THE PROPOSED STANDARD
AND HOW IT MAY AFFECT NEW JERSEY
The 1997 New Jersey Clean Air Council (Council) Public Hearing
sought information on issues relating to the November 27, 1996
U.S. Environmental Protection Agency (EPA) proposed new health
standard for fine particulate matter (PM). The proposed new
standard addresses fine particulate matter of 2.5 micrograms
or less (PM 2.5). The current health standard includes coarse
particles of 10 micrograms or less.
The hearing included testimony on the sources of fine particulates
in New Jersey, the role of long-range transport and the health
benefits attributed to the new standard. The forum also explored
the fact that research data is inconclusive as to the chemical
characterization and source apportionment of PM 2.5.
The Federal Clean Air Act directs the EPA to identify and
set standards for pollutants which impact public health and
the environment. EPA is required to review the health standard
at least once every five years. In November 1996, after receiving
the recommendations of the Clean Air Scientific Advisory Council
(CASAC), the EPA concluded that the PM 10 standard was not fully
protective of public health. (See Appendix A) The EPA cited
increased premature deaths, aggravation of respiration and cardiovascular
illnesses, lung function effects, changes to lung structure
and defense mechanisms. Other effects include decreased visibility,
soiling and materials change.
There are significant differences between PM 10 and PM 2.5.
These particulates are generated by different mechanisms, have
distinctly different compositions and are deposited differently.
Coarse particles are generated by mechanical mechanisms, they
have a short atmospheric lifetime and are often largely composed
of soil and dust.
Knowledge of the makeup of fine particles in the air is incomplete.
One source is diesel emissions and another source is soil and
dust. It is also known that a significant part of fine particulates
comes from secondary aerosol, particles that are not directly
emitted to the air but form from emissions of gaseous pollutants,
such as sulfur dioxide (SOx) and nitrogen oxides (NOx). These
particles take time to form and can be transported long distances,
hundreds of miles or more. Emissions from coal power plants
are major sources of SOx and NOx pollution. Some control of
SOx pollution will be accomplished by the programs already adopted
to stem acid rain. The effort to reduce ground level ozone will
reduce emissions of NOx thereby cutting the level of nitrate
particles. However, cooperation among the states in controlling
these emissions will be necessary.
In addition to the complex make-up of fine particles, there
are large uncertainties as to the appropriate level of a PM
2.5 standard. The proposed standard is the level required to
reduce premature deaths by 50 % according to epidemiological
data, but the uncertainties in this number are large. Toxicological
studies have been unable to identify a plausible biological
mechanism to explain the epidemiological findings, there is
little evidence of threshold, no understanding regarding the
degree of life shortening, and the susceptible population is
Control of PM 2.5 will require regional planning and control
of gas-phase precursors. For these reasons, chemical characterization
and source apportionment activities will be important to the
development of an effective air quality management plan.
* The Council strongly supports New Jersey's promulgated
rules requiring the inspection and maintenance of heavy duty
diesel powered vehicles. This program should begin now and should
be incorporated into the State Implementation Plan (SIP). (Proposed
Amendments: N.J.A.C. 7:27-14 and 7:27B-4)
* The Council continues to support full implementation
of the enhanced I/M (inspection and maintenance) program for
automobiles. (N.J.A.C. 7:27-15)
* The Council recommends future regional fine
particulate mapping for incorporation into the current television
ozone mapping program. The council believes that fine particulate
matter reporting is an important part of public education.
* Studies have shown that a significant
part of total particulate matter is formed from the emissions
of gaseous pollutants, such as sulfur dioxide and nitrogen oxides.
Such particulate matter takes time to form, and can thus be
transported long distances in the atmosphere. It is therefore
necessary to work with other states, both neighboring and more
remote, to address the transport problem.
