Before the

Environmental Protection Agency

Washington, D.C. 20460

Comments of Citizens for a Sound Economy Foundation

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(Related Electricity Daily Article)

(Contents:)

(Science on Particulate Matter)

(Uncertainties in the Science)

(Indoor versus Outdoor air)

(Humidity and Mortality)

(Threshold versus Linear Response)

(Where's the Data?)

(Will PM2.5 Kill Consumers?)

(PM 2.5 Regulation could do Positive Harm to the Health of Americans)

(Why PM2.5 will be More Expensive than EPA says)

(Impact of the New Standards: Real Cost Imposed on Real People)

(A Closer Look at the Sources of PM2.5)

(Potential Changes to Lifestyle)

(Conclusions)

Citizens for a Sound Economy (CSE) Foundation hereby submits these comments in opposition to the U.S. Environmental Protection Agency's (EPA) proposed revisions to the National Ambient Air Quality Standards (NAAQS) for ozone and particulate matter. CSE Foundation is a nonprofit research and educational organization with 250,000 members and supporters in every state in the country.

The new standards would change allowable ozone concentrations from the current standard of 0.12 parts per million (ppm) over a one-hour average, to 0.08 ppm over an eight-hour average. They also would add a new standard for particulate matter as small as 2.5 microns or less (PM2.5), while maintaining the existing standard for particulate matter 10 microns or less in size.

Given the lack of scientific evidence to support the new measures—as confirmed by the EPA's own science panel, the Clean Air Science Advisory Committee (CASAC), more time should be given to learning about the specific sources of health problems. The quality of the air we breathe is a serious issue and deserves policy decisions that are based on solid scientific consensus, rather than on mere political judgment.

If we knew the proposed standards would produce the benefits EPA Administrator Carol Browner claims, the requirements might be justified. But there is no indication they will even come close to achieving the stated goal. Even assuming the new standards were achievable, there is little scientific evidence to support the EPA's claims that thousands of premature deaths and hospital admissions a year are caused by ground-level ozone and PM2.5.

The Science on Particulate Matter

EPA's scientific research to justify the new PM 2.5 standard reveals deep cracks in the scientific method, which remain hidden to the American consumer. Both studies used by the EPA to justify the new standard failed to accurately evaluate the exposure levels to fine particulate matter as well as other confounding factors. These studies failed to use real life estimates of PM exposure by failing to account for three important health factors: (1) The precise exposure to outdoor air of the individuals studied; (2) The exact level of outdoor vs. indoor air exposure; and (3) Air conditioning's influence on particulate exposure and the overall health of individuals during high heat and pollution days. Without understanding these factors influence on mortality, the basic facts about particulate exposure remain unknown. Further research into these areas would determine if there is a true health effect from fine PM exposure exists. EPA, in its budget request for 1998, acknowledged that more research was needed stating: "The budget proposes $26.4 million for PM research....To reduce the great uncertainty about PM's health effects, EPA will continue its efforts to identify the mechanisms by which particles affect human health."

EPA has also failed in its cost-benefit analysis, which does not factor in the potential short-term costs of increased energy prices. In some cases, such as air conditioning (electricity) costs, PM regulation could significantly increase the physical stress from heat and humidity even cause death. According to the Center for Disease Control, over five thousand people succumbed to the deadly consequences from heat-related stress from 1979 to 1992. Although the high ownership of air conditioning in the United States has helped this problem, the increasingly high cost of electricity has certainly caused harm, especially for the elderly and the poor. Chicago's heat wave in 1995 was a recent reminder of how grizzly the summer heat can be and the potentially high costs to human life from discouraging the use of air conditioning. EPA and medical journal studies point to the lack of, and the expense of, air conditioning as a factor in many heat-related deaths, while few studies mention pollution as a serious factor. As everyday experience suggests, the stress of hot humid days can take its toll, especially on the weak and the poor.

Before EPA moves forward, it must reconsider its past research on the topic of heat related mortality. EPA must make the data from the two most recent PM 2.5 epidemiological studies available to the public. EPA should look more carefully at the science of fine particulate matter, and then do a more accurate analysis of the potential health risks of higher energy costs. EPA's PM 2.5 RIA states that the cost of monitoring, which would reveal much about the real life exposure of humans to PM 2.5, would cost only $22 million. Particulate matter levels have already fallen by 78 percent according to the Council on Environmental Quality, and particulate matter levels are expected to continue this trend well into the next century. Since the air is already getting cleaner under the current standards, EPA should slow down and do the necessary research to ensure that a new PM standard will not do positive harm to consumers. The $22 million price tag of precautionary research would be dwarfed by the potential suffering and loss of life from the higher energy costs from PM 2.5 regulation. Hastily pushing forward with this regulation may put many people, especially the elderly and poor, at increased risk of mortality.

