1
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
1
2
Transcript
of
Hearing
to
Take
Comment
on
3
Two
Proposed
Rules
4
5
1.
Revisions
to
the
National
Ambient
Air
Quality
6
Standards
for
Particulate
Matter
7
and
8
2.
Revisions
to
Ambient
Air
Monitoring
Regulations
9
10
March
8,
2006
11
12
HEARING
held
at
Hyatt
Regency
Chicago
13
151
East
Wacker
Drive,
Chicago,
14
Illinois,
commencing
at
9
a.
m.
15
16
17
HEARING
PANEL
18
JASON
BURNETT,
Hearing
Officer
19
ERIKA
SASSER,
Panel
Member
20
LEWIS
WEINSTOCK,
Panel
Member
21
CHERYL
NEWTON,
Panel
Member
22
JAY
BORTSER,
Panel
Member
23
24
Reported
by:
Janyce
Booth,
CSR,
RMR,
CRR
25
2
MR.
BURNETT:
Good
morning.
I
think
1
we're
about
ready
to
get
started.
2
Thank
you
for
attending
the
3
Environmental
Protection
Agency's
public
hearing
4
on
two
proposed
rules
for
particulate
matter.
I
5
recognize
that
many
of
you
have
traveled
quite
a
6
distance
to
be
here,
and
I
appreciate
your
7
efforts.
8
My
name
is
Jason
Burnett.
I'm
the
9
Senior
Policy
Advisor
to
the
Acting
Assistant
10
Administrator
of
the
EPA's
Office
of
Air
and
11
Radiation,
Bill
Wehrum.
I'll
be
chairing
today's
12
hearing.
13
We're
here
today
to
listen
to
your
14
comments
on
EPA's
proposed
revisions
to
the
15
National
Ambient
Air
Quality
Standards,
or
NAAQS,
16
for
Particulate
Matter
and
proposed
revisions
to
17
the
Ambient
Air
Monitoring
Regulations.
As
a
18
reminder,
this
is
a
hearing,
an
opportunity
for
19
the
public
to
comment
on
EPA's
proposed
rules.
20
The
panel
members
may
answer
questions
that
seek
21
to
clarify
what
we
have
proposed,
but
the
purpose
22
of
this
hearing
is
to
listen
to
your
comments,
23
not
to
discuss
or
debate
the
proposals.
24
Before
we
move
to
the
comment
period,
I
25
3
would
like
to
briefly
describe
the
proposed
rules
1
that
are
the
subject
of
today's
hearing.
Both
2
the
proposed
rules
were
published
in
the
Federal
3
Register
on
January
17,
2006.
4
Particulate
matter,
also
known
as
5
particulate
pollution,
includes
a
mixture
of
6
solids
and
liquid
droplets.
Particles
comes
in
a
7
wide
range
of
sizes.
Some
particles
are
emitted
8
directly,
and
others
are
formed
in
the
atmosphere
9
when
pollution
emissions
such
as
sulfur
dioxide,
10
nitrogen
oxides,
ammonia
and
volatile
organic
11
compounds
react
together
chemically.
Exposure
to
12
particles
has
been
associated
with
premature
13
death
as
well
as
significant
adverse
14
cardiovascular
and
respiratory
effects.
15
The
proposed
revisions
to
the
National
16
Ambient
Air
Quality
Standards
for
particulate
17
matter
address
two
categories
of
particles:
Fine
18
particles,
or
PM2.5,
which
are
2.5
micrometers
in
19
diameter
or
less,
and
inhalable
coarse
particles,
20
or
PM10­
2.5,
which
are
smaller
than
10
21
micrometers
in
diameter
but
larger
than
PM2.5.
22
We've
had
National
Ambient
Air
Quality
23
Standards
for
PM2.5
since
1997
and
for
particles
24
10
micrometers
and
smaller,
PM10,
since
1987.
We
25
4
have
proposed
specific
revisions
to
the
current
1
PM
standards
and
requested
comment
on
a
wide
2
range
of
alternative
standards
for
both
fine
and
3
inhalable
coarse
particles.
The
proposed
4
revisions
address
changes
to
both
the
primary
5
standards
to
protect
public
and
the
secondary
6
standards
to
protect
public
welfare
including
7
visibility
impairment.
8
With
respect
to
the
primary
standards
to
9
protect
public
health,
the
proposal
included
the
10
following:
11
First,
lowering
the
level
of
the
24­
hour
12
fine
particle
standard
from
the
current
level
of
13
65
micrograms
per
cubic
meter
to
35
micrograms
14
per
cubic
meter.
We've
also
requested
comment
on
15
retaining
the
current
level
of
the
standard
at
16
65,
and
on
levels
between
25
and
65,
and
also
on
17
alternative
approaches
for
selecting
the
level
of
18
the
standard.
19
Second,
we
are
proposing
to
retain
the
20
level
of
the
annual
fine
particle
standard
at
21
15
micrograms
per
cubic
meter.
We've
considered
22
and
are
seeking
public
comment
on
a
range
of
23
levels
from
15
down
to
12.
24
Third,
we
are
establishing
a
new
25
5
indicator
for
inhalable
coarse
particles
­
1
PM10­
2.5.
The
proposed
new
PM10­
2.5
standard
has
2
been
qualified
to
include
any
ambient
mix
of
3
coarse
PM
dominated
by
resuspended
dust
from
high
4
density
traffic
on
paved
roads
and
PM
generated
5
by
industrial
sources
and
construction
sources,
6
and
to
exclude
any
ambient
mix
of
coarse
PM
7
dominated
by
rural
wind­
blown
dust
and
soils
and
8
PM
generated
by
agricultural
sources
and
mining
9
sources.
10
We
have
proposed
setting
a
24­
hour
11
standard
for
inhalable
coarse
particles
at
75
12
micrograms
per
cubic
meter.
Under
the
proposed
13
regulations,
agricultural
sources,
mining
sources
14
and
other
similar
sources
of
crustal
materials
15
shall
not
be
subject
to
control
in
meeting
this
16
standard.
17
We
have
requested
comment
on
selecting
a
18
level
down
to
as
low
as
50
micrograms
per
cubic
19
meter
or
below
and/
or
selecting
an
unqualified
20
PM
10­
2.5
indicator.
We
have
also
asked
for
21
comment
on
whether
we
should
retain
the
22
current
PM10
standard
in
place
of
the
proposed
23
PM10­
2.5
standard
or
whether
we
should
establish
24
a
coarse
PM
standard
at
this
time
pending
the
25
6
development
of
a
coarse
fraction
monitoring
1
network
and
further
reference
on
the
health
2
effects
of
coarse
particles.
3
Now,
with
respect
to
the
secondary
4
standards
to
protect
public
welfare,
we
have
5
proposed
that
the
secondary
standards
would
be
6
identical
to
the
primary,
health­
based
standards.
7
We
have
requested
comment
on
setting
a
sub­
daily
8
four­
to­
eight­
hour
averaging
time
PM2.5
PM2.5
9
standard
to
address
visibility
impairment
within
10
the
range
of
20
to
30
micrograms
per
cubic
meter.
11
Inhalable
coarse
particles,
or
PM10­
2.5,
12
is
a
subset
of
the
type
of
PM
controlled
by
13
existing
standards
for
PM10,
raising
the
question
14
what
would
happen
to
the
current
PM10
standards
15
if
we
finalized
standards
for
PM10­
2.5.
We
have
16
proposed
that
current
scientific
evidence
does
17
not
support
setting
an
annual
standard
for
18
inhalable
coarse
particles
and,
therefore,
19
propose
to
revoke
the
current
annual
PM10
20
standards
in
all
areas.
If
we
finalize
24­
hour
21
primary
standard
for
PM10­
2.5,
we've
proposed
to
22
revoke
the
current
PM10
standard
except
in
areas
23
that
have
at
least
one
monitor
that
is
located
in
24
an
urbanized
area
with
a
minimum
population
of
25
7
100,000
people
and
that
has
measured
a
violation
1
of
the
24­
hour
PM10
standard
based
on
the
most
2
recent
three
years
of
data.
3
In
the
second
rule,
the
monitoring
rule,
4
we
have
proposed
revisions
to
the
ambient
air
5
quality
monitoring
requirements
for
criteria
6
pollutants.
The
proposed
changes
would
support
7
proposed
revisions
to
the
NAAQS
for
particulate
8
matter,
including
new
minimum
monitoring
9
requirements
for
inhalable
coarse
particles,
10
PM10­
2.5
and
criteria
for
approval
of
applicable
11
sampling
methods.
12
These
proposed
changes
would
establish
a
13
new
nationwide
network
of
monitoring
stations
14
that
take
an
integrated,
multi­
pollutant
approach
15
to
ambient
air
quality
monitoring
in
support
of
16
multiple
objectives.
The
proposed
amendments
17
would
modify
the
current
requirements
for
ambient
18
air
monitors
by
focusing
requirements
on
19
populated
areas
with
air
quality
problems.
The
20
purpose
of
these
proposed
changes
is
to
enhance
21
the
ambient
air
quality
monitoring
to
better
22
serve
current
and
future
air
quality
management
23
and
research
needs.
24
Additional
information
on
the
two
25
8
proposed
rules
can
be
found
in
fact
sheets
1
available
in
the
registration
area
outside
the
2
door
through
which
you
came
in.
3
Now
let
me
turn
to
the
comment
portion
4
of
today's
hearing.
This
hearing
is
one
of
three
5
public
hearings
we
are
holding
across
the
country
6
today.
Philadelphia,
San
Francisco
and
here
in
7
Chicago.
We'll
be
preparing
a
written
transcript
8
of
each
hearing.
The
transcripts
will
be
9
available
as
part
of
the
official
record
for
each
10
rule.
We're
also
accepting
written
comments
for
11
the
two
rules
until
April
17th,
2006.
We
have
a
12
handout
available
in
the
registration
area
with
13
detailed
information
for
submitting
written
14
comments.
15
At
this
time
I
would
like
to
outline
how
16
today's
hearing
will
work.
I
will
call
the
17
scheduled
speakers
to
the
microphone
in
pairs
18
here
at
this
table.
Please
state
your
name
and
19
your
affiliation,
and
it
will
help
the
court
20
reporter
if
you
also
spell
your
name.
21
In
order
to
be
fair
to
everyone,
we're
22
asking
that
you
limit
your
testimony
to
five
23
minutes
each
and
to
remain
at
the
microphone
24
until
both
speakers
in
the
pair
have
finished.
25
9
After
you
finish
your
testimony,
one
of
us,
one
1
of
the
panel
members,
may
ask
clarifying
2
questions.
3
As
I
mentioned,
we're
transcribing
4
today's
hearing,
and
each
speaker's
oral
5
testimony
will
become
part
of
the
official
6
record.
Please
be
sure
to
give
a
copy
of
any
7
written
comments
to
our
staff
at
the
registration
8
table.
We
will
put
the
full
text
of
your
9
comments
into
the
docket
for
you.
10
We
have
a
timekeeping
system
consisting
11
of
a
green,
yellow
and
red
light
here
in
front
of
12
me.
When
you
begin
speaking,
the
green
light
13
will
come
on.
You'll
have
five
minutes
to
speak.
14
The
yellow
light
will
signal
that
you
have
two
15
minutes
left.
We
will
ask
you
to
stop
speaking
16
when
the
red
light
comes
on.
17
Although
we
have
a
fairly
full
schedule
18
of
speakers
already,
we
intend
to
stay
into
the
19
evening
until
everyone
has
had
an
opportunity
to
20
comment.
If
you'd
like
to
testify
but
have
not
21
yet
registered
to
do
so,
please
sign
up
at
the
22
registration
table
just
outside.
23
For
those
who
have
already
registered
to
24
speak,
we
have
tried
to
accommodate
your
requests
25
10
for
specific
time
slots.
We
ask
for
your
1
patience
as
we
proceed
through
the
list.
We
may
2
need
to
make
some
minor
adjustments
as
the
day
3
progresses.
4
Now
I'd
like
to
introduce
the
EPA
5
representatives
on
our
panel.
6
First,
Cheryl
Newton,
Associate
Director
7
of
Air
and
Radiation,
Region
5.
8
Erika
Sasser,
Office
of
Air
Quality
9
Planning
and
Standards,
Health
and
Environmental
10
Impacts
Division.
11
And
Lewis
Weinstock,
Office
of
Air
12
Quality
Planning
and
Standards'
Air
Quality
13
Assessment
Division.
14
With
that,
I'd
like
to
thank
you
again
15
for
coming
here
today
to
participate.
Let's
16
begin
by
asking
Mrs.
Nolen
and
Mrs.
Stanfield
to
17
please
come
forward
to
the
speaker's
desk.
18
Thank
you.
19
MS.
NOLEN:
Good
morning.
I'm
Janice
20
Nolen,
Director
of
National
Policy
for
the
21
American
Lung
Association.
That's
N­
O­
L­
E­
N.
22
Thank
you
for
the
opportunity
to
discuss
23
the
Lung
Association's
concerns
about
the
24
proposed
standards.
We
will
be
submitting
more
25
11
detailed
comments
later
in
writing.
1
Congress
long
ago
made
it
clear
how
the
2
Environmental
Protection
Agency
should
determine
3
this
standard.
The
Clean
Air
Act
directs
EPA
to
4
set
the
standard
at
a
level
that
will
protect
5
public
health
with
an
adequate
margin
of
safety.
6
That
is
the
single
determining
factor
for
this
7
decision.
8
The
Supreme
Court
ruled
years
ago
that
9
costs
cannot
come
into
the
decision
until
the
10
next
stage
as
we
decide
how
to
clean
up
the
air
11
to
reach
that
limit
in
the
most
cost
effective
12
manner.
Nor
can
politics
be
a
factor.
Exploring
13
the
implications
of
how
this
would
affect
14
politicians
is
not
on
the
table.
For
now,
the
15
sole
issue
is
how
much
particle
pollution
it
16
takes
to
make
people
sick
from
breathing
it.
17
That's
the
bottom
line.
18
The
American
Lung
Association
believes
19
that
EPA's
proposal
fails
to
protect
public
20
health.
Period.
21
Unfortunately,
EPA
somehow
managed
to
22
find
too
much
uncertainty
in
the
results
of
over
23
2,000
studies
showing
clear
evidence
of
harm
at
24
levels
far
below
the
limits
proposed
here
to
set
25
12
truly
protective
standards.
1
EPA
ignored
specific
recommendation
of
2
its
own
expert
scientific
advisors
who
3
recommended
that
both
the
annual
and
the
24­
hour
4
standard
be
lowered.
For
example,
the
scientists
5
argued
that
to
keep
the
annual
standard
at
15
6
would
fail
to
protect
people
who
live
in
cities
7
which
rarely
exceed
the
daily
standard
but
have
8
high
particle
levels
day
in
and
day
out.
Yet
the
9
administrator
refused
to
budge.
We
urged
him
to
10
rethink
this
decision.
11
We
believe,
as
did
his
scientific
12
advisors,
that
he
already
had
plenty
of
evidence.
13
But
if
more
is
needed,
today
the
Journal
of
the
14
American
Medical
Association
published
a
study
15
looking
at
hospitalizations
in
over
200
U.
S.
16
counties
where
the
levels
of
pollution
would
be
17
well
within
the
proposed
annual
standard.
They
18
found
that
the
11
million
seniors
on
Medicare
19
living
in
those
counties
faced
an
increased
risk
20
of
being
put
into
the
hospital
for
heart
and
lung
21
diseases
because
of
the
particle
pollution
they
22
could
not
avoid.
Researchers
involved
in
the
23
study
have
also
analyzed
the
data
to
exclude
all
24
days
over
the
proposed
24­
hour
standard
as
well
25
13
and
find
that
the
increased
risk
of
1
hospitalization
would
still
remain.
2
EPA
chose
to
find
that
those
Americans
3
who
live
in
small
cities
and
counties
did
not
4
deserve
protection
from
coarse
particles.
EPA
5
chose
to
find
that
some
particles
were
harmless
6
and
should
not
even
be
studied
despite
evidence
7
that
particles
of
that
size
were
not
only
harmful
8
but
potentially
lethal.
EPA
proposes
to
9
eliminate
the
monitoring
network
that
could
help
10
determine
how
lethal
these
particles
might
be
to
11
people
living
in
the
small
cities
and
rural
areas
12
of
the
nation.
13
This
decision
is
the
most
important
14
decision
Steven
Johnson
will
make
in
his
tenure
15
as
Administrator
of
EPA.
This
will
be
the
16
official
decision
telling
the
nation
how
much
17
particle
pollution
can
be
in
the
air
we
breathe
18
and
still
have
it
safe
for
us,
all
of
us,
to
19
breathe.
Not
just
safe
for
healthy
adults.
The
20
air
must
be
safe
for
newborn
babies,
15
year
olds
21
with
asthma,
for
retirees
with
heart
disease,
for
22
mothers
with
diabetics,
and
for
my
colleague
at
23
work
who
lost
part
of
her
lung.
Safe
for
the
24
millions
of
Americans
whose
lungs
and
bodies
put
25
14
them
at
risk
from
breathing
these
intrinsically
1
dangerous
and
tiny
bits.
2
The
American
Lung
Association
recommends
3
the
following
standards
instead
of
EPA's
4
proposal:
5
For
PM2.5,
an
annual
standard
of
12
6
micrograms
per
cubic
meter
and
a
24­
hour
standard
7
of
25
micrograms
per
cubic
meter,
99
percentile.
8
For
PM10­
2.5,
a
24­
hour
standard
of
25
9
to
30
micrograms
per
cubic
meter,
99th
10
percentile,
based
on
particle
size,
not
11
composition
or
source.
12
These
standards
must
be
more
protective,
13
not
just
because
the
Clean
Air
Act
requires
it,
14
but
to
do
less
means
that
we
risk
the
lives
and
15
health
of
millions
of
Americans.
16
Thank
you
for
the
opportunity
to
17
comment.
18
MR.
BURNETT:
Thank
you.
Thank
you
very
19
much.
And
you
did
mention
the
JAMA
article
that
20
was
published
today.
Are
you
going
to
be
21
submitting
in
your
written
comments
­­
or
I
would
22
encourage
you
to
submit
in
your
written
comments
23
that
and
any
other
studies
that
you
would
like
us
24
to
consider.
25
15
MS.
STANFIELD:
Good
morning.
My
name
1
is
Rebecca
Stanfield,
S­
T­
A­
N­
F­
I­
E­
L­
D.
I
2
direct
the
Illinois
PIRG,
which
is
a
nonprofit,
3
nonpartisan
consumer
and
environmental
advocacy
4
organization
with
20
thousands
members
in
5
Illinois.
Thank
you
for
giving
me
the
6
opportunity
to
testify
today.
7
I'm
here
to
urge
you
to
heed
the
8
scientific
community
and
protect
public
health
by
9
substantially
strengthening
the
air
quality
10
standards
for
fine
particles
of
pollution.
11
Air
pollution
impacts
everyone,
even
the
12
hardiest
people
among
us.
Here
in
Chicago
we
are
13
exposed
day
in
and
day
out
to
a
level
of
fine
14
particle
pollution
that
is
unsafe
to
breathe,
15
even
by
the
definition
of
unsafe
adopted
ten
16
years
ago.
Every
resident
of
Chicago
suffers
a
17
level
of
heart
and
lung
damage
from
exposure
to
18
pollution
on
a
daily
basis,
and
we
all
know
19
people
who
are
especially
sensitive
as
well.
20
These
are
our
parents,
our
grandparents,
our
21
children,
and
the
growing
number
of
people
with
22
asthma
and
other
respiratory
disease.
They
are
23
precious
to
us.
They're
having
asthma
attacks,
24
heart
attacks,
strokes,
and
dying
early
because
25
16
of
exposure
to
air
pollution.
1
So
this
debate
isn't
so
much
about
65,
2
35,
25
as
it
is
that
those
numbers
represent
real
3
people
that
we
care
about
in
our
lives
that
are
4
becoming
sick
and
dying
early
because
of
air
5
pollution.
6
Over
the
last
decade,
numerous
studies
7
have
shown
that
fine
particle
exposure,
whether
8
long­
term
or
short­
term
has
devastating
health
9
effects,
even
at
levels
well
below
the
current
10
standards.
And
the
more
we
learn
about
the
11
health
effects
of
soot,
the
more
we
realize
the
12
severity
of
this
threat.
13
For
instance,
a
major
study
published
14
last
November
found
that
the
chronic
health
15
effects
of
fine
particles
are
two
to
three
times
16
greater
than
previously
believed,
and
that
for
17
each
increase
of
10
micrograms
per
cubic
meter
18
fine
particles
in
the
air,
the
risk
of
death
from
19
any
cause
rose
by
11
to
17
percent.
20
This
kind
of
knowledge
really
demands
21
action,
and
the
law
also
demands
action.
Under
22
the
Clean
Air
Act,
the
EPA
must
set
air
quality
23
standards
to
protect
public
health,
including
the
24
health
of
sensitive
groups,
with
an
adequate
25
17
margin
of
safety.
The
agency
must
also
review
1
air
quality
standards
every
five
years
to
insure
2
that
they
reflect
the
latest
scientific
knowledge
3
and
update
the
standards
as
needed.
4
Last
year
both
the
EPA
staff
scientists,
5
the
Scientific
Advisory
Committee,
the
6
administration's
independent
science
advisors
on
7
pollution
issues,
concluded
that
the
current
fine
8
particle
standards
are
too
weak
to
protect
public
9
health.
As
a
result
they
recommended
that
the
10
administration
strengthen
the
standards.
11
The
medical
and
scientific
communities
12
both
endorse
the
strongest
standards
within
EPA's
13
recommended
ranges.
12
micrograms
per
cubic
14
meter
for
the
annual,
25
micrograms
per
cubic
15
meter
for
the
daily.
Regrettably,
the
16
administration
chose
to
disregard
the
advice
of
17
its
scientific
advisors.
18
I
want
to
quote
an
excerpt
from
a
letter
19
sent
to
your
agency
last
week
from
the
members
of
20
your
own
Children's
Health
Protection
Advisory
21
Committee.
These
doctors
said,
"
The
proposed
22
standards
do
not
provide
an
adequate
protection
23
for
infants
and
children."
24
Further
they
say,
"
It
appears
the
health
25
18
of
children
was
neither
adequately
nor
explicitly
1
considered
in
determining
the
proposed
2
standards."
3
You
received
another
letter
in
December
4
from
a
group
of
104
doctors
who
urged
you
to
set
5
stronger
standards
as
advised
by
your
Scientific
6
Advisory
Committee.
You
also
chose
to
ignore
7
this
letter
and
to
ignore
your
Scientific
8
Advisory
Committee.
9
Thankfully,
it
is
not
too
late
to
change
10
course.
I
was
heartened
by
the
remarks
of
11
Administrator
Johnson
who
conceded
before
a
12
Congressional
panel
that
your
proposal
may
have
13
been
based
on
outdated
studies
and
expressed
a
14
willingness
to
reconsider.
15
I
strongly
urge
the
administration
to
16
heed
the
science
and
adopt
an
annual
standard
no
17
tighter
than
­­
no
higher
than
12
micrograms
per
18
cubic
meter
and
a
daily
standard
no
higher
than
19
25
micrograms
per
cubic
meter.
20
Air
quality
standards
are
the
foundation
21
for
reducing
air
pollution
nationwide,
so
this
22
decision
is
one
of
the
most
important
that
this
23
administration
will
make
on
air
pollution
issues.
24
Thank
you.
25
19
MR.
BURNETT:
Thank
you
very
much.
And
1
a
question.
2
You
mentioned
a
study
published
last
3
November
that
­­
can
you
provide
the
details
of
4
that
study
either
now
or
in
your
written
5
comments?
6
MS.
STANFIELD:
I'll
submit
the
full
7
study
for
the
record.
8
MR.
BURNETT:
Okay.
And
do
others
have
9
any
questions?
10
Thank
you
very
much.
11
Next
I
would
request
that
Dr.
Garcia
and
12
Representative
Nekritz
please
come
to
the
table.
13
Thank
you.
14
I
will
say
I
do
apologize
if
I
15
mispronounce
anyone's
name,
and
please
correct
16
me.
17
DR.
GARCIA:
Hello.
My
name
is
Skip
18
Garcia,
G­
A­
R­
C­
I­
A.
I'm
the
Chairman
of
19
Medicine
at
the
University
of
Chicago.
20
Previously
I
was
the
Chief
of
the
Pulmonary
at
21
Johns
Hopkins.
22
I'm
a
pulmonologist
by
training,
and
23
today
I'm
speaking
on
behalf
of
that
American
24
Thoracic
Society.
This
is
a
medical
professional
25
20
society
with
over
13,000
members
who
are
1
dedicated
to
the
prevention,
diagnosis,
treatment
2
and
research
of
respiratory­
related
illnesses.
3
The
American
Thoracic
Society
is
deeply
concerned
4
about
air
pollution,
both
as
an
underlying
cause
5
of
respiratory
illness
and
its
effect
of
6
exacerbating
existing
lung
disease.
7
The
ATS
has
significant
concerns
with
8
several
aspects
of
the
proposed
EPA
rule
for
9
particulate
matter
pollution.
My
colleagues
in
10
Philadelphia
and
San
Francisco
will
comment
on
11
our
concerns
with
the
PM2.5
PM2.5
and
PM10
12
standards.
I
would
like
to
focus
my
comments
13
today
on
the
integration
of
expert
opinion
into
14
the
rule­
making
process
and
the
need
for
15
additional
research
to
better
inform
future
rule
16
making.
17
It
is
the
strong
belief
of
the
American
18
Thoracic
Society
that
emission
standards
should
19
be
based
on
the
available
science
and
that
20
further
research
is
needed
to
address
the
many
21
persisting
uncertainties.
That
is
why
the
22
Society
supports
an
ongoing
research
agenda
to
23
continue
studying
and
answering
key
questions
24
related
to
particulate
air
pollution.
25
21
We
note
that
the
National
Research
1
Council
of
the
National
Academies
of
Science
2
recently
published
a
work
entitled
Research
3
Priorities
for
Airborne
Particulate
Matter
in
4
which
ten
key
priorities
were
identified.
Of
5
particular
importance
is
Research
Topic
No.
5,
6
The
Assessment
of
Hazardous
particulate
matter
7
components.
The
ATS
strongly
concurs
with
this
8
priority
and
calls
for
continued
research
support
9
from
the
EPA
and
other
federal
agencies
into
10
particulate
matter
research,
research
which
we
11
believe
will
better
inform
future
rule­
making
12
processes.
13
We
offer
the
following
recommendation:
14
That
EPA
use
the
framework
put
into
place
by
the
15
Research
Priorities
for
Airborne
Particulate
16
Matter
document
to
expand
and
fund
its
ongoing
17
research
portfolio
on
air
pollution.
18
While
the
ATS
strongly
supports
the
19
development
of
future
research
data
and
20
expertise,
we
are
extremely
concerned
that
the
21
EPA
is
not
fully
utilizing
available
data
in
this
22
expertise.
We
note
that
several
studies
have
23
shown
adverse
health
effects
from
exposure
to
24
PM
2.5
at
levels
below
the
average
annual
25
22
exposure
proposed
by
the
EPA
Administrator.
1
Additionally,
EPA
staff
experts
and
the
2
Clean
Air
Scientific
Advisory
Committee
have
3
recommended
lowering
the
annual
exposure
4
standards
to
below
15
micrograms
per
cubic
meter.
5
With
its
currently
proposed
standard,
6
the
EPA
is
effectively
ignoring
available
7
research
data,
ignoring
the
recommendations
of
8
EPA
Clean
Air
staff,
and
ignoring
the
experts
on
9
the
Clean
Air
Scientific
Advisory
Committee.
10
This
marks
the
first
time
that
the
expert
advice
11
has
been
ignored.
The
ATS
believes
discarding
12
the
available
science
and
the
advice
of
experts
13
is
an
ill­
advised
precedent
to
set
in
the
Clean
14
Air
Act
standard­
setting
process.
15
We
offer
the
following
recommendation:
16
The
EPA
should
issue
final
rules
for
particulate
17
matter
that
do
not
exceed
the
recommendations
18
provided
by
the
Clean
Air
Scientific
Advisory
19
Committee.
20
On
behalf
of
the
entire
membership
of
21
the
ATS,
I
would
like
to
thank
the
EPA
staff
for
22
this
opportunity
to
comment.
23
MR.
BURNETT:
Thank
you
very
much.
I
24
will
turn
to
my
colleagues
if
there's
any
25
23
clarifying
questions.
1
One
question
for
you.
We
have
in
the
2
preamble
to
the
proposed
rule
that
spelled
out
3
the
rationale
for
the
Administrator's
proposed
4
judgment,
and
I
would
be
interested
if
you
have
5
comments
on
that
particular
rationale
if
you're
6
able
to
provide
written
comments
to
that
affect.
7
DR.
GARCIA:
We're
happy
to
provide
8
written
comments
at
a
future
day.
9
MR.
BURNETT:
Thank
you.
10
MS.
NEKRITZ:
Good
morning.
My
name
is
11
Elaine
Nekritz,
N­
E­
K­
R­
I­
T­
Z.
I'm
a
state
12
legislator
representing
the
north
and
northwest
13
suburbs
of
Chicago
in
the
Illinois
House
of
14
Representatives.
I
currently
serve
as
the
Vice
15
Chair
of
the
House
Environment
and
Energy
16
Committee.
17
I
support
strong
air
quality
standards
18
at
levels
that
protect
public
health
and
are
19
applied
uniformly
across
the
country
and
across
20
industries.
21
Over
the
last
two
years,
I
have
22
sponsored
legislation
in
the
Illinois
General
23
Assembly
to
limit
excessive
idling
by
24
diesel­
powered
trucks,
buses
and
construction
25
24
equipment.
I'm
delighted
to
tell
you
that
the
1
legislation
is
moving
forward
with
strong
2
bipartisan
support.
But
through
that
process,
I
3
have
heard
from
numerous
people
throughout
the
4
Chicagoland
area
who
are
affected
by
soot
5
pollution.
6
There
are
folks
like
the
gentleman
from
7
Chicago
who
lives
near
a
grocery
store
where
the
8
trucks
idle
all
night
waiting
to
make
a
morning
9
delivery
while
the
exhaust
permeates
his
home
as
10
well
as
that
of
his
neighbors.
Or
the
woman
from
11
suburban
Glenview
who
works
at
a
local
school
and
12
each
day
watches
as
dozens
of
children
breathe
13
concentrated
exhaust
from
idling
school
buses
14
waiting
to
load
or
unload.
Or
one
of
my
15
colleagues
in
the
legislature
from
DuPage
County
16
who
wanted
to
know
whether
the
anti­
idling
17
legislation
would
prevent
trucks
from
running
18
their
engines
needlessly
in
a
local
parking
lot
19
while
waiting
to
head
out
for
the
day.
20
These
people
are
all
concerned
about
one
21
thing:
The
impact
to
their
health
from
air
22
pollution.
They
are
concerned
about
asthma,
23
lungs
disease
and
cardiovascular
disease.
They
24
are
not
scientists,
but
it
doesn't
take
a
25
25
scientist
to
know
that
breathing
that
polluted
1
air
is
bad
for
their
health.
2
Our
state
suffers
from
some
of
the
worst
3
fine
particle
pollution
in
the
nation,
and
our
4
public
health
statistics
reflect
our
poor
air
5
quality.
The
asthma
hospitalization
rate
in
6
Chicago
is
nearly
double
the
national
average.
7
Asthma
is
the
number
one
cause
of
school
8
absenteeism
due
to
a
chronic
illness
among
9
children.
And
our
death
rate
for
asthma
is
10
higher
in
Chicago
than
in
the
United
States
11
overall.
12
Illinois
cannot
fight
this
battle
on
its
13
own.
Particle
pollution
can
travel
long
14
distances
from
its
source,
and,
therefore,
we
15
need
strong
national
standards
to
help
us
fight
16
this
public
health
crisis
­­
strong
national
17
standards
that
include
an
annual
standard
no
18
higher
that
12
micrograms
per
cubic
meter
and
a
19
daily
standard
no
higher
than
25
micrograms
per
20
cubic
meter.
In
addition,
the
current
21
recommendation
to
eliminate
pollution
monitoring
22
in
small
and
mid­
sized
communities
and
to
exempt
23
agriculture
and
mining
from
control
requirements
24
should
be
rejected.
25
26
The
standards
must
be
based
on
science,
1
not
politics.
Under
the
Clean
Air
Act,
air
2
quality
standards
must
be
set
at
levels
that
3
protect
public
health,
including
the
health
of
4
sensitive
populations
within
an
adequate
margin
5
of
safety.
6
It
is
distressing
that
the
EPA
would
7
ignore
the
provisions
of
the
Clean
Air
Act
as
8
well
as
the
recommendations
of
its
own
9
independent
science
advisors
on
the
Clean
Air
10
Scientific
Advisory
Committee
in
favor
of
11
industry.
Certainly
the
history
of
the
Clean
Air
12
Act
demonstrates
that
when
we
as
a
nation
set
13
high
standards,
industry
finds
a
way
to
meet
14
them.
We
cannot
abandon
this
concept
that
for
15
over
30
years
has
provided
additional
protection
16
for
our
health
and
our
environment.
17
We
in
Illinois
are
working
to
protect
18
our
citizens
from
asthma,
lung
and
heart
disease
19
caused
by
particle
pollution.
We
want
air
that
20
is
clean
and
healthy.
However,
we
cannot
be
21
successful
if
our
partners
at
the
federal
22
government
fail
to
set
the
bar
high
enough.
We
23
hope
and
expect
the
EPA
to
adopt
air
quality
24
standards
that
provide
an
adequate
margin
of
25
27
safety
to
our
constituents.
Thank
you.
1
MR.
BURNETT:
Thank
you.
I
appreciate
2
your
comments
on
­­
and
your
actions
on
reducing
3
diesel
pollution.
It
is
one
of
the
priorities
4
for
U.
S.
EPA
for
the
same
reason
that
it
appears
5
to
be
a
priority
for
you.
And
I
would
just
like
6
to
say
that
I
appreciate
the
work
that
you're
7
doing.
8
I'll
ask
my
colleagues
if
they
have
any
9
clarification
questions.
10
Thank
you.
Thank
you
both.
11
Next
Mr.
Paul
and
Mr.
Maier.
12
MR.
PAUL:
My
name
is
John
Paul,
and
I'm
13
the
supervisor
of
the
Regional
Air
Pollution
14
Control
Agency
in
Dayton,
Ohio.
That's
Paul,
15
P­
A­
U­
L.
16
I'm
also
the
President
of
ALAPCO,
the
17
National
Association
of
Local
Air
Pollution
18
Control
Officials,
and
I
appear
today
on
behalf
19
of
STAPPA
and
ALAPCO,
the
national
associations
20
representing
state
and
local
air
pollution
21
control
agencies
throughout
the
country.
We
have
22
three
major
concerns
with
EPA's
proposal:
One,
23
the
levels
of
the
PM2.5
standards.
Two,
the
24
source
and
population
exemptions
associated
with
25
28
the
coarse
particulate
standard.
And,
three,
the
1
lack
of
funding
for
monitoring.
2
First,
we
find
it
troubling
that
EPA's
3
revisions
to
the
annual
and
daily
PM2.5
standards
4
are
outside
the
ranges
recommended
by
CASAC,
a
5
Congressionally
chartered
group
of
outside
6
scientific
experts.
7
While
CASAC
recommended
tightening
the
8
annual
PM2.5
standard
in
conjunction
with
9
lowering
the
daily
standard,
EPA
is
proposing
to
10
just
do
the
one
standard.
With
respect
to
the
11
annual
standard,
the
agency
proposes
no
changes
12
at
all,
even
though
CASAC
told
EPA
it
did
not
13
endorse
the
option
of
keeping
the
annual
standard
14
at
its
present
level.
Even
EPA's
own
staff
paper
15
indicates
that
more
deaths
from
fine
particulate
16
are
avoided
by
lowering
the
annual
standard
than
17
by
lowering
the
daily
standard.
18
With
respect
to
the
daily
standard,
19
while
CASAC
recommended
a
range
of
limits,
it
20
made
the
upper
end
of
the
range
conditional
on
21
tightening
the
annual
standard.
Regrettably,
EPA
22
has
chosen
the
upper
limit
of
CASAC's
23
recommendation
without
the
important
condition
of
24
tightening
the
annual
standard.
Unless
EPA
25
29
strengthens
its
proposal
consistent
with
the
1
recommendations
of
CASAC,
our
associations
are
2
concerned
we
will
continue
to
see
significant
3
increases
in
premature
mortality
and
adverse
4
health
effects
throughout
the
country.
5
Our
second
concern
with
EPA's
proposal
6
relates
to
the
coarse
PM
standard.
While
we
7
support
the
adoption
of
such
a
standard,
we
8
believe
that
EPA's
proposal
is
seriously
flawed
9
in
two
major
aspects.
We're
equally
troubled
10
that
the
proposal
exempts
from
control
major
11
sources
contributing
significantly
to
coarse
PM
12
emissions
including
agricultural,
mining,
and
13
other
sources
of
crustal
material.
Excluding
14
these
sources
implies
that
their
emissions
are
15
not
harmful.
Yet
EPA
does
not
present
any
such
16
evidence.
On
the
contrary,
it
is
likely
that
17
coarse
particulates
from
agriculture
and
mining
18
activities
pose
risks
similar
to
urban
coarse
PM.
19
These
exemptions
also
raise
serious
20
implementation
questions
for
state
and
local
21
agencies.
For
example,
are
mining
and
22
agricultural
activities
that
occur
in
or
near
23
urban
areas
to
be
exempted
from
controls
even
if
24
they
are
the
dominant
source
of
coarse
PM
25
30
emissions
in
the
area?
1
We're
also
concern
that
EPA's
proposed
2
coarse
PM
standard
has
the
practical
effect
of
3
ignoring
the
health
and
welfare
of
millions
of
4
people
throughout
the
country
living
in
areas
5
with
populations
less
than
100,000.
Exempting
6
these
areas
from
monitoring
is
an
unprecedented
7
action
and
completely
ignores
the
recommendation
8
of
CASAC.
Moreover,
we
do
not
believe
the
Clean
9
Air
Act
makes
any
provision
for
selective
10
protection
of
public
health.
Accordingly,
we
11
urge
EPA
to
rescind
these
exemptions
from
coarse
12
PM.
13
Finally,
while
it's
critical
that
EPA
14
establish
NAAQS
that
are
fully
protective
of
15
public
health
and
welfare,
it
is
also
vitally
16
important
that
we
have
adequate
monitoring
17
networks
that
allow
the
public
to
know
if
their
18
air
is
safe
to
breathe.
Unfortunately,
EPA's
19
proposal
and
its
fiscal
year
2007
budget
request
20
ignore
the
important
funding
issues
associated
21
with
deploying
and
operating
monitoring
networks
22
for
both
PM2.5
and
coarse
PM.
23
With
respect
to
PM2.5,
EPA
has
made
no
24
provision
to
increase
federal
funding
to
address
25
31
the
expanded
monitoring
requirements
for
the
new
1
standard.
In
fact,
the
President's
proposed
2
budget
for
fiscal
year
2007
slashes
fine
3
particulate
monitoring
by
$
17
million,
which
will
4
severely
weaken
existing
monitoring
programs
and
5
likely
result
in
significant
staff
cuts
6
throughout
the
country.
Agencies
will
have
7
serious
difficulties
rehiring
personnel
who
have
8
been
laid
off
as
a
result
of
these
budget
cuts
9
and
who
would
have
been
expected
to
operate
these
10
monitoring
networks.
We
urge
that
the
proposed
11
FY
2007
budget
cuts
be
restored
and
that
EPA
12
provide
funding
in
FY
2008
to
expand
the
PM2.5
13
monitoring
program.
14
We're
also
troubled
that
EPA
has
ignored
15
any
commitment
to
funding
the
proposed
coarse
PM
16
network
scheduled
for
deployment
in
FY
2008.
17
In
conclusion
we
strongly
recommend
that
18
EPA:
1)
follow
CASAC's
recommendation
in
setting
19
the
PM2.5
air
quality
standards.
2)
establish
a
20
coarse
particulate
standard
without
exemptions.
21
Three,
require
PM
monitors
in
rural
areas.
And,
22
4,
commit
to
providing
additional,
not
23
reprogrammed,
funds
for
PM2.5
and
coarse
PM
24
monitoring.
25
32
Thank
you.
1
MR.
BURNETT:
Thank
you
very
much.
2
Just
a
process
point.
We
are,
3
particularly
in
the
morning,
given
the
number
of
4
speakers,
are
going
to
try
to
limit
to
five
5
minutes.
6
I
do
have
a
clarifying
question.
7
Mr.
Paul,
you
said
that
you
have
evidence
of
8
similar
risks
posed
by
urban
coarse
particles
and
9
rural
coarse
particles.
We
have
proposed
what
we
10
have
proposed
for
two
reasons:
One,
that
there
11
appears
to
be
a
lack
of
evidence
for
rural
coarse
12
particles,
and
there
also
appears
to
be
some
13
evidence
of
a
lack
of
health
effects.
14
Wondering
if
you
could
clarify
what
you
15
mean
by
evidence
of
similar
risks.
16
MR.
PAUL:
In
our
ten­
minute
statement,
17
we
have
a
study
from
California.
So
we'll
18
provide
that
in
our
written
comments.
19
MR.
BURNETT:
Okay.
Thank
you.
20
MR.
MAIER:
Good
morning.
My
name
is
21
Bruno
Maier.
That's
M­
A­
I­
E­
R.
I'm
supervisor
22
of
the
Monitoring
and
Analysis
Unit
of
the
23
Regional
Air
Pollution
Control
Agency,
or
RAPCA,
24
in
Dayton,
Ohio.
25
33
RAPCA
is
one
of
nine
local
air
agencies
1
in
Ohio.
These
local
agencies
play
a
vital
role
2
in
Ohio,
protecting
the
health
and
welfare
of
our
3
citizens
by
implementing
measures
to
achieve
the
4
National
Ambient
Air
Quality
Standards,
which
5
include
the
fine
particulate
standards.
6
We're
working
on
a
full
review
of
EPA's
7
proposed
rule
regarding
revising
the
NAAQS
for
8
particulate
matter
and
will
submit
detailed
9
comments
at
a
future
date.
Today,
we
would
like
10
the
opportunity
to
present
to
you
our
most
11
pressing
concerns.
12
First,
let
us
state
our
complete
support
13
of
the
statement
of
John
Paul
which
he
delivered
14
on
behalf
of
STAPPA/
ALAPCO.
We
would
ask
EPA
to
15
pay
special
heed
to
the
STAPPA/
ALAPCO
comments
as
16
they
represent
the
comments
of
our
nation's
17
frontline
defenders
of
air
quality.
State
and
18
local
air
pollution
control
agency
directors
and
19
staff
take
very
seriously
the
finding
of
Congress
20
that
the
control
of
air
pollution
at
its
source
21
is
the
primary
responsibility
of
state
and
local
22
agencies.
23
The
RAPCA
area
is
currently
classified
24
as
nonattainment
for
the
PM2.5
standard
and
25
34
modeling
of
air
quality
in
2009
through
2010
1
shows
continued
nonattainment.
This
modeling
2
assumes
implementation
of
EPA's
Clean
Air
3
Interstate
Rule
and
various
mobile
source
4
emission
measures,
including
the
Heavy
Duty
5
Diesel
rule.
Modeling
for
all
Ohio
shows
even
6
more
severe
nonattainment
problems
in
the
future
7
for
the
Cincinnati
and
Cleveland
areas.
Clearly,
8
fine
particulates
are
a
significant
health
issue
9
to
our
area
residents.
10
It
is
with
significant
concern
that
we
11
find
the
suite
of
fine
particulate
standards
12
proposed
by
U.
S.
EPA
to
be
outside
the
ranges
13
recommended
by
both
the
Clean
Air
Science
14
Advisory
Committee
and
EPA's
own
staff.
The
15
combined
standards
EPA
proposes
of
15
micrograms
16
per
cubic
meter
annual
with
a
daily
standard
of
17
35
micrograms
per
cubic
meter
are
outside
of
what
18
the
health
science
experts
specifically
19
recommended.
This
is
very
disturbing
as
it
20
brings
the
standard­
setting
process
into
serious
21
question.
EPA
needs
to
protect
the
integrity
of
22
the
system,
either
by
following
the
advice
of
its
23
independent
science
advisors
or
by
giving
a
very
24
detailed
explanation
as
to
why
this
proposal
25
35
differs.
1
The
science,
as
amply
documented
in
the
2
docket's
supporting
information,
is
clear.
3
Thousands
of
scientific
studies
have
shown
that
4
fine
particulates
cause
serious
health
problems.
5
As
a
metropolitan
area
currently
listed
as
6
nonattainment
for
particulate
pollution,
we
are
7
particularly
concerned.
Based
on
what
the
8
science
tells
us
now,
our
residents
will
continue
9
to
be
at
risk
at
the
standard
levels
proposed,
10
especially
those
with
asthma,
cardiovascular
11
disease,
the
elderly,
children,
and
pregnant
12
women.
13
In
the
RAPCA
area,
transported
sulfur
­­
14
sulfate
predominates
the
PM2.5
concentrations
15
measured
on
high
days
in
the
summer
months.
16
Sulfates
appear
to
skew
the
annual
mean
above
the
17
standard.
We
believe
that
only
by
addressing
18
these
precursors,
through
either
a
more
19
significant
lowering
of
the
daily
standard,
or
20
alternatively
a
lowering
of
the
annual
standard,
21
will
we
be
adequately
able
to
protect
our
22
citizens'
hit.
23
Further,
EPA
has
taken
the
unprecedented
24
approach
of
excluding
emissions
from
certain
25
36
sources.
In
this
case,
agricultural
and
mining
1
sources
in
its
proposed
rule
making.
NAAQS
2
standards
are
intended
to
be
national
in
scope.
3
Yet
the
effect
of
this
proposal
will
be
to
4
exclude
rural
areas
from
the
standard's
health
5
benefit.
EPA
has
never
before
excluded
source
6
categories
from
control
in
proposing
a
NAAQS.
7
The
result
will
undermine
state
and
8
local
control
efforts.
The
identified
sources
9
will
likely
argue
against
regulation
as
EPA
has
10
indicated
there's
no
need
for
controlling
them.
11
The
effect
will
be
to
weaken
state
and
local
12
authority
and
discretion
in
regulating
emissions
13
from
these
sources
in
those
cases
where
further
14
control
would
bring
public
health
benefit.
15
We
are
also
concerned
with
EPA's
16
proposal
to
site
coarse
particulate
monitors
only
17
in
areas
with
a
population
of
100,000
or
more.
18
Is
EPA
proposing
that
the
health
and
welfare
of
19
rural
communities
is
not
important?
There
are
20
many
rural
areas
in
the
United
States
with
21
significant
industrial
sources
of
coarse
22
particulate
emissions.
We
need
to
site
monitors
23
and
measure
the
air
quality
of
such
areas.
24
Additionally,
as
a
local
agency,
we
are
25
37
concerned
with
the
lack
of
address
of
funding
1
issues
associated
with
the
proposal.
At
a
time
2
when
we
are
faced
with
major
issues
surrounding
3
the
attainment
(
sic)
of
the
current
standards
for
4
ozone
and
fine
particulate,
EPA
is
proposing
an
5
entirely
new
pollutant
(
PM
coarse)
to
be
6
monitored,
yet
is
ignoring
important
resource
7
issues.
And
to
make
the
situation
even
worse,
8
the
President's
proposed
budget
for
2007
cuts
9
state
and
local
funding
by
17
percent.
This
is
10
disheartening.
11
It
should
be
obvious
why
we
have
12
concerns
regarding
this
rule
proposal.
Without
13
following
the
recommended
standard
levels
14
proposed
by
the
scientific
advisors
and
your
own
15
staff,
it
appears
the
citizens
of
the
RAPCA
area
16
are
destined
to
breathe
unhealthy
air.
17
So
what
do
we
­­
18
MR.
BURNETT:
Mr.
Maier,
I
am
going
to
19
have
to
cut
you
off
in
the
interest
of
fairness.
20
I
apologize
for
that.
21
I'm
wondering
if
you
have
a
question
on
22
monitoring?
23
MR.
WEINSTOCK:
I
would
just
like
to
24
encourage
RAPCA
and
STAPPA/
ALAPCO
nationally
to
25
38
comment
on
all
provisions
in
the
monitoring
rule
1
as
well
as
the
NAAQS.
I
realize
the
coarse
2
particulate
monitoring
aspects
of
the
monitoring
3
rule
have
gotten
a
lot
of
attention,
but
there
4
are
a
lot
of
provisions
elsewhere
in
the
5
monitoring
rule
that
we
can
really
benefit
from
6
your
comments
on.