* The Council applauds the Ozone Transport Assessment
Group (OTAG), for its activities in developing consensus for
the control of emissions from coal-fired power plants. The Council
proposes that a similar regional interstate group be formed
to plan for regional control of fine particulate matter. The
Council recognizes the importance of implementation and enforcement
of regional strategies for control of interstate transport of
fine particulates and of NOx.
* The Council recommends ongoing research into
the health effects of fine particulate matter emissions.
* The Council advocates continued research into
the chemical characterization and source apportionment of PM
2.5. Such research is essential to the development of an effective
air quality management plan.
* Prior to implementation of a SIP for fine
particulates, the Council recommends careful social and economic
research into the impact on residents and businesses in New
* The Council recommends the development of
a reliable standard reference monitoring method needed to determine
compliance. Regional monitoring of fine particulate matter through
appropriate siting of the monitoring stations and proper equipment
installation should proceed based on a standard reference method.
* The Council continues to support the establishment
of a comprehensive statewide public education program aimed
at increasing the public's understanding of air pollution and
the action needed to correct the problem. This program needs
to include information on the sources of particulates and the
public's role in curbing them.
* The Council recommends that as an important
part of public education there be increased emphasis on educating
school children on environmental matters, especially the sources
of particulate matter in air pollution.
* The Council realizes that indoor air quality
is not specifically part of the National Ambient Air Quality
Standards ( NAAQS). Nevertheless, the Council would like to
understand the relative roles of an individual's exposure to
outdoor and to indoor levels of PM and the Council recommends
research into the significance of these levels in respect to
SUMMARIES OF TESTIMONY
LEWIS NAGY - POLICY AND PLANNING, ASSISTANT COMMISSIONER,
The standard that EPA is proposing for fine particulates is
based on health studies which link an increased incidence of
both respiratory problems and mortality rates to elevated levels
of fine particulates in the air. Proponents believe that because
of the severity of the health
effects, we need to act now to control the problem. Opponents
find the evidence insufficient and inconclusive. They believe
adopting new standards is too costly. Attaining the new standard
in New Jersey could mean improved quality of life for the State,
but it could also put some industries at a severe economic disadvantage
by costing millions.
New Jersey meets the current air quality standards for particulates
(PM 10), but probably will not meet the new standard (PM 2.5).
The State will have to develop a plan to meet the
standard. We know that a significant part of the total amount
of fine particulates in New Jersey comes from secondary aerosols,
particulates that are not directly emitted, but are formed from
gaseous emissions, such as SOx and NOx. Diesel emissions are
another source and that will be addressed by the inspection
and maintenance of heavy duty diesel powered vehicles will begin
next year. The proposed standard for fine particulates will
pose many challenges for New Jersey.
RAYMOND WERNER - EPA REGION 2
EPA is due to make a decision on the particulate standard
on July 19, 1997. We have already received over 17,000 comments
on this new standard.
The Clean Air Act requires the administrator to establish
national ambient air quality standards in order to protect the
public health and to prevent damage to crops, materials and
visibility. We have these standards for six pollutants right
now: carbon monoxide, PM 10, ozone, lead, NOx and SOx. We are
required to revisit these standards every five years. We last
evaluated PM 10 in 1987. EPA focused on PM 10 in the 1980s because
it was known that those particles had the ability to penetrate
In setting the standard, cost is not a factor. But, the best
scientific data should be considered and EPA does not collect
this data. Universities and medical institutions do that. EPA
looks at the data published in medical journals and the like
and from this body of information, EPA develops a criteria document.
Congress set up the Clean Air Scientific Advisory Council
(CASAC). It is made up of experts from industry, academia, government
and the medical sector. EPA's criteria document is reviewed
officially by this body. They decide whether or not EPA has
an adequate data base for setting the standard. Then, EPA proposes
the standard and receives public comment on the new standard.
For particulate matter the EPA identified about 80 key epidemiological
studies. Sixty of those studies found a link between particulate
matter levels and health problems. 19 of the 21 CASAC members
recommended revising the standard to PM 2.5.