Uncertainties in the Science of PM 2.5:

What The Six Cities and ACS Study Do Not Tell Us. Many possible confounding variables were unaccounted for in the Six Cities study and the American Cancer Society study. These factors include the smoking history of the individuals, physical fitness, exact exposure levels to pollutants, the amount of humidity in the air, and allergen levels. Making matters more difficult, EPA has not made the data from these studies widely available, which limits attempts to reanalyze the data to determine whether or not confounding factors were responsible for the small risk attributed to fine particulate matter. Further, there is evidence that reanalyzing the data in these studies will bear fruit. In a recent study of the data of a PM 10 study of Birmingham, Alabama, researchers found that coarse particulate matter posed no significant health risk after humidity was factored into the analysis. If other meteorological factors are confounding the low risk factor in the two studies, EPA must allow the appropriate reanalysis of its data to determine the accuracy of the two studies in question.

The Six Cities study by Joel Schwartz and Douglas Dockery, commissioned by EPA and the American Cancer Society (ACS) Study by C. Arden Pope et. al are the only evidence the EPA has to support the new air quality standard. Neither of these studies suggests a high risk factor associated with fine particulate matter exposure. In both cases, the increase in relative risk hovers in the 1.05-1.26 range. Relative risks this low would amount to a risk nearly ten times lower than the risk associated with smoking. More importantly though, the studies failed to account for some potential confounding factors, which raises serious questions about the correlation between fine particulates and mortality and morbidity.

Both studies have little proof of what the actual exposure to PM was to the individuals studied. The Six Cities and ACS study are both ecologic studies. The accuracy of ecologic studies is limited by the fact that the sample population's exposure to PM is estimated and not exactly known. We have no idea whether the people who died prematurely had any significant exposure to particulate matter.

Another problem with the Six Cities study is that we do not know the exact medical history of the individuals studied. It has been suggested that the people who died prematurely may have had serious, chronic respiratory disease that predated exposure to particulate matter. The data in this study must be reanalyzed carefully so that other confounding health factors can be taken into account. Unfortunately, without the release of the data in the two studies by EPA, shedding light on the actual exposure levels and the health history of those studied will be difficult.

Indoor vs Outdoor Air.

Both the Six Cities study and the ACS study may have overestimated the average individual's exposure to polluted outdoor air by assuming that we spend most of our time outside. In addition to the problems of using the ecologic method, if Americans are spending most of their time indoors, it would be useful to have more research on the effects of indoor air pollution, which has been suggested to have a much more significant impact on health. EPA itself confirms the problems with indoor air pollution in its guide to indoor air quality; "a growing body of scientific evidence has indicated that the air within homes and other buildings can be more seriously polluted than the outdoor air in even the largest and most industrialized cities. Other research indicates that people spend approximately 90 percent of their time indoors. Thus, for many people, the risks to health may be greater due to exposure to air pollution indoors than outdoors." Assuming that individuals tend to spend most of their time outside would overestimate the risk fine particulate matter. Further study into the issue of outdoor vs. indoor air exposure is necessary before adopting a new standard.

In addition, research indicates that air conditioning removes fine particulate matter from indoor air. Several studies, including those by scientists working with the EPA, mention this cleansing effect of air conditioning devices. In "Is Daily Mortality Associated Specifically with Fine Particles?" Schwartz and Dockery determined that fine particulate levels were considerably lower in houses with air conditioning. Another study, which included CASAC member Petros Koutrakis, found that air conditioning significantly and consistently lowered the amount of acid aerosols in homes. Dockery and Spengler made similar conclusions about the beneficial impact of air conditioning on respiratory health, claiming that full air conditioning of a building could reduce the infiltration of outdoor fine particulates by about one half. All of these studies concluded that air conditioning reduced pollution indoors. Since many households have air conditioning, more research is necessary to determine how air conditioning affects respiratory health and how much PM 2.5 exposure will be increased by increased electricity costs from the new standard.

Is Humidity Confounding PM Mortality Risks?

