March 28, 2023
Environmental, Health, and Grassroots Organizations Support Stronger Protections from Particulate Matter Pollution
The message to the Biden administration: We are counting on you to keep your promise.
Docket ID No. EPA-HQ-OAR-2015-0072
Dear President Biden and EPA Administrator Regan,
We the undersigned 180 groups write to express support for stronger National Ambient Air Quality Standards (NAAQS) for fine particulate matter pollution (PM2.5), also known as soot. While we applaud the EPA’s work to update the current standards, we are concerned that the draft proposal does not align with the recommendations of the majority of the Clean Air Scientific Advisory Committee (CASAC). Adoption of strong standards at the lowest end of the recommended range would make tremendous strides in delivering on your administration's promise to prioritize environmental justice in your decision making. We urge you to finalize, without delay, standards no higher than 8 μg/m3 for the annual standard and 25 μg/m3 for the 24-hour standard. We also urge the agency to finalize stronger secondary standards to protect our ecosystems and natural resources.
Exposure to fine particle pollution causes a range of health harms, such as increased infant mortality, cardiovascular and respiratory disease, asthma attacks, diabetes, dementia, and premature death. These health impacts disproportionately impact communities of color, fenceline communities, and lower-income households who are already overburdened by pollution and healthcare costs.
Standards no higher than 8 μg/m3 (annual) and 25 μg/m3 (24-hour) would be consistent with law and firmly supported by science. They would also provide substantially greater benefits over and do more to reduce mortality disparities across racial and ethnic groups than even the lowest end of the range EPA has proposed. Adopting the most stringent annual standard proposed by EPA — 9 μg/m3 — would save more than 4,200 lives, but adopting the standard recommended by the majority of CASAC — 8 μg/m3 — would save more than twice that number in the year 2032. Under current standards, Black Americans over 65 are 300 percent more likely to die from air pollution than White Americans. EPA’s proposed standards, however, would barely begin to address these disparities. As EPA’s own analysis shows, it could save seven times more Black lives every year with a standard of 8 μg/m3 compared to a standard of 10 μg/m3. And an annual standard of 8 μg/m3 would also essentially eliminate racial disparities in exposures to particulate matter pollution. The net benefits that could be realized under an annual standard of 8 μg/m3 were estimated by EPA to total $44–93 billion annually, higher than the benefits under an annual standard of 9 μg/m3.
EPA must strengthen both the annual and 24-hour primary standards because both are critical for protecting public health. Communities that live closest to pollution sources like industrial facilities and heavily trafficked roads are disproportionately affected by short-term spikes in air pollution. Because of historically racist planning practices like redlining, these communities are often communities of color. Research suggests that people of color are disproportionately exposed to short-term spikes in soot pollution across all EPA regions, and that and racial disparities in short-term soot pollution exposure may even be larger than disparities in long-term soot exposure. A majority of CASAC members recommended tightening the 24-hour standard, citing numerous scientific studies that support the decision. Strengthening only the annual standard is not enough to protect communities from dangerous short-term pollution spikes. EPA must act to right long-standing environmental and health injustices faced by fenceline communities, and it can do so by finalizing the most protective standard.
Millions of Americans are counting on the EPA to advance solutions for pollution that protect our environment and right to clean air. We urge you to move quickly to finalize stronger, more protective primary and secondary standards (no higher than 8 μg/m3 for the annual and 25 μg/m3 for the 24-hour) for particle pollution.
Sincerely,
A
- Adirondack Council
- AFGE Local 704
- Air Alliance Houston
- Alliance of Nurses for Healthy Environments
- Alternatives for Community and Environment
- American Academy of Pediatrics
- American Society of Landscape Architects
- American Sustainable Business Network
- ANA-California
- ANA-Illinois
- ANA-New York
- Animals Are Sentient Beings, Inc.
- Appalachian Mountain Club
- Appalachian Voices
- Arizona Climate Action Coalition
- Arizona Interfaith Power & Light
- Asthma and Allergy Foundation of America
- Aytzim: Ecological Judaism
B
- Between the Waters
- Black Millennials 4 Flint
- Breathe Project
C
- California Communities Against Toxics
- California Safe Schools
- Carolina Advocates for Climate, Health, and Equity
- Center for Biological Diversity
- Center for Community Action and Environmental Justice
- Center for Progressive Reform
- Central California Asthma Collaborative
- Central Valley Air Quality Coalition
- Chesapeake Climate Action Network
- Chicago Area Progressives
- Chicano Latino Caucus of San Bernardino County
- Chispa AZ
- Church Women United in New York State
- Citizens for Arsenal Accountability
- Citizens for Pennsylvania's Future (PennFuture)
- Citizens for Safe Water Around Badger (CSWAB)
- The Clean Air Coalition of WNY
- Clean Air Task Force
- Cleveland Lead Advocates for Safe Housing (CLASH)
- Climate Action PA
- Climate Action Campaign
- Climate Crisis Policy Digest
- Climate Reality Project Chicago Metro
- The Climate Reality Project: Philadelphia and Southeastern PA Chapter
- Coalition for a Safe Environment
- Coalition to Protect America's National Parks
- Coalition to Protect New York
- COCO-Coalition of Community Organizations
- Comite Pro Uno
- Community Activist
- Community In-power & Development Association Inc.