There is a difference between the size of the particle and
concentration. The concentration standard for PM 10 is fifty
micrograms, the standard for PM 2.5 is 15 micrograms on an annual
basis. In calculating PM 2.5 spatial averaging also would be
There is a certain amount of scientific uncertainty involved
with the new standard. There are also many details to work out.
Decisions need to be made concerning areas of attainment and
non-attainment, determination of upwind and downwind states'
contribution to particulates and time limits on compliance plans.
If a new standard is adopted, monitoring techniques and a
monitoring plan must also be developed. The placement of monitors,
the core areas for monitoring, frequency of monitoring all needs
to be worked out. The first monitor will not be in the field
until January 1998.
Collection will take place over a three year period. The attainment
date will be five years from the designation of the standard.
State Implementation Plans (SIPs), clean air plans will be due
in the year 2002. There will also be two one-year extensions
so that it could be 12 years or more before the standard is
enforced. The time frame for meeting these standards goes well
into the next century.
No full cost benefit analysis has been done, but it is estimated
that there will be a net
benefit of fifty billion to over a hundred billion dollars
in savings when the new standard is implemented. There will
be tens of thousands of fewer deaths per year, sixty thousand
cases of chronic bronchitis. Visibility will improve through
the removal of the regional haze effect.
GEORGE WOLFE -General Motors Corporation, Scientist
and Former Chairman CASAC
I was chairman of CASAC during the time when the reviews
for the PM and ozone standard were being reviewed. For the PM
review CASAC was made up of 21 scientific experts on air pollution.
PM 2.5 is a separate pollutant because it comes from different
sources. It comes from combustion and secondary reactions. It
also comes from wind-blown dust, grinding sanding and the buffalo
effect. There are many health effect studies, but the process
was driven by the epidemiology studies that linked mortality
Although there was concern about setting the PM 2.5 standard,
there was absolutely no consensus on the level of the standard.
Five members supported a fifty microgram per cubic meter standard
for 24 hours, four members supported greater than or equal to
sixty-five to seventy-five micrograms and four members did not
support a 24 hour standard at all. Eight members said yes to
the concept, but did not endorse a range. For the annual standard,
two members supported 15 micrograms, two members 20 micrograms
and two members recommended 25-30 micrograms. Eight members
said no to the annual standard and six said yes in concept but
did not endorse a value.
The question must be asked, "Why this diversity of opinion?"
One of the reasons was that the Court-ordered review did not
allow enough time for these complex issues to be discussed and
the second reason was that there are unanswered questions and
uncertainties concerning PM 2.5. The case for PM 2.5 is not
established. The studies are not conclusive that the health
effects are really caused by PM 2.5. Mark Yetel, a notable chest
physician on the CASAC, claims that there is no biological mechanism
to explain how PM is killing people. We don't know if there
is a threshold and the methods we use can not detect it.
The National Institute for Statistical Sciences in North Carolina
has done two re-analyses so far and they conclude that the studies
are statistical artifacts. Causality has not been established.
There is no consensus on the level or range of interaction.
At this point a standard cannot be chosen based on the underlying
I favor a target research program over the next five years.
I recommend using that research to make a decision.
PAUL LIOY - Environmental and Occupational Health
Sciences Institute (EOSHI) and EPA Science Advisory Board
The epidemiological studies have established that
serious health effects are associated with increases in ambient
particulate matter in urban air sheds. However, although coherence
is strong, this has not been translated to a biological mechanism.
Relatively few studies have found the biologically active agents
in PM 2.5. Right now we are capable of measuring the mass but
not the biologically active fraction. PM 2.5 is a mixture which
increases the uncertainty. If we control NOx and hydrocarbons,
we are controlling some of the precursors for the formation
of particles. There are some things that we are already doing
that will enable us to reduce particulate matter. One of these
is the controls on SOx for acid rain. Another is the fact that
DEP will be looking at truck and bus emissions and this will
reduce the fine particle emissions in New Jersey.
