Tuesday, June 8, 2010

EJ and Science Letter on EPA authority and co-pollutants

June 8, 2010

The Honorable Nancy Pelosi
U.S. House of Representatives
23 Cannon House Office Building
Washington, DC 20515-0508
Fax: (202) 225-4188

The Honorable Harry Reid
Majority Leader
United States Senate
522 Hart Senate Office Building
Washington, DC 20510-2803
Fax: (202) 224-7327

Dear Speaker Pelosi and Majority Leader Senator Reid,

We are environmental justice advocates, scientists and other academics who have come together in an effort to find common ground on, and address, issues of critical importance to our environment. Although we come from very different communities, one important issue upon which we agree is that the public health aspects of climate change have been insufficiently emphasized in the discussions and policies connected to this global threat. We write this letter to highlight two policy recommendations that could improve the public health of our nation and would be applicable to any climate and energy legislation. Because of our overriding concern with public health impacts, which disproportionately affect low-income communities and communities of color, we believe that: 1) the U.S. Environmental Protection Agency’s (EPA) authority to regulate greenhouse gases (GHGs) should not be overturned or diminished; and 2) climate change policy should address the emissions of greenhouse gas co-pollutants, as well as the emissions of greenhouse gases themselves. Below, we elaborate briefly on these policy recommendations.

On Aril 2, 2007 the U.S. Supreme Court (Mass. v. EPA, 549 U.S. 497, 2007) ruled that the EPA had the authority and obligation to regulate GHGs under the terms of the Clean Air Act of 1970 if the agency found that these emissions posed a danger to the public health and welfare of our nation. Then, on December 7, 2009, the EPA declared (“the Endangerment finding”) that GHGs threaten the public health and welfare of current and future generations.

The EPA based this ruling on findings that climate change has direct and indirect consequences for human health. Heat waves affect health directly and, especially with warmer nights, are projected to take an increasing toll in developed and developing nations (1,2). Climate constrains the range of infectious disease vectors and agents, while weather extremes and changing weather patterns affect the timing, intensity and location of outbreaks (3). With warmer winters, for example, tick-borne Lyme disease is increasing dramatically in the U.S. Northeast (4), and the heavier rainfalls occurring often overwhelm sewage systems and precipitate water-borne disease outbreaks (5). Rising carbon dioxide concentrations, by boosting plant pollen production, compounds the respiratory and cardiac effects of particulates and ozone from fossil fuel combustion, while spring and fall allergy seasons have lengthened with climate change (6). And the flourishing of forest pests leaves dead stands vulnerable to fires that release stored carbon and worsen air quality.

The “Endangerment” finding enabled the EPA to exercise its legal power to regulate emissions of greenhouse gases and thus help stabilize the climate and reduce the ongoing detrimental health effects of climate change. However, there are efforts by several members of Congress, including Senator Murkowski of Alaska, to legislatively strip the EPA of this authority. Moreover, several of the climate and energy bills being considered in the U.S. Congress also remove from the EPA some or all of this authority.

Emissions of greenhouse gases are driving a global threat that could have potentially devastating health consequences for the population of our nation and the rest of the world. For that reason we believe EPA should retain its current authority to regulate greenhouse gas emissions.

The fight against global warming presents us with another significant opportunity to improve the current state of public health in our nation: we can use climate and energy policy to help reduce emissions of other air pollutants in addition to greenhouse gases, such as particulate matter and its precursors. Particulate matter air pollution results in the premature death and illness of tens of thousands of U.S. residents annually, especially in urban areas where concentrations tend to be highest. Exposure to particulate matter is linked with all causes of premature mortality, cardiovascular and cardiopulmonary mortality, and respiratory illnesses, hospitalizations, reduced lung function and school absences. Fine and large particles, nitrogen oxides and sulfur dioxide emitted by U.S. power plants alone, which are typically coal-fired, kill as many as 24,000 people each year in the U.S., including 2,800 from lung cancer. These power plant emissions are also responsible for 38,200 non-fatal heart attacks and tens of thousands of emergency room visits, hospitalizations and lost work days (7-14). Emissions from transport fuels add to the burden. By using climate change policy in combination with existing reduction strategies we will be able to drive down concentrations of these deadly particulates to levels we have not yet been able to achieve. Greenhouse gases and other air pollutants are often emitted by the same sources; thus attempting to reduce emissions of both simultaneously is a logical step.

