Contacts:
Andrew Weisser, (818) 703-6444
aweisser@earthlink.net
or your local American Lung Association
at (800) LUNG-USA. www.californialung.org

Comments of Bonnie Holmes-Gen
Assistant V.P., Government Relations
American Lung Association of California

On

Review of the California Ambient Air Quality Standards For Particulate Matter and Sulfates

On behalf of the American Lung Association of California and it’s medical section, the California Thoracic Society, I am testifying in support of the proposed changes to strengthen the California Ambient Air Quality Standards for Particulate Matter. The review of particulate air quality standards that resulted in the proposed new health-based levels was conducted pursuant to SB 25 (Escutia), the Children’s Environmental Health Protection Act adopted in 1999. The proposed new particulate matter standards are necessary to protect all communities in California from lung illnesses and premature death, but are especially important to protect infants and children. The developing lungs and immune systems in infants and children are especially vulnerable to air pollution hazards. Few decisions that you make are likely to have a greater impact on the health and longevity of California communities and children.

The proposals to strengthen the annual ambient air quality standard for PM₁₀, to establish a new annual standard for fine particles, known as PM_2.5, and to retain the existing PM10 24 hour standard are vital to public health protection in California. Equally as vital is the need for a new 24 hour PM 2.5 standard. While the PM 2.5 24 hour standard is not before you today due to the need to analyze a recently discovered software glitch that affected some relevant research, we strongly urge you to bring the short-term PM 2.5 standard back to the Board for consideration by December, 2002.

The State’s air quality standards are in critical need of updating in light of hundreds of recent studies demonstrating premature mortality, increased hospital admissions for cardiopulmonary causes, acute and chronic bronchitis, emergency room visits, and asthma episodes at particulate matter levels well below the current standards. Infants, children, the elderly, and those with pre-existing heart or lung disease are at greatest risk.

The scientific evidence accumulated in the 20 years since California last reviewed its particulate matter standards in 1982 points to very serious risks of premature death and disease from exposure to very fine particles, which are easily inhaled deep into the lungs. These fine particles are not controlled under the standards currently on the books.

Annual Average PM₁₀ Standard Should Be Adopted

We strongly support the staff proposal to establish a more stringent level for the annual average PM₁₀ standard (20 m /m³⁾. Long-term community health studies definitively establish the risk of premature death from exposure to PM₁₀ air pollution at levels well below the current standards, and establish a sound scientific basis for selecting the proposed more stringent level.

Annual Average PM_2.5 Standard Should Be Adopted

The proposed new annual average standard for PM_2.5 of 12 m /m³ is needed to protect sensitive members of the population from exposures to fine particle pollution, which are not controlled under the current or proposed PM₁₀ standards. If the level of the proposed standard is weakened in any way it will not meet the statutory requirement to protect the health of the public, including children, with an adequate margin of safety.

The long-term epidemiological studies upon which the proposed annual standards for PM₁₀ and PM_2.5 are based -- the Harvard Six Cities Study and the American Cancer Society study -- were both reanalyzed in depth by an independent panel and upheld in 2000. The conclusions of the American Cancer Society study on the risks of fine particles were further reinforced with the analysis of eight additional years of follow-up research, published in 2002.

24-hour PM_2.5 Standard Should Be Considered By December, 2002

A 24-hour PM_2.5 standard is critically needed to protect against the short-term effects of fine particles demonstrated in hundreds of time-series studies. These effects range from respiratory symptoms and declines in lung function, to an increased rate of emergency room visits and hospital admissions for cardiac and respiratory causes, to premature mortality following short-term increases in particulate air pollution. The major scientific uncertainties about these studies have all been addressed by recent research.

The annual standard alone will allow for excursions in many California cities well into the range in which adverse effects, including mortality, have been identified in epidemiological studies.

The fresh discovery of a software problem that affected the results of the National Morbidity, Mortality, and Air Pollution Study has led to a deferral of consideration of the 24-hour PM_2.5 standard. While this deferral may be needed to allow time for reanalysis of time-series studies that may be affected by the software problem, there must be a date-certain established for reconsideration of this important standard that was unanimously approved by CARB’s scientific review panel, the Air Quality Advisory Committee.

We urge the Air Resources Board to direct staff to bring the PM 2.5 24 hour standard back to the board for consideration as soon as possible after re-evaluation of the studies affected by the software problem and before December, 2002.

24-hour PM₁₀ Standard Should Be Maintained

The staff has proposed to retain the existing 24-hour PM₁₀ standard of 50 m /m³. We note that this standard was established in 1982, and that the studies that underlie this standard are not affected by the software problem, which only bears on certain time-series studies conducted in the last five years. Therefore, we support retaining this standard.

"Not To Be Exceeded" Form Critical to Standards

The health protection provided by the standards is a function of the level as well as the form of the standard. The "not to be exceeded" form of all of the proposed standards is extremely important to ensure the best level of health protection and must not be diluted in any way.

The entire nation and the rest of the world look to California for leadership on air quality issues. Establishment of health-protective air quality standards is the foundation for all our clean air programs. Thousands of premature deaths, hospitalizations, and other severe health effects will be averted every year through attainment of the proposed standards.

We urge immediate adoption of the proposed standards, and a directive to complete a review of the 24-hour PM_2.5 standard and return before the Board with a proposal before year’s end. Thank you for your consideration.