Testing for PM 2.5 is complex. In measuring the PM 2.5 sample
the mass will be considered related to the epidemiology. However,
unlike other pollutants, because it is a complex mixture, you
will not get the truth about what is in the mass. The sampler
may not allow us to develop control strategies.
More research needs to be done on the relationship between
indoor and outdoor PM. The outdoor PM affects indoor levels
because buildings are not hermetically sealed. Indoor levels
are affected by cooking, fireplace burning and tobacco smoking.
There is an absolute quantity that is a person's lung burden
coming from both indoor and outdoor sources. This can be three
or four times higher than the outdoor source alone.
Fine particles move in the air because it takes one to three
days for them to settle. They have very low deposition velocities.
If you emit something high enough, it takes days for the particles
to settle. Fine particles can get caught up on the air screen
and move far away. Studies have show that it could be that 50%
to 70% of the total mass burden of fine particulates in New
Jersey is coming from transport. The rate will be higher or
lower depending on the weather conditions.
Monitoring poses a problem. We don't have a adequate monitoring
network across the country. Monitoring will be complex because
we need to have a two stage sample. We need one sample that
collects non-volatile components and one that collects a semi-volatile
component. Setting the standard for PM 2.5 will be difficult.
I would recommend setting it at 20 to 30 micrograms per cubic
meter for an annual average. I also recommend targeted research.
JOHN ELSTON - Air Quality Management, Administrator,
There is a problem with the PM 2.5 standard in that there is
no "smoking gun" with regard to setting a standard. However,
there is circumstantial evidence. We do know that there is no
threshold for particulate matter and therefore, wherever we
draw the standard there will be a risk for someone. Some say
that we shouldn't have a standard, just some sort of risk analysis.
There are three issues to consider when we think about adopting
a PM 2.5 standard.
1. When a standard is established, a SIP must accompany it.
Without a SIP there is no federally enforceable document. In
order to have effective control program you need to have EPA
law behind that program.
2. Regional transport must be considered. The regional transport
of ozone and acid rain have already been established and there
are some controls in place. In considering particulate matter,
the long range transport is critical. The combustion products
tend to be light particles which are transported hundreds, maybe
thousands of kilometers. Therefore, the regional concept of
transport must be considered.
3. Public health standards must be addressed. Over the years
there has been a weakening of the standards. The ozone standard
has been weakened from .08 to .12. If we do not adopt the PM
2.5 standard and just keep the PM 10 standard, that will be
weakened again because the form of the standard is being changed
to allow more exceedences to occur under the same standard.
This weakening of health standards is not good policy.
Another aspect that needs to be considered is the debate between
epidemiology and toxicology. Toxicology has more definitive
causality, but epidemiological evidence is no less compelling
here and is very important. In epidemiology there is a weight
of evidence of many difference studies, but the monitoring is
not precisely PM 2.5.
There will be Areas of Violation (AOVs) and Areas of Influence
(AOIs). Air quality planning is going through a very radical
changes, less involved in delineating where the pollution is
as in where it originates. An AOI may be anywhere from Virginia
to Maine, but an AOV could be Hudson County, New Jersey. We're
becoming more involved in contributing sources relative to violations.
We're trying to become more stakeholder oriented. We're trying
to involve everyone in the process, including neighboring states.
CHARLES PIETARINEN - Air Quality Monitoring, Chief,
There will be four standards for particulate matter, two for
PM 10 and two for PM 2.5. We anticipate that New Jersey will
continue to be in attainment for PM 10. There will be spatial
averaging, but we don't know exactly how that will work. The
entire state could be in non-attainment or just certain areas.
There will be some averaging of sites and some overall sense
of the attainment areas. Although health studies use this averaging
effect, we have not used it before now.
In calculating the PM 2.5 standard, we took the data from
the PM 10 network and applied a factor of .6 to it to estimate
PM 2.5. This was based on national data published by EPA and
supported by some limited data that we collected in New Jersey.