Furthermore, recent scientific calculations (15) indicate that particulates from combustion of diesel, biomass and coal are themselves heat-trapping and, when they settle in ice and snow, accelerate their melting and the heat absorbing properties of the earth. This may be playing a significant role in warming of the Arctic and melting of Andean and Himalayan glaciers. It thus makes sense that climate change and energy policy be constructed so that it yields maximum reductions of greenhouse gas emissions and emissions of other more traditional air pollutants, including particulate matter.

While some of the signers of this letter take issue with other aspects of passed and proposed national climate change legislation, addressing the issues of EPA authority and emissions of co-pollutants would significantly improve the proposed climate and energy legislation and further its implementation in the coming years. It would also save lives.

Sincerely yours,


Institutions listed for identification purposes only

Melissa Ahern, Ph.D.
Associate Professor, Department of Pharmacotherapy
Washington State University
Spokane, Washington

Martha Arguello
Executive Director, Physicians for Social Responsibility - Los Angeles
Member, Environmental Justice Leadership Forum on Climate Change
Los Angeles, California

Jose Bravo
Executive Director, Just Transition Alliance
Member, Environmental Justice Leadership Forum on Climate Change
San Diego, California

Robert Bullard, Ph.D.
Ware Professor of Sociology
Director, Environmental Justice Resource Center
Clark-Atlanta University
Member, Environmental Justice Leadership Forum on Climate Change
Atlanta, Georgia

Cecil Corbin-Mark
Deputy Director, WEACT for Environmental Justice
Coordinator, Environmental Justice Leadership Forum on Climate Change
New York, New York

Paul R. Epstein, M.D., M.P.H.
Associate Director, Center for Health and the Global Environment
Harvard Medical School
Boston, Massachusetts

Bill Gallegos
Executive Director, Communities for a Better Environment
Member, Environmental Justice Leadership Forum on Climate Change
Huntington Park, California

Shalini Gupta, M.S.
Fellow in Residence
Center for Earth, Energy and Democracy at the Institute for Agriculture and Trade Policy
Member, Environmental Justice Leadership Forum on Climate Change
Minneapolis, Minnesota

Jamie Hoyte, Esq.
Fellow, Du Bois Institute for African and African-American Research
Harvard University
Former Massachusetts Secretary of Environmental Affairs
Lexington, Massachusetts

Cecilia Martinez, Ph.D.
Center for Earth, Energy and Democracy at the Institute for Agriculture and Trade Policy
Member, Environmental Justice Leadership Forum on Climate Change
Minneapolis, Minnesota

James J. McCarthy, Ph.D.

Alexander Agassiz Professor of Biological Oceanography

Department of Organismic and Evolutionary Biology

Harvard University

Cambridge, Massachusetts

Joseph Montoya, Ph.D.

Professor of Biology, School of Biology

Georgia Institute of Technology

Atlanta, Georgia

Michele Roberts

Advocates for Environmental Human Rights

Member, Environmental Justice Leadership Forum on Climate Change

Washington, DC

Nicky Sheats, Esq., Ph.D.

Director, Center for the Urban Environment

John S. Watson Institute for Public Policy of Thomas Edison State College

Member, New Jersey Environmental Justice Alliance and

Environmental Justice Leadership Forum on Climate Change

Trenton, New Jersey

Peggy Shepard

Executive Director, WEACT for Environmental Justice

Member, Environmental Justice Leadership Forum on Climate Change

New York, New York

Kim Wasserman

Coordinator, Little Village Environmental Justice Organization

Member, Environmental Justice Leadership Forum on Climate Change

Chicago, Illinois

Sacoby Wilson, M.S., Ph.D.