7
So
in
addition
to
that
aspect
of
it,
I
8
would
encourage
RAPCA
and
other
agencies
to
read
9
the
whole
rule
and
take
all
the
opportunities
10
they
can
to
comment.
11
MR.
MAIER:
We
will
include
comments
in
12
our
written
testimony.
13
MR.
WEINSTOCK:
Thank
you.
14
MR.
BURNETT:
Thank
you
both.
15
Now
I'd
like
to
request
that
Mrs.
Scott
16
and
Mrs.
Woodard
please
come
to
the
table.
17
Mrs.
Scott.
18
MS.
SCOTT:
Good
morning.
Thank
you
for
19
the
opportunity
to
testify
here
today.
My
name
20
is
Janea
Scott,
J­
A­
N­
E­
A,
and
last
name
21
S­
C­
O­
T­
T.
22
I'm
testifying
on
behalf
of
23
Environmental
Defense,
a
nonprofit,
24
nongovernmental,
nonpartisan
environmental
25
39
organization
with
more
than
400,000
members
1
nationwide.
Since
1967,
our
organization
has
2
linked
science,
economics,
and
law
in
tackling
3
environmental
problems.
4
I
want
to
begin
my
testimony
today
here
5
with
a
point
that
is
too
often
overlooked.
Our
6
National
Ambient
Air
Quality
Standards
are
7
effective.
They
work.
They
are
the
cornerstone
8
of
the
Clean
Air
Act,
and
they
have
successfully
9
driven
our
nation's
efforts
to
solve
its
air
10
pollution
problems.
Since
the
inception
of
the
11
NAAQS
in
1970,
the
concentration
of
lead
in
the
12
air
we
breathe
has
decreased
by
98.5
percent,
13
carbon
monoxide
and
sulfur
dioxide
by
14
approximately
50
percent,
and
particulate
15
pollution
by
about
75
percent.
At
the
same
time
16
that
this
pollution
has
decreased,
our
economy
17
has
flourished.
Since
1970,
our
GDP
has
grown
by
18
174
percent.
So
the
past
35
years
have
clearly
19
demonstrated
that
the
NAAQS
framework
can
make
20
our
air
safe
to
breathe
without
inhibiting
the
21
growth
of
our
economy.
22
Now,
however,
the
effectiveness
of
these
23
air
quality
standards
is
at
risk.
The
24
particulate
matter
standards
proposed
on
25
40
December
20,
2005,
fall
far
short
of
the
mandate
1
and
the
spirit
of
the
Clean
Air
Act
to
provide
2
clean,
healthy
air
for
all
Americans
with
an
3
adequate
margin
of
safety.
4
Since
1996
when
EPA
last
updated
the
5
NAAQS
for
particulate
air
pollution,
more
than
6
2,000
peer­
reviewed,
scientific
studies
have
been
7
published.
These
studies
validate
earlier
8
epidemiological
studies,
expand
the
list
of
9
health
effects
associated
with
PM,
and
identify
10
health
effects
at
lower
exposure
levels
than
11
previously
reported.
12
Conclusions
like
these
demand
prompt
13
action
to
protect
human
health.
But,
14
unfortunately,
EPA
has
proposed
standards
that
15
are
not
as
protective
as
those
recommended
by
its
16
own
career
scientists
and
its
independent
17
scientific
advisory
committee.
18
In
Chicago,
there
are
eight
counties
19
that
are
not
meeting
the
current
basic
public
20
health
standards
for
fine
particulates.
And
the
21
American
Lung
Association
in
its
State
of
the
Air
22
2005
report
ranked
the
Chicago
metropolitan
area
23
as
No.
13
on
a
list
of
the
top
25
U.
S.
cities
24
most
polluted
by
short
term
particle
pollution.
25
41
This
translates
into
more
than
214,000
cases
of
1
pediatric
asthma,
532,000
cases
of
adult
asthma,
2
and
278,000
cases
of
chronic
bronchitis
each
year
3
in
an
area
that
has
a
population
of
about
4
9.5
million.
5
The
Clean
Air
Act
has
been
a
model
of
6
success
in
reducing
environmental
threats
to
7
public
health.
A
number
of
factors
in
the
design
8
of
the
Act
have
contributed
to
the
success
9
including
the
principle,
upheld
by
the
Supreme
10
Court
in
2001,
that
the
setting
of
national
11
standards
be
based
solely
on
public
health
12
science.
Unfortunately,
the
proposed
standards
13
we're
discussing
today
fail
to
reflect
the
most
14
up­
to­
date
public
health
science
and
are
flawed
15
because
they
ignore
the
advice
of
EPA's
external
16
advisory
board
by
failing
to
adopt
a
sufficiently
17
protective
daily
standard
for
fine
particles.
18
Furthermore,
the
proposal
is
flawed
19
because
it
seeks
to
exclude
certain
populations
20
from
the
protection
of
the
NAAQS.
The
proposal
21
would
create
unprecedented
and
unjustified
22
exemptions
for
the
agricultural
and
mining
23
industries
and
carve­
outs
for
rural
areas.
This
24
means
that
Americans
living
in
rural
areas
or
25
42
places
with
a
population
of
less
than
100,000
1
will
not
be
protected
from
coarse
particles.
If
2
adopted,
this
proposal
would
be
the
first
time
in
3
the
history
of
the
NAAQS
that
protection
is
4
withheld
from
certain
groups
based
arbitrarily
on
5
the
size
of
the
community
in
which
they
live.
6
Therefore,
Environmental
Defense
7
strongly
urges
EPA
to
remove
the
categorical
8
exemptions
for
agricultural
and
mining
9
industries,
to
ignore
any
requests
by
other
10
industries
for
similar
exemptions,
and
to
apply
11
the
coarse
particle
standard
equally
in
all
areas
12
of
the
country.
13
National
Ambient
Air
Quality
Standards
14
are
supposed
to
be
based
on
the
most
current
15
science,
but
this
standard
is
not.
National
16
Ambient
Air
Quality
Standards
are
supposed
to
17
protect
all
Americans,
but
the
standard
in
this
18
proposal
does
not.
Therefore,
Environmental
19
Defense
calls
on
EPA
to
listen
to
its
science
20
advisory
committee
and
set
standards
that
protect
21
the
health
of
all
Americans
with
an
adequate
22
margin
of
safety
as
required
by
the
Clean
Air
23
Act.
This
includes
an
annual
fine
particle
24
standard
of
12
micrograms
per
cubic
meter,
a
25
43
daily
fine
particle
standard
of
25
micrograms
per
1
cubic
meter,
and
daily
coarse
particles
standard
2
of
30
micrograms
per
cubic
meter
applied
3
throughout
the
country.
4
Environmental
defense
is
going
to
submit
5
detailed
written
comments.
So
thank
you
for
the
6
opportunity
today.
7
MR.
BURNETT:
Thank
you
very
much.
8
A
related
question
to
one
that
I
asked
9
earlier.
If
you
have
particular
studies
on
10
your
­­
to
support
your
recommendation
for
the
11
coarse
particle
standard
to
apply
where
the
12
ambient
mix
is
dominated
by
sources
such
as
13
agriculture
and
mining
sources,
we
would
be
14
interested
in
such
studies.
As
you
may
note,
15
CASAC
and
staff
paper
both
recommended
a
standard
16
that
focuses
on
urban
areas,
and
we
would
be
17
interested
in
any
studies
to
support
your
18
recommendation.
19
MS.
SCOTT:
We'll
be
sure
to
get
those
20
in.
21
MR.
BURNETT:
Thank
you.
22
Mrs.
Woodard.
23
MS.
WOODARD:
Good
morning.
My
name
is
24
Julie
Woodard
­­
that's
W­
O­
O­
D­
A­
R­
D
­­
with
the
25
44
Dow
Chemical
Company,
and
I'm
here
on
behalf
of
1
the
American
Chemistry
Council.
2
We
believe
EPA
and
states
should
fully
3
implement
the
existing
fine
particle
standard
4
adopting
any
tighter
standards
such
as
those
5
proposed
on
January
17,
2006.
EPA's
existing
6
fine
particulate
standard,
through
a
series
of
7
significant
emission
control
programs,
will
8
continue
to
provide
necessary
protection
of
9
public
health
as
EPA
improves
their
understanding
10
of
fine
particulate
emissions.
At
this
time,
we
11
do
not
believe
the
scientific
evidence
supports
12
further
tightening
of
the
PM2.5
standard.
13
ACC
members
understand
and
value
the
14
importance
of
clean
air,
and
we
support
15
protecting
public
health
and
the
environment
as
16
demonstrated
by
this
industry's
significant
and
17
continued
progress
in
reducing
our
emissions.
18
Since
1988,
ACC
companies
and
the
broader
19
business
of
chemistry
have
reduced
air
toxic
20
emissions
by
75
percent,
nitrogen
oxide
by
21
62
percent,
volatile
organic
compounds
by
22
78
percent,
and
fine
particulate
emissions
down
23
34
percent.
24
More
broadly,
the
nation's
air
quality
25
45
has
significantly
improved
and
continues
to
1
improve
with
new
programs
being
implemented,
all
2
while
our
economy
continues
to
grow.
3
Between
1970
and
2004,
U.
S.
gross
4
domestic
product
increased
187
percent,
vehicles
5
miles
traveled
increased
is
171
percent,
energy
6
consumption
increased
47
percent,
and
U.
S.
7
population
grew
by
40
percent.
During
the
same
8
time
period,
total
emissions
of
the
six
criteria
9
of
air
pollutants
dropped
by
54
percent.
10
These
emission
reductions
were
driven
11
primarily
by
EPA
rule
makings.
These
rule
12
makings
will
continue
to
be
implemented
over
the
13
next
ten
years
and
include
the
2007
Clean
Diesel
14
Truck
and
Bus
Rule
and
the
Clean
Air
Interstate
15
Rule,
or
CAIR.
The
Clean
Diesel
Truck
and
Bus
16
Rule
will
result
in
diesel
truck
and
buses
being
17
95
percent
cleaner
than
today's
models
for
18
smog­
causing
emissions,
and
90
percent
cleaner
19
for
particulate
matter.
CAIR,
which
covers
29
20
eastern
status,
would
cut
SO2
by
more
than
40
21
percent
from
today's
levels
by
2010,
and
NOx
22
emissions
will
be
cut
by
50
percent
from
today's
23
levels
by
2010.
24
We
believe
that
EPA,
state,
and
industry
25
46
resources
are
already
being
taxed
by
these
1
emission
reduction
programs.
Adopting
new,
2
tighter
standards
for
fine
particulates,
when
the
3
implementation
of
the
existing
PM2.5
standards
4
are
barely
underway,
will
be
confusing
and
5
detrimental
for
achieving
fine
particulate
6
standard
attainment
as
states
struggle
to
meet
7
their
current
obligations.
8
States
are
just
beginning
to
design
and
9
implement
emission
reduction
tools
to
reach
the
10
current
PM2.5
standard
that
has
significant
11
deadlines
looming.
EPA
and
states
are
still
12
debating
rules
and
guidance
instructing
states
13
how
to
meet
the
current
PM
2.5
standards.
States
14
must
submit
attainment
plans
for
the
current
15
PM2.5
standard
by
April
2008.
16
EPA
should
allow
states
to
focus
on
17
fully
attaining
the
current
standards
before
18
making
the
states
plan
for
a
different
target
19
with
different
deadlines.
While
the
current
20
standards
are
being
achieved,
EPA
could
learn
21
more
about
health
risks
associated
with
22
particulate
matter
and
make
scientifically
sound
23
decisions
on
whether
further
action
is
needed.
24
This
would
also
allow
EPA
to
develop
an
25
47
understanding
of
what
part
of
the
PM2.5
1
constituent
may
be
contributing
to
adverse
health
2
effects.
3
Lastly,
I
want
to
mention
the
increased
4
energy
cost
of
tightening
standards.
We've
5
already
seen
firsthand
the
skyrocketing
cost
of
6
energy
in
this
country,
both
for
automotive
fuel
7
as
well
as
natural
gas,
which
is
increasingly
8
used
to
heat
our
homes
and
fuel
our
electricity
9
generating
capacity.
10
The
nation's
natural
gas
bill
was
over
11
$
200
billion
last
year;
while
in
1999,
it
was
12
just
over
$
50
billion.
Our
industry
share
of
13
this
total
is
$
30
billion.
According
to
the
14
National
Association
of
Manufacturers,
these
15
costs
are
a
major
reason
why
the
nation
has
lost
16
2.9
million
manufacturing
jobs
since
2000.
17
In
conclusion,
ACC
recommends
that
EPA
18
retain
the
current
PM2.5
standard,
and
not
19
tighten
the
standard
further
as
proposed
in
20
January
2006.
Implementation
of
the
current
21
standard
will
continue
to
provide
necessary
22
health
protection
as
EPA
works
to
understand
23
what,
if
any,
additional
actions
might
be
24
warranted
in
the
future.
25
48
Thank
you
very
much
for
your
time.
The
1
American
Chemistry
Council
will
also
be
2
submitting
detailed
technical
comments
prior
to
3
the
April
17th
closing
date.
4
MR.
BURNETT:
Thank
you.
5
I
have
one
clarifying
remark;
that
we
6
have
also
issued
an
advanced
notice
of
proposed
7
rule
making
that
addresses
some
of
the
8
transitional
issues
between
the
'
97
standards
and
9
the
standards
that
we're
discussing
today.
That
10
may
be
of
interest
to
you
and
others,
and
I
11
believe
that
there's
information
about
that
rule
12
making
in
the
registration
area.
13
I
then
just
have
a
clarifying
question.
14
You
said
that
the
­­
from
your
perspective,
the
15
current
standards
are
sufficient
to
protect
16
public
health.
I'm
wondering
if
you
have
17
comments
or
will
offer
comments
on
the
studies
18
that
we
looked
at
in
proposing
a
revision
down
to
19
the
35.
20
MS.
WOODARD:
Yes.
We
will
provide
that
21
in
our
more
detailed
comments.
22
MR.
BURNETT:
I'll
ask
our
panel
members
23
for
any
clarifying
questions.
24
Thank
you
very
much.
25
49
If
I
can
ask
Dr.
Schraufnagel
and
1
Dr.
Cohen
to
come
forward.
Thank
you.
2
DR.
SCHRAUFNAGEL:
I'm
Dr.
Dean
3
Schraufnagel.
I'm
a
Professor
of
Medicine
and
4
Pathology
at
the
University
of
Illinois
in
5
Chicago
and
also
on
the
Board
of
Directors
of
the
6
American
Lung
Association,
both
nationally
and
7
locally.
But
my
comments
today
would
be
more
in
8
keeping
with
my
role
as
a
chest
or
a
lung
9
specialist
and
the
patients
I
see.
10
When
I
greet
a
patient
with
lung
11
disease,
especially
with
advanced
lung
disease,
I
12
ask
them,
how
are
you
doing?
And
the
response,
13
if
they're
honest,
is,
almost
always,
well,
I
14
have
good
days
and
I
have
bad
days.
And
when
you
15
ask
them
a
little
more
carefully
about
what
the
16
bad
days
are,
they
will
often
tell
you,
well,
I
17
think
it's
the
weather.
I
think
it
might
be
the
18
humidity,
the
temperature.
And
it's
not
the
19
temperature
exactly,
but
I
think
it's
the
change
20
in
the
temperature.
Or
it's
­­
they're
never
21
quite
exactly
sure
how
it
is,
but
they
clearly
22
relate
it
to
the
environment.
23
Several
studies
that
you're
aware
of
­­
24
and
I
just
would
call
your
attention
to
the
one
25
50
that's
published
in
today's
JAMA
­­
relates
this
1
factor
to
the
air
pollution
and
particularly
the
2
particles
and
particularly
the
PM2.5s.
These
3
particles
and
the
levels
in
the
atmosphere,
as
4
you
know,
have
been
associated
with
excess
5
hospitalizations,
excess
deaths
compared
to
the
6
days
when
they're
normal.
7
Some
of
my
patients
will
say,
I
­­
on
8
today's
­­
the
weather
or
the
atmosphere
­­
the
9
pollution
is
so
bad
that
I
won't
go
out
today.
10
Now,
for
those
of
us
who
have
normal
lungs
or
for
11
me,
I
think
it's
just
an
ordinary,
hot
day.
I
12
really
don't
understand
how
they
can't
breathe.
13
But
for
them,
it's
really
a
matter
of
life
or
14
death.
15
So
I'm
encouraging
you
to
pass
the
16
stricter
laws
that
are
promulgated
­­
actually
17
that
are
advocated
by
the
American
Lung
18
Association.
Thank
you.
19
MR.
BURNETT:
Thank
you
for
those
20
comments.
21
Based
on
your
experience,
are
you
22
recommending
both
a
tightening
of
the
annual
and
23
of
the
daily
standards
for
PM2.5.
24
DR.
SCHRAUFNAGEL:
Yes.
I
would
do
the
25
51
12
micrograms
per
cubic
meter
for
the
annual
1
standard,
and
for
the
daily
standard
of
25
2
micrograms.
3
MR.
BURNETT:
Okay.
4
DR.
SCHRAUFNAGEL:
Per
cubic
meter.
5
MR.
BURNETT:
Thank
you.
6
DR.
SCHRAUFNAGEL:
Thank
you.
7
MR.
BURNETT:
Dr.
Cohen
­­
I'm
sorry.
8
MR.
WEINSTOCK:
Doctor,
I'm
just
9
curious.
Are
your
patients
aware
of
the
air
10
quality
forecasts
that
are
issued
through
the
11
AirNow
web
site?
Do
they
take
advantage
of
that?
12
MR.
BURNETT:
Some
of
them
are
and
some
13
of
them
are
not.
And
the
ones
that
are
do
notice
14
and
do
take
­­
some
of
them
take
care
and
stay
15
indoors
when
this...
16
I
might
say
that
these
are
not,
you
17
know,
like,
end
of
line.
These
are
sort
of
18
ordinary
people
that
are
working
and
­­
you
know,
19
but
they
just
have
­­
they
have
lung
problems.
20
But
they
are
aware
of
those,
yes.
Some
21
of
them
are.
22
MR.
WEINSTOCK:
Thank
you.
23
DR.
COHEN:
Hi.
I'm
Dr.
Bob
Cohen
from
24
Stroger
Hospital
of
Cook
County
that
was
formerly
25
52
known
as
Cook
County
Hospital.
I'm
the
Director
1
of
Pulmonary
Physiology
and
Rehabilitation
there
2
and
take
care
of
many
patients
with
advanced
lung
3
disease.
4
And
I'm
going
to
speak
also,
like
5
Dr.
Schraufnagel,
on
behalf
of
my
patients.
But
6
I
also
want
to
talk
­­
I'm
also
the
medical
7
director
of
the
National
Coalition
of
Black
Lung
8
and
Respiratory
Disease
Clinics
nationally,
which
9
is
a
group
that
is
a
coalition
of
10
federally­
funded
clinics
diagnosing,
treating,
11
and
caring
for
coal
miners
and
other
victims
of
12
occupational
lung
disease.
So
I
also
want
to
13
speak
to
the
separate
category
that
you
have
for
14
coarse
particles
in
rural
and
mining
areas
15
because
our
miners
and
other
workers
in
those
16
areas
are
going
to
be
affected
very
strongly
by
17
this.
18
I'm
not
going
to
speak
very
much
about
19
the
science
behind
this,
but
I
am
very
convinced
20
by
the
literature
that
you've
reviewed
and
in
21
general
about
the
relationship
between
PM2.5
and
22
PM10
on
increasing
respiratory
disease,
cases
of
23
asthma,
exacerbations
of
respiratory
disease,
24
cardiovascular
mortality,
and
all
causing
25
53
mortality.
1
But
my
patients
are
a
group
that
is
not
2
uncommon
with
very
particularly
sensitive
­­
not
3
only
because
of
their
advanced
lung
disease,
but
4
also
because
they
are
poor.
I
serve
5
African­
American,
Latino,
and
poor
white
6
populations
that
live
in
neighbors
that
actually
7
are
very
close
to
fossil­
fired
fueled
power
8
plants,
that
live
next
to
heavy
industry.
Many
9
of
my
patients
live
near
the
Dan
Ryan
or
10
Eisenhower
expressways
and,
therefore,
are
11
exposed
to
diesel
exhaust
particulate.
12
They
don't
have
garages
next
to
their
13
homes
with
air­
conditioned
cars
to
drive
to
nice
14
cool
gyms
to
work
out
or
to
exercise.
They
have
15
to
take
the
bus.
They
have
to
take
the
trains.
16
And,
therefore,
they
are
exposed
to
ambient
17
conditions
and
can't
protect
themselves
as
well
18
as
other
populations.
They
don't
live
in
19
beautiful
tree­
lined
streets
unfortunately
near
20
gorgeous
bodies
of
water.
21
So
my
patients
actually
are
often
22
imprisoned
in
their
homes
during
the
winter
23
because
of
our
Chicago
winters.
But
then
when
24
spring
and
summer
comes,
we
have
to
advise
them
25
54
often
that
they
cannot
go
out
and
exercise.
They
1
can't
even
do
their
activities
of
daily
living
in
2
terms
of
shopping
because
of
air
quality
3
concerns,
which
are
worse
for
them
because
of
the
4
differential
nature
of
the
microenvironments
that
5
they
live
in.
And
that's
a
huge
concern.
6
And
that's
why
it's
very
important
for
7
me
that
the
EPA
adopt
strict,
very
strict
8
standards,
not
only
to
protect
the
average
person
9
that
has
decent
incomes
and
can
take
care
of
10
themselves,
but
also
to
protect
the
most
11
vulnerable
members
of
our
society.
12
And
I
think
it's
very
important
­­
we
13
all
know
that
our
patients
exercise
and
­­
in
14
order
to
improve
their
life.
We
have
a
huge
15
problem
in
this
country
with
obesity
and
lack
of
16
exercise,
but
it
applies
particularly
to
patients
17
with
advanced
lung
disease
as
well.
Exercise
18
improves
quality
of
life
and
improves
­­
19
decreases
hospital
stays
and
numbers
of
20
admissions.
And
they
just
can't
do
that
because
21
of
air
quality
in
many
cases.
22
As
the
medical
director
for
the
Black
23
Lung
Clinics,
I
want
to
mention
that
we
have
24
23,000
users
in
our
federally
funded
clinics
25
55
nationally,
which
over
11
states,
including
1
Wyoming,
Montana,
Utah,
as
well
as,
you
know,
2
West
Virginia,
Kentucky,
and
Virginia
and
3
Appalachian
minor
states
that
we're
also
familiar
4
with.
5
We
think
­­
we've
had
a
lot
of
attention
6
recently
drawn
to
people
that
have
died
in
mining
7
disasters
like
the
Sago
miners
who
recently
died
8
from
overwhelming
carbon
monoxide
exposures
and
9
their
very
dramatic
deaths
from
rock
falls
and
10
roof
collapses.
But
we
don't
think
about
what
11
these
people
who
often
have
lung
disease
from
12
heavy
exposure
to
particulate
matter
during
their
13
occupation
careers
now
may
have
to
live
in
14
environments
in
their
rural
communities
that
are
15
going
to
have
­­
be
exempted
from
EPA
standards
16
under
the
new
proposed
regulations
and,
17
therefore,
already
suffering
from
chronic
lung
18
disease,
may
have
increased
episodes
of
mortality
19
and
chronic
bronchitis
and
the
other
associated
20
diseases
that
we
talked
about
because
of
the
21
protections
that
are
not
going
to
be
afforded
to
22
them
under
the
proposed
regulations.
23
So
we,
in
this
clinic,
are
very,
very
24
concerned
about
what's
going
to
happen
to
our
25
56
patients
in
the
clinics
in
these
rural
mining
1
areas.
They
all
live
in
environments
that
have
2
been
destroyed
in
many
cases
environmentally
by
3
the
mining
industry,
and
now
we're
worried
about
4
their
lungs
after
that.
5
So
in
summary
I
would
like
to
advise
the
6
EPA
to
lower
the
PM
standards
to
below
those
7
proposed.
And
I
agree
with
Dr.
Schraufnagel
of
a
8
12
microgram
per
cubic
meter
for
the
PM2.5,
and
a
9
24­
hour
daily
average
of
25
or
30
for
the
coarse
10
particulate
in
all
areas
of
the
country,
not
just
11
urban
areas.
12
Thank
you
for
allowing
me
to
make
my
13
comments.
14
MR.
BURNETT:
Thank
you.
15
And
one
question
for
you
so
that
I
16
understand
what
you're
saying.
You
know
that,
of
17
course,
EPA
does
not
regulate
the
occupational
18
exposure?
19
DR.
COHEN:
Of
course.
20
MR.
BURNETT:
But
what
I'm
hearing
you
21
say
­­
and
I
just
want
to
make
sure
that
I'm
22
clear
­­
is
that
these
individuals
are
23
particularly
vulnerable
to
the
ambient
24
concentrations,
and,
therefore,
we
should
pay
25
57
particular
attention
to
their
vulnerabilties
1
because
of
their
occupational
history?
2
DR.
COHEN:
Correct.
They
already
have
3
chronic
lung
disease
from
their
occupation.
They
4
have
retired.
They're
disabled.
Living
in
these
5
communities
that
have
mines
and,
therefore,
are
6
going
to
suffer
now
the
mines
getting
them
later.
7
MR.
BURNETT:
I
appreciate
your
8
comments,
and
I
thank
you
both.
9
Dr.
Dorevitch
and
Ms.
Clayborn,
please.
10
Is
Ms.
Clayborn
in
the
room?
11
Move
on
to
Mr.
DeSutter.
12
Doctor.
13
DR.
DOREVITCH:
Thank
you.
14
Good
morning.
My
name
is
Samuel
15
Dorevitch,
and
I'm
an
air
pollution
researcher
at
16
the
School
of
Public
Health
at
the
University
of
17
Illinois
at
Chicago
in
the
Divisions
of
18
Environmental
and
Occupational
Health
Sciences
19
and
in
the
Division
of
Epidemiology
in
20
Biostatistics.
21
MR.
BURNETT:
Excuse
me
for
one
second.
22
Do
you
need
a
spelling
for
his
name?
23
DR.
DOREVITCH:
D­
O­
R­
E­
V­
I­
T­
C­
H.
24
MR.
BURNETT:
Thank
you
very
much.
25
58
DR.
DOREVITCH:
Sure.
1
I
would
like
to
express
concerns
about
2
the
EPA's
proposed
revisions
to
ambient
air
3
monitoring
regulations
published
in
the
Federal
4
Register
on
January
17th,
2006.
5
Scientists
within
the
EPA
in
their
staff
6
report,
scientists
outside
of
the
EPA
on
the
7
Clean
Air
Scientific
Advisory
Committee
in
their
8
June
6,
2005,
letter,
and
a
hundred
independent
9
air
pollution
public
health
experts
in
a
10
December
5,
2005,
letter
have
provided
11
Administrator
Johnson
with
a
range
or
12
recommendations
regarding
lowering
the
PM2.5
13
standard
to
better
protect
the
health
of
the
14
public.
15
Unfortunately,
the
proposed
revisions
to
16
the
standard
fall
far
short
­­
are
short
of
the
17
thinking
of
experts
in
the
field.
The
EPA's
18
proposed
changes
fail
to
meet
its
obligation
19
under
the
Clean
Air
Act
to
protect
the
public
20
health
with
an
adequate
margin
of
safety.
21
As
interpreted
by
the
courts,
the
Clean
22
Air
Act
requires
that
air
quality
standards
be
23
set
solely
with
public
health
and
welfare
in
mind
24
and
without
consideration
of
economic
factors.
25
59
Although
the
EPA
was
not
convinced
by
1
the
recommendations
of
scientists
within
and
2
outside
of
the
agency,
I
would
like
to
add
to
the
3
body
of
evidence
being
evaluated
by
the
agency
4
the
results
of
three
research
studies
that
were
5
not
available
for
EPA
staff
at
the
time
they
6
produced
the
PM
criteria
document.
7
The
first
is
by
Dr.
James
Gauderman
and
8
colleagues
published
in
the
New
England
Journal
9
of
Medicine
in
September
2004.
Dr.
Gauderman
10
studied
children
in
12
cities
and
towns
in
11
California.
Those
who
lived
in
communities
with
12
higher
PM2.5
concentrations
had
less
lung
13
development
during
their
teenage
years
than
14
children
living
in
cities
with
lower
PM2.5,
even
15
though
the
annual
average
PM2.5
concentrations
in
16
a
majority
of
the
communities
studied
were
below
17
15
micrograms
per
meter
cubed.
And
in
five
of
18
the
12
communities,
the
average
was
below
10
19
micrograms
per
meter
cubed.
Not
only
was
lung
20
growth
diminished
in
relation
to
PM2.5,
but
there
21
was
no
suggestion
of
a
threshold
effect
at
15
22
micrograms
per
meter
cubed.
23
In
the
EPA's
2004
PM
criteria
document,
24
children
with
chronic
respiratory
disease,
such
25
60
as
asthma,
were
recognized
as
a
group
with
1
increased
susceptibilty
to
the
adverse
health
2
consequence
of
particulate
matter.
Distinct
from
3
susceptibility,
the
criteria
document
also
4
recognizes
the
concept
of
vulnerability:
That
5
reduced
access
to
health
care
or
living
close
to
6
roadways
with
heavy
traffic
put
groups
at
risk
7
for
the
negative
health
consequences
of
PM.
8
Here
in
Chicago,
rates
of
asthma,
9
particularly
among
African­
American
children
are
10
quite
high,
exceeding
25
percent
in
several
11
studies.
Many
of
the
cities'
children
with
12
severe
asthma
live
below
the
poverty
line
and
13
adjacent
to
heavy
traffic
on
Interstate
90­
94
on
14
the
south
side
and
Interstate
290
on
the
west
15
side.
Thus,
they
are
both
susceptible
as
16
asthmatic
children
and
vulnerable
to
the
limited
17
access
to
health
care
and
proximity
to
heavy
18
traffic.
As
these
children
develop,
they
need
19
every
bit
of
lung
growth
they
can
get
as
they
go
20
through
their
teenage
years.
21
The
finding
of
Dr.
Gauderman
and
22
colleagues
suggest
that
in
order
to
maximize
lung
23
growth
into
these
susceptible
and
vulnerable
24
children,
the
PM2.5
annual
standard
should
be
25
61
revised
to
a
level
substantially
lower
than
15
1
micrograms
per
meter
cubed.
2
The
second
study
I
would
like
to
3
highlight
is
by
Francesca
Dominici
and
colleagues
4
published
to
today's
issue
of
the
Journal
of
the
5
American
Medical
Association.
That
research
6
focused
on
hospitalizations
among
the
elderly
in
7
204
counties
across
the
U.
S.
In
those
counties,
8
the
average
annual
PM2.5
concentration
was
13.4
9
micrograms
per
meter
cubed,
lower
than
the
10
current
annual
standard
of
15.
Even
at
this
11
level
of
air
pollution,
day­
to­
day
fluctuations
12
in
PM2.5
were
associated
with
hospitalization
13
among
the
elderly
for
cardiac,
cerebrovascular
14
and
respiratory
disease.
15
Again,
a
group
recognized
by
the
16
criteria
document
as
being
susceptible
to
the
17
harmful
effects
of
PM,
this
time
the
elderly
was
18
found
to
have
life­
threatening
health
events
when
19
the
annual
average
PM2.5
concentration
was
20
typically
below
the
current
standard
of
15
21
micrograms
per
meter
cubed.
22
The
third
study
I'd
like
to
bring
to
the
23
attention
of
the
agency
is
that
by
Dr.
Francine
24
Laden
and
colleagues
to
be
published
in
the
25
62
March
15,
2006,
issue
of
the
American
Journal
of
1
Respiratory
and
Critical
Care
Medicine,
and
2
currently
available
electronically.
3
Dr.
Laden
and
colleagues
confirm
that
in
4
six
cities,
PM2.5
concentrations
were
associated
5
with
higher
death
rates,
even
during
a
nine­
year
6
period
in
which
four
of
the
six
cities
had
annual
7
average
PM2.5
concentrations
well
below
15
8
micrograms
per
meter
cubed.
Significantly,
they
9
also
demonstrated
that
a
10.5
micrograms
per
10
meter
cubed
reduction
in
PM2.5
concentrations
was
11
associated
with
a
73
percent
decrease
in
the
risk
12
of
death.
13
Taken
together
these
three
studies
­­
14
MR.
BURNETT:
I'm
going
to
have
to
ask
15
you
to
wrap
up.
16
DR.
DOREVITCH:
Okay.
17
MR.
BURNETT:
Thank
you.
18
DR.
DOREVITCH:
Taken
together,
these
19
three
studies
suggest
that
with
long­
term
average
20
concentrations
at
or
below
15
micrograms
per
21
meter
cubed,
PM2.5
is
harmful
to
children,
the
22
elderly,
and
that
the
risk
of
dying
can
be
23
reduced
substantially
if
PM2.5
concentrations
24
were
lower.
Lowering
the
acceptable
level
of
25
63
PM2.5
to
12
micrograms
per
meter
cubed
and
the
1
annual
standard
­­
for
the
annual
standard
and
to
2
25
micrograms
per
meter
cubed
for
the
24­
hour
3
standard
would
be
good
for
both
public
health
and
4
for
the
credibility
of
the
EPA's
commitment
to
5
protecting
it.
6
Thank
you
for
the
opportunity.
7
MR.
BURNETT:
Thank
you.
8
MS.
SASSER:
I
have
one
follow­
up
9
question.
Thank
you
for
the
additional
10
information
on
the
studies.
11
Did
you
mention
the
time
period
for
the
12
JAMA
study,
the
length
of
time
that
the
study
was
13
from?
14
DR.
DOREVITCH:
I
didn't
mention
it,
but
15
I
have
the
studies
in
front
of
me.
And
I
can
16
tell
you
that
now,
or
I
can
enter
them
into
the
17
record.
However
you
would
like
me
to
proceed.
18
MS.
SASSER:
If
there's
a
short
answer.
19
Is
it
a
multiyear
study
­­
20
DR.
DOREVITCH:
Yes.
1999
to
2002.
21
MS.
SASSER:
Thank
you.
22
DR.
DOREVITCH:
Sure.
23
MR.
BURNETT:
And
I
also
have
a
24
question.
25
64
On
these
studies,
you
have
­­
I
think
1
that
you
cited
the
annual
averages.
I'm
2
wondering
if
you
­­
if
the
studies
report
the
3
daily
values
and
what
sort
of
protection
that
4
these
populations
will
be
afforded
by
the
5
tightening
­­
proposed
tightening
of
the
24­
hour
6
PM2.5
standard.
7
DR.
DOREVITCH:
Well,
the
studies
8
themselves
don't
recommend
specific
numbers
in
9
terms
of
what
the
daily
24­
hour
average
standard
10
should
be.
They
do
provide
evidence
that
11
lowering
­­
especially
the
Laden
study
produced
12
evidence
that
lowering
PM2.5
concentrations
13
produces
decreases
in
the
mortality
rate,
but
the
14
studies
did
not
specifically
name
a
number
for
15
what
the
24­
hour
annual
average
standard
should
16
be.
17
MR.
BURNETT:
Okay.
Thank
you.
18
MR.
DeSUTTER:
Hello.
My
name
is
Randy
19
DeSutter.
I'm
vice
president
of
the
American
20
Soybean
Association.
I'm
from
Woodhull,
21
Illinois,
which
is
about
180
miles
west
of
here
22
and
30
miles
south
of
the
Quad
Cities.
23
My
first
part
of
the
testimony
I
want
to
24
tell
you
a
little
bit
of
what
it's
like
to
be
a
25
65
farmer
and
grow
soybeans,
and
then
the
second
1
part
will
be
a
little
more
technical.
2
I
farm
6,500
acres
with
my
family,
about
3
half
in
corn
and
half
in
soybeans.
So
that's
4
about
3,250
acres
each.
My
planting,
I
do
it
all
5
no
till,
which
means
there's
no
tillage.
I
plant
6
straight
into
last
year's
residue.
So
really
7
only
two
times
a
year
do
I
have
a
potential
to
8
create
dust:
That
being
at
planting
and
9
harvesting.
10
My
planter's
40
feet
wide,
and
I
can
do
11
about
20
acres
an
hour.
So
that
means
I
do
an
12
acre
about
every
four
minutes.
Now,
an
acre's
13
the
size
of
a
football
field
in
case
you're
not
14
sure
how
big
an
acre
is.
15
Harvesting,
that's
the
other
time
I
16
create
dust.
I
have
a
35­
foot
head
on
my
17
combine,
and
I
can
do
about
15
acres
an
hour.
So
18
that's
one
every
four
minutes.
19
Now,
if
you
add
this
up,
that's
about
20
seven
minutes
a
year
that
I'm
on
that
acre
maybe
21
creating
dust.
So
it's
very
minimal.
22
Another
thing,
when
you're
out
on
the
23
farm,
you
can
only
work
when
it's
dry.
You
can't
24
go
out
there
on
a
rainy
day
and
plant
because
25
66
your
planter
will
just
chock
up
with
mud,
and
1
you'll
compact
the
soil.
So
we
have
no
choice
2
but
to
be
out
there
when
it's
dry.
3
As
far
as
harvesting,
it's
the
same
way.
4
You
can't
go
out
into
a
muddy
field.
In
fact,
5
harvesting
soybeans
are
particularly
finicky.
6
You
can't
really
start
in
the
morning
until
the
7
dew
goes
off.
Because
if
it's
wet,
they're
8
tough,
they
won't
go
through
the
combine,
you'll
9
plug
your
combine.
And
the
same
thing
happens
at
10
night.
Once
it
gets
dark
and
the
dew
comes
on,
11
you
gotta
shut
down
because
you
can't
go
any
12
other
way.
13
I'd
be
willing
to
personally
extend
an
14
invitation
to
all
four
of
you
to
come
and
visit
15
my
farm
if
you'd
like
to
see
what
it's
like
out
16
there.
And
you
can
wear
your
suits.
We
have
17
climate
controlled
cabs.
I've
had
several
people
18
ride
in
my
combine.
I
take
school
children
in
my
19
combine.
We
have
a
farm
by
the
high
school.
And
20
you
wouldn't
get
dirty.
You
might
if
I
maybe
21
grease
the
combine
or
something,
but
not
just
22
riding.
23
I
think
if
you
­­
and
if
you
are
out
24
there
in
the
field,
you'll
see
that
the
dust
does
25
67
quickly
dissipate.
It
comes
out
behind
the
1
machine,
and
then
it
just
drops
down
pretty
2
rapidly.
3
I
just
question
the
need
to
regulate
4
agriculture
like
you
do
urban
areas
when
we're
5
there
so
little
time
and
there's
so
low
6
population
density
out
there.
I
mean,
there's
­­
7
a
lot
of
places
there's
not
houses
for
miles.
8
Now,
moving
on
to
some
of
the
more
9
technical
stuff.
The
Clean
Air
Act
requires
U.
S.
10
EPA
to
set
standards
to
limit
ambient
air
levels
11
of
designated
air
pollutants
including
12
particulate
matter.
Fugitive
dust,
which
these
13
measures
are
designed
to
control,
is
comprised
of
14
coarse
particulate
matter.
15
U.
S.
agriculture
supports
the
use
of
16
best
available
control
measures
by
its
members
17
and
the
agriculture
industry
to
control
this
18
particulate
matter.
19
Numerous
experts
have
raised
concerns
20
about
the
validity,
science,
and
rationale
for
a
21
coarse
PM
standard
at
this
time.
The
scientific
22
evidence
does
not
support
the
adoption
of
a
23
coarse
PM
standard
at
the
concentration
levels
of
24
the
existing
standard
or
those
proposed.
Such
a
25
68
regulation
would
impose
huge
costs
on
industries
1
that
emit
coarse
PM
and
provide
little
or
no
2
public
health
benefit.
Few
if
any
agriculture
3
operations
could
consistently
comply
with
the
4
current
or
proposed
standards.
5
A
coarse
PM
standard
study
should
not
be
6
promulgated
unless
or
until
research,
based
on
7
sound
science,
justifies
a
health­
based
standard.
8
Based
on
current
knowledge,
a
coarse
PM
standard
9
is
not
warranted
at
this
time.
10
The
attempt
to
separate
rural
11
particulate
from
urban
particulate
and
exclude
12
rural
dust
from
a
proposed
coarse
PM
standard
is
13
technically
difficult
to
institute
and
may
be
on
14
a
very
weak
legal
ground
within
the
context
of
15
the
Clean
Air
Act.
16
Significant,
long­
term,
peer­
reviewed
17
research
should
be
funded
to
determine
the
health
18
impacts
of
coarse
PM
for
both
urban
and
rural
19
particulate.
20
EPA
and
the
Clean
Air
Science
Advisory
21
Committee
agree
that
coarse
PM
health
science
is
22
weak,
and
additional
research
is
necessary.
23
Monitoring
the
proposal.
Initially
the
24
proposed
revisions
to
the
ambient
air
monitoring
25
69
sections
appear
reasonable.
It
is
imperative
1
that
the
five­
part
test
design
monitoring
rules
2
insure
effective
exclusion
of
excluded
emission
3
for
agricultural
sources,
and
other
sources
of
4
crustal
material
is
to
be
appropriately
5
implemented.
6
MR.
BURNETT:
Mr.
DeSutter,
I
apologize.
7
I'm
going
to
have
to
ask
you
to
wrap
up.
8
MR.
DeSUTTER:
That's
good
enough.
9
MR.
BURNETT:
Okay.
I
would
be
10
interested
in
your
comments
on
the
fine
PM
11
standards
if
you
have
any.
And
if
you
don't,
I
12
have
a
related
question
on
the
coarse.
13
MR.
DeSUTTER:
Well,
I
think
you
get
a
14
little
bit
of
fine.
Most
of
the
stuff
is
coarse.
15
Very
minimal
is
fine.
And
I
think
it
all
falls
16
out
with
the
coarse
when
you're
­­
you
know,
when
17
you're
combining
and
planting,
that
sort
of
18
thing.
19
MR.
BURNETT:
Okay.
On
the
coarse,
our
20
proposal,
as
you
know
and
as
you
articulated,
21
does
not
cover
agricultural
sources.
In
fact,
22
there's
an
explicit
exclusion
of
such
sources.
23
I'm
wondering
if
you
believe
that
and
will
offer
24
written
comments
for
your
statement
that
at
this
25
70
point
we
should
not
have
any
coarse
standard
even
1
in
covering
the
industrial
sources
and
2
traffic­
related
sources?
3
MR.
DeSUTTER:
I'm
going
to
turn
in
4
these
comments
written
here,
and
also
I
believe
5
the
National
Cattleman's
Association
is
kind
of
a
6
lead
ag
association
that's
done
a
lot
of
research
7
on
that,
and
they're
gonna
have
a
lot
more
8
in­
depth
studies
on
that
sort
of
thing
to
submit.
9
MR.
BURNETT:
Okay.
10
MS.
SASSER:
So
is
the
primary
concern
11
here
that
it
would
be
difficult
to
separate
out
12
agricultural
sources
that
may
be
near
urban
13
areas?
I'm
not
sure
that
I
understood
completely
14
what
the
concern
is
with
regard
to
the
exclusion
15
of
all
sources
versus
just
agricultural
sources.
16
MR.
DeSUTTER:
Well,
we're
concerned
17
that
agriculture
will
get
locked
in
with
18
everybody
else.
And,
you
know,
for
a
few
minutes
19
a
year,
you
know,
you­­
I
can't
combine
my
beans
20
unless
it's
dry.
You
know,
for
just
a
few
21
minutes
a
year,
we
just
don't
feel
that
that's
22
justifiable.
23
And,
you
know,
I
told
you
I
farmed
24
around
the
school.
You
know,
the
kids
come
out
25
71
and
ride
in
the
combine.
It's
­­
you
know,
if
1
you
stand
right
behind
it,
well,
yeah
you're
2
gonna
get
a
lot
of
dust.
But
kids
are
smarter
3
than
that,
and
people
are
smarter
than
that.
The
4
dust
quickly
dissipates
there.
They're
able
to
5
have,
you
know,
gym
classes
when
we're
out
there
6
planting
and
harvesting,
so
it's
not
a
big
deal.
7
I
don't
know
if
I
answered
what
you
8
wanted.
9
MS.
SASSER:
I
was
just
trying
to
get
a
10
better
understanding
of
given,
as
we
discussed,
11
the
standard
is
written
to
exclude
the
12
agricultural
sources
and
actually
said
we
will
13
not
regulate
those
sources
in
meeting
the
14
standard,
I'm
wondering
what
the
concern
is
from
15
the
standpoint
of
agricultural
source
as
the
EPA
16
has
currently
written.
17
Is
it
that
it
will
be
too
difficult
to
18
distinguish
what
contributions
come
from
19
agricultural
sources
versus
­­
20
MR.
DeSUTTER:
Well,
we
just
get
21
concerned
that
we'll
get
thrown
in
with
everybody
22
else,
and
we
want
to
make
sure
that
agriculture
23
isn't
thrown
in
with
all
industries
that
are
24
smokestacks,
that
are
going
24
hours
a
day,
365
25
72
days
a
year.
You
know,
for
our
seven
minutes
1
that
we're
out
there
planting
and
harvesting,
we
2
just
don't
feel
that
would
be
justified
to
go
3
after
agriculture.
4
MR.
WEINSTOCK:
I
guess,
sir,
I
would
5
just
clarify
that
the
proposed
coarse
particle
6
max
at
a
98
percentile
daily
standard
wouldn't
7
necessarily
be
impacted
by
a
few
minutes
a
year.
8
Several
days
would
have
to
go
back
that
could
be
9
high
and
still
be
within
the
proposed
standard.
10
On
a
daily
sampling
schedule,
that
would
be
like
11
a
sixth
or
seventh
average
in
the
year.
So
I
12
would
expect
a
few
minutes
of
activities
for
13
several
days
really
wouldn't
affect
the
standard
14
at
all.
15
MR.
DeSUTTER:
That's
good
to
hear.
16
Appreciate
it.
17
MR.
BURNETT:
Thank
you
both.
18
Next,
Ms.
Clayborn
and
Mr.
Suchecki.
19
MS.
CLAYBORN:
Hi,
my
name
is
Becki
20
Clayborn,
C­
L­
A­
Y­
B­
O­
R­
N.
Thank
you
for
this
21
opportunity
to
speak.
22
Again,
my
name
is
Becki
Clayborn.
I'm
a
23
regional
representative
for
the
Sierra
Club,
and
24
I
work
on
clean
air,
clean
energy
issues
in
25
73
Illinois
and
in
the
Midwest.
Sierra
Club
has
1
been
working
for
over
100
years
to
protect
our
2
environment
whether
we're
protecting
national
3
parks
from
development
or
protecting
people
from
4
pollution.
5
The
EPA's
new
proposal
to
limit
6
pollution
has
disappointed
us.
Since
last
7
updated
­­
since
the
EPA
last
updated
its
8
standard
in
1997,
more
than
2,000
scientific
9
studies
have
shown
that
exposure
to
even
smaller
10
amounts
of
soot
cause
serious
health
damage.
11
Scientist
urged
EPA
to
create
a
standard
in
12
keeping
with
the
deluge
of
scientific
findings
13
detailing
the
damaging
health
impacts
of
soot
14
pollution
on
the
respiratory
and
circulatory
15
systems
and
the
increased
risks
for
illness
and
16
death.
EPA
ignored
the
scientific
advisors
and
17
carved
out
weak
standards
riddled
with
loopholes.
18
The
Sierra
Club
supports
soot
standards
19
that
protect
sensitive
and
vulnerable
people
like
20
infants,
children,
those
with
asthma
or
cardiac
21
conditions,
and
the
elderly.
22
The
Sierra
Club
does
not
support
the
23
standards
proposed
by
EPA
because
they
are
too
24
weak
to
protect
all
people,
they
don't
provide
25
74
equal
protection
to
urban
and
rural
communities,
1
and
they
are
riddled
with
loopholes.
2
We
urge
the
adoption
of
a
soot
level
3
consistent
with
the
most
recent,
comprehensive,
4
and
reliable
scientific
evidence
and
is
5
protective
of
children,
elderly,
and
other
6
sensitive
people.
The
Club
supports
the
most
7
protective
option
evaluated
by
the
EPA,
which
is
8
the
12
micrograms
per
cubic
meter
of
annual
9
standard
and
the
25
micrograms
daily
standard
for
10
fine
particulate
matter.
11
We
oppose
the
weak
standard
currently
12
proposed
by
the
EPA.
