Walk for Health April 3rd

Walk for health on April 3rd in Denver!

Sign on for Stronger Ozone Standards

While "National Health and Environmental Organizations" are being asked to sign on to the letter below, we see no reason why you, me, and all our friends and family can't print, sign, and send our very own copy and send it to the Environmental Protection Agency as well. So, go ahead, cut and paste the letter below into your processor, print it, sign it (on behalf of yourself and your family, preferably), and send it to Stephen Johnson (his address is below).

We may not be "National Health and Environmental Organizations," but our clean air concerns carry just as much weight as theirs.

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Sign-On Letter for National Health and Environmental Organizations (or any individual or group that cares about clean air)


April __, 2007



The Honorable Stephen L. Johnson
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, DC 20460

Re: Science Review Compels Stricter NAAQS for Ozone

Dear Administrator Johnson:

The undersigned organizations urge you to propose revised, more protective National Ambient Air Quality Standards (NAAQS) for ozone air pollution. Revised standards must reflect the growing evidence of the harm to public health at and below the level of the 1997 ozone air quality standards.

Our organizations concur with the fundamental findings and recommendations of the Clean Air Scientific Advisory Council (CASAC) ozone panel, as expressed in an October 24, 2006 letter to the U.S. Environmental Protection Agency and reaffirmed in a March 26, 2007 letter to you.

The Current Standard Fails to Protect Public Health

The National Ambient Air Quality Standards (NAAQS) are precautionary standards that must protect public health with an adequate margin of safety. Standards must be set at levels that will protect children, people with asthma and other lung diseases, seniors, outdoor workers and otherwise healthy “responders” who are especially sensitive to ozone exposure.

There are plentiful examples of the failure of the current standard to provide that protection. Numerous chamber studies of healthy adults have shown that some subjects experience reduced lung function, increased respiratory symptoms, changes in airway responsiveness and inflammation following just 6.6 hour exposures to 0.08 ppm ozone. Since ozone health effects are a function of dose, it follows that an 8-hour standard must be set below the level shown to cause harm over 6.6 hours. Further, the standards must be set at lower levels to protect the health of children and people with serious respiratory disease who are not tested. Moreover, recent controlled human exposure studies show that some healthy adults experience adverse effects at 0.06 ppm or below.

The current standard permits exposures in excess of the level demonstrated to harm healthy adults, children and those with respiratory diseases. Failing to provide even the mandated protection by the Clean Air Act, the current standard cannot possibly provide the margin of safety further required.

We agree with the unanimous CASAC conclusion and that of the final Staff Paper: you cannot justify retention of the current standard based on the health evidence.

The EPA Must Close the Rounding Loophole

The current eight-hour ozone standard of 0.08 ppm is treated in practice as 0.085 ppm. EPA permits states to round off the monitor readings, resulting in millions of Americans exposed to uncontrolled air pollution concentrations between 0.080 and 0.084 ppm. This rounding convention is an artifact from a time when monitors could not report concentrations accurately, and has resulted in a substantial loophole in public health protection.

Advances in monitoring instrumentation have improved the precision with which ozone concentrations can be measured. EPA should specify the standard to the third decimal place, as recommended by CASAC and EPA staff scientists.

Scientific Evidence Supports a Much Lower Eight-Hour Primary Standard

In addition to the evidence from the chamber studies, recent epidemiological studies have reported associations between ozone concentrations below the current standards and respiratory hospital admissions, emergency room visits, particularly for asthma, school absenteeism and respiratory symptoms in infants and children.

Moreover, multi-city studies from the United States and Europe have now demonstrated that day-to-day increases in ozone concentrations during the summer months increase the risk of premature death, even at concentrations well below the current standard.

Animal studies corroborate the findings of the human clinical studies, demonstrating increased airway resistance and inflammation at low levels. Furthermore, toxicological studies demonstrate that repeated injury-repair cycles can cause fibrosis of the lung tissue. Studies in infant primates show that chronic exposure to high ozone concentrations can change the architecture of the airways.

We concur with the expert judgment expressed by the 23-member CASAC ozone panel which unanimously recommended a range of 0.060 ppm to 0.070 ppm for the eight-hour primary ozone standard. We urge you to propose an eight-hour ozone standard at the lower end of this range -- at 0.060 ppm -- to protect against known and anticipated adverse health effects and to provide a margin of safety as required by the Clean Air Act.

