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Field Notes


Comments on new smog standard due March 22

 

THE ENVIRONMENTAL PROTECTION AGENCY PROPOSED NEW SMOG STANDARDS in January with the aim of bringing health benefits to millions of Americans.

The deadline to submit comments to the EPA on its proposed rule changes for ground-level ozone is March 22. Please see below for where and how to make sure your voice is heard.

The new standards would replace Bush-era rules that medical experts agree are inadequate to protect people from potentially dangerous air pollution.

The standards would be the strictest to date, and would be in line with the unanimous recommendation put forth in 2008 by the agency’s Clean Air Scientific Advisory Committee, which was composed of preeminent medical doctors, air quality experts, and public health professionals.

“EPA is stepping up to protect Americans from one of the most persistent and widespread pollutants we face,” EPA Administrator Lisa Jackson said in January. “Smog in the air we breathe poses a very serious health threat, especially to children and individuals suffering from asthma and lung disease. It dirties our air, clouds our cities, and drives up our health care costs across the country.”

Using the best science to strengthen these standards is a long overdue action, Jackson said, and will help millions of Americans “breathe easier and live healthier.”

MAKE SURE YOUR VOICE IS HEARD: HOW TO COMMENT

  • The EPA is accepting comments on the proposed regulatory revision until March 22. Thank you for letting the EPA know how you feel!
  • Subject line of emails, letters and faxes: Docket No. EPA–HQ–OAR–2005–0172
  • If you would like to read the full text of EPA’s proposed rule, it is available here: http://www.epa.gov/air/ozonepollution/fr/20100119.pdf.
  • You can send comments by email by clicking here, or copying and pasting the following email address into the “To” field in your email client: a-and-r-Docket@epa.gov
  • You can send comments by fax at this number: 202–566–9744.
  • You can send comments by regular mail to this address: Docket No. EPA–HQ–OAR–2005–0172, Environmental Protection Agency, Mail code 6102T, 1200 Pennsylvania Ave., NW., Washington, DC 20460. Please include a total of two copies.

Sample Letter:

U.S. Environmental Protection Agency
Docket No. EPA-HQ-OAR-2005-0172
Mail Code 6102T
1200 Pennsylvania Ave., NW
Washington, D.C. 20460

To whom it may concern:

I write to express support for the EPA’s proposal to make the National Ambient Air Quality Standards for ozone more stringent. This effort is long overdue and in line with the best available science, as indicated by the unanimous recommendations of the EPA’s Clean Air Scientific Advisory Committee. I urge you to set the primary standard at a level of 0.060 ppm, as recommended by many expert groups such as the American Lung Association and the American Medical Association. I also urge you to set the secondary standard within the proposed range of 7-15 ppm-hours. This range is also supported by the recommendations of the EPA’s CASAC. I urge you move toward finalization of this rule change by August 31, as required, so that the public receives these benefits promptly.

Setting the primary standard at 0.060 ppm will help ensure that all of us enjoy better health, especially vulnerable populations such as the very young, old, those with respiratory conditions, and those who work or recreate outdoors. Setting the secondary standard in the proposed range will help ensure vegetation in our wilderness areas and National Parks is adequately protected.

Thank you for moving forward with this rulemaking as expeditiously as possible.

Sincerely,

Signatory


BACKGROUND

In 2008, the Bush administration rejected the unanimous recommendations of the EPA’s expert advisory panel, and chose instead to set a weaker standard that would allow for more pollution.

Many medical professionals and public health officials protested that decision, and in 2009, in Pinedale, Wyoming, a grassroots organization called Citizens United for Responsible Energy Development—along with other local individuals—petitioned the Cowboy State to set its own smog standard that would be in line with what the scientists and medical professionals had recommended to the EPA.

That request was ultimately dropped by Wyoming’s Environmental Quality Council, but the EPA’s newly proposed standard for smog would be roughly the same level of pollution control that the Wyoming petitioners had asked for.

THE PROBLEM WITH OZONE

Smog, also known as ground-level ozone, is especially dangerous to children and the elderly, and can cause a number of serious health problems, including aggravation of asthma and increased risk of premature death in people with heart or lung disease, according to the U.S. Centers for Disease Control and Prevention, and the EPA.

BrucePullQuote-2Ozone can also harm healthy people who work and play outdoors. The damage caused to people’s lungs by ozone is thought to be immediate and irreversible.

The EPA on Thursday proposed to set the “primary” standard, which protects public health, at a level between 0.060 and 0.070 parts per million measured over eight hours. The current national primary standard is 0.075 ppm. Children are at the greatest risk from ozone because their lungs are still developing and they are most likely to be active outdoors, and they are more likely than adults to have asthma, according to the agency.

The EPA is also proposing to set a separate “secondary” standard to protect the environment, especially plants and trees. Secondary standards are set with the intention of protecting the “public welfare.” The seasonal standard the EPA is recommending is designed to protect plants and trees from damage caused by repeated ozone exposure, which can reduce tree growth, damage leaves, and increase susceptibility to disease, the agency explained in a media release.

OLD STANDARD WAS INADEQUATE

Administrator Jackson announced in September of 2009 that the Obama administration would reconsider the existing ozone standards, which the Bush administration set at 0.075 ppm. Since September, the EPA conducted a review of the science that guided the 2008 decision, including more than 1,700 scientific studies and public comments from the 2008 rulemaking process, according to the agency.

The EPA also reviewed the findings of the independent Clean Air Scientific Advisory Committee, which unanimously recommended that standards be set in the ranges ultimately proposed on Thursday by the agency.

Depending on the level of the final standard, the proposal will yield health benefits between $13 billion and $100 billion, according to the EPA.3-15-04LindaBaker-flaring-sm

“This proposal would help reduce premature deaths, aggravated asthma, bronchitis cases, hospital and emergency room visits and days when people miss work or school because of ozone-related symptoms,” the agency wrote in a January media release. “Estimated costs of implementing this proposal range from $19 billion to $90 billion.”

This rulemaking is important for Wyoming, especially western Wyoming in the Pinedale area where ozone levels in excess of even the current, weaker, national standard have been recorded in recent years.

Ozone levels have gotten so high in the Pinedale area in recent winters that they have rivaled the worst bad-ozone days in major metropolitan areas, such as Los Angeles. As a result, the state, with the support of Gov. Dave Freudenthal, has recommended that the EPA designate the Pinedale area in nonattainment with the national ambient air quality standard for ozone.

Ground-level ozone forms when emissions from industrial facilities, power plants, landfills, and motor vehicles react with sunlight.

The EPA will take public comment for 60 days after the proposed rule is published in the Federal Register.

 

 

The photo above of natural gas flaring was taken by Linda Baker in the Upper Green River Valley, a rural area in western Wyoming that has experienced big-city like ozone pollution spikes in recent years as a result of a natural gas drilling boom.

Media Contact: Bruce Pendery, program manager, Wyoming Outdoor Council, 435-752-2111, bruce@wyomingoutdoorcouncil.org.