13
Loopholes
woven
into
EPA's
proposed
rule
14
undermine
the
annual
particulate
soot
standard.
15
Under
the
98th
percentile
portion
of
the
rule,
16
data
for
a
certain
number
of
high­
pollution
days
17
is
allowed
to
be
excluded
from
the
calculation
of
18
the
annual
average.
In
practice,
this
means
that
19
air
quality
is
permitted
to
exceed
health­
based
20
standards
for
two
weeks
every
year.
21
Sierra
Club's
position
is
that
22
statistical
tricks
should
not
be
employed
to
undo
23
the
findings
of
thousands
of
scientific
studies
24
demonstrating
that
every
day
people
breathe
25
75
polluted
air
­­
that
every
day
people
breathe
1
polluted
air,
injury
may
occur.
The
EPA
should
2
close
this
loophole
and
require
that
every
day
is
3
a
good
air
day.
4
In
addition,
the
rule
does
not
protect
5
all
parts
of
the
nation
or
all
communities
6
equally.
EPA
has
proposed
that
the
National
7
Ambient
Air
Quality
Standards
should
apply
only
8
to
those
areas
or
populations
of
100,000
or
9
larger.
The
national
standard
would
then
only
be
10
an
urban
standard,
and
rural
areas,
towns,
and
11
small
urban
populations
would
be
left
12
unprotected.
13
Its
point
is
that
there
is
supposedly
14
benign
nature
of
the
rural
particulate
matter,
15
but
in
reality,
this
means
we're
exempting
16
mining,
agriculture,
and
a
lot
of
heavy
industry
17
from
the
Clean
Air
Act
and
encouraging
sloppy
18
operations
in
our
small
towns
and
rural
districts
19
and
denying
equality
to
small­
town
America.
20
Agricultural
sources
of
coarse
21
particulate
pollution
are
of
a
great
concern.
22
Farm
implements
kick
up
soil,
including
coarse
23
particulates,
and
we
should
be
­­
we
should
24
insure
that
the
general
public,
farmers,
farm
25
76
workers
and
farm
families
are
protected
from
1
diesel
exhaust,
particulates
of
manure,
bacterial
2
toxins,
and
pesticide
residue
which
may
be
3
associated
with
these
particulates.
4
In
addition
to
farming
in
rural
areas,
5
the
harsh
reality
is
that
the
rural
areas
also
6
host
some
of
the
heaviest
industrial
sources
of
7
coarse
particulate
matter
in
the
nation,
8
including
mines,
coal­
fired
utilities,
cement
9
plants,
and
steel
companies,
which
release
10
thousands
of
tons
of
particulate
pollution
11
annually.
12
These
rural
communities
should
benefit
13
from
the
scientific
advances
of
the
last
decade,
14
but
they
are
being
left
behind,
literally,
in
the
15
dust.
16
And
finally,
the
Sierra
Club
urges
the
17
adoption
of
the
24­
hour
standard
for
coarse
18
particulate
matter
set
well
below
that
which
has
19
been
scientifically
demonstrated
to
harm
human
20
health.
21
We
understand
the
EPA
is
moving
away
22
from
the
existing
PM10
standards,
which
is
all
23
particulate
matter
that
is
10
microns
or
less
to
24
a
more
definitive
standard
for
coarse
25
77
particulates
of
PM2.5
to
10.
This
transition
1
should
retain
an
annual
standard
for
coarse
PM
to
2
insure
protection
of
the
public
health.
3
The
Sierra
Club
urges
the
adoption
of
an
4
annual
standard
comparable
to
California's
PM10
5
standards
of
20
micrograms.
6
We
hope
that
our
comments
help
and
thank
7
you
for
your
time.
8
MR.
BURNETT:
Thank
you.
9
I
have
one
clarifying
remark.
For
the
10
annual
­­
the
proposed
daily
standard
is
at
98
11
percentile
form.
The
annual
standard
is
an
12
annual
mean
actually
averaged
over
three
years.
13
And
I
thought
that
I
heard
a
comment
about
the
14
exclusion
of
certain
days
for
the
calculation
of
15
the
annual
standard,
and
I
just
wanted
to
clarify
16
that
that's
not
the
case.
17
The
proposed
daily
standard,
and,
for
18
that
matter,
the
current
daily
standard
at
65
19
micrograms
per
cubic
meter,
is
proposed
to
be
at
20
98
percentile
form,
which
is
such
that
you
21
compare
the
98
percentile
day
with
the
level
of
22
the
standard
for
determining
an
exceedance
of
the
23
NAAQS.
24
Just
a
clarifying
remark.
Okay.
Thank
25
78
you.
1
MR.
SUCHECKI:
Good
morning.
I'm
Joe
2
Suchecki
­­
that's
S­
U­
C­
H­
E­
C­
K­
I
­­
Director
of
3
Public
Affairs
for
the
Engine
Manufacturers
4
Association.
EMA
is
the
international
trade
5
association
representing
the
major
manufacturers
6
of
internal
combustion
engines,
and
our
29
member
7
companies
manufacture
diesel,
gasoline,
and
8
alternative
fueled
engines
that
power
much
of
9
country's
transportation
and
distributed
10
electricity
generation
infrastructure.
11
EMA
has
closely
followed
PM
research
and
12
has
previously
submitted
comments
and
testimony
13
on
the
science
of
the
Criteria
Document,
Staff
14
Paper,
and
Risk
Assessment.
Our
interest
in
PM
15
is
based
on
frequently
cited
statements
that
16
heavy­
duty
diesel
engines
are
the
major
source
of
17
PM
in
the
nation
and
are
also
unregulated.
18
Neither
of
those
statements
is
true.
19
First,
if
you
look
at
EPA's
National
20
Emission
Trend
Report
for
2002,
that
report
21
actually
shows
that
PM2.5
emissions
from
all
22
diesel
sources
account
for
only
2.5
percent
of
23
the
total
PM
inventory
and
that
nationwide
diesel
24
emissions
have
declined
by
65
percent
between
25
79
1990
and
2002.
1
And
secondly,
diesel
engine
2
manufacturers
are
currently
implementing
3
solutions
that
will
reduce
PM
emissions
another
4
90
percent
from
today's
low
levels
to
meet
the
5
new
stringent
EPA
standards
for
on­
highway
and
6
nonroad
engines.
These
near­
zero
emissions
7
engines
will
start
entering
the
market
later
this
8
year
and
will
further
reduce
the
ambient
PM
9
levels
across
the
nation
regardless
of
any
new
10
action
on
the
PM
NAAQS.
11
Regarding
the
proposed
standards,
EMA
12
has
the
following
comments:
13
First,
today's
science
clearly
does
not
14
support
lowering
the
current
annual
PM
standard
15
of
15
micrograms
per
cubic
meter.
Despite
the
16
hundreds
of
millions
of
dollars
that
have
been
17
spent
on
PM
research
since
the
1997
standards
18
were
established,
there's
really
no
new
19
scientific
evidence
to
indicate
that
lowering
the
20
annual
standard
is
needed
to
protect
public
21
health.
22
New
information
on
long­
term
exposure
to
23
PM2.5
is
limited
to
several
epidemiology
studies
24
that
report
a
small
association
between
PM2.5
and
25
80
health
effects
at
ambient
PM
levels
above
the
1
current
standard,
but
even
these
results
are
2
confounded
and
complicated
by
the
interaction
of
3
other
pollutants,
effects
of
weather
and
4
temperature,
socioeconomic
factors,
and
even
the
5
various
statistical
models
that
are
used
for
the
6
analysis.
Importantly,
the
health
effects
7
associated
with
annual
PM2.5
levels
decrease
or
8
disappear
when
researchers
use
multiple
pollutant
9
studies,
thus
providing
evidence
that
reported
10
associations
may
not
actually
be
related
11
specifically
to
PM2.5
but
simply
to
the
ambient
12
mixture
off
all
pollutants.
13
There
is
no
demonstration
in
the
14
Criteria
Document
that
average
annual
15
concentration
of
PM
in
any
city
is
an
accurate
16
predictor
of
health
impacts
or
that
lowering
or
17
raising
the
annual
average
level
of
PM2.5
by
two,
18
three
or
even
more
micrograms
would
result
in
any
19
significant
change
to
human
health.
So
absent
20
any
significant
new
scientific
result
regarding
21
long­
term
effects
of
PM2.5,
maintaining
the
22
current
annual
standard
is
the
correct
decision.
23
Secondly,
EMA
supports
EPA's
decision
to
24
use
total
mass
as
the
indicator
for
PM2.5
as
25
81
opposed
to
selecting
a
specific
PM
component.
1
Despite
significant
research
efforts,
we
are
no
2
closer
today
to
identifying
the
constituents
of
3
ambient
PM
that
may
be
associated
with
health
4
effects.
Both
the
National
Research
Council
and
5
the
Health
Effects
Institute
have
concluded
that
6
there
has
been
little
progress
on
this
question
7
since
the
last
PM
review.
8
Until
the
time
that
this
or
any
other
9
research
identifies
a
clear
causal
association
10
between
a
health
outcome
and
any
PM
component,
11
there's
really
no
justification
to
regulate
12
specific
PM2.5
sources
or
components.
EPA
13
recognizes
this
fact
and
correctly
proposes
to
14
use
undifferentiate
PM
mass
as
the
indicator.
15
Third,
and
largely
based
on
our
lack
of
16
knowledge
on
the
health
effects
of
PM
components,
17
EMA
opposes
EPA's
proposed
urban
PM10­
2.5
coarse
18
particle
standard.
The
reason
is
that
there's
19
really
no
justification
for
establishing
a
coarse
20
standard
targeted
at
urban
areas
or
at
sources.
21
The
epidemiology
studies
of
coarse
22
particles
report
health
effects
from
both
urban
23
and
rural
locations.
Speculation
that
ambient
24
coarse
particles
are
more
harmful
in
certain
25
82
areas
has
no
basis
in
the
scientific
record.
1
Where
are
the
data
to
show
that
coarse
2
PM
a
metropolitan
area
or
an
area
with
a
certain
3
population
size
is
more
harmful
than
a
coarse
4
particle
collected
outside
that
boundary?
To
5
validate
EPA's
proposed
coarse
PM
standard,
one
6
is
forced
to
conclude
that
a
coarse
particle
7
emitted
from
a
facility
in
one
part
of
the
8
country
is
harmful,
but
a
coarse
particle
emitted
9
from
an
identical
facility
in
another
part
of
the
10
country
is
not
harmful.
11
So
there
is
really
no
scientific
or
12
legal
rationale
to
justify
applying
a
NAAQS
for
13
coarse
PM
to
certain
parts
of
the
country.
We
14
believe
that
approach
is
totally
arbitrary,
and
15
EPA
should
alter
its
coarse
particle
regulation.
16
And
I
think
just
to
say
that
finally
as
17
you
look
in
your
­­
at
your
final
decision,
we
18
really
believe
and
strongly
recommend
that
you
19
really
need
to
look
at
the
science
here
and
make
20
the
logical
and
appropriate
decisions
as
you
21
consider
these
final
standards.
22
Thank
you
for
the
opportunity
to
speak
23
today.
24
MR.
BURNETT:
Thank
you.
I
have
a
25
83
clarifying
question.
1
Your
opposition
to
the
proposed
coarse
2
standard,
is
your
recommendation
­­
would
you
3
mind
restating
what
your
recommendation
is.
4
MR.
SUCHECKI:
Well,
we
don't
think
that
5
there's
any
evidence
to
really
state
that
coarse
6
particles
in
urban
areas
or,
as
the
proposal
7
states,
coarse
particles
from
traffic
or
certain
8
industrial
sources
are
really,
you
know,
any
more
9
or
less
toxic
or
harmful
than
coarse
particles
10
from
other
areas.
And
I
think,
you
know,
that
­­
11
there's
been
a
lot
of
discussion
this
morning
12
about
taking
the
recommendations
of
CASAC.
And
13
the
idea
of
this
differential
coarse
particle
14
standard
was
actually
hatched
at
a
CASAC
meeting,
15
and
I
think
they're
the
ones
who
recommended
that
16
EPA
take
this
approach.
And
we
disagreed
with
17
it,
and
I
know
a
lot
of
the
environmental
and
18
lung
associations
disagreed
with
it.
19
In
terms
of
what
we
would
recommend,
I
20
think
EPA
just
needs
to
go
back
and
take
a
look
21
to
see
if
there's
enough
information
in
the
22
science
to
come
up
with
some
standard
for
coarse
23
particles.
We
don't
have
a
specific
24
recommendation
on
that.
Obviously,
we
believe
it
25
84
should
be
uniform
across
the
nation,
and
you
1
should
take
a
look
and
see
if
there's
enough
2
information
to
develop
one
at
this
point
in
time.
3
MR.
BURNETT:
Thank
you.
4
MR.
WEINSTOCK:
Does
EMA
have
a
position
5
on
the
proposed
tightening
of
the
fine
particle
6
daily
standard?
If
I
recall,
your
comments
7
addressed
long­
term
effects
and
the
annual
8
average
specifically.
I
don't
recall
hearing
any
9
recommendations
for
the
daily
standard.
10
MR.
SUCHECKI:
Right.
We
­­
obviously,
11
you
know,
the
basis
of
a
lot
of
our
comment
is
12
that
certainly
at
the
bulk
of
the
scientific
work
13
that
has
been
done
has
been
on
examining
the
14
daily
standards
and
the
short­
term
standards
of
15
health
effects.
And
that's
where
a
lot
of
new
16
research
has
come
in,
and
we
have
a
lot
more
17
information.
18
And
it
appears
that,
you
know,
there
is
19
justification
there
that,
you
know,
there
is
a
20
connection
between
short
term
and
standard
­­
21
short­
term
health
effects
and
PM
that,
you
know,
22
we
did
not
have
the
information
for
before.
We
23
really
don't
have
a
specific
relation
on
that.
24
The
problem
is
that
the
data
is
so
I
think
25
85
uncertain
at
this
point
in
time
as
to
what
that
1
standard
would
be.
So
we
really
don't
have
a
2
recommendation
on
the
specific
24­
hour
standard.
3
MR.
WEINSTOCK:
Thank
you.
4
MR.
BURNETT:
Thank
you
both
for
your
5
comments.
6
I
would
like
to
request
that
7
Dr.
McColley
and
Ms.
Owen
please
come
up
to
the
8
table.
9
DR.
McCOLLEY:
My
name
is
Dr.
Susanna
10
McColley,
M­
c­
C­
O­
L­
L­
E­
Y.
I'm
here
today
11
speaking
as
a
private
citizen,
but
I
do
feel
that
12
I
have
some
credentials
that
give
me
some
13
expertise
in
this.
I'm
a
long­
term
resident
of
14
the
City
of
Chicago.
I'm
a
granddaughter
and
a
15
great
niece
and
will
tell
you
why
that's
16
important
in
a
minute.
17
I'm
a
division
head
of
pulmonary
18
medicine
at
Children's
Memorial
Hospital
here
in
19
Chicago.
I
am
a
medical
school
faculty
member
at
20
Northwestern
University
Feinberg
School
of
21
Medicine.
And
I'm
a
taxpayer.
I'm
also
a
22
long­
standing
member
of
the
American
Thoracic
23
Society,
and
I
have
served
second
on
its
Board
of
24
Director
and
currently
chair
it's
strategic
25
86
planning
process.
I'm
a
former
member
of
the
1
American
Academy
of
Pediatrics,
Pulmonary
section
2
Executive
Committee,
and
I'm
a
former
member
of
3
the
Medical
Advisory
Council
for
the
Cystic
4
Fibrosis
Foundation.
5
I
would
like
to
start
with
a
personal
6
story
that
has
to
do
with
the
health
of
my
7
grandfather
and
my
great
aunt.
They
both
8
suffered
from
ischemic
heart
disease
and
they
9
developed
it
relatively
early
in
life
in
their
10
sixties.
My
aunt
also
suffered
from
chronic
11
obstructive
pulmonary
disease.
We
tend
to
think
12
of
these
disorders
as
being
lifestyle
disorders,
13
things
that
you
can
avoid
by
having
a
healthy
14
lifestyle.
In
fact,
neither
of
them
smoked
15
cigarettes,
neither
were
ever
overweight,
neither
16
ever
had
a
measurably
elevated
serum
cholesterol
17
level.
18
What
they
shared
was
that
they
were
19
long­
term
residents
of
Los
Angeles,
and
they
20
lived
in
Los
Angeles
in
the
1950s
and
1960s
when
21
air
pollution
and
particulate
air
pollution
were
22
the
highest
that
they
have
been
in
our
nation's
23
history.
And
in
fact
to
the
extent
that
24
particulate
matter
air
pollution
has
decreased
in
25
87
some
communities,
I
do
give
you
my
appreciation.
1
As
a
resident
of
the
City
of
Chicago
and
2
the
mother
of
two
young
boys,
I
worry
about
the
3
health
consequences
of
air
pollution
every
day.
4
I
know
that
particulate
matter,
particularly
fine
5
particulate
matter
in
air
pollution,
causes
6
inflammation
in
the
heart
and
in
the
lungs,
and
7
this
occurs,
not
only
in
people
with
chronic
8
illness,
but
in
healthy
people.
9
In
experiments,
healthy
people
exposed
10
to
diesel
exhaust
develop
inflammation
of
the
11
airways
that's
very
similar
to
people
who
have
12
chronic
asthma.
Exposure
to
high
levels
of
13
particulate
matter
have
been
shown
to
impair
lung
14
development
in
children,
and
lung
development
15
stops
at
about
the
age
of
eight.
And
once
you
16
lose
that
lung
development,
you
cannot
get
it
17
back.
There's
more
and
more
evidence
now
that
18
early
insults
to
the
developing
lung
are
carried
19
through
life
and
are
a
cause
of
lung
disease
in
20
adults.
21
I
want
my
family
to
be
physically
22
active.
We
like
to
go
out.
We
ride
our
bikes
on
23
the
lakefront
path
and
we
run,
but
I
worry
about
24
the
effect
of
breathing
that
air
as
we're
out
and
25
88
about.
I
myself
developed
exercise­
induced
1
asthma
a
couple
of
years
ago
when
training
for
2
the
Chicago
Triathlon.
3
I
am
concerned
about
my
own
health
and
4
that
of
my
family.
But
we're
lucky.
We
don't
5
have
any
serious
chronic
illnesses.
As
a
6
pediatric
pulmonologist,
I
worry
a
lot
more
about
7
the
children
who
I
treat
every
day
at
Children's
8
Memorial
Hospital.
These
are
children
with
9
severe
illnesses
like
cystic
fibrosis
and
asthma.
10
Very
simply
put,
children
who
have
these
diseases
11
are
more
likely
to
be
hospitalized
and
have
worse
12
lung
function
if
they
live
in
areas
with
high
13
levels
of
air
pollution.
And
the
science
on
this
14
is
strong.
15
Chicago
is
No.
14
in
the
country
in
16
particular
matter
air
pollution.
We're
No.
1
in
17
asthma
mortality.
I
think
that
these
are
18
related,
and
we
know
that
children
here
die
of
19
asthma.
Just
this
week,
I
lost
a
six
year
old
20
for
severe
­­
to
severe
cystic
fibrosis
lung
21
disease.
22
We
know
that
there
is
a
linear
23
correlation
between
particulate
air
pollution
24
levels
and
death
rates
and
that
there
are
25
89
estimated
to
be
about
half
a
million
deaths
per
1
year
around
the
world
due
to
air
pollution
and
2
close
to
5,000
in
this
country.
This
is
3
compelling,
and
I
just
want
to
remind
you
that
4
some
of
these
deaths
are
going
to
be
the
deaths
5
of
children.
6
As
a
faculty
member
of
Northwestern
7
University
Feinberg
School
of
Medicine
and
as
an
8
active
member
of
the
professional
societies
that
9
I
mentioned,
I
believe
that
the
application
of
10
scientific
methodology
is
our
best
hope
to
11
improve
the
health
of
individuals
and
the
greater
12
public.
Epidemiology
and
clinical
studies
are
13
very
difficult
science,
and
it
takes
a
long
story
14
to
be
sure
of
something.
But
we
have
over
2,000
15
published
articles
since
1996
stressing
the
16
correlation
between
air
pollution
and
health
17
problems.
This
is
strong
scientific
evidence,
18
and
the
Environmental
Protection
Agency
staff
and
19
the
Clean
Air
Scientific
Advisory
Committee
have
20
reviewed
this
evidence
and
have
recommended
a
21
stricter
standard
for
air
pollution,
and
22
particularly
for
fine
particulate
matter.
23
The
American
Thoracic
Society
and
the
24
American
Academy
of
Pediatrics,
along
with
other
25
90
professional
organizations,
also
recommend
a
1
stricter
standard:
Specifically,
21
microns
per
2
cubic
meter
for
the
average
annual
standard,
and
3
25
for
the
24­
hour
standard,
and
compliance
4
determined
at
the
99th
percentile.
I
fully
5
support
these
scientifically­
based
standards.
6
As
a
taxpayer,
I
just
also
want
to
7
stress
­­
8
MR.
BURNETT:
I'm
going
to
have
to
ask
9
you
to
wrap
up,
Ms.
McColley.
10
DR.
McCOLLEY:
All
right.
11
MR.
BURNETT:
Thank
you.
12
DR.
McCOLLEY:
I
was
just
at
the
end.
13
We
need
a
reasonable
margin
of
safety.
14
It's
in
the
law.
Thank
you.
15
MR.
BURNETT:
Thank
you.
And
I'd
like
16
to
offer
my
condolences
to
you
and
the
family
of
17
your
patient.
I
am
sorry
to
hear
that.
18
DR.
McCOLLEY:
Thank
you.
19
MR.
BURNETT:
I
have
a
question
about
­­
20
you
mentioned
experiments
with
respect
to
diesel
21
exhaust
and
exposure
to
healthy
individuals.
22
Wondering
if
you
are
offering
in
your
written
23
comments
the
specifics
of
which
studies
­­
I
24
assume
these
are
the
CAP
studies,
but
which
25
91
studies
in
particular
are
you
referring
to
there?
1
DR.
McCOLLEY:
These
studies
have
been
2
referenced
in
the
American
Thoracic
Society
3
position
and
in
a
recent
editorial.
I
don't
have
4
all
those
­­
I
didn't
want
to
bring
a
huge
pile
5
of
paper
with
me,
but
I
do
have
them,
and
I
can
6
provide
them,
and
I
believe
that
they
have
been
7
provided
by
these
other
organizations.
8
MR.
BURNETT:
Okay.
I
just
want
to
make
9
sure
the
studies
are
in
the
record.
We
are
10
for
­­
everybody
should
know
that
we
will
be
11
doing
what
we
refer
to
as
a
provisional
12
assessment
of
new
science
that
has
come
in
and
13
are
particularly
interested
in
any
new
studies
14
that
may
be
submitted
during
the
public
comment
15
period.
16
Thank
you
for
your
comments.
17
DR.
McCOLLEY:
Thank
you.
18
MS.
OWEN:
Good
morning.
My
name
is
19
Verena
Owen,
and
I
don't
blame
you
for
not
trying
20
to
pronounce
that.
21
I've
sat
on
your
side
of
the
table
a
22
couple
of
times
at
EPA
hearings,
so
I
appreciate
23
the
challenges
of
the
job
and
thank
you
for
24
providing
us
an
opportunity
to
address
you.
25
92
I
had
the
privilege
to
work
with
EPA
1
over
the
last
two
years
on
a
major
project,
and
I
2
want
to
make
sure
that
my
remarks
today
are
not
3
aimed
at
them.
There
are
really
good
folks
4
working
for
the
agency.
My
remarks
are
aimed
at
5
those
who
want
to
play
politics
with
public
6
health.
7
Let
me
start
with
a
personal
story.
You
8
may
hear
that
I
wasn't
born
in
this
country.
I
9
immigrated
about
20
years
ago,
and
I
met
my
best
10
friend
in
an
aerobics
class.
She
had
just
had
11
her
first
child,
and
I
just
had
my
second,
and
12
she
was
a
wonderful
person.
We
both
ended
up
13
having
four
boys,
and
you
can
just
imagine
what
14
our
get­
togethers
were
like.
15
She
was
diagnosed
with
lung
cancer
after
16
her
last
child
was
born.
She
never
smoked
a
day
17
in
her
life.
And
she
was
35.
She
died
before
18
her
youngest,
Matthew,
went
to
kindergarten,
and
19
she
never
saw
Bill
graduate
from
high
school.
20
When
I
hear
about
premature
deaths
and
21
what
soot
causes,
this
is
what
I
see.
And
I
want
22
to
put
a
face
on
it
for
you
too.
23
Therefore,
I
am
outraged.
I
am
truly
24
outraged
that
EPA
would
even
contemplate
rules
25
93
that
would
not
be
protective
of
public
health
and
1
ignore
scientific
evidence.
You
know
what
the
2
health
threats
are.
Soot
is
a
lethal
form
of
3
pollution,
and
don't
think
that
we
don't
know
4
that
either.
5
I
am
the
Clean
Air
Campaign
Chair
for
6
the
Illinois
Chapter
of
the
Sierra
Club.
The
7
Illinois
Chapter
has
28,000
members
in
Illinois.
8
Thousands
of
our
members
live
in
areas
that
do
9
not
meet
the
National
Ambient
Air
Quality
10
Standards.
11
We
believe
that
every
day
and
every
12
where
should
be
a
clean
air
day.
Seems
pretty
13
straightforward
goal
for
a
clean
air
campaign,
14
and
we
have
been
over
the
last
two,
three
years
15
working
very
diligently
towards
that
goal.
We
16
have
challenged
permits
for
major
sources
of
17
pollution
that
did
not
have
an
adequate
best
18
available
retrofit
technology
determination
for
19
particulate
matter.
We
have
fought
to
have
20
condensables
be
considered
a
part
of
a
BART
21
analysis,
and
we
have
petitioned
the
22
administrator
reject
the
permits
that
do
not
23
include
parametric
monitoring
ranges
for
PM
24
compliance
for
the
23
major
coal­
fired
power
25
94
plants
in
the
state.
1
Speaking
of
the
administrator,
in
a
2
phone
interview
that
the
transcripts
were
3
available
on
EPA's
web
site,
Mr.
Johnson
said
of
4
the
new
rules,
"
This
is
a
proposal.
We
are
5
beginning
a
public
process.
There
are
divergent
6
views,
and
I
will
base
my
ultimate
decision
on
7
best­
available
science."
8
Okay.
A
bit
disappointing
that
the
9
first
round
of
rules
did
not
live
up
to
the
10
based­
on­
science
edict
he
has,
but
it's
not
too
11
late
to
fix
it.
So
let
him
get
right
the
second
12
time
around,
please.
13
No
loopholes.
You're
still
working
on
14
the
loopholes
from
the
1970s,
folks,
okay.
15
Don't
discriminate
against
people
in
16
rural
areas
and
small
towns.
Fund
more
17
monitoring.
18
And
lastly,
adopt
fine
and
coarse
19
particulate
matter
standards
that
are
based
on
20
scientific
evidence
that
are
protective
of
all
21
public
health,
including
children,
the
elderly,
22
and
the
sensitive
populations.
And
I
thank
you
23
for
your
time.
24
MR.
BURNETT:
Thank
you.
And
I
want
to
25
95
similarly
express
my
condolences
for
your
friend
1
and
for
that
story.
It
is
one
of
the
major
2
reasons
why
we're
working
aggressively
on
3
particulate
matter
and
why
we
have
proposed
a
4
tightening.
I
understand
your
comments
and
your
5
recommendations
for
a
tighter
standard
still,
and
6
I
appreciate
your
remarks.
7
Anyone
have
questions?
8
Thank
you
both.
9
MR.
BURNETT:
Mr.
Gard
and
Ms.
Casten,
10
please.
11
MR.
GARD:
Good
morning.
David
Gard,
12
G­
A­
R­
D.
13
Thank
you
very
much
for
this
opportunity
14
to
express
our
views.
I
represent
a
group
called
15
the
Michigan
Environmental
Council,
and
we
are
a
16
group
of
72
member
organizations
around
the
State
17
of
Michigan.
We
have
groups
such
as
the
American
18
Lung
Association
of
Michigan,
and
10,000­
member
19
Michigan
Nurses'
Association,
and
many
others.
20
Total
individuals
in
our
coalition
number
about
21
200,000,
so
I'm
really
here
on
their
behalf
22
today.
And
I
will
also
say
that
my
remarks
here
23
will
be
supplemented
by
filed
comments
that
I'll
24
submit
electrically
later.
25
96
Basically
the
people
in
our
coalition
1
are
extremely
troubled
by
the
proposal
as
has
2
been
laid
out
in
December.
Like
many
other
3
people
today
across
the
country,
I
am
devoting
4
this
entire
day
to
come
here
and
offer
five
5
minutes
of
comment
because
this
is
such
an
6
important
issue.
And
we
really
just
want
to,
you
7
know,
make
it
clear
­­
get
the
clear
message
8
across
to
the
agency
that
people
around
this
9
region
are
extremely
dissatisfied
with
the
10
proposal.
11
Last
September,
the
Detroit
Free
Press
12
highlighted
at
least
the
cases
of
asthma
in
13
Michigan,
pointing
out
that
nearly
nine
percent
14
of
the
people
in
Michigan
have
asthma,
over
15
800,000
people,
many
of
those
in
Southeast
16
Michigan­
Detroit
area.
And
Michigan
ranks
fourth
17
in
the
country,
as
you
probably
know,
but
this
is
18
beyond
just
asthma,
as
bad
as
those
numbers
are.
19
This
is
about
a
number
of
other
cardiorespiratory
20
diseases,
cancer,
many
negative
health
impacts.
21
So
that's
why
I'm
here
today.
22
And
this
is
a
year­
around
problem.
Just
23
before
the
winter
holidays,
Michigan
had
a
string
24
of
days
that
were
forecasted
as
moderate
or
25
97
unhealthy
for
sensitive
populations
regarding
the
1
existing
PM2.5
standards.
2
By
law,
air
quality
standards
must
3
reflect
the
latest
health
science.
And
it's
4
worth
emphasizing
that's
not
a
strong
suggestion;
5
that's
a
requirement.
They
must
reflect
the
6
latest
science.
And
that's
highlighted
by
the
7
fact
that
it
needs
to
reflect
an
adequate
margin
8
of
safety
for
the
sensitive
population:
Infants,
9
children,
people
with
asthma
or
cardiac
10
conditions,
and
the
elderly.
11
As
has
been
said
before
today,
thousands
12
of
peer­
reviewed
studies,
since
the
last
time
the
13
agency
examined
the
standards,
have
been
done.
14
They
all
point
in
the
same
direction.
But
for
15
the
first
time,
the
agency
has
rejected
these
16
recommendations
of
its
own
scientific
advisors.
17
And
I
think
that's
what
really
is
troubling
a
lot
18
of
people
who
may
not
have
the
time
or
the
19
expertise
to
understand
the
actual
numbers.
They
20
just
know
that
the
best
scientists
have
provided
21
this
information,
and
it
has
not
been
received
as
22
they
intended.
23
So
for
the
first
time,
again
24
unprecedented,
this
committee
has
formally
stated
25
98
their
discontent
for
the
agency.
1
Just
to
move
along
in
terms
of
what
the
2
Michigan
Environmental
Council
would
like
to
see
3
changed
in
the
proposals.
We
support
the
4
American
Academy
of
Pediatrics
and
their
5
recommendations
that
the
standards
be
lowered
to
6
an
annual
standard
of
12
micrograms
per
cubic
7
meter
and
also
the
daily
of
25
­­
PM2.5.
We
8
support
the
American
Lung
Association
9
recommendation
that
the
PM
­­
the
coarse
particle
10
standard
be
lowered
to
at
least
in
the
range
of
11
25
to
30
in
order
to
protect
the
sensitive
12
populations.
13
And
in
conclusion,
there
are
a
number
of
14
other
things
I'll
highlight
in
my
written
15
comments
when
they're
submitted.
But
just
in
16
conclusion,
I
want
to
state
that
policy
on
17
particle
pollution
shouldn't
reflect
power
18
company
politics,
shouldn't
reflect
engine
19
manufacturing
politics
or
any
other
special
20
interest.
It's
based
on
public
health
and
must
21
reflect
the
scientific
studies.
22
To
be
frank,
from
the
people
at
the
23
grassroots
level
in
Michigan
anyway,
it's
really
24
undermining
people's
trust
in
their
government.
25
99
And
I
also
suspect
that
a
number
of
the
1
scientists
who
have
been
involved
in
this
process
2
are
also
questioning
whether
their
time
spent
in
3
this
effort
for
its
better
public
health
is
worth
4
their
time
in
their
busy
schedules.
5
Again,
thank
you
very
much
for
the
6
opportunity
to
comment,
and
I
will
submit
written
7
comments.
8
MR.
BURNETT:
Thank
you
for
your
9
comments.
10
Many
people
have
put
in
long
hours
into
11
what
has
ultimately
culminated
in
this
proposed
12
ruling
and
I
want
to
acknowledge
the
­­
your
13
comment
in
terms
of
the
time
that
CASAC
14
scientists
have
put
into
that.
We
very
much
15
appreciate
their
comments,
and
we
also
very
much
16
appreciate
the
effort
that
people
have
made
to
17
come
here
today.
So
I'd
just
like
to
acknowledge
18
that.
19
Ms.
Casten.
20
MS.
CASTEN:
Thank
you.
21
My
name
is
Liane
Casten.
I
have
been
a
22
cofounder
and
chair
of
an
organization
called
23
Chicago
Media
Watch
for
14
years.
I'm
also
an
24
environmental
journalist,
and
I
have
published
a
25
100
book
on
breast
cancer
and
its
proven
connection
1
to
the
environment.
70
percent
of
breast
cancers
2
are
indeed
environmentally
caused.
3
But
I'm
not
here
to
talk
about
the
4
science.
I'm
here
to
talk
about
the
politics.
5
It's
really
not
about
our
lungs
or
our
6
asthma
or
our
cancers.
It's
not
about
scientific
7
research
or
scientific
advisory
panels.
It's
8
about
this
present
administration's
priorities.
9
That
simple.
It's
about
priorities
and
it's
10
about
integrity.
It's
about
business
profits
11
that
support
business
as
opposed
to
the
value
of
12
a
human
life.
There's
enough
evidence
to
support
13
what
I'm
saying
all
over
the
map.
14
Right
now,
business
profits
have
become
15
supreme.
Many
times
regulatory
administrators
16
are
chosen
because
they
had
been,
at
one
point,
17
heads
of
the
very
industries
that
were
doing
the
18
polluting.
And
there's
a
long
list
of
that.
19
Okay.
20
Often
these
priorities
include
fighting
21
in
a
public
arena
to
suggest
that
the
data
is
yet
22
uncertain;
that
we
will
always
need
more
studies.
23
We
know
that
scientific
advisory
panels
24
are
ignored.
We
know
that
scientific
conclusions
25
101
can
be
at
this
point
seriously
flawed.
And
1
outspoken
scientists
are
asked
to
leave.
We
see
2
this
in
the
climate
change
area.
3
So
I
suggest
we
do
something
that's
4
rather
radical.
We
have
today
a
moral
vacuum
if
5
there
is
any
chance
of
considering
the
health
of
6
a
human
life
of
value.
So
I
urge
the
EPA
to
find
7
some
kind
of
collective
conscience.
There's
a
8
higher
principle
operating.
It's
called
the
9
precautionary
principle.
Divergent
views
indeed
10
have
value,
but
they
must
be
placed
in
balance
11
with
a
deep
respect
for
human
life.
12
Thank
you
for
letting
me
say
these
13
words.
14
MR.
BURNETT:
Thank
you
for
coming
15
today.
I
will
simply
note
that
the
­­
you're
16
right.
The
statute
requires
and
the
17
administrator
has
made
a
preliminary
judgment
18
based
on
the
health
science.
And
if
you
have
19
particular
comments
on
the
rationale
for
the
20
interpretation
of
that
health
science,
we
would
21
also
welcome
those
in
addition
to
your
comments
22
today.
Thank
you
very
much.
23
Ms.
Brock
and
Ms.
Bledstein.
Please.
24
Miss
Brock,
please.
25
102
MS.
BROCK:
Hello.
I'm
Belinda
Brock.
1
I'm
not
here
today
to
furnish
you
with
data
and
2
epidemiological
studies.
I'm
not
a
doctor.
And
3
certainly
you
have
scientific
evidence
and
4
recommendations
that
you've
received
from
CASAC,
5
which
apparently
have
been
rejected,
at
least
by
6
the
administration.
7
What
I
am
is
a
concerned
citizen,
a
8
taxpayer.
I
myself
have
a
debilitating
9
multiple­
chemical
sensitivity.
But
at
this
10
moment,
since
I
do
not
have
a
lot
of
time,
I
11
would
like
to
focus
briefly
on
my
son,
Max,
who
12
suffers
from
asthma.
His
allergies
and
asthma
13
and
pulmonary
function
deteriorated
sharply
after
14
an
exposure
to
unhealthy
air
quality
several
15
years
ago
in
his
elementary
school.
16
Now
it's
necessary
for
him
to
take
17
several
medications
every
day,
the
impact
of
18
which
on
his
growth
we
are
not
sure
about.
He
19
has
to
curtail
many
of
his
activities.
And
even
20
so,
an
asthma
attack
can
still
be
triggered
by
21
particle
pollution.
22
You're
probably
thinking,
well,
what
is
23
so
unusual
about
this?
There
are
a
lot
of
kids
24
who
have
asthma.
And
that's
my
point
exactly.
I
25
103
mean,
hey,
I'm
his
mom.
I
know
he's
special.
1
But
there
are
dozens,
hundreds,
thousands
of
kids
2
all
over
who
have
asthma,
and
I
want
you
to
think
3
about
these
kids.
4
My
son
is
a
wonderful
boy.
He's
a
good
5
student.
He
loves
science,
political
science,
6
and
history,
math.
He
is
not
yet
cynical.
Even
7
more
importantly,
he
is
a
good
person,
a
fact
8
that
was
recognized
by
our
city
a
couple
of
years
9
ago.
He
received
a
Character
Counts
Award
for
10
having
demonstrated
outstanding
and
valuable
11
character
traits.
12
He
also
loves
sports,
watching
and
13
paying.
He
had
a
great
natural
talent
for
14
soccer.
Unfortunately,
with
the
toll
asthma
has
15
taken
on
him,
he
was
unable
to
continue
with
the
16
demands
that
any
team
sport
makes.
17
He's
a
good
student,
and
we
are
starting
18
to
think
about
colleges.
His
concerns
are
a
19
little
different
than
the
average
student
who
is
20
just
thinking
about
ACT
scores
and
grades
and
21
recommendations.
Our
issues
are
can
he
go
away
22
to
school?
How
far
can
he
go?
And
what
is
the
23
air
quality
in
the
particular
city
in
which
he
24
might
be
interested
in
attending.
25
104
Just
as
there
are
many
children
and
1
young
people
like
Max,
there
are
many
parents
2
like
myself
who
lie
in
bed
at
night
and
dread
3
hearing
that
cough,
that
deep,
deep
cough
in
the
4
middle
of
the
night,
and
I
often
lie
in
bed
5
feeling
helpless.
6
But
you
are
not
helpless.
In
this
life
7
there
are
many
things
over
which
we
have
no
8
control.
In
this
instance,
you're
fortunate
in
9
that
you're
able
to
exercise
control.
10
I
don't
want
to
be
presumptuous
or
11
preachy,
but
I
think
that
your
mission,
your
12
obligation
is
to
protect
our
planet,
our
13
environment,
our
health
­­
literally,
our
future.
14
So
I
am
urging
you
to
not
let
business
and/
or
15
political
issues
cloud
your
vision
and
deter
you
16
from
your
path.
17
Be
courageous,
not
shortsighted.
Heed
18
our
scientists,
our
doctors,
all
the
people
who
19
have
come
here
today
to
speak.
Act
also
for
20
those
who
are
too
young,
too
old,
too
21
disadvantaged,
too
sick
to
advocate
for
22
themselves.
23
Please
don't
betray
the
trust
of
our
24
young
people.
After
all,
you
are
the
United
25
105
States
Environmental
Protection
Agency,
so
I
urge
1
you
to
adopt
the
most
protective
form
of
2
standards
for
daily
and
annual
levels
of
3
particulate
air
matter.
4
Thank
you
very
much
for
allowing
me
to
5
speak.
6
MR.
BURNETT:
Thank
you
for
your
7
comments,
and
I
­­
would
you
mind
telling
us
8
what
­­
you
mentioned
your
son
had
exposure
in
9
elementary
school
several
years
ago.
10
MS.
BROCK:
They
were
doing
construction
11
and
didn't
go
about
it
in
the
right
way.
And
12
this
is
in
Highland
Park,
and
really
you
would
13
think
that
the
administration,
you
know,
would
14
have
­­
the
school
administration
would
have
15
known
better.
16
And
they
did
a
lot
of
things
during
the
17
day
when
the
kids
were
at
school
instead
of
18
leaving
it
for
vacation,
weekends,
or
even
19
after­
school
hours.
And
my
son
had
a
lot
of
20
accumulated
exposures
of
things
that
were
going
21
on.
I
tried
to
take
him
out
of
school
when
I
22
knew
in
advance
what
was
going
to
happen.
In
the
23
last
instance,
the
principal
didn't
tell
me
that
24
anything
was
being
done
that
day,
so
I
let
my
son
25
106
go
to
school.
You
know,
he
wanted
to
go
to
1
school.
He's
a
good
student,
and
he's
­­
you
2
know,
wanted
to
do
the
normal­
type
things
that
3
kids
do.
4
And
they
used
some
petro
chemicals,
some
5
petroleum­
based
construction
adhesive
to
put
up
6
sow
boards
on
the
wall,
and
fumes
just
filled
his
7
area
of
the
school.
And
he
had
­­
I
had
to
rush
8
there
and
take
him
to
the
emergency
room.
He
had
9
a
terrible
asthma
attack
and
was
out
of
school
10
for
a
week
after
that.
And
then
after
that,
he
11
had
to
take
about
­­
has
to
take
about
ten
12
different
medications
every
day.
And,
you
know,
13
he
worries
that
he's
not
­­
because
of
all
the
14
steroids
he
took,
that
he
won't
reach
the
height
15
that
he
would
have
and
the
things
along
those
16
lines.
17
MR.
BURNETT:
My
condolences
go
to
your
18
son
and
to
your
family,
and,
again,
I
appreciate
19
your
comments.
20
MS.
BLEDSTEIN:
My
name
is
Adrien
21
Bledstein.
That's
B­
L­
E­
D­
S­
T­
E­
I­
N.
And
my
22
story
is
also
personal.
23
I
am
founder
and
president
of
I
Can
24
Breathe!
Inc.
In
Chicago,
we
design
and
25
107
manufacture
air
filter
masks
so
individuals
may
1
control
their
environment
when
the
air
is
not
2
clear.
3
Twelve
years
ago
I
was
a
literature
4
teacher
and
writer,
not
a
business
woman.
Due
to
5
ill
effects
of
air
pollution,
in
desperation
I
6
created
masks
to
regain
my
quality
of
life.
I
7
support
more
stringent
standards
to
control
8
particulate
air
pollution.
I
am
one
of
those
9
sensitive
people
for
whom
even
moderate
pollution
10
is
unhealthy,
and
this
is
my
story.
11
Before
1994,
I
was
swimming
four
to
five
12
times
a
week.
I
never
smoked.
I
was
leading
13
five
literature
classes,
plus
teaching
eight
14
individual
students
reading
comprehension,
15
critical
thinking
and
writing.
I
was
doing
16
research
in
archives,
delivering
papers,
and
17
writing
for
publication.
18
That
summer
I
developed
a
postnasal
drip
19
that
lasted
through
fall.
I
was
often
exhausted,
20
so
I
cut
teaching
to
one
hour
a
week
and
took
no
21
individual
students.
All
the
research
and
22
writing
stopped.
23
One
morning
I
woke
up
wheezing.
After
24
three
months
of
antibiotics
made
no
difference,
I
25
108
was
diagnosed
with
asthma.
Despite
rigorously
1
adhering
to
asthma
medications,
three
or
four
at
2
a
time,
I
periodically
experienced
unaccountable
3
fatigue.
Unable
to
think,
teach,
and
write,
I
4
was
devastated.
5
"
Avoid
triggers,"
my
doctor
told
me.
6
Following
his
advice,
I
experimented
with
wearing
7
a
dust
mask
and
noticed
a
dramatic
increase
in
8
energy
and
clear
thinking.
However,
there
were
9
still
days
when
I
couldn't
function
mentally
or
10
physically.
11
Toward
the
end
of
summer
1997,
I
had
an
12
"
Aha!"
experience.
One
day
when
I
was
listless
13
and
confused,
I
rested
for
two
hours
with
no
14
improvement.
Through
mental
fog
I
wondered
if
15
something
might
be
in
the
air
which
my
silk
16
comfort
mask,
good
for
screening
2
to
5
micron
17
particles,
did
not
filter.
I
pulled
from
my
18
pocket
a
mask
I
developed
to
avoid
fragrances
and
19
cigarette
smoke.
In
my
fifth
­­
in
my
fit
test,
20
the
carbon
filter
reduced
exposure
to
one­
micron
21
particles
by
99
percent,
and
the
carbon
captures
22
toxic
chemicals.
Within
minutes
of
putting
it
23
on,
my
body
warmed,
my
energy
returned,
and
my
24
mind
cleared.
The
current
air
quality
report
was
25
109
particulate
matter
moderate,
but
damaging
to
me.
1
In
Chicago,
when
the
north
wind
blows,
2
the
air
is
crisp
and
clean
and
energizing.
But
3
when
the
air
is
stagnant,
as
it
was
this
Monday
4
and
Tuesday
until
mid­
morning,
with
the
air
5
quality
moderate,
my
mind
would
not
function
6
without
this
mask.
7
Since
I
have
been
avoiding
triggers,
my
8
health
is
restored
without
medications.
These
9
days,
at
67
years
old,
I
have
a
lot
to
do.
As
a
10
result
of
my
experience
in
research,
on
days
when
11
particulate
matter
drains
my
energy
and
ozone
12
irritates
my
asthmatic
lungs,
I
take
control
of
13
my
environment
by
wearing
this
carbon
mask.
I
am
14
able
to
teach,
do
research,
and
publish
papers.
15
But
most
of
the
time
I
run
a
business.
16
The
mask
I
invented
out
of
desperation
for
myself
17
are
sold
nationally
for
others
who
need
immediate
18
relief
for
air
pollution
and
other
challenges.
19
Every
weekday
I
hear
from
individuals
who
suffer
20
from
lax
pollution
controls
in
our
country.
21
In
February
of
this
year,
I
was
dismayed
22
on
two
counts
when
I
read
in
the
Los
Angeles
23
Times
that
regarding
soot
and
dust,
"
The
24
standards
put
forward
by
the
EPA
administrator,
25
110
Stephen
Johnson,
ignored
most
of
the
committee's
1
earlier
recommendations
and
could
lead
to
2
additional
heart
attacks,
lung
cancer,
and
3
respiratory
ailments."
4
First,
that
Mr.
Johnson
ignored
5
recommendations
of
independent
scientists
is
6
abhorrent
to
me.
Second,
from
people
who
calls
7
us
for
help,
I
suspect
that
the
excessive
number
8
of
people
who
die
due
to
current
standards
may
be
9
relatively
small
compared
to
the
uncounted
people
10
who
are
unable
to
function
normally
and
to
live
11
fully.
12
I
urge
you
to
press
for
rigorous
13
standards
so
that
lives
may
be
safe
and
uncounted
14
adults
and
children
can
breathe
without
wearing
a
15
mask.
Thank
you.
16
MR.
BURNETT:
Thank
you
for
your
17
comments
and
in
particular
for
your
story
of
what
18
you
have
gone
through
other
the
past
few
years.
19
I
am
interested
in
knowing
more
about
20
the
­­
your
mask
technology.
You
said
that
the
21
mask
that
you're
currently
wearing
gets
22
99
percent
capture
of
PM
of
size
one
micrometer
23
in
diameter;
is
that
correct?
24
MS.
BLEDSTEIN:
Yes.
I've
had
it
tested
25
111
at
Rayco,
a
fit
test.
1
MR.
BURNETT:
And
how
does
it
function.
2
For
other
sizes
of
PM.
3
MS.
BLEDSTEIN:
The
smaller
sizes
is
not
4
as
­­
this
is
not
an
N95
mask,
so
it
doesn't
go
5
down
to
the
lower
minus
­­
to
.2
or
.5.
I'm
6
working
on
finding
masks
for
people
that
will
do
7
that.
8
MR.
BURNETT:
Are
there
any
other
9
questions?
