Given the deadly risks of soot, especially to communities assaulted by polluting industries and vehicle exhaust from highways and heavy trucking, there’s nothing fine about the Environmental Protection Agency’s (EPA’s) recent proposal to clamp down on fine-particulate pollution.
You don’t have to be a scientist to understand why.
The soot particles in question are known as PM 2.5 for particulate matter that is 2.5 micrometers or smaller. This fine particulate often comprises a toxic brew of carbon, sulfur dioxide and nitrogen oxide created by several sources, including combustion in fossil fuel power plants, factories, and from car and truck emissions.
It is both fascinating and maddening to consider that a single particle of this soot is so tiny that 30 of them could fit inside the diameter of a single human hair. As New York’s State Department of Health noted, “several thousand of them could fit on the period at the end of this sentence.”
That microscopic size allows these particles to travel deeper into lungs and allows them to build up as time bombs in our lungs and blood streams. And the ambient air is filled with these particles. An international team of researchers said in Nature Communications last year that PM 2.5 is the “world’s leading environmental risk factor.”
Globally, fine particulate pollution kills at least 4.2 million people a year, according to the World Health Organization, and perhaps as many as 5.7 million a year, according to a study last year led by Canadian researchers. According to the Energy Policy Institute at the University of Chicago, PM 2.5 results in 2.2 years of life lost on average, more than from cigarette smoking, alcohol and drug use, or polluted water.
And the Lancet Commission on pollution and health last year warned that rising global deaths from ambient air pollution are offsetting public health progress made in lowering mortality from household air pollution and unsanitary water. “Since 2017, there has been strikingly little effort in most countries to act on these recommendations or to prioritize action against pollution,” the commission said.
That includes the United States. PM 2.5 prematurely kills between 100,000 and 200,000 people a year, according to several studies involving researchers from the University of Minnesota, the University of New Mexico, the University of Washington, the University of California Berkeley, the University of Illinois, the University of Texas, Carnegie Mellon, Stanford, and Brigham Young. Even the lower end of these estimates is equivalent to more than the deaths from guns and car crashes combined.
Chronic White House waffling on science
The US federal government has never sufficiently grappled with the gravity of this situation, largely because it has never fully embraced the counsel of its own scientists.
During the George W. Bush administration, the EPA’s Clean Air Scientific Advisory Committee (CASAC) recommended that polluters should emit no more PM 2.5 in their operations on an annual basis than 13 or 14 micrograms per cubic meter, “to provide increased public health protection.” Bush, beholden to industry, kept the standard at 15 micrograms, which had been established by the Clinton administration. In a highly unusual move, the CASAC even explicitly said it “did not endorse” keeping the standard at 15 micrograms.
The Obama administration lowered the standard to 12 micrograms per cubic meter, but only after being sued for dragging its feet by the American Lung Association, the National Parks Conservation Association and 11 states that Obama won both times, including California and New York. Even then, many public health experts said the federal standard was still insufficient.
The American Lung Association, in a joint report with the Clean Air Task Force and Earthjustice, said that the 12 microgram per cubic meter level might save 12,000 lives a year. But they also said tightening by just one more microgram to 11 micrograms would have avoided 35,700 premature deaths a year. It would have also avoided an annual 1.4 million cases of aggravated asthma, 2,350 heart attacks, and 2.7 million days of missed work or school.
The EPA of the Trump administration, run by coal and chemical industry hacks, clung to the 12- micrometer standard even though it admitted in its own analysis that such air quality would result in between 16,000 and 17,000 annual heart disease deaths from the narrowing of arteries. The Trump EPA also ignored a major study of people on Medicare that found that just a one microgram tightening of standards would save 12,000 lives. At that time, the government’s own scientists said a standard of 9 micrograms could save anywhere from 9,050 to 34,600 lives a year.
