Encouraging EPA to Strengthen Air Quality Standards

Feb 24, 2023

LCV Senior Director of Government Affairs Matthew Davis and LCV Government Affairs Representative for Healthy Communities Lizzy Duncan testified before the Environmental Protection Agency on February 22nd and 23rd to encourage the EPA to further strengthen the particulate matter national ambient air quality standards. Below are their testimonies.


Testimony Encouraging EPA to Further Strengthen the Particulate Matter National Ambient Air Quality Standards

Matthew Davis, Senior Director of Government Affairs, League of Conservation Voters

February 22, 2023

Hello, my name is Matthew Davis, and I am currently Senior Director of Government Affairs for the League of Conservation Voters, or LCV, and formerly was a health scientist in the EPA’s Office of Children’s Health Protection where I worked on a previous review of this particulate matter standard. Thank you to my former colleagues on the panel and other civil servants across EPA for your public service. I appreciate the opportunity to provide comment encouraging EPA to further strengthen the National Ambient Air Quality Standards (NAAQS) for Particulate Matter, also known as soot or particle pollution. On behalf of LCV’s more than half a million members, its Latinx community organizing project, Chispa, and network of 33 state partner organizations across the country, I urge EPA Administrator Regan to protect public health with an adequate margin of safety in the final rule — decreasing the allowable level of toxic soot in the air to 8ug/m3 annually and 25ug/m3 daily. Particularly for those disproportionately exposed nearest to polluting industries and busy roadways in communities of color and low income communities, sensitive groups such as those with asthma and heart disease, and vulnerable lifestages such as babies to be, children, and older adults, it is critical that EPA tighten both the annual and daily limit to the lowest level that scientific experts and advisors have recommended. In the previous 2013 review, the EPA’s Children’s Health Protection Advisory Committee recommended that EPA set the NAAQS for particulate matter at the lowest level recommended by the Clean Air Scientific Advisory Committee, which in this case would be 8ug/m3 annually and 25ug/m3 daily.

Families around the country are depending on the EPA to help them achieve a very basic and important goal- allowing their children to grow up as healthy as possible and not be limited by disease or ill health. Especially families who live near freight corridors, oil refineries, or train yards, where concentrations of the particle pollution caused by burning fossil fuels is often at its worse, are looking to you all and to Administrator Regan to safeguard their loved ones and help them achieve their goal of clean air to breathe. As a parent, I understand that feeling, as I’m sure Administrator Regan does too – my son Jasper is the same age as his son Matthew. I’m fortunate to be able to afford living where there isn’t a lot of diesel or industrial pollution and most folks do not heat their homes primarily with old inefficient wood stoves. The good news for everyone is that cleaner air is achievable and it is associated with improved health in kids’ growing and developing lungs. Just as there is strong scientific evidence of no threshold below which there are not damaging health effects from breathing in toxic soot pollution, there is strong scientific evidence that improvements in air quality result in significant population – level improvements in lung capacity and health in school-aged children. Studies from researchers at the University of Southern California found that over the period of a decade in and around Los Angeles, reductions in particulate and other air pollution meant kids in school there had healthier, more robust lungs – improvements that will help them throughout childhood and adulthood, allowing those younger cohorts the opportunity to lead more active, healthier lives than their older siblings (Association of Improved Air Quality with Lung Development in Children. March 5, 2015; N Engl J Med 2015; 372:905-913; DOI: 10.1056/NEJMoa1414123; Association of Changes in Air Quality With Bronchitic Symptoms in Children in California, 1993-2012. JAMA. 2016;315(14):1491-1501. doi:10.1001/jama.2016.3444). The Biden-Harris administration is striving to provide people opportunity to live their full potential, and setting strong particle pollution standards down to 8 ug/m3 for the annual and 25 ug/m3 for the daily standards would do just that, protecting people year round and reducing spikes in pollution.

The 2019 Integrated Science Assessment that underpins this proposed rule found adequate evidence that children and communities of color were at elevated risk of negative health effects due to increased exposure to soot pollution. Studies have also shown that toxic soot pollution even harms babies before they are born and the mothers gestating them, leading to increased risk of preterm birth, low birth weight, and other potentially health-harming pregnancy outcomes. Here too we see big, unfair disproportionate harm to Black mothers and their babies, who also have disproportionately high exposures to particle pollution across a variety of locations, both rural and urban.

Although the feasibility and cost of implementation cannot influence EPA setting the standards, the investments in the clean energy plan passed by Congress and signed by President Biden last August will put within reach necessary reductions in particle pollution that the strongest standards would require and make the pollution-reducing solutions, like solar, wind, and electric vehicles more affordable for every community. Strengthening the standard to the lowest levels recommended by the outside scientific experts, as EPA’s Children’s Health Protection Advisory Committee has previously recommended, would help President Biden and Administrator Regan to deliver on their commitments to advance environmental justice and healthy lungs for everyone.

Testimony Encouraging EPA to Further Strengthen the Particulate Matter National Ambient Air Quality Standards

Lizzy Duncan, Government Affairs Representative for Healthy Communities, League of Conservation Voters

February 23, 2023

Hello. My name is Lizzy Duncan. I am a Government Affairs Representative for the Healthy Communities team at the League of Conservation Voters (LCV). I’m here on behalf of LCV’s members and supporters and appreciate the opportunity to share our thoughts on EPA’s proposal to regulate dangerous soot pollution.  Unfortunately, we feel that the EPA’s current proposal  fails to protect public health or prevent premature deaths–especially in communities of color and low-wealth communities, and would encourage the agency to strengthen it in the final rule. 

Soot pollution is extremely dangerous and harmful to our health and environment. It is important for the  Biden-Harris Administration to heed the recommendations of their own scientific advisory panel and to enact the strongest possible standards to limit soot pollution.

EPA’s own Regulatory Impact Analysis (RIA) analysis shows that 8 ug/m3 (micrograms per cubic meter) for the annual standard and 35 ug/m3 for the 24-hour standard would prevent 9,200 premature deaths compared to 4,200 premature deaths prevented at the proposed low end of 9 ug/m3 and retaining the daily standard of 35 ug/m3. Based on these numbers alone,  the current proposal falls far short of this Administration’s commitment to protect our health and advance environmental justice by curtailing deadly air pollution.

Although the harms of soot pollution are widespread, they are not evenly distributed. Soot poses a heightened danger to the most vulnerable people in our communities: children, the elderly, and people with chronic diseases. Additionally, because of biased policies and other historic systemic injustices, communities of color suffer higher exposure to soot pollution.

Racist practices like redlining often meant that people of color had no choice but to live near polluting industries, like power plants and warehouses with lots of traffic. Likewise, the deliberate routing of interstate highways through communities of color left the people within these communities with higher exposure to air pollution and soot. These historic injustices continue to drive racial disparities in health today with higher instances of asthma, heart attacks, COPD, and other respiratory illnesses than in other communities.  

I am from California, and have seen my friends and family members living in high pollution regions of cities like Richmond, West Oakland, Manteca and Merced suffer from lifelong heart and respiratory issues because of the air they had no choice but to breathe as children and young adults. If there is a way to mitigate life-threatening public health damage like this in communities across the country, why wouldn’t the Administration want to do everything in its power to act?

In order to fulfill their environmental justice commitments, President Biden and this EPA must finalize the strongest possible standards to limit dangerous and deadly soot pollution. Thank you for allowing me to speak today.