 TESTIMONY OF DR. JOEL BALBIEN

AUGUST 30, 2007 EPA OZONE HEARINGS

  

Hello, my name is Dr. Joel Balbien, and I am speaking today as a Private
Citizen.  Thank you for giving me the opportunity to testify today on
EPA’s proposal to revise the national air quality standard for ozone. 


I am pleased that the Environmental Protection Agency is taking a step
toward cleaner air by proposing to strengthen the ozone air quality
standard.  According to the American Lung Association, the Los
Angeles-Long Beach-Riverside Metropolitan area is the most polluted in
the country for both Ozone and Particulates with an at risk population
of nearly 3.8 million people in LA county alone.  While, non-attainment
regions like southern California face great technological and economic
challenges in meeting even the existing and scientifically inadequate
standard, these local efforts will have a greater likelihood of success
if our appliances, transportation and capital equipment imported into
southern California are engineered under tighter national emission
standards.  

Unfortunately, even EPA’s proposal falls short of the ozone standard
its own scientific advisors said is necessary to protect public health. 
Furthermore, its proposal leaves open the possibility of not
strengthening the ozone standards at all, which may in turn leave many
non-attainment regions of the country, like southern California 
vulnerable to a plateau in air quality improvements.      

Ozone is a powerful pollutant that can burn our lungs and airways,
causing health effects ranging from coughing and wheezing to asthma
attacks and even premature death. Children, teenagers, senior citizens,
and people with lung disease are particularly vulnerable to the health
effects of ozone.  New clinical studies of otherwise healthy adults have
found decreased lung function, increased respiratory symptoms,
inflammation, and increased susceptibility to respiratory infection at
or below the current standard of 0.08 parts per million.     

The independent Clean Air Scientific Advisory Committee reviewed a 2,000
page summary of the scientific research of the health impacts of ozone
and unanimously concluded that the current ozone standard is not
adequate to protect human health.   As a result, the Committee
recommended setting a new ozone standard in the range of 0.060 to 0.070
parts per million.  

EPA’s proposal to strengthen the standard to within a range of 0.070
to 0.075 parts per million, or even retain the current ozone standard is
weaker than what the agency’s scientific advisors say is necessary to
protect public health.  In effect, EPA’s proposed standards would
protect millions of Americans but would continue to leave millions
more—particularly those with lung disease or who are otherwise
sensitive to air pollution, and in all likelihood, millions of people in
southern California—exposed to the harmful effects of dirty air.  I
agree with the scientific consensus and EPA Administrator Johnson that
the current standard is not good enough to protect public health.  

Every American deserves to breathe clean air.  Those of us that live and
breathe in southern California, recognize that both government and
industry need very challenging macro air quality targets in order to
develop and deploy the regulatory strategies and technologies required
to achieve a significant improvement in air quality in our region, and
thereby protect the population.  EPA should reject industry pressure to
retain the current standard, listen to its own scientific advisors, and
instead adopt an ozone standard of 0.060 parts per million with no
“rounding loophole.”  

It should also be noted that the incremental cost benefit analysis
utilized by air quality regulators, that assumes actual achievement of
the existing ozone and particulate standards nationwide, may
significantly underestimate the real health and other benefits of a
lower ozone standard consistent with the scientific evidence.  In
addition, many of the technological solutions for reducing ozone
precursors, motivated in part by a tougher ozone standard, will also
reduce dangerous diesel particulates, air toxins, unregulated greenhouse
gas emissions, and fuel consumption, thereby multiplying net benefits by
orders of magnitude.     

Our president often talks about the importance of technology,
innovation, and entrepreneurship in solving our environmental and
energy-related problems.  However, it is very unlikely that these new
technologies will be developed and commercially adopted by industry and
consumers unless there are strong economic and regulatory incentives
that internalize the external costs of more inefficient and polluting
systems.  

Imagine what our environmental and energy security situation in our
country would be today if back in 1985, the Congress, with the support
of the Department of Transportation and EPA, had the wisdom and
foresight to set a CAFÉ target of 40 or even 50 miles per gallon, and a
simultaneous ULEV mandate for all light duty vehicles purchased in the
United States by 2005.    If this had occurred, many of us would be
driving vehicles today with aerodynamic bodies made out of light-weight
composite materials, rolling on low resistance tires, powered by smart
internal combustion engines, clean-diesel, and Air or Plug In hybrid
drive trains.  In addition, the U.S. automotive industry, instead of
laying-off workers and losing market share to the Japanese, would be
leading the world in clean and efficient vehicles.   Regulated and
unregulated emissions would have been cut dramatically improving air
quality and lowering Green House Gas emissions.

In a similar manner, the EPA can help clean up our air here in southern
California and throughout the nation and drive the engine of
environmental innovation nationwide by focusing on the science, setting
aggressive macro targets for industry, and promoting market based
solutions where feasible to help industry and government meet the macro
standards at the lowest possible cost.            

Thank you again for this opportunity to speak to you today.

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