"
Grahame,
Thomas"
<
Thomas.
Grahame@
HQ.
DOE.
GOV>

07/
06/
2006
01:
36
PM
T
o
"
Flynn,
Amy
E."
<
Amy_
E._
Flynn@
omb.
eop.
gov>,
"
Fraas,
Arthur
G."
<
Arthur_
G._
Fraas@
omb.
eop.
gov>,
Jason
Burnett/
DC/
USEPA/
US@
EPA,
"
Fredriksen,
Kathy"
<
Kathy.
Fredriksen@
hq.
doe.
gov>
c
c
"
Difiglio,
Carmen"
<
Carmen.
Difiglio@
hq.
doe.
gov>
S
u
b
j
e
c
t
summary
of
DOE
views
on
draft
PA
and
briefing
material
Everyone,
the
attached
document
contains
the
analysis
behind
the
summary
statements
provided
below
for
this
afternoon's
3
PM
conference
call.

We
would
make
the
following
summary
points.

1.
Fine
PM
is
not
an
appropriate
measure
of
pollution
for
protecting
the
public
health.
Some
constituents
appear
not
to
be
harmful,
while
new
studies
with
new
methodologies
show
increasing
large
health
effects
associated
with
one
major
source
of
pollution,
vehicles.
These
emissions
include
both
particles
and
gases,
but
all
are
health­
relevant.

2.
Newer
studies,
those
using
newer
methodologies,
almost
all
published
since
the
April
2002
"
cutoff
date,"
show
that
vehicular
emissions
generally,
and
residual
oil
emissions
in
certain
localities,
are
the
important
health
threats
from
ambient
air
pollution
in
the
U.
S.
today.
Secondary
sulfate
and
secondary
organic
aerosols
appear
to
cause
little
to
no
harm
in
virtually
all
of
these
new
studies,
including
for
the
following
health
endpoints:

 
Daily
mortality
 
Daily
morbidity
 
Heart
rate
variability
(
reduction)

 
ST­
segment
depression
 
Respiratory
symptoms
in
children
with
asthma
 
Vasoconstriction
 
Increased
blood
pressure
 
Mutagenicity
 
Long
term
mortality
via
inflammatory
pathway
 
Various
cytotoxicity
effects
in
vivo
 
Various
inflammatory
effects
in
vivo
3.
The
Lipfert
et
al
(
2006)
studies
are
two
such
studies.
These
studies
show
that
when
a
variable
for
traffic
density
is
included
in
a
multi­
city
study
of
health
effects
from
air
pollution,
the
traffic
density
variable
drives
all
measures
of
air
pollution
to
insignificance
in
multi­
pollutant
models
(
except
occasionally
peak
ozone).

This
finding
suggests
that
traffic
density
is
a
better
surrogate
for
exposure
to
the
types
of
vehicular
pollution
that
decline
rapidly
within
100
to
200
meters
of
major
roads,
which
are
rarely
monitored,
and
which
are
different
from
the
types
of
pollution
typically
used
in
epidemiological
studies
of
air
pollution
 
e.
g.,
pollutants
such
as
PM2.5.

This
finding
suggests
that
other
multi­
city
studies,
old
or
new,
which
use
the
older
methodology
of
central
monitor
pollution
concentrations
as
a
measure
of
exposure,
all
may
be
missing
the
most
important
measure
of
exposure
to
harmful
pollutants,
vehicle
density.
These
studies
would
include
the
Six
Cities
studies,
the
ACS
studies,
the
NMMAPS
and
related
studies,
and
the
Seventh
Day
Adventists
(
AHSMOG)
studies.
We
suggest
in
the
attachment
and
in
earlier
DOE
comments,
based
on
internal
evidence
or
reanalyses
of
several
of
these
studies,
that
indeed
there
is
evidence
that
traffic
emissions
are
the
main
cause
of
mortality
or
other
adverse
health
effects.

