll be able to identify the typical species right outside your window and in your community. Of course, permanent residential birds in your neighborhood will <a href="https://nestwatch.org/learn/focal-species/" target="_blank" rel="noopener noreferrer">vary by region</a>, as will those migrating through it.</p>
3. Get Out and Explore<p>Venturing elsewhere might allow you to spot some different species beyond those frequenting your backyard. Anywhere with water or greenery offers a place for birding; as an urbanite myself, I've found that even small- and mid-sized parks in New York City allow me to find more elusive birds (although Central Park takes the crown for an afternoon of urban birding).</p><p>If you are able to travel a bit further from home, <a href="https://www.fws.gov/refuges/" target="_blank">national wildlife refuges</a> and <a href="https://www.americasstateparks.org/" target="_blank" rel="noopener noreferrer">state/national parks</a> are excellent places to explore bird habitats and perhaps log some less-common sightings. The American Birding Association also lists <a href="https://www.aba.org/aba-area-birding-trails/" target="_blank" rel="noopener noreferrer">birding trails by state</a>, and Audubon and BirdLife International identify <a href="https://www.audubon.org/important-bird-areas" target="_blank" rel="noopener noreferrer">Important Bird Areas (IBAs)</a> across the country – important bird habitats and iconic places that activists are fighting to protect – where birders can spot birds of significance.</p>
4. Finding a Bird: Stop, Look, Listen, Repeat<p>The National Audubon Society recommends the "<a href="https://www.audubon.org/news/how-find-bird" target="_blank">stop, look, listen, repeat</a>" mantra when seeking and identifying birds.</p><p>First and foremost, spotting birds requires attention. Stopping – getting out of the car, pausing on the sidewalk, trail, or in the backyard to look up – is the most important step.</p><p>When looking for birds, try to avoid gazing wildly around; rather, scan your surroundings, focusing on any odd shapes or shadows, trying to think about where a bird might perch (power lines, fence posts, branches), or keep an eye on the sky for flying eagles and hawks. In open areas like fields and beaches, you might have a more panoramic view, and can take in different sections of the landscape at a time. Look around with the naked eye before reaching for the binoculars to hone in.</p><p>While it can be hard to sift through the noise, listening for birds is perhaps an even more important element of bird watching than looking. Once you spend more time in the field, you'll be able to parse apart the racket and identify specific species, especially aided by Audubon's Bird Guide app or by learning from their <a href="https://www.audubon.org/section/birding-ear" target="_blank">Birding by Ear series</a>.</p><p>Repeat this pattern as you continue on your way, stopping to look and listen for birds as you go, rather than waiting for them to come to you. </p>
5. Identification<p>When you head out for a day of bird watching – especially when you're hoping to spot some new species – you'll want to be armed with the tools to identify what you see. <a href="https://www.audubon.org/news/how-identify-birds" target="_blank" rel="noopener noreferrer">Major considerations when identifying birds</a> are their group (such as owls, hawks, or sparrow-like birds), size and shape, behavior, voice, field marks, season, and habitat.</p><p>The <a href="https://www.sibleyguides.com/about/the-sibley-guide-to-birds/" target="_blank" rel="noopener noreferrer">Sibley Guide to Birds</a> and the <a href="https://www.hmhbooks.com/shop/books/peterson-field-guide-to-birds-of-north-america-second-edition/9781328771445" target="_blank" rel="noopener noreferrer">Peterson Field Guide</a> are widely considered the best books for identifying birds in North America, although many <a href="https://www.audubon.org/news/what-bird-guide-best-you" target="_blank" rel="noopener noreferrer">specialized guides</a> focus on specific species or regions as well.</p><p>Plenty of <a href="https://blog.nature.org/science/2013/05/27/boucher-bird-blog-apps-smart-birder/" target="_blank" rel="noopener noreferrer">bird identification apps</a> have popped up in recent years – including National Geographic Birds, Sibley eGuide to Birds, iNaturalist, Merlin Bird ID, and Birdsnap – which are basically a <a href="https://www.audubon.org/news/the-best-birding-apps-and-field-guides" target="_blank" rel="noopener noreferrer">field guide in your pocket</a>. I'm partial to the Audubon Bird Guide, which allows users to filter by common identifiers, including a bird's habitat, color, activity, tail shape, and general type, adding them all to a personal map to view your sightings.</p>
6. Recording Your Sightings<p><span>As you deepen your commitment to birding, you might join the community of birders that track and quantify their sightings, building their </span><a href="https://www.thespruce.com/what-birds-count-on-a-life-list-386704#:~:text=A%20life%20list%20is%20a,which%20birds%20you%20have%20seen." target="_blank" rel="noopener noreferrer">life list</a><span>.</span></p><p>While a standard notebook noting the date, species name, habitat, vocalizations, or any other data you wish to include will suffice, some birders opt for a more <a href="https://www.riteintherain.com/no-195-birders-journal" target="_blank" rel="noopener noreferrer">structured birder's journal</a> with pre-determined fields to record your encounters, take notes, draw sketches, etc.</p><p>Many birders also choose to record their sightings online and in shared databases (which include many of the field guide apps), often pinpointing them on a map for others to view. Launched by the Cornell Lab of Ornithology and Audubon, <a href="https://ebird.org/home" target="_blank" rel="noopener noreferrer">eBird is one of the largest databases and citizen science projects around birding</a>, where hundreds of thousands of birders enter their sightings, and users can explore birds in regions and hotspots around the world. Users can also record their sightings on the <a href="https://apps.apple.com/us/app/ebird/id988799279" target="_blank" rel="noopener noreferrer">eBird app</a>.</p>
