Public Hearing on Proposal to Retain the National Ambient Air Quality Standards for Particulate Matter
May 21, 2020
Testimony from Green For All, a program of the Dream Corps
Shannon Baker-Branstetter, Senior Policy Manager
Good morning. I’m Shannon Baker-Branstetter, Senior Policy Manager at Green For All. Green For All is a program of the Dream Corps. We work at the intersection of the environmental, economic, and racial justice movements to advance solutions to poverty and pollution toward a world that is green for all, not green for some. Thank you for the opportunity to partake in this hearing.
The currents levels of domestic, anthropogenic air pollution are killing over 100,000 Americans1 each year, and disproportionately killing people of color.2 Why? Well, communities of color are exposed to higher industrial, power and transportation-related PM2.5 emissions thanks to a long history of discriminatory land use and facility siting.3 Therefore, EPA’s proposal to maintain the status quo as it relates to air quality, especially for particulate matter (PM2.5), which is one of the most dangerous air pollutants to public health,4 is unacceptable and unsupported by scientific research. There are now more premature deaths from transportation-related emissions than from vehicle crashes and homicides combined.5 We urge the EPA to issue a more stringent standard that will protect the people exposed to these harmful emissions every day, save lives, and increase economic opportunity by stimulating innovation and deployment of clean transportation and clean energy solutions.
1. Air pollution, and PM2.5 in particular, was a preexisting condition that compounded and exacerbated the current COVID-19 health crisis in communities of color.
Right now, I ask you to think about a time you were out of breath, really struggling to breathe. Maybe you went up some stairs in a rush because you were late or you were running after a child in danger. Now imagine if that feeling went on for hours or days and you didn’t know if you’d ever breathe easily again. This feeling of not being able to depend on your breathing, not knowing when or if you can have enough air is terrifying. It’s how millions of kids and adults feel when they have an asthma attack or chronic lung disease. And now, millions more have the added risk and fear of contracting COVID-19 and suffering permanent lung damage.6
For many people of color, the current COVID crisis compounds a pre-existing health crisis. The additional risks from COVID pile on the pre-existing pollution burden disproportionately borne by people of color. Nationally, PM2.5 exposure for non-Whites was 28% higher than the overall population, and African Americans specifically, had 54% higher burden, much higher than the 35% higher burden borne by people living in poverty.7 And in California, the most populous state in America and home to some of the country’s most polluted cities, African American, Latino, and Asian Californians are exposed to more PM2.5 pollution from cars, trucks, and buses than white Californians, with average exposure 43, 39, and 21 percent higher, respectively, than white Californians.8
COVID-19 infection and mortality rates tread a disturbingly familiar path of existing racial and ethnic health disparities. According to CDC data and AP News analysis, African Americans represented more than double the COVID cases and deaths than their relative population.9 And in some cities where there are data, the number of cases and mortality rates for Latinos were especially high. In New Mexico, Native Americans account for nearly 37% of the state’s cases and only 11% of the state’s population.10 As Dr. Clyde W. Yancy, a cardiologist researcher at Northwestern University states, “The pattern is irrefutable: underrepresented minorities are developing COVID-19 infection more frequently and dying disproportionately.”11
PM2.5 pollution is a contributing factor for many of the underlying conditions–lung and heart disease in particular–that make people susceptible to COVID-19,12 and yet thus far, EPA’s instincts have been to weaken clean air protections rather than strengthen them. That makes zero sense. Strengthening the current standard would help close the health disparities gap and save lives.
2. A stronger PM2.5 standard would save lives and protect the health of children, seniors, and other medically vulnerable populations, especially in communities disproportionately impacted by cumulative exposure.
