The brushfires raging through New South Wales have shrouded Australia's largest city in a blanket of smoke that pushed the air quality index 12 times worse than the hazardous threshold, according to the Australia Broadcast Corporation (ABC).
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Tweeting that the U.S. has the cleanest air in the world does not make it so. Not only do we rank 10th, but a new study says that after steady improvement during the Obama-era, air pollution has gotten worse while Donald Trump has been president.
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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 Elephant in the CASAC Meeting<p>CASAC has already acknowledged that <a href="https://blog.ucsusa.org/gretchen-goldman/uncharted-territory-the-epas-science-advisors-just-called-out-administrator-wheeler" target="_blank">they don't have the expertise</a> 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.</p><p><span style="background-color: initial;">As a result, we should watch whether or not CASAC aligns with the panel in their recommendations on the standards. If CASAC </span>doesn't <span style="background-color: initial;">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 </span><a href="https://ucs-documents.s3.amazonaws.com/science-and-democracy/pm-panel-meeting-docs/2-ipmrp-biosketches.pdf" target="_blank" style="background-color: initial;">set of experts</a><span style="background-color: initial;"> on the topic. In any event, the administrator will have access to both CASAC and the </span><a href="https://ucs-documents.s3.amazonaws.com/science-and-democracy/IPMRP-FINAL-LETTER-ON-DRAFT-PA-191022.pdf" target="_blank" style="background-color: initial;">Independent Panel's recommendations</a><span style="background-color: initial;"> 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.</span></p>
The Fine Particulate Matter Standards Don’t Protect Public Health<p>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 <a href="https://www.epa.gov/sites/production/files/2019-09/documents/draft_policy_assessment_for_pm_naaqs_09-05-2019.pdf" target="_blank">Draft EPA Policy Assessment</a> that the current standards aren't requisite to protect public health.</p><p>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.</p><p>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.</p><p>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.</p>
Keeping the Current Fine Particulate Matter Standards Ignores the Science<p>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.</p><p>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.</p>
Otherwise, the EPA’s Draft Policy Assessment Is Scientifically Sound<p>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.</p><p>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 <a href="https://science.sciencemag.org/content/363/6434/1398" target="_blank">not shared by the scientific community</a>, and now, not shared by the Independent Panel either.</p>
Other Particulate Pollution Standards Also May Need Revamping<p>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.</p>
The Panel Condemns the EPA’s Broken Process<p>The Independent Panel's deliberations, demands for further research, and unanswered questions highlight how <a href="https://blog.ucsusa.org/gretchen-goldman/wheeler-worsens-particulate-pollution-review-process" target="_blank">broken the EPA process is</a>. 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 <a href="https://twitter.com/GretchenTG/status/1184207743261036551" target="_blank">policy decisions were discussed</a>. But alas, the panel had to make do with what was available to them and CASAC does too.</p><p>Fortunately for CASAC, an Independent Panel has already done their job, and they are free (and encouraged) to run with it, especially given <a href="https://blog.ucsusa.org/gretchen-goldman/a-timeline-of-recent-attacks-on-the-epas-science-based-ambient-air-pollution-standards" target="_blank">the long list</a> of ways that EPA Administrator Wheeler has damaged the ambient air pollution review process.</p><p><a href="https://yosemite.epa.gov/sab/sabproduct.nsf/MeetingCalCASAC/A2DF51609E3DFC9C85258473006CF120?OpenDocument" target="_blank">Listen</a> and <a href="https://yosemite.epa.gov/sab/sabproduct.nsf/MeetingCalCASAC/49FAF8892AD2D38285258473006D1F4A?OpenDocument" target="_blank">watch</a> 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.</p><p>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 <a href="https://yosemite.epa.gov/sab/sabproduct.nsf/MeetingCalCASAC/A0D0F9D4C6BC36D88525848C00467771?OpenDocument" target="_blank">future CASAC meeting</a> and commenting on the docket for the <a href="https://www.federalregister.gov/documents/2019/09/11/2019-19627/release-of-a-draft-document-related-to-the-review-of-the-national-ambient-air-quality-standards-for" target="_blank">particulate matter rule-making</a>. I'll be providing public comments this afternoon urging CASAC to follow the advice of the Independent Panel and commenting on the <a href="https://blog.ucsusa.org/gretchen-goldman/a-timeline-of-recent-attacks-on-the-epas-science-based-ambient-air-pollution-standards" target="_blank">EPA's problematic process</a> and drawing attention to that elephant in the room.</p>
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Exposure to air pollution is known to cause a vast array of respiratory health problems, but in a new study, researchers at Columbia University's Mailman School of Public Health have determined that air pollution can also weaken bones.
The paper, published in The Lancet Planetary Health, is the first to document high rates of hospital admissions for bone fractures in communities with elevated levels of ambient particulate matter (PM2.5).
A coalition of groups has filed a lawsuit in the Ninth Circuit Court of Appeals challenging the U.S. Environmental Protection Agency’s (EPA) issuance of air pollution discharge permits for Shell’s Discoverer drillship and associated fleet for use in the Beaufort and Chukchi seas. The permits, provisionally approved last September, were issued Feb. 10, 2012. Shell intends to use the Discoverer to drill in the fragile, remote, stormy and icy waters of the America's Arctic Ocean starting this summer.
