Today, Matthew Davis, LCV Legislative Director and former EPA health scientist, gave oral testimony over the phone during the EPA’s hearing on Particulate Matter National Ambient Air Quality Standards (PM NAAQS).

Matthew spoke in opposition to the proposed rule from the EPA to retain the PM NAAQS urging the EPA to strengthen rather than retain the current standards to protect the health of our communities, especially communities of color and low-income communities. The hearings are continuing May 21, May 22, and May 27.

Read Matthew’s full testimony below:

Matthew Davis, LCV Legislative Director: 

Hello and thank you for the opportunity to provide comment in opposition to the proposed rule to not strengthen, or retain, the National Ambient Air Quality Standards for Particulate Matter, or PM NAAQS.

My name is Matthew Davis, and I am Legislative Director of the League of Conservation Voters, or LCV. I am also a former EPA health scientist and worked on the 2012 PM NAAQS. On behalf of the LCV’s more than 2 million members, its Latinx community organizing project, Chispa, and network of 30 state partner organizations across the country, I’d like to state that EPA’s proposal is unacceptable.

This would have been a bad policy decision even before we were facing a pandemic that early research indicates is exacerbated by exactly this kind of air pollution – and now it is simply unthinkable. The science has advanced in the near decade since I worked on the 2012 PM NAAQS, and clearly shows that stronger limits are needed to protect public health with an adequate margin of safety. The EPA must follow the science and statutory requirements, and set stronger PM NAAQS – the PM2.5 annual standard should be lowered to 8 ug/m3 and the 24-hour standard should be lowered to 25 ug/m3. 

In the midst of a pandemic that is exacerbated by air pollution, the last thing the EPA should be doing is making it harder to breathe and maintaining inadequate protection from soot pollution.

Studies show that air pollution exposure is linked to greater risk of respiratory infections. Some early evidence suggests that exposure to air pollution may make people more vulnerable to Covid-19 infection and may increase the severity of the disease or risk of dying if they get sick. To make matters tragically worse, these high pollution areas are far more likely to be in communities of color or low wealth communities. And scientists suspect that the disproportionate number of cases and deaths in communities of color around the country, from Detroit to New Orleans to Prince Georges County are likely in part because of this environmental injustice created and compounded by structural racism and other cumulative impacts. 

The science has shown time and again that particle pollution is deadly, especially fine particles, called PM2.5. These particles come from coal-fired power plants, wildfires, refineries, industrial facilities, wood-burning heaters, and diesel vehicles, among other sources. We also know that the current limits do not sufficiently protect Americans – especially children with developing lungs and brains, and adults with lung and heart disease. EPA’s own scientists and policy experts, some of my former colleagues, have pointed out that over 12,000 fewer people would die each year if the annual PM2.5 standard was strengthened to 9 ug/m3. 

In addition to causing premature death, PM is associated with many other health effects, from asthma and other respiratory problems to strokes and cardiovascular disease to neurodevelopmental problems and dementia to low birth weight and pre-term births. Despite what some in industry or with other financial interests in the outcome of this rule try to claim, science has found no threshold below which there aren’t health effects. The fact is, our bodies don’t respond well to having microscopic particles from the combustion of fossil fuels getting into our lungs and our bloodstream. There’s nothing good about soot at any level. 

This refusal to make the air cleaner with a stronger PM NAAQS comes on the heels of recent announcements that the EPA suspended enforcement, rolled back clean air standards for cars, standards for air pollution for waste coal-fired power plants, and deadlines for requiring cleaner wood-burning heaters. The rollback for waste coal-fired power plants, primarily located in coal country in West Virginia and Pennsylvania, will allow them to emit more pollution, which could lead to increased particulate matter in the area, which already contains counties with soot pollution levels above the current and past standards. And delaying the requirement for cleaner wood-burning heaters will mean that places like Idaho, Northern California, Montana, and Colorado will have a harder time attaining and maintaining the standards. I challenge the administration to legitimately show how the increased pollution from these rollbacks won’t make it harder for these counties to attain or maintain compliance with the already inadequate 2012 PM NAAQS.  

The Trump administration’s disregard for science and scientists’ advice in the middle of a public health crisis is shameful — and especially so given these are favors for polluting industries at great risk to public health. The EPA’s proposed rule fails to meet its core requirement under the Clean Air Act: to protect public health with an adequate margin of safety. Now is the time, especially amid an unprecedented respiratory pandemic, to strengthen these PM standards and safeguard families’ health.