By: Cynthia Palmer, Senior Policy Analyst, Moms Clean Air Force
Date: February 23, 2023
About: Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2015-0072
To: Environmental Protection Agency
My name is Cynthia Palmer, and I am a Senior Analyst for Petrochemicals at Moms Clean Air Force, a community of 1.5 million moms united to protect children’s health from air pollution and climate change.
I am here to urge EPA to set its particle pollution standards at 8 micrograms per cubic meter for the annual standard and 25 for the daily standard.
As a daily bicycle commuter in Virginia for the past 15 years, I’ve spent much of my life sucking in the exhaust from the cars I ride behind—and wishing for cleaner air.
As the chair of the Bicycle Advisory Committee in Arlington, I field questions from fellow commuters who are hoping to find less polluted routes that do not aggravate their asthma or heart conditions.
The elevated pollution exposures (along with the road safety risks) leave many of us questioning the wisdom of our environmentally-sound transportation choices.
For guidance, we look to the Air Quality Index to help assess our risk levels on any given day—this index is tied to EPA’s outdated 24-hour standard.
But enough about me. I am here to share my disappointment with EPA’s proposed annual and 24-hour particulate matter standards, especially as they affect overburdened communities that are already suffering unacceptable environmental harm.
Particle pollution comes largely from fossil fuel combustion, and many of the sources continue to grow, whether it’s the
- the supersized SUVs and pickups I ride among on the nation’s roadways
- the vast expansion of plastics production and incineration facilities in this country, much of it by foreign investors eager to take advantage of our lax air pollution regulations
- the 1.7 million active oil and gas wells, from the Ohio River Valley to the Permian Basin, or
- industrial agriculture, which some studies say is our biggest contributor to soot emissions—and one of the least regulated.
The invisible particles penetrate deep into the lungs, inflaming the airways, and impairing the body’s immune responses. Particle pollution stunts developing lungs and brains in kids.
Particularly troubling is EPA’s decision to leave in place the outdated 24-hour soot standard. The EPA’s own Scientific Advisory Committee found that this daily standard is not protective—and no wonder, as it was last updated in 2006.
EPA’s decision not to lower the daily standard is a slap in the face to fenceline communities from Port Arthur, Texas, to Beaver County, Pennsylvania. A robust 24-hour standard could help protect people from dangerous short-term spikes, often in the form of the flaring and venting episodes that plague these communities in the secrecy of night.
I urge EPA to set the standards at 8 micrograms per cubic meter for the annual standard and 25 for the daily standard. Thank you!