10
I
will
thank
both
of
you,
and
we're
11
going
to
take
a
five­
minute
break.
By
my
watch
12
it
is
11:
15,
so
at
11:
20,
we'll
recommence.
13
Thank
you.
14
(
Whereupon
a
break
was
taken.)
15
MR.
BURNETT:
Next
I
would
like
to
16
request
Dr.
Orris
and
Ms.
Slaughtaire
to
come
up
17
to
the
table.
18
Dr.
Orris,
I
apologize.
I
know
that
you
19
signed
in
earlier
and
we're
only
now
getting
to
20
you.
Please.
21
DR.
ORRIS:
Good
morning.
Thank
you.
I
22
appreciate
being
able
to
testify
here
today.
23
My
name
is
Peter
Orris.
I'm
a
physician
24
specializing
in
environmental
and
occupational
25
112
medicine.
I
practice
at
Stroger
Cook
County
1
Hospital
where
I'm
proud
to
be
immediate
past
2
president
of
the
medical
staff,
and
I
also
serve
3
as
a
professor
on
the
faculties
of
the
University
4
of
Illinois,
Rush,
and
Northwestern.
5
I
must
say
it
amazes
me
to
be
here
today
6
on
this
particular
topic.
I
thought,
in
my
7
naivete,
that
we
had
fairly
well
resolved
these
8
issues,
both
scientifically
and
with
respect
to
9
policy
in
the
late
'
90s.
In
the
development
of
10
that
consensus
at
that
time
about
PM2.5,
a
11
torrent
of
words
were
expressed
and
mountains
of
12
written
materials
developed.
I'm
not
13
substantially
going
to
add
to
that
work
product
14
today.
15
I
appear
before
you
to
restate
the
plea
16
contained
in
a
letter
sent
on
December
5th
to
17
Administrator
Johnson
from
myself
and
scores
of
18
my
colleagues
from
around
the
country.
We
ask
19
him
to
act
on
the
recommendations
of
his
of
20
staff,
the
EPA
staff,
as
well
as
Clean
Air
21
Scientific
Advisory
Committee
to
revise
both
the
22
annual
and
24­
hour
average
National
Ambient
Air
23
Quality
Standards
for
fine
particulate
matter
24
significantly
downward
to
protect
public
health
25
113
and
to
establish
a
stringent
new
24­
hour
standard
1
for
coarse
particulate
matter.
2
Specifically,
we
believe
that
standards
3
should
be
set
at
or
below
the
low
end
of
the
4
ranges
recommended
in
final
EPA
Staff
Paper.
5
Ample
scientific
evidence
supports
adopting
lower
6
standards
in
order
to
protect
the
health
of
7
people
who
are
most
susceptible
to
serious
health
8
effects
of
these
pollutants.
9
Specifically,
we
urged
him
to
set
10
standards
following
health­
based
NAAQS
for
11
particulate
matter
to,
1)
annual
average
PM2.5
12
standard
of
12
micrograms
per
meter
cubed;
a
13
24­
hour
2.5
standard
of
25
micrograms
per
meter
14
cubed;
a
stringent
24­
hour
average
PM
10­
2.5
15
standard
applied
equally
throughout
the
country,
16
because
we
mentioned
that
further
we
opposed
the
17
allowance
of
"
spatial
averaging
among
air
18
monitors
as
such
an
approach
would
allow
some
19
communities
to
become
pollution
hot
spots
without
20
any
requirement
to
mitigate
local
air
quality
21
problems."
22
As
you
are
aware,
the
2004
EPA
Criteria
23
Document
reviewed
and
confirmed
the
earlier
24
epidemiologic
work
in
the
late
­­
that
was
25
114
reviewed
originally
in
the
late
'
90s
that
1
identified
serious
morbidity
and
mortality
2
associated
with
fine
particulate
exposure.
In
3
fact,
the
newer
studies
that
emerged
since
that
4
mid­'
90s
review
identified
adverse
effects
of
5
lower
levels
of
exposure
than
the
earlier
work.
6
These
studies
and
prior
work
take
us
a
7
long
way
to
identify
PM2.5s
as
causing
a
large
8
variety
of
adverse
effects
in
people.
These
9
include
decreased
functioning
of
the
lungs,
10
cough,
wheeze,
missed
school
days
due
to
11
respiratory
symptoms,
increased
use
of
asthma
12
medication,
cardiac
arrhythmias,
stroke,
13
emergency
room
visits,
hospital
admissions,
lung
14
cancer,
and,
in
fact,
premature
death.
We
now
15
know
that
short­
term
exposure
effects
are
16
significant
as
well.
And,
as
usual,
infants,
the
17
elderly,
and
people
with
heart
and
lung
disease
18
are
particularly
vulnerable.
Those
of
us
working
19
in
large
public
hospitals
see
that
particular
20
vulnerability
every
day
and
the
disproportionate
21
impact
of
this
type
of
pollution
on
poor
and
22
minority
communities.
23
I
invite
this
panel
to
tour
our
24
pediatric
emergency
room
at
Stroger
Hospital
and
25
115
discuss
with
the
staff
the
effects
of
both
acute
1
and
chronic
exposure
to
these
particulates
on
our
2
patients
and
their
families.
This
is
not
an
3
abstract
issue
to
us,
but
rather
one
played
out
4
daily
on
the
most
innocent
and
defenseless
of
our
5
patients.
6
I
implore
the
Administrator
to
listen
to
7
the
EPA's
own
Clean
Air
Scientific
Advisory
8
Committee,
the
staff
of
the
Office
of
Air
Quality
9
Planning
and
Standards,
the
Children's
Health
10
Protection
Advisory
Committee
as
well
as
hundreds
11
of
academic
and
community
physicians
from
12
throughout
the
country
as
well
as
other
health
13
care
professionals.
14
I
urge
him
to
reject
the
new
"
tobacco
is
15
good
for
you"
public
relations
campaign
that
has
16
been
launched
by
industry
and
their
paid
17
consultants
placing
their
desire
for
windfall
18
profits
above
the
health
of
my
patients
and
their
19
communities.
20
I
call
upon
him
to
carry
out
the
mission
21
of
the
Environmental
Protection
Agency
so
22
succinctly
put
in
the
EPA
web
site
"
to
protect
23
human
health
and
the
environment."
24
Thank
you
very
much
for
hearing
me
25
116
today,
and
I
appreciate
it
and
will
answer
any
1
questions
you
may
have.
2
MR.
BURNETT:
Thank
you
for
your
3
comments
and
for
your
December
5,
2005,
letter
4
which
we
are
in
­­
we
do
have.
5
You
mentioned
your
opposition
to
spatial
6
averaging.
For
others
here
­­
and
since
I
didn't
7
discuss
this
in
my
opening
remarks,
and
I'm
not
8
sure
that
it's
in
the
fact
sheet.
For
the
9
current
annual
standard,
we
do
allow
spatial
10
averaging.
We're
actually
proposing
to
restrict
11
the
situations
when
spatial
averaging
would
be
12
allowed,
but
not
to
prohibit
it
entirely,
13
although
we
are
taking
comment
on
that
issue.
14
I
appreciate
your
comments
on
that,
and
15
if
you
have
anymore
details,
we
would
welcome
16
them.
Do
you
have
anything
else
at
this
point
17
you
would
like
to
say
on
that
particular
issue?
18
DR.
ORRIS:
No.
We
do
support
the
19
elimination
of
spatial
averaging.
20
MR.
BURNETT:
Okay.
I
understand.
21
Thank
you
very
much
for
your
comments.
22
MS.
SLAUGHTAIRE:
Hello.
I
am
Pamela
23
Slaughtaire.
I'm
a
mother
and
I
am
also
an
24
asthmatic.
I
have
been
very
vigilant
­­
25
117
MR.
BURNETT:
Sorry.
If
I
could
ask
you
1
to
spell
your
last
name
for
the
­­
2
MS.
SLAUGHTAIRE:
Okay.
My
last
name
is
3
S­
L­
A­
U­
G­
H­
T­
A­
I­
R­
E,
Slaughtaire.
4
MR.
BURNETT:
Thank
you.
5
MS.
SLAUGHTAIRE:
You're
welcome.
6
I've
been
a
vigilant
mom.
I
have
three
7
children
who
also
have
asthma.
Two
years
ago
I
8
was
also
diagnosed
with
asthma.
9
One
of
the
things
that
I
have
discovered
10
about
living
in
the
city
is
that
when
you
live
in
11
a
city
that
has
lots
of
industry,
lots
of
trucks,
12
cars,
highways
and
byways,
when
the
weather
13
changes
in
the
summer
and
your
children
want
to
14
go
out
and
there's
a
weather
advisory,
you
have
15
to
take
steps
to
protect
them.
16
And
I
have
­­
I'm
the
EPA
in
my
house.
17
I've
got
to
turn
on
the
air
conditioner.
I've
18
got
to
make
sure
everybody
is
hydrated.
We
have
19
to
manage
our
meds
properly.
And
I
will
tell
you
20
that
it
is
very
difficult
to
contain
your
kids
21
and
ask
them
to
stay
inside
when
everybody
else
22
goes
out.
It's
unfortunate
but
it
does
help
them
23
keep
a
good
health
standard.
24
I
think
that
one
of
the
problems
I'm
25
118
having
now
with
this
effort
to
ignore
the
1
reality.
Research
says
a
lot
of
different
2
things.
You
know,
there's
a
range.
But
the
3
bottom
line
is
we
all
know
what's
happening
4
globally.
We
all
know
what
we
need
to
do.
5
And
I
think
that
the
EPA
needs
to
do
6
what
they
know
is
correct
for
people
whose
mom
is
7
not
as
vigilant.
Okay.
The
people
who
aren't
as
8
vigilant
don't
even
know
how
sick
they
can
9
become.
They
just
get
sick,
they
go
to
the
10
public
hospitals,
they
go
to
the
emergency
rooms,
11
and
it
costs
us
so
much
money
in
medical
care.
12
And
the
doctors
and
the
staff
work
so
13
hard,
especially
when
there's
children.
They
are
14
so
vigilant.
They
are
so
dedicated.
And
what
is
15
the
use
of
the
dedication
if
we're
not
going
to
16
consider
that
there's
something
we
can
do
­­
we
17
know
what
we
need
to
do,
and
I
would
request
that
18
the
EPA
do
the
right
thing.
Thank
you.
19
MR.
BURNETT:
Thank
you.
20
And
in
terms
of
your
own
family,
how
do
21
you
determine
which
days
are
such
that
you
allow
22
your
children
­­
do
you
use
the
EPA's
air
quality
23
index?
24
MS.
SLAUGHTAIRE:
I
can
go
on
the
25
119
Internet,
and
I
can
use
EPA
indexes.
I
can
also
1
listen
to
the
weather
report
in
the
morning.
2
They
always
­­
here
in
the
City
of
Chicago,
our
3
weather
people
are
very
good
at
warning
us
4
because
they
know
of
the
increase
in
pulmonary
5
problems,
the
heart
attacks,
the
strokes.
They
6
warn
us.
7
And
so
I
try
to
do
­­
I
try
to
fashion
8
our
activities
around
those
warnings
so
that
my
9
kids
can
be
as
safe
as
possible.
I
try
not
to
10
keep
them
in
a
bubble,
but
if
it's
extreme,
then
11
we
try
to
follow
the
safety
tips
and
do
what's
12
right
so
that
we
can,
you
know,
have
a
good
day.
13
But
it's
hard.
It's
really
hard.
Because
you're
14
talking
about
compliance,
and
everybody
doesn't
15
want
to
be
compliant.
And
some
people
don't
know
16
any
better,
and
those
are
the
people
that
are
out
17
there
that
the
EPA
should
be
protecting.
18
MR.
BURNETT:
Appreciate
your
comments.
19
Thank
you
both.
20
Dr.
Cugell
and
Ms.
Catrambone,
please.
21
MS.
CATRAMBONE:
Thank
you
for
22
pronouncing
my
name
correctly.
I've
worked
for
23
ten
years,
and
she
still
doesn't
say
my
name
24
correctly.
25
120
My
name
is
Cathy
Catrambone,
1
C­
A­
T­
R­
A­
M­
B­
O­
N­
E.
I
am
here
as
a
public
2
citizen.
I've
been
a
nurse
for
27
years
at
Rush
3
University
Medical
Center
in
Chicago,
and
my
4
primary
area
of
practice
has
been
caring
for
5
people
with
chronic
lung
disease.
I
understand
6
all
too
well
the
suffering
that
individuals
and
7
their
families
must
endure
in
coping
with
such
8
illnesses
and
the
negative
impact
of
air
9
pollution
on
their
already­
compromised
state
of
10
health.
11
The
reason
I'm
here
today
is
to
advocate
12
on
their
behalf
as
well
as
for
the
health
of
our
13
citizens.
Our
health
is
our
most
precious
14
commodity,
and
we
have
an
obligation
to
protect
15
and
promote
a
healthy
environment.
16
I
would
like
to
share
some
important
17
facts
about
air
pollution
from
the
medical
18
literature.
And
I
apologize
if
these
have
been
19
repeated
before,
but
I
feel
it's
worth
pointing
20
to
them
once
again.
21
Number
one.
Fine
particle
pollution
is
22
the
nation's
deadliest
air
pollutant.
Particles
23
lodge
deep
within
the
lungs
and
enter
the
24
bloodstream
causing
respiratory,
cardiovascular
25
121
problems
such
as
asthma
attacks,
heart
attacks,
1
strokes.
Fine
particle
pollution
is
so
dangerous
2
that
it
contributes
to
tens
of
thousands
of
3
premature
deaths
every
year.
4
The
more
we
learn
about
particle
5
pollution,
the
more
we
understand
how
dangerous
6
it
is.
A
major
study
published
last
November
in
7
the
Journal
of
Epidemiology
found
that
the
8
chronic
effects
of
fine
particles
are
two
to
9
three
times
greater
than
previously
believed
and
10
that
for
an
increase
of
10
micrograms
per
cubic
11
meter
fine
particles
in
the
air,
the
risk
of
12
death
for
any
cause
increases
by
11
to
13
17
percent.
14
We
have
overwhelming
evidence
of
the
15
devastating
effects
of
fine
particles,
even
at
16
levels
below
the
current
standards.
The
Bush
17
Administration's
proposal,
which
largely
18
maintains
the
status
quo
for
particles,
is
19
inadequate
to
protect
the
public
health.
EPA's
20
own
analysis
shows
that
proposed
fine
particle
21
standards
will
leave
millions
of
Americans
22
unprotected.
23
I
concur
with
the
consensus
in
the
24
medical
and
scientific
community
that
the
25
122
standard
should
be
set
at
the
most
protective
1
levels
within
EPA's
recommended
ranges.
2
Specifically,
as
Dr.
Orris
has
pointed
out,
we
3
should
adopt
an
annual
standard
no
higher
than
12
4
micrograms
per
cubic
meter
and
a
daily
standard
5
no
higher
than
25
micrograms
per
cubic
meter
when
6
it
finalizes
the
standards
in
September.
Unlike
7
the
Clean
Air
Act,
air
quality
standards
must
be
8
set
at
levels
that
protect
the
public
health
with
9
an
adequate
margin
of
safety.
10
Thank
you
for
this
opportunity
to
11
testify
on
the
support
and
public
health
issue.
12
MR.
BURNETT:
Thank
you
for
your
13
comments
today.
And
we
are
aware
of
the
study
14
submitted
in
epidemiology,
and
it
will
be
part
of
15
the
provisional
assessment
of
new
studies.
I
16
appreciate
you
raising
that
study
to
our
17
attention
again
today.
18
MS.
CATRAMBONE:
Okay.
Thank
you
so
19
much.
I'm
happy
to
be
here
today.
20
MR.
BURNETT:
Thank
you.
21
Good
morning.
I'm
David
W.
Cugell.
22
That's
Cugell.
I'm
here
on
behalf
of
the
23
American
Lung
Association
of
metropolitan
24
Chicago.
I'm
a
faculty
member
at
the
25
123
Northwestern
University
Feinberg
School
of
1
Medicine
and
share
some
common
activities
with
2
Dr.
McColley
from
whom
we
heard
a
few
moments
ago
3
in
that
I
was
in
charge
of
the
pulmonary
program
4
there
in
the
recent
past,
but
for
adults
contrary
5
to
her
role
which
she's
got
a
similar
case
of
6
children.
7
I
would
like
to
think
that
my
major
8
representation
here
is
on
behalf
of
those
less
9
fortunate
among
us
who
have
asthma,
chronic
lung
10
disease,
and
also
a
substantial
portion
of
our
11
community
that's
afflicted
with
chronic
heart
12
disease.
All
of
these
ailments
are
adversely
13
affected
by
particulate
inhalation,
specifically
14
the
PM2.5
about
which
we've
heard
a
great
deal.
15
In
the
greater
Chicago
area,
there
are
16
approximately
650,000
people
with
asthma,
and
17
according
to
a
1997
survey,
there
were
over
18
70,000
asthma­
related
emergency
room
visits
in
19
one
year.
In
addition
there
were
about
19,000
20
hospitalizations
so
that
asthma
alone
is
a
very
21
substantial
health
problem
for
the
public
at
22
large.
23
Of
particular
importance
is
the
fact
24
that
asthma
is
primarily
or
is
much
more
25
124
prevalent
among
minorities
and
is
substantially
1
higher
than
in
the
white
community.
The
death
2
rate
in
Afro­
Americans
from
asthma
is
four
3
times
­­
and
this
is
in
the
Chicago
area
­­
is
4
four
times
the
death
rate
for
­­
the
national
5
death
rate
from
asthma.
Four
times
greater.
6
All
our
major
metropolitan
areas
have
7
this
problem
with
increasing
asthma
prevalence,
8
but
Chicago
is
particularly
difficult
in
that
9
regard.
Asthma
attacks
and
episodes
of
10
respiratory
failure
in
patients
with
other
types
11
of
chronic
lung
disease
occur
for
many
reasons,
12
most
of
them
unknown,
but
we
do
know
that
smoke
13
particulates
can
be
responsible.
And
I
would
14
like
to
quote
briefly
from
two
web
sites
I
came
15
across
in
which
the
­­
these
are
EPA
web
sites,
16
one
of
which
says,
"
pollutants
include"
­­
let
me
17
start
with
this
one.
18
It
says
"
People
with
asthma
are
more
19
severely
affected
by
ozone
and
particulate
matter
20
than
are
people
without
the
disease."
21
And
in
another
location,
it
says,
22
"
Pollutants
include
fine
particles
which
are
23
unhealthy
to
breathe
and
have
been
associated
24
with
premature
mortality
and
other
serious
health
25
125
effects.
Fine
particles
are
those
less
than
2.5
1
micrometers
in
diameter
and
are
also
referred
to
2
as
PM2.5."
3
So
the
EPA
acknowledges
the
adverse
4
affect
on
health,
but
apparently
it's
ready
to
5
ignore
their
own
statement,
let
alone
the
6
Scientific
Advisory
Committee
recommendations
7
that
these
standards
be
tightened.
8
Let
me
quote
a
report
to
indicate
the
9
impact
on
heart
disease,
which
I
have
not
heard
10
discussed
here.
In
the
year
2000
it
was
an
11
interesting
­­
well,
let
me
start
this
way.
12
A
function
of
a
healthy
heart
is
a
13
variability
in
the
heart
rate
when
someone
is
14
exercising
or
sleeping
or
whatever
they're
doing.
15
But
under
stable
circumstances,
there's
a
normal
16
variation
in
the
heart
rate.
As
a
subtle
and
17
early
sign
of
impaired
cardiac
function,
that
18
rate
variability
disappears,
and
the
rate
becomes
19
much
more
stable.
That
was
shown
five
years
ago
20
to
be
adversely
affected;
that
is,
the
normal
21
variation
disappeared,
when
PM2.5
levels
were
22
elevated.
Nothing
much
further
was
done
about
23
that
until
a
very
recent
publication
has
shown
24
the
adverse
impact
on
cardiac
function
of
25
126
elevated
levels
of
PM2.5.
1
Another
recent
publication
shows
a
2
very
­­
an
additional
important
feature,
and
that
3
is
when
the
levels
of
PM2.5
are
reduced,
4
respiratory
function
improves.
When
you're
5
trying
to
relate
something
demonstrating
6
cause­
and­
effect
relationship
in
the
disease
7
process,
it's
one
thing
to
show
that
when
you
8
have
more
of
compound
x,
you
have
more
ailments.
9
But
you
should
also
be
able
to
show,
when
you
10
reduce
the
concentration,
the
adverse
effect
11
disappears
or
improves.
And
that's
already
now
12
been
confirmed
with
respect
to
PM2.5.
13
It
seems
to
me
that
the
evidence
as
14
we've
heard
over
and
over
again
here
­­
and
will
15
hear
further
today
I'm
sure
­­
that
PM2.5,
among
16
other
things,
is
injurious
to
health
and
can't
be
17
ignored.
And
if
we
do
so,
we
do
so
not
only
at
18
the
peril
of
those
who
are
adversely
affected
who
19
we
just
discussed,
but
for
the
rest
all
of
us
as
20
well
considering
humanitarian,
economic
and
21
social
consequences
of
chronic
ailments.
Thank
22
you.
23
MR.
BURNETT:
Thank
you
for
your
24
comments
today.
I
have
one
clarification
and
one
25
127
question,
and
I'll
ask
if
others
here
do.
1
The
first
is
that
we
are
proposing
a
2
tightening
of
the
daily
standard
from
65
to
35.
3
I
just
want
to
clarify
that
that
is
in
fact
what
4
we
are
proposing.
5
My
question
is
you
mentioned
recent
6
publications
that
have
shown
that
when
PM
levels
7
are
reduced,
health
is
improved.
I'm
wondering,
8
one,
if
you
are
able
to
submit
those
particular
9
studies
to
the
record
and
if
you
would
be
able
to
10
comment
briefly
on
the
nature
of
those
studies.
11
Are
they
bench
studies,
or
are
they
CAP­
like
12
studies?
13
DR.
ORRIS:
If
you
can
give
me
30
14
seconds,
I'll
be
able
to
respond
with
the
15
document
that
­­
I
believe
it
was
­­
appears
in
16
the
American
Journal
of
Respiratory
Diseases'
17
current
issue,
which
is
either
out
today
or
18
shortly
thereafter,
and
which
is
available
on
the
19
American
Lung
Association
web
site.
20
There
is
another
publication
in
the
21
Journal
of
the
American
Medical
Association
22
directly
related
to
this.
23
MR.
BURNETT:
Thank
you
both.
24
Next
I
would
like
to
invite
Mr.
Breuer
25
128
and
Ms.
Shoop.
1
Mr.
Breuer,
please.
2
MR.
BREUER:
Yes,
sir.
3
My
name
is
Dorian
Breuer,
last
name
4
B­
R­
E­
U­
E­
R.
5
I'm
with
an
organization
in
the
Pilsen
6
neighborhood
of
Chicago
called
the
Pilsen
7
Environmental
Rights
and
Reform
Organization.
I
8
first
had
a
question.
9
What
has
the
EPA
done
about
giving
10
notice
of
this
hearing?
How
much
money
was
11
spent?
12
MR.
BURNETT:
We
issued
a
notice
in
the
13
Federal
Register.
I
don't
know
the
details
of
14
how
much
that
cost,
but
I'll
turn
to
my
15
colleague,
Erika.
Do
you
have
any
­­
16
MS.
SASSER:
I
don't
know
the
exact
cost
17
of
it.
It
was
a
short,
half­
page
notice.
18
MR.
BREUER:
Okay.
Is
that
it?
19
MR.
BURNETT:
I
know
that
we
have
20
announced
it
publicly
as
we
have
­­
as
various
21
people
have
spoken
about
the
proposal.
I
believe
22
it's
also
on
our
web
page.
In
addition
to
that,
23
I
don't
have
the
details
of
what
our
24
communication
office
has
put
out.
25
129
MR.
BREUER:
For
example,
the
community
1
I
live
in
in
Chicago
is
a
Spanish­
speaking
2
96
percent
Latino
community
that
lives
directly
3
adjacent
to
Chicago's
two
coal­
fired
power
4
plants.
Have
you
issued
any
notices
in
Spanish
5
to
any
of
the
Spanish­
language
media
in
those
6
neighborhoods,
for
example?
7
MR.
BURNETT:
I
do
not
know,
but
I
will
8
look
into
that,
and
we
can
try
to
get
back
to
you
9
on
that
question.
10
MR.
BREUER:
This
leads
me
to
my
second
11
question.
That
is,
in
the
proposed
rules,
are
12
there
any
provisions
made
to
account
for
the
13
environmental
justice
standards
that
the
EPA
is
14
meant
to
be
following?
Is
there
any
writing
in
15
the
proposed
rules
that
will
address
16
environmental
justice
issues?
17
MS.
SASSER:
We
do
at
the
end
of
the
18
preamble
as
a
requirement
address
environmental
19
justice
issues
as
one
of
the
executive
orders
20
that
we
are
required
to
followed.
So
there
is
a
21
discussion
at
the
end
of
the
preamble
about
how
22
the
rule
interacts
with
that
executive
order
and
23
its
requirements.
24
In
particular,
we
note
that
in
this
25
130
context,
because
the
studies
that
were
done
did
1
focus
on
vulnerable
populations
of
the
type
that
2
might
be
of
concern
to
environmental
justice
3
communities,
we
feel
that
we
have
satisfied
the
4
requirements
of
that
order.
5
MR.
BURNETT:
It
is
in
Federal
Register,
6
Volume
LXXI,
Page
2694,
where
it
discusses
the
7
executive
order,
12898,
the
environmental
justice
8
executive
order.
9
MR.
BREUER:
Okay.
Our
organization
a
10
couple
of
weeks
ago
held
a
public
forum
to
11
discuss
the
pollution
that
comes
from
the
two
12
coal­
fired
power
plants
in
Chicago
and
also
13
around
the
state,
and
the
issue
of
this
fine
14
particulate
matter
came
up.
We
had
about
200
15
community
residents
come
out,
and
we
heard
16
extensive
discussion
from
the
people
that
came
17
out
from
the
Pilsen
neighborhood,
from
the
Little
18
Village
neighborhood.
19
These
are,
again,
mostly
Latino
20
neighborhoods,
and
overwhelmingly
people
were
21
extremely
concerned
about
the
health
effects
that
22
they
were
experiencing,
both
living
near
these
23
plants,
but
also
living
in
a
heavily
24
industrialized
area
of
Chicago,
which
is
this
25
131
particular
area,
which,
of
course,
includes
the
1
diesel
engine
traffic
that
they
talked
about.
We
2
heard
mothers
that
came
up
with
children,
and
3
they
felt
that
the
children's
disabilities,
in
4
one
case,
was
due
to
the
extra
pollution
that
was
5
in
the
neighborhood.
We
heard
from
a
number
of
6
people
who
had
asthma.
7
I
don't
see
anyone
from
my
neighborhood
8
here,
and
I'm
not
sure
how
anyone
in
my
9
neighborhood
would
have
heard
about
this
hearing.
10
I'm
not
sure
how
this
hearing
addresses
11
environmental
justice
issues.
12
The
people
that
live
in
my
neighborhood
13
are
largely
low
income.
The
median
average
­­
14
the
median
income
is
$
27,000
per
family,
and
it's
15
prevalent
to
have
both
parents
working
more
than
16
one
job.
The
family
that
lives
below
me
are
17
seven
in
a
small
apartment,
the
same
size
18
apartment
that
I
have
just
for
myself,
and
I'm
19
not
really
sure
how
they
would
have
heard
about
20
this
and
how
you're
ever
going
to
hear
from
these
21
people
about
the
standards
that
you're
proposing
22
for
clean
air,
for
their
clean
air.
I
know
the
23
family
below
me
has
a
child
with
asthma.
24
I'll
have
to
read
what
the
environmental
25
132
justice
arguments
are
being
made
in
your
proposed
1
rules
and
how
they
are
supposed
to
satisfy
2
environmental
justice
standards,
but
I
have
to
3
say
that
I
don't
feel
that
they
are
doing
that.
4
And
I
just
have
one
last
question
if
I
5
could.
Can
you
let
me
know
­­
and
I'll
bring
6
this
back
to
my
neighborhood
­­
the
reason
that
7
the
EPA
would
not
adopt
the
standards
that,
for
8
example,
the
American
Lung
Association
has
9
proposed,
the
standard
of
average
of
12
and
the
10
yearly
or
the
24­
hour
standard
of
25
down
from
15
11
and
65
that
is
the
current
standard.
Can
you
12
address
why
the
EPA
would
not
simply
adopt
the
13
rules
that
would
provide
obviously
the
most
14
healthy
air
for
the
most
people?
15
MR.
BURNETT:
The
question
is
an
16
important
one
and
is
complicated
enough
that
I
do
17
not
want
to
try
to
summarize
the
rationale.
But
18
I
will
point
you
to
the
preamble
of
the
proposed
19
rule,
and
I
believe
we
have
copies
or
at
least
20
the
references
to
it
where
it
does
describe
the
21
administrator's
justification
for
proposing
what
22
he
did
propose.
23
I
will
also
note,
as
I
noted
in
my
24
opening
comments,
that
we
are
taking
comments
on
25
133
a
wide
range
including
down
to
an
annual
standard
1
of
12
and
a
daily
standard
as
low
as
25.
So
we
2
are
taking
comment
and
look
forward
to
hearing
3
those
comments.
4
As
for
the
notice
of
this
hearing
and
5
other
opportunities
to
offer
public
comment,
we
6
do
have
information
in
the
back.
I
do
not
7
believe
that
that
information
is
in
any
language
8
but
English,
and
I
will
have
to
get
back
to
you
9
as
to
what
sort
of
outreach
beyond
the
outreach
10
that
I
articulated
earlier
we
have
done.
11
MR.
BREUER:
Can
I
get
a
copy
of
some
12
Spanish­
language
versions
at
some
point,
and
I
13
can
disseminate
it
in
the
communities
and
give
it
14
to
other
community
groups
that
are
in
the
15
community?
16
MR.
BURNETT:
I
will
ask
you
to
get
in
17
touch
with
Jan
Cortelyou­
Lee
after
we
actually
18
hear
from
­­
19
MR.
BREUER:
Okay.
And
people
can
20
submit
written
testimony?
21
MR.
BURNETT:
That's
right.
You
can
22
submit
comments
up
until
­­
April
17th
is
the
23
close
of
the
public
comment
period,
and
there's
a
24
variety
of
ways
that
we
accept
comments,
25
134
electronically
and
physical
comments.
1
I'd
like
to
­­
2
MS.
NEWTON:
If
I
could
just
add,
while
3
my
counterparts
here
on
the
panel
are
from
our
4
headquarters
office,
you
know,
I
am
actually
from
5
the
EPA
regional
office
in
Chicago
from
the
Air
6
and
Radiation
Division.
And
I
would
ask
that
­­
7
in
terms
of
community
concerns,
we
do
work
with
8
communities.
So
separate
and
apart
from
this
9
particular
rule­
making
action,
I
would
want
to
10
open
the
invitation,
I
guess,
if
you
haven't
11
already,
to
touch
base
with
my
office.
And,
you
12
know,
perhaps
there
are
either
forums
I
think
we
13
can
attend
to
answer
questions
or
to
look
at
14
opportunities
there
might
be
to
address
some
of
15
the
concerns
that
you
have.
16
MR.
BREUER:
I'd
be
happy
to
do
that.
17
What
­­
would
you
­­
18
MS.
NEWTON:
See
that
tall
guy
back
19
there.
20
MR.
BREUER:
Yes.
21
MS.
NEWTON:
He
works
for
me.
So
if
you
22
just,
you
know,
touch
base
with
him,
he
can
give
23
you
the
number
and
also
just
exchange
24
information.
25
135
MR.
BREUER:
Okay.
Thank
you
for
that
1
offer.
2
MR.
BURNETT:
Ms.
Shoop.
3
MS.
SHOOP:
Good
morning.
My
name
is
4
Geri
Shoop,
S­
H­
O­
O­
P.
I'm
a
senior
corporate
5
environmental
project
manager
for
air
quality
at
6
Louisiana­
Pacific
Corporation.
I'm
speaking
7
today
on
behalf
of
the
American
Forest
&
Paper
8
Association,
AF&
PA.
9
AF&
PA
is
the
trade
association
of
the
10
forest
products
industry.
It
represents
more
11
than
250
companies
and
related
associations
that
12
engage
in
or
represent
the
manufacture
of
pulp,
13
paper,
paperboard
and
wood
products.
The
forest
14
products
industry
accounts
for
more
than
15
seven
percent
of
total
U.
S.
manufacturing
output,
16
employs
1.5
million
people,
and
ranks
among
top
17
ten
manufacturing
employers
in
42
states.
18
AF&
PA
and
its
members
have
a
vital
19
interest
in
the
rule
making
regarding
fine
20
particulates.
The
resulting
rules
and
their
21
implementation
will
carry
substantial
cost
22
implications
for
the
forest
products
industry.
23
On
January
17,
2006,
the
U.
S.
EPA
24
proposed
revisions
to
the
National
Ambient
Air
25
136
Quality
Standards
for
fine
particulate
matter,
1
PM2.5.
The
proposed
revision
would
greatly
2
increase
the
stringency
of
the
PM2.5
NAAQS
at
a
3
time
when
implementation
of
the
current
standard
4
is
just
beginning
and
despite
the
fact
that
key
5
uncertainties
remain
regarding
underlying
6
science.
7
Air
quality
in
this
country
is
clean
and
8
getting
significantly
cleaner
even
as
our
economy
9
grows.
Additionally,
current
EPA
regulations
and
10
future
EPA
actions
will
continue
to
achieve
11
improvement.
12
Between
1970
and
2004,
U.
S.
gross
13
domestic
product
increased
187
percent,
vehicle
14
miles
traveled
increased
171
percent,
energy
15
consumption
increased
47
percent,
and
the
16
population
grew
by
40
percent.
Yet
during
this
17
same
time
period,
total
emissions
of
the
six
18
principal
air
pollutants
dropped
by
54
percent
19
based
upon
EPA's
own
air
trending
data.
20
Between
1990
and
1999,
air
toxic
21
emissions
declined
by
30
percent.
These
22
reductions
are
the
result
of
implementation
of
23
stationary
and
mobile
source
regulations.
24
All
new
cars
and
light
trucks
now
comply
25
137
with
the
Tier
II
program
which
established
1
tighter
tailpipe
standards
and
limits
the
amount
2
of
sulfur
and
gasoline.
These
new
standards
3
require
passenger
vehicles
to
be
77
to
95
percent
4
cleaner
than
those
produced
before
2004.
Fine
5
particulate
and
ozone
pollution
will
also
6
decrease
as
a
result
of
EPA's
2007
Clean
Diesel
7
Trucks
and
Bus
Rule.
As
a
result,
diesel
trucks
8
and
buses
will
soon
be
95
percent
cleaner
than
9
today's
models
for
smog­
causing
emissions
and
10
90
percent
cleaner
for
particulate
matter.
11
The
Clean
Air
Interstate
Rule,
or
CAIR,
12
addresses
power
plant
emissions
in
29
eastern
13
states
plus
the
District
of
Columbia.
CAIR
would
14
cut
SO2
by
more
than
40
percent
from
today's
15
levels
by
2010
and
70
percent
when
fully
16
implemented.
NOx
emissions
would
be
cut
by
50
17
percent
from
today's
levels
by
2010
and
18
60
percent
when
implemented.
19
As
mentioned
previously,
EPA
has
only
20
just
begun
its
implementation
of
current
PM2.5
21
standards.
It
is
unfair
to
move
the
goalpost
22
with
a
newly
revised
standard
before
the
states
23
and
regulated
sources
even
begin
to
comply
with
24
the
existing
PM2.5
standards.
25
138
States
are
just
beginning
to
design
1
emission­
reduction
tools
to
reach
the
existing
2
standard,
which
they
must
meet
by
2010.
EPA
has
3
not
yet
issued
any
rules
or
guidance
to
instruct
4
states
as
to
exactly
how
to
meet
the
current
5
PM2.5
NAAQS.
After
those
rules
are
issued,
6
states
must
submit
attainment
plans
for
the
7
current
PM2.5
standard
by
April
2008.
If
EPA
8
finalizes
its
proposed
revisions
to
the
existing
9
PM2.5
standard,
it
would
unfairly
burden
states
10
with
a
new
and
more­
difficult
target
even
states
11
submit
attainment
plans
for
the
current
standard.
12
The
science
developed
since
the
existing
13
PM2.5
standard
does
not
support
revising
the
14
standard.
Pursuant
to
the
requirements
of
the
15
Clean
Air
Act,
EPA
set
the
current
standard
for
16
the
PM2.5
NAAQS
at
a
level
that
is
requisite
to
17
protect
the
public
health.
18
Subsequent
to
establishing
the
existing
19
standard,
EPA's
analysis
has
shown
that
the
20
existing
standard
is
more
protective
than
EPA
had
21
originally
assumed.
For
the
proposed
changes
to
22
the
standard,
EPA
relied
upon
studies
which
do
23
not
provide
a
cause
and
effect
between
PM2.5
and
24
health
effects.
Actually,
EPA
chose
certain
25
139
epidemiological
studies
that
claim
the
1
association
between
PM2.5
and
health
effects
2
while
ignoring
other
studies
which
don't
support
3
this
relationship.
4
The
PM2.5
NAAQS
includes
everything
from
5
dust
to
sea
salt.
However,
the
science
has
not
6
proven
how
PM2.5
causes
health
effects
or
even
7
which
portion
may
be
the
cause
of
the
problem.
8
In
light
of
this
uncertainty,
it
is
premature
to
9
change
the
standard
until
definitive
scientific
10
data
shows
a
direct
relationship
between
PM2.5
11
and
health
effects.
12
Revising
the
standard
will
increase
the
13
number
of
nonattainment
areas.
These
new
14
nonattainment
areas
will
adversely
affect
both
15
large
and
small
businesses
in
those
areas
as
well
16
as
stunt
the
growth
and
expansion
of
many
urban
17
and
suburban
counties.
One
estimate
shows
that
18
the
proposed
new
standards
would
result
in
a
19
total
of
441
counties
to
be
designated
20
nonattainment,
based
upon
2004­
2005
monitoring
21
data.
22
MR.
BURNETT:
Ms.
Shoop,
I'm
going
to
23
have
to
ask
you
to
wrap
up
­­
24
MS.
SHOOP:
I'm
just
about
finished.
25
140
MR.
BURNETT:
Thank
you.
1
MS.
SHOOP:
Within
these
nonattainment
2
areas,
attracting
new
business
or
expanding
3
existing
facilities
would
require
emissions
4
offsets,
thus
pushing
development
away
from
urban
5
and
suburban
areas
to
greenfield
sites.
Harming
6
these
local
economies
by
implementing
a
new
7
standard
that
is
based
upon
unproven
science
is
8
not
sound
public
policy.
9
Thank
you
for
this
opportunity
to
10
discuss
our
views
related
to
these
proposed
11
revisions.
12
MR.
BURNETT:
Thank
you
for
your
13
comments.
14
I
have
just
one
clarifying
remark,
and
15
that
is,
as
has
been
stated
previously,
we
are
­­
16
we
do
not
consider
cost.
We
are
not
allowed
to
17
consider
cost
in
the
setting
of
the
NAAQS.
We
18
are
allowed
to
consider
cost
in
the
19
implementation
and,
in
fact,
have
done
so
in
a
20
number
of
the
rules
issued
by
U.
S.
EPA,
including
21
the
rules
that
you
mentioned
such
as
the
Clean
22
Air
Interstate
Rule.
23
My
question
I
guess
is
twofold.
One,
24
you
made
several
comments
about
the
transition
25
141
between
existing
standards
and
new
standards,
1
should
we,
come
September,
propose
­­
or
finalize
2
revisions.
I'm
wondering
if
you
have
looked
at
3
the
Advanced
Notice
of
Proposed
Rule
Making,
and
4
would
encourage
you
to
do
so.
5
MS.
SHOOP:
Yes.
We
have
looked
at
it.
6
We'll
be
commenting
on
it.
One
comment
we
do
7
make
is
it's
interesting
that
the
public
comment
8
period
ends
on
that
prior
to
the
­­
ending
of
the
9
public
comment
on
the
actual
standards
10
themselves,
which
seemed
a
little
out
of
whack.
11
MS.
SASSER:
Well,
we
should
note
there,
12
though,
that
that
is
an
advanced
notice,
and
its
13
purpose
is
to
solicit
comment
on
quite
a
number
14
of
issues,
and
we
will
follow
that
with
a
full
15
proposal
and
another
comment
period.
So
­­
16
MS.
SHOOP:
Sure.
17
MR.
BURNETT:
I'd
like
to
thank
you
both
18
and
request
that
Ms.
Reese
and
Ms.
Erickson
19
please
come
up
to
the
table.
20
MS.
REESE:
I'm
an
actual
and
evidently
21
rare
member
of
the
public
­­
22
MR.
BURNETT:
I'm
sorry.
If
I
could
ask
23
you
to
introduce
yourself.
24
MS.
REESE:
My
name
is
Joy
Reese,
and
25
142
I'm
a
real
member
of
the
public.
I
read
the
1
newspapers
thoroughly,
and
I
watch
national
and
2
public
local
television.
And
I
didn't
know
about
3
this
until
nine
o'clock
this
morning,
and
I
had
4
to
do
some
digging
to
go
find
out
what
time
and
5
where.
So
this
is
very
hard
to
find
out
about
6
these
public
hearings.
7
I
had
this
experience
once
before,
and
I
8
saw
a
tiny
ad
in
a
help­
wanted
ad,
and
I
wasn't
9
looking
for
a
job,
but
I
happened
to
see
it
that
10
day.
But
the
public
is
not
being
informed
about
11
these
public
hearings.
12
I
would
like
to
know
why
the
EPA
deleted
13
latest
research
and
softening
the
conclusions
14
about
harmfulness
and
soot
and
the
substantial
15
impact
on
health
and
why
do
you
want
to
lower
the
16
standards?
17
MR.
BURNETT:
The
rationale
for
lowering
18
the
standard
to
a
more
protective
standard
of
15
19
annual
and
35
daily
is
spelled
out
in
the
20
preamble.
And
as
I
said
before,
I
don't
want
to
21
summarize
those
arguments
because
the
details
are
22
important,
and
I
don't
want
to
gloss
over
those.
23
MS.
REESE:
You
have
huge
amounts
of
24
data
connecting
health
affects
and
they're
25
143
incontrovertible.
So
why
question
them?
Even
1
from
your
own
scientists
as
well
as
many
outside
2
sources.
I
mean,
I
don't
understand
even
the
3
reason
for
having
this
because
you
have
the
4
evidence.
And
I
wonder
what
impact
all
these
­­
5
these
public
hearings
have
on
your
decision
6
making?
Or
is
your
decision
­­
it's
just
a
7
facade
that
you've
already
made
your
decision?
8
MR.
BURNETT:
The
Administrator
has
made
9
a
preliminary
decision,
and
that
is
reflected
in
10
the
proposal.
But
as
I
said
in
my
opening
11
remarks,
we
are
taking
comments
on
a
wide
range
12
of
alternatives,
and
that's
because
we
believe
13
that
there
are
very
important
questions
14
reflective
in
­­
reflected
in
different
people
15
advocating
different
levels,
and
we
fully
intend
16
to
look
at
all
comments
and
take
them
into
17
careful
consideration
in
formulating
our
final
18
ruling.
19
MS.
REESE:
And
regardless
for
all
the
20
adults
and
children
who
suffer
with
chronic
21
disability
and/
or
death,
I
thought
your
mission
22
was
to
protect
the
public
health
and
the
23
environment.
That
is
what
your
stated
mission
24
is.
That's
who's
paying
you
is
the
public
I
25
144
believe.
1
There's
no
justification
for
lowering
2
the
standards,
and
the
public
health
should
not
3
be
secondary
to
private
interests.
4
The
black
dust
I
experience
daily
­­
I'm
5
talking
about
my
own
problem
­­
in
my
apartment
6
is
­­
has
been
causing
me
chronic
sinus
since
7
I've
moved
to
Chicago.
I
was
healthy
before
I
8
move
here,
and
I
have
developed
all
kinds
of
9
allergies
as
a
result
as
well.
I've
experienced
10
many
days
disability
where
I
can't
function,
11
think,
do
anything
up
to
five
months
a
year.
And
12
this
is
­­
many
people
call
Chicago
the
13
capital
­­
science
capital
of
America.
Probably
14
also
asthma,
but
I
don't
know
about
that
part.
15
Fortunately
it
hasn't
happened
yet
to
me.
16
Just
look
out
the
window
today
because
17
there's
pollution
right
out
there.
And
I
look
18
out
the
window
every
day,
and
it
affects
my
life
19
constantly
whether
I
go
out
or
don't
go
out.
20
Most
of
the
warm,
nice
days
I
don't
go
out.
I
21
stay
home,
holed
in,
running
my
air
purifiers,
22
which
I
have
three
of
them,
which
really
don't
do
23
that
much
good.
24
And
I
try
to
warn
people.
My
daughter
25
145
goes
out
with
her
kids
on
unhealthy
air
days.
I
1
tell
her
about
them.
And
most
of
the
public
­­
2
she's
just
typical
­­
ignore
this
and
don't
even
3
know
about
it.
She
didn't
know
about
it.
So
my
4
grandkid,
one
of
them,
has
a
chronic
cough
which
5
I
assume
is
from
that.
6
I
support
the
12
micrograms
per
cubic
7
meter
with
a
24
maximum.
8
Over
50
thousand
nonsmokers
die
of
lung
9
cancer
annually
I've
read.
I'm
also
concerned
10
about
the
mercury
that's
attracted
to
the
lake
11
from
coal
plants.
I'm
sure
that
the
coal
plants
12
are
accumulating
in
my
soot
as
well
­­
the
13
mercury
that
is.
And
because
I
live
near
the
14
lake,
I'm
concerned
about
the
coal.
Why
EPA,
in
15
all
these
many
years,
have
not
enforced
the
coal
16
power
plants
to
lower
their
emissions.
I
just
17
don't
get
it.
18
I'm
sure
many
neurological
diseases,
19
quote,
unquote,
stem
from
mercury
pollution
in
20
fish,
but
the
air
is
not
great.
21
So
please
do
the
right
thing.
Enforce
22
the
right
of
the
public
to
breathe
healthy
air,
23
which
should
be
their
birthright,
by
the
way,
and
24
should
be
nonnegotiable.
The
bottom
line
should
25
146
not
be
the
buck
but
public
health.
1
MR.
BURNETT:
I'm
going
to
have
to
ask
2
you
to
wrap
up.
3
MS.
REESE:
Unless
you
consider
the
huge
4
public
cost
of
health
care,
that
is
the
buck
you
5
should
consider.
Thank
you.
6
MR.
BURNETT:
Thank
you.
And
actually
7
if
you
wouldn't
mind
staying
at
the
table
just
8
while
the
other
person
talks.
But
we
do
have
a
9
question,
please.
10
MR.
WEINSTOCK:
Miss
Reese,
I'm
just
11
curious.
What
other
ways
should
we
have
12
advertised
this
that
would
have
worked
for
your
13
particular
situation?
People
get
information
14
differently
­­
15
MS.
REESE:
Well,
an
article
in
a
16
newspaper
would
be
helpful.
There's
in
Chicago
17
the
Sun­
Times
and
the
Tribune
here.
The
local
18
radio
stations,
Channel
10
and
9,
and
there
are
19
others.
The
public
never
knows
about
this
stuff.
20
I
mean,
I
went
to
another
event
once
21
that,
as
I
say,
I
was
the
only
member
of
the
22
public.
This
is
kind
of
disconcerting.
This
is
23
supposed
to
be
affecting
us,
and
we're
supposed
24
to
come,
right?
25
147
MR.
WEINSTOCK:
Thank
you.
1
MR.
BURNETT:
Ms.
Erickson.
2
MS.
ERICKSON:
Thank
you.
3
Good
morning.
My
name
is
Nancy
4
Erickson,
the
Director
of
Natural
and
5
Environmental
Resources
with
the
Illinois
Farm
6
Bureau,
and
we
appreciate
the
opportunity
to
7
provide
you
some
initial,
brief
comments
with
the
8
proposed
revision
to
the
National
Ambient
Air
9
Quality
Standards
for
particulate
matter,
and
we
10
will
submit
additional
comments
in
greater
detail
11
prior
to
the
close
of
the
comment
period
on
12
April
17.