The EPA Should Reinstate the One-Hour Primary Standard

Chamber studies of one-to three-hour exposures have shown adverse effects of ozone at concentrations of 0.12 ppm. The one-hour ozone standard should be reinstated to protect
against peak exposures in areas that meet the eight-hour standard but still have relatively high one-hour concentrations.

The current air quality standards for ozone fail to protect public health. This conclusion is scientifically established and unequivocal. EPA must substantially strengthen the ozone standards to meet the requirements of the Clean Air Act. We urge you to propose revised air quality standards for ozone at the lower end of the CASAC recommended ranges.

Thank you for your consideration of these critical issues.

Sincerely,

Denver's Dirty Little Secret Part 2

The city of Denver continues to disappoint those of us who enjoy breathing clean air.

Rocky Mountain Clean Air Action is right now working to secure additional smog reductions in the Denver metro area. Called the Saving Our Health From Smog Plan, it calls for a 53% reduction in smog forming pollution from coal burning power plants. It would require these plants to cut smog forming pollution to the same degree that power plants across this country are already doing.

The Plan would help us all breathe easier in the summertime smog season. That's something worth supporting. Unless you're the city of Denver, apparently.

Rocky Mountain Clean Air Action recently invited the Denver Department of Environmental Health to partner in supporting the Saving Our Health From Smog Plan. Their response:

Denver does not want to invest effort at this time on a proposal that may have to be re-worked if we indeed are out of attainment.

"Attainment" refers to whether or not we're violating health standards for smog. The Department of Environmental Health's response means they won't do anything to protect our health from smog unless we violate these health standards. That seems a bit counterintuitive, doesn't it?

When Rocky Mountain Clean Air Action pressed the issue, the Department of Environmental Health responded, "We have only limited resources to invest in policy and rulemaking."

Since it's the policy and rulemaking that actually get us the clean air we need, the city of Denver's response is a telling sign that priorities in this city are woefully misplaced.

It also exposes the city's unwillingness to work with its citizen partners. Remember, Rocky Mountain Clean Air Action is the one investing most of the resources in the Saving Our Health From Smog Plan. The city of Denver was just asked to tag along.

Is being "green" in Denver just another specious marketing device? The city of Denver's track record of failing to work with citizens to help clear the air certainly leads us to that conclusion.

When it comes to cleaning up air pollution, don't hold your breath waiting for the city of Denver to step up, or even tag along for that matter.

Denver's Dirty Little Secret

It's time for the city of Denver to come clean, admit how filthy the air is here in the city, and help do something about it.

We say this because the mantra of environmental "sustainability," which is voiced over and over by city officials like some droning, mindless chant, is nothing but a bunch of smoke when it comes to the health of our air. We mean that both literally and figuratively.

Get this. While Mayor Hickenlooper's Greenprint Denver plan calls for reducing air pollution emissions, the city of Denver was fined $18,000 last fall for violating clean air laws. The city actually violated laws that keep smog pollution in check. Sadly, this doesn't come as a surprise to us.

The Denver metro area is on the verge of violating health standards for smog. That's right, Denver is a filthy urban city with the smog to prove it. Last summer, health standards for smog were exceeded 66 times. That's 66 times that children were advised to play indoors to protect themselves and who knows how many people went to the hospital for asthma attacks.

Guess who responded by leading the charge for tougher clean air rules? Nope, it wasn't the city of Denver. It was Rocky Mountain Clean Air Action.

Last December, when the state of Colorado proposed a weak rule to ratchet down on emissions of smog forming pollution, it was Rocky Mountain Clean Air Action Director, Jeremy Nichols, who convinced the Air Quality Control Commission to adopt a stronger rule. As the Rocky Mountain News reported:

Nichols' testimony citing failures by some oil and gas operators in the Weld County region to comply with existing emission control requirements was cited by commissioner Thor Nelson, who led the charge to toughen a compromise proposal...

Sure, Rocky Mountain Clean Air Action is the most cutting-edge health advocacy group in the state of Colorado today. Still, we find it a bit ironic that one person with a scrappy, underfunded, overworked health advocacy group got the goods here--not the city of Denver.

Most recently, fine particle pollution health standards were exceeded nine days straight in Denver. Do you remember the foul haze last February? Well, it smelled bad for a reason. And while Rocky Mountain Clean Air Action is working for stronger clean air rules in the wake of this pollution crisis, the city of Denver hasn't done a thing.

