Memo
to
EPA
Docket
From:
Andrew
Beck
Director,
Public
Outreach
Office
of
the
Administrator
Jason
Burnett
Senior
Policy
Advisor
Office
of
Air
and
Radiation
On
July
12,
2006,
a
group
of
environmental/
health
representatives
met
with
EPA
Administrator
Stephen
Johnson
to
share
a
synopsis
of
their
previously
submitted
comments.
This
memo
summarizes
their
concerns.
Medical
societies,
public
health,
and
environmental
organizations'
position
is
that
the
adverse
public
health
impacts
of
fine
and
thoracic
coarse
particle
pollution
are
extraordinarily
severe
and
affect
a
wide
crosssection
of
individuals
and
communities
throughout
the
U.
S.
According
to
these
groups,
the
annual
toll,
in
morbidity,
mortality,
and
cost
to
the
health
care
system
and
to
caregivers,
ranks
this
readily
controllable
pollutant
among
the
most
serious
ambient
environmental
exposures
that
affect
human
health
and
well­
being.

Their
contention
is
that
a
consensus
has
emerged
in
the
medical,
nursing,
scientific
and
public
health
communities
that
the
current
daily
and
annual
average
standards
for
fine
particles
are
not
protective
of
public
health
and
must
be
substantially
strengthened,
and
that
a
new
standard
for
coarse
particles
is
warranted.

These
groups
believe
that
for
both
fine
and
coarse
particulate
matter
the
proposed
standards
are
insufficient
to
protect
public
health
and
welfare
with
an
adequate
margin
of
safety
as
required
by
the
Clean
Air
Act.
According
the
groups,
the
proposed
standards
reflect
serious
flaws:
a
failure
to
include
or
assess
relevant
health
studies;
a
failure
to
include
an
appropriately
precautionary
approach
for
interpreting
and
applying
the
scientific
data;
an
overstatement
of
uncertainty;
and
a
neglect
of
the
advice
of
the
panel
of
scientific
experts
specifically
created
to
advise
the
agency
on
the
setting
of
NAAQS.

These
organizations
allege
that
new
evidence
has
emerged
since
the
2004
CD
that
reinforces
the
need
for
tighter
standards.
Furthermore,
the
consensus
opinion,
including
the
opinion
of
the
Clean
Air
Scientific
Advisory
Committee
supports
a
tighter
annual
standard
in
addition
to
a
tighter
fine
particle
standard.
Finally,
new
evidence
on
coarse
particles
since
the
2004
CD
warrants
tighter
standards
that
apply
nationwide
to
all
types
of
particles.

Therefore,
these
organizations
recommend
the
following
standards:
°
Annual
average
PM
2.5
standard
of
12
µ
g/
m3
°
24­
hour
average
PM
2.5
standard
of
25
µ
g/
m3
(
99th
percentile)
°
24­
hour
average
PM
10­
2.5
standard
of
25­
30
µ
g/
m3
(
99th
percentile),
applied
equally
to
all
areas
of
the
country
and
to
all
types
of
particles.
Materials
were
distributed
and
are
also
included
in
the
docket.

The
below
list
of
stakeholders
were
present
at
the
meeting:

American
Lung
Association­
Paul
Billings,
V.
P.,
National
Policy
and
Advocacy
Janice
Nolan,
Director,
National
Policy
American
Thoracic
Society­
Gary
Ewart,
Director
of
Government
Relations
American
Academy
of
Pediatrics­
Dana
Best,
MD,
MPH,
FAAP
National
Assoc.
for
Medical
Direction
of
Respiratory
Care­
Phil
Porte,
Exec.
Director
Environmental
Defense­
Jana
Milford,
Ph.
D.,
J.
D.,
Senior
Scientist
Clean
Air
Task
Force­
Conrad
G.
Schneider,
Advocacy
Director
New
York
University
School
of
Medicine­
George
D.
Thurston,
Sc.
D.,
Associate
New
York
School
of
Medicine­
William
N.
Rom,
M.
D.,
MPH
American
College
of
Chest
Physicians­
Michael
Galano,
counsel
(
from
Holland
&
Knight)

American
Medical
Association­
Debra
Cohn,
Legislative
Counsel
EPA
officials
present
were:

Administrator
Steve
Johnson
Charles
Ingebretson,
Chief
of
Staff
Jason
Burnett,
Office
of
Air
&
Radiation
Andrew
Beck,
Office
of
Public
Liaison
Chet
Thompson,
Office
of
General
Counsel
Rob
Brenner,
Office
of
Air
&
Radiation