13
The
Illinois
Farm
Bureau
is
a
voluntary
14
grassroots
organization
whose
members
include
15
about
three­
fourths
of
the
farmers
in
the
State
16
of
Illinois,
and
Illinois
Farm
Bureau
supports
17
voluntary
best­
management
practices
and
18
educational
efforts
to
address
natural
resource
19
issues
including
voluntary
efforts
to
help
20
control
fugitive
dust
issues.
21
We
do
have
concerns
with
the
proposed
22
regulations
however.
First
and
foremost,
we
23
question
whether
science
indicates
that
coarse
24
particulate
matter
causes
health
problems.
We,
25
148
therefore,
support
the
repeal
of
the
existing
1
PM10
standard
without
replacement.
2
However,
if
a
standard
is
going
to
be
3
set,
we
support
the
agency's
proposed
exclusion
4
of
agricultural
crustal
emissions
from
the
new
5
coarse
PM
standard.
We
believe
that
this
6
exclusion
makes
it
clear
that
there
is
not
7
sufficient
basis
to
control
these
sources
to
8
obtain
public
health
benefits.
This
is
an
9
acknowledgment
that
coarse
particulate
matter
is
10
really
not
a
problem
and
echoes
the
agency's
11
statement
that
evidence
does
not
support
12
standards
for
windblown
dust
and
soil
by
13
agricultural
sources.
14
Our
concerns
with
this
exclusion
of
15
agricultural
emissions
from
the
standard
centers
16
on
whether
the
exclusion
would
stand
up
if
it
17
were
challenged.
Here
again
our
position
is
that
18
science
does
not
support
the
need
for
coarse
19
particulate
standard
to
protect
human
health,
and
20
at
the
very
least,
the
agency
must
insure
that
21
any
exclusion
is
legally
structured
and
strong
to
22
withstand
a
challenge.
23
We
will
continue
to
support
monitoring
24
and
research
on
this
issue.
Monitoring
must
be
25
149
practical,
accurate,
and
not
merely
an
1
extrapolation
of
data.
Of
course,
PM
standards
2
should
not
be
established
unless
or
until
3
research,
based
on
sound
science,
justifies
a
4
health­
based
standard.
We
feel
the
current
5
scientific
evidence
does
not
support
the
adoption
6
of
coarse
PM
standards
at
the
concentrated
levels
7
of
the
existing
standards
or
of
those
proposed.
8
In
conclusion,
we
urge
the
agency
to
9
repeal
the
PM10
standards
without
replacement.
10
However,
if
the
agency
chooses
to
exclude
11
agriculture
from
the
new
particulate
matter
12
standards,
any
exclusion
we
feel
must
be
done
13
correctly
so
that
this
exclusion
will
not
­­
will
14
be
strong
enough
to
withstand
any
future
15
challenges.
16
We
thank
you
for
the
opportunity
to
17
comment
on
the
regulations.
18
MR.
BURNETT:
Thank
you
for
your
19
comments.
20
In
the
preamble
to
the
proposed
rule,
we
21
described
several
coarse
fraction
studies
that
22
went
into
Administrator's
judgment
to
propose
the
23
coarse
standard
that
he
did.
Do
you
have
24
comments
on
those
particular
studies
either
now,
25
150
or
will
you
be
providing
them?
1
MS.
ERICKSON:
We
will
be
providing
them
2
prior
to
the
April
17th
deadline.
3
MR.
BURNETT:
Thank
you
both
for
your
4
comments.
5
Dr.
Ehrman
and
Mr.
Riedinger.
6
DR.
EHRMAN:
Good
afternoon.
My
name
is
7
Dr.
Howard
Ehrman.
Last
name
is
spelled
8
E­
H­
R­
M­
A­
N.
I'm
an
assistant
professor
at
the
9
University
of
Illinois
at
Chicago
in
the
College
10
of
Medicine
and
the
School
of
Public
Health,
and
11
I'm
also
a
board
member
of
the
Little
Village
12
Environmental
Justice
Organization
here
in
13
Chicago.
14
I'd
also
like
to
ask
a
question
about
15
these
public
hearings.
I'd
like
to
know,
since
16
there
are
10
federal
regions
included
for
the
17
U.
S.
EPA,
why
are
there
only
three
hearings
in
18
the
United
States?
19
MR.
BURNETT:
We
have
responded
to
a
20
request
for
hearings,
and
we
worked
to
strike
the
21
right
balance
between
resource
concerns
and
22
hearings
so
that
we
­­
throughout
the
country
so
23
that
we
could
hear
from
individuals.
I
will
note
24
that
there
are
a
variety
of
other
ways
that
25
151
individuals
can
submit
their
comments,
and
we
1
encourage
individuals
who
have
not
been
able
to
2
attend
one
of
the
hearings
today
to
submit
3
comments
either
in
­­
electronically
or
in
hard
4
copy.
And
if
you
are
interested
in
how
that
can
5
be
done,
we
have
a
handout
at
the
registration
6
desk.
7
DR.
EHRMAN:
Yes,
I
have
a
handout.
8
If
interested
citizens,
residents,
9
elected
officials
want
hearings
in
their
federal
10
region,
would
they
just
contact
the
Administrator
11
then?
12
MR.
BURNETT:
I
believe
that
these
are
13
the
three
hearings
that
we're
holding
for
these
14
two
proposed
rules.
If
individuals
­­
as
I
said,
15
if
individuals
were
not
able
to
attend
these
16
hearings,
or
even
if
they
were
able
to
attend
17
these
hearings
and
they
have
comments
they'd
like
18
to
submit
to
the
record,
the
record
­­
the
docket
19
is
open.
The
public
comment
period
is
open
until
20
April
17th.
21
DR.
EHRMAN:
Right.
22
I
guess
I'm
in
favor
and
I'll
work
with
23
people
as
well
as
the
other
organizations
here
24
nationally
to
insure
that
this
period
is
extended
25
152
and
that
submitting
comments
electronically
or
1
any
other
way
is
not
public
comment
in
the
sense
2
of
that
other
people
don't
know
about
it
as
3
opposed
to
people
sitting
here
in
the
room
and
4
reporters
and
other
people
can
pick
up
on
these
5
comments.
6
I'm
here
basically
to
oppose
the
7
proposed
standards
of
15
micrograms
per
cubic
8
meter
a
year
and
the
35
microgram
per
cubic
meter
9
daily
standard
and
to
replace
those
with
what
10
your
own
scientific
advisors
for
both
adults
and
11
children
held,
and
many
other
people
I'm
sure
12
this
morning
in
other
places
have
said
that
13
should
be
12
micrograms
per
cubic
meter
for
each
14
year,
and
the
limit
for
daily
exposure
should
be
15
25.
16
I
think
the
scientific
data
is
17
overwhelming.
And
I
think,
like
a
lot
of
other
18
people,
this
decision
was
not
made
on
the
basis
19
of
what
the
Clean
Air
Act
clearly
says
and
what
20
you've
already
stated:
That
business
21
considerations
and
monetary
and
financial
22
considerations
are
not
supposed
to
be
taken
into
23
effect.
They're
supposed
to
be
health­
based
24
standards,
and
I
think
those
health­
based
25
153
standards
do,
however,
interact
with
the
economic
1
situation
in
this
country
and
the
world.
2
And
I
think
that
one
of
the
things
3
that's
really
important
is
to
see
what's
happened
4
with
other
so­
called
experiments
in
basically
5
fooling
around
with
the
Clear
Air
Act
that
have
6
already
happened.
The
biggest
one
is
cap
and
7
trade
with
sulfur
dioxide.
8
Your
own
consultants
for
your
9
statistical
analysis
for
the
U.
S.
EPA,
one
of
the
10
primary
sources
used
is
ABT,
which
is
based
in
11
Washington,
DC.
ABT
is
an
independent
consultant
12
group
that
always
works
with
Clear
the
Air,
which
13
is
a
national
coalition
also
based
in
Washington,
14
D.
C.
and
Boston.
Their
analysis,
which
was
15
issued
in
a
report
that's
available
on
the
web
16
and
in
hard
copy,
in
2005
basically
said
very
17
clearly
that
all
those
coal­
power
plants
that
18
were
built
before
1977
actually
are
putting
out
19
more
sulfur
dioxide
than
they
were
before
cap
and
20
trade.
21
This
is
very
likely
the
conclusion
I
22
think
that
you
can
reach
based
on
the
fact
that
23
cap
and
trade
meets
those
newer
power
plants
that
24
are
easier
to
upgrade
to
new
standards
­­
25
154
basically,
that's
happened
­­
and
that
those
old
1
power
plants
basically
have
gone
to
pot,
2
literally
and
figuratively.
3
The
other
thing
I
would
like
to
refer
to
4
is
the
question
of
what
studies,
you
know,
are
in
5
there?
For
example,
one
question
is:
Is
the
6
epidemiology
from
the
Journal
of
Epidemiology
7
study
of
November
2005
taken
into
consideration
8
in
these
new
standards.
That's
the
study
done
by
9
Jerrett,
et
al.
which
I
have
here,
and
I'd
be
10
happy
to
give
you
a
copy
of,
Spatial
Analysis
of
11
Air
Pollution
and
Mortality
in
Los
Angeles.
Was
12
that
study
taken
into
effect?
13
MR.
BURNETT:
If
it
was
not
in
the
14
proposal,
we
have
a
process
whereby
the
studies
15
are
pulled
together
in
a
Criteria
Document,
and
16
that
document
closed
several
years
ago.
And
then
17
that
document
was
used
to
generate
a
Staff
Paper,
18
which
we
have
a
copy
of
that
we
can
show
you,
and
19
then
that
Staff
Paper
was
used
to
inform
the
20
Administrator's
decision.
21
It's
part
of
the
process
that
we
do
22
currently
have
a
cutoff
period,
and
then
we
do
23
this
provisional
assessment
that
I
mentioned
24
earlier
whereby
studies
that
we
have
collected
25
155
and
that
are
submitted
to
us
during
this
public
1
comment
period
are
taken
into
account
before
a
2
final
decision
is
made.
So
that
study
we
will
3
take
a
careful
look
at
before
a
final
decision
is
4
made.
5
DR.
EHRMAN:
Okay.
I
just
want
to
close
6
by
just
quoting
a
couple
things
from
this
study
7
and
also
about
the
Peters
and
Polk
study.
8
Basically
this
study
and
its
result
say
that
9
the
­­
and
the
thing
that's
important
about
this
10
study
was
it's
the
first
time
­­
11
MR.
BURNETT:
I'm
sorry.
I'm
looking
12
down
at
the
clock.
I'm
going
to
have
to
ask
you
13
to
keep
this
very
brief.
14
DR.
EHRMAN:
Okay.
Well,
it's
the
first
15
time
there's
been
actually
intracommunity
studies
16
done
that
show
the
relative
risk
for
both
lung
17
cancer
and
cardiovascular
heart
disease
18
significantly
increased.
The
Peters
and
Polk
19
study
that
was
done
of
almost
7,000
children
20
prospectively
over
ten
years,
clearly
showed
that
21
those
children
that
were
at
high
exposures
to
22
particulate
matter
had
asthma,
and
it's
the
first
23
time
the
proposal
was
made
where
data
is
now
24
accumulating
very
quickly
that
particulate
matter
25
156
is
not
just
an
exacerbation
factor
for
asthma
but
1
actually
probably
is
the
cause
of
asthma.
2
The
last
thing
I
want
to
just
say
is
3
basically
­­
4
MR.
BURNETT:
I
am
at
this
point
­­
I'm
5
sorry.
In
the
interest
of
fairness,
we
have
a
6
number
of
people
who
would
like
to
comment.
We
7
will
take
a
careful
look
at
the
studies
that
you
8
referenced.
I
would
encourage
you
to
submit
9
those
in
the
docket,
which,
by
the
way,
is
a
10
public
docket
so
that
everybody
can
see
what
11
everybody
else
submits
­­
12
DR.
EHRMAN:
So
the
time
of
you
13
answering
question
counts
against
us,
the
time
14
for
testimony?
15
MR.
BURNETT:
In
the
interest
of
16
fairness,
I'm
trying
to
move
along
this
process.
17
And
I'll
ask,
Mr.
Riedinger,
for
your
18
comments,
please.
19
MR.
RIEDINGER:
Thank
you.
20
My
name
is
Dan
Riedinger,
21
R­
I­
E­
D­
I­
N­
G­
E­
R,
and
I'm
a
spokesman
for
the
22
Edison
Electric
Institute
in
Washington,
D.
C.
23
EEI
is
the
association
of
U.
S.
shareholder­
owned
24
electric
companies,
and
our
members
generate
25
157
about
60
percent
of
the
nation's
electric.
1
Power
plants
and
other
industrial
2
sources
have
been
making
dramatic
reductions
in
3
emissions
for
decades
while
supplying
the
4
nation's
ever­
increasing
demand
for
energy
and
5
consumer
products.
The
electric
power
sector
6
itself
already
has
cut
emissions
associated
with
7
fine
particulate
matter
by
more
than
40
percent
8
since
1980
with
additional
major
reductions
9
underway.
10
Whether
EPA
tightens
the
fine
particles
11
as
proposed
or
leaves
the
current
standards
in
12
place,
air
quality
will
continue
to
significantly
13
improve.
The
power
sector
is
on
track
to
reduce
14
its
sulfur
dioxide
and
nitrogen
oxides
emission
15
rates
by
more
than
90
percent
upon
implementation
16
of
EPA's
Clean
Air
Interstate
Rule,
Clean
Air
17
Mercury
Rule,
and
Clean
Air
Visibility
Rule.
18
These
amount
to
huge
pollution
cuts
19
already
in
the
pipeline
ordered
just
within
this
20
past
year,
and
we
think
EPA
should
give
them
a
21
chance
to
work
before
seeking
additional
22
emissions
reductions.
23
EEI's
comments
focus
on
the
EPA
proposal
24
to
reduce
the
24­
hour
fine
particle
standard.
25
158
EEI
supports
the
establishment
of
air
quality
1
standards
based
on
complete
and
thorough
review
2
of
the
current
body
of
scientific
literature.
3
Unfortunately,
we
do
not
yet
believe
EPA
has
4
completed
such
a
review.
5
Our
concern
is
that
the
science,
to
some
6
degree,
has
been
cherry­
picked,
giving
short
7
shrift
to
studies
that
suggest
PM2.5
itself
8
presents
little
or
no
concern.
9
Equally
important
is
the
fact
that
EPA's
10
review
of
the
scientific
literature
fails
to
11
assess
and
identify
specific
types
of
particles
12
or
other
pollutants
that
may
be
present
in
the
13
air
along
with
fine
particulate
matter
that
may
14
be
more
significantly
associated
with
health
15
concerns.
This
issue
has
been
raised
by
the
16
National
Academy
of
Scientists
and
EPA's
office
17
of
Inspector
General.
As
a
result,
EPA
may
not
18
truly
know
which
of
the
many
substances
that
19
comprise
fine
particulate
matter
might
be
causing
20
a
problem.
Obviously,
legitimate
health
concerns
21
have
to
be
addressed,
but
moving
ahead
with
a
22
plan
that
may
not
in
fact
address
them
is
in
no
23
one's
best
interest.
24
EPA's
inspector
general
has
recognized
25
159
the
potential
pitfalls
of
heading
further
down
1
the
road
to
regulation
without
adequate
guidance
2
as
to
what
should
be
regulated.
In
a
3
February
2005
report,
the
IG
determined
that
by
4
2010
industry
would
spend
37
billion
annually
to
5
reduce
ambient
fine
particle
concentrations,
6
despite
the
fact
that
the
agency
has
inadequate
7
fine
particle
speciation
data
to
help
insure
that
8
reductions
are
made
by
the
right
sources.
9
In
contrast
to
these
uncertainties,
the
10
consequences
of
being
classified
as
a
11
nonattainment
area
are
far
reaching
and
very
12
real.
13
An
analysis
for
the
American
Petroleum
14
Institute
of
the
impact
of
the
proposed
standard
15
finds
that
more
than
225
additional
counties
will
16
be
thrown
into
nonattainment.
Again,
public
17
health
always
is
paramount,
but
let's
be
sure
18
we're
providing
the
public
with
the
health
19
benefits
they
expect
before
we
lower
the
boom
on
20
local
economies.
21
In
closing,
the
science
supporting
EPA's
22
proposed
tightening
of
the
fine
particle
standard
23
presents
some
uncertainties
while
the
potential
24
costs
to
consumers
are
very
real.
EPA
should
25
160
allow
states
to
implement
the
existing
standard,
1
which
they
must
meet
by
2010,
before
moving
the
2
regulatory
goalposts
yet
again.
3
EEI
appreciates
the
opportunity
to
4
discuss
our
views
on
the
EPA's
proposed
5
particulate
matter
standards.
Thank
you.
6
MR.
BURNETT:
Thank
you
for
your
7
comments.
8
A
clarifying
question.
You've
described
9
a
percent
reduction
in
SO2.
I'm
wondering
if
you
10
can
­­
I
wonder
if
I
misheard.
In
the
early
part
11
of
your
remarks.
12
MR.
RIEDINGER:
Sure.
We've
got
­­
13
we've
made
about
40
percent
reductions
in
SO2
and
14
NOx
since
1980
because
of
regulatory
15
requirements.
Requirements
already
on
the
books
16
will
cause
us
to
further
improve
our
emission
17
rates
to
about
90
percent,
which
I
think,
as
has
18
been
said
earlier,
translates
into
reductions
19
into
SO2
and
NOx
by
about
40
percent
and
20
50
percent
respectively.
Or
another
way
put,
21
about
70
percent
reductions
forthcoming
using
22
2003
as
a
baseline
in
SO2,
NOx,
and
mercury.
23
MR.
BURNETT:
Okay.
Thank
you
for
that
24
clarification.
25
161
I
want
to
thank
you
both
and
request
1
that
Ramsey
and
Ms.
Shultz
please
come
forth.
2
MR.
RAMSEY:
My
name
is
Steve
Ramsey.
3
I'm
just
another
average
citizen
who
just
came
to
4
speak
today
about
this.
5
I
here
a
lot
of
data
being
thrown
out
6
here
and
a
lot
of
large
industries
talking
about
7
lowering
the
boom
on
the
economy.
And
these
are,
8
in
my
personal
point
of
view,
very
large
and
9
wealthy
industries,
and
I
don't
think
we're
going
10
to
be
lowering
the
boom
on
them
if
we
try
to
make
11
our
air
cleaner.
I
don't
see
how
the
cost
factor
12
could
outweigh
the
importance
of
the
health
13
issues.
14
And
I
know
we've
been
hearing
all
sorts
15
of
data
about
rising
health
costs
and
if
we
16
penalize
the
industries
to
enforce
cleaner
17
standards,
it's
going
to
cost
them,
you
know,
18
this
many
dollars,
and
it's
going
to
result
in
19
things
being
more
expensive
and
crippling
the
20
economy,
which
is
an
old
song
and
dance
I've
21
heard
all
my
life.
And
the
credibility
of
that
22
is
very,
very
thin.
23
The
Bush
Administration
has
rejected
its
24
own
independent
study
and
some
of
the
EPA
25
162
studies.
And
whatever
we
talk
about
here
today,
1
if
the
administration
just
decides
to
reject
your
2
recommendations
of
lowering
the
standards
­­
and
3
in
my
opinion
they
are
not
low
enough.
But
you
4
can
say,
okay,
165,
135,
or
112
for
our
daily,
5
for
our
24­
hour
period.
It's
­­
where
does
that
6
leave
us
when
we've
all
walked
away
from
here
and
7
you
guys
have
said,
yes,
we're
going
to
lower
to
8
this
amount,
and
in
five
years
we're
gonna
review
9
and
lower
to
the
next
amount,
and
we'll
do
a
90
10
percent
reduction,
if
when
we
all
walk
away
11
later,
the
administration
just
rejects
your
12
findings,
your
studies.
13
And
it
sounds
like
more
fuzzy
science
to
14
me
when
we
have
studies
done
and
then
reject
them
15
based
on
an
administration
that
decides,
well,
16
you
know,
what's
important
to
the
country
is
the
17
economy,
which
may
mean
our
big
industrial
18
friends
make
lots
of
money,
not
health
care
for
19
individuals.
And
I
know
that
the
administration
20
is
supposed
to
be
doing
what's
best
for
the
21
people
and
what's
best
for
the
nation,
but
I
just
22
keep
seeing,
time
and
time
again,
that
whatever
23
the
spin
is,
the
bottom
line
always
turns
out
24
that
the
people
­­
industry,
big
money,
campaign
25
163
donations,
powerful
lobbyists,
these
are
the
1
people
that
have
the
administration's
ear.
2
So
I
could
go
on
and
on.
Actually
what
3
I
have
written
I'm
totally
not
even
using
because
4
the
information
I'm
hearing
today
is
giving
me
5
the
more
spontaneous
material
that
I'm
spewing
at
6
you
at
the
moment.
7
So,
you
know,
we've
all
heard
the
8
science
data
and
what
the
amount
should
be,
what
9
they
suggest
that
it
be
lowered
to,
what
they
10
were
in
'
70s,
what
they
were
in
the
'
90
11
revisions.
And
I
see
you're
going
toward
the
12
right
direction.
You're
trying
to
go
in
the
13
right
direction,
not
enough
for
the
public.
But
14
as
I
said
earlier,
even
if
your
recommendations
15
are
in
line
with
what
the
public
says,
if
the
16
administration
just
says,
well,
you
know,
so
far
17
for
that
study.
We
stay
X,
Y,
Z.
18
That's
all
I
would
have
to
say.
Thank
19
you
for
the
time
to
speak
today.
20
MR.
BURNETT:
And
thank
you
for
your
21
comments.
It's
been
said
before,
but
costs
and
22
the
economic
considerations
are
not
a
factor
that
23
we
consider
and
cannot
be
considered
under
the
24
clean
air
act.
25
164
In
terms
of
the
­­
where
we
are
in
the
1
process,
Administrator
Johnson
has
made
his
2
preliminary
judgment
that
tightening
the
daily
3
standard
from
65
to
35
is
justified.
We're
4
taking
comment
on
a
wide
range
of
other
issues
5
and
appreciate
comments
such
as
yours
and
6
everyone
else's
here
today.
7
Please,
Ms.
Shultz.
8
MS.
SHULTZ:
Hi.
I'm
Jan
Shultz,
9
S­
H­
U­
L­
T­
Z.
10
I
heard
about
this
hearing
from
PIRG,
11
and
I
thought,
well,
I
should
probably
get
12
involved
in
something
like
this
because
when
I
13
walk
out
of
my
door
­­
I
live
by
the
lake
­­
many
14
times
I
have
the
overwhelming
smell
of
gasoline
15
and
car
emissions,
and
there
was
a
semitruck
that
16
was
parking
in
our
alley
for
a
number
of
months.
17
And,
you
know,
I'm
a
gardener.
I'm
a
human
being
18
on
this
planet,
and
I
want
to
breathe
good
air.
19
Okay.
20
I
did
a
little
stint
with
the
EPA
as
a
21
temp
with
you
guys,
and
I
was
really
stunned
by
22
the
amount
of
paperwork
you
guys
have
to
deal
23
with.
It's
an
amazing
thing.
And
just
listening
24
to
the
industry
here
talk
about
their
stats
and
25
165
going
through
their
little
speeches
about
how
1
well
they're
doing
and
everything,
I
would
like
2
to
be
the
person
here
that
brings
it
to
a
very
3
human,
you
know,
touch
on
the
whole
thing.
4
I
mean,
Dana
Reeves
just
died
of
cancer.
5
Everybody
is
talking
about
it.
She
died
of
6
cancer
because
probably
she's
had
some
problem
7
with
pollution
­­
you
know,
who
knows.
We
don't
8
know
exactly.
She's
not
a
smoker.
We
know
9
smoking
is
bad.
So
we're
changing
­­
you
know,
10
the
whole
City
of
Chicago
has
come
on
board
with
11
the
smoking
thing.
12
We
cannot
relax
the
standards
that
we've
13
grown
to
at
this
point.
If
we
were
living
with
14
what
we
had
created
in
the
'
60s
when
I
was
born,
15
we'd
all
be
dead
now.
You
know,
we
all
know
the
16
reality
of
the
science
that's
out
there.
You
17
guys,
it's
on
paper.
You
have
stacks
of
it
in
18
your
offices.
And
you
guys
are
the
ones
we're
19
depending
on
to
make
sure
that
we
do
the
right
20
thing
here.
21
It's
not
­­
it's
not
really
a
question
22
of
whether
or
not
there's
a
link
between
these
23
emissions
and
cancer
and
heart
disease
and
24
asthma.
I
mean,
the
children
with
all
these
25
166
problems.
They
live
­­
I
have
friends
that
live
1
in
Pilsen.
Little
Spanish
kids
with
asthma.
2
That's
the
big
news
over
there.
How
can
we
let
3
this
just
continue
and
not
­­
it's
not
about
4
money.
It
shouldn't
be
about
money
all
the
time.
5
And
all
of
these
corporations
­­
we're
6
all
part
of
these
corporations.
All
these
people
7
that
have
the
stats
and
the
­­
you
know,
several
8
people
spoke
before
us
that
had
lots
to
say
about
9
how
bad
it
is
for
business.
Well,
you're
10
business.
We're
all
business.
We're
all
part
of
11
this.
And
there
are
better
ways
to
do
it.
12
We
know
from
the
science
that's
been
13
read
here,
you
know,
the
studies
that
have
been
14
done
that
we
should
be
following
these
standards.
15
And
just
don't
let
it
happen,
you
know.
16
Really,
until
­­
you
know,
a
friend
of
mine
17
just
­­
you
know,
he
was
a
strong
­­
you
know,
he
18
had
­­
he
just
confessed
to
me
that
he
was
always
19
against
stem
cell
research.
He's
very
20
Republican,
very
bright.
Nice
guy,
very
21
artistic.
But
he
was
always
against
it.
22
Guess
what?
He
has
MS.
Guess
what?
23
He's
liberal
now
and
he
is
supporting
stem
cell
24
research.
25
167
Now,
when
does
it
have
to
happen
to
1
these
people
to
bring
it
home
that
when
you
walk
2
out
your
door
and
you
smell,
like,
sulfur
dioxide
3
or
whatever
these
chemicals
are
that
come
at
us
4
in
the
summertime
from
the
Indiana
­­
the
poor
5
people
who
live
down
there.
You
know,
it's
6
not
­­
we
all
share
in
this.
We
can
control
it,
7
and
we
are
all
part
of
it.
And
I
just
want
to
8
make
sure
that
everyone
understands
that,
you
9
know,
it's
not
really
­­
corporate
profits
10
shouldn't
really
be
our
concern.
We
are
11
corporations
ourselves,
but
I
mean
we
are
all
12
going
to
suffer
from
the
effects
of
this.
13
Thanks.
14
MR.
BURNETT:
Thank
you
for
your
15
comments.
16
For
fine
PM,
PM2.5,
what
we
are
17
proposing
is
a
tightening.
A
number
of
people
18
have
expressed
their
desire
that
we
tighten
it
19
further,
but
there's
no
­­
we're
not
even
­­
for
20
PM2.5
we
are
not
even
taking
comment
on
21
relaxation.
So
this
is
all
about
­­
22
MS.
SHULTZ:
­­
how
far
you
want
to
go.
23
Let's
go
as
far
as
we
can
is
my
point.
24
Why
are
we,
like,
stumbling
over
ourselves
trying
25
168
to
make
it
harder?
You
know
what
I
mean?
It's
1
like
the
science
is
here.
This
is
the
2
recommendation.
We're
smart
people,
you
know.
3
And
I
just
think
people
aren't
connected
to
the
4
fact
that
it
includes
them.
It's
not
just
that
5
they
work
at
this
company,
or
they
have
this
job,
6
or
they're
lost
in
all
the
stacks
of
paperwork.
7
It's
like
their
grandmother,
their
kids.
8
Everybody
is
affected.
9
Let's
go
as
far
as
we
can
to
make
sure
10
that
we
are
being
smart
about
it.
And
the
11
science
is
there
to
lead
the
way.
So
don't
12
fall
­­
don't
grab
on
the
bandwagon
when
your
13
cousin
dies
of
lung
cancer,
you
know.
I
mean,
14
that's
what
people
do.
It's
an
amazing
thing
to
15
me.
16
Go
to
the
12
micrograms
limit.
Why
17
wait?
Why
go
35,
24.
Just
go
to
the
lowest.
18
The
health
issues
almost
dictate
it.
I
just
19
don't
see
how
­­
because
I
swear
these
people
20
will
be
on
the
bandwagon.
When
it's
directly
21
involving
them,
they
will
be.
22
MR.
BURNETT:
I
appreciate
both
of
your
23
comments.
Thank
you
very
much.
24
Ms.
Rendulich
and
Ms.
Persky,
please.
25
169
MS.
RENDULICH:
My
name
is
Ellen
1
Rendulich,
R­
E­
N­
D­
U­
L­
I­
C­
H.
I'm
with
a
small
2
grassroots
group
in
the
suburb
of
Lockport,
3
Citizens
Against
Ruining
the
Environment.
4
I
agree
with
everything
I've
heard
here
5
from
the
local
people
in
the
environmental
6
groups.
I
think
that
we
have
to
tighten
the
7
reins
on
any
environmental
issue.
8
The
pollution
is
horrendous.
I
have
9
asthma.
My
husband
uses
two
inhalers.
My
10
sister­
in­
laws
died
of
lung,
and
two
of
my
close
11
friends
have
died
of
lung
disease.
12
I
think
that
we
don't
get
enough
13
notification
out
into
the
suburbs
and
the
areas.
14
I
think
the
Hispanic
communities
and
the
Joliet
15
area
I
don't
think
they
have
any
inclination
of
16
what's
going
on.
17
There's
­­
just
about
everything
that
I
18
can
think
of
to
say
has
been
said.
We'll
send
in
19
written
comments,
and
Sandy
will
go
ahead
and
20
read
some
of
the
comments
that
we
have
now.
21
MR.
BURNETT:
Sorry.
I
do
have
a
22
question.
You
said
not
enough
notification.
Are
23
you
speaking
specifically
to
these
public
24
hearings.
25
170
MS.
RENDULICH:
The
public
hearings
­­
1
we
don't
have
any
notification
except
those
of
us
2
that
kind
of
are
in­
the­
know,
and
we
send
e­
mails
3
to
each
other.
But
I've
never
seen
anything
in
4
the
papers.
The
local
people,
we
don't
know
5
about
any
of
this.
The
residents,
the
local
6
people
have
no
knowledge
of
this.
7
MR.
BURNETT:
Do
you
have
any
8
suggestions
for
how
we
can
do
a
better
job?
9
MS.
RENDULICH:
Yeah.
I
think
local
10
newspapers
and
the
media.
Someone
else
mentioned
11
some
local
radio
stations
that
are
popular.
12
Again,
the
Hispanic
communities
that
language
13
would
help
a
lot.
In
our
area
there's
a
lot
of
14
Hispanics,
and
we
have
a
lot
of
industry
out
15
there.
16
MR.
BURNETT:
Thank
you.
17
MS.
BURCENSKI:
Good
afternoon.
My
name
18
is
Sandy
Burcenski,
B­
U­
R­
C­
E­
N­
S­
K­
I.
I'm
going
19
to
read
a
prepared
statement
from
­­
also
from
20
CARE,
Citizens
Against
Ruining
the
Environment.
21
We're
located
in
Will
County,
Lockport,
Illinois.
22
We
will
be
submitting
other
written
comments,
but
23
this
is
a
prepared
statement
I
will
be
reading.
24
Thank
you.
25
171
Why
do
private
citizens
have
to
1
continually
defend
our
rights
for
clean
water
and
2
clean
air.
Citizens
Against
Ruining
the
3
Environment,
CARE,
have
attended
public
hearings,
4
written
letters,
and
networked
without
pay
for
5
more
than
ten
years.
The
government
is
being
6
paid
to
protect
us,
and
we
expect
nothing
less.
7
Thousands
of
us
that
live
in
small
and
8
mid­
sized
communities
are
home
to
extremely
heavy
9
polluting
industries
including
three
coal­
fired
10
power
plants
in
Romeoville
and
Joliet.
We
have
11
numerous
polluting
industries
including
chemical
12
plants
that,
according
to
the
EPA,
spew
13
neurotoxins,
particulate
matter,
coarse
14
particles,
and
other
hazardous
chemicals
into
our
15
air.
16
Will
County
is
the
fastest
growing
17
county
in
the
nation,
and
new
polluting
18
industries
are
approaching
our
neighborhoods
19
daily.
The
death
rate
from
asthma,
lung
20
diseases,
heart
attacks
and
strokes
will
only
21
continue
to
worsen
as
the
pollution
increases.
22
Last
year
American
Lung
gave
us
an
F
for
23
ozone.
Now
the
administration
is
considering
24
exempting
our
small
and
mid­
size
communities
from
25
172
monitoring.
To
hear
that
the
administration
1
proposes
to
maintain
the
status
quo
and
reject
2
the
more
protective
standards
in
our
communities
3
and
to
exempt
agriculture
and
mining
from
control
4
requirements
is
ludicrous.
Is
there
some
5
correlation
between
the
proposed
growth
for
20
6
new
coal­
fired
power
plants
in
Illinois
and
the
7
fact
that
mining
areas
would
be
exempt
from
these
8
control
requirements?
9
When
taxpayers
pay
for
scientific
10
studies
by
the
EPA
and
independent
scientists
and
11
more
than
2,000
published
studies
confirm
that
12
pollution
controls,
which
to
date
are
sorely
13
lacking
considering
the
amount
of
people,
14
including
members
of
CARE,
neighbors'
children,
15
and
friends,
as
well
as
thousands
of
others
that
16
are
using
inhalers
for
asthma
and
respiratory
17
problems
because
of
the
pollution
caused
by
18
industry,
we
expect
immediate
protection.
19
When
it
has
been
proven
that
our
waters
20
are
polluted
by
industry
and
many
of
us
on
21
private
wells
have
no
protection,
we
expect
our
22
government
to
step
in.
23
Future
generations
will
one
day
ask
why
24
they
did
not
do
something.
They
will
be
talking
25
173
about
us.
Now
is
the
time
for
pollution
­­
to
1
control
pollution.
We
have
to
be
responsible.
2
This
is
not
going
to
be
easy.
Doing
the
right
3
thing
is
rarely
easy.
4
Thank
you
for
this
time.
5
MR.
BURNETT:
Thank
you
for
your
6
comments.
You
mentioned
the
monitoring
rule.
I
7
think
that
Mr.
Weinstock
has
a
question.
8
MR.
WEINSTOCK:
Ms.
Burcenski,
I
just
9
wanted
to
clarify
that
for
PM
fine,
there's
a
10
robust,
nationwide
network
of
monitors
of
11
approximately
1200
urban,
rural
areas
that
12
certainly
will
continue
under
the
monitoring
13
provisions.
We're
also
taking
comment
under
the
14
proposed
coarse
particle
standard
for
monitoring,
15
for
instance,
around
power
plants
that
would
be
16
outside
of
these
urban
areas,
about
a
hundred
17
thousand
or
more,
so
we
invite
your
comments
to
18
those
specific
provisions.
But
I
did
want
to
19
clarify
that
the
fine
particle
network
monitors
20
are
very
well
distributed
and
certain
will
21
continue.
22
MS.
BURCENSKI:
Are
there
any
at
our
23
location?
Are
there
any
in
Will
County,
the
24
locations
in
Will
County
around
the
power
plants
25
174
that
are
located
in
our
areas?
1
MR.
WEINSTOCK:
Probably
the
best
way
to
2
answer
that
would
be
through
the
regional
public
3
affairs
people
for
that
kind
of
information.
4
Also
it
probably
is
on
EPA's
web
site,
but
they
5
would
probably
know
the
particular
locations
6
better
than
we
would
here
since
we're
not
all
7
local.
8
MS.
BURCENSKI:
Okay.
Thank
you
very
9
much.
10
MR.
BURNETT:
Thank
you.
11
MS.
SASSER:
If
I
could,
too,
before
you
12
leave
here.
13
MS.
BURCENSKI:
Sure.
14
MS.
SASSER:
I
think
we've
already
lost
15
some
people.
But
I
know
there's
been
a
lot
of
16
frustration
expressed
here
about
the
fact
that
17
the
hearings
aren't
always
as
well
noticed
as
18
people
might
like
and
that
it
may
be
hard
for
the
19
average
person
to
understand
the
rule
and
20
understand
what's
going
on
here.
21
And
I
want
to
say,
I
think
for
all
of
us
22
here,
that
we
very
much
appreciate
the
work
of
23
individuals
like
yourselves
and
the
other
groups
24
who
are
here
trying
to
help
us
with
outreach
and
25
175
to
spread
the
news
about
the
hearings
and
to
take
1
the
time
to
come
here
and
speak
to
us.
We
get
2
tens
of
thousands
of
public
comments,
and
we
read
3
each
of
them.
We
hear
each
of
you
when
you
come
4
to
speak.
And
it
does
make
a
difference.
It
5
does
impact
the
decision
that
we
make.
So
I
6
wanted
to
say
that
to
all
of
you.
7
Also
if
you
have
concerns
with
specific
8
populations
or
groups
that
you
think
could
use
9
more
information
and
would
like
a
chance
to
10
comment,
we
would
also
like
to
hear
that.
11
Because
we
can
make
an
effort
to
send
a
12
representative
out
to
speak
with
individuals
or
13
community
groups,
either
from
the
regional
office
14
or
from
headquarters.
15
We've
gotten
requests,
for
example,
from
16
some
of
our
tribal
communities
saying
that
it's
17
very
difficult
for
them
to
travel
to
these
18
hearings,
and
we
have
responded
to
that
in
a
19
variety
of
ways.
So
we're
very
happy
to
try
to
20
do
that
and
to
try
to
reach
out
to
you
if
there's
21
another
way
that
we
can
do
that.
22
MS.
BURCENSKI:
Thank
you
very
much.
23
MR.
WEINSTOCK:
I
also
wanted
to
mention
24
that
in
the
registration
area
we
have
summaries
25
176
of
the
opportunities
within
the
proposals
to
1
comment.
Of
course,
everyone
is
free
to
comment
2
on
anything
in
the
proposals,
but
we
realize
that
3
they're
voluminous.
And
to
try
to
focus
people's
4
attention
if
it's
helpful
to
them,
there
are
5
actually
summary
documents
where
we
solicit
for
6
comment,
and
references
are
there,
and
it
may
7
save
some
time.
Thank
you.
8
MR.
BURNETT:
Thank
you
both
again.
9
Ms.
Headington
and
Ms.
Abrams,
please.
10
And
before
we
get
started,
on
the
agenda
11
we
were
scheduled
for
a
lunch
break
about
now.
12
We're
going
to
ask
this
panel
and
one
more,
and
13
if
there's
­­
two
more,
and
then
we
will
break
14
for
lunch.
So
we
just
want
to
make
sure
that
15
everyone
has
an
opportunity
to
talk.
16
Ms.
Headington,
please.
17
MS.
HEADINGTON:
I'm
Maureen
Headington,
18
H­
E­
A­
D­
I­
N­
G­
T­
O­
N,
a
resident
of
Burr
Ridge,
19
Illinois,
and
environment
advocate,
and
President
20
of
the
Stand
Up/
Save
Lives
Campaign.
I
am
not
21
paid
for
my
work,
and
this
campaign
is
financed
22
solely
from
personal
funds.
23
Yesterday
the
tragic
loss
of
Dana
Reeve,
24
widow
of
Christopher
Reeve,
blanketed
the
news.
25
177
When
famous
people
die
or
become
disabled,
it
1
makes
news
and
calls
our
attention
to
underlying
2
problems.
When
unknown
people
die
or
become
3
afflicted,
the
loss
to
family
and
friends
is
felt
4
as
deeply
but
without
public
attention
and
5
outcry.
6
Mrs.
Reeves
tragic
death
at
age
44
has
7
been
linked
to
secondhand
smoke.
Smoke,
whether
8
from
cigarettes
or
cars,
buses
or
coal­
fired
9
power
plants,
contributes
to
the
toxic
stew
that
10
has
become
our
air.
Metra
Chicago's
air
quality
11
suffers
and
so
does
its
populace.
Technology
is
12
available
to
eliminate
or
greatly
diminish
13
emissions,
but
it
is
contrary
to
polluters'
14
bottom
lines.
15
You
are
the
standard
bearers
and
the
16
department
charged
with
protecting
our
17
environment.
You
determine
whether
to
dole
out
18
life
or
death.
19
Unfortunately,
the
Clean
Air's
program
20
is
anything
but
its
name.
Pollution­
trading
21
credits
result
in
some
communities
receiving
the
22
lion's
share
of
pollution.
These
games
do
little
23
to
benefit
the
whole
of
society
and
it
is
24
appalling.
Communities
such
as
mine
are
downwind
25
178
of
a
hospital
incinerator
and
caught
between
four
1
coal­
fired
power
plants
to
the
west
and
two
to
2
the
east.
Many
of
the
pollutants
fall
most
3
heavily
within
a
30­
to­
50­
mile
radius
of
origin.
4
Here
in
Illinois
we
have
the
misfortune
5
of
an
incredibly
unlevel
playing
field
when
it
6
comes
to
environmental
protection
with
polluters
7
giving
enormous
sums
to
our
elected
officials
and
8
where
former
directors
of
the
Illinois
EPA
leave
9
their
posts
only
to
go
to
work
lobbying
and
10
lawyering
for
the
very
polluters
that
pose
our
11
risks.
This
has
happened
with
two
former
12
directors
in
recent
years.
The
benefits
of
13
membership
are
limitless
when
it
comes
to
14
industry
using
former
players
to
their
own
15
advantage
and
to
the
disadvantage
of
every
16
Illinois
resident.
17
During
the
past
eight
years,
I
have
been
18
attending
city
council
and
village
board
meetings
19
with
a
program
of
public
education
called
Stand
20
Up/
Save
Lives
Campaign.
To
date
101
municipal
21
leaders
representing
over
eight
million
Illinois
22
residents
have
formally
adopted
resolutions
23
addressing
Illinois'
largest
source
of
industrial
24
air
pollution:
The
old
coal­
fired
power
plants.
25
179
Specifically
they
want
to
reduce
all
toxins,
1
including
the
soot
or
particulate
matter
that
2
embeds
in
lungs
and
is
responsible
for
death
and
3
disability
of
Illinois'
residents
from
heart
4
disease,
lung
disease,
asthma,
and
cancer.
5
These
are
the
names
of
the
6
municipalities
participating
in
this
bold
7
initiative:
West
Central
Municipal
Conference,
8
The
DuPage
Mayors
and
Managers
Conference,
the
9
DuPage
County
Board,
Lake
County
Board,
Will
10
County
Board,
Kane
County
Board,
Cook
County
11
Board,
Lyons
Township,
Bremen
Township,
Rich
12
Township.
13
The
villages
and
cities
of
the
14
following:
Addison,
Antioch,
Aurora,
Barrington,
15
Bloomingdale,
Bridgeview,
Brookfield,
Burbank,
16
Burr
Ridge,
Carpentersville,
Cary,
Chicago
17
Heights,
Chicago
Ridge,
Cicero,
Clarendon
Hills,
18
Countryside,
Darien,
Des
Plaines,
Downers
Grove,
19
Elmhurst,
Elmwood
Park,
Evanston,
Evergreen
Park,
20
Flossmoor,
Forest
Park,
Glen
Ellyn,
Glendale
21
Heights,
Glenview,
Grayslake,
Hanover
Park,
22
Harvey,
Harwood
Heights,
Hawthorn
Woods,
Hickory
23
Hills,
Highland
Park,
Hinsdale,
Hometown,
24
Homewood,
Indian
Head
Park,
Justice,
LaGrange,
25
180
LaGrange
Park,
Lake
in
the
Hills,
Lemont,
1
Libertyville,
Lincolnshire,
Lincolnwood,
2
Lindenhurst,
Lisle,
Lockport,
Lyons,
McHenry,
3
Markham,
Maywood,
Melrose
Park,
Mokena,
Morton
4
Grove,
Naperville,
Niles,
Norridge,
North
5
Barrington,
Northbrook,
Northlake,
Oak
Park,
6
Oakbrook
Terrace,
Orland
Park,
Oswego,
Palos
7
Park,
Park
Forest,
Park
Ridge,
Phoenix,
Posen,
8
Prospect
Heights,
Riverdale,
Riverside,
Roselle,
9
Schaumburg,
Skokie,
Summit,
Tinley
Park,
Vernon
10
Hills,
Villa
Park,
Warrenville,
Waukegan,
Western
11
Springs,
the
Village
of
Westmont,
City
of
12
Wheaton,
Willow
Springs,
Willowbrook,
Wood
Dale,
13
and
the
City
of
Zion.
14
A
stricter
standard,
one
that
is
truly
15
protective
of
public
health
is
needed
and
is
what
16
these
communities
are
all
calling
for.
I
thank
17
you
and
I
have
my
comments
to
submit.
18
MR.
BURNETT:
Thank
you
very
much.
And
19
I
take
it
that
that
list
will
be
in
your
20
comments.
I
tried
to
take
notes,
but
­­
21
MS.
HEADINGTON:
I
know.
I
have
it
down
22
to
reading
it
in
under
two
minutes.
And
in
23
hearings
when
you
only
have
two
minutes,
it's
24
tough.
25
181
In
addressing
some
of
your
concerns
1
about
getting
the
word
out,
I
would
suggest
that
2
over
the
eight
years
I've
been
doing
this,
I
have
3
seen
on
the
landscape
an
emergence
of
environment
4
and
quality
commissions,
and
I
would
suggest
that
5
you
send
notification
to
every
municipality
if
6
you
truly
want
the
public
to
know
what's
going
7
on.
These
commissions
would
then
have
something
8
to
work
with,
and
most
of
their
meetings
are
9
televised.
So
that's
what
outreach
is
about.
10
That's
what
I've
been
doing.
And
I
hope
EPA
can
11
find
the
funding
to
do
that.
12
Thank
you
very
much.
13
MR.
BURNETT:
Thank
you
for
your
14
comments.
15
Please,
Ms.
Abrams.
16
MS.
ABRAMS:
Hi.
My
name
is
Wendy
17
Abrams.
I
have
a
comment
on
behalf
of
my
18
business,
and
I
also
was
asked
to
read
a
19
statement
by
Karen
May,
State
Representative.
20
As
far
as
the
business,
I'm
a
principal
21
shareholder
of
Medline
Industries.
It's
the
22
largest
privately
held
manufacturing
distributor
23
of
hospice
supplies
in
the
country.
We
do
over
24
two
billion
dollars
in
sales,
and
we've
got
four
25
182
manufacturing
plants
in
Illinois.
1
I
think
the
question
about
business
is
2
being
framed
wrong.
I
think
that
when
you
talk
3
about
putting
pollution
controls
on
and
how
that
4
affects
businesses
and
the
cost
of
doing
5
business,
I
think
we're
not
looking
­­
we're
not
6
asking
the
right
questions.
The
question
that
I
7
look
at
is
how
much
are
we
spending
for
the
8
health
care
of
our
employees.
We
employ
other
9
4,000
people,
and
over
1700
in
Illinois
alone.
10
Of
those
1700
people,
breaking
out
my
health
care
11
costs
for
respiratory
illness
alone
was
over
a
12
million
dollars.
13
So,
you
know,
if
our
energy
costs
went
14
up
negligibly,
I
think
our
health
care
costs
­­
15
would
all
the
asthma
and
respiratory
illness
go
16
away?
Probably
not.
But
would
it
be
17
significantly
reduced?
Yes.
There's
a
coal
18
plant
in
Waukegan
which
is
very
close
to
our
19
manufacturing
sites.
20
So,
again,
I
think
that
the
pro­
business
21
stance
is
really
­­
is
on
its
head.
And,
again,
22
businesses
pay
for
health
care
costs.
So
I
23
wanted
to
make
that
point.
24
I
also
have
a
larger
concern,
which
I
25
183
would
love
to
hear
your
thoughts
on,
and
that
is
1
just
about
the
Democratic
process.
It
seems
to
2
me
­­
and
I
have
to
believe
that
all
of
you
here
3
if
you've
been
working
at
the
EPA
for
a
long
4
time,
truly
do
care
about
protecting
the
5
environment
and
protecting
people's
health.
6
It
seems
that
this
administration
­­
and
7
I
think
the
EPA
is
a
nonpartisan
group.
But
it
8
seems
that
there's
a
pattern,
not
only
at
the
9
EPA,
but
the
FDA
and
other
organizations
where
10
decisions
are
being
made
at
a
level
that
is
­­
11
disregards
studies.
You
know,
I
look
at
what
12
happened
with
mercury
in
tuna.
And
despite
the
13
findings
that
the
FDA
and
the
EPA
found,
you
14
know,
the
tuna
lobby
was
so
powerful
that
they
15
decided
to
recommend
against
eating
four
other
16
fish
and
didn't
change
that
recommendation.