4.
The
main
finding
of
the
two
Lipfert
et
al
(
2006)
studies
is
that
no
other
measure
of
pollution
other
than
traffic
density
(
except
occasionally
peak
ozone)
is
significantly
related
to
long
term
mortality
in
many
robust
multi­
pollutant
models.
For
this
reason,
it
is
very
misleading
for
EPA
to
use
the
one
result,
in
only
one
of
the
studies,
showing
a
positive
significant
association
between
long
term
mortality
and
fine
PM
in
a
non­
robust,
single
pollutant,
and
report
this
one
finding
in
the
draft
PA
and
the
briefing
materials
as
if
it
is
a
conclusion
of
the
study,
rather
than
part
of
the
usual
preliminary
assessment,
in
studies
using
multi­
pollutant
modeling.

It
is
all
the
more
misleading
when
one
realizes
that
there
are
a
total
of
eight
other
fine
PM
associations
in
the
two
studies
which
are
not
significant.
A
more
comprehensive
and
balanced
assessment
of
the
Lipfert
findings
regarding
fine
PM
is
that
it
is
almost
never
significant,
with
the
one
significant
finding
coming
in
a
non­
robust
single
pollutant
model.
In
addition,
because
it
is
important
for
understanding
which
pollutants
are
harmful
and
which
are
not,
the
draft
Provisional
Assessment
(
PA)
and
briefing
materials
for
the
conference
call
should
state
that
sulfate
is
never
found
significant,
even
in
single
pollutant
models.

5.
Two
other
new
studies
make
the
points
that
centrally
monitored
pollutants
don't
pick
up
the
pollutants
of
relevance
to
health:

Delfino
et
al
(
2005):

"
The
main
limitation
of
most
epidemiological
studies
is
exposure
misclassification
from
dependence
on
central
site
rather
than
on
personal
or
microenvironmental
exposure
data"

Sioutas
et
al
(
2005)
point
to
the
differences
in
types
of
pollutants
near
major
roads,
vs.
pollutants
measured
further
away:

"...
people
who
live
within
about
90
meters
of
roadways
are
exposed
to
particles
of
very
different
size
and
chemical
composition
than
are
others
who
live
farther
away
from
busy
streets
and
roadways."

6.
Several
studies
of
health
effects
in
the
draft
PA
and
the
briefing
materials
occur
in
California.
California
doesn't
have
major
sources
of
fine
PM
found
in
the
east,
such
as
coal
plants
and
steel
complexes,
but
instead
is
dominated
by
vehicular
emissions
(
with
residual
oil
emissions
from
shipping
as
well
in
some
localities).
EPA
should
recognize
that
pollution
in
California
is
dominated
by
vehicular
emissions,
and
state
that
findings
from
studies
such
as
Kuenzli
et
al
(
2005)
and
the
Jerrett
et
al
(
2005)
study
of
the
Los
Angeles
ACS
cohort
are
studies
of
vehicular
emissions.
One
of
the
studies
reviewed
by
EPA,
Gauderman
et
al
(
2004),
the
12
city
Children's
Health
Study,
does
make
this
conclusion:

"
In
southern
California,
the
primary
source
of
these
pollutants
is
motor
vehicles,
either
through
direct
tailpipe
emissions
or
downwind
physical
and
photochemical
reactions
of
vehicular
emissions...

"
In
the
current
study,
however,
we
could
not
discern
the
independent
effects
of
pollutants
because
they
came
from
common
sources
and
there
was
a
high
degree
of
correlation
among
them."

Failure
to
note
that
associations
found
with
fine
PM
in
California
reflect
health
effects
associated
with
vehicular
emissions
may
lead
people
to
think
that
all
components
of
fine
PM,
including
those
found
in
abundance
in
the
east
but
missing
in
California,
are
associated
with
adverse
health
effects,
and
may
lead
them
away
from
the
important
conclusion
that
vehicular
emissions
are
the
main
cause
of
harm
from
ambient
pollution
in
the
U.
S.

7.
The
draft
PA
and
briefing
materials
should
be
completely
refocused
to
reflect
these
new
findings.

Thanks,

Tom
Thomas
J.
Grahame
U.
S.
Department
of
Energy
1000
Independence
Ave.,
SW
Washington,
DC
20585
202
586
7149
(
voice)

202
586
7085
(
fax)

<<
SHORT
VERSION.
doc>>
