22 Jan Tell the EPA You Want Strong Smog Protections

By Sarah Sharif 

EPA is holding a hearing on January 29, 2015 in the Dallas area and this is our time to tell EPA to crack down on polluters that cause the orange and red smog days we have every summer. Smog is caused by the harmful gas ozone and it fills the skies in Texas cities like Dallas, Fort Worth, Austin, San Antonio, and Houston every summer. Together with our allies and friends we are organizing buses from Central Texas and everyone who can make it should join us on the trip up to North Texas.

We need to tell EPA to take steps to crack down on the pollution from dirty oil and gas and fracking operations, from cement kilns and other industrial smokestacks, from toxic coal plants, and from old diesel trucks. The latest medical science tells us that children with asthma are particularly vulnerable to smog pollution and its up to us to put pressure on EPA to take the steps needed to protect Texas children

We know we can’t count on the so-called Texas Commission on Environmental Quality to get polluters to eliminate their toxic air emissions. That’s why we need the U.S. EPA to step in and set a strong smog standard that will force polluters to clean up their emissions.

The Clean Air Act requires EPA to set National Ambient Air Quality Standards (NAAQS) that will protect public health, including the health of sensitive populations, with an adequate margin of safety. The current standard allows too much pollution and it is above the level proven to harm the lungs, and in particular, the lungs of our kids.  Unfortunately, the TCEQ prefers to spend its time and money creating confusion in the public about whether ozone smog is harmful to the public, and they are doing everything they can to help big polluters at the expense of good science and our health.

The evidence is absolutely clear: Ozone smog is harmful and EPA needs to strengthen the ozone standard and make polluters reduce their emissions.

Populations most at risk include children, the elderly, people with asthma, and otherwise healthy individuals that work or exercise outdoors. People with pre-existing respiratory diseases are at increased risk because they have less pulmonary reserve and cannot tolerate the reduction in lung function or the increase in respiratory symptoms. 

More than 25 million people in the United States have asthma, 74 million are children, and 40 million are senior citizens.  There are nearly 17 million outdoor workers.  Based on age criteria alone, more than one-third of the population is at increased risk of adverse effects from ozone air pollution. 

The EPA Clean Air Scientific Advisory Committee (CASAC), an independent blue-ribbon panel of doctors and scientists has repeatedly recommended that EPA strengthen the smog air quality standard. In their most recent letter to the EPA Administrator, the CASAC made clear that the current standard is inadequate to protect public health, and that even a standard that was a little better than the one we have today would still allow adverse effects including decrease in lung function, increase in respiratory symptoms, and increase in airway inflammation.

The CASAC advised that the standard should be significantly improved and strengthened to meet the statutory requirement in the Clean Air Act to protect public health with an adequate margin of safety. 

We are asking for EPA to set a standard of how much pollution is allowed in our air of no more than 60 ppb – substantially lower than the current standard of 75 ppb – because it is the most protective option, and the only option that would “certainly” provide an adequate margin of safety.

According to the CASAC: 

“ . . . there is a causal relationship between short-term ozone exposure and a broad range of respiratory effects, including lung function decrements, respiratory symptoms, inflammation, hospital admissions, and emergency department visits, all of which are observed below the level of the current ozone NAAQS.”

“The CASAC concludes that there is adequate scientific evidence to recommend a range of levels for a revised primary ozone standard from 70 ppb to 60 ppb.”

“The frequency of lung function decrements and premature mortality from short-term exposure to ozone decreases even further when the alternative standard is lowered to 60 ppb.”

EPA’s own Children’s Health Protection Advisory Committee recommends a revised ambient air quality standard of 60 ppb to protect the health of children.  According to that Committee: 

“Children suffer a disproportionate burden of ozone-related health impacts due to critical developmental periods of lung growth in childhood and adolescence that can result in permanent disability.”

An Integrated Science Assessment completed by EPA in 2013 found stronger evidence of the adverse effects of short- and long-term exposure to ozone for many health endpoints. 

The key new findings include a conclusive determination that ozone causes adverse respiratory effects, several new controlled human exposure studies (in healthy young adults) demonstrating respiratory deficits and inflammation at 60 ppb, stronger findings that the adverse effect of ozone on cardiovascular health are likely causa, new information suggesting reproductive effects such as increased risk of low birth weight babies, suggestive neurological effects new community health studies strengthening the link between ozone exposure and mortality, even at concentrations below the current standards, and new information about the impact of longer-term exposures on respiratory health endpoints such as pulmonary inflammation and injury, and new onset asthma.

After a comprehensive six-year review, EPA staff scientists conclude that the current standard is not protective of public health and recommend a standard in the range of 60 to 70 ppb in the 2014 Policy Assessment. EPA scientists said “Staff reaches the overall conclusion that the available health evidence and exposure/risk information call into question the adequacy of the public health protection provided by the current standard.” 

In the laboratory, controlled human exposure studies provide strong evidence that healthy young adults experience diminished breathing capacity and airway inflammation at ozone concentrations of 60 ppb. The physiological effects demonstrated at 60 pbb are linked to aggravation of asthma, increased susceptibility to respiratory infection, increased use of medication, more school and work absences, doctor visits, and emergency room visits. 

Sensitive populations such as children and people with asthma would likely experience these effects at even lower concentrations. People with pre-existing lung disease such as COPD have lower ventilatory reserves, and ten percent declines in lung function of can lead to moderate to severe respiratory symptoms. 

Epidemiological studies provide evidence that ozone increases risk of emergency room visits and hospital admissions for respiratory problems, and even premature death. The most compelling studies are those that report associations with ozone in areas that meet the current air quality standards. Multicity studies in less polluted areas of Canada report positive associations with morbidity and mortality even when the majority of study locations would have met the current ozone standard. A study in Seattle reported associations between ozone and asthma emergency department visits in an area that would have met current standards during the entire study period. A study of pediatric asthma emergency visits in Atlanta found no evidence of a threshold down to concentrations of 30 ppb ozone, with the greatest statistical confidence at 55 ppb.

A study of asthma hospital admissions in New York City reported positive associations with ozone, even when over 99 percent of the days would have met the current standard.

Panel studies of children and outdoor workers report respiratory effects at ambient concentrations lower than 60 ppb.  Epidemiological studies show increased risk of premature death associated with short-term ozone exposures, even when days with concentrations above 60 ppb are excluded from the analysis. 

Don’t let the TCEQ confuse the issue. Ozone smog is harmful, in particular to children and their developing lungs. We need everyone who cares about clean air to join us in North Texas, on Thursday January 29^th at the Arlington City Hall, 101 W. Abram Street, Arlington, TX 76010. It’s an all-day hearing that runs from January 29, 9 a.m. to 7 p.m.

We are organizing buses for people from San Antonio, Austin, and Oklahoma City, so please contact me at sarah.sharif@sierraclub.org, or my good friend Cherelle Blazer at cherelle.blazer@gmail.com . We’d love to hold a free seat for you on one of the buses. Food, refreshments, materials, and anything else you’ll need for the hearing will be provided. Also, we can help you with information on how to sign up to speak at the hearing and how to reserve a time slot that day to tell EPA you want clean air. If you want to sign up yourself, send an email to the EPA contact Ms. Eloise Shepherd at shepherd.eloise@epa.gov or call her at 919-541-5507.