17
Again,
this
became
­­
this
is
all
18
politics.
I'd
like
to
believe
that
the
EPA
is
19
not
a
political
organization.
So
when
you
talk
20
about
lowering
standards
when
clearly
we
have
a
21
health
care
crisis
with
respiratory
illness
in
22
this
country,
I
don't
even
understand
why
23
anybody
­­
if
it's
not
driven
by,
you
know,
24
corporate
politics,
the
motivation
of
lowering
25
184
standards.
I
can
understand
saying,
you
know,
1
how
high
should
we
raise
the
standards
could
be
2
debatable,
but
to
lower
them
and
go
backwards,
I
3
would
love
to
hear
your
thoughts
on
that.
4
Do
you
want
to
­­
5
MS.
SASSER:
I
think
that
may
be
­­
6
MR.
BURNETT:
Why
don't
you
conclude
7
your
remarks?
8
MS.
ABRAMS:
I'll
just
finish
my
remarks
9
by
just
reading
­­
Karen
May's
my
state
10
representative
of
the
58th
District,
and
she
11
asked
me
to
read
her
comments.
She's
out
of
12
town.
13
The
Clean
Air
Act
provides
for
the
14
administration
to
set
air
quality
standards
at
15
levels
that
protect
public
health.
Study
after
16
study
has
confirmed
the
damaging
health
effects
17
of
fine
particulate
matter.
In
fact,
in
2005
the
18
EPA
staff
scientists
concluded
that
adverse
19
health
effects
occur
at
levels
well
below
the
20
current
fine
particulate
standards.
21
Particulate
pollution
is
both
dangerous
22
and
pervasive,
posing
a
serious
and
costly
public
23
health
problem.
Particulate
pollution
causes
24
asthma
attacks,
heart
attacks,
strokes
and
lung
25
185
cancer
and
cuts
short
the
lives
of
tens
of
1
thousands
of
Americans
every
year.
Our
state
2
suffers
from
some
of
the
worst
particulate
3
pollution
in
the
nation
in
Illinois.
Asthma
is
4
the
leading
cause
of
school
absences.
5
As
chair
of
the
Environmental
Health
6
Committee,
I'm
committed
to
protecting
the
7
citizens
of
Illinois
from
environmental
dangers.
8
Strong
particulate
standards
are
crucial
to
9
fulfilling
the
responsibility
to
reduce
air
10
pollution
and
protect
our
citizens.
The
national
11
air
quality
standards
set
by
EPA
drive
all
of
the
12
work
we
do
to
reduce
air
pollution.
Weak
13
standards
handicap
our
ability
to
fulfill
our
14
obligations
to
our
constituents.
15
Under
the
Clean
Air
Act,
air
quality
16
standards
must
be
set
at
levels
that
protect
17
public
health,
including
the
health
of
sensitive
18
populations
with
an
adequate
margin
of
safety.
19
I
urge
the
administration
to
heed
the
20
scientific
research
on
the
dangers
of
particulate
21
pollution
and
to
adopt
an
annual
standard
no
22
higher
than
12
micrograms
per
cubic
meter
and
a
23
daily
standard
no
higher
than
25
micrograms
per
24
cubic
meter.
25
186
In
addition,
the
EPA
is
required
to
1
issue
uniform
air
quality
standards
that
protect
2
all
Americans.
The
EPA's
proposal
to
limit
3
standards
to
urban
areas
and
issue
blanket
4
exemptions
for
major
industrial
sectors
such
as
5
agriculture
and
mining
is
unprecedented
in
its
6
discrimination
against
populations
living
in
7
those
areas.
8
As
more
and
more
research
provides
9
evidence
of
the
dangers
of
air
pollution,
I
again
10
urge
the
EPA
and
the
administration
to
adopt
the
11
strongest
measures
as
recommended
by
the
Clean
12
Air
Scientific
Advisory
Committee,
your
own
13
scientists,
to
protect
our
American
citizens
14
throughout
this
country.
15
I
should
also
note
the
cost
of
our
16
health
care
does
not
include
the
cost
of
reduced
17
productivity
from
absenteeism.
18
MR.
BURNETT:
You
asked
a
question
about
19
our
process,
and
I
think
it
is
a
fairly
general
20
question.
What
I
would
like
to
do
is
explain
how
21
our
process
works
in
the
hopes
that
that
will
22
answer
your
question
or
at
least
as
best
we
are
23
able
to.
24
The
process
is
that,
as
I
mentioned
25
187
earlier,
we
pull
together
our
Criteria
Document
1
of
the
underlying
science.
We
produce
a
Staff
2
Paper
which
is
reviewed
by
CASAC.
CASAC
issues
3
recommendations,
both
on
the
science
and
on
the
4
policy
recommendations.
At
the
end
the
5
administrator
is
required
by
the
Clean
Air
Act
to
6
make
a
judgment
about
the
level
that
is
requisite
7
to
protect
public
health
to
an
adequate
margin
of
8
safety
and
to
explain
the
rationale
for
his
9
judgment.
And
that
is
what
we
have
tried
to
do
10
in
the
proposed
rule
to
lay
out
the
rationale
for
11
his
judgment
of
tightening
the
daily
standard,
12
making
those
standards
more
health
protective
13
than
they
currently
are,
tightening
from
65
to
35
14
micrograms
per
cubic
meter,
98th
percentile
form.
15
So
that's
how
the
process
works
up
until
16
today
where
we,
of
course,
are
in
the
middle
of
17
the
public
comment
period,
and
we
will
take
your
18
comments
and
all
of
the
other
comments
19
collectively
and
bring
those
back
ultimately
to
20
the
Administrator
so
that
he
understands
what
has
21
been
said
and
can
make
a
final
judgment
as
to
the
22
level
that's
requisite
to
protect
public
health
23
within
an
adequate
margin
of
safety.
24
MS.
SASSER:
I
just
want
to
ask
a
25
188
clarifying
question
also.
You
­­
I
understood
1
from
your
comment
that
you
interpreted
the
term
2
"
lowering
the
standard"
to
mean
a
relaxation
of
3
the
standard,
which
is
in
fact
not
­­
it's
the
4
opposite
of
what
we're
proposing.
When
we
use
5
the
term
"
lowering
the
standard,"
we
actually
6
mean
to
make
it
more
health
protective
to
7
tighten
­­
to
lower
the
level
that
is
allowed
in
8
ambient
air.
So
to
tighten
the
standard.
So
9
what
we're
proposing
is
not
a
relaxation.
It's
a
10
tightening.
11
MR.
BURNETT:
Thank
you
both.
12
MS.
ABRAMS:
Thank
you.
13
MR.
BURNETT:
If
I
could
ask
Mr.
Truitt
14
or
Ms.
Truitt
and
Mr.
Brennan
to
please
come
15
forward.
16
Yes,
please.
17
MR.
TRUITT:
Thank
you.
18
Good
afternoon.
Again,
my
name
is
Jay
19
Truitt.
I'm
the
Vice
President
of
Government
20
Relations,
Government
Affairs,
for
the
National
21
Cattlemen's
Beef
Association.
We
appreciate
the
22
opportunity
comment
to
EPA's
proposal
to
regulate
23
coarse
particulate
matter
under
the
National
24
Ambient
Air
Quality
Standards.
25
189
The
NCBA,
just
so
that
you
understand
1
who
we
represent,
represent
somewhere
around
2
250,000
people
nationwide
who
produce
the
3
nation's
beef
supply.
Our
members
are
proud
of
4
their
tradition
as
stewards
and
conservators
of
5
America's
land.
We
believe
we're
good
neighbors
6
to
our
communities.
We
support
dust
control
7
measures.
We
use
them
every
day
in
supplying
8
America
with
food
that
it
needs
and
the
protein
9
that
it
desires.
10
We're
not
here
today
to
ask
for
you
to
11
roll
back
any
dust­
control
measures
but
instead
12
to
look
to
maintain
and
improve
them
and
use
13
science
as
the
basis
for
your
decisions.
14
The
amount
of
dust
remaining
after
we
15
typically
employ
our
best
management
practices
16
have
never
been
demonstrated
to
harm
public
17
health
at
ambient
levels.
For
the
last
30
years,
18
the
EPA
has
excluded
these
dusts
when
determining
19
compliance.
20
We
thank
the
EPA
for
continuing
this
21
historic
scientifically
based
policy
by
proposing
22
to
exclude
coarse
PM
from
agriculture
from
23
regulation
under
the
core
NAAQS.
We
don't
24
believe,
however,
that
the
current
science
shows
25
190
a
need
to
regulate
urban­
type
dust
in
many
1
circumstances
as
well.
NCBA
is
opposed
to
EPA's
2
proposal
to
do
so.
There's
a
number
of
3
agriculture
operations
that
are
near
urban
areas,
4
and
we're
concerned
about
where
the
lines
become
5
drawn
and
whether
or
not
we're
truly
basing
those
6
decisions
based
on
a
regulation
that
best
7
responds
to
the
needs.
8
The
fact
is
that
the
four
studies
on
9
which
EPA
relied
upon
for
its
proposed
coarse
10
standards
are
fatally
flawed.
The
EPA
11
acknowledges
the
flaws
in
the
alternative
12
interpretation
section
of
the
proposed
rule,
but
13
for
some
reason
appears
to
ignore
them
and
14
propose
regulations
anyway.
The
proposed
coarse
15
PM
standard
is
not
at
all
supported
by
those
16
studies.
17
It's
perplexing
to
us
at
some
level
why
18
EPA
has
failed
to
consider
a
far
larger
number
of
19
studies
with
much
larger,
more
powerful
databases
20
that
specifically
considered
coarse
PM
data
did
21
not
find
statistically
significant
associations.
22
And
we
will
be
submitting
those
studies
along
23
with
the
public
record
and
our
comments
as
well
24
so
that
you'll
have
those
available
to
consider
25
191
and
that
everyone
can
look
at.
1
Any
fair
and
sound
scientific
weighing
2
of
the
evidence
on
coarse
PM
shows
that
3
regulation
of
coarse
PM
is
not
warranted
to
4
protect
public
health.
We
urge
the
EPA
to
do
the
5
right
thing,
decide
not
to
regulate
dust
until
6
science
shows
a
regulation
is
necessary.
7
We
will
submit
our
complete
testimony
8
for
you
today
and
at
other
locations
around
the
9
country
where
these
hearings
are
being
held.
We
10
will
be
supporting,
for
the
record,
comments
from
11
the
National
Mining
Association
as
well,
and
we
12
thank
you
for
your
time.
Thank
you.
13
MR.
BURNETT:
And
thank
you
for
your
14
comments.
15
I
wanted
to
clarify.
You
said
16
urban­
type
dust
in
many
circumstances.
Does
that
17
mean
that
there
are
some
circumstances
where
it
18
may
be
appropriate
from
your
perspective?
19
MR.
TRUITT:
I
think
the
reality
is
that
20
we
need
to
be
careful
about
where
we
actually
21
draw
those
boundaries,
and
we
hope
that
you
22
consider
­­
I
guess
the
fundamental,
underlying
23
fact
here,
from
our
perspective,
is
we're
24
concerned
that
really
by
EPA,
while
we're
pleased
25
192
that
agriculture
has
been
excluded,
we
see
a
1
court
battle
down
the
road
that
by
virtue
of
just
2
differing
standards
that
EPA
essentially
is
3
putting
itself
in
a
place
to
lose
that
eventual
4
lawsuit.
So
with
that,
you're
going
to
have
to
5
tackle
the
issue
from
another
direction
and
6
another
way.
We'll
be
happy
to
work
with
you
7
throughout
that
process.
8
MR.
BURNETT:
Thank
you
again
for
your
9
comments.
10
MR.
BRENNAN:
Hi.
My
name
is
Michael
11
Brennan.
I'm
the
president
­­
that's
12
B­
R­
E­
N­
N­
A­
N.
I'm
the
President
of
Metro
13
Seniors
in
Action
which
is
a
coalition
of
senior
14
citizen
groups
and
individual
seniors
in
the
City
15
of
Chicago.
16
And
you
are
doing
such
important
work
17
right
here,
and
you're
touching
so
many
lives.
I
18
would
like
to
introduce
you
to
someone
whose
19
lives
you
are
going
to
touch,
and
that's
our
20
First
Vice
President,
Beryl
Clemens.
21
Would
you
stand
up,
Beryl?
22
The
reason
I
want
you
to
meet
Beryl
is
23
because
she
does
a
lot
of
great
work
for
seniors.
24
She's
even
helped
someone
from
being
kidnapped
25
193
and
she
goes
and
does
a
lot
of
things
for
1
seniors.
But,
unfortunately,
Beryl
has
asthma.
2
And
because
she
has
asthma,
there
are
days
when
3
the
air
is
too
bad
for
her
to
go
outside.
4
So
I
just
want
­­
when
you
make
your
5
decisions
whether
you're
going
to
go
with
this
6
weak
standard
improvement
or
whether
you're
going
7
to
listen
to
the
EPA
scientists
and
all
these
8
other
scientific
studies
that
suggest
a
much
9
stronger
standard
that
will
save
lives
from
being
10
cut
short,
I'm
just
asking
you
to
please
remember
11
Beryl.
And
you've
seen
a
lot
of
other
people
to
12
remember
too.
13
And
I
would
like
to
put
one
more
image
14
in
your
mind.
Can
you
imagine
a
hospital
with
15
1,500
beds.
That's
the
number
of
people
in
16
Chicago
who
every
year
have
a
heart
attack
17
brought
on
by
power
plant
pollution.
1,500
18
Chicagoans.
And
of
course,
we
seniors,
being
19
especially
vulnerable,
are
probably
a
good
20
percentage
of
those.
1,500.
And
that's
just
21
from
power
plants.
And
that's
just
heart
22
attacks.
That's
not
the
asthma,
that's
not
all
23
the
other
things
that
can
go
wrong
when
the
air
24
is
bad.
25
194
And
I
just
want
to
again
stress
how
1
important
it
is
what
you're
doing
and
how
­­
2
someone
earlier
say,
well,
you
know,
they'll
say
3
why
didn't
people
do
anything.
Well,
I'm
4
counting
on
you
to
be
the
people
that
make
sure
5
that
it
doesn't
ever
get
asked.
Because,
you
6
know,
even
people
as
young
as
you
are,
we
don't
7
know
how
many
sooty
breaths
any
of
us
are
away
8
from
a
heart
attack
or
asthma
attack
or
stroke.
9
There's
a
lot
of
uncertainty
in
all
our
lives.
I
10
feel
pretty
healthy,
but
I'm
trusting
­­
and
I'm
11
trusting
that
you
will
continue
to
do
everything
12
you
can
to
make
sure
that
the
soundest
scientific
13
information
is
used
and
that
the
EPA
keeps
faith
14
with
the
American
people
because
we're
trusting
15
the
EPA.
You've
got
a
very
important
trust,
as
16
I'm
sure
you're
very
well
aware,
to
protect
us.
17
No
one
else
can
do
what
you
do.
Thank
you.
18
MR.
BURNETT:
Thank
you
for
your
19
comments.
20
I
will
note
that
we,
about
a
year
ago
­­
21
in
fact,
almost
to
the
day
a
year
ago
­­
issued
a
22
very
important
rule,
the
Clear
Air
Interstate
23
Rule,
that
will
require
substantial
reductions
in
24
SO2
and
NOx
from
power
plants.
And
it's
done
for
25
195
many
of
the
reasons
that
you
articulated.
1
I
appreciate
your
comments,
both
of
you,
2
and
thank
you.
3
Mr.
Norbeck
and
Ms.
Morley.
4
Is
Ms.
Morley
here?
She
might
not
be.
5
Mr.
Norbeck,
please.
6
MR.
NORBECK:
Good
afternoon.
My
name
7
is
Michael
Norbeck,
N
as
in
neutral­
O­
R­
B
as
in
8
baseball­
E­
C­
K.
I'm
here
to
speak
on
behalf
of
9
Lieutenant
Governor
Pat
Quinn.
10
First
of
all,
I
just
want
to
say
I'll
11
try
and
be
brief.
I
know
everybody
is
looking
12
forward
to
a
lunch
break
and
a
chance
to
stretch
13
your
legs.
I
don't
want
to
keep
you
here
any
14
longer
than
you
have
to
be.
I
appreciate
you
15
being
here
and
taking
the
public
comments
in.
16
It's
a
very
valuable
process,
and
we
appreciate
17
the
chance
to
be
able
to
speak
to
you
and
the
18
opportunity
that
affords
us.
So
thank
you
very
19
much.
20
Under
the
Environmental
Article
of
the
21
Illinois
Constitution,
all
the
citizens
of
our
22
state
have
the
right
to
a
healthful
environment.
23
The
U.
S.
EPA's
proposed
revisions
to
the
National
24
Ambient
Air
Quality
Standards
for
fine
and
coarse
25
196
particulate
matter
pose
a
serious
threat
to
the
1
health
of
the
people
of
Illinois.
It
is
the
duty
2
of
all
us
in
Illinois
to
work
for
revisions
of
3
NAAQS
which
will
strengthen
ambient
air
quality
4
standards,
not
weaken
them.
I
urge
the
U.
S.
EPA
5
to
take
this
course
by
following
the
advice
of
6
federal
air
quality
experts
and
leaders
in
the
7
medical
and
scientific
community.
8
According
to
extensive
medical
and
9
epidemiological
research
spanning
more
than
two
10
decades,
fine
and
coarse
particulate
matter
11
constitutes
some
of
the
most
dangerous
pollution
12
in
our
state.
Fine
particles
under
2.5
microns
13
in
diameter
can
work
their
way
into
the
14
bloodstream
and
get
lodged
in
arteries
and
deep
15
in
the
lungs
where
they
cause
a
range
of
16
debilitating
health
effects.
These
include
17
increased
respiratory
infection,
decreased
lung
18
function
and
asthma,
lung
cancer,
and
even
heart
19
attacks.
A
growing
body
of
evidence
indicates
20
that
coarse
particles,
those
10
microns
and
under
21
in
diameter,
have
many
of
the
same
and
sometimes
22
more
severe
health
effects.
23
Diesel
trucks
and
coal­
fired
power
24
plants
emit
the
vast
majority
of
particulate
25
197
pollution
in
Illinois,
in
current
standards
for
1
PM2.5
and
PM10
do
not
manage
emissions
from
these
2
sources
in
a
way
that
sufficiently
protects
3
public
health.
Under
current
standards,
4
emissions
from
diesel
trucks
cause
over
19,000
5
asthma
attacks
and
800
premature
deaths
every
6
year
in
Illinois.
Emissions
from
coal­
fired
7
power
plants
cause
over
33,000
asthma
attacks
and
8
1,300
premature
deaths
every
year
in
our
state.
9
While
the
negative
aspects
of
these
10
effects
may
seem
obvious,
they
also
trigger
a
11
range
of
the
correlative
problems.
Children
who
12
have
asthma
attacks
miss
school
in
greater
13
numbers,
falling
behind
their
peers
and
requiring
14
extra
care
from
family
who
must
stay
home
from
15
work.
Parents
who
have
asthma
attacks
and
miss
16
work
risk
losing
their
jobs.
Patients
17
hospitalized
for
heart
attacks
face
escalating
18
medical
costs.
19
Given
the
damage
particulate
pollution
20
does
to
the
health
and
economy
of
our
state
under
21
current
standards,
every
step
must
be
taken
to
22
decrease
this
pollution
by
strengthening
ambient
23
air
quality
standard.
Unfortunately,
the
U.
S.
24
EPA's
proposed
revisions
to
the
NAAQS
for
PM2.5
25
198
and
PM10
do
little
to
improve
these
standards
1
and,
in
some
cases,
move
in
the
opposite
2
direction.
3
U.
S.
EPA
staff,
the
federal
Clean
Air
4
Science
Advisory
Committee,
and
hundreds
of
5
leaders
in
medicine
and
science
have
urged
the
6
U.
S.
EPA
to
maintain
or
strengthen
standards
for
7
daily
exposure
to
PM10
and
PM2.5.
In
addition,
8
they
have
urged
the
U.
S.
EPA
to
strengthen
the
9
standards
for
annual
exposure
to
PM2.5.
10
Unfortunately,
the
U.
S.
EPA
is
proposing
11
to
disregard
the
advice
of
scientists
and
CASAC
12
and
the
medical
and
scientific
community.
The
13
U.
S.
EPA's
proposed
revisions
to
the
NAAQS
for
14
particulate
matter
do
nothing
to
strengthen
15
annual
standards
for
PM2.5.
Even
worse,
nonurban
16
areas
with
populations
under
100,000
would
be
17
completely
exempt
from
PM10
standards.
18
Agriculture
and
mining
operations
would
also
be
19
completely
exempt
from
controls
aimed
at
meeting
20
24­
hour
PM10
standards.
We
can
do
better
than
21
that.
22
I
respectfully
urge
the
U.
S.
EPA
to
keep
23
the
advice
of
its
own
scientists,
the
CASAC,
and
24
hundreds
of
medical
and
scientific
leaders.
As
25
199
these
experts
make
clear,
limits
of
12
micrograms
1
per
cubic
meter
for
annual
exposure
to
PM2.5
and
2
25
micrograms
per
cubic
meter
for
24­
hour
3
exposure
to
PM2.5
are
reasonable.
A
stringent,
4
uniform
standard
for
24­
hour
exposure
to
PM10
is
5
equally
important.
6
Thank
you
very
much
for
your
time
and
7
consideration.
8
MR.
BURNETT:
Thank
you
very
much.
9
Just
one
clarifying
remark.
CASAC
10
recommended
a
range
of
13
to
14
­­
11
MR.
NORBECK:
I'm
aware
of
that.
12
MR.
BURNETT:
Thank
you.
Appreciate
13
your
comments,
and
we
are
going
to
suspend
the
14
hearing
for
a
lunch
break.
2:
05.
We
will
15
recommence
the
hearing
at
2:
05.
16
(
Whereupon
a
lunch
break
was
17
taken.)
18
19
MR.
BURNETT:
We're
going
to
recommence
20
this
hearing
on
the
record.
I'm
going
to
make
21
some
opening
remarks
abbreviated
from
this
22
morning,
and
then
we'll
get
started
with
the
23
first
speaker.
24
First
of
all,
thank
you
for
attending
25
200
this
hearing
of
our
EPA's
two
proposed
rules
for
1
particulate
matter.
I
recognize
that
many
of
you
2
have
traveled
quite
a
distance,
and
I
appreciate
3
you
coming
here
today.
4
My
name
is
Jason
Burnett.
I'm
the
5
Senior
Policy
Advisor
to
Acting
Assistant
6
Administrator,
Bill
Wehrum,
of
the
EPA's
Office
7
of
Air
and
Radiation.
8
We
are
having
this
public
hearing
for
9
two
rules.
One
is
the
proposed
PM
NAAQS
10
revisions,
and
those
revisions
consist
of,
first,
11
a
lowering;
namely,
a
tightening
of
the
24­
hour
12
fine
particle
standard
currently
set
for
PM2.5.
13
That's
particulate
matter,
2.5
microns
in
14
diameter
and
less.
Current
level
is
65
15
micrograms
per
cubic
meter.
We're
proposing
to
16
lower
it
to
35.
17
We're
also
requesting
comment
on
a
range
18
of
other
options
for
the
24­
hour
standard.
We're
19
proposing
to
retain
the
annual
level
at
15
and
20
also
seeking
comment
on
a
range
from
15
down
to
21
12,
and
we're
establishing
a
new
indicator
for
22
inhalable
coarse
particles,
particles
larger
than
23
PM2.5
and
smaller
and
10
micrometers
in
diameter
24
and
smaller,
PM10­
2.5.
That
indicator
has
been
25
201
qualified
to
include
any
ambient
mix
of
PM10­
2.5
1
dominated
by
resuspended
road
dust
and
PM
2
generated
from
industrial
sources
and
3
construction
sources
and
to
exclude
any
ambient
4
mix
dominated
by
windblown
dust
and
PM
generated
5
by
agricultural
sources
and
mining
sources.
We
6
propose
setting
that
at
a
level
of
70
micrograms
7
per
cubic
meter
at
98
percentile
form.
8
With
respect
to
the
secondary
standards,
9
we
are
proposing
that
they
would
be
identical
to
10
the
primary
standards,
and
we're
requesting
11
comment
on
alternatives
to
that.
12
For
today's
hearing,
first
I
want
to
13
note
this
is
one
of
these
public
hearings.
The
14
other
two
are
in
San
Francisco
and
in
15
Philadelphia.
We'll
be
preparing
a
written
16
transcript
of
each
hearing,
and
the
transcript
17
will
be
available
as
part
of
the
official
record
18
for
each
rule.
And
we'll
be
accepting
written
19
comments
for
the
two
proposed
rules
until
20
April
17th,
2006.
We
have
a
handout
available
in
21
the
registration
area
just
outside
the
door
22
through
which
you
came
in
with
detailed
23
information
for
submitting
written
comments.
24
I'd
like
to
outline
how
this
afternoon
25
202
will
work.
I
will
call
scheduled
speakers
to
the
1
microphone
to
this
table
here
in
pairs,
ask
you
2
to
please
state
your
name
and
your
affiliation.
3
And
it
will
help
the
court
reporter
here
if
you
4
also
would
spell
your
name.
5
To
be
fair
to
everyone,
we're
asking
6
that
you
limit
your
testimony
to
five
minutes
7
each
and
remain
at
the
microphone
table
until
8
both
speakers
are
finished.
After
you
finish,
9
one
of
us
may
ask
clarifying
questions.
As
I
10
mentioned,
we're
transcribing
today's
hearing,
11
and
each
speaker's
oral
testimony
will
become
12
part
of
the
official
record.
13
Please
be
sure
to
give
a
copy
of
any
14
written
comments
or,
if
you
read,
your
oral
15
testimony
to
the
court
reporter
and,
if
you
16
desire,
the
staff
at
the
registration
table,
and
17
we'll
be
sure
to
put
full
text
of
both
in
the
18
docket.
19
We
have
a
timekeeping
system
consisting
20
of
a
red,
yellow
and
green
light.
When
you
begin
21
speaking,
the
green
light
will
come
on.
When
you
22
have
two
minutes
left,
the
yellow
light
will
come
23
on,
and
we'll
ask
you
to
stop
speaking
at
about
24
five
minutes.
And
I
will
say
that
people
this
25
203
morning
were
quite
good
at
sticking
with
that.
I
1
appreciate
that,
and
we'll
ask
for
the
same
this
2
afternoon.
3
For
those
who've
registered
to
speak,
4
we've
tried
to
accommodate
your
specific
slots,
5
and
we
ask
for
your
patience
as
we
proceed
6
through
the
list.
I
think
we're
now,
with
these
7
remarks,
running
a
few
minutes
late,
but
we
will
8
do
our
best.
9
And
with
that
I'd
like
to
introduce
the
10
panel.
We
have
Jay
Bortser
with
Region
5,
Erika
11
Sasser
with
the
Office
of
Air
Quality
Planning
12
and
Standards,
and
Lewis
Weinstock
with
the
13
Office
of
Air
Quality
Planning
and
Standards.
14
With
that,
I
would
like
to
invite
Ms.
15
Mix
and
Mr.
Victor
to
come
up
to
the
table
with
16
us.
17
MS.
MIX:
Hello
there.
My
name
is
Sarah
18
Mix,
and
I'm
here
today
representing
the
Izaak
19
Walton
League
of
America.
I'm
both
an
employee
20
and
a
member
of
the
league,
and
I
live
in
21
Appleton,
Wisconsin.
22
The
League
is
a
national
conservation
23
organization
that
was
founded
in
1922.
We're
a
24
pretty
diverse
group
of
40,000
members
and
25
204
supporters
dedicated
to
protecting
the
soil,
air,
1
woods,
water,
and
wildlife
of
the
U.
S.
and
other
2
lands.
Our
strength
lies
in
our
grassroots,
3
commonsense
approach
to
solving
conservation
4
issues.
Member
interests
span
the
spectrum
of
5
outdoor
recreation
and
conservation
activities,
6
from
angling
and
hunting
to
stream
monitoring
and
7
support
of
the
development
of
clean
energy.
8
The
League's
national
office
operates
9
advocacy
and
education
programs
covering
a
wide
10
spectrum
of
conservation
and
environmental
11
issues.
They
are
located
in
Gatorsburg,
12
Maryland,
and
our
Midwest
office,
located
in
13
St.
Paul,
has
been
dedicated
to
clean
energy
and
14
air
quality
issues
for
20
years
and
has
15
coordinated
successful
regional
and
state
efforts
16
to
reduce
emissions
from
coal­
burning
power
17
plants.
18
Of
primary
importance
to
the
League
is
19
enforcing
the
Clean
Air
Act
and
promoting
20
standards
that
are
most
protective
of
human
21
health
and
our
natural
resources.
Fine
particle
22
pollution
is
the
nation's
deadliest
air
23
pollutant.
Because
fine
particles
can
bypass
the
24
respiratory
system's
defenses
and
lodge
deep
25
205
within
the
lungs
and
even
enter
the
blood
stream,
1
this
pollution
causes
serious
respiratory
and
2
cardiovascular
problems,
such
as
asthma
attacks,
3
heart
attacks,
lung
cancer
and
strokes.
This
4
pollution
is
so
dangerous
that
it
contributes
to
5
tens
of
thousands
of
premature
deaths
every
year
6
as
you're
well
aware.
7
The
League
finds
that
this
proposal
8
simply
maintains
the
status
quo,
which
is
9
indefensible
in
light
of
the
overwhelming
10
scientific
evidence
of
the
dangers
posed
by
fine
11
particle
pollution,
and
my
comments
today
are
12
going
to
focus
on
the
need
for
our
policies
to
be
13
based
on
science
and
then
also
the
need
to
14
protect
rural
residents.
The
League
urges
that
15
EPA's
proposed
particulate
matter
standard
be
16
strengthened
before
it's
finalized
in
September.
17
First,
the
League
believes
that
18
dedication
to
science
and
the
scientific
process
19
is
of
paramount
importance.
The
League
is
20
committed
to
science
and
has
based
80
years
of
21
our
own
policy
on
the
best
science
available.
22
And
today,
the
more
we
study
the
nature
and
23
effects
of
fine
particles
pollution,
the
more
we
24
understand
really
how
dangerous
it
is.
25
206
In
the
journal,
Epidemiology,
last
1
November
a
major
study
was
published
that
found
2
that
chronic
effects
of
fine
particles
are
two
to
3
three
times
greater
than
previously
believed.
4
And
further,
scientific
study
has
provided
us
5
with
overwhelming
evidence
of
the
devastating
6
effects
of
this
pollution.
More
than
2,000
7
peer­
reviewed
studies
have
been
published
since
8
1996
confirming
the
relationship
between
9
particles
and
illness,
hospitalization,
and
10
premature
death.
Studies
also
show
that
these
11
effects
occur
at
levels
well
below
the
current
12
standards,
indicating
that
the
standards
are
too
13
weak
to
protect
public
health.
14
The
League
is
troubled
that
EPA
did
not
15
follow
the
recommendations
made
by
its
own
16
independent
science
advisors,
the
Clean
Air
17
Scientific
Advisory
Committee,
to
strengthen
both
18
the
annual
and
daily
standards.
As
the
committee
19
concluded,
both
standards
need
to
be
20
substantially
strengthened
to
protect
public
21
health.
22
Second,
the
League
is
concerned
about
23
the
effects
this
proposal
will
have
on
those
who
24
live
outside
of
major
urban
areas.
Most
of
the
25
207
League's
members
live
in
cities,
towns,
and
1
villages
with
populations
less
than
a
hundred
2
thousand
people,
including
myself.
3
A
recent
analysis
conducted
by
the
Clean
4
Air
Task
Force
demonstrated
that
the
effects
of
5
fine
particles
can
be
significant
in
rural
areas.
6
In
its
analysis,
the
Task
Force
looked
at
the
7
cancer
risks
posed
by
diesel
emissions.
As
you
8
know,
diesel
emissions
are
essentially
a
9
collection
of
fine
particles
of
differing
10
chemical
compositions.
11
One
might
expect
that
the
analysis
would
12
show
the
greatest
risk
in
the
most
heavily
13
populated
metropolitan
areas,
for
example,
in
the
14
Twin
Cities
of
Minneapolis
and
St.
Paul
in
15
Minnesota.
Surprisingly,
however,
the
analysis
16
found
the
area
with
the
highest
lifetime
cancer
17
risk
from
diesel
soot
to
be
in
Duluth,
which
has
18
a
population
of
about
70,000
people.
19
In
Duluth,
the
lifetime
cancer
risk
from
20
diesel
soot
is
12
times
greater
than
the
cancer
21
risk
from
other
133
air
toxics
in
the
National
22
Air
Toxics
assessment
combined.
Duluth
is
a
23
perfect
example
of
why
some
rural
communities
24
will
be
adversely
impacted
if
they
are
25
208
categorically
exempted
as
proposed.
Because
1
Duluth
is
the
terminus
of
rail
lines
and
an
2
interstate
freeway
as
well
as
a
major
Great
Lakes
3
port,
diesel
fine
particle
emissions
are
of
great
4
concern
as
is
this
proposed
rule.
5
Many
of
us
living
in
rural
communities
6
are
also
concerned
about
the
changes
in
7
monitoring
proposed
by
EPA.
The
League
urges
EPA
8
to
issue
standards
and
monitoring
requirements
9
for
coarse
particles
that
protect
all
Americans.
10
In
conclusion
we
urge
EPA
to
strengthen
11
the
fine
particle
standard
following
the
best
12
scientific
advice
of
the
Clean
Air
Scientific
13
Advisory
Committee.
EPA
should
adopt
an
annual
14
standard
no
higher
than
12
micrograms
per
cubic
15
meter
and
a
daily
standard
no
higher
that
25
16
micrograms
per
cubic
meter
when
it
finalizes
its
17
standards
in
September.
We
believe
the
daily
18
study
should
be
set
at
the
99th
percentile,
19
meaning
no
more
that
four
days
in
any
year
should
20
be
above
the
standard,
and
monitors
that
record
21
high
annual
exposures
should
not
be
allowed
to
22
average
their
readings
with
monitors
at
cleaner
23
sites.
24
Furthermore,
EPA
should
issue
standards
25
209
and
monitoring
requirements
for
coarse
particle
1
pollution
that
protects
all
Americans
regardless
2
of
the
size
of
the
communities
where
they
live.
3
And
finally,
all
matters
should
be
held
4
at
the
same
standard,
and,
therefore,
agriculture
5
and
mining
industries
should
not
be
categorically
6
exempt
from
complying
with
these
standards.
7
Thank
you.
8
MR.
BURNETT:
Thank
you
for
those
9
remarks.
10
One
­­
you
mentioned
this
study
of
11
diesel
exposure.
I
just
wanted
to
make
sure
for
12
everybody's
understanding
that
the
fine
standard,
13
PM2.5
standard
is
a
undifferentiated
mass­
based
14
standard,
applies
everywhere.
And
I
will
just
15
leave
it
at
that.
16
You
mentioned
studies
well
below
the
17
standards.
I'm
wondering
if
those
are
studies
­­
18
studies
showing
effects
in
populations
exposed
to
19
air
quality
well
below
the
standards,
whether
20
that's
the
current
standards
or
the
proposed
21
tighter
standards.
22
MS.
MIX:
I
believe
that
it's
the
23
current
standards.
24
MR.
BURNETT:
Okay.
Do
you
have...
25
210
MR.
WEINSTOCK:
Yes.
1
Ms.
Mix,
with
regard
to
the
monitoring,
2
I
guess
I
wanted
to
clarify
that
EPA's
fine
3
particle
monitoring
network
is
both
in
urban
and
4
rural
areas,
and
those
are
required
monitors.
In
5
fact,
outside
of
that
network
of
monitors,
EPA
6
funds
other
networks
called
­­
CASTNet
is
one
of
7
the
names
of
the
networks
that
are
specifically
8
designed
to
track
trends
and
fine
particles
away
9
from
major
urban
areas.
So
that's
definitely
10
something
that
we
understand
is
important
and
11
that
will
continue.
12
MS.
MIX:
Great.
13
MR.
BURNETT:
Thank
you
again
for
your
14
comments.
15
Mr.
Victor.
16
MR.
VICTOR:
My
name
is
Steve
Victor.
17
I've
come
here
for
myself
today.
I
have
no
great
18
scientific
theory
or
ideas
about
what
to
espouse
19
here.
All
I
know
is
that
I
have
suffered
from
20
asthma
my
entire
life.
I've
grown
up
in
21
Springfield,
Illinois,
which
may
be
considered
22
rural,
and
I've
lived
half
of
my
life
here
in
23
Chicago.
And
throughout
my
entire
life,
asthma
24
has
been
a
terrible
burden.
25
211
During
my
childhood,
first
half
of
my
1
life
perhaps,
I
spent
most
of
it
in
my
house.
It
2
was
virtually
living
in
a
bubble.
I
would
3
routinely
miss
40
or
50
days
of
school
and
take
4
50
and
60
pills
a
day.
I
would
tend
to
be
in
the
5
hospital,
if
not
once
a
week,
once
a
month,
and
6
the
impact
of
that
is
huge,
I
mean,
both
from
a
7
health
care
standpoint
to
cost
standpoint,
from
8
how
my
family
had
to
nurture
and
take
care
of
me.
9
I
am
particularly
worried
now
as
I
have
10
two
children
with
asthma.
We
currently
live
in
11
Chicago,
and
I
don't
want
them
to
grow
up
in
a
12
bubble.
I
was
particularly
distressed
when
I
13
read
the
article
today
where
the
EPA
may
not
14
listen
to
its
own
scientific
people
about
the
15
particulate
levels.
16
I
think
it
is
important
and
should
be
17
mandatory
that
we
all
do
­­
you
all
do
what
is
18
necessary
to
get
into
a
level
where
we
can
live,
19
where
I
can
have
my
kids
go
outside
and
play.
20
They
can't
miss
40
or
50
days
of
school.
We've
21
evolved
in
the
last
20
years.
Medication
has
22
evolved.
But
I
need
the
government
and
society
23
and
the
cities
to
work
together
to
make
it
better
24
for
my
children
and
other
children.
25
212
So
I
would
urge
you
to
stick
to
and
move
1
towards
the
stronger
standards.
That's
really
2
all
I
have.
Thank
you.
3
MR.
BURNETT:
I
appreciate
those
4
comments
and
for
the
time
that
you
and
everyone
5
has
taken
to
come
in
and
offer
those
comments.
6
And
I
do
offer
my
condolences
for
you
and
your
7
children
all
having
asthma.
That
is
one
of
the
8
reasons
that
we
take
these
standards
so
seriously
9
and
one
of
the
reasons
that
we're
here
today
10
listening
to
public
input.
So,
again,
I
11
appreciate
it.
12
MR.
BURNETT:
Thank
you.
13
MR.
VICTOR:
Thank
you.
I
appreciate
14
your
time.
15
MR.
BURNETT:
Thanks.
16
If
I
could
ask
Dr.
Schwartzman
and
17
Mr.
Henriksen.
18
Dr.
Schwartzman.
19
DR.
SCHWARTZMAN:
Yes.
20
Greetings,
members
of
the
Environmental
21
Protection
Agency.
I
appreciate
your
taking
the
22
time
to
listen
to
the
people
of
the
United
States
23
and
their
concerns
about
the
planet's
atmosphere
24
and
the
air
that
we
all
breathe.
25
213
My
name
is
Peter
Schwartzman,
I'm
1
Associate
Professor
in
Environmental
Studies
at
2
Knox
College.
It's
a
small
liberal
arts
school
3
in
West
Central,
Illinois.
I've
been
there
for
4
eight
years.
My
expertise
lies
in
atmospheric
5
science,
and
I
taught
courses
ranging
in
various
6
areas
including
natural
resources,
environmental
7
health,
and
science
and
technology.
I'm
here
to
8
remind
you
of
a
few
things,
things
you've
9
obviously
read
or
heard,
but
nonetheless
10
deserving
of
repeating.
11
Of
all
the
resources
that
we
rely
on,
we
12
humans
rely
on,
air
and
water
obviously
the
ones
13
that
we
depend
on
the
most.
We
ingest
them
daily
14
by
breathing,
drinking,
and
eating
in
huge
15
quantities.
And
given
that
our
entire
physical
16
metabolism
depends
so
highly
on
these
two
17
particular
substances,
it's
imperative
that
we
18
keep
then
as
clean
and
unadulterated
as
possible.
19
This
is
where
you
come
in.
Members
of
the
EPA
20
are
responsible
for
insuring
the
people
of
this
21
nation
breathe
clean
air
and
drink
clean
water.
22
Plain
and
simple,
these
are
two
of
the
most
23
important
duties
of
those
that
work
for
your
24
agency.
25
214
So
let's
look
at
your
recent
fine
1
particle
air
pollution
standard
in
this
context.
2
Does
it
guarantee
clean,
healthy
air
for
the
3
people
of
the
United
States
to
breathe?
The
4
answer,
in
my
estimation,
is
flatly
no
on
many
5
counts.
Let
me
just
explain
a
couple
in
my
short
6
time.
7
First,
the
science
on
the
dangers
of
8
particulate
emissions,
in
my
view,
are
clear.
9
People
are
getting
sick
and
many
die
from
it.
10
The
connections
between
particulate
emissions
and
11
chronic
respiratory
disorders
is
also
clear.
The
12
more
we
look
into
the
question,
the
more
it
is
13
becoming
evident
that
even
small
concentrations
14
of
particulate
matter
can
be
very
harmful
to
the
15
population.
16
In
my
view,
we
must
appropriate
the
17
precautionary
principle
in
this
case.
We
must
18
take
an
honest
look
at
the
health
studies
that
19
establish
the
dangers
associated
with
particulate
20
exposure.
We
must
protect
the
people
from
21
further
medical
distress.
It
is
incumbent
upon
22
the
EPA
to
adopt
a
preventive
approach,
23
especially
when
the
science
is
so
clear
about
the
24
dangers
of
particulate
matter
on
the
health
of
25
215
our
nation's
citizens.
1
Second,
the
proposed
changes
to
the
2
National
Ambient
Air
Quality
Standards
that
you
3
recommend
are
also
shortsighted
in
terms
of
4
leaving
out
dangerous
sources
of
particulate
5
matter.
All
particulate
matter
must
be
monitored
6
and
controlled.
Particulate
matter
­­
7
particulate
pollution
in
cities
largely
comes
8
with
diesel
fuel
and
coal­
burning
fire
plants,
9
two
of
which
exist
in
Chicago
in
the
city
limits.
10
Part
of
the
pollution
in
rural
America
11
largely
comes
from
agricultural
and
mining
12
activities.
Both
of
these
sources
are
13
contributing
to
crippling
health
impacts
observed
14
in
communities,
both
urban
and
rural,
due
to
high
15
levels
of
particulate
matter.
Therefore,
neither
16
of
them
can
be
ignored
from
a
public
health
stand
17
point.
18
As
a
resident
of
a
small
city
in
the
19
western
part
of
Illinois,
once
surrounded
on
all
20
sides
by
soy
and
corn
fields,
I
have
witnessed
21
numerable
children
suffering
from
asthma.
I
22
can't
tell
you
how
difficult
it
is
to
watch
ten
23
year
olds
gasping
for
air.
I
witnesses
this
24
horrible
sight
many
times
while
I
was
a
volunteer
25
216
coach
at
my
wife's
elementary
school
in
1
Galesburg.
While
working
in
Chicago
for
the
past
2
few
months
on
sabbatical,
I've
also
heard
3
numerous
stories
about
kids
and
adults
who
have
4
respiratory
problems
here.
5
According
to
the
comprehensive
study
6
performed
by
the
Harvard
School
of
Medicine
­­
7
School
of
Public
Health,
the
two
coal­
fire
8
burning
plants
that
exist
in
the
city
limits
of
9
Chicago
are
responsible
for
over
premature
deaths
10
and
thousands
of
hospital
visits.
And
that's
on
11
a
yearly
basis,
and
that
is
because
of
12
particulate
emission,
not
because
of
some
of
the
13
other
­­
the
Nox
and
SOx
and
some
other
things
14
that
are
being
emitted.
15
In
the
little
time
I've
spent
in
16
Chicago,
which
at
this
point
has
been
less
than
17
three
months,
I
personally
have
found
myself
18
coughing
at
regular
times
and
for
unexplainable
19
reasons.
Certainly
I
feel
the
effects
of
living
20
in
this
city.
21
In
my
view
there's
no
room
in
your
22
mandate
to
protect
people's
health
for
a
choice
23
between
urban
versus
rural
residents.
Everyone
24
breathes
and
everyone
deserves
clean
air.
25
217
Third,
your
proposal
as
it
stands
1
doesn't
protect
infants
and
children.
This
is
2
made
abundantly
clear
in
the
letter
dated
3
March
3rd,
2006,
that
you
received
from
the
4
Children's
Health
Protection
Advisory
Committee.
5
Your
proposal
fails
to
set
the
daily
and
annual
6
PM2.5
standards
low
enough
to
protect
children.
7
These
studies
that
you
cite,
which
you
use
to
8
argue
for
the
very
modest
cuts
that
you
have
9
offered,
ignore
children
and
infants
who,
by
10
virtue
of
their
physiological
makeup,
are
much,
11
much
more
vulnerable
to
adverse
health
impacts
12
due
to
fine
particulate
emissions.
13
No
policy
which
neglects
to
include
14
these
most
sensitive
and
innocent
members
of
our
15
society
can
be
said
to
be
in
the
best
interest
of
16
our
nation
or
the
best
interest
of
public
health.
17
As
a
father
of
two
small
daughters
18
myself,
protecting
children
from
undue
harm
is
of
19
paramount
importance.
The
EPA
has
responsibility
20
to
protect
my
children
as
well
as
other
children
21
and
future
children
as
well.
We
are
counting
on
22
you
to
do
so.
Please
respect
the
authority
that
23
has
been
granted
to
you
and
adopt
air
quality
24
standards
that
truly
protect
our
nation.
25
218
I'll
also
submit
an
archive
of
my
1
remarks
for
the
record.
Thank
you.
2
MR.
BURNETT:
Thank
you
for
those
3
remarks.
4
You
recommend
that
we
follow
5
precautionary
principle.
I'm
wondering
if
you
6
have
a
specific
way
in
which
you
would
recommend
7
that
be
applied
in
the
context
of
the
Clean
Air
8
Act
language
requisite
to
protect
public
health
9
with
an
adequate
margin
of
safety,
which
is
what
10
our
proposal
lays
out.
11
DR.
SCHWARTZMAN:
Yes.
Well,
I
fully
12
recognize
that
precautionary
principle
has
not
13
itself
been
included
and
activated
in
a
very
14
forceful
way
in
the
United
States.
It
is
being
15
activated
in
that
way
in
other
places.
16
How
it
specifically
relates
to
what's
17
going
on
here,
studies
as
we
continue
­­
the
18
2,000
peer­
reviewed
papers
that
were
previously
19
mentioned
­­
as
more
and
more
cities
come
out
and
20
present
data
­­
results
from
data
suggesting
the
21
harmful
effects
of
smaller
and
smaller
quantities
22
of
particulate
matter
in
the
ambient
air,
I
think
23
we
need
to
think
about
and
perhaps
change
the
24
laws
possibly,
to
incorporate
the
potential
of
25
219
the
unknown.
What
I'm
saying
essentially
very
1
simply
is
we've
been
polluting
the
air
with
2
particulate
matter
for
a
long
time,
and
it
was
3
only
fairly
recently
that
we
did
anything
about
4
it.
Now,
we're
beginning
to
understand
how
5
dangerous
it
is,
and
we
have
to
think
about
the
6
future
as
well
as
the
present.
And
I
would
7
advise
you
that's
not
specific
to
what
you're
8
doing
at
the
moment
but
looking
long
term
and
9
hopefully
I
suspect
many
of
us
will
be
around
in
10
20
years
having
this
discussion
again.
11
MR.
BURNETT:
Thank
you.
12
Mr.
Henriksen.
13
MR.
HENRIKSEN:
Yes.
14
My
name
is
John
Henriksen.
I
serve
as
15
the
executive
director
of
the
Illinois
16
Association
of
Aggregate
Producers,
the
trade
17
association
representing
mining
companies
that
18
produce
crushed
stone,
sand,
and
gravel.
Our
19
mines
operate
in
80
out
of
102
Illinois
counties
20
in
rural
and
urban
areas.
In
fact,
two
of
the
21
largest
aggregate
mines
in
the
United
States
are
22
located
in
Cook
County,
Illinois,
just
a
few
23
miles
south
of
this
hearing
site.