In considering whether to adopt a new standard, EPA must choose a standard that provides an “adequate margin of safety” and it considers such factors as “the nature and severity of the health effects involved” and the “size of the susceptible group(s).”13
Let’s first talk about the “nature and severity of the health effects involved.” In short, the health effects of PM2.5 range from life-limiting to lethal. The National Academy of Sciences puts it bluntly, “Fine particulate matter (PM2.5) air pollution exposure is the largest environmental health risk factor in the United States.”14
As far as the second factor to be considered, the size of the groups who are at increased risk of health complications and death from PM2.5, it’s probably easier to count the people who do not face elevated risk. Infants, children, teens, seniors, people with low-incomes, people who have experienced exposure from other pollutants, and people who have cardiovascular disease or lung disease, are all more susceptible to illness and early death from PM2.5 emissions.15 Over 16 million adults have Chronic obstructive pulmonary disease (known as COPD), and 25 million adults and 5.5 million children have asthma, placing them in the susceptible group.16
Research has shown that current PM2.5 pollution continues to contribute to mortality and loss of longevity in the United States, with larger harms in poorer counties, and that further lowering PM2.5 pollution is likely to benefit the health of the entire US population and decrease health inequalities.17
The current standard does not maximize health benefits; the concentration–response relationship is linear down to PM2.5 concentrations of 8 µg/m3, well below the current standard.18 Even short-term exposures to PM2.5 at levels below current national air quality standards are significantly associated with increased risk of mortality for older adults.19
The increased risks from PM2.5 were already severe, and now the COVID-19 pandemic further elevates the risk of harm for people who had experienced exposure from other pollutants or were otherwise suffering from lung disease. A recent Harvard study showed that an increase of 1 μg/m3 (microgram per cubic meter) in PM2.5 is associated with an 8% increase in the COVID-19 death rate (95% confidence interval [CI]: 2%, 15%).20 A recent meta-analysis demonstrates “COPD is associated with a significant, over five-fold increased risk of severe COVID-19 infection.”21
Even before COVID-19 struck many of the same populations facing higher risk of illness and death from pollution, current PM2.5 levels did not offer an adequate margin of safety. Now that COVID-19 is compounding that risk, EPA must re-assess the appropriate standard to adequately protect the health of millions of Americans.
3. Strengthening the standard would incentivize clean tech innovation and boost efforts to invest in renewable energy and cleaner transportation, including low- and zero emission school buses, trucks, and electric passenger vehicles, jump starting our economic recovery and ushering in a green economy strong enough to lift people out of poverty.
The good news is that there are plenty of affordable technologies available to reduce PM2.5. By cleaning up the grid and investing in low-and zero-emission mobility, we can build a world that is better than before, where our air is safe and our communities are resilient. Electrification of transportation and increasing renewable energy’s share of the electric power grid will reduce PM2.5 emissions and put us on the path to a future that is healthier for us all.22 Reducing emissions from the power grid and transportation are especially helpful for saving lives because emissions concentrated in or near densely populated areas play an outsized role in damaging human health with 10% of total emissions accounting for 40% of total health damages.23
Electrifying transportation is already happening on a small scale, and accelerating this growth, when paired with continued progress on a cleaner electric grid, will lower PM2.5 and other harmful pollutants. This impact will be especially beneficial for the millions of low-income Americans who live by major roadways who are the most impacted by pollution and are disproportionately people of color.24 There is a huge opportunity to reduce pollution and uplift communities by converting diesel school and transit buses and heavy duty trucks to electric powertrains.25 Stronger pollution standards support a positive feedback loop that will encourage further private investment in domestic manufacturing and states and local governments to invest in the transition to electric transportation.
A stronger pollution standard that encourages more energy efficiency and renewable energy is a triple win for public health, economic growth, and quality of life. In addition to improving health, the multiple benefits from clean energy and energy efficiency include reducing energy bills for households and businesses, job creation, and improving the resiliency of the grid.26 Climate change is likely to further exacerbate the health impacts from PM2.5 and other pollutants,27 and so by reducing criteria pollutants and greenhouse gas emissions, clean energy investments provide positive co-benefits for public health.
The status quo even before the COVID-19 pandemic made far too many people of color sick and die too early. And neglecting the most vulnerable among us has exacerbated the current pandemic, which as we know, puts everyone at risk. We can only reopen a healthy economy and build prosperity for all Americans by adopting pollution standards that are strong enough to protect the health of the most vulnerable and to encourage innovation and deployment of clean energy solutions. We can and must do better than before so we can all breathe easier. Thank you.
