I went to Texas to participate in EPA’s public hearing on the smog standard on January 29, 2015. Here is the testimony I delivered:
I am here as a public health expert to talk about the health effects of smog, and to respectfully urge you to set the smog standard at 60 parts per billion – which is more stringent than the standard you proposed in November. The scientific record demonstrates that this level would provide the strongest public health protections for Americans.
I want to tell a somewhat personal story as a way of explaining why parents need a more stringent standard.
I am the mother of three school age children, and I live in Washington, DC, an area of the country with consistently high levels of smog. Several years ago, when my children were still quite young, I developed asthma-like symptoms that bothered me in the summer. I eventually realized that breathing smog on hot, humid days likely triggered the coughing, wheezing, chest tightness, and pain that I felt. I received a prescription for an inhaler and was told that I was now considered among the “vulnerable.”
What did that mean? It meant that I should take precautions on days with high air pollution, because those days could trigger the very uncomfortable symptoms I had started to have. My lungs were sensitive. And the way to protect myself, as a vulnerable person, was to pay attention to the Air Quality Index.
And so, at the suggestion of my doctor, I started looking at the AQI in the newspaper and online. Now I make sure to avoid prolonged outdoor time on high ozone days. Because I don’t want my children’s lungs harmed by smog either, I also do the same for them, making sure that they go to the library instead of the playground when the AQI hits orange. The AQI is a tool I can use, as a parent, to try to keep my kids and myself safe.
The problem is that the AQI is a function of the NAAQS. It represents the health determination implicit in the EPA standard. If the EPA standard is too lax, the AQI doesn’t help parents.
Parents need a NAAQS standard that tells us the truth. Through the AQI, we rely on this measure to make determinations about how to care for our children, our parents, and ourselves. We use it to keep our babies safe. If the smog standard is too lax, as it currently stands, the air quality alert system can tell us that it’s safe to send our kids outside to play, even when it’s not. We deserve to know the truth about whether the air is safe to breathe.
Smog at levels below 65 parts per billion can harm some of the most vulnerable among us – potentially people like me, and my children. That’s what the independent Clean Air Scientific Advisory Panel said to your agency, based on their thorough and expert review of the science. Our national standard needs to reflect that determination. Parents have a right to know the truth.
We know that breathing smog triggers asthma attacks, interferes with lung development, increases lung infections, increases hospital visits, and is associated with premature death from cardiovascular and respiratory causes. Breathing smog gets in the way of little lungs developing properly, exacerbates the national childhood asthma epidemic, and it causes our elders pain, suffering, and even death.
The science is clear on this issue. Study after study has shown appreciable health impacts of breathing smog at levels currently common in cities like Dallas.
Right now, EPA has the opportunity to protect millions of Americans from dirty air and unnecessary illness. According to EPA’s analysis, strengthening the smog standard to 60 ppb would confer profound health benefits to Americans. At this level of protection, EPA estimates 7,900 fewer deaths, 1.8 million fewer asthma attacks in children, and 9.2 million fewer restricted activity days or lost school days, each year. The monetized benefits of this level of protection in 2025 would be upwards of $37 billion.
The Clean Air Scientific Advisory Committee recommended a standard in the range of 60 to 70 ppb. The CASAC was clear that a standard of 60 ppb would offer more public health protection than a standard of 65 or 70.
EPA should follow the science. The scientific record shows that setting the allowable level of smog at 60 ppb would provide the strongest public health protections for American families. New, stronger standards for smog pollution will help millions of Americans with asthma and other respiratory ailments, like myself, breathe easier.