The biggest problem with both the Six Cities study and the ACS study is that neither study accounts for humidity as a possible confounder. Unfortunately, we do not understand the role of humidity in the two PM 2.5 studies used by EPA, because the researchers did not include this important meteorological factor in their analyses. There is one particular study of PM 10 that may give us clues as to the relationship of humidity and particulate exposure to human mortality. This study, "Airborne Particulate Matter and Daily Mortality in Birmingham, Alabama," reanalyzed data from an earlier study by Joel Schwartz, which showed a significant relative risk from exposure to coarse particulate matter, PM 10. This re-evaluation implemented a more complete multivariate analysis, adding more meteorological variables. Humidity, among others, was added to the list of possible factors responsible for the mortality figures in Schwartz's earlier study. Interestingly, this study found that the relative risk from coarse particulate matter was statistically insignificant when humidity was included as a factor. And even when humidity was left out of the model, as in Schwartz's original Birmingham study, the researcher found that the relative risk was "barely" significant. The study states:

"....when humidity is included among the meteorological variables (it is excluded in the analysis by Schwartz), we find that the PM10 effect is not statistically significant....When all the model uncertainties are taken into account, our overall conclusion is that we do not find any consistent effect due to PM10." The study concluded, "We have outlined a number of different approaches to this selection, but they all have in common the inclusion of a humidity (and/or lagged humidity) term, which is absent in Schwartz models. As a result we do not find a significant PM10 component in any model, except in the case when (to imitate Scwartz) we omit the humidity component. Even in this case the effect is only barely significant when applied to elderly mortality, which is the variable which has been most widely studied in analyses of the PM 10 effect."

Humidity was never considered in any of the PM 2.5 studies. Given that coarse as well as fine particulate matter is suspended by humidity, it would be prudent for the EPA to consider further research into this area before establishing new standards. It seems possible that the risk from fine particulate matter is confounded by meteorological factors such as humidity, or, other particles suspended in humid weather. If this is the case, further research should be done to determine if humidity has confounded the particulate matter exposure mortality and morbidity rates found in the two studies.

PM 2.5 Threshold and Linear Response.

EPA has suggested that there is a linear response to fine particulate matter exposure, using the previous two studies as proof that higher exposures to PM will produce directly proportional increases in mortality. In other words, a 1000 microgram increase in particulate exposure would produce a 100 percent mortality rate. Common sense tells us this is probably not the case, but the two studies considered by EPA suggest a perfectly linear response from PM exposure. There is also no data showing a threshold level of exposure, indicating the exact level of exposure at which PM becomes dangerous. EPA is saying, in essence, that we can expect some mortality from very low PM exposure levels--even exposure levels approaching background levels that Americans experience every day.

There are a few simple possibilities for further research into the threshold and linear response questions about fine particulate matter. Recent events have subjected Americans to very high concentrations of PM, levels so high that the EPA's estimates would predict 100 percent mortality. These two events are the Kuwait oil fires after the Gulf war, and the Mt. Saint Helen's volcano eruption. Both events produced massive exposures to fine and coarse particulate matter, but have not produced the death tolls predicted by the EPA's two studies. Clearly, research into these events could shed light on the effects of particulate matter in the lungs.

Where's the Data?

Although the ecologic method was used to estimate exposure to PM, further investigation of the data in the two studies could help determine the actual exposure levels and potential confounding variables. The data from the Six Cities study, if released, could shed more light on what the exact exposures to PM were and also what other health factors, such as smoking and respiratory disease, were affecting the individuals in the study. Unfortunately, the authors of the study as well as the EPA have been reluctant to release this data. Until this data is reanalyzed in the fashion of the Birmingham study, it will be unclear whether the data is reliable in forecasting mortality from PM.

PM 2.5 Regulation Could Do Positive Harm to the Health of Americans.

There is serious question as to whether the regulatory costs from the proposed PM 2.5 regulation could do positive harm to consumers. Regulatory controls on fugitive dust sources such as crop dust, residential wood burning, and unpaved roads will be difficult to control. Thus, it is likely that controls on fossil fuel combustion also will be implemented. Higher energy prices from controls on petroleum and fossil fuels could have significant effects on consumers, especially those with low incomes. In some circumstances, these regulatory costs will cause lost consumption, in others, poorer quality of life. In some cases, such as the summer heat wave of 1995, higher air conditioning costs may have even caused loss of life. In addition to adding to heat-related stress, increased costs of air conditioning will likely lower the quality of indoor air in many homes, which, as the EPA says, is a significant problem, especially if Americans are spending nearly 90 percent of their time inside. Because air conditioning acts as the only filter of air in many homes, reducing the use of these devices through higher energy costs will almost certainly decrease air quality.