1 See Tessum, Christopher W., Apte, Joshua S., Goodkind, Andrew L., Muller, Nicholas Z., Mullins,Kimberley A., Paolella, David A., Polasky, Stephen, Springer, Nathaniel P., Thakrar, Sumil K., Marshall, Julian D. and Hill, Jason D., Inequity in consumption of goods and services adds to racial–ethnic disparities in air pollution exposure, PNAS March 26, 2019 116 (13) 6001-6006; first published March 11, 2019 https://doi.org/10.1073/pnas.1818859116.
3 Mikati I, Benson AF, Luben TJ, Sacks JD, Richmond-Bryant J. Disparities in Distribution of Particulate Matter Emission Sources by Race and Poverty Status. Am J Public Health. 2018;108(4):480‐485. doi:10.2105/AJPH.2017.304297, at https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5844406/.
4 See e.g. Goodkind, Andrew L., Tessum, Christopher W., Coggins,Jay S., Hill, Jason D., and Marshall, Julian D., “Fine-scale damage estimates of particulate matter air pollution reveal opportunities for location-specific mitigation of emissions, PNAS April 30, 2019 116 (18) 8775-8780; first published April 8, 2019 https://doi.org/10.1073/pnas.1816102116; Silva, R., West, J., Lamarque, J. et al. Future global mortality from changes in air pollution attributable to climate change. Nature Clim Change 7, 647–651 (2017). https://doi.org/10.1038/nclimate3354.
6 Galiatsatos, Panagis, “What Coronavirus Does to the Lungs,” Johns Hopkins Medical Center, Posted April 13, 2020, at https://www.hopkinsmedicine.org/health/conditions-and-diseases/coronavirus/what-coronavirus-does-to-the-lungs.
7 Ihab Mikati, Adam F. Benson, Thomas J. Luben, Jason D. Sacks, Jennifer Richmond-Bryant, “Disparities in Distribution of Particulate Matter Emission Sources by Race and Poverty Status”, American Journal of Public Health 108, no. 4 (April 1, 2018): pp. 480-485. https://doi.org/10.2105/AJPH.2017.304297.
8 Union of Concerned Scientists, “Inequitable Exposure to Air Pollution from Vehicles in California (2019)” published Jan 28, 2019, at https://www.ucsusa.org/resources/inequitable-exposure-air-pollution-vehicles-california-2019.
9 Stafford K, Hoyer M, Morrison A. Racial toll of virus grows even starker as more data emerges. The Associated Press (AP). April 18, 2020. APnews.com. https://apnews.com/8a3430dd37e7c44290c7621f5af96d6b.
10 Yancy, Clyde W. COVID-19 and African Americans, JAMA. Published online April 15, 2020. doi:10.1001/jama.2020.6548, https://jamanetwork.com/journals/jama/fullarticle/2764789.
11 Yancy, Clyde W. COVID-19 and African Americans, JAMA. Published online April 15, 2020. doi:10.1001/jama.2020.6548, https://jamanetwork.com/journals/jama/fullarticle/2764789.
12 Brandt EB, Beck AF, Mersha TB, Air pollution, racial disparities and COVID-19 mortality, Journal of Allergy and Clinical Immunology (2020), doi: https://doi.org/10.1016/ j.jaci.2020.04.035.
13 42 U.S. Code § 7409(b)(1).
14 Tessum, Christopher W., Apte, Joshua S., Goodkind, Andrew L., Muller, Nicholas Z., Mullins,Kimberley A., Paolella, David A., Polasky, Stephen, Springer, Nathaniel P., Thakrar, Sumil K., Marshall, Julian D. and Hill, Jason D., Inequity in consumption of goods and services adds to racial–ethnic disparities in air pollution exposure, PNAS March 26, 2019 116 (13) 6001-6006; first published March 11, 2019 https://doi.org/10.1073/pnas.1818859116.