A significant amount of research has not been done on the
composition of particulate matter in New Jersey. This is because
we have been in attainment for PM 10, so we have not done speciation
of particles to define the problem.
One area we did test between 1992 and 1995 was Brigantine.
This testing shows that the largest particulate component was
sulfate, making up 52% of the particles; organics, 27% of the
particles; nitrates are 11%, elemental carbon is 6% and soil
is a small component. The sulfate, nitrate and organics are
all secondary aerosols. They are not emitted directly, but take
this form in the atmosphere. They take time to form and are
subject to transport so they may not be locally generated. Brigantine
was a very limited data site.
There have already been significant improvements in the amount
of sulfate particles because of the acid rain program. Acid
rain controls focus on sulfur emissions. Because of this, we
don't see the same improvements for nitrate values.
We have over 20 years of data on smoke shade in New Jersey.
Smoke shade is a surrogate for particulate matter. The levels
of smoke shade dropped dramatically throughout the 1970s and
have continued to decline.
In determining PM 2.5 values, spatial averaging will come
into play. For instance, all of the sites in northern New Jersey
and all of the sites in southern New Jersey could be averaged
to get 18 micrograms per cubic meter, which would mean non-attainment.
There could also be spatial averaging over smaller areas with
several sections of the state in attainment and others in non-attainment.
Spatial averaging has been controversial within the monitoring
community, but it is based on the fact that health studies use
this averaging effect. Even with spatial averaging, we estimate
that there will be non-attainment over a significant portion
of the State.
ALBERT MANNATO - American Petroleum Institute, Washington,
We believe the EPA should not establish a PM 2.5 standard because
the scientific basis for PM 2.5 as a causative agent for adverse
health effects has not been established. In its closing letter
the CASAC said, "There are many unanswered questions and uncertainties
associated with the establishment of causality of the association
between PM 2.5 and mortality."
It is important to note that association does not equal causation.
EPA is relying totally on epidemiological studies and the greatest
relative risk within these studies is 1.3. Most of the studies
show a relative role of 1.1 or less. The scientific community
generally considers risks that small as unreliable evidence
of a causal link. In other areas EPA has rejected such a low
The court-ordered deadline also hindered the standard development
process. CASAC's letter supports this. EPA has failed to address
the concerns raised by CASAC. EPA only looked at the vote and
ignored the substance of CASAC's concerns.
There is no justification of PM 2.5 as a causative agent because
almost all of the epidemiological studies did not use PM 2.5.
The criteria document lists 38 studies and 1/3 of those studies
were negative. Further, only two of those studies looked at
PM 2.5. There were actually nine PM 2.5 studies and five of
them were negative. Even Harvard's Sick Cities Study is questionable.
The Pope study that was used to estimate death benefits from
PM 2.5 had incorrect results. The study should have shown 15,000
deaths not 20,000. In cities where there have been multiple
investigations, there were inconsistent results. The data just
I believe that the CASAC voted in favor of the PM 2.5 standard
because without a standard, you cannot collect the monitoring
data that you need. Great progress has been made in New Jersey
regarding NOx and SOx and ozone, but if the new standard is
enacted, based on our estimates, we think that all of the counties
in New Jersey will not be able to meet the new particulate standard.
We believe the EPA grossly underestimated the cost of this
standard and overestimated the benefits. EPA put artificial
cost construction on the analysis of the PM 2.5 standard. Our
contractor, Sierra, estimated that in Chicago it would take
a 90% reduction in emissions to meet the standard and in New
York, a 70% reduction. New Jersey will also be worse off with
these standards. We join others who oppose the new standards
because there is no scientific basis for them. We recommend
keeping PM 10 the way it is because the cost of change is prohibitive.
BARBARA TURPIN - Environmental Sciences, Rutgers University,
I have been involved in the development of the EPA criteria
document, which is the scientific basis for the proposed standard.