Why PM 2.5 Will be More Expensive Than EPA Says.

The 15 micrograms per cubic meter yearly average is very close to background PM 2.5 levels, and would require major controls on all mobile and stationary sources, since other major sources such as unpaved roads and residential wood burning are more difficult to control. Controls on petroleum combustion and electricity generation have already reached the point of diminishing marginal returns. Since the low hanging regulatory fruit have already been picked, it is likely that new PM controls will be much more costly and produce much smaller reductions in emissions than previous efforts.

EPA has showed uncertainty about the costs of this standard in statements about trading particulate pollution permits. In section 3.3 of the PM 2.5 RIA, EPA states that no assessment of the impacts of a trading program has been done and places the burden of this analysis on the states. But without this analysis, it will be difficult for states to consider permit trading for their State Implementation Programs. EPA itself illustrated this point at a panel discussion organized by the National Environmental Policy Institute, "Right now we lack some of the scientific underpinnings and some of the basic technical tools to really enable us to assess the environmental and health impact of tradeoffs across pollutants within a media...." This ignorance of the basic scientific underpinnings of particulate matter is further evidence that the agency needs to do more scientific research. Understanding the cost of a particulate matter trading program, the most sensible method of regulation for particulate matter, is crucial, so that the most accurate, lowest estimate of the standard's cost can be determined. EPA's analysis must consider such a trading program, especially given the possible costs to human health from higher energy prices.

Despite the lack of data on costs, EPA's analysis still shows the costs of the new standard would be significant, raising the prices of all goods and services as the cost of energy production is raised by PM controls. The EPA's own RIA estimated that the cost per household for the new PM controls would reach $69 per household. Unfortunately, in the absence of PM 2.5 monitors, we have no idea what levels of PM 2.5 really exist, which means this estimated cost could be seriously understated. In fact, some studies, equally problematic, have estimated that the actual cost of PM controls could reach into the billions for a single city, putting the EPA's $69 per household cost figure many times to low. It is within the realm of possibility that the PM rule could cost households hundreds of dollars in increased gasoline, electricity, and other costs. If this is true, this new regulation will force low-income consumers to make very difficult choices, especially when deciding how much electricity and gasoline to buy.

Will PM 2.5 Kill Consumers?

Increased costs of petroleum products will certainly have huge economic impacts on consumers, but nowhere will the impact of a PM 2.5 regulation be more evident than with increased electricity costs. Tighter air quality standards will force consumers to make tough choices in the amount of heating and cooling expenses they incur. There is much evidence showing that extreme temperatures can exert enormous stress on humans. Alleviating the summer heat and humidity can prove to be expensive, and in many cases consumers will choose to bear the physical, rather than the financial burdens of hot weather. Studies have shown that heat-related stress is responsible for increasing mortality in sick people whom otherwise might have survived. In situations of extreme heat and humidity, economic choices can prove to be a matter of life or death. Numerous studies by the government of past heat waves have shown that the lack of adequate air conditioning in residences during summer heat waves can increase mortality. Since nearly 70 percent of American households had air conditioning according to the 1990 census, raising the cost of operating these units will certainly have an effect on the quality of many American lives through increased stress due to heat and humidity, and, potentially, even loss of life. The New England Journal of Medicine suggests that air conditioning was responsible for saving many lives in the heat wave of 1995 in Chicago. This study looked at the causes of at least 700 excess deaths, determining who was at greatest risk for heat-related death. People most at risk were people with medical illnesses, those socially isolated, and those who did not have access to air conditioning. In fact, the study found that the risk of death was reduced for people with working air conditioners by 80 percent as well as reducing the mortality due to cardiovascular disease by 66 percent. In closing, the study stated: "Access to air-conditioned environments is the factor with the greatest protective effect with respect to heat-related mortality. We found that people who lived in apartments without air conditioning had a lower risk if they had access to an air-conditioned lobby."

