Date: April 21, 2025
To: Lee M. Zeldin, Administrator, U.S. Environmental Protection Agency
Re: Maintain national ambient air quality standard for PM2.5
Dear Administrator Zeldin:
We, the undersigned 100 organizations, write to urge you to maintain and promptly implement a vital, lifesaving protection—the national ambient air quality standard for fine particulate matter (PM2.5 or soot) that was established in 2024. EPA has announced that it is revisiting the rule to decide what, if anything, to seek to change about the rule. The rule should remain because it is fully consistent with the Clean Air Act and the evidence. EPA followed all applicable legal requirements in promulgating it, it is exceedingly well-supported by a wealth of science, and it advances the Clean Air Act’s promise—which you have embraced—of providing clean air to every American. In your confirmation hearing, we were heartened to hear your commitment to “uphold EPA’s mission” to “protect the environment and public health.” The soot standard does exactly that—it saves lives. Weakening or delaying it will cost them.
Soot pollution kills people and causes or is linked to a wide range of other health challenges, including increases in hospitalization rates and emergency room visits, cases of asthma, heart attacks, strokes, heart disease, lung cancer, chronic obstructive pulmonary disease, Parkinson’s disease, dementia, low birth weight, preterm birth, and infant mortality. As the Supreme Court unanimously confirmed, in an opinion by Justice Scalia, the Clean Air Act clearly requires that, for air pollutants like soot, EPA must ensure that national ambient air quality standards protect public health, with an adequate margin of safety.1
EPA painstakingly abided by the law in 2024. Its staff and independent outside experts—including one working for the State of Georgia’s Environmental Protection Division—unanimously agreed the prior soot standard was too weak. After years of work and thoughtful, public consideration, EPA updated the annual standard in line with recommendations from those same internal and external experts. There is no legally viable basis for weakening it. The 2024 update will improve the lives of millions in our country by reducing the harms of deadly air pollution for communities across the country, including for thosewho already experience disproportionate pollution burdens, such as Latino, Black, and low-income populations. EPA estimates that this new, health-protective standard will save 4,500 lives annually, avoid nearly 1 million cases of asthma-related health complications, avoid 290,000 lost work days, and generate up to $46 billion in public health benefits by 2032.2 So, EPA’s 2024 action fits with the first pillar you said guides EPA’s work—“Clean Air, Land, and Water for Every American.”3
Standards like these are the core of EPA’s mission. They have resulted in cleaner air and better lives for millions of Americans. And, with careful collaboration between the federal and state governments, and leveraging American business’s ingenuity, this environmental success story is paired with economic success: since 1970, as air pollution has plummeted, economic growth has soared. You don’t have to take our word for it— it’s what your own agency finds.4
We believe in America’s promise, including its promise of clean air for all and government of the people, by the people, and for the people. The vast majority of Americans regardless of political party support a strong EPA and public health protections.5 Our nation can have the clean air the 2024 soot standard promises along with economic growth, just as we have achieved repeatedly over time. The standard rests on firm legal and scientific footing, while weakening it or delaying its implementation would be unlawful and arbitrary. Accordingly, we urge you to ensure EPA moves ahead to realize the full promise of the 2024 soot standard by maintaining and fully and timely implementing it as the Clean Air Act requires.
Sincerely,
350 New Orleans New Orleans, Louisiana
A Community Voice New Orleans, Louisiana
A Just Harvest Chicago, Illinois
Accelerate Climate Solutions Naperville, Illinois
Adirondack Council Elizabethtown, New York,
Air Alliance Houston Houston, Texas
Alaska Community Action on Toxics Anchorage, Alaska
Allegheny County Clean Air Now Pittsburgh, Pennsylvania
Alliance of Nurses for Healthy Environments Mount Rainier, Maryland
Animals Are Sentient Beings, Inc. Watertown, Massachusetts
Appalachian Voices Boone, North Carolina
Asthma and Allergy Foundation of America Arlington, Virginia
Atchafalaya Basinkeeper Plaquemine, Louisiana
Between the Waters Dayton, Ohio
Breathe Project Pittsburgh, Pennsylvania
California Communities Against Toxics Rosamond, California
California Safe Schools Los Angeles, California
Center for Biological Diversity Tucson, Arizona
Center for Environmental Health Oakland, California
Center for Healthy Environments & Communities, University of Pittsburgh School of Public Health Pittsburgh, Pennsylvania
Center for Progressive Reform Washington, District of Columbia
Central Illinois Healthy Community, Peoria, Illinois
Cherokee Concerned Citizens Pascagoula, Mississippi