I have also been discussing with EPA the research needed for
PM 2.5. I have a background in atmospheric particulate matter,
chemistry and physics.
Economics should not play a role in setting air quality standards.
The health based standards are important. Over 50 studies show
that the current PM 10 standard is not adequate.
Fine and coarse particles differ from one another because
they are generated by different mechanisms. Fine particles are
formed in combustion processes directly emitted as particles
or they are formed in the atmosphere from photochemical reactions
with gas phase precursors, such as SOx and NOx. Like ozone,
these fine particles are transported long distances. They are
able to penetrate into the air exchange regions of the lungs.
In contrast, coarse particles are formed by mechanical processes,
have a shorter life span and are largely composed of soil and
dust. The are removed largely in the upper airways.
The epidemiological studies are largely based on PM 10 because
a data base for PM 2.5 doesn't exist. We think the epidemiological
studies relate to the fine particle portion of PM 10. Most of
PM 10 is coarse particles dominated by soil and dust. Fine particle
PM 2.5 contains much more toxic materials. There are good scientific
reasons to treat fine and coarse particles separately.
There are uncertainties regarding the plausible mechanism
by which PM 2.5 causes these effects. There is also considerable
disagreement on the level of the standard. However, there is
substantial agreement on the role of a fine particulate standard.
A good argument centers on the fact that to reduce fine particles,
which are carried into the lower respiratory regions, you need
a PM 2.5 standard.
I would like to argue for an interim standard. If the current
EPA proposal were implemented control efforts wouldn't begin
until 2004. Before implementation we would need to establish
a monitoring network and we would need three years of data.
We would also need to develop new SIPs. It would be ten years
or so before compliance would be necessary.
There is no reason why we can't be doing these things concurrently
with further mechanistic research. There are some problems with
doing chemical analysis on the current PM 2.5 sampler because
of the collection method used. This chemical analysis is essential
in order to do source apportionment and to develop effective
SIPs. It is important that the federal sampler is suitable for
chemical analysis and for air quality needs. The control of
these gas phase precursors will be essential in devising effective
air quality management plans.
BERNARD GOLDSTEIN - EOSHI, Director
In addition to my current post, I am a former chairman
of the CASAC. I think the PM 2.5 is a better standard. Ozone
and particulate matter are difficult pollutants to source out
because they are formed by a very complex photochemical process
that we have to understand. The PM problem is that we have a
mixture. The biggest deficiency is that the research doesn't
completely understand the causes that are responsible for the
We need better ways to study and research the effects of air
pollution on humans. We have always looked at healthy humans
and healthy animals. We need to look at sick animals and sick
humans. Some of these particles are not toxic to healthy humans.
We don't know exactly what particles, sulfates or organics are
causing the health problems.
If we had this epidemiological data in the mid 1980s, we would
have had a stronger particulate standard rather than an acid
rain program. We noticed the effects of acid rain on the trees,
lakes and fish before we noticed the effects of particulates
formed from SOx and NOx on humans. Now we need to evaluate what
effect PM 2.5 has on human health.
TIM DILLINGHAM - Sierra Club, Director
I am not a toxicologist or an epidemiologist, nor a representative
of industry. I can only give you a sense of what the Sierra
Club membership believes we should do with regard to PM 2.5.
We can get lost in debate about the science of this standard.
We may never reach the point scientifically when we have a bright
line to follow regarding fine particulates. My members are concerned
with the impact of PM 2.5 on people's lives.
Hospital admissions, rates of asthma and respiratory disorders
are on the rise in New Jersey. This should be our main concern,
not the scientific debate. If we keep debating the standard,
we will never move toward implementation. Industry has always
overestimated the cost of environmental regulations, specifically
air strategies. After we set the standards, then we can enter
into a discussion of the cost in a way that does not create
MARIE CURTIS - New Jersey Environmental Lobby, Executive
The New Jersey Environmental Lobby for almost 30 years
has represented local and statewide environmental groups here
in Trenton as a lobbying arm for the environment. We endorse
the new EPA proposal for PM standards.