24
I'm
appearing
today
on
behalf
of
our
25
220
industry
regarding
two
issues.
First,
we
1
strongly
support
the
EPA's
proposed
exclusion
for
2
coarse
particles
generated
by
mining
sources
as
3
set
forth
in
Section
50.13(
a)(
2).
4
Second,
in
the
event
the
EPA
elects
to
5
back
off
this
mining
exclusion
for
coarse
6
particles
in
the
final
rule,
we
submit
that
the
7
proposed
24­
hour
standard
for
coarse
particles
8
should
not
be
adopted.
Instead,
the
EPA
should
9
retain
the
current
concentration
of
150
10
micrograms
per
cubic
meter
as
its
24­
hour
11
standard.
12
First
let
me
address
the
proposed
13
exclusion
for
mining.
The
EPA's
proposed
14
standard
for
coarse
particles
found
in
new
15
Section
50.13(
a)(
2)
specifically
excludes
any
16
ambient
mix
of
such
particles
dominated
by
rural
17
windblown
dust
and
soils
and
PM
generated
by
18
agriculture
and
mining
sources.
This
section
19
then
goes
on
to
state
that
agricultural
sources,
20
and
mining
sources,
and
similar
sources
of
21
natural
crustal
materials
shall
not
be
subject
to
22
control
in
meeting
this
standard.
We
applaud
23
this
regulatory
exclusion
as
evidence
of
the
24
EPA's
focus
on
particulate
matter
that
truly
25
221
poses
an
actual
risk
to
human
health.
1
The
inhalable
coarse
PM
emitted
by
2
aggregate
mines
consists
of
natural
geological
3
crustal
material
­­
the
same
nontoxic
particles
4
used
to
improve
crop
yields
when
used
as
aglime,
5
to
purify
drinking
water
when
used
at
public
6
water
treatment
facilities,
and
to
provide
7
sources
of
calcium
carbonate
in
food
and
8
cosmetics
and
medicine.
9
The
data
in
the
rule­
making
record
10
already
before
this
agency
submitting
by
agency
11
staff
and
by
the
Clean
Air
Scientific
Advisory
12
Committee
clearly
supports
the
EPA's
approach
to
13
excluding
coarse
PM
emitted
by
aggregate
mines.
14
The
preamble
to
this
rule
making
contained
in
the
15
January
17th
Federal
Register
at
Pages
2667
to
16
2668
outlines
the
key
elements
of
the
EPA's
17
thought
process
on
this
issue.
18
The
preamble
on
this
issue
then
closes
19
with
the
following
statement
"
The
regulation
for
20
the
proposed
thoracic
coarse
particle
indicators
21
states
that
'
agriculture
sources,
mining
sources,
22
and
other
similar
sources
of
crustal
material
23
should
not
be
subject
to
control
in
meeting
this
24
standard.'
This
proposed
language
reflects
that
25
222
the
information
supporting
the
proposed
standard
1
for
thoracic
coarse
particle
does
not
support
2
extending
controls
to
thoracic
coarse
particles
3
from
agricultural,
mining
sources,
and
other
4
similar
sources
of
crustal
material."
5
And
this
part
of
the
record
concludes
6
with
this
sentence.
"
This
statement
in
the
7
regulations,
therefore,
is
designed
to
make
clear
8
that
there
is
no
need
nor
basis
to
control
these
9
sources
to
obtain
the
public
health
benefits
10
intended
by
the
proposed
indicator."
11
In
essence,
the
record
in
EPA's
own
rule
12
making
flatly
states
that
there
is
limited
health
13
data
supporting
a
coarse
particle
standard
for
14
mining
and
agricultural
sources
of
natural
15
geologic
crustal
material.
Moreover,
the
EPA's
16
proposed
rules
recognize
that
there's
no
17
difference
in
emissions
from
mines
located
in
18
either
urban
areas
or
in
rural
areas.
For
that
19
reason,
aggregate
mines
are
­­
and
the
inhalable
20
coarse
particles
that
are
emitted
from
these
21
sites,
are,
quite
properly,
not
the
focus
of
the
22
EPA's
proposed
National
Ambient
Air
Quality
23
Standards
for
Particulate
Matter.
24
Please
bear
in
mind
that
the
aggregate
25
223
mines
exclusion
proposed
in
this
section
does
not
1
impact
ongoing
industry
efforts
to
control
dust
2
emissions.
All
aggregate
mines
that
emit
3
particulate
matter
associated
with
processing
4
activities
are
permitted
by
either
the
state
or
5
federal
environmental
protection
agencies
or
6
both.
The
permits
issued
to
our
mines
require
7
our
industry
to
use
best
available
control
8
technologies
using
wet
suppression
and
dry
9
collection
systems
for
dust
control.
These
10
dust­
control
activities
will
continue
in
Illinois
11
as
a
matter
of
law,
no
matter
what
you
do
in
this
12
rule
making.
13
Second,
in
the
event
the
EPA
elects
to
14
remove
the
mining
exclusion
for
these
particles,
15
we
submit
that
the
coarse
PM
standard
should
16
remain
at
150
micrograms
per
cubic
meter,
the
17
concentration
in
the
current
PM10
24­
hour
18
standard
in
lieu
of
the
new
standard.
19
The
new
standard
is
I
believe
70
20
micrograms
per
cubic
meter.
Our
concerns
21
regarding
the
new
standard
for
the
PM
that
we
22
emit
is
reflected
well
in
the
record.
23
The
preamble
to
your
own
rule
making
24
states
flatly,
"
Taken
together,
the
Staff
Paper
25
224
concludes
that
the
health
evidence,
including
1
dosimetric,
toxicologic
and
epidemiologic
study
2
findings,
supports
retaining
some
standard
to
3
protect
against
effects
associated
with
4
short­
term
exposure
of
thoracic
coarse
5
particles."
6
Thank
you.
Probably
a
little
7
particulate
matter.
8
In
the
current
rule
making,
EPA
9
justifies
the
proposed
standard
of
70
micrograms
10
per
cubic
meter
as
being
reasonably
equivalent
to
11
the
current
PM10
standard
of
150,
however,
but
12
that's
not
the
case
for
industries
where
13
emissions
consist
predominantly
of
coarse
PM
­­
14
MR.
BURNETT:
All
right.
I
apologize
15
but
I
am
going
to
have
to
ask
you
to
wrap
up.
16
MR.
HENRIKSEN:
Thank
you.
17
Clean
Air
Act
Sections
109
and
109
18
limits
the
Epa's
standard­
setting
authority
to
19
air
pollution
which
may
reasonably
be
anticipated
20
to
endanger
public
health
and
standards
that
are
21
requisite
to
protect
the
public
health.
If
the
22
EPA
proceeds
with
the
proposed
rule
making,
it's
23
imperative
that
the
agency
provides
exclusion
for
24
emissions
that
have
not
been
shown
to
be
harmful
25
225
emissions
such
as
those
generated
by
my
industry.
1
Thank
you.
2
MR.
BURNETT:
Thank
you
for
your
3
comments.
4
A
question.
Have
you
looked
at
the
5
difference
in
the
form
of
the
current
PM10
6
standard,
a
single
exceedance
form
set
of
150
and
7
the
98
percentile
form
set
at
a
level
of
70?
8
Because
there
­­
as
the
Staff
Paper
looked
at
9
this
and
as
CASAC
looked
at
this,
the
difference
10
in
form
interacts
with
the
difference
in
level.
11
And
I'm
wondering
if
you
have
comments
on
that.
12
MR.
HENRIKSEN:
I've
looked
at
it
13
briefly.
Again,
the
next
two
witnesses
from
my
14
industry
will
­­
you
can
probably
question
in
15
more
depth
about
that.
But
the
whole
point
is
16
the
new
standard
is
supposed
to
be
reasonably
17
equivalent
to
the
current
150
micrograms
per
18
cubic
meter.
And
it's
not.
80
percent
of
our
PM
19
is
coarse.
20
So
if
you
want
to
be
equivalent,
it
21
would
be
roughly
around
120,
if
that's
the
22
intent.
I
mean,
your
data
in
the
record
23
indicates
that
the
science
is
still
kind
of
24
lacking.
This
record
is
replete
with
concerns
25
226
addressed
by
your
own
­­
raised
by
your
own
staff
1
and
other
people
regarding
the
kind
of
2
questionable
nature
of
some
of
the
conclusions.
3
So
for
that
reason
­­
you
know,
if
we
had
the
4
exclusion,
which
I
think
it's
appropriate.
But
5
in
the
event
that,
for
whatever
reason,
the
6
agency
elects
to
back
off
exclusion
for
our
7
industry,
exclusion
for
particulate
matter
that's
8
not
been
shown
to
hurt
people
­­
9
MR.
BURNETT:
Okay.
10
MR.
HENRIKSEN:
­­
then
we
ask
you
keep
11
the
current
level
that
is,
for
our
industry,
12
working.
13
MR.
BURNETT:
Thank
you
both
for
your
14
comments.
15
MR.
HENRIKSEN:
Thank
you.
16
MR.
BURNETT:
I
will
now
ask
Ms.
Hunter
17
and
Mr.
Spainhour,
please.
18
MS.
HUNTER:
Hello.
Good
afternoon.
My
19
name
is
Mary
Anne
Hunter,
H­
U­
N­
T­
E­
R,
and
I
work
20
in
the
Environmental
Department
of
Material
21
Service
Corporation.
I
have
a
bachelor's
of
22
science
degree
in
biology,
25
years
of
experience
23
in
toxicological
studies,
government,
private
24
industry,
and
have
been
certified
hazardous
25
227
materials
manager
for
more
than
16
years.
1
The
Material
Service
Corporation
2
produces
and
provides
aggregate
primarily
for
the
3
construction
industry
from
quarrying
operations
4
located
in
Indiana
and
Illinois,
and
we
are
one
5
of
the
two
largest
quarries
in
Cook
County.
We
6
have
operations
in
both
rural
and
urban
settings.
7
Regulated
emissions
from
these
facilities
are
8
composed
of
particulate
matter
from
natural
9
geologic
crustal
material.
Most
of
our
emissions
10
are
found
in
the
PM
coarse
fraction
of
2.5
to
10
11
microns.
12
Our
quarrying
operations
already
13
implement
best
available
control
technologies
as
14
well
as
curtailing
operations
when
weather
15
conditions
are
such
that
our
dust­
control
methods
16
are
not
as
effective.
Our
industry
currently
17
employs
the
following
methods
to
control
dust
18
from
its
operations.
19
They
include:
Use
of
wet
suppression
20
with
water,
other
materials,
and/
or
dry
21
collection
to
minimize
or
eliminate
dust
from
22
processes
and
stockpiles
and
roadways;
use
of
23
partial
enclosures
and
buildings;
use
of
certain
24
types
of
conveyors
that
are
designed
to
minimize
25
228
the
freefall
onto
a
stockpile;
use
of
sweepers
1
and
water
trucks
on
quarry
and/
or
paved
roads;
2
use
of
wheel
washers
in
high
density
population
3
areas;
mandatory
opacity,
or
otherwise
known
as
4
dust
testing,
of
new
equipment;
record
keeping
5
for
various
facility
activities
to
demonstrate
6
compliance
with
standard
permit
conditions;
7
maintenance
of
and
compliance
with
Fugitive
Dust
8
Operating
Plans
in
urban
areas
which
require
9
additional
controls
via
compliance
measures.
10
As
a
side
point,
one
of
our
facilities,
11
which
is
not
the
largest
one,
is
located
along
12
with
one
of
our
competitors
in
an
area
that
was
13
designated
many
years
ago
as
PM10
nonattainment.
14
That
area
has
been
in
attainment
since
1997.
It
15
was
recently
lifted
and
approved
by
U.
S.
EPA
last
16
year.
Nothing
is
going
to
change
with
our
17
operations
in
those
locations.
The
state
18
regulations
and
the
federal
requirements
require
19
that
there
is
no
deterioration
of
air
in
those
20
areas,
so
we
are
not
doing
anything
different
21
today
than
what
we
did
five
years
ago
or
ten
22
years
ago.
23
Material
Service
offers
the
following
24
comments
with
regard
to
regulation
under
the
25
229
proposed
rules
relative
to
mining:
That
the
1
exemption
should
continue
to
apply
to
both
rural
2
and
urban
location;
that
there
is
little
3
scientific
or
medical
data
regarding
negative
4
health
effects
of
the
PM
coarse
fraction,
and
in
5
particular
PM
coarse
particles
generated
from
6
processing
naturally
occurring
geologic
crustal
7
materials.
Additional
research
is
necessary
8
prior
to
implementing
additional
regulations
or
9
revising
the
current
standard
of
150
micrograms
10
per
cubic
meter
when
there
is
no
way
to
measure
a
11
health
benefit
as
a
result
of
more
stringent
12
requirement.
13
As
a
final
note,
we've
been
monitoring
14
our
employees
for
respirable
dust
during
the
last
15
25
to
30
years.
To
date,
there
has
not
been
a
16
single
short­
term
or
long­
term
exposure
case
17
indicating
a
negative
health
effect.
18
If
our
employees
who
work
in
these
areas
19
are
not
negatively
affected,
we
find
it
difficult
20
to
understand
that
we
are
negatively
affecting
21
off­
site
locations
when
the
potential
for
22
exposure
is
far
greater
within
the
active
mining
23
and
processing
areas.
Thank
you.
24
MR.
BURNETT:
Thank
you
for
your
25
230
comments.
1
MS.
SASSER:
Can
I
ask
one
clarifying
2
question.
3
Just
for
someone
who's
not
familiar
with
4
your
industry,
you
described
a
number
of
5
dust­
control
measures
that
you
use.
What
is
the
6
regulatory
driver
for
the
application
of
those
7
measures?
Are
these
voluntary?
Are
they
being
8
driven
by
the
current
PM10
standard
or
OSHA
9
regulations
or
what's
the
source
of
those?
10
MS.
HUNTER:
They
are
both.
No.
1,
11
technically
you
can't
cross
­­
visible
emissions
12
cannot
cross
the
property
line.
Based
on
where
13
you
are,
we
are
required
to
stay
within
certain
14
limits
in
terms
of
potential
emissions
at
our
15
facilities.
It's
primarily
a
nuisance­
driven
16
regulation
in
that
we
have
to
minimize
dust
17
leaving
our
facility.
18
MR.
BURNETT:
Mr.
Spainhour.
19
MR.
SPAINHOUR:
Okay.
Can
you
hear
me
20
okay?
21
MR.
BURNETT:
Yes.
Thank
you.
22
MR.
SPAINHOUR:
I'm
going
to
abbreviate
23
my
comments
a
little
bit
in
the
interest
of
time.
24
I
think
I
have
a
little
bit
too
much
here
to
25
231
cover
in
five
minutes.
1
My
name
is
Charles
Spainhour,
2
S­
P­
A­
I­
N­
H­
O­
U­
R.
I'm
the
Environmental
Manager
3
for
Vulcan
Material
Company,
and
we're
4
competitors
to
Material
Service.
We're
the
5
other,
second
large
producer
that
operates
in
the
6
Cook
Area.
We're
also
the
largest
producer
in
7
the
United
States.
We
have
operations
in
23
8
states
including
District
of
Columbia
and
Mexico.
9
We
employ
over
8,000
people
and
crush
quite
a
bit
10
of
stone
in
a
year.
I
think
John
mentioned
11
before
some
of
the
uses
for
stone,
and
certain
12
aggregates
go
into
everything
basically:
13
Buildings,
concrete,
asphalt.
Any
type
of
14
structure
really
has
construction
aggregates
in
15
it.
16
We're
headquartered
in
Birmingham,
but
17
we've
got
a
big
presence
in
the
Midwest,
so
we
18
thought
it
was
important
to
come
up
here
and
19
testify.
20
The
points
that
I
want
to
mention
kind
21
of
mirror
what
John
has
mentioned.
The
proposed
22
standard,
we
have
concern
that
the
level
of
70
23
micrograms
per
cubic
meter
is
not
going
to
be
24
reasonably
equivalent
to
the
existing
PM10
25
232
standard.
1
You
asked
about
the
speciation
and
how
2
the
method
was
going
to
effect
that.
Our
3
technical
folks
that
have
worked
on
this
out
of
4
our
national
trade
association
I
believe
have
5
made
comments
on
that,
and
my
basis
for
my
6
statement
are
based
on
their
technical
analysis.
7
Particulate
emissions
sources
from
8
mining
and
agriculture
are
dominated
by
the
9
coarse
fraction.
However,
the
majority
of
those
10
emissions
are
from
natural
geologic
crustal
11
materials.
There's
numerous
comments
in
the
EPA
12
Staff
Paper,
which
I
don't
really
have
time
to
13
reference
here
regarding
those
standards,
that
14
indicate
that
the
natural
crustal
materials
are
15
not
the
materials
believed
to
cause
the
adverse
16
health
effects.
In
addition,
I
believe
the
17
coarse
fraction
is
not
one
believed
to
cause
18
adverse
health
effects
as
much
as
the
fine
19
fraction.
20
So
when
you
look
at
our
industry,
we
21
generate
the
coarse
fraction,
we
generate
the
22
natural
crustal
material
from
an
aggregate
mine.
23
Basically,
we're
taking
rock
and
we're
crushing
24
it
and
making
it
into
smaller
rock.
So
we
don't
25
233
really
generate
a
lot
of
PM2.5,
and
we
don't
1
generate
toxic
type
contaminants.
We
usually
2
generate
natural
crustal
materials.
3
So
we
have
a
concern
about
the
4
equivalency
and
feel
the
new
standard
is
going
to
5
be
much
too
strict,
and
we
propose
that
the
6
coarse
standard
be
set
at
close
to
the
existing
7
level
for
the
PM10
standard.
8
Proposed
Exemption
for
Natural
Geologic
9
Crustal
Material.
We,
like
John
mentioned,
10
support
and
applaud
the
EPA's
proposed
exemption.
11
I
know
there's
been
a
lot
of
background
work
12
that's
going
on,
information
submitted
from
the
13
industry
from
technical
experts
of
studies
that
14
have
been
done
looking
at
that
issue,
and
I
think
15
EPA
has
recognized
the
validity
of
those
studies.
16
As
I
mentioned,
these
materials
are
not
the
17
primary
types
of
emissions
from
aggregate
mining
18
and
agricultural
operations.
19
Vulcan
agrees
with
the
position
of
the
20
Clean
Air
Scientific
Advisory
Committee
that
21
thoracic
health
effects
observed
from
exposure
to
22
coarse
particulate
matter
are
related
more
to
23
toxic
particle
exposure
such
as
those
generated
24
by
industrial
sources.
The
health
effects
from
25
234
these
type
of
particles
are
generally
not
1
associated
with
exposure
to
the
type
of
particles
2
we
generate.
So,
again,
Vulcan
supports
that
3
exclusion.
4
One
area
of
concern
­­
we
again
support
5
the
exclusion,
but
we
have
a
concern
relative
to
6
our
industry
of
rural
versus
urban
sources.
Our
7
industry
does
not
change
based
on
where
we're
8
located.
We're
doing
the
same
basic
process.
9
So
Vulcan
supports
the
EPA's
proposed
10
exclusion
for
natural
geologic
crustal
material,
11
but
we
believe
it's
sound
to
apply
that
exclusion
12
to
all
source
areas,
not
just
to
rural
source
13
areas.
14
I
believe
the
information
in
the
health
15
effects
studies,
and
the
reason
for
the
16
distinction,
relates
more
to
the
nature
that
the
17
health
effect
studies
that
have
been
done
that
18
have
been
focused
more
on
urban
settings
where
19
you
have
high
population
density,
but
you
also
20
have
a
lot
of
compounding
effect.
So
you're
not
21
seeing
the
true
exposure
from
these
natural
type
22
of
materials.
23
So
we
propose
that
that
exclusion
be
24
expanded
and
not
just
cover
those
types
of
25
235
sources
but
cover
sources
in
our
industry
across
1
the
country.
I
have
some
additional
comments
on
2
that
in
my
notes.
3
The
next
point
that
I
want
to
make
­­
4
Secondary
Emission
Standard.
If
EPA
does
decide
5
to
keep
the
­­
establish
a
secondary
emission
6
standard,
we
also
would
like
to
see
the
exclusion
7
added
to
the
secondary
emission
standard.
We
8
can't
have
a
primary
standard
exclude
mining­
type
9
sources,
agricultural­
type
sources,
natural
10
crustal
materials
and
then
have
them
come
in
kind
11
of
on
the
backside
through
the
secondary
12
standard.
So
we
think
it's
important
to
also
13
provide
the
exclusion
in
the
secondary
standard.
14
In
conclusion,
the
proposed
standard
of
15
75
micrograms
per
cubic
meter
is
unwarranted
for
16
the
aggregates
industry
because
most
of
our
17
emissions
are
natural
materials
and
the
industry
18
is
already
heavily
regulated
which
we've
talked
19
about.
20
Setting
a
standard
closer
to
the
21
existing
PM10
level
should
be
considered.
The
22
exclusion
for
mining
agriculture
and
our
emission
23
sources
not
demonstrated
to
be
harmful
should
be
24
retained,
and
the
exemption
for
rural
sources
for
25
236
natural
crustal
material
should
be
expanded
to
1
urban
areas.
Thank
you.
2
MR.
BURNETT:
Thank
you
for
your
3
comments.
You're
one
of
the
first
people
today
4
that
mentioned
the
secondary
standards,
and
I'm
5
wondering
if
you
would
be
interested
in
6
elaborating
on
your
comment
on
the
secondary
7
standard
for
the
coarse
fraction.
8
MR.
SPAINHOUR:
Well,
the
concern
that
9
our
industry
has
­­
and
in
preparation
for
this
10
testimony,
I
talked
to
our
national
trade
11
association.
The
concern
that
they
expressed
is
12
I
don't
believe
­­
and
it
could
be
a
mistake,
but
13
I
don't
believe
that
specifically
the
14
exemption
­­
the
exclusion
is
specifically
15
referenced
in
the
secondary
standard.
And
we
16
want
to
make
sure
that
it
does
applies
to
the
17
secondary
standard
because
obviously
we
don't
18
want
to
have
that
back­
door
effect
where
we
get
19
regulated
into
secondary
standard
­­
secondary
20
type
of
exposure
concerns
when
we're
not
21
regulated
relative
to
the
new
proposed
standards
22
for
the
primary
standard.
23
As
we
talked
before,
we're
very
heavily
24
regulated
relative
to
the
control
of
emissions
25
237
within
our
operations,
and
we
have
basically
1
state
permits
on
how
we're
regulated
right
now.
2
Most
of
our
sources
are
minor
sources
and
not
3
major
sources.
4
MS.
SASSER:
Just
looking
at
the
5
regulatory
language
here
and
because
each
of
the
6
cases
the
primary
and
secondary
standards
are
the
7
same
for
each
for
PM2.5
and
PM10­
2.5,
in
fact
the
8
exclusion
would
apply
to
both
as
it's
currently
9
regulated.
10
MR.
SPAINHOUR:
Okay.
11
MR.
BURNETT:
Thank
you
both
for
your
12
comments
today.
13
Mr.
Pozner
and
Mr.
Hale,
please.
14
Mr.
Pozner.
15
MR.
PONSER:
Ponser.
16
MR.
BURNETT:
Thank
you.
I
apologize.
17
MR.
PONSER:
My
name
is
Jonathan
Ponser,
18
and
I'm
an
Illinois
PIRG
member.
Okay.
19
It
seems
like
everything
can
cause
20
cancer
or
heart
disease
these
days.
I'd
like
to
21
think
I
stay
pretty
healthy.
And
while
food
22
products
are
constantly
getting
labeled
hazardous
23
to
your
health,
I
never
thought
that
simply
being
24
outdoors
could
pose
a
similar
hazard.
25
238
I
love
to
run.
And
when
it's
warmer
1
out,
I
enjoy
running
about
five
days
a
week.
2
Since
moving
to
the
city,
I
found
that
along
with
3
dodging
cats
as
I
cross
the
street,
I
also
am
4
affected
by
the
pollutants
in
the
air
coming
from
5
buses,
power
plants
and
the
like.
6
I
always
considered
such
things
7
annoyances
which
robbed
me
of
performance
due
to
8
greater
difficulties
breathing.
It
turns
out
9
this
is
just
the
tip
of
the
iceberg.
I
soon
10
found
out
these
annoyances
emitted
fine
particles
11
which
are
a
hazard
to
your
health
and
can
lead
to
12
heart
disease,
cancer,
stroke,
and
otherwise
13
prematurely
end
tens
of
thousands
of
American
14
lives
each
year.
15
While
I'm
keenly
aware
of
the
amount
of
16
buses
in
the
city,
the
number
of
coal­
burning
17
electric
plants
are
not
always
as
obvious.
In
18
the
Chicago
area,
there
are
five
coal­
burning
19
plants,
and
while
technology
exists
to
help
such
20
plants
clean
up
their
act,
the
government
has
not
21
compelled
them
to
do
so.
22
The
PSI,
or
Pollutant
Standard
Index,
23
which
is
now
called
the
AQI,
or
Air
Quality
24
Index,
was
established
in
1976.
This
allows
the
25
239
general
public
to
know
how
much
of
a
risk
they
1
will
be
taking
by
going
outdoors
on
any
given
2
day.
Surely
the
data
collected
from
the
last
30
3
years
would
indicate
the
need
for
public
health
4
to
be
protected
through
higher
standards.
5
Having
air
pollution
action
days
should
6
not
be
a
normal
part
of
every
summer.
Research
7
currently
points
to
fine
particle
levels
well
8
below
current
standards
greatly
deteriorating
a
9
person's
health.
Furthermore,
under
the
Clean
10
Air
Act,
air
quality
standards
must
be
set
at
11
levels
that
protect
public
health
with
an
12
adequate
margin
of
safety.
Given
the
13
aforementioned
information,
this
is
not
the
case.
14
Therefore,
I
urge
you
and
I
urge
the
15
Bush
Administration
to
strength
the
standards
16
before
finalizing
them
later
this
year.
You
can
17
do
it
to
protect
my
health,
you
can
do
it
to
18
protect
your
own
health,
or
you
can
do
it
to
19
protect
your
children's
health.
Thank
you.
20
MR.
BURNETT:
Thank
you
for
your
21
comments.
22
You
mentioned
the
Air
Quality
Index.
Do
23
you
look
at
that
yourself?
We're
always
24
interested
in
feedback
­­
25
240
MR.
PONSER:
Yes.
1
MR.
BURNETT:
­­
when
we
make
our
­­
2
MR.
PONSER:
Yeah.
Like,
I
found
it
3
online,
and,
you
know,
I
was
going
through
the
4
different
times.
And
in
the
Chicago
area,
I
5
noticed
that
it's
generally
­­
you
know,
it's
6
yellow
most
of
the
time
it
seems
like,
where
I'm
7
originally
from
downstate,
and
so
that
wasn't
8
really
as
much
of
a
problem
before.
And
I
know
9
that
my
main
concern
when
I
first
noticed
it
10
obviously
was
when
I
was
running
that
it's
much
11
more
difficult
to
breathe
when
I'm
running
now,
12
now
that
I
live
in
the
city
versus
when
I
lived
13
in
a
more
rural
area.
14
MR.
BURNETT:
Thank
you.
15
Mr.
Hale.
16
MR.
HALE:
Thank
you
for
allowing
me
to
17
speak
today
and
having
a
public
forum
on
this
18
important
issue.
19
My
name
is
Tom
Hale.
I
live
here
in
20
Chicago.
I
am
a
chemical
engineer
by
training
21
and
profession,
and
I
own
an
integrated
22
pharmaceutical
design
manufacturing
company
with
23
operations
both
here
and
abroad.
I
teach
24
chemical
engineering
and
have
served
in
various
25
241
roles
with
the
FDA
­­
not
the
EPA,
the
FDA
­­
1
from
submitting
regulatory
documents
for
my
own
2
use
and
as
well
as
being
a
member
of
the
FDA
3
science
advisory
subcommittees
on
various
4
technical
issues.
I'm
also
a
member
of
the
Board
5
of
Directors
of
the
Near
North
Montessori
School
6
here
in
Chicago
which
you'll
hear
from
some
kids
7
a
little
later.
They're
our
kids.
8
I
come
here
not
as
an
expert
on
9
particulate
matter
in
the
atmosphere
or
pulmonary
10
issues.
I
come
here
as
a
concerned
citizen
and
11
an
avid
observer
of
these
issues,
a
sufferer
of
12
asthma,
and
probably
more
importantly
as
a
father
13
of
an
11
year
old.
I
believe
that
the
scientific
14
community
should
be
listened
to
and
that
federal
15
regulatory
limits
on
these
issues
should
be
16
tightened
in
order
to
be
conservative
in
17
protecting
the
health
of
our
community.
And
in
18
support
of
that,
I
have
three
points
to
make
that
19
are
general
in
nature.
20
Number
one,
we
live
in
a
tumultuous
and
21
transitional
time
in
this
country.
There
are
22
many,
many
large
issues
from
economic
health
care
23
systems,
educational
systems,
preemptive
wars,
24
and
the
like.
These
and
other
issues
are
very
25
242
critical
to
discuss.
But
I
believe
that
they
are
1
all
trumped
by
the
issue
that
we
are
here
talking
2
about
today.
3
If
we
as
a
people,
culture,
and
as
4
individuals
allow
the
continual
rapid
degradation
5
of
our
environment,
all
these
other
issues
will
6
become
less
and
less
important
in
the
grand
7
scheme
of
things,
and
we'll
be
struggling
to
get
8
our
collective
bearings
in
tow.
This
makes
your
9
and
your
colleagues'
jobs
some
of
the
most
10
critical
in
the
U.
S.
government
in
my
mind,
and
I
11
thank
you
for
doing
the
jobs
that
you're
doing,
12
more
important
than
almost
any
other
role.
13
I,
therefore,
ask
of
you
to
look
beyond
14
the
political
constituencies
that
may
have
15
brought
you
where
you
are
and
consider
the
health
16
and
the
future
of
the
children
in
this
room
and
17
perhaps
even
more
the
kids
out
there
that
are
18
suffering
from
asthma
and
wheezing
and
cannot
19
come
to
this
meeting.
20
No.
2.
My
career
has
been
in
a
very
21
heavily
regulated
industry,
in
the
pharmaceutical
22
industry.
Many
of
the
regulations
that
come
and
23
go
are
nonsensical,
inappropriately
restrictive,
24
and
inhibit
progress
with
no
particular
25
243
improvement
in
public
safety.
At
the
same
time,
1
there
are
many
important
and
intelligently
2
considered
regulations
that
not
only
improve
3
public
safety
but
create
a
positive
environment
4
to
pursue
a
stronger
competitive
arena
for
U.
S.
5
concerns
and
enterprise
and
for
them
to
excel.
6
I,
therefore,
encourage
you
to
create
7
regulations
that
are
responsive
to
science
and
8
known
and
even
projected
risks
but
at
the
same
9
time
drive
efficiencies,
new
technologies
and
10
better
systems.
I
believe
this
all
can
be
done,
11
and
I
believe
it
can
be
done
efficiently
and
fast
12
and,
I
think
we
can
do
it
in
this
country
as
well
13
or
better
than
anyplace
else
in
the
world.
So
I
14
encourage
you
to
view
beyond
just
restrictions
15
but
encourage
new
technology
developments
and
16
efficiencies.
17
No.
3.
There
is
the
perception,
whether
18
it's
real
or
not,
of
a
growing
level
of
19
incompetence
in
our
public
institutions.
I
20
believe
the
scientific
and
technical
staff
in
the
21
EPA
and
its
ancillary
academic
and
industrial
22
environments
serves
a
critical
role
in
the
public
23
debate
on
the
environment,
and
I
encourage
you
to
24
create
an
environment
within
the
EPA
and
its
25
244
environments
that
attracts
the
best
minds
and
1
keeps
them;
that
encourages
the
best
of
what
2
scientific
inquiry
has
to
offer
and
allows
a
free
3
exchange
of
ideas.
4
I
believe,
again,
that
it
is
in
our
5
collective
self­
interest
for
everyone
to
engage
6
in
a
high­
level
debate
on
the
state
of
the
7
environment,
and
I
believe
it
is
the
critical
8
issue
of
our
time.
9
Thank
you
for
your
time,
thank
you
for
10
being
here,
and
thanks
for
listening.
11
MR.
BURNETT:
And
thank
you
for
your
12
comments.
13
Thank
you
both,
and
we
will
now
turn
to
14
Ms.
Gardiner
and
a
number
of
students
from
the
15
North
Montessori
School.
16
MS.
GARDINER:
Hi.
My
name
is
Laura
17
Gardiner.
I'm
a
teacher
at
the
Near
North
18
Montessori
School,
and
I'm
here
with
a
few
19
representatives
from
our
seventh
and
eighth
20
grades
who
would
like
to
speak
with
you
about
21
their
concerns
about
air
pollution.
22
MR.
BURNETT:
And
I
have
a
list.
I
23
think
this
is
everybody
here,
and
I'm
just
24
wondering
if
I
can
go
through
it,
and
if
you
can
25
245
identify
yourself.
1
Lain
Drinkwater.
2
MISS
DRINKWATER:
Hi.
3
MR.
BURNETT:
I
do
apologize
if
I
4
mispronounce
your
name.
5
Emma
Gregoline.
Carlyle
DePriest
and
6
Karlyn
Gehring.
And
Lindley
French.
7
MISS
FRENCH:
Yeah.
8
MR.
BURNETT:
And
Lane
Beckstrom.
9
Thank
you
very
much
for
coming
today.
10
MONTESSORI
SCHOOL
STUDENT:
Yeah.
I'm
11
concerned
about
my
health
as
well
as
my
family's
12
but
also
the
poor
communities
of
Chicago.
Many
13
housing
projects
right
now
are
closer
to
14
factories
and
power
plants,
and
they're
the
ones
15
who
are
being
most
affected
by
this,
and
they
16
can't
afford
good
health
care.
And
so
children
17
with
asthma
or
older
people
with
heart
problems
18
can't
get
the
health
care
that
they
need,
and
I
19
think
that's
really
important.
20
Also
one
of
my
friends
­­
I
play
soccer
21
and
basketball,
and
a
lot
of
my
friends
suffer
22
from
asthma.
And
it's
kind
of
sad
because
they
23
can't
really
play
up
to
their
potential.
And
24
that
might
not
seem
important,
but
it's
important
25
246
to,
like,
a
lot
of
my
friends
and
everything.
1
And
I
think
that
it's
important
to,
like,
knowing
2
more
about
this
cause
and
everything.
3
MR.
BURNETT:
Thank
you
for
your
4
comments.
5
MONTESSORI
SCHOOL
STUDENT:
I
myself
6
suffer
from
asthma,
and
I
­­
in
earlier
years
it
7
did
not
seem
to
affect
my
life
as
much,
but
as
8
recently
as
this
month,
it
seemed
to
affect
me
a
9
lot
more.
And
I
believe
that
this
probably
has
10
something
to
do
with
the
amount
of
pollution
11
because
nobody
else
in
my
family
has
any
kind
of
12
asthma­
related
anything.
And
this
is
a
concern
13
to
me
because
it's
getting
worse
as
I
grow
up,
14
and
I'm
feeling
that
it's
not
something
I'm
gonna
15
grow
out
but
something
I
grow
into
more,
and
16
that's
a
scare
for
me
because
I
like
to
be
17
outside
and
I
like
to
run
around,
and
I
don't
18
want
to
lose
any
of
those
things.
19
MONTESSORI
SCHOOL
STUDENT:
Even
though
20
passing
laws
takes
time,
the
more
time
that
we're
21
spending
actually
talking
about
doing
something,
22
the
more
time
that
we're
wasting
and
the
more
23
polluted
our
air
is
becoming.
And
a
lot
of
24
people
are
trying
to
fix
the
problem,
but
even
25
247
though
we're
trying
and
we're
doing
it
and
we
1
trying
to
do
it
as
fast
as
we
can,
we
still
are
2
not
getting
it
done
more
effectively.
3
And
one
­­
one
of
the
problems
of
this
4
is
that
if
­­
since
a
lot
of
people
depend
on
5
things
that
pollute
the
air,
if
we
were
going
to
6
stop
that
pollution,
we
would
need
another
system
7
of
how
we
would
get
our
needs,
like
8
transportation
of
materials
and
food.
And
that
9
takes
even
more
time,
and
so
we're
wasting
even
10
more
time
trying
to
figure
that
out.
That's
it.
11
MS.
GARDINER:
I
think
that's
everyone.
12
MR.
BURNETT:
I
want
to
thank
you
all
13
for
coming
in
and
participating
in
this
process.
14
It's
a
vital
part
of
our
process
for
­­
in
15
particular
for
significant
rules
like
this,
the
16
public
comment
period
is
something
that
we
pay
17
very
close
attention
to
in
order
to
hear
from
18
citizens
such
as
yourselves,
and
we
appreciate
19
you
coming
in
here
today.
Thank
you.
20
Mr.
Sims
and
Ms.
Jones,
please.
21
MS.
JONES:
My
name
is
Corey
Jones.
I
22
am
here
today
as
a
volunteer
to
make
a
personal
23
statement
today.
I
am
a
volunteer
with
the
24
Sierra
Club
which
has
25,000
members
in
the
State
25
248
of
Illinois,
12,000
being
in
the
immediate
1
Chicago
metro
area.
2
People
always
ask
me
what
do
I
do
for
3
the
Sierra
Club
as
a
volunteer.
After
a
few
4
years,
I
still
say
I'm
fighting
for
clear
air
and
5
clean
water.
Clean
air
and
clean
water
is
6
something
that
you
shouldn't
have
to
fight
for.
7
I
just
came
back
from
Springfield
last
8
week
fighting
for
a
decent
bill
for
clean
air
and
9
getting
the
particulates
out
of
the
air
and
all
10
the
kids
that
were
there
as
well
with
the
11
American
Lung
Association
the
day
before.
Talk
12
about
all
these
kids
with
asthma
in
one
place.
I
13
mean,
it
was
quite
shocking
to
see
that
many
14
problems,
be
faced
that
many
problems
15
immediately.
16
In
realizing
that
these
are
very
complex
17
issues,
there's
no
easy
answers.
And
realizing
18
too
that
corporations
and
even
townships
and
19
power
plants
don't
always
have
the
best
interests
20
of
these
kids
and
the
best
interest
of
us
as
the
21
public
citizens
in
mind,
it's
just
really
hard
22
for
me
to
see
that
there
is
a
battle
and
it
23
continues
to
be
a
battle.
24
And
I
give
it
quite
a
bit
of
thought.
25
249
Driving
­­
it
took
me
an
hour
and
a
half
to
get
1
in
here
from
the
suburbs
from
working
today,
and
2
I
gave
a
lot
of
thought
to
what,
in
two
minutes,
3
I
would
share
with
you.
And
I
would
just
say
4
please
help
fight
for
us.
Help
us
fight
for
the
5
clean
air.
That
we're
not
empowered.
We
don't
6
have
the
expertise
or
the
empowerment
to
effect
7
the
change
that
you
can.
So
if
you
can
help
us
8
fight
for
clean
air,
that
would
be
what
I
would
9
ask
for
today.
10
That's
all
I
have
to
say.
11
MR.
BURNETT:
Appreciate
you
taking
time
12
off
work
and
coming
in
here
today,
and
it
13
certainly
is
what
this
rule
is
about.
I
know
14
that
the
tightening
is
not
what
it
is
as
much
as
15
some
people
have
wanted,
and
that's
part
of
the
16
process.
We're
certainly
taking
this
very
17
seriously
and
as
I
think
everyone
here
is.
I
18
appreciate
your
comments.
19
MR.
SIMS:
Good
afternoon.
My
name
is
20
Jim
Sims.
I
am
head
of
the
Western
Business
21
Roundtable.
I
appreciate
the
opportunity
to
22
provide
testimony.
I
want
to
apologize
in
23
advance.
These
comments
which
I
will
submit
for
24
the
record
were
written
by
an
attorney,
and
so
25
250
I'm
going
to
try
to
dumb
them
down
little
bit.
1
My
apologies
to
those
of
you
who
are
lawyers.
2
And
also
since
I'm
not
an
expert
in
3
atmospheric
science,
there
are
many
questions
you
4
could
ask
me
that
I
would
not
be
able
to
answer,
5
and
I
will
get
back
to
the
panel
within
24
hours
6
with
any
of
the
question
details
that
I
can't
7
answer.
8
The
Roundtable
is
comprised
of
senior
9
business
executives
mostly
operating
in
the
10
Western
United
States,
here
in
Illinois,
and
many
11
other
states.
We
represent
a
broad
range
of
12
industries
from
agricultural
folks
to
accounting,
13
chemicals,
coal,
a
large
list
and
that
list
is
14
there
in
the
record,
which
means
I'm
an
expert
at
15
none
of
these
things.
But
I
do
want
to
point
out
16
that
we
do
a
lot
of
work
on
air
regulation.
17
And
a
story
that
is
almost
never
told
in
18
forums
like
this
or
in
the
newspapers
or
in
19
Congress,
et
cetera,
is
that
there
is
almost
20
unbelievable
good
news
about
what
our
environment
21
has
been
doing
for
the
last
30
years.
In
fact,
22
as
all
of
you
probably
well
know,
by
almost
every
23
single
measure
of
environmental
quality,
24
America's
air,
our
land,
and
our
water
is
25
251
dramatically
cleaner
today
than
it
was
30
years
1
ago.
That's
not
a
story
that
often
gets
told.
2
And
for
good
reason,
people
are
concerned
about
3
environmental
degradation.
The
fact
is
the
trend
4
is
in
the
right
direction
in
almost
every
aspect.
5
My
concern
about
these
proposed
6
regulations
is
that
the
science
is
not
quite
7
there
to
support
a
standard
that
goes
this
far
8
and,
therefore,
which
shows
some
substantial
9
health
benefit.
The
indicator
in
this
PM
coarse
10
standard
as
you
know
excludes
any
ambient
mix
of
11
PM10­
2.5
that's
dominated
by
windblown
dust
and
12
soils
and
those
generated
by
agricultural
or
13
mining
sources.
The
Agency
is
asserting
14
justifications
for
this
in
its
equivalency
15
standard,
but
I
would
say
that
that
proposition
16
does
not
bear
scrutiny.
17
And
I
don't
want
to
repeat
what
you've
18
probably
heard
15
times
already
today,
but
19
obviously
in
the
arid
southwestern
cities,
coarse
20
PM
can
constitute
80
percent
or
more
of
PM10,
21
while
in
eastern
humid
cities,
fine
PM,
as
you
22
know,
constitutes
80
percent
or
more
of
PM10.
23
Therefore,
you
can
have
measured
in
an
24
eastern
city
that
ratio
fine
coarse.
You
can
25
252
have
20
micrograms
per
cubic
meter
of
coarse,
1
while
in
the
west
you
could
have
the
opposite.
2
So
what
it
does
is
obviously
discriminates
3
against
western
cities.
And
this
is
particularly
4
ironic
given
that
the
standard
is
being
developed
5
based
on
EPA's
reliance
on
studies
done
mostly
in
6
these
humid
eastern
cities
­­
Toronto,
Detroit,
7
Steubenvillle
and
other
places.
So
those
cities
8
would
not
be
subject
to
controls,
really
any
9
controls,
as
a
result
of
the
doubling
of
the
10
current
standard,
while
cities
in
the
west
would
11
probably
go
into
nonattainment
immediately.
12
Second,
the
Circuit
Court
said
in
the
13
American
Trucking
Association
case
­­
in
that
14
case
it
found
that
PM10
was
confounded
by
15
including
indeterminate
amounts
of
fine
and
16
coarse
PM.
And
the
fundamental
reasoning
in
the
17
case
negates
any
possibility
of
equating
coarse
18
PM
with
one
of
the
two
indeterminate
components
19
of
PM10.
That's,
of
course,
the
lawyer
stuff.
20
I
would
just
argue
as
someone
who
spent
21
18
years
out
in
an
eastern
humid
city,
the
swamp
22
of
Washington,
D.
C.,
and
now
has
spent
seven
23
years
in
the
west,
it's
obvious
to
any
person
24
that
the
ambient
air
is
different
in
those
two
25
253
regions
of
the
country.
In
the
west,
we
live
and
1
have
lived
for
hundreds
of
years
in
a
dry,
2
semi­
arid,
dusty
part
of
the
world.
It's
just
3
part
of
the
environment
that
we
live
in.
4
So
I
will
not
go
through
the
rest
of
all
5
this
stuff,
but
just
to
say
that
the
Roundtable
6
believes
that
­­
let
me
back
up.
7
As
a
father
of
three,
who
has
three
8
young
kids
in
a
Montessori
School
­­
I
was
glad
9
to
see
the
Montessori
kids
here
­­
the
day
that
10
the
science,
independently
verifiable
science,
11
comes
in
and
shows
that
an
aggressive
PM
coarse
12
standard
is
required
and
shows
measurable
health
13
benefits,
I
will
be
here
testifying
let's
do
it,
14
even
though
many
of
my
members
would
probably
be
15
opposed
to
that.
16
The
science
is
not
in
yet,
and
I
would
17
argue
that
for
these
and
other
reasons
that
18
there's
not
a
scientifically
sound
or
adequate
19
basis
for
the
adoption
of
a
coarse
PM
standard
at
20
this
time.
We
support
the
alternative
of
not
21
adopting
a
coarse
PM
standard
for
ambient
22
exposure.
However,
if
the
agency
does
decide
to
23
go
forward,
we
would
certainly
urge
the
use
of
an
24
indicator
defined
as
urban
PM
coarse.
25
254
And
since
the
red
light
is
blinking,
1
I'll
stop
at
this
point.
Thank
you
very
much.
2
MR.
BURNETT:
Thank
you.
And
thank
you
3
for
sticking
within
the
five
minutes.
We'll
have
4
questions.
5
One
question
and
probably
something
that
6
would
­­
you
may
need
to
go
back
for.
We
are
7
proposing
for
the
coarse
standard
to
change
the
8
averaging
time
from
one
expected
exceedance
form
9
to
a
98
percentile
form.
And
in
so
doing,
the
10
equivalent
level
would
be
lower
than
150.
Even
11
apart
from
the
issue
that
you're
talking
about
in
12
terms
of
defined
fraction,
I
would
be
interested
13
if
you
have
comments
on
the
equivalency
issue
14
taking
into
account
the
different
form
of
the
15
proposal
compared
to
the
current
1990
­­
1987
16
PM10
standard?
17
MR.
SIMS:
I
would
like
to
do
that,
and
18
this
is
something
that
I'd
like
to
get
back
to
19
you
on.
And
I've
got
a
number
of
our
members
who
20
are
following
this
very
closely,
and
I
can
21
quickly
get
a
survey
to
them
and
say
what
is
­­
22
on
this
issue
what
is
the
consensus.
So
if
you
23
would
let
me
get
back
to
you,
I
would
love
to
do
24
that.
25
255
MR.
BURNETT:
Very
good.
1
Thank
you
both
again
for
your
time
2
coming
in.
3
MS.
JONES:
Can
I
make
a
quick
comment,
4
please?
I
know
I
didn't
use
my
time
up.
5
MR.
BURNETT:
We
have
two
more
­­
I'm
6
sorry
­­
we
have
three
more
speakers,
and
then
7
we're
probably
going
to
have
a
break.
Wondering
8
if
you
would
be
willing
to
hold
this
comment
9
until
the
break.
I
would
be
happy
to
talk
with
10
you
at
that
point
in
time.
I
would
like
to
move
11
through.
12
MS.
JONES:
Okay.
Fine.
13
MR.
BURNETT:
Dr.
Persky
and
Ms.
Pino,
14
please.
15
Dr.
Persky.
16
DR.
PERSKY:
Hello.
My
name
is
Victoria
17
Persky.
I'm
an
internist
and
a
professor
of
18
epidemiology
at
the
University
of
Illinois
in
19
Chicago.
Most
of
my
research
these
days
is
20
environmental
epidemiology.
And
I'm
here
today
21
to
urge
the
EPA
to
decrease
the
annual
standard
22
of
PM2.5
from
15
to
12
micrograms
per
meter
cubed
23
and
to
decrease
the
daily
standard
to
25
24
micrograms
per
meter
cubed.
25
256
Over
the
last
10
to
15
years,
it
has
1
become
clear
that
exposure
to
fine
particulates,
2
PM2.5
or
less
than
2.50
microns
in
diameter,
is
a
3
key
factor
in
morbidity
and
mortality.
The
4
increased
risk
of
respiratory
symptoms,
5
hospitalizations,
total
deaths,
and
6
cardiopulmonary
deaths
at
far
lower
levels
than
7
previously
appreciated
and
appear
to
act
through
8
a
wide
variety
of
documented
pathways
including
9
increased
inflammation,
altered
heartbeats,
10
decreased
lung
function,
and
an
increased
11
tendency
to
heart
attacks.
