Testimony to the EPA on proposed change to PM 2.5 soot standards

Testimony of Michael Lewis for the Environmental Protection Agency Public Hearing on the Proposed Change to PM 2.5 Standards

February 23, 2023 

Thank you, for the opportunity to speak before you today. My name is Michael Lewis, I am the Clean Air and Water Advocate for Environment Texas, a non-partisan non-profit organization that advocates for clean air, clean water, clean energy, wildlife, open spaces and a livable climate. 

While The Environmental Protection Agency’s (EPA) proposed soot standard is a step in the right direction, it should be strengthened to meet the strongest science-based soot pollution standards. Those are the recommendations of the EPA’s own Clean Air Scientific Advisory Committee report to lower the annual PM2.5 standards from 12 to 8 micrograms per cubic meter, and lower the 24-hour standard from 35 to 25 micrograms. 

The impacts of soot are well documented. Exposure to soot can lead to increased infant mortality, cardiovascular disease, asthma, diabetes, cognitive impairments, and premature death. Even low levels of air pollution exposure, including soot, can lead to increased risks of Covid-19 infection. And as we grapple with rising temperatures which are themselves impacted by soot, heatwaves also exacerbate their impacts, as the risk of death increases up to 21% on days with both extreme heat and air pollution. These effects disproportionately hurt our most vulnerable citizens; children, the elderly, and lower income families.  

You are no doubt aware of the support for the 8 micrograms per cubic meter standard. The American Lung Association’s website states that 63 million Americans experience unhealthy spikes in daily soot pollution, and more than 20 million Americans experience dangerous levels of soot pollution year-round. In November of last year, 167 public health and climate advocates, called for the stronger standard citing soot’s negative health impacts. A 2019 study published in Environment International estimated these tightened standards would save nearly 20,000 lives each year. 

From an environmental justice perspective, the 10 microgram standard leaves many communities behind. Hispanic residents are 25% more likely to die of particulate matter exposure than White residents are. Black residents are 300% more likely. For the Black community, who faces the highest disparity in soot pollution, EPA’s proposal will barely begin to address that disparity. By setting the standard at 8 micrograms, the EPA could reduce the black mortality rate from soot pollution by about 7 times more than it would with a standard at 10 µg/m3. EPA’s own analysis points out, these disparities reduce only if we adopt the more stringent standard.

Limits on soot pollution will also help us fight global warming. An article in the Journal of Geophysical Research found soot is second only to carbon dioxide in terms of impact to climate change. Given the damaging effects of soot in our largest cities, the state of Texas desperately needs to to clean up our air. The state is home to some of the most polluting coal fired power plants in the country, including W.A. Parish, Martin Lake Steam Station, and J.K Spruce Power Plants.  

We urge the EPA to take advantage of this opportunity and take a strong position to protect our health and our climate. Thank you for the opportunity to provide these comments, and I look forward to the EPA’s action to further protect Texans and all of our citizens.