The epidemiological studies that we heard about today were
done by reputable organizations, such as the Harvard School
of Public Health, American Cancer Society, American Lung Association
and the Natural Resources Defense Council. We have also seen
studies from Canada, Alaska and elsewhere. The evidence is overwhelming
that small particles penetrate deeply into the lungs causing
In 1993 the New England Journal of Medicine studied 8,000
people in six cities over 17 years and found a 26% greater risk
of early death in areas of high fine particulate concentrations.
A 1995 study involving 155,000 people in 51 metropolitan areas
found a risk of premature death to be 17% higher than normal.
Rather than debate the numbers, I submit that one early death
from something we can control in the environment is one death
too many. We cannot put a price tag on life.
It is true that 19 out of 21 members of the CASAC want to
set a standard. The disagreement is on what the standard should
be. The fact that the EPA time line puts compliance off for
several years gives us time to do the needed research. An interim
standard could also be considered.
Because fine particulates are formed secondary to the transformation
of acid gases by atmospheric processes, transport is important.
Also, because New Jersey is a corridor state, emissions from
diesel exhaust is a primary concern. We also still have four
coal burning power plants in New Jersey. Industry is complaining
about the cost, however, in sulfur dioxide reduction we were
told that it would be two to three thousand dollars per ton
for emissions avoided. Currently on the Stock Exchange, the
price is $65.00 per ton. These costs are always exaggerated.
The standard should be PM 2.5 in light of increasing childhood
asthma and increasing cardiopulmonary disease.
BETTY WOLFE - Joint Bureau Township Princeton Environmental
We are citizens not experts in health or air pollution.
However, we are very concerned about the rise in asthma and
respiratory problems in New Jersey. We question if the current
Clean Air Standards are adequate to protect the public health.
The pollution alert days that we only heard about in California
are now here in New Jersey. Tighter standards, more accurate
monitoring, diligent implementation is needed.
We want the federal government to support New Jersey's efforts
to protect public health by setting a more stringent particulate
standard. I regret that the Clean Air Council was not able to
have this hearing within the time frame of the formal public
comment period for EPA so that New Jersey could be on the EPA
REBECCA STANFIELD - New Jersey Public Interest Research
Group (NJPIRG) Citizen Lobby
I would like to add the voice of NJPIRG citizen lobby and it
25,000 New Jersey members to the voices of the Sierra Club and
the Environmental Lobby in supporting the new standard for PM
2.5. Our concern is protecting the public health. Many epidemiological
studies have shown the correlation between PM 2.5 and mortality
and illness. 19 out of 21 members of CASCA agree that a new
standard is necessary. EPA is required to act.
Cost is the only relevant to the implementation stage. Monitoring
stations for PM 2.5 are critical. They need to be developed
and put in place. Finally the non-attainment areas should not
dissuade us from adopting the new standard. All of these problems
will be addressed after we set a new standard.
Anecdotally, as NJPIRG canvases from door to door, we hear
stories of more kids with inhalers in school and children unable
to go outside. NJPIRG strongly supports the proposed standard
for PM 2.5.
JAMES SINCLAIR - New Jersey Business and Industry
In addition to the NJ Business and Industry Trade Association,
I also represent the South Jersey Chamber of Commerce and the
NJ Air Standards Coalition, which includes over 21 associations
and federations representing most of the major employers in
I am an engineer and a student of public policy. I understand
that scientific thinking and rational thinking are not always
the same as political thinking. I've made an effort to assess
the facts regarding the new standard for particulate matter.
The shocking aspect to these discussions is that only one
or two of the studies dealt with PM 2.5 and the results of those
studies were inconclusive. From a scientific point of view that
doesn't make sense. We don't know how to analyze PM 2.5 and
we don't know where it comes from or if it has an impact.
We don't inform people of New Jersey about the improvement
in air quality, we just say that we have the second