It summarizes the findings of Health Benefits of Alternative PM2.5 Standards, a technical report that was prepared for the American Lung Association, Clean Air Task Force and Earthjustice by Donald McCubbin, Ph.D.
On December 14, 2012, the EPA adopted protections that will slash the amount of soot allowed in our air, improving air quality for millions of Americans.
This move by the EPA comes in response to legal action filed by Earthjustice on behalf of the American Lung Association and the National Parks Conservation Association asking that the EPA follow the Clean Air Act’s requirements to protect the public’s health and well-being.
The EPA’s proposal is slightly below the strongest recommended levels, but is nonetheless an important step towards cleaner, healthier air.
The Nation Is Sick of Soot
1. In early 2009, following an Earthjustice lawsuit, the U.S. Court of Appeals for the D.C. Circuit found that the EPA's current soot standards do not adequately protect public health and ordered the agency to update them.
On November 16, 2011, after several years of inaction by the EPA, Earthjustice petitioned the U.S. Court of Appeals for the D.C. Circuit on behalf of several public health and environmental groups to set a deadline for the EPA to issue stronger soot standards.
PM NAAQS Mandamus Petition
States' Petition for Writ of Mandamus
2. On October 18, 2011, Earthjustice sent the EPA a notice of intent to sue giving the agency 60 days to address its failure to conduct a mandatory five-year review of the current soot standards, set in 2006.
Notice of Intent Letter
In July 2012, members of the public shared personal and emotional testimony at a public hearing in Sacramento, CA, focused on EPA's recent proposal to further limit emissions of deadly air pollution.
Listen to attorney Paul Cort's comments in an episode of Earthjustice’s environmental news podcast, EJ90:
Sick Of Soot summarizes the findings of Health Benefits of Alternative PM2.5 Standards, a technical report that was prepared for the American Lung Association, Clean Air Task Force and Earthjustice by Donald McCubbin, Ph.D.
Dr. Donald McCubbin has analyzed the health benefits of the Clean Air Act, major regulations such as the Heavy-Duty Diesel Rule and the Clean Air Interstate Rule, and the impacts of power plants, motor vehicles and other pollution sources.
He received the EPA's Level 1 Science and Technological Achievement Award for work on the health benefits of alternative ozone standards and he received Abt Associates' Daniel Bell Award for the development of the Environmental Benefits Mapping and Analysis Program (BenMAP).
Research for Health Benefits of Alternative PM2.5 Standards was made possible by the generous support of the Energy Foundation.
The U.S. Environmental Protection Agency (EPA) must soon update national health standards for fine particulate matter air pollution (PM2.5), commonly referred to as soot—a major cause of premature death and a widespread threat to those who suffer from lung and heart disease. The national health standards are critical tools that drive the cleanup of soot pollution across the country.
According to the EPA, fine particle pollution:
- Causes early death (from both short- and long-term exposure);
- Causes cardiovascular harm (e.g., heart attacks, stroke, heart disease, congestive heart failure);
- Likely causes respiratory harm (e.g., worsened asthma, worsened COPD, inflammation);
- May cause cancer; and
- May cause developmental and reproductive harm.
The EPA will choose an updated national health standard from a range of possible options. In April 2011, staff scientists at the EPA made a series of recommendations to Administrator Lisa Jackson. These recommendations were based on a review of current research on the health effects of PM2.5, conducted by the EPA National Center for Environmental Assessment and vetted by the Clean Air Scientific Advisory Committee (CASAC), an independent body that offers technical advice to the EPA on ambient air quality standards. Health Benefits of Alternative PM2.5 Standards, a new analysis prepared for the American Lung Association, Clean Air Task Force and Earthjustice, examines these and other options and estimates the life- and costsaving potential for each scenario of reduced soot pollution.
