Proposed Changes in National Ambient Air Quality Standards, Ozone and Particulate Matter

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RE: EPA Dockets A-95-54, A-95-58, A-96-51

Thank you for the opportunity to comment on the agency's proposed revisions of the NAAQS for ozone and particulate matter. These changes would have far-reaching effects on many aspects of national life, and are of great concern to the Human Ecology Action League, Inc. and its members.

The Human Ecology Action League, Inc. (HEAL) is a national, nonprofit organization dedicated to providing information and education about environment and health. We are not a professional association, nor are we a lobbying group. We are a service organization, funded entirely by memberships and donations. We have no ties to any industry, profession or political organization.

HEAL is one of the oldest organizations of its kind in the world. It was founded in 1977 by physicians and citizens concerned about the health effects of environmental exposures. As such, HEAL is not a "one issue" organization, but is concerned with a wide range of environment and health issues.

In recent years, we have dedicated much of our attention to the effects of low-level chemical exposures on human health. We have concentrated our attention on the issue of multiple chemical sensitivities (MCS), from which many of our members suffer. However, we are also concerned about other environment-related disorders including asthma, chronic headaches, and severe allergy. Our members look to us to provide information about environmental exposures of many kinds, their risks, and prudent measures that can be taken to avoid harmful exposures.

We take it as a given that the ambient environment is the setting in which all other exposures take place. General ambient conditions provide the background to which all additional exposures are added. Thus, HEAL and its members have always had a keen interest in, and concern about, the healthfulness of ambient environmental conditions.

Our comments regarding the agency's proposed revisions of the NAAQS for ozone and particulate matter will consider both items together. This is in keeping with our organization's endeavor to conceptualize environmental concerns in a global fashion. We believe that many environmental problems are best considered as parts of a larger whole, and that our organization can best contribute to public discussions of environmental problems and solutions by keeping the whole picture clearly in mind.

It is evident that the debate over the agency's proposed changes in the ozone and particulate matter NAAQSs will be fierce. Many segments of society have considerable stakes in how these pollutants are regulated. We believe that it may be very important to bear in mind that, no matter what decisions are made regarding these regulations, there will be a price to be paid.

An example of how failing to reduce pollution levels will ultimately be costly can be clearly seen in asthma. We think that if the current standards are left unchanged, the current trends in asthma incidence and severity will continue. This would mean a continuation of increasing numbers of cases of asthma, asthma onset at younger ages, more severe and difficult-to-control asthma, and asthma with greater morbidity (and perhaps mortality). In this scenario, the cost of doing nothing includes increased healthcare costs, loss of quality of life for those affected, failure to meet social and economic goals as young asthmatics fail in academic achievement and worker productivity, increased disability-related costs, and decreased tax revenues collected.

We are particularly concerned about the life-long medical, social and economic costs of early-onset asthma. In 1992, an economic evaluation of asthma published in the New England Journal of Medicine put the 1990 cost of asthma at $6.1 billion, a number that included missed school days and lost worker productivity (1). Missing from that analysis was the effect of poor academic achievement and decreased worker productivity on private savings rates and tax revenues (including worker contributions to Social Security and Medicare). If asthma cases increase, asthma attacks increase, and the cost of health-care continues to rise at even a modest rate, the cost of pollutant-related asthma could be very high indeed. The cost is very significant if only a portion of all asthma-related healthcare and other costs are attributed to preventable environmental exposures.

The relationship between asthma and pollutants - particularly ozone and, to a lesser degree particulate matter - has been more fully explored than the relationship between other lung diseases and pollution. The attribution of 60,000 premature deaths to particulate pollution has gained some currency, but more subtle chronic health effects have not been so widely discussed. Yet these less-familiar effects may become facts of life for many Americans if current pollution levels are not reduced.

For instance, we are concerned about the effects of current levels of ozone and particulate matter on the nation's aging population. As the "baby boom" generation ages, there will be an increasingly large population susceptible to "nonspecific airway hyper-responsiveness" manifested as bronchospasm in response to irritant inhaled pollutants (2). Health-care costs can be anticipated to increase for this entire cohort of Americans, simply as a function of their age. Additional health-care costs as the result of increased rates of lung disease in this population could have a dramatic impact on health-care costs at a time when the workforce is shrinking due to worker retirement.

Not only breathing difficulties, but also increased incidence of cardiovascular disease (and related increased susceptibility to air pollutant effects) can be anticipated in this very large group of Americans as it ages. In particular, aging asthmatics who develop cardiovascular disease may challenge both efforts to provide effective treatment, and health-care cost containment.

These are just a few examples of how the combination of current pollution levels and the aging population may together represent a potential threat to the nation's health - and health-care system. We believe that the evidence provided by current research (3) on the effects of ambient pollution on human health, together with some common-sense assumptions about anticipated changes in the aging population, are together sufficient to support further reductions in ambient air pollution.

We believe that improved environmental conditions will help to protect the vulnerable, including the very young, the very old, and the genetically-susceptible. We think that such improvements will also help preserve function in those whose health is already impaired, such as the allergic, the asthmatic, the sensitive, and the immune-impaired. We know that these protections are costly -- but we also strongly believe that the cost of not offering these protections is even higher.

We believe that further investment in pollution reduction would benefit many Americans, especially those facing age-related changes in health. We believe that such reductions would prevent illness, and that preventing illness benefits everyone. Healthy children succeed better in school than those too ill to attend. Successful students can become highly-qualified workers in good-paying jobs. Healthy workers produce more, lose less time to illness, cost less in health- care coverage, and contribute more in taxes. Healthy retired workers can remain productive as small business owners, as volunteers, and as vigorous participants in community life.

We realize that, although the Clean Air Act 1970 specifically enjoined the agency to consider regulating pollution for public health without regard to economic impact, the agency's proposed changes in the NAAQS for ozone and particulate matter face potential challenges from Congress under the 1996 Small Business Regulatory Enforcement Fairness Act. We believe that a good case can be made for a positive balance of benefit to cost with respect to pollution reduction and health protection.

We are aware that revising the NAAQSs has been highly controversial since passage of the Clean Air Act in 1970. We also believe that resources devoted to pollution reduction as the result of the Clean Air Act have been invested well. We believe that further investments in pollution reduction are in order, to protect the health of citizens. We believe that healthy citizens are necessary to achieve the nation's goals in education, global competitiveness, fiscal health and environmental stewardship.

Muriel A. Dando, President
On behalf of the Governing Board,
Human Ecology Action League, Inc. (HEAL)
Ty M.Bridges JD,
Virginia Carlson,
Kenneth L. Dominy,
Beatrice Trum Hunter,
Kenneth V. King Jr. R.Ph.,
Lydia C. Jones MBA