By: Laurie Anderson, Colorado field organizer, Moms Clean Air Force
Date: August 31, 2020
About: Environmental Protection Agency Review of NAAQS for Ozone Docket ID No. EPA-HQOAR-2018-0279
To: Environmental Protection Agency
Thank you for the opportunity to testify today. My name is Laurie Anderson. I am a Council Member in the City and County of Broomfield, speaking on my own behalf. The community that I represent is located just east of the Front Range in Colorado, where air quality is an issue as we struggle with background ozone, as well as ozone and pollution from heavy industrial operations, which are intensified by air-inversions along our mountain range. I urge you to strengthen EPA ozone standards to protect families whose health is put at risk from breathing harmful ground-level ozone pollution.
I am also a Colorado field organizer for Moms Clean Air Force, and the mom of four school-age children and one young adult who just began college.
The EPA is required to review and update the NAAQS standards every five years, taking into account the latest available science. A robust body of scientific research has shown that ozone pollution causes health problems even in communities that are meeting the current standards. This clearly indicates that the current standards are too weak and not adequately protecting us from serious health harms. Based upon this data, the ozone standards should be lowered to a safe level with oversight to ensure communities across the country are taking the necessary steps to reduce harmful emissions to subsequently decrease ground-level ozone. However, Administrator Wheeler announced a proposal to just “retain the current standards,” which is a clear denial of science.
If individuals living in communities that are meeting the current 70 ppb ozone standard are experiencing negative health impacts, what about families like mine who are living in communities that have been designated by the EPA as seriously out of attainment for ozone? Colorado communities along Colorado’s Front Range hit multiple highs above 90 ppb for ozone last week and the Broomfield AQM station known as “Soaring Eagle” recorded a high of 99 ppb on August 23, which is dangerously high!
Colorado’s high ground-level ozone is a multi-pronged problem resulting from ozone generated in Colorado, interstate drift, and air-inversions, which exacerbate the problem. Colorado has over 50,000 active oil and gas wells, which produce high levels of ozone precursors, a high metro commuting population, which increases tail pipe emissions, and bright sunshiny days for which Colorado is well-known—all of which lend part to become the perfect recipe for ozone pollution. The above conditions are already problematic, yet we must also contend with high levels of background ozone, which are outside our state’s control, that elevate our overall ozone through “interstate drift.” Additionally, wind patterns push the Front Range pollution into the mountains and, after the sun goes down, a reverse in the airflow brings the pollution back to the Front Range. This can intensify the already high levels of ozone.
Thankfully, Colorado is already working hard to meet the 70 ppb standard in the Denver Metro North Front Range Ozone nonattainment zone with progress already underway to substantially reduce emissions from the largest sources of pollutants, such as oil and gas operations. According to the Regional Air Quality Council data, oil and gas operations account for 44% of VOCs and 28% of NOx, while vehicle emissions account for 15% of VOCs. This alone will not be enough though since we also need federal action on ozone to address background ozone.
Last week, my community was issued a “multiple pollutants” alert so we are facing high particulate matter in addition to high ozone, which is a result of the additional pollutants from the ongoing wildfires. Our state authorities advised staying indoors because of the effects on respiratory and cardiovascular systems of all populations—not just those most at high risk. This recommendation included setting up “safe rooms” with increased air filtration where family members should spend the majority of their time.
This exposure to a combination of air pollutants, intensified by strong air inversions, is absolutely of great concern to me—especially for my children—and should also be of great concern to all of you. The choices that the EPA makes now will inform important decisions and help determine the level of pollutants that our families breathe in the future.
Ozone pollution is harmful to breathe and increases asthma attacks, respiratory infections, can cause stunted lung development, and result in coughing, shortness of breath, and wheezing. This pollution can even cause premature death and exacerbate underlying respiratory conditions, increase hospital admissions for asthma, and result in lower birth weight and decreased lung function in newborns. We are at a crossroads where we are struggling to contain a lethal respiratory disease, while we continue to battle ozone pollution resulting from our industrial operations.
Although I spend much of my time with residents in Broomfield who have been adversely impacted by oil and gas development, and I consider these residents to be highly motivated toward bringing necessary change to reduce the harmful pollution from oil and gas operations, many were unaware that the EPA is reviewing ozone standards. Many are frustrated that the proposal is to just maintain the current ozone standard, rather than lower it to a level that data indicates is more protective of public health. Please know that for every one of us testifying today, that there are hundreds more residents who have similar concerns—they just weren’t informed in time. This remarkably short comment period is unfortunate considering the decisions being made have high consequences, and the content is highly technical.
I urge you to consider the science on ground-level ozone and strengthen the national standards for this dangerous pollutant in order to protect public health.
Thank you for the opportunity to testify.