Regan Warns Of PM2.5 Health Risks, Need To Combat ‘Structural Racism’

Source: By Stuart Parker, InsideEPA • Posted: Sunday, October 17, 2021

EPA Administrator Michael Regan is warning of the need to protect vulnerable populations from the dangers of fine particulate matter (PM2.5) and the adverse impact it has in exacerbating racial and economic disparities in environmental health, indicating a likely push to strengthen federal standards in a reconsideration of the limits now underway.

Speaking virtually to the agency’s Clean Air Scientific Advisory Committee (CASAC) specialized PM panel at the outset of its review of EPA’s reconsideration effort Oct. 14, Regan noted new scientific evidence that may call into question the Trump EPA’s December decision to retain all PM national ambient air quality standards (NAAQS) at current levels that were last strengthened in 2012.

Welcoming a return to “scientific integrity” since the end of the Trump era, Regan, EPA’s first African-American administrator, said that exposure to PM “can be particularly deadly,” with Black communities and others historically overburdened by pollution especially at risk.

EPA must protect the most vulnerable populations “living with the legacy of structural racism,” and “achieving environmental justice must be our collective task,” Regan said.

While Regan did not explicitly call for tougher PM standards, his decision to reconsider the Trump rule and heavy emphasis on the impacts to equity communities appears to strongly suggest a desire to tighten the limits.

Under the Clean Air Act, the administrator can tighten the limits if, in his opinion, they are not sufficient to protect public health with an “adequate margin of safety.”

Under legal precedent, EPA interprets this to require a margin to protect those especially vulnerable to an air pollutant, such as those with chronic respiratory diseases, children or the elderly.

EPA has set itself an ambitious timetable to propose a reconsidered NAAQS rule in summer 2022 and finalize it in the spring of 2023.

To achieve this, the agency is relying on a draft supplemental integrated science assessment (ISA) that adds new evidence gathered since the cutoff date for studies to be included in the Trump EPA’s 2019 ISA. This includes major U.S. and Canadian epidemiological studies published from January 2018 to March 2021 showing harmful effects from exposure to PM2.5 at levels below the current NAAQS.

Already, EPA staff has reworked its earlier policy assessment (PA) document into a draft PA that includes the findings of the supplemental ISA. The revised draft PA again suggests that EPA tighten the annual “primary,” or health-based NAAQS for PM2.5 from 12 micrograms per cubic meter (ug/m3) down to a tougher limit between 8 ug/m3 and 12 ug/m3.

Although EPA staff made this recommendation during the Trump administration review, then-Administrator Andrew Wheeler overrode the advice and retained the 2012 limits, with the support of a majority of the CASAC.

Since then, Regan has replaced most of the membership of the seven-member chartered CASAC and reinstated the special PM panel that the Trump EPA scrapped.

‘Clock Is Ticking’

Addressing the CASAC PM panel, acting EPA air chief Joe Goffman said “we are also aware that the clock is ticking” to complete the reconsideration. “It is imperative to move forward quickly.”

Goffman said the “PM NAAQS has always been the cornerstone” of EPA’s mission to protect air quality.

EPA staff on the call also noted the time pressure created by the reconsideration schedule, and the unique nature of this procedure, which one staffer called “a first for this program.” EPA has, however, introduced supplementary scientific evidence during the course of prior NAAQS reviews, staff said.

The expedited timetable, however, presents a potential conflict with the need for thorough CASAC review and potential revision of draft documents. EPA staff said that to stay on track, CASAC needs to produce its final letters offering the panel’s advice on the ISA and PA documents early next year.

Former air advisers and environmentalists heavily criticized the Trump EPA for its truncated review process that combined previously separate review steps and limited CASAC input.

Two critics of the Trump NAAQS review process were the new CASAC Chair Elizabeth Sheppard, a University of Washington professor, and Chris Frey, a former CASAC chair and chair of the Wheeler-disbanded PM review panel who the Biden administration has nominated to lead EPA’s Office of Research and Development (ORD).

Addressing the meeting, Frey praised the reestablishment of the PM review panel, and noted that the CASAC has historically supported EPA staff’s weight-of-evidence approach that analyzes risks from air pollution using multiple lines of evidence. One exception was the Trump-era CASAC, headed by industry consultant Tony Cox, who called into question EPA’s methods for assessing whether air pollution exposure “causes” health problems. — Stuart Parker (