Brian Moench: Your job is to tell the EPA to do its job

Agency has fallen behind on its responsibility to set safe standards for air quality in Utah.

(Francisco Kjolseth | The Salt Lake Tribune) A plane flies into the Salt Lake International airport as inversion conditions settle into the valley diminishing the air quality on Wednesday, Feb. 9, 2022.

The World Health Organization (WHO) states, “Air pollution is the greatest environmental threat to health and well-being at the global scale, and all populations are affected.” Someone should inform the U.S. Environmental Protection Agency (EPA). And that someone is you, The Salt Lake Tribune reader.

EPA is poised to revise national ambient air quality standards (NAAQS) that will have more of an impact on Wasatch Front air quality than just about any other hot button issue. More than the mysterious inland port, more than shutting down US Magnesium, more than incentives for electric vehicles, perhaps as much as looming toxic dust storms from a disappearing Great Salt Lake.

The Clean Air Act mandates that EPA update NAAQS every five years for “criteria” pollutants-- PM2.5, ozone, NOx, SO2, carbon monoxide, and lead. Despite the mandate, under both Republican and Democratic Administrations, EPA has repeatedly stalled updates, setting standards that were too weak. The annual standard for nitrogen oxides (NOx) has not been updated since its inception in 1971. The two PM2.5 standards, for 24 hr. (the one the Wasatch Front violates) and annual average, have not been updated since 2006 and 2012 respectively.

It is routine that the relevant major medical organizations call for stricter standards than EPA ultimately adopts, despite all of us having access to the same science. This year is no different. EPA’s default modus operandi is a capitulation to polluting industry stonewalling, Congressional bullying, White House politicking, or a combination of all three.

After refusing to update any standards during Trump’s Administration, EPA under Biden is showing renewed interest in doing its job, but as with previous proposals they are not going far enough. EPA proposes lowering the annual PM2.5 standard from the current 12 ug/m3 to “9-10″ (that really means 10). Every medical organization is calling for 8 ug/m3. Inexplicably, they are also proposing to leave the 24 hr standard unchanged at 35 ug/m3. That would leave the Wasatch Front without any benefit at all.

Utah Physicians for a Healthy Environment (UPHE) is submitting detailed comments to EPA making the scientific case for setting the PM2.5 standards no higher than 8 and 20 ug/m3. But this is not really a battle of disputed science, it’s a battle of politics, and Utah citizens need to show EPA their proposal is as much a political mistake as it is a scientific one.

If you care about how air pollution harms your health, now is your chance to do something about it. Send your personal comments to EPA about their proposal. By e-mail to: a-and-r-Docket@epa.gov. Include the Docket ID No. EPA–HQ– OAR–2015–0072 in the subject line of the message. Or go to: https://www.regulations.gov/ and follow the instructions. Below are some talking points.

1. Every major medical organization in the country is calling for stricter standards than what EPA is proposing. Why is EPA

dismissing their advice?

2. EPA’s methodology for reviewing the medical literature and drawing conclusions from it is extreme, it can only be explained by a default industry bias.

3. EPA approaches their job as engineers, demanding an unrealistic level of proof before taking aggressive action. Medical care is not engineering. Physicians have to analyze diagnostic and treatment options when perfect knowledge is seldom available. Medical decisions have to made on the best available knowledge and risks/benefits have to be weighed. The best available knowledge and a risks/benefits analysis both compel stricter standards than what EPA is offering.

4. EPA is legally prohibited from considering the cost to industry of implementing standards, and is required to go sufficiently stricter than research indicates to ensure those standards provide an “adequate margin of safety.”

5. The science is clear: not only is there no safe level of exposure, but the relationship between exposure and disease is even stronger at lower doses, and as WHO says, everyone is affected. That alone compels the strictest standard that can be achieved.

6. If you or your family have experienced heart or lung disease, strokes, neurodegenerative disorders, cancer, pregnancy complications, birth defects, kidney or metabolic diseases, mention that in your comments, and mention that the medical research strongly indicates your family’s adverse health outcome is statistically more likely because of the air pollution that EPA allows.

The comment deadline is March 28.

Dr. Brian Moench | president, Utah Physicians for a Healthy Environment

Brian Moench, M.D., Salt Lake City, is president of Utah Physicians for a Healthy Environment.