Chesapeake Climate Action Network Takoma Park, Maryland
Church Women United in New York State Rochester, New York
Citizens Coal Council Washington, Pennsylvania
Clean Air Action Network of Glens Falls Glens Falls, New York
Clean Air Coalition of Greater Ravena-Coeymans New Baltimore, New York
Clean Air Council Philadelphia, Pennsylvania
Climate Action Campaign Bayside, California
Climate Justice Alliance National
Climate Reality Project Chicago Metro Chapter Chicago, Illinois
Conservation Northwest Seattle, Washington
Creation Justice Ministries Washington, District of Columbia
Defend Our Health Portland, Maine
Don't Waste Arizona Phoenix, Arizona
Earthjustice Action Washington, District of Columbia
Eco-Justice Collaborative Champaign, Illinois
EcoMadres Washington, District of Columbia
Elevate Chicago, Illinois
Environmental Defense Fund New York, New York
Environmental Justice Health Alliance for Chemical Policy Reform National Environmental Justice Law Society at Vermont Law & Graduate School South Royalton, Vermont
Environmental Law & Policy Center Chicago, Illinois
Environmental Protection Network Washington, District of Columbia
Equity in Health Advisors Network Naperville, Illinois
FreshWater Accountability Project Grand Rapids, Ohio
Friends of the Earth Washington, District of Columbia
Go Green Illinois Illinois Green America Washington, District of Columbia
Green Science Policy Institute Berkeley, California
Greenlatinos Washington, District of Columbia
Group Against Smog & Pollution Pittsburgh, Pennsylvania
Hispanic Access Foundation Washington, District of Columbia
It’s Electric! Michigan Kentucky Resources Council, Inc. Frankfort, Kentucky
League of Conservation Voters, National
Long Beach Alliance for Clean Energy Long Beach, California
Memphis Community Against Pollution Memphis, Tennessee
Metro East Green Alliance, Alton, Illinois
Midwest Sustainability Group Grayslake, Illinois
Moms Clean Air Force Washington, District of Columbia
Moms for a Nontoxic New York Albany, New York Montana Environmental Information Center Helena, Montana
Mothers & Others For Clean Air Georgia
National Parks Conservation Association Washington, District of Columbia
National Wildlife Federation Washington, District of Columbia
Natural Resources Defense Council Washington, District of Columbia
New Mexico Environmental Law Center Albuquerque New Mexico
New Virginia Majority Richmond, Virginia
North American Climate, Conservation and Environment Roosevelt, New York
Northeast Ohio Black Health Coalition Cleveland, Ohio
Ocean Conservation Research San Rafael, California
Oil and Gas Action Network Berkeley, California
Oregon Environmental Council Portland, Oregon
Partnership for Policy Integrity Amherst, Massachusetts
Physicians for Social Responsibility Pennsylvania Philadelphia, Pennsylvania
Plastic Pollution Coalition Washington, District of Columbia
Progressives for Climate Denver, Colorado
Protect All Children's Environment Chapel Hill, North Carolina
Protect PT Harrison City, Pennsylvania
Putnam Progressives Putnam County, New York
Resource Renewal Institute Fairfax, California
Respiratory Health Association Chicago, Illinois
RiSE for Environmental Justice, Kansas City, Kansas, Kansas City, Missouri
Santa Cruz Climate Action Network Santa Cruz, California
Sierra Club National
Silvix Resources Portland, Oregon
Social Eco Education Los Angeles, California
Southern Environmental Law Center Atlanta, Georgia
Terra Advocati San Antonio, Texas
The Last Beach Cleanup Laguna Beach, California
The Last Plastic Straw, Santa Cruz, California
Tri-Valley Communities Against a Radioactive Environment Livermore, California
Unitarian Universalists for a Just Economic Community National
Vermont Law & Graduate School's Environmental Law Society South Royalton, Vermont
Virginia Clinicians for Climate Action Fairfax Station, Virginia
Warehouse Workers for Justice Joliet, Illinois
West Berkeley Alliance for Clean Air and Safe Jobs Berkeley, California
West End Revitalization Association Mebane, North Carolina
CC: Aaron Szabo, nominee, Assistant Administrator for the Office of Air and Radiation; Adam Gustafson, Principal Deputy Assistant Attorney General, ENRD
Sources:
1 Whitman v. Am. Trucking Ass’ns, 531 U.S. 457, 462-71 (2001).
2 EPA, Final Rule to Strengthen the National Air Quality Health Standard for Particulate Matter: Health Sheet 1 (Feb. 7, 2024), https://www.epa.gov/system/files/documents/2024-02/pm-naaqs-overview.pdf.
3 EPA, EPA Administrator Lee Zeldin Announces EPA’s “Powering the Great American Comeback” Initiative (Feb. 4, 2025), https://www.epa.gov/newsreleases/epa-administrator-lee-zeldin-announces-epaspowering-great-american-comeback.
4 EPA, Our Nation’s Air: Air Quality Improves as America Grows, https://gispub.epa.gov/air/trendsreport/2024/documentation/AirTrends_Flyer.pdf (since 1970, emissions of pollutants subject to national ambient air quality standards have dropped 78%, while gross domestic product has increased by 321%)
5 Environmental Protection Network, 2024 Voter Priorities, https://www.environmentalprotectionnetwork.org/wp-content/uploads/2024/11/2024-Post-Election-PollEPN-Questions-Deck.pdf.