A few weeks ago, I testified before the US EPA against Administrator Wheeler’s decision not to strengthen the PM2.5 annual and 24-hour standards. This decision was made despite the findings of career scientists and the recommendations of an independent 20-member panel of experts.
Moreover, this decision was made against the backdrop of a global respiratory pandemic that highlights environmental racism in this country. Black and brown communities are disproportionately affected by high rates of respiratory issues due to constant exposure to higher levels of air pollution.
Administrator Wheeler’s decision to NOT improve air quality standards was arrived at by:
- disbanding the Particulate Matter Review Panel,
- removing independent scientists from the Clean Air Scientific Advisory Committee,
- eliminating drafts of scientific documents,
- ignoring science and slews of relevant health studies, and
- hastily rushing the process, thus excluding meaningful public participation.
My full testimony can be read below.
On behalf of ELPC, I call on EPA to follow the science and set stronger National Air Quality standards for particulate matter pollution to protect public health.
Chicago is at the crossroads of most US truck and rail routes and is host to multiple intermodal facilities, where freight is transferred between diesel trains and diesel trucks.
Many of our neighborhoods have also been bisected by the interstate system and as we’ve learned from public health studies, living near a major roadway constantly exposes one to air pollution, including small particulates.
Because of this, ELPC has long-standing concerns about particulate matter (PM) sources and their contribution to respiratory health disparities like the high rates of asthma– especially among Chicago children, which in some neighborhoods affect 1 in 3 kids.
Illinois has only 12 monitors measuring PM2.5 for the entire 1635 square miles area of Cook County with over 5.1 million residents (2nd most populous in the US).
While these inform one of the regional averages of PM pollution, most of the monitors only operate 1 or 2 days per week making it seemingly impossible to accurately show what individuals are exposed to on a day to day basis in their neighborhoods.
Due to community members needs for wanting to understand more about what is in the air they breathe and have transparent data, ELPC began a community science air quality monitoring project and has partnered with neighborhood residents, community organizations, and students, to conduct air quality monitoring, collecting and mapping small particulate levels.
The AirBeam monitors we use for the program test well against Federal Reference Monitors, for a fraction of the cost, and allow one to get an immediate sense of resident’s exposure levels to PM when they are outside.
ELPC’s community’s science project is relatively new (we are entering our 4th summer of monitoring) therefore we have not thoroughly mapped all of Chicago. However, we already see that exposures to PM2.5 are not even across our city.
We see higher levels on major corridors, especially those with regular diesel truck traffic such as 47th St between intermodal facilities and others with frequent diesel bus service.
Sadly, but not surprisingly the maps of Chicago’s poverty, pollution sources, poor health, and now death rates from COVID 19 all look the same: communities on the south and west sides show higher levels of all 4. And our African American population in Chicago is suffering greatly from both increased particulate pollution and also COVID related deaths.
This health disparity and environmental justice situation I just described is not unique to Chicago only, which is why we at ELPC are appalled that the EPA, whose mission is to protect public health, has decided to take a pass on doing just that with stronger PM2.5 standards after scientific evidence has demonstrated current standard is too lenient. We are deeply disappointed that Administrator Wheeler has dismissed the recent finding by Harvard’s School of Public Health that a long-term exposure increase of only 1 microgram/m3 of PM2.5 is associated with an 8% increase in the COVID-19 death rate.
I’d also like to comment on the hearing process itself.
We understand and are sensitive to the fact that in-person hearings cannot be held due to the COVID-19 crisis. And while we appreciate the opportunity to testify today under the circumstances, teleconference hearings must not become the norm.
EPA should be utilizing available technology to ensure these hearings afford the public the opportunity to testify virtually “face-to-face” with EPA staff and the experts responsible for the rule as they would at an in-person hearing. This would also offer the public the opportunity to “see” other speakers offering testimony.
In conclusion, ELPC joins all those supporting strengthening the standards in line with the recommendations of the Independent Panel:
- A primary annual PM2.5 standard between 8 µg/m3 and 10 µg/m3
- A primary 24-hour PM2.5 standard between 25 µg/m3 and 30 µg/m3
- A primary PM10 that is tightened in line with PM2.5 standards, and
- Secondary standards tightened to address visibility concerns and other welfare effects.
These would reflect an intention to meet the purpose of the Clean Air Act’s standards: to protect public health with an adequate margin of safety.