Based on the analysis, the options currently under consideration at the EPA are not strong enough to protect public health with an adequate margin of safety. These organizations recommend that the EPA adopt a health standard at the strongest end of the range of options considered by the analysis—an annual standard of 11 micrograms per cubic meter (μg/m3) and a daily standard of 25 μg/m3.
Meeting this standard could prevent as many as 35,700 premature deaths every year, in addition to delivering major reductions in harm to people with heart and respiratory disease. Overall, the nation could benefit by as much as $281 billion every year from reduced costs associated with premature death and disease.
The Clean Air Act requires the EPA to follow science and protect public health. To comply with the law, it should adopt the PM2.5 health standard recommended by this report.
Findings And Recommendations
If the EPA strengthens the current standard of 15 μg/m3 annually and a daily limit of 35 μg/m3 to the recommendation of this report—an annual limit of 11 μg/m3 and a daily limit of 25 μg/m3—the analysis predicts that, every year, Americans will be spared from as many as:
- 35,700 premature deaths;
- 2,350 heart attacks;
- 23,290 visits to the hospital and emergency room;
- 29,800 cases of acute bronchitis;
- 1.4 million cases of aggravated asthma; and
- 2.7 million days of missed work or school due to air pollution-caused ailments.
These health benefits—which are estimates based on improvements relative to current air quality conditions—far outweigh the benefits from any standard the EPA is currently considering.
Overall, the number of premature deaths that could be avoided every year from the most protective standard is equivalent to the size of a sold-out crowd at Fenway Park, Boston's historic baseball stadium. The same epidemiological study used in Figures 1, 2 and 3 found that the current standard—15 μg/m3 (annual) and 35 μg/m3 (daily)—could prevent up to 5,240 premature deaths every year. Strengthening the soot standard to 13 μg/m3 (annual) and 35 μg/m3 (daily), the weakest option that the EPA is considering, could prevent 2,950 additional premature deaths and be important progress. Yet, adopting the standard recommended by this report could prevent an additional 30,460 premature deaths every year—more than 10 times the current number. To maximize the potential of these important health protections to prevent premature death and illness, it is clear that the EPA must set a strong soot standard of 11 μg/m3 (annual) and 25 μg/m3 (daily).
The health benefits bring major financial benefits as well. Strengthening the annual PM2.5 standard to 11 μg/m3 and the daily standard to 25 μg/m3 will lead to economic benefits for the American public of $281 billion every year from reduced costs associated with premature death and disease.
While health benefits will be distributed across the nation, 10 major metropolitan areas stand to benefit significantly.
To estimate these health and economic benefits, recent air quality data from the EPA's monitoring network were incorporated into the same computer modeling program that the agency uses in its own regulatory impact analyses. This analysis, however, goes beyond the findings published in the EPA's Quantitative Health Risk Assessment for Particulate Matter in several important respects:
- It is national in scope. The EPA's analysis only focuses on 15 urban areas in the continental U.S.
- It examines a wider range of daily and annual health standard combinations than the EPA has considered.
- It uses more current data. The air quality monitoring data used in this report comes from 2007–2009, whereas the EPA risk assessment, which was completed in 2010, relied on older data from 2005–2007. The more current data used in this report are closer to today's actual air quality conditions. Air quality has improved considerably in recent years due to a number of factors, including cleaner cars entering the fleet and the economic downturn. Consequently, it should be easier for the nation to meet the health standard recommended by this report because current conditions are in fact closer to that standard than the EPA's older modeling has shown.
The EPA is required by the Clean Air Act to protect public health with an adequate margin of safety. To do so, the agency should strengthen the national standard for fine particulate matter to an annual standard of 11 μg/m3 coupled with a daily standard of 25 μg/m3. This standard could prevent as many as 35,700 premature deaths every year, significantly more than any of the standards that the EPA is currently considering. It will also prevent illness, tens of thousands of hospital visits and millions of days of lost productivity, while providing up to $281 billion annually in benefits associated with reducing premature death and disease.