The
effects
are
both
12
acute
and
chronic.
13
Previously
it
was
thought
that
exposures
14
to
fine
particles
may
increase
risk
of
deaths
by
15
a
few
percent
per
year.
Just
this
month
a
16
recently
published
update
of
the
Harvard
Six
17
Cities
Study
by
Francine
Laden,
a
long­
term
18
cohort
study
upon
which
many
recommendations
have
19
been
rested
in
the
past,
suggest
for
each
10
20
micrograms
per
meter
cubed
increase
in
fine
21
particles,
the
term
risk
of
total
death
might
22
increase
by
as
much
as
14
to
16
percent,
or
tens
23
of
thousands
of
deaths
per
year
in
the
United
24
States
alone.
25
257
And
just
this
week,
March
8th,
JAMA
1
using
hospitalizations
and
the
Medicare
database
2
with
a
mean
fine
particle
level
of
13.4
showed
a
3
28
percent
increase
in
congestive
heart
failure
4
deaths.
5
There
is
now
ample
data
also
suggesting
6
that
both
short
and
long­
term
effects
exist
at
7
levels
considerably
below
the
current
standards
8
as
shown
by
the
two
recent
papers
and
several
9
analyses
in
the
past
with
no
clear
threshold
10
apparent.
These
appear
to
be
linear
effects
down
11
to
levels
far
below
those
addressed
by
the
12
current
standards.
13
Fine
particle
come
from
both
mobile
and
14
stationary
sources,
from
motor
vehicles
and
15
industrial
pollutants.
The
new
proposal
to
16
replace
standards
to
coarse
particles
of
PM10
or
17
PM
less
than
10
microns
to
a
new
size
range
of
18
2.5
to
10
in
urban
areas
alone
would
eliminate
19
exposure
within
that
category
to
particles
less
20
than
2.5,
the
fine
particles
that
have
been
found
21
to
be
more
related
to
cardiac
and
pulmonary
22
disease.
23
In
addition,
the
standards
would
no
24
longer
address
exposures
in
small
and
mid­
sized
25
258
communities
and
particulate
exposures
from
1
mining,
oil
and
gas
development,
logging
and
2
industrial
agriculture.
3
Health
effects
of
particulate
exposure
4
have
been
documented
in
thousands
of
people
with
5
acute
and
chronic
exposures
and
in
all
age
6
groups.
They
affect
the
15
million
Americans
7
with
asthma
and
contribute
to
the
hundreds
of
8
thousands
of
deaths
due
to
cardiovascular
and
9
respiratory
diseases.
10
This
is
a
key
time
in
our
history.
11
We've
made
substantial
progress
as
noted
by
some
12
of
the
previous
speakers
over
the
last
20
years.
13
During
this
time,
however,
the
evidence
of
14
effects
of
lower
levels
of
pollution
has
also
15
increased
and
underscored
the
importance
of
16
continued,
aggressive
approaches
to
regulation.
17
Let
us
not
ignore
the
Clean
Air
Scientific
18
Advisory
Committee.
Let
us
not
step
backwards
19
but
continue
to
move
forward
in
creating
a
20
healthy
environment
for
all
of
us.
21
MR.
BURNETT:
Thank
you
for
your
22
comments.
23
Ms.
Pino.
24
MS.
PINO:
My
name
is
Delores
Pino.
I'm
25
259
here
speaking
as
a
citizen,
a
life­
long
resident
1
of
the
Chicago
area.
I'm
also
a
environmental
2
activist
and
attorney.
3
I
support
­­
I
fully
support
4
strengthening
the
current
EPA
proposal
as
in
5
Dr.
Orris's
testimony
and
Environmental
Defense
6
testimony
that
was
submitted.
And
I
echo
7
Dr.
Persky's
testimony.
8
I
wanted
to
­­
since
I'm
an
attorney,
I
9
have
a
couple
of
­­
well,
first
my
everyday
10
experience
living
in
the
Chicago
area
tells
me
­­
11
you
know,
my
eyes
and
my
breath
and
my
lungs
tell
12
me
that
it's
a
major
problem.
You
know,
the
soot
13
in
the
air.
You
just
walk
down
any
downtown
14
street,
try
to
walk
a
mile
downtown,
and
they're
15
sculpting
great
amounts
of,
you
know,
fine
16
particulate
matter.
And
all
of
our
lungs,
living
17
in
this
area,
are
probably
gray.
Even
though,
18
you
know,
for
nonsmokers
on
dissection
when
we
19
die,
you
know,
the
smoker's
lungs
are
black
20
usually
versus
the
normal
healthy
lungs
which
are
21
pink.
Ours
are
all
gray.
I'm
sure
­­
I
believe,
22
you
know,
it
has
to
be
the
case.
23
And
it
just
is
such
a
tragedy.
I
feel
24
so
horrible
every
time
I
see
children
and
babies,
25
260
you
know,
up
on
the
city
streets,
and
that's,
of
1
course,
everywhere
in
the
city.
I'm
mostly
2
downtown.
But
the
babies
and
the
children
3
breathing
in
this
horrible
air
that's
poisoning
4
their
new
lungs
and
causing
all
these
health
5
problems.
You
know,
they
can't
go
out
to
play.
6
They
have
to
limit
how
much
they
play.
It's
a
7
horrible
tragedy.
8
So
it's
these
standards,
the
stricter
9
ones,
that
all
the
environmentalists
are
10
advocating
that
should
be
­­
that
EPA
should
11
change
the
current
proposal
to.
12
Mr.
Burnett,
you
said
in
response
to
the
13
professor
from
Knox
College
that
the
current
14
standard
does
protect
public
health
with
an
15
adequate
margin
of
safety,
but,
however,
I
want
16
to
point
out
that
since
the
clean
air
­­
Clean
17
Air
Scientific
Advisory
Committee
and
U.
S.
EPA
18
staff
have
advocated
the
stricter
ones
yet
the
19
current
proposal
is
a
less
stringent
choice,
that
20
can
only
be
a
political
choice
and
an
economic
21
choice
based
on
what
industry,
corporations,
you
22
know,
are
asking
for
or
have
asked
for
of
the
23
Bush
Administration,
which
has
been
the
history
24
of
the
Bush
Administration,
weakening
all
of
our
25
261
major
environmental
protections,
you
know,
at
the
1
behest
of
industry,
you
know,
short­
term
dollars.
2
However,
we
know
that
the
Clean
Air
Act
3
states
very
clearly
that
these
standards
are
to
4
be
based
on
public
health
alone,
without
5
reference
to
the
economics,
the
money
involved.
6
And
that's
very
much
morally
I
believe
the
7
right
­­
you
know,
it's
great
that
we
have
this
8
Clean
Air
Act
and
that
Congress
set
that
­­
those
9
standards
and
that
form
of
moral
decision­
making
10
for
the
air
that
we
all
have
to
breathe
every
day
11
to
live,
to
continue
to
live.
12
So
EPA's
choices
on
this
proposal
and
on
13
many
other
things
since
the
Bush
Administration
14
came
to
power
have
been
on
economic
choices.
But
15
this
does
violate
the
Clean
Air
Act
because
it's
16
supposed
to
be
made
on
public
health
alone.
And
17
the
overwhelming
amount
of
the
science,
as
18
everyone
has
stated
­­
I'm
not
an
expert
either.
19
But
thousands
and
thousands
of
studies
and
U.
S.
20
EPA's
own
scientists
stating
that
it
needs
to
be
21
stricter.
That
is
the
current
state
of
the
22
science,
and
that's
what
we
should
be
doing.
23
I
want
to
­­
I'll
ask
a
question
now.
24
I'm
quite
concerned
about
jet
pollution
and
the
25
262
fact
that
jet
exhaust
from
the
millions
of
1
flights
every
year
in
this
country
around
the
2
world
are
totally
excluded
from
controls
for
3
particulate
matter
as
well
as
for
all
other
Clean
4
Air
Act
standards.
Is
that
not
true?
That's
5
correct,
isn't
it?
It's
not
governed
at
all
what
6
comes
out
in
the
jet
engines,
and
there's
7
nothing,
you
know,
that's
controlling
it
or
8
filtering
it.
Like
on
vehicles,
you
know,
the
9
catalytic
converter
filters,
there's
nothing
10
filtering
jet
engines.
And
we're
exposed
to
11
1.5
million
landings
and
takeoffs
from
O'Hare
12
every
year
in
the
Chicago
area,
fifty
mile
13
radius,
plus
what's
at
Midway.
14
So
­­
and
every
city,
you
know,
where
15
there's
a
major
airport
has
similar
problems.
16
And
that's
totally
invisible.
It's
not
invisible
17
to
people
who
know
about
it,
but
it's
not
taken
18
into
account
and
it's
not
regulated
and
it's
not
19
being
ratcheted
down
as
all
the
air
pollution
20
should
be.
21
So
that
needs
to
be
worked
on,
jet
22
pollution,
because
that's
a
huge
part
of
this
too
23
and
absolute
particulate
matter
raining
down
on
24
all
of
us
from
the
planes
landing
and
taking
off
25
263
at
O'Hare
which
are
about
to
double
with
the
1
proposed
expansion
of
O'Hare.
And
all
major
­­
2
many
major
airports,
thousands
around
the
country
3
have
planned
expansions,
so...
4
Thank
you.
5
MR.
BURNETT:
I
appreciate
your
6
comments.
The
specifics
of
the
regulations
that
7
we
have
for
jet
engines
we
will
have
to
­­
I
will
8
have
to
get
back
to
you.
I
don't
know
if
anyone
9
else
here
­­
10
MS.
PINO:
I
don't
think
it
touches
­­
11
I'm
sure
it
does
not
touch
jet
engines.
Those
12
have
always
been
excluded
from
the
Clean
Air
Act
13
regulations.
14
MR.
BURNETT:
On
the
issue
of
the
15
airport
expansion,
it's
my
understanding
that
we
16
work
quite
close
with
­­
the
U.
S.
A.
EPA
has
17
worked
quite
closely
with
the
city,
and
the
city
18
has
put
together
the
required
environmental
19
impact
assessment,
and
that
would
be
the
place
20
that
I
would
go
to
for
a
more
detailed
discussion
21
about
how
these
issues
have
been
taken
into
22
account.
23
MS.
PINO:
Well,
it's
not
regulated
24
whatsoever.
That
also
is
political
choices,
you
25
264
know,
involved.
So
it's
a
­­
you
know,
that
1
doesn't
regulate
what
comes
out
of
the
jet
2
engines.
It
just
basically
allows
it
to
occur
3
and
to
double.
So
it's
a
huge
­­
what
comes
out
4
of
the
jet
engines
in
and
out
of
the
Chicago
5
region
is
a
huge
component
of
the
soot,
you
know,
6
the
particulate
matter,
of
the
total
particulate
7
matter
of
the
Chicago
region,
and
no
one
really
8
pays
attention
to
that.
So
­­
and
it
needs
to
9
be
­­
start
being
regulated.
10
MS.
SASSER:
We
should
maybe
note
here
11
that
EPA
does
have
a
number
of
voluntarily
12
programs
focusing
on
other
types
of
emissions
13
from
airports
such
as
the
ground
transportation
14
equipment
and
so
forth.
So
even
though
the
15
aircraft
themselves
may
be
out
of
our
16
jurisdiction,
we
do
try
to
make
an
effort
to
17
reach
out
to
the
components
that
we
might
make
an
18
impact
with.
19
MS.
PINO:
Why
are
they
out
of
your
20
jurisdiction?
What
do
you
mean?
21
MS.
SASSER:
Well
­­
22
MR.
BURNETT:
In
the
Office
of
Air
and
23
Radiation,
we
have
an
office
focused
on
24
transportation
issues.
Our
Office
of
25
265
Transportation
Air
Quality.
And
I
would
­­
we're
1
gonna
have
a
break
in
probably
15
minutes
or
so.
2
At
that
point
please
come
up
to
one
of
us,
and
we
3
can
put
you
in
touch
with
the
appropriate
expert
4
in
that
office.
I
apologize
but
I
think
that
we
5
don't
have
the
right
expertise
at
the
table
here
6
to
answer
your
particular
question.
7
I'd
like
to
thank
you
both
again
for
8
coming,
and
ask
Ms.
Alexander
and
Mr.
Neufeld
to
9
come
forward,
please.
10
MS.
ALEXANDER:
My
name
is
Ann
11
Alexander.
I'm
am
Environmental
Counsel
to
12
Attorney
General
Lisa
Madigan,
and
I'm
here
today
13
because
we
want
to
emphasize
that
the
Agency's
14
decision
to
ignore
the
scientific
consensus
on
15
the
need
to
tighten
the
fine
particulate
matter
16
standard
is
not
only
a
matter
of
violation
of
17
scientific
integrity,
it's
also
a
violation
of
18
law.
19
For
the
first
time
in
history,
the
20
Agency
has
disregarded
the
recommendation
of
the
21
Clean
Air
Scientific
Advisory
Committee
which
22
advised
that
the
current
annual
standard
is
23
insufficiently
protective
of
health
and
is
24
allowing
many
preventable
deaths.
The
CASAC
25
266
recommendation
is
consistent
with
the
1
overwhelming
consensus
of
peer­
reviewed
2
scientific
study
since
1996
when
the
currently
3
applicable
standard
was
promulgated.
More
than
4
2,000
such
peer­
reviewed
studies
have
confirmed
5
the
link
between
fine
particulate
matter
and
6
various
disease
and
death
and
have
also
7
determined
that
increased
levels
of
sickness
and
8
death
attributable
to
fine
particulate
matter
are
9
occurring
under
the
current
standard.
10
The
CASAC
was
established
by
Congress
11
with
the
specific
mission
of
advising
EPA
in
12
setting
its
ambient
standards.
If
that
Clean
Air
13
Act
provision
establishing
CASAC
in
its
role
is
14
to
have
any
meaning
at
all,
then
the
U.
S.
EPA
is
15
obligated
to
carefully
consider
CASAC's
16
recommendations
as
it
consistently
has
in
the
17
past,
until
now.
18
Now,
some
might
argue
that
the
Agency
is
19
legally
entitled
to
consider
the
CASAC
20
recommendation
and
then
make
a
choice
to
reject
21
it
based
on
sound
science.
That
may
or
may
not
22
be
true,
but
the
fact
of
the
matter
is
that
23
that's
not
what
happened
here.
It
can
be
fairly
24
gleaned
from
the
record
that
the
agency
rejected
25
267
the
CASAC
recommendation
simply
because
it
did
1
not
like
its
conclusions.
2
Rejection
in
this
way
of
science
as
a
3
basis
for
Clean
Air
Act
standards
is
not
just
a
4
violation
of
the
Clean
Air
Act
provisions
5
established
in
CASAC
but
also
we
believe
of
the
6
U.
S.
Supreme
Court
decision
from
2001
which
7
determined
that
the
agency
is
required
to
set
8
standards,
ambient
standards,
based
solely
on
9
public
health
considerations
and
not
on
costs
and
10
other
considerations.
11
Now,
it's
not
entirely
clear
from
the
12
record
exactly
what
considerations
were
in
fact
13
behind
U.
S.
EPA's
decision
to
reject
the
CASAC
14
recommendation
and
the
recommendation
of
the
15
2000­
plus
peer­
reviewed,
scientific
studies,
but
16
I
think
it's
fair
to
say
that
public
health
does
17
not
appear
to
be
foremost
among
those
18
considerations.
19
We
believe
the
rejection
of
the
CASAC
20
recommendations
sets
a
terrible
precedent.
But
21
worse
than
that,
it's
really
not
even
a
precedent
22
in
the
larger
sense.
We
view
it
unfortunately
as
23
the
latest
example
of
the
Agency's
setting
aside
24
the
conclusions
of
it's
own
scientist
in
order
to
25
268
assist
the
industry
that
it's
supposed
to
be
1
regulating.
We
saw
it
happen
with
the
mercury
2
rule.
We
saw
it
happen
with
the
New
Source
3
Review
rules.
And,
unfortunately,
we
believe
4
that
we're
seeing
that
happen
again
now.
5
Once
again,
as
in
those
other
6
situations,
we
are
asking
EPA
to
put
the
focus
7
back
where
the
law
requires
it
to
be
which
is
on
8
the
conclusions
of
scientists
rather
than
the
9
wish
lists
of
regulated
industry.
Thank
you.
10
MR.
BURNETT:
Thank
you
for
your
11
comments.
12
Are
there
any
clarifying
questions?
13
Appreciate
you
coming
in
to
comment.
14
Mr.
Neufeld.
15
MR.
NEUFELD:
My
name
is
Randy
Neufeld.
16
I'm
the
Healthy
Streets
Campaign
Coordinator
for
17
the
Chicagoland
Bicycle
Federation.
I'm
here
18
today
to
suggest
that
a
more
protective
19
particulate
standard
would
be
consistent
with
20
other
public
health
policies
of
the
current
21
administration.
22
The
public
health
effort
for
clean
air
23
is
firmly
linked
to
the
public
health
effort
to
24
increase
physical
active.
Right
now,
as
many
of
25
269
you
know,
we
have
a
sedentary
lifestyle
problem
1
in
the
United
States
that
is
creating
a
public
2
health
crisis.
The
list
of
illness
and
disease
3
caused
by
sedentary
lifestyle
is
very
similar
to
4
the
list
of
illness
and
disease
caused
by
5
exposure
to
particulates,
and
there's
a
6
tremendous
effort
across
the
country
to
encourage
7
physical
activity
and
nutrition
as
a
solution
to
8
these
problems
of
sedentary
lifestyle.
9
There
are
efforts
all
across
the
10
country.
The
most
predominant
is
in
the
latest
11
transportation
bill.
There
are
$
621
million
for
12
a
federal
Safe
Routes
to
School
program.
About
13
21
millions
of
dollars
of
that
will
be
spent
in
14
the
State
of
Illinois.
That
program
essentially
15
encourages
the
replacement
of
driving
trips
to
16
school
with
bike
and
walk
trips
to
school.
17
Bicycle
­­
essentially
it's
part
of
a
whole
set
18
of
public
health
efforts
that
try
to
get
children
19
outside
recreating,
exercising,
using
their
20
bodies,
instead
of
sitting
in
front
of
computers
21
and
TV
screens
and
generally
sitting.
22
When
children
are
outside,
when
adults
23
are
outside,
exercising,
riding
bicycles,
24
walking,
they
are
taking
in
more
air
and
whatever
25
270
particulates
are
in
the
air.
They're
breathing
1
more
of
those,
so,
therefore,
a
more
protective
2
standard
would
be
appropriate.
3
Also
other
parts
of
the
EPA
are
4
encouraging
people
to
replace
automobile
trips
5
with
walking
and
bicycling
as
a
way
to
mitigate
6
emissions
of
vehicles.
When
air
is
dirty,
it
7
undermines
and
counteracts
the
benefits
of
8
physical
activity.
When
particulate
standards
9
are
inadequate,
they
compromise
efforts
to
10
promote
physical
activity.
11
There
are
also
economic
development
12
ramifications
to
this
issue.
The
health
of
a
13
city
is
very
much
dependent
on
its
retail
14
corridors.
There's
been
a
lot
of
revitalization
15
of
those
retail
corridors.
They
generally
run
16
along
transportation
corridors.
And
when
there
17
is
heavy
diesel
use
and
other
particulates,
they
18
become
less
economically
viable
places.
19
Most
Americans
live
in
urban
areas.
20
Physical
activity
is
a
daily
part
of
life.
It's
21
important
to
the
health
and
our
quality
of
life.
22
We
should
not
abandon
the
outdoor
environment
of
23
our
cities
and
suburbs.
24
We'd
like
you
to
please
strengthen
the
25
271
particulate
standard.
It's
sort
of
a
bicycle
1
helmet,
except
not
for
the
head
but
for
the
2
lungs.
We
realize
that
the
standard
doesn't
3
automatically
clean
up
the
air,
but
it's
a
very
4
important
basis
for
the
work
that
many
of
us
do
5
in
terms
of
dirty
diesel,
in
terms
of
6
transportation
sources
in
particular
trying
to
7
mitigate
those
sources.
8
And
we
would
like
to
see
the
efforts
9
that
the
Administration
and
others
are
doing
to
10
promote
physical
activity
to
achieve
the
full
11
benefits
of
walking
and
bicycling
by
maintaining
12
the
cleanest
air
quality
possible.
Thank
you.
13
MR.
BURNETT:
Thank
you
both
for
your
14
comments.
15
Mr.
Jones
and
Mr.
Lensu,
please.
16
Mr.
Jones.
17
MR.
JONES:
Okay.
My
name
is
Bruce
18
Jones.
I
live
in
Northwest
Indiana.
I
was
19
diagnosed
with
Chronic
Obstructive
Pulmonary
20
Disease
in
the
year
2000.
21
I
might
sound
a
little
faint
at
times
22
due
to
air
flow
obstruction
in
my
lungs.
When
I
23
was
diagnosed,
I
was
able
to
stop
smoking
easily,
24
but
I
soon
learned
that
there
were
various
risk
25
272
factors
that
I
would
have
to
control,
one
of
1
those
being
avoiding
secondhand
smoke,
one
of
2
those
being
limiting
my
exposure
to
air
3
pollution,
which
I
have
been
largely
successful
4
in
doing,
but
not
always.
5
In
Chicago,
there's
estimated
to
be
6
225,000
patients
with
COPD
who
have
not
yet
been
7
diagnosed.
There's
another
225,000
who
have
been
8
diagnosed.
What
are
they
to
do,
what
am
I
to
do,
9
if
we
are
required
to
be
exposed
on
an
ongoing,
10
day­
to­
day
basis
to
what
has
been
identified
as
11
risk
factors
that
will
cause,
compound
Chronic
12
Obstructive
Pulmonary
Disease.
13
The
global
initiative
for
obstructive
14
lung
disease
has
identified
air
particulates,
and
15
air
pollution
as
a
whole,
as
a
significant
risk
16
factor
for
causing
this
illness.
COPD
is
the
17
fourth
leading
cause
of
death
in
the
United
18
States.
It's
expected
to
become
the
third
19
leading
cause
of
death
in
the
United
States.
20
We
will
not
be
alone.
People
in
this
21
room
will
end
up
with
the
disease
probably,
22
whether
they
want
it
or
not,
whether
they
smoke
23
or
not.
Not
only
is
smoking
and
secondhand
smoke
24
and
air
pollution
known
causes
of
COPD,
but
there
25
273
is
also
that
Alpha­
1
Antitrypsin
Deficiency,
1
which
is
an
inheriting
cause
of
COPD.
You
2
combine
this
inherited
deficiency
with
known,
3
other
known
risk
factors,
and
it's
almost
certain
4
that
a
person
will
be
diagnosed
some
day
with
5
COPD.
6
I
have
no
idea
why
our
President
has
7
chosen
to
limit
public
health
as
a
national
8
security,
homeland
security
interest.
And
he
9
seems
to
think
that
terrorism,
and
only
10
terrorism,
is
our
national
threat,
when
we
have
11
threats
from
within
too.
And
public
health
is
12
relevant
and
is
significant.
13
I'm
also
a
bicyclist.
I
travel
to
14
Chicago
all
the
time
to
go
bicycling.
I'm
a
15
member
of
the
Chicago
Bicycle
Federation.
I
need
16
this
kind
of
exercise.
I
can't
jog
but
I
can
17
bicycle.
Other
COPD
patients
have
stated
the
18
same
thing.
They
can't
run.
There's
a
limit
to
19
what
they
can
do.
And
as
long
as
they
are
20
exposed
to
risk
factors
that
caused
their
disease
21
in
the
first
place,
they
are
expected
to
progress
22
and
have
a
continued
decline
in
their
lung
23
function.
Their
lungs
will
continue
to
24
deteriorate
and
perhaps
eventually
kill
them.
25
274
Thank
you.
That's
it.
Thank
you.
1
MR.
BURNETT:
Appreciate
your
comments.
2
And
I'm
sorry
to
hear
about
your
condition,
and
3
it's
certainly
one
of
many
reasons
why
we,
as
an
4
agency,
take
particulate
matter
pollution
very
5
seriously
and
are
both
issuing
regulations
that
6
reduce
it
as
well
as
proposing
tightening
of
the
7
standard.
8
Do
you
have
particular
recommendations
9
for
tightening
of
the
standard?
10
MR.
JONES:
Yes,
I
do.
11
Ignore
President
Bush's
proposal
to
12
weaken
the
health
standards,
but
go
with
the
13
current
scientific
advice
to
strengthen
them
to
14
the
maximum
extent
possible.
15
MR.
BURNETT:
Mr.
Lensu.
16
MR.
LENSU:
Hello.
My
name
is
Wayne
17
Lensu.
I've
been
in
Chicago
for
14
years.
I
18
come
from
New
York,
and
I've
noticed
a
definite
19
worse
air
quality
in
Chicago
than
I
had
20
experienced
in
New
York
most
of
my
life.
I've
21
had
many
more
respiratory
problems
since
I've
22
been
working
and
living
here.
23
I
realize
there's
an
enormous
amount
of
24
diesel
emissions
from
vehicles,
trucks,
and
all
25
275
of
the
railroads
that
you
have
in
container
1
shipping
that
comes
through
Chicago.
So
that
2
certainly
contributes
to
the
problems
that
you
3
have
in
this
city.
4
I've
also
read
and
think
that
Chicago
5
has
worse
air
quality
and
more
problems
with
6
asthma
and
other
respiratory
diseases
than
many
7
cities
in
this
country.
8
I've
also
noticed
in
the
last
three
or
9
four
years
some
kind
of
black
mold
that
I
didn't
10
experience
here,
you
know,
in
the
years
before
11
living
in
Chicago.
I
have
no
idea
where
that's
12
coming
from
or
what's
causing
it,
but
it
seems
to
13
be
all
over.
I
travel
back
and
forth
to
New
York
14
several
times
a
year,
and
I
don't
see
any
of
this
15
black
mold
or
anything
like
that
in
New
York,
and
16
New
York
is
certainly
an
industrial,
you
know,
17
city.
I
think
your
electric
generating
plants
18
here
are
predominantly
coal
fired,
and
New
York
19
may
not
have
that
problem
with
particle
emissions
20
from
coal­
fired
generating
plants.
21
One
of
my
concerns
is
noticing
some
kind
22
of
aerosol
spraying
that
apparently
started
the
23
end
of
1998
was
the
first
time
that
I
saw
it
24
here.
And
it
doesn't
look
like
it's
typical
25
276
contrail
formations
which
carry
at
a
high
1
altitude
certain
temperatures
and
extremely
low
2
humidity.
3
I
worked
for
Pan
Am
for
19
years
till
4
they
went
out
of
business
in
New
York
in
December
5
of
1991.
I
also
worked
for
Beech
Aircraft
in
6
Boulder,
Colorado,
in
1967.
And
typically
7
contrails
disappear
shortly
after
the
plane
is
8
passing.
You
can
watch
them
just
dissipate
as
9
the
plane
is
moving
across
the
sky.
10
What
I'm
talking
about
is
some
kind
of
11
aerosol
phenomenon
that
persists
that
disperses
12
and
starts
to
look
like
normal
clouds
after
a
13
certain
period
of
time.
Now,
I
don't
know
what
14
this
is.
I've
tried
to
get
information
about
it.
15
I've
called,
you
know,
radio
stations,
NPR,
the
16
Chicago
Tribune,
the
environmental
people
there.
17
And
all
of
the
research
that
I've
done
personally
18
on
the
Internet
results
in
a
total
stonewall
or
19
denial
that
a
program
like
this
is
going
on.
20
What's
curious
to
me
in
particular
is
I
21
work
as
a
waste
water
operator
for
Metropolitan
22
Water
Reclamation
­­
I'm
a
Class
I
Wastewater
23
Operator
­­
and
our
operating
permit
has
strict
24
limits
in
the
different
metals
and
particles
that
25
277
we're
allowed
to
discharge
with
our
effluent.
1
And
there
are
absolutely
no
limits
on
aluminum,
2
which
is
strikes
me
as
being
particularly
3
strange.
We're
checking
for
barium,
lithium,
4
iron,
iron
oxide,
everything
you
can
imagine,
5
mercury.
But
nothing
about
aluminum.
And
I'm
6
trying
to
find
out
why
that's
been
excluded,
and
7
so
far
I
haven't
gotten
any
information
on
that.
8
There's
a
lot
of
people
that
think
that
9
aluminum
contributes
to
Alzheimer's
disease,
10
arthritis,
many
neurological
problems,
and
it's
11
definitely
not
something
that
we
would
want
to
12
have
in
our
air
if,
in
fact,
that
is
being
13
sprayed
in
the
air
deliberately.
I'm
trying
to
14
understand
why
anyone
would
want
to
be
doing
15
something
like
this
and
why
there's
complete
16
denial
about
it.
17
I've
stopped
my
contributions
to
a
lot
18
of
the
major
environmental
organizations
after
19
asking
them
what
they
know
about
it
or
what
20
they're
doing
about
it,
and
they
are
all
in
total
21
denial
as
well
and
say,
no,
these
are
typical
22
aircraft
contrails.
There
is
nothing
else
going
23
on.
24
And
I
think
any
person
who
would
look
at
25
278
the
sky
for
a
few
minutes
a
day
would
have
to
1
agree
that
these
are
not
normal
contrails;
that
2
this
is
some
kind
of
obvious
program,
whether
3
it's
covert,
black,
military,
who
knows.
4
I
realize
if
we
were
spraying
some
kind
5
of
metallic
particles,
there
would
be
a
definite
6
military
application
to
reflect
radar
around
the
7
surface
of
the
earth.
And
I
remember
the
first
8
video
coverage
that
I
saw
on
TV
when
we
went
into
9
Afghanistan,
there
were
lines
or
trails
being
10
sprayed
by
aircraft
there,
and
it
was
very
11
obvious
in
newsreel
footage.
So
I
suspect
that
12
was,
you
know,
definitely
a
military
application
13
to
be
able
to
see
what
was
on
the
other
side
of
14
the
hills
and
so
on.
I
doubt
that
anybody
in
15
Afghanistan
would
have
been
deliberately
spraying
16
something
like
that
for
some
reason.
You
know,
17
it's
a
low­
tech
country,
very
poor.
No
one
would
18
be
spending
money
on
that,
that
I
can
imagine.
19
Anyway,
that's
my
concern.
I
didn't
20
know
if
any
of
you
would
address
that
or
have
any
21
knowledge
of
this
program.
It's
something
that
22
obviously
is
going
on,
and,
you
know,
maybe
I'm,
23
you
know,
looking
at
the
emperor
with
no
clothes
24
here.
But,
you
know,
I'm
being
persistent
trying
25
279
to
find
out
what
I
can
about
this
ongoing
1
phenomenon.
2
Thank
you.
3
MR.
BURNETT:
Thank
you
for
your
4
comments.
And
I
would
ask
if
you
have
written
5
comments
that
you
have
available
that
you
submit
6
them
to
the
record.
And
as
part
of
this
process,
7
we
respond
to
comments,
and
we
have
a
8
response­
to­
comment
document,
and
that
is
the
9
place
where
we
bring
the
Agency's
expertise
to
10
bear
on
issues
raised
by
comment
at
this
time.
11
So
I
will
thank
you
both
for
coming
in
12
today
and,
again,
repeat
that
if
you
have
any
13
comments,
that
you
submit
them
to
the
14
registration
desk
at
the
front,
and
we
will
put
15
that
in
the
public
docket.
16
MR.
LENSU:
Thank
you.
17
MR.
BURNETT:
Thank
you.
18
Ms.
Bagot
and
Mr.
Urbatchesky.
19
MR.
URBASZEWSKI:
Urbaszewski.
20
MR.
BURNETT:
Urbaszewski.
I
apologize.
21
Mr.
Urbaszewski.
22
MS.
BAGOT:
Hi.
My
name
is
Ashley
23
Bagot.
As
far
as
how
it's
pronounced,
good
job.
24
I've
lived
in
Chicago
all
my
life,
and
I
25
280
can't
possibly
be
the
first
person
to
comment
on
1
the
winter
that
we've
just
had.
I've
made
jokes
2
to
my
friends
about
how
I
feel
a
bit
perverse
3
enjoying
the
45­
degree
January
when
I
know
that
4
it
came
on
the
heels
of
the
horrible
devastation
5
of
Hurricane
Katrina.
6
Again,
I'm
sure
I'm
not
the
first
person
7
to
bring
that
up.
And
I
bring
it
up
for
a
good
8
reason;
that
it
is
a
shocking
and
horrifying
9
example
of
global
climate
change.
And
the
global
10
climate
change,
it's
not
an
accident.
It's
not
a
11
fluke.
It's
not
just
some
bizarre
happenstance.
12
It's
something
that
we've
perpetrated
because
13
we're
not
careful
about
the
things
that
we
14
release
into
our
environment
and
we're
not
being
15
held
accountable.
16
I
look
at
­­
I'm
a
social
worker,
and
I
17
work
with
people
who
are
mentally
ill
who
have
18
chronic
and
persistent
mental
illness,
and
I
work
19
with
children
who
are
autistic.
And
I
know
that
20
releasing
­­
the
sharp
increase
of
mercury
in
our
21
waters
is
directly
linked
to
the
sharp,
amazing,
22
almost
a
hundred
percent
increase
in
autism
over
23
the
last
20
years.
24
I
also
know
that
particle
pollution
is
25
281
directly
linked
to
the
raise
in
asthma.
There
1
are
so
many
children
in
Chicago
who
have
asthma
2
because
they
live
in
poor
neighborhoods
like
3
Pilsen
where
there
is
still
coal
dust,
4
coal­
burning
plants.
And
it
really
kind
of
5
breaks
my
heart
because
I
know
that
every
time
I
6
look
on
line
I
see
these
ideas
of
lowering
7
restrictions
and
weakening
standards
for
8
pollution,
air
pollutants,
and
I
know
that
it's
9
happening
because
of
big
power
lobbyists
and
10
special
interests,
because
it's
all
about
the
11
bottom
line.
And
the
bottom
line
to
them
is
12
profit
margins.
13
But
what's
our
bottom
line?
My
bottom
14
line
is
the
health
and
public
safety
of
our
15
citizens,
not
just
nationally,
but
globally.
16
And
in
addition
to
being
a
social
17
worker,
I'm
also
a
babysitter.
And
I
babysit
two
18
very
sweet
little
boys
who
both
have
asthma
and
19
can't
enjoy
running
and
playing
outside.
And
20
they're
so
lively
and
wonderful,
and
I
want
them
21
to
live
their
lives
to
the
fullest.
And
I
also
22
just
can
see
how
air
pollution
affects
everyone.
23
It
affects
poor
and
rich
alike.
24
And
to
all
of
these
special
interests
25
282
and
big
power
lobbyists,
I
just
have
to
ask:
How
1
much
money
is
enough
to
make
it
worth
it
to
2
knowing
they
release
poison
into
the
air
that
3
everyone
has
to
breathe?
Air
pollution
affects
4
everyone.
5
And
I
guess
that
that's
all
I
have
to
6
say.
I
would
just
hope
that
everyone
would
do
7
everything
in
their
power
to
make
sure
that
we
8
are
leaving
a
cleaner
and
safer
world
for
our
9
children
instead
of
looking
to
line
our
own
10
pockets.
11
MR.
BURNETT:
Thank
you
for
coming
in
12
and
making
those
comments.
13
MR.
URBASZEWSKI:
My
name
is
Brian
14
Urbaszewski.
I'm
the
Director
of
Environmental
15
Health
Programs
for
the
American
Lung
Association
16
of
Metropolitan
Chicago.
17
As
you
know,
Chicago
recently
went
smoke
18
free.
Despite
pressure
from
the
purveyors
and
19
beneficiaries
of
tobacco
pollution,
local
20
officials
here
ultimately
took
action
to
improve
21
indoor
air
quality
because
they
knew
the
medical
22
science
was
unassailable.
Among
detrimental
23
medical
impacts,
tobacco
smoke
triggers
asthma
24
attacks,
causes
cancer,
and
it
kills.
25
283
While
we
have
made
­­
begun
to
make
1
significant
strides
in
eliminating
indoor
air
2
pollution
in
our
region,
like
many
other
urban
3
areas,
the
entire
Chicago
metropolitan
area
also
4
has
a
serious
outdoor
air
pollution
problem.
We
5
still
don't
meet
the
fine
particle
pollution
6
health
standards
set
by
U.
S.
EPA
way
back
in
7
1977.
Like
tobacco
smoke,
this
pollution
is
tied
8
to
severe
health
effects
ranging
from
asthma
9
attacks
to
strokes,
heart
attacks,
and,
as
I
said
10
before,
premature
deaths.
11
No
matter
how
hard
you
try,
you
simply
12
can't
avoid
this
pollution
as
it
is
found
both
13
indoors
and
outdoors.
It's
in
homes,
offices,
14
and
schools,
downtown
streets,
suburban
parking
15
lots.
16
Unfortunately,
this
pollution
most
17
profoundly
affects
the
most
sensitive
and
18
vulnerable
groups
in
society,
including
those
who
19
live
with
lung
disease.
The
numbers
for
asthma
20
alone
here
are
staggering.
Approximately
650,000
21
people
in
the
metropolitan
Chicago
area
have
22
asthma,
one
third
of
them
children.
It
can
keep
23
children
home
from
school.
It
can
send
people,
24
young
and
old,
to
the
emergency
room
and
keep
25
284
them
in
the
hospital.
And
although
people
should
1
not
die
from
asthma,
too
many
do,
over
a
hundred
2
a
year
typically
in
the
Chicago
area.
3
We
also
have
approximately
450,000
4
people
in
the
region
with
COPD,
Chronic
5
Obstructive
Pulmonary
Disease,
and
breathing
for
6
many
of
them
is
a
challenge
every
day,
much
less
7
on
a
day
with
elevated
particles.
8
We
rely
on
the
EPA
to
fulfill
its
9
responsibility
to
set
strong
air
pollutant
health
10
standards
that
protect
these
most
vulnerable
11
populations.
We
also
expect
the
agency
to
use
12
the
best
science
and
the
advice
of
top
experts
to
13
carry
out
their
responsibility
under
the
law.
14
Yet
EPA
Administrator
Johnson
has
rejected
the
15
proposals
of
his
own
government
scientists
as
16
well
as
the
CASAC,
even
though
studies
continue
17
to
find
health
damage
below
the
annual
standard
18
level
set
back
in
1977.
19
If
EPA
is
supposed
to
set
standards
at
20
levels
that
protect
public
health,
including
the
21
health
of
sensitive
populations
with
an
adequate
22
margin
of
safety,
how
can
the
Agency
justify
the
23
position
it
has
taken
of
not
tightening
the
24
annual
standard?
25
285
We
believe
that
even
the
weight
of
the
1
evidence
in
the
studies
prior
to
2003
does
not
2
support
the
Agency's
position.
And
apparently,
3
CASAC
agrees
as
it
is
also
contesting
your
4
proposal.
Nevertheless,
Agency
standards
must
be
5
set
on
the
latest
scientific
knowledge.
6
The
many
studies
published
in
the
last
7
several
years,
including
the
studies
mentioned
8
here
today,
are
again
showing
significant
health
9
impacts
below
the
level
of
the
existing
annual
10
fine
particle
standards,
and
these
compound
the
11
data
of
the
Agency
proposal.
Because
such
health
12
impacts
are
already
within
the
annual
range
13
already
proposed
by
CASAC,
we
propose
that
the
14
Agency
set
an
annual
standard
of
12
micrograms
15
per
cubic
meter.
Again,
the
agency
must
set
a
16
standard
that
protects
everyone
with
an
adequate
17
margin
of
safety.
18
We
realize
that
CASAC
only
considered
19
and
published
research
prior
to
2003,
and
that
20
may
account
for
their
range.
This
protective
21
annual
standard
should
also
be
coupled
with
a
22
24­
hour
standard
of
25
micrograms
using
the
99
23
percentile
approach.
24
Other
people
have
commented
on
coarse
25
286
fraction.
I'll
leave
that
to
others.
But
I
just
1
wanted
to
drive
home
the
point
that
the
public
2
relies
on
the
federal
government
to
tell
them
3
what
is
safe
and
what
isn't.
Right
now,
given
4
the
proposal
from
the
Administrator
and
the
5
scientific
record,
this
is
a
critical
6
responsibility
that
EPA
is
failing.
People
are
7
getting
sick
and
dying.
They
should
know
the
8
cause.
Knowing
that
is
the
only
way
to
begin
to
9
clearly
map
out
a
solution
to
the
problem.
10
The
EPA
proposals
will
leave
millions
of
11
Americans
unprotected
and
will
lead
to
thousands
12
of
avoidable
premature
deaths
and
even
greater
13
morbidity
numbers.
We
deserve
better
from
our
14
government.
15
Thank
you.
16
MR.
BURNETT:
Thank
you
for
your
17
comments.
18
Are
there
particular
studies
that
you
19
would
recommend
that
we
look
at,
and
will
you
be
20
submitting
those?
21
MR.
URBASZEWSKI:
I
think
you
will
get
a
22
wealth
of
studies
being
submitted
in
the
23
written­
comment
period.
Several
of
them
were
24
already
mentioned
today
like
the
JAMA
study
that
25
287
came
out
yesterday,
the
American
Journal
of
1
Respiratory
Care
study
that
came
out,
I
think,
a
2
week
or
so
ago
as
well
as
the
many,
many
studies
3
that
have
been
done
and
published
since
the
close
4
of
the
CASAC
starting
period.
5
MR.
BURNETT:
Thank
you
both
for
your
6
comments
today.
7
Is
there
anybody
else
who
would
like
to
8
testify
at
this
point?
If
not,
we
will
suspend
9
the
hearing
until
we
have
a
couple
of
people
who
10
come
forward
at
which
point
we
­­
sorry
­­
at
11
which
point
we
will
start
back
up.
But
for
the
12
time
being,
we
will
suspend
the
hearing.
Thank
13
you.
14
(
Whereupon
a
break
was
taken.)
15
MR.
BURNETT:
We
are
going
to
start
back
16
up.
We
have
one
person.
17
Mr.
Zeigler,
please
come
forward
here.
18
After
you
give
your
oral
statement,
which
will
be
19
limited
to
five
minutes
­­
and
we
have
a
clock
20
right
here
that
will
signal
when
you
have
two
21
minutes
left
by
turning
yellow
and
then
red
at
22
the
end
of
five
minutes.
After
you
do
that,
if
23
you
wouldn't
mind
giving
your
written
testimony
24
to
the
court
reporter
here.
25
288
And
with
that,
I
will
turn
it
over
to
1
you.
If
you
have
any
questions
about
2
procedure...
3
MR.
ZEIGLER:
No.
4
MR.
BURNETT:
Okay.
5
MR.
ZEIGLER:
Thank
you
very
much.
6
My
name
is
Don
Zeigler
of
Evanston
7
Illinois.
I'm
on
the
faculty
of
Rush
University
8
Medical
Center
in
the
Department
of
Preventive
9
Medicine
in
Chicago
and
serve
as
the
Vice
Chair
10
of
the
Evanston
Community
Health
Advisory
Board.
11
And
I
have
my
complete
statement
here
for
you.
12
While
I'm
not
a
physician,
I
have
a
13
Ph.
D.
in
public
health
and
health
promotion,
and
14
I
was
involved
in
the
first
Earth
Day
in
1970
and
15
fully
expected
that
we
would
have
made
more
16
progress
in
the
last
35
years.
17
I
speak
today
in
my
own
behalf
as
a
18
concerned
citizen
and
health
professional.
We
19
know
conclusively
that
fine
particle
pollution
20
from
power
plants
and
diesel
engines
is
the
21
nation's
deadliest
air
pollutant,
and
in
some
22
parts
of
the
country,
agriculture
and
mining
23
contributes
to
serious
local
coarse
particle
24
problems.
These
particles
lodge
in
the
lungs
and
25
289
enter
the
bloodstream,
causing
serious
problems
1
in
the
cardiovascular
and
respiratory
systems
and
2
contribute
to
problems
of
asthma,
heart
attacks,
3
lung
cancer
and
strokes.
According
to
a
recent
4
peer­
reviewed
article
in
the
Journal
of
5
Epidemiology,
the
health
effects
may
be
6
significantly
greater
than
previously
believed.
7
The
entire
Chicago
metropolitan
area
8
fails
to
meet
the
current
federal
air
quality
9
standards
for
particle
pollution
set
in
1997.
In
10
the
near
north
suburb
of
Evanston
where
I
live,
11
our
high
school's
health
center
told
me
this
12
morning
of
the
increasing
prevalence
and
severity
13
of
asthma
among
students
over
the
past
ten
years.
14
Moreover,
the
city's
health
department
indicated
15
to
me
today
that
part
of
our
community,
South
16
Evanston,
which
borders
on
Chicago,
has
17
traditionally
high
hospital
admission
rates
for
18
asthma,
usually
twice
the
state
average.
My
own
19
son­
in­
law
suffers
from
severe
asthma
and
found
20
significant
relief
only
after
moving
from
21
Chicago.
22
According
to
the
Clean
Air
Act,
the
23
Administration
must
set
quality
standards
at
24
levels
that
protect
public
health
and
regularly
25
290
review
and
update
these
standards.
In
2005
both
1
the
Administration's
independent
science
advisors
2
on
clean
air
and
EPA
staff
concluded
that
adverse
3
health
effects
occur
at
levels
well
below
the
4
current
fine
particle
standards.
Even
though
5
they
recommended
strengthening
the
standards
to
6
protect
public
health
in
December,
I
understand
7
the
Bush
Administration
rejected
these
8
recommendations
and
proposed
fine
particle
9
standards
that
would
largely
maintain
the
status
10
quo
as
requested
by
the
electric
utility
11
companies
and
others.
12
Specifically,
the
Administration
13
rejected
lowering
the
annual
standard
and
14
proposed
only
a
token
reduction
in
the
daily
15
standard
from
65
to
35
micrograms
per
cubic
meter
16
that
will
have
little
effect
on
public
health.
17
It
is
unprecedented
that
an
administration
­­
for
18
the
Administration
to
disregard
the
19
recommendations
of
its
independent
clean
air
20
science
advisors.
21
In
addition
to
the
revisions
in
the
22
particle
standards,
EPA
is
proposing
a
standard
23
for
a
new
size
range
for
coarse
particles
from
25
24
to
10
micrograms
which
would
be
limited
to
urban
25
291
areas
and
exempt
agriculture
and
mining
regions
1
as
I
understand.
2
Coarse
particle
standards
are
important
3
because
breathing
coarse
particles
is
associated
4
with
serious
illness,
hospital
admissions,
and
5
premature
death.
EPA's
proposal
to
limit
the
6
coarse
standards
to
urban
areas
will
have
the
7
most
serious
consequences
in
the
western
U.
S.
8
where
many
small
and
medium­
sized
communities
9
already
face
high
levels
of
coarse
particles
due
10
to
industrial
activities
including
mining,
oil
11
and
gas.
12
I
strongly
urge
the
Administration
to
13
heed
the
scientific
research
on
the
dangers
of
14
particle
pollution
and
to
adopt
an
annual
15
standard
no
higher
than
12
micrograms
per
cubic
16
meter
and
a
daily
standard
no
higher
than
25
per
17
cubic
meter.
Such
an
action
could
reduce
the
18
number
of
premature
deaths
by
possibly
19
80
percent.
In
setting
achievable
standards
to
20
protect
the
health
of
the
nation,
please
follow
21
professional
recommendations
based
on
good
22
science,
and
not
advice
from
private
interests
23
groups.
24
Thank
you
very
much.
25
292
MR.
BURNETT:
Thank
you
for
coming
in
to
1
comment.
2
Just
a
very
minor
technical
note.
The
3
PM10­
2.5
standard
is
covered
particles,
inhalable
4
coarse
particles
smaller
that
10
micrometers
in
5
diameter
and
larger
than
2.5
micrometers
in
6
diameter.
I
just
wanted
to
clarify
that
for
the
7
record.
8
Any
questions?
9
Again,
thank
you
very
much
for
coming
in
10
today.
11
MR.
ZEIGLER:
My
pleasure.
I
know
it's
12
a
long
day
for
you.
I'm
sure
you're
getting
an
13
earful.
Welcome
to
Chicago.
It's
a
great
city.
14
MR.
BURNETT:
Thank
you
very
much.
15
Anyone
else?
16
We
will
suspended
the
hearing
until
17
someone
else
comes
forward
or
until
the
next
18
scheduled
speaker.
Thank
you.
19
(
Whereupon
a
break
was
taken.)
20
21
22
23
24
25