One EPA and National Oceanic and Atmospheric Administration (NOAA) study of deaths in a New York City heat wave in 1966 claimed the death rate more than doubled a day after the maximum temperature of 103 degrees was reached. According to this same study, in one three-day period, for example, the cancer death toll rose from 43 to 98 per day while heart failures jumped from 88 to 230 a day. Carl A. Posey, a spokesperson for NOAA, maintained that high energy costs were killing people: "the cost of cool air moves steadily higher, adding what appears to be a cruel economic side to heat wave fatalities...Preliminary indications from the 1978 Texas heat wave suggest that some elderly people on fixed incomes, many of them in buildings that cannot be ventilated without air conditioning, found the cost too high, turned off their units, and ultimately succumbed to the stress of heat syndrome....When a human's heat limits are exceeded, he does not doze reptile-fashion, he dies."

Apparently, the EPA has done significant research on the topic of air conditioning's life saving capability. Another EPA study showed air conditioning saved lives during a heat wave. According to the Chicago Tribune, "Researchers for the U.S. Environmental Protection Agency estimated that in New York more than 3,500 deaths were avoided between 1964 and 1988 because of air conditioning. That number is equal to 21 percent of all heat-related deaths in that period."

Other federal agencies have shown concern about the dangers of heat waves and the lack of air conditioning. In 1982, the Federal Centers for Disease Control and Prevention published a study of the deaths associated with the July 1980 heat wave in Kansas City and St. Louis, Missouri. Not surprisingly, lack of air conditioning was the most critical factor in the fatalities; those without it had a 50 percent greater risk of dying.

These studies are also supported by the many reports in the press about the benefits of air-conditioning. According to one article by The New York Times news service, the inability to afford air conditioning was a factor in the many of deaths in 1995 in Chicago: "the one factor common to heat victims was a lack of air conditioning....and others point out that while there were hundreds of deaths in Chicago in the hot spell, only 80 people died of heat in the same period in more affluent Cook County suburbs..."Folks in the suburbs, with a lot of air conditioners, didn't have the same kind or amount of problems we had in the city."

Mayor Daley must have believed that air conditioning saved lives when he implemented a system of air conditioned shelters during the heat wave of 1995. Increased pollution from the shelters, which cooled thousands during the heat wave were obviously of little concern to Daley. He likely considered the pollution problem irrelevant. Anecdotally, this experience shows that the rational approach to lowering mortality in the summer may not be through pollution control, but by increased use of air conditioning.

In the World Climate Report, Professor Lawrence S. Kalkstein of the University of Delaware and principal investigator for the EPA in its Climate and Human Health Program also saw air conditioning as a life-saver: "In addition, power failures contributed to more deaths being reported in affluent areas where residents would normally have survived thanks to air conditioning....The excess number of deaths in less affluent areas were blamed on lack of air conditioning...." Kalkstein said he expected increased mortality because of the lack of air conditioning. In a study sponsored by the Environmental Protection Agency and the Southern and Southeast Regional Climate Centers, Kalkstein showed strong correlation between hot, humid air masses and increased mortality. After reaching this conclusion, Dr. Kalkstein went on to help implement a hot-weather watch/warning system for the city of Philadelphia.

The Science on Ozone

Studies on ground-level ozone show that public health is not threatened by ozone unless it is in concentration levels far above the current standard of 0.12 ppm. As CASAC concluded following its review of the new proposed ozone standard, "there is no `bright line' which distinguishes any of the proposed standards (either the level or the number of allowable exceedances) as being significantly more protective of public health." Natural causes which contribute to ozone alone could bring ozone levels well above the proposed standard. According to CASAC, "Based on information now available, it appears ozone may elicit a continuum of biological responses down to background concentrations...The paradigm of selecting a standard at the lowest-observable-effects-level and then providing an `adequate margin of safety' is no longer possible." CASAC was unable to endorse the EPA's new standard for ozone based on its review of the science and instead called on the EPA to make a policy "judgment" call.

The latest research on ozone shows that reduced levels may actually pose adverse health effects. A report published in a recent issue of Environmental Science and Technology finds that the reduction of ozone actually increases human exposure to damaging ultraviolet-B (UV-B) radiation. The authors estimate that a decrease in ozone concentration of 0.10 ppm leads to "increases in cancers and cataracts valued at $0.29 billion to $1.1 billion annually."