- Coney Island Beautification Project, Inc.
- Conservation Voters of PA
- Cuyahoga County Section-NCNW
D
- Dayenu: A Jewish Call to Climate Action
- Defend Our Future
- Delaware Nurses Association
- Dogwood Alliance
- Don't Waste Arizona
- Downwinders at Risk
E
- EARTHDAY.ORG
- Earthjustice
- Earthworks
- Ecology Center
- Elders Climate Action
- Elected Officials to Protect America
- Environment America
- Environmental Community Advocates of Galena Park
- Environmental Defenders of McHenry County
- Environmental Defense Fund
- Environmental Integrity Project
- Environmental Law & Policy Center
- Evergreen Action
- Extinction Rebellion US
- Extinction Rebellion San Francisco Bay Area
F
- 48217 Zip Code Air Monitoring Committee
- Faith in Place
- First Focus on Children
- Florida Rising
- Forest Keeper
- FreshWater Accountability Project
- Fridays for Future Charlotte
- Friends of the Earth (FOE) - USA
G
- GASP
- Georgia Conservation Voters
- Georgia Interfaith Power and Light
- Great Lakes Business Network
- Green The Church
- Green the Church Louisiana
- GreenLatinos
H
- Health & Medicine Policy Research Group
- Health Babies Bright Futures
- Health Care Without Harm
- Healthy Environment Alliance of Utah
- Healthy Schools Network
- Hispanic Access Foundation
- Hispanic Federation
I
- Illinois Association of School Nurses
- Institute for a Progressive Nevada
- Interfaith Power & Light
- Interreligious Eco-Justice Network
- Iowa Environmental Council
- Ironbound Community Corporation
K
- Kenwood Oakland Community Organization
L
- La Mujer Obrera
- League of Conservation Voters
- Learning Disabilities Association of America
- LULAC Council 22387
- LULAC Council 4703
- LULAC Florida
M
- Macedonia Development Corporation, NFP
- Metro east green alliance
- MI Air MI Health
- The Michael J. Fox Foundation for Parkinson's Research
- Michigan Climate Action Network
- Michigan Clinicians for Climate Action
- Michigan League of Conservation Voters
- Michigan Sustainable Business Forum
- Missouri Nurses Association
- Moms Clean Air Force
- Moms Clean Air Force - Arizona
- Moms Clean Air Force Georgia
- Moms Clean Air Force, Michigan
- Montana Environmental Information Center
- Montana Health Professionals for a Healthy Climate
- Mothers And Others For Clean Air
- MoveOn Hoboken RESIST
N
- National Association of Neonatal Nurses
- National Association of Pediatric Nurse Practitioners
- National Association of School Nurses
- National Environmental Health Association
- National Parks Conservation Association
- National Student Nurses' Association, Inc.
- National Wildlife Federation
- Natural Resources Defense Council
- NC100BW Inc. Greater Cleveland Chapter
- Nevada Conservation League Commission
- New Hampshire Nurses Association on Planetary Health
- New Jersey Audubon
- New Mexico Environmental Law Center
- New Mexico Wild
- North American Climate, Conservation and Environment (NACCE)
- Northeast Ohio Black Health Coalition
O
- Old Southwest Inc - Green Committee
- OLÉ Education Fund
- One APIA Nevada
P
- Parents Engaging Parents PEPNJ
- Partnership for Policy Integrity
- PennEnvironment
- PennFuture
- Pennsylvania Interfaith Power & Light
- Physicians for Social Responsibility
- Physicians for Social Responsibility, AZ Chapter
- Pitzer College Robert Redford Conservancy
- Poder Latinx
- Powder River Basin Resource Council
- Progressives for Climate
- ProgressNow New Mexico
- Prosperity Works
- Public Citizen
R
- Rachel Carson Council
- Rep GA Institute Inc.
- Responsible Alpha, Inc.
S
- Sierra Club
- Sierra Club - Grand Canyon Chapter
- Southern Alliance for Clean Energy
- Southwest Energy Efficiency Project
- Southwest Detroit Community Benefits Coalition
- South Fontana Concerned Citizens Coalition
- Sustainable Roanoke
T
- 350 Humboldt
- Terra Advocati
U
- The Union for Reform Judaism
- Unlimited Potential
- US Partnership for Education for Sustainable Development
- Utah Physicians for a Healthy Environment
V
- V Martin Environmental Justice Consultant LLC
- Valley Watch, Inc.
- Virginia Clinicians for Climate Action
- Vote Solar
W
- Warehouse Workers for Justice
- Webb County LULAC #22387
- Western Clean Energy Campaign
- Western Resource Advocates
- Wisconsin Green Muslims
- Womxn From The Mountain
This letter (PDF) was delivered to the White House and U.S. Environmental Protection Agency on Mar. 28, 2023.