EPA's Particulate Matter Proposal Makes Sense
Posted April 14, 2020
Some points and data that help frame EPA’s proposed rule on National Ambient Air Quality Standards (NAAQS) for particulate matter (PM), which would retain all six of the current standards:
- Annual concentrations of PM2.5 have dropped 39% since 2000.
- The U.S. has reduced emissions that can contribute to PM – including an 84% drop in sulfur dioxide (SO2), and a 54% decrease in nitrogen oxide (NOx) – since 2000. Fuel switching to clean natural gas in the power sector played an important role in those reductions. This progress can be helped by continued implementation of existing regulations.
- Retaining the current PM NAAQS is supported by the absence of compelling new evidence to lower the existing standards. Another NAAQS review was completed in 2015, and at that time an economic analysis indicated there could be a significant impact on the income of families and potential job losses if a lower NAAQS option was selected.
- EPA’s proposal is consistent with the recommendation of the agency’s independent Clean Air Scientific Advisory Committee, which voted 5-1 to keep the current standards.
Frank Macchiarola, API senior vice president of policy, economics and regulatory affairs, said there’s broad-based support from U.S. industry groups that EPA’s proposal – which the agency is legally mandated to do every five years – represents a “smart balance” of the needs to reduce emissions, protect public health and meet U.S. energy needs. Macchiarola:
“The U.S. has made significant progress in this area as the U.S. has reduced PM2.5 annual concentrations by 39% since 2000. This proposal is an important step toward continuing this progress. We are reviewing EPA’s proposal and intend to provide public testimony and comments to the regulatory docket.”
We’ve long argued that the existing standards were working and would continue to work as the standards were fully implemented. Proponents of more stringent standards offered studies claiming to show positive health effects, but these failed to adequately quantify errors and uncertainties.
Release of EPA’s proposal opens a 60-day comment period, with two virtual public hearings to come. Look for more analysis on this issue in coming weeks.
We expect, too, there will arguments that the NAAQS PM proposal runs counter to a recent study that asserts long-term exposure to air pollution poses a heightened COVID-19 risk, such as appears in this New York Times article. There are problems with this view.
First, members of API’s health research and public health policy groups point out the study clearly puts forward preliminary findings, is not peer reviewed and not intended to be used for policy making. Certainly, amid the COVID-19 crisis, it’s easy to see how the report’s value could be overstated.
More specifically, the exposure information as stated by the report’s authors uses assumptions – since there is no data on actual exposures to local air quality. This, paired with incomplete COVID-19 mortality data, underscores the need for caution in interpreting the report’s results – you know, to reduce the possibility of scare headlines and erroneous media reports.
More about the report’s methodology and potential flaws in this article by Dr. Charles Dinerstein, director of medicine at the American Council on Science and Health. A sample:
[The authors] concluded that a 1 µg/m3 increase in PM2.5 resulted in an excess of 15% more COVID-19 deaths. But, as described above, they never determined the actual PM2.5 exposure. Nor do they account for the duration of exposure, the second component of dose.
When people move from one area to another, they do not magically acquire the locations attributable dose. Moreover, they never separate PM2.5 from its fellow travelers, all of which are associated with adverse health. A more pertinent finding would be the adverse effect of PM2.5 relative to more readily identifiable health risks, like cardio-respiratory diseases or population density.
As always, the key is separating fact from narratives that are spun to advance certain points of view. As the nation battles COVID-19, solid research is at a premium. The political debates should come later.
About The Author
Mark Green joined API after a career in newspaper journalism, including 16 years as national editorial writer for The Oklahoman in the paper’s Washington bureau. Previously, Mark was a reporter, copy editor and sports editor at an assortment of newspapers. He earned his journalism degree from the University of Oklahoma and master’s in journalism and public affairs from American University. He and his wife Pamela have two grown children and six grandchildren.