7. Attracting Birds to Your Own Yard<p>Feeding birds is a common phenomenon: more than 40% of Americans maintain a birdfeeder to attract birds and watch them feast.</p><p>Not all birdfeed is created equal, however. Many commercial varieties are mostly made with "fillers" (oats, red millet, etc.) that birds will largely leave untouched. After researching what birds to expect in your area – and which ones you want to attract – you can create your own birdfeed with <a href="https://www.allaboutbirds.org/news/types-of-bird-seed-a-quick-guide/?pid=1142" target="_blank">seeds that will appeal to them</a>.</p><p>Beyond filling a birdfeeder, <a href="https://www.ecowatch.com/eco-friendly-lawn-2651194858.html" target="_self">transforming your yard into an eco-friendly oasis</a> is by far the best way to attract birds. Choosing to forgo mowing your lawn, planting native flowers and grasses, and ditching the pesticides will bring back the bugs that birds feed on, and provide a safe haven in which birds can happily live and eat.</p><p>While it's widely considered acceptable – and even beneficial – to feed birds with appropriate seeds, communal birdfeeders often <a href="https://www.audubon.org/news/to-feed-or-not-feed" target="_blank" rel="noopener noreferrer">foster unlikely interactions between different species</a>, who can then transmit harmful diseases and parasites to one another. Maintaining several bird feeders with different types of seeds might keep different species from coming into contact, and feeders can be <a href="https://www.allaboutbirds.org/news/how-to-clean-your-bird-feeder/" target="_blank" rel="noopener noreferrer">cleaned to prevent the spread of infection</a>.</p>
8. Inclusivity and Anti-Racism in the Birding Community<p>Like all outdoor activities and areas of scientific study, birding communities are subject to racist and discriminatory ideologies. Black birders have long experienced discrimination and underrepresentation in outdoor spaces. The work of organizations like the <a href="https://www.instagram.com/birdersfund/" target="_blank">Black & Latinx Birders Fund</a>, <a href="https://www.instagram.com/birdability/" target="_blank">Birdability</a>, and <a href="https://www.instagram.com/feministbirdclub/" target="_blank">Feminist Bird Club</a> highlight the contributions and importance of birders of color, birders with disabilities, and women and LGBTQ+ birders to the birding community, as do activists and naturalists like <a href="https://www.instagram.com/hood__naturalist/" target="_blank">Corina Newsome</a> and <a href="https://www.instagram.com/tykeejames/" target="_blank">Tykee James</a>. The work of <a href="https://www.audubon.org/news/its-bird-new-comic-written-central-park-birder-christian-cooper" target="_blank">Christian Cooper</a>, <a href="https://camilledungy.com/publications/" target="_blank">Camille Dungy</a> (read her poem <a href="https://www.poetryfoundation.org/poetrymagazine/poems/58363/frequently-asked-questions-10" target="_blank">Frequently Asked Questions: 10</a>), and <a href="https://orionmagazine.org/article/9-rules-for-the-black-birdwatcher/" target="_blank">J. Drew Lanham</a> – including his essay "<a href="https://lithub.com/birding-while-black/" target="_blank">Birding While Black</a>" – are a great place to start.</p><p>Getting involved in birding means educating ourselves on these issues and taking meaningful action; the work of <a href="https://www.audubon.org/news/its-bird-new-comic-written-central-park-birder-christian-cooper" target="_blank">Christian Cooper</a> and <a href="https://orionmagazine.org/article/9-rules-for-the-black-birdwatcher/" target="_blank">J. Drew Lanham</a> – including his essay "<a href="https://lithub.com/birding-while-black/" target="_blank" rel="noopener noreferrer">Birding While Black</a>" – are a great place to start. Just as birders are activists for protecting habitats and natural areas, we must also be active and aware of inclusivity in these spaces.</p>
9. Get Involved<p>To learn from and enjoy the company of other birders, check out local birding groups in your area to join. Many Audubon chapters host trips, meetings, and bird walks for members. The American Birding Association even maintains a <a href="https://www.aba.org/festivals-events/" target="_blank">directory of birding festivals</a> across the country.</p><p>Volunteering for birds is also a great way to meet other birders and take action for birds in your community; local organizations might have opportunities for assisting with habitat restoration or helping at birding centers.</p><p>Like all wildlife, climate change and habitat destruction threaten the livelihood of birds, eliminating their breeding grounds and food sources. A <a href="https://www.audubon.org/climate/survivalbydegrees" target="_blank">2019 report released by the National Audubon Society</a> found that two-thirds of North American birds may face extinction if global temperatures rise 5.4 degrees Fahrenheit by 2100. Staying informed about and taking action for legislation designed to protect birds and our climate – such as the recent <a href="https://www.congress.gov/bill/116th-congress/house-bill/5552/text" target="_blank" rel="noopener noreferrer">Migratory Bird Protection Act</a> – is important for ensuring a livable future for wildlife and humans alike.</p><p><em>Linnea graduated from Skidmore College in 2019 with a Bachelor's degree in English and Environmental Studies, and now lives in Brooklyn, New York. Most recently, Linnea worked at Hunger Free America, and has interned with WHYY in Philadelphia, Saratoga Living Magazine, and the Sierra Club in Washington, DC. </em><em>Linnea enjoys hiking and spending time outdoors, reading, practicing her German, and volunteering on farms and gardens and for environmental justice efforts in her community. Along with journalism, she is also an essayist and writer of creative nonfiction.</em></p>
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