Alaska Wilderness League, Center for Biological Diversity, Natural Resources Defense Council, Northern Alaska Environment Center, Oceana, Pacific Environment, Resisting Environmental Destruction on Indigenous Lands (REDOIL), Sierra Club, and The Wilderness Society filed the challenge late last Friday, represented by Earthjustice. The organizations issued the following statement regarding the lawsuit:
“As early as this summer, the Discoverer drillship and other vessels in Shell’s fleet could be in the Chukchi Sea or Beaufort Sea of the Arctic Ocean where they will pump tens of thousands of tons of pollution into pristine Arctic skies. Not only will they be drilling for oil in some of the harshest conditions on earth, each year these ships will emit large amounts of harmful air pollutants such as carbon monoxide, nitrogen dioxide and particulate matter. Further, greenhouse gases and black carbon from the Discoverer fleet are expected to accelerate the loss of snow and sea ice in the Arctic, to the detriment of both the fragile Arctic ecosystem and members of Alaska Native communities that rely upon a healthy ecosystem for subsistence and other traditional cultural activities.
“The EPA approved these permits without ensuring that all air quality standards are met, and as such our only option is to challenge them in court. Although the Clean Air Act requires modern pollution controls that could greatly reduce much of this pollution, the EPA did not require Shell to install all the controls it should have.
“In addition to the excess air pollution from the Discoverer and Shell’s other ships, Shell’s drilling poses other risks. Drilling for oil in the remote waters of the Arctic Ocean is risky and fraught with potential disaster. An oil spill in these waters would have significant impacts on endangered and threatened species such as bowhead whales and polar bears.”
For more information, click here.
The American Lung Association and the National Parks Conservation Association filed a federal lawsuit on Feb. 14 to force the U.S. Environmental Protection Agency (EPA) to complete the required review of the need for stronger limits on the amount of soot, smoke and other airborne particles that endanger public health.
Airborne particulate matter is comprised of tiny particles of smoke, soot, metals and other chemical compounds emitted from sources like power plants, factories, and diesel trucks. Scientists say particulate matter, which can penetrate deep into our lungs, is one of the most toxic forms of air pollution.
The Clean Air Act requires EPA to review the science and update the National Ambient Air Quality standards every five years to ensure the public is protected by the best available science. The agency failed to meet the deadline in October 2011. EPA’s failure to update these standards nationwide means that outdated limits remain in place even though they fail to protect public health. Those particularly hard hit by particulate pollution include children, seniors, people with lung disease, heart disease and diabetes, and low income communities. Without updated standards, millions of Americans will face continued risk from unhealthy levels of particle pollution. Stronger standards would drive cleanup measures nationwide that could prevent thousands of premature deaths annually, according to an analysis published in 2011.
The lawsuit, filed by the public interest law firm Earthjustice on behalf of both national, nonprofit organizations, asks the U.S. District Court for the District of Columbia to impose a deadline of October 2012 for EPA to complete its review of the National Ambient Air Quality Standards.
In a companion lawsuit filed last week, nearly a dozen state attorneys general also sued the EPA over this ongoing violation of the federal Clean Air Act.
“EPA let this deadline come and go but did nothing to address a growing health crisis,” said Earthjustice attorney Paul Cort. “Meanwhile, thousands more Americans are getting sick and dying from the air they breathe. EPA needs to act now, do its job, and obey the law.”
The health risks caused by breathing particulate matter are outlined in a recent study published by Earthjustice, the American Lung Association, and the Clean Air Task Force. The report, Sick of Soot, details how a reduction of soot in the air can prevent more than 35,000 premature deaths each year, decrease cases of aggravated asthma by more than one million, and save at least $280 billion in health care costs.
“Since the last review, we’ve learned a lot about how dangerous these particles are. It makes no sense to continue to base public health protections on outdated science,” said Janice Nolen, assistant vice president of National Policy and Advocacy for the American Lung Association. “A stronger particulate matter standard would provide more protection to people across the nation from dangerous particles. Strengthening the standards drives the action we can take to prevent thousands of premature deaths and hundreds of thousands of asthma attacks each year. EPA needs to finish its job.”
In 2006, EPA overruled its science advisors, who called for stronger pollution protections, and instead adopted the current weak particulate matter standards. In 2009, as a result of a separate legal challenge brought by these same health and environmental groups, a federal appeals court ruled that these standards were deficient and sent them back to EPA for corrective action. Since then, EPA has failed to propose new standards for particulate matter.
Airborne particulate matter is comprised of tiny particles of smoke, soot, metals and other chemical compounds emitted from sources like power plants, factories, and diesel trucks. Scientists say particulate matter, which can penetrate deep into our lungs, is one of the most toxic forms of air pollution. Particulate matter is also responsible for much of the haze that clouds many of our cities and parklands.
“These particles of pollution are a hazard not only to our health but to our environment as well,” said Mark Wenzler, vice president of Climate & Air Quality Programs at the National Parks Conservation Association. “The same soot we breathe is also degrading the views, plants, and wildlife in our national parks. For the sake of our parks and their neighboring communities that depend on clean, clear air, it’s time for EPA to get to work and clear the air.”
For more information, click here.