Unfortunately, that's not the end of it. Did you know that your risk of getting cancer is 100 times greater than what it should be in Denver because of formaldehyde in the air? According to the Department of Environmental Health, all they've done is "assess" the problem. Sorry, but our lungs can only take so much assessing before they start asking for some clean air.

And while the city of Denver does have a green fleet, that does little good when the number of gasoline burning cars on the streets continues to climb along with the metro population. Do the math, you'll see that summation doesn't bode well when it comes to reducing our cancer risk.

We could go on and on. The bottomline is that the city of Denver can talk all it wants about being "green," but all the green in the world can't hide the brown cloud. And just like the brown cloud, the City of Denver's unwillingness to step up and help keep air pollution in check, or at least to support citizen efforts to make our city healthier, just stinks.

In our eyes, the failure of the city of Denver to step up for our health makes them just as bad as the polluters fouling our skies. And that's not so far from the truth. The city of Denver is, after all, a polluter itself.

So will the city of Denver come clean? Hopefully so, we'd think the last thing Mayor Hickenlooper needs is for his Greenprint Denver plan to be tarnished by the brown cloud. Or worse yet, for his 7,000 trees to die because of air pollution.

In the meantime, perhaps this could all be taken a different way. When it comes to clean air, maybe we just need to rely on Rocky Mountain Clean Air Action, rather than the city of Denver. It sounds crazy, but Denver's track record of sticking up for clean air lately is pretty dismal, while Rocky Mountain Clean Air Action's is...well, a breath of fresh air.

Kerr-McGee in the Hot Seat

Rocky Mountain Clean Air Action and the Natural Resources Defense Council are gearing up to file suit against the Kerr-McGee corporation over its failure to control smog forming pollution from 11 gigantic natural gas compressor engines operating north of Denver.

The engines have been illegally spewing smog forming pollution for nearly two years and release as much pollution as over 115,000 cars.

Cutting Through the Smoke

The state of Colorado has taken important steps to reduce smog forming pollution from oil and gas development in the Denver metro region. Unfortunately, massive sources of smog forming pollution have yet to do anything to protect people from smog--coal burning power plants.

This is going to change.

In practically every other region of the United States dealing with smog pollution, coal burning power plants have had to cut nitrogen oxide emissions to protect people from smog. In Denver, that has yet to happen.

Working with the state, the Environmental Protection Agency, and other public interest groups, Rocky Mountain Clean Air Action is working to change that. Through the Saving Our Health From Smog Plan, coal burning power plants would have to cut smog forming pollution by 53% during the summertime smog season.

The coal burning power plants affected would include Arapahoe in south Denver, Cherokee in north Denver, the Valmont in Boulder, Pawnee in Morgan County, and the Rawhide Energy Station north of Fort Collins.

Denver is on the verge of violating health standards for smog, putting children, seniors, those with asthma, and those who are active outdoors at great risk. We need to cut smog forming pollution from coal burning power plants to make sure our health is fully protected today and years to come.

Changes to Tailpipe Testing

The Colorado Air Pollution Control Division is proposing changes to Denver's tailpipe testing program. The notice is posted online, but the 153 page document is probably the last thing you want to read right now.

Tailpipe testing is one of three ways that air pollution from cars and trucks is kept in check. First off, vehicle manufacturers have to ensure that cars and trucks meet federally established fuel mileage standards and are built with pollution controls installed. Second, oil refiners have to ensure that gasoline and diesel only contain so much sulfur, so much lead, so much oxygen, and so on, so that when they're burned, the pollution is less severe. And third, there's tailpipe testing to pick up the slack, meaning it's supposed to target older, dirtier, or less maintained cars that are spewing the most pollution.

But the state thinks tailpipe testing could be better in Denver. It's now proposing to use remote sensing to "clean-screen" supposedly "clean" vehicles. The screening process would allow vehicles to avoid testing if remote sensing finds them to be "clean."

The goal of the proposed changes are to make tailpipe testing more efficient and cost-effective. These are admirable goals, but really the goal of tailpipe testing is to protect us from air pollution. It causes some concern when the need to reduce air pollution is not driving changes to clean air rules.

At this point, it's hard to tell what the impacts of the proposed changes are going to be to clean air. A rulemaking hearing is set for June of this year. Stay tuned for more information and updates.