15 American Lung Association, “Particle Pollution,” at https://www.lung.org/clean-air/outdoors/what-makes-air-unhealthy/particle-pollution.
16 American Lung Association, “Particle Pollution,” at https://www.lung.org/clean-air/outdoors/what-makes-air-unhealthy/particle-pollution.
17 Bennett JE, Tamura-Wicks H, Parks RM, Burnett RT, Pope CA III, Bechle MJ, et al. (2019) Particulate matter air pollution and national and county life expectancy loss in the USA: A spatiotemporal analysis. PLoS Med 16(7): e1002856. https://doi.org/10.1371/journal.pmed.1002856.
18 Lepeule, Johanna, Laden, Francine, Dockery, Douglas and Schwartz, Joel, “Chronic Exposure to Fine Particles and Mortality: An Extended Follow-up of the Harvard Six Cities Study from 1974 to 2009,”Environmental Health Perspectives 120:7 (2012), available at: https://doi.org/10.1289/ehp.1104660.
19 Di Q, Dai L, Wang Y, Zanobetti A, Choirat C, Schwartz JD, Dominici F. “Association of Short-Term Exposure to Air Pollution with Mortality in Older Adults.” JAMA. 2017. 318: 2446-2456, available at: https://www.ncbi.nlm.nih.gov/pubmed/29279932.
20 Wu, Xiao & Nethery, Rachel C., “COVID-19 PM2.5, A national study on long-term exposure to air pollution and COVID-19 mortality in the United States,” updated April 24, 2020, available at: https://projects.iq.harvard.edu/covid-pm.
21 Lippi, Giuseppe & Henry, Brandon Michael, “Chronic obstructive pulmonary disease is associated with severe coronavirus disease 2019 (COVID-19),” Respiratory Medicine, Vol. 167, 105941, June 01, 2020,Published:March 24, 2020, available at https://doi.org/10.1016/j.rmed.2020.105941.
22 Jordan L. Schnell, Vaishali Naik, Larry W. Horowitz, Fabien Paulot, Paul Ginoux, Ming Zhao, Daniel E. Horton. Air quality impacts from the electrification of light-duty passenger vehicles in the United States. Atmospheric Environment, 2019; 208: 95 DOI: 10.1016/j.atmosenv.2019.04.003, https://www.sciencedirect.com/science/article/abs/pii/S1352231019302183?via%3Dihub.
23 Goodkind, Andrew L., Tessum, Christopher W., Coggins,Jay S., Hill, Jason D., and Marshall, Julian D., “Fine-scale damage estimates of particulate matter air pollution reveal opportunities for location-specific mitigation of emissions,” PNAS April 30, 2019 116 (18) 8775-8780; first published April 8, 2019 https://doi.org/10.1073/pnas.1816102116.
24 Welch, Dan, Center for Climate and Energy Solutions, “Electrified Transportation for All: How Electrification Can Benefit Low-Income Communities,” November 2017, https://www.c2es.org/site/assets/uploads/2017/11/electrified-transportation-for-all-11-17-1.pdf.
25 See e.g. Welch, Dan, Center for Climate and Energy Solutions, “Electrified Transportation for All: How Electrification Can Benefit Low-Income Communities,” November 2017, https://www.c2es.org/site/assets/uploads/2017/11/electrified-transportation-for-all-11-17-1.pdf; Union of Concerned Scientists, “Ready for Work, Now Is the Time for Heavy-Duty Electric Vehicles,” published Dec 11, 2019, at https://www.ucsusa.org/resources/ready-work.
26 Environmental Protection Agency, “The Multiple Benefits of Energy Efficiency and Renewable Energy,” at https://www.epa.gov/statelocalenergy/part-one-multiple-benefits-energy-efficiency-and-renewable-energy.
27 Silva, R., West, J., Lamarque, J. et al. Future global mortality from changes in air pollution attributable to climate change. Nature Clim Change 7, 647–651 (2017). https://doi.org/10.1038/nclimate3354.