The Impact of the New Standards: Real Costs Imposed on Real People

As a consumer organization, CSE Foundation's focus is the enormous impact the new standards would have on communities throughout the country, both economically and in terms of potential threats to accustomed lifestyle. By the EPA's own estimate, many areas of the nation would fall into nonattainment, and at least 100 million individuals would be impacted. Many others would be effected by rising prices for gas and consumer products, lost jobs, and an overall decline in the quality of lif

The EPA, placing the estimated costs of the new standards between $6.5 billion and $8.5 billion a year, dismisses the relevance of cost because under the Clean Air Act, the agency is not supposed to consider its impact or the impact on lifestyle until the implementation process. As Carol Browner herself stated, clean air standards are to be driven by health issues, "not a cost-benefit analysis." However, financial burdens on citizens should not be so readily dismissed. Income losses from increased regulatory burdens may generate adverse health impacts, given that lower income has been correlated with higher mortality rates. The new standards would lead to the imposition of real costs and the real loss of jobs to real people. Furthermore, EPA's own preliminary review of the possible costs and benefits of the new ozone standard found that costs (estimated at $600 million to $2.5 billion a year) would far exceed benefits (estimated at $0 to $1.5 billion a year). Surely, these findings should not be so easily discarded.

As stated in the EPA's Regulatory Impact Analysis on particulate matter, "The consideration of cost and...cost-benefit analyses, provides a structured means of evaluating and comparing various implementation policies, as well as a means of comparing the variety of tools and technologies available for air pollution control efforts. The Agency has found the use of such analyses to be of significant value in developing regulatory options over the years." Given the EPA's own recognition of the importance of the consideration of costs, as well as the strong link associated between income and health, we should not ignore costs at this point in the process.

The EPA, in fact, is required by law under the provisions of the Small Business Regulatory Enforcement Fairness Act (SBRFA) to consider the impacts of regulations on state, local, and tribal governments and based on the findings, select approaches that offer the least costly course. The EPA's assumption that the standards have no economic impact ignores the fact that the standards do, indeed, require the adoption of costly new control technologies.

A Closer Look at the Sources of PM2.5 .

The State and Territorial Air Pollution Program Administrators (STAPPA) and the Association of Local Air Pollution Control Officials (ALAPCO), in a report entitled Controlling Particulate Matter Under the Clean Air Act: A Menu of Options, list the many activities that release the large amounts of PM2.5. Surprisingly, by far the largest source of PM2.5C 83 percentCis "fugitive" dust, which is caused by roads (paved and unpaved), agricultural crops and livestock, and natural soil erosion.

Manufacturing and industrial activity as a percentage of total emissions is surprisingly low at only 2 percent. Equally surprising is the fact that residential wood burning is one of the single most leading contributors. Together with other residential activities that cause fuel combustion, these activities contribute as much as 5 percent of all PM2.5 emissions.

But even though industry contributes a relatively small portion of all PM2.5 emissions, this source will be a primary target for reduction. Many smaller business operations will become targets as well. Gas station owners, for example, could be required by state or local governments to replace the current gasoline pumps with new pumps that capture fumes and recycle them back into the underground storage tanks. One supplier of equipment for gas stations in Indiana put the cost per station at $30,000 to $80,000, depending on the number of pumps to be converted. Large gas station operations would most likely find a way to pass the cost onto the consumer, while small gas station operations would probably be forced to close their doors.

Potential Changes to Lifestyle.

Carol Browner insists that restrictions to accustomed lifestyles will not occur. But the STAPPA and ALAPCO report Controlling Particulate Matter Under the Clean Air Act suggests otherwise. The report, released to state and local officials to provide a menu of options for meeting standards on particulates, specifically includes restrictions on the use of these products.

For example, the recommendations for limiting "residential wood combustion" (fireplaces, woodstoves, wood heaters, and "coal-fired appliances), include among others, the following:

! Establish an episode curtailment program...a communication strategy to implement the plan; a surveillance plan; and enforcement provisions such as procedures, penalties, and exemptions. A voluntary program will be deemed reasonable if the area is one that demonstrates attainment.

! Provide inducements that would lead to reductions in the stove and fireplace population or use by slowing the growth of woodburning devices in new housing units by imposing taxes, installation permit fees, or other disincentives.

! Ban the resale or installation of uncertified wood heaters.

! Regulate the wood moisture content of wood fuel by requiring the use of dry or seasoned wood.

! Develop an offset program, whereby homeowners may only receive a residential wood combustion permit if they replace an existing device or if two existing devices are retired for every new device installed.

! Ban coal use in residential wood combustion devices.

! Charge an emissions fee in dollars per gram for certified levels.