The Biden administration came into office promising to restore science to its proper place in guiding environmental health policy and elevating environmental justice as a priority. Many studies show that communities of color and low-income neighborhoods disproportionately breathe in PM 2.5 pollution and thus suffer more than their fair share of sickness and death. The Medicare study, conducted by researchers at the Harvard School of Public Health, found that the risk of death to Black people from PM 2.5 is triple that of the general population. Indigenous, Latinx, and Asian American people also face elevated risks.
In a partial recognition of this, the Biden EPA announced early in January that it plans to lower the PM 2.5 standard down to between 9 and 10 micrograms per cubic meter. The agency said that would avoid up to 4,200 premature deaths a year. EPA Administrator Michael Regan said the proposal “is grounded in the best available science.”
While tightening the standard is surely welcome, the problem is that, in the decade since the Obama EPA set the standard at 12 micrograms, air pollution research continues to outstrip policy. The latest research points to the need for even lower limits and the ultimate elimination of such emissions. A University of Wisconsin study last year estimated that if this nation eliminated the emissions of fine particulates, sulfur dioxide and nitrogen dioxide from the power sector, transportation, industry, and buildings, that would avoid 53,200 premature deaths a year and $608 billion in savings from illness and death.
That study directly connected the elimination of particulates to the fight against climate change. Given that “many of the same activities and processes that emit planet-warming greenhouse gases also release health-harming air pollutant emissions. . .Transitioning energy production away from fossil fuels and toward cleaner sources can produce health benefits from improved air quality in the near term while also providing climate benefits in the longer term.”
The 53,200 avoided deaths would more than fill Yankee Stadium. “These results offer a clear rationale for mitigating climate change on public health grounds,” the Wisconsin researchers said.
The Biden EPA has put out its proposal for public comment until March 28 and has set a public hearing for February 21 and 22. While signaling its intention for a standard of between 9 and 10 micrograms, the agency said it would hear arguments for as high as 11 micrograms and as low as 8.
Who will the EPA listen to?
In the current debate, it’s no surprise who is arguing to keep the standard at 12 micrograms. Invoking the worn-out rhetoric of job-killing regulations, US Chamber of Commerce executive Chad Whiteman said tighter standards would “stifle manufacturing and industrial investment.” Never mind that the corporate profits from unregulated industry surely comes at the cost of chronically ill workers and consumers who head to hospitals instead of shopping malls.
Conversely, many public health experts, overburdened community members, and environmental groups are making a case for 8 micrograms that should be impossible to ignore. A report published by the Environmental Defense Fund agrees with the Biden EPA that a standard of 10 micrograms might avoid 4,800 premature deaths. But it notes that a standard of 8 micrograms could save 19,600 lives–four times more.
Once again, the EPA’s Clean Air Scientific Advisory Committee has sent strong signals in favor of tighter standards. Most of the expert committee said an annual range of 8-to-10 micrograms would be “appropriate” to achieve “meaningful risk reductions,” given the “strengthened” science of “adverse health effects” at current levels. It is also strongly suggesting to the Biden administration that the EPA tighten regulations on daily emissions, as annual standards may not adequately account for the kind of concentrated bursts of pollution that smother fenceline communities living next to industrial facilities. Such communities that are disproportionately of color or low-income.
Perhaps to avoid getting industry too riled up about monitoring emissions around the clock, Regan proposes to leave the daily limits in place, although the EPA will take comments on tightening it. Despite Regan claiming that the EPA’s proposal will protect “the most vulnerable among us,” his own advisory committee said, “It is important to note that risk disparities across racial and ethnic groups remain substantial with the focus on an annual standard.” Environmental justice advocates are strongly displeased with the status quo on daily emissions. Beverly Wright of the Deep South Center for Environmental Justice flatly said the EPA’s proposal, as it stands, “does not address this racially disproportionate pollution burden.”
That means the burden once more is on the EPA to catch up to the anger in fenceline communities and to the analysis of its own expert advisors. Tens of thousands of lives have been lost over the years because regulations for PM 2.5 were one, two, three or four micrograms per cubic meters higher than they should be. The Biden administration has the chance to save lives with limits set exactly where the science says they should be.