PM 2.5 contributed to 5,000 deaths in Houston alone in 2015. Photo: U.S. Air Force.

'Protective of everyone': A conversation about particle pollution with Rachel Fullmer

April 28th, 2020

PM 2.5 contributed to 5,000 deaths in Houston alone in 2015. Photo: U.S. Air Force.

In April, as the coronavirus was spreading, disproportionately impacting those who have been exposed for years to air pollution, the Environmental Protection Agency declined to strengthen a federal standard for one of the most widespread air pollutants.

Tiny airborne particles, also known as soot, fine particulate matter or PM 2.5, can lodge in the lungs and enter the bloodstream and lead to a range of cardiovascular and respiratory diseases. Many of the EPA’s own scientists don’t believe that the current standard for these particles, which allows 12 micrograms per cubic meter, is protective of public health.

Conducting a five-year review of the standard that is required by the Clean Air Act, they found that strengthening the current standard to 9 from 12 could save 10,000 American lives every year.

Pollution 101: What is particulate matter?

Exposure to this kind of pollution in the Houston region, a new analysis has found, contributed to more than 5,000 premature deaths and nearly $50 billion in economic damages in 2015 alone. Rachel Fullmer, senior attorney with Environmental Defense Fund (EDF), said, “Americans deserve better leadership from the EPA. The latest science shows clearly that we need stronger, more protective limits on particle pollution.”

Here, Fullmer explains how EPA Administrator Andrew Wheeler might have reached his conclusion and what happens next. This conversation has been edited and condensed for clarity.

Allyn West: The Associated Press reported this heartbreaking anecdote out of Houston. A grandmother wakes her granddaughter early every morning to spend an hour with a nebulizer to treat her asthma. And then she drives her to daycare, drops her off, comes home and takes a turn on the nebulizer herself. It shows the impact of air quality on people’s everyday lives. So, why would Wheeler say that the standard is protective of public health?

Rachel Fullmer: That's a great question. To back up a bit, not only does the EPA administrator need to determine that the standard protects public health, he's also required to determine that it's protective with an adequate margin of safety. So, not just most people would be protected, but people who are vulnerable because they have asthma or lung or heart disease. The standard needs to be protective of everyone.

And the latest data that EDF scientists have shown me underscores that that's not the case — more than 85,000 Americans die every year from particle pollution. EPA’s scientists told Wheeler that even among only 47 cities in one study, 52,000 Americans were dying early because of PM, even at 12.

There’s a huge disparity between what the science is showing and saying that the standard is protective.

AW: What else is the latest data and science showing you? When you look at it, what do you see? And what might Wheeler see?

RF: The health harms associated with exposure to particle pollution are well documented and serious.

I'm an attorney, not a scientist, but one of EDF's senior health scientists, Dr. Ananya Roy, told me that the evidence has only become stronger over time, as studies have focused more, and more specifically, on the impacts of particle pollution at levels even below the current standard of 12.

In a Canadian study of more than 2 million people, for just one example, nearly all were exposed to pollution below the current standard. The average was exposed to pollution at 7, and both levels were associated with premature death.

Another study of 61 million Medicare beneficiaries in the U.S. found that higher particle pollution was associated with higher mortality, even when the analysis was restricted to levels below 12. The EPA’s decision does not meaningfully grapple with these important studies, but they clearly point to the need to strengthen the standards.

Who's Protecting Us?: Stronger EPA standards are critical for our communities and families

Worse, the administration further minimized consideration of these studies by removing an important subpanel of experts that were a previous part of the process. There used to be a subpanel of experts, 26 scientists who had an expertise in particle pollution, and the EPA summarily disbanded them for the first time ever without an explanation at the very beginning of this review. The EPA’s committee even said, essentially, We don’t have the expertise to do this review without the PM subpanel.

AW: Thirteen industry groups released their lobbying position earlier this year: the standard was adequate and would maintain their “economic viability.” But Eric Schaeffer, executive director of the Environmental Integrity Project, told me that Justice Antonin Scalia had ruled many years ago that economics ought not come into play when decisions like this are made.

RF: That's exactly right. It was a unanimous Supreme Court opinion written by Justice Scalia in a landmark case called Whitman v. American Trucking Associations, Inc.

The Supreme Court looked at the Clean Air Act text and held that Congress had clearly told the EPA to set a level based on public health alone. They're not allowed to take costs or any economic considerations into account when they set the standards.

Costs and economics are considered when states and localities make choices about how to best meet these standards, though a lot of the best emissions reduction strategies are cost effective. But these questions aren't new, and they have consistently been proven wrong. Throughout the history of the Clean Air Act, we have made dramatic reductions in air pollution and experienced strong economic growth, too.

So, we should be adhering to this approach, adopting health-based standards that are firmly grounded in the latest scientific evidence and empowering states and localities to choose how to best meet those standards.

AW: It seems typical of this administration to ignore long-term improvements that would benefit our health and the economy. What can we do to express that this decision is not in our best interest?

RF: There's going to be at least a 60-day public comment period. [Editor's note: That comment period ends June, 29, 2020.] We would urge everyone to take the time to write even a brief comment in the record urging EPA to adopt more protective standards, consistent with the scientific record and the agency’s legal duty to protect our health.

There's also going to be a public hearing where people can actually sign up to speak. I think it's important that people in communities that are burdened with pollution speak during the hearing. It's not always something that happens and the discussion remains technical and abstract.

Anything people can do to break down barriers and talk about the actual impacts of pollution in their everyday life is powerful and important for administration officials to understand the consequences of these decisions.

Right now, there’s still an opportunity to persuade them that they’re wrong. There’s always a possibility that they would change their minds and realize there’s no defensible way to maintain the outdated standard.

But then the EPA will consider all the public comments and move to finalize the rule. As we've seen with the Trump administration, though, they have a clear pattern of trying to rush things through and sidestep the best science. So, it will be important to pay attention to the process and make sure all our voices are heard.

West is a senior communications specialist for the Environmental Defense Fund. You can follow him on Instagram and Twitter @allynwest.


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