Inconsistent with Carol Browner's insistence that lifestyle changes will not occur is the fact that much of the research upon which STAPPA and ALAPCO based their recommendations is from EPA studies, including one that attributes residential wood burning with "decreases in lung capacity and increases in asthma attacks..."

In parts of the country (Denver, Reno, and Scottsdale), wood burning fires in homes is already against the law during most of the winter season. And areas in Northern California may not be far behind. The Sacramento Bee reported that "many Northern California air regulators are eyeing fireplaces as one of the few places where significant reductions in fine-particle pollution can be gained."

In addition to fireplaces, another prime source for target are "two-stroke engines" (lawn mowers, leaf blowers, chain saws, shredders & tillers, welders & compressors, and boats & other recreational vehicles). According to the STAPPA and ALAPCO report, these products account for 12 percent of all non-road engine sources of particulates, more than four-stroke engines contribute.

Again, the possibility that these devices may be banned or restricted in production is not as unlikely as Browner says. In fact, some areas struggling to meet the current standards have already banned the use of some of these appliances. In Maricopa County, Arizona the Maricopa Association of Governments last January approved a list of 61 measures in an effort to meet the EPA's standards. The federal agency had recently lowered their status from "moderate" to "serious." Among the 61 restrictions is a ban on gas-powered lawn mowers and garden equipment. As Larry Morrison, a city councilman and head of the association explains, "Such a cut is pretty steep, and every little measure will help." Responding to the public anger against the new measures, he conceded, "Any time you change a person's lifestyle, it's difficult." But despite the 61 restrictions, local officials are already concerned that even these many not be enough to meet the 1990 Clean Air Act requirements, let alone the proposed new standards.

Policies adopted earlier this year to "scrub the skies" of particulate matter in Southern California require that all cities and counties within a region purchase new sweepers with vacuums or filters to remove dust from all paved streets. Many of the 4,600 miles of unpaved streets will have to be paved. And new measures will go into effect that restrict when farmers can grind their hay. Farmers will also have to come up with plans to reduce soil erosion, and construction workers will have to use more water or soil stabilizers. Other regulations will be put into place that reduce dust from mines and landfills. The estimated cost? As much as $10.6 million a year, with local governments picking up 83 percent of the cost.

Concluding Comments

As a first step to further studying the health effects specifically of PM2.5, the Harvard School of Public Health should release the key data used in the "Six City" study. It is unreasonable not to release the data for public debate when the standard could impose billions of dollars of new costs on society each year. Allowing the authors to withhold this critical information weakens the peer review system and suggests the EPA's lack of willingness to commit to thorough scientific review.

EPA is pushing forward with the new PM 2.5 air quality standard before proving its scientific validity. The concept of an air quality standard based on strictly quantitative measures, in this case particle diameter, is a subtle admission of the agency's ignorance. EPA is uncertain about the science of this new standard, so it has chosen to take a fine-mesh fishnet approach to regulation, attempting to clean the air of all possible pollutants. Such an approach is unlikely to have any effect on the health of human beings. Much research needs to be carried out to understand if there is any health threat from any of the hundreds of fine particles the agency has proposed to regulate. Casting out a net at this point is questionable, since we are not even sure of what we are trying to catch.

Toxicologists and epidemiologists must move forward to discover if biological mechanisms and exposure levels exist to substantiate claims of health risks from fine PM. On the other hand, evidence clearly shows that the increased costs from regulation will force many consumers, especially those of low income, to choose between physical and financial burdens. In some cases, increased energy costs will kill. We know with absolute certainty that many people have died from heat waves in the past, and that this problem will continue in the future. It is also certain that people have died from the lack of air conditioning, and sometimes people have even chosen to suffer, rather than turn on their units for fear of high energy bills. The EPA needs to consider the health of the consumer before a new PM 2.5 standard is accepted. EPA must be absolutely sure that the benefits of minimal pollution reduction will not be lost by the very real health disbenefits of expensive electricity.

The EPA's new NAAQS proposal to further regulate ozone and particulate matter is too drastic a response at this time based on our limited scientific knowledge of the health effects. The impact of implementation would be far-reaching and devastating, throwing much of the nation into nonattainment and imposing heavy economic burdens throughout most of the country. Giving more time to allow for the scientific study of ozone and PM will ensure that we are focusing limited resources on those health threats that pose the greatest risk to our children's well-being.

Citizens for a Sound Economy Foundation

1250 H Street, NW, Suite 700

Washington, D.C. 20005

March 12, 1997