Assistant Research Professor

University of South Carolina

Department of Epidemiology and Biostatistics

Institute for Families in Society

Columbia, South Carolina

Beverly Wright, Ph.D.

Director, Deep South Center for Environmental Justice

Dillard University

Member, Environmental Justice Leadership Forum on Climate Change

New Orleans, Louisiana


1. Meehl, G.A., Tebaldi, C. More intense, more frequent, and longer lasting heat waves in the 21st Century. Science 305:994 (2004).

2. Kalkstein, L.S., Greene, J.S., Mills, D.M., Perrin, A. Samenow, J. Cohen, J.-C. Analog European heat waves for U.S. cities to analyze impacts on heat-related mortality. Bulletin of the American Meteorological Society 2008:89:75-86.

3. Epstein, P. The ecology of climate change and infectious diseases: Comment. Ecology 91:925-928 (2010).

4. Maine Dept of Health and Human Services: http://chge.med.harvard.edu/programs/policy/factsheets/maine.pdf

5. Rose, J.B., Epstein, P.R., Lipp, E.K., Sherman, B.H., Bernard, S.M., Patz, J.A. Climate variability and change in the United States: Potential impacts on water and foodborne diseases caused by microbiologic agents. Environmental Health Perspectives 109(suppl 2):211-221 (2001).

6. Ziska, L.H., Epstein, P.R., Schlesinger, W.H. Rising CO2, climate change, and public health: Exploring the links to Plant Biology. Environmental Health Perspectives. 117(2):155-158 (2009).

7. See New Jersey Department of Environmental Protection. State Implementation Plan (SIP) for the Attainment and Maintenance of the Fine Particulate Matter (PM2.5) National Ambient Air Quality Standard, PM2.5 Attainment Demonstration Proposal (2008).

8. See California Environmental Protection Agency, Air Resources Board. Methodology for Estimating Premature Deaths Associated with Long-term Exposures to Fine Airborne Particulate Matter in California, Draft Staff Report (2009).

9. Health Effects Institute: http://www.healtheffects.org/

10. Pope, C.A., Dockery, D.W. Critical review: Health effects of fine particulate air pollution: Lines that connect. Journal of the Air & Waste Management Association 56(6):709-742 (2006).

11. Levy, J., Hammitt, J., Spengler, J. Estimating the mortality impacts of particulate matter: What can be learned from between-study variability? Environmental Health Perspectives 108(2):109-117 (2000).

12. Levy, J. Spengler, J. Modeling the benefits of power plant emission controls in Massachusetts. Journal of the Air & Waste Management Association 52(1):5-18 (2002).

13. Ritz, B., Wilhelm, M., Zhao, Y. Air pollution and infant death in southern California, 1989-2000. Pediatrics 118(2):493-502 (2006).

14. Schwartz, J., Coull, B., Laden, F., Ryan, L. The effect of dose and timing of dose on the association between airborne particles and survival. Environmental Health Perspectives 116(1) (2007): http://ehp03.niehs.nih.gov/article/fetchArticle.action?articleURI=info%3Adoi%2F10.1289%2Fehp.9955#abstract0

15. Ramanathan, V., Carmichael, G. Global and regional climate changes due to black carbon. Nature Geoscience 1:221-227 (2008).

1 comment:

  1. File this under science and common sense
    The party of NO, however, will not entertain such forward thinking concepts and solutions

    If this was 30 years ago, and somehow the country could have elected educated, thoughtful, and enlightened representatives, then we might have a had a chance to have developed systems to combat this issue and we also may have been of the forefront of exporting the technology to the third world.

    That was then and this is now. Anyone taking bets that nothing of substance will be done until a major climate tipping point occurs?

    Eat desert first.