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EPA: We Need Stronger Air Quality Standards for Ozone

Public Hearing on Proposal to Retain the National Ambient Air Quality Standards for Ozone

August 31, 2020
Testimony from Green For All, a program of the Dream Corps

Audio testimony from
Shannon Baker-Branstetter, Deputy Director of Policy
Audio testimony from
Stan Njuguna, National Organization

TESTIMONY: Stan Njuguna, National Organizer

Good morning and thank you for the opportunity to provide my comment on the proposed rule. My name is Stanley Njuguna and I am the national organizer for Green For All which seeks to find the solutions that will bring the benefits of a green economy to the communities hardest hit.

As I participate in this hearing as a young Black man in America, it is not lost on me that just my blackness complicates my right to breathe free. I enter this hearing as a human being born just in time for the most devastating effects of our climate crisis and environmental degradation, one of which will be a dramatic increase in yearly stagnation events. I enter this hearing as the son of a mother who puts herself at risk each day she works on the frontlines of this pandemic of respiratory illness- which has currently claimed the lives of more than 180,000 Americans.

I enter this hearing as someone who grew up in the heart of coal country in the rust belt, where asthma is already rampant, and the color of my skin coupled with the size of my parents’ paychecks makes me statistically more likely to both breathe and suffer the adverse effects of air pollution.

When I reflected upon the remarks I wished to make to this agency today, at this moment in history, when so many are being choked by wildfires–when I considered the millions of Americans all over this country who look like me and have similar stories, I found it impossible to overstate the significance of the terms on which we breathe. I find the suspension of rigorous, standard procedure in the development of this rule deeply disappointing. 

My argument today is simple, the current level of ground level ozone is a threat to public health; it is killing and impairing Americans along the lines of race; and it is in our collective best interest to tighten the standard to no more than 60 ppb. I implore this agency to heed to the science and set stronger (NAAQS) for ozone pollution, because the people you govern deserve cleaner air.

In 2014 the EPA’s own Clean Air Scientific Advisory Committee, which the Trump Administration discontinued, found that an Ozone standard of 70 ppb inflames airways and can lead to a decrease in overall lung function. In acknowledgement of the breadth of research synthesized by the body, former administrator Gina McCarthy claimed there was substantial scientific evidence supporting a tighter standard of 60 ppb.

In their 2020 state of the air report, the American Lung Association found that nearly half of the country is living in a county that has a failing grade for ozone. Furthermore The Journal of the American Medical Association concluded in 2017 that there is strong evidence of increased mortality from ozone at the current level. Last year research published by the National Academy of the Sciences found that air pollution is responsible for 100,000 deaths in the United States, annually. This is absolutely unacceptable. 

Systemic racism is a pervasive problem in this country and it makes no exceptions here, not even the air we breathe is exempt from it. Last year, a study published in the PNAS found that Black and Hispanic communities bear the burden 56% and 63% more air pollution respectively than they cause by their consumption whereas white communities breathe 17% less pollution than they produce. The American Lung Association state of the air report for 2020 found that out of the 20 million people living in counties with failing grades for both ozone and P.M 2.5, 70% are people of color. And again I would like to remind the panel that air pollution is the largest environmental health risk factor in our country. These realities translate into disparate health outcomes across the board including cardiovascular disease and premature death. What is the justification for communities of color having to breathe and live within more poison and toxicity than they are even responsible for. I ask the panel to consider, what is the right to pursuit of happiness when the air you need to even be human…is killing you. 

We must as a country seek solutions that decrease pollution, poverty, and save lives. Due to the sensitivity of human reaction to ozone and P.M 2.5, a stronger standard of even 60 ppb would provide triple benefits to public health, economic growth, and quality of life. Incentivizing the already cost competitive technologies of clean energy and electrified transportation. A healthy human being can survive a little over a month without food, three days without water, and just 3-5 minutes without oxygen. Air is our most fundamental need as living beings. Our experience of everything from happiness, justice, liberty, loss, triumph, and life itself begins (inhale) and ends (exhale) with the breath. Honor it, and please revise and strengthen the NAAQs standard. Thank you. 

TESTIMONY: Shannon Baker-Branstetter, Deputy Director of Policy

Good morning. I’m Shannon Baker-Branstetter, Deputy Director of Policy 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 participate in this hearing. 

The current levels of domestic, human-caused air pollution are killing over 100,000 Americans each year, and disproportionately killing people of color. Just three months ago, we testified against EPA’s unacceptable proposal to maintain the status quo on the standard for particulate pollution, and today we again urge the EPA to heed the science and prioritize Americans’ health and adopt a stronger standard for ozone. Green For All supports the recommendation of the American Lung Association to strengthen the standard to no higher than 60 parts per billion (ppb). A more stringent standard for ozone will protect the people exposed to this harmful pollutant, save lives, and increase economic opportunity and productivity by reducing lost work and school days due to pollution-caused illness.  

1. Air pollution, including ozone, reduces life expectancy and causes respiratory and heart conditions that limit people’s ability to work, exercise and go to school, and the burdens of air pollution disproportionately harm communities of color.

A recent study showed that neighborhoods subject to redlining by banks and the government decades ago now experience extreme heat 5 to 12 degrees hotter than other neighborhoods in the same city. This means that largely Black and Brown residents who live in these neighborhoods are at higher risk of harmful ozone pollution, which is exacerbated by heat. The ozone standard must be strong enough to protect the neighborhoods hit the hardest by climate change, extreme heat and other compounding factors like combined pollutant burdens.

2. A stronger ozone standard would save lives and protect the health of children, seniors, and other medically vulnerable populations, especially in communities impacted by cumulative exposure.

 The American Lung Association’s most recent “State of the Air” report found that of the 20 million people living in counties with failing grades for ozone and particulate matter pollution, 14 million are people of color. We don’t have to live this way and burden communities with poor health. We have solutions to decrease pollution and save lives.

3. Similar to the particulate matter standard, strengthening the ozone standard would incentivize clean tech innovation and boost efforts to invest in renewable energy and cleaner transportation, jump starting our economic recovery and ushering in a green economy strong enough to lift people out of poverty.

We can only build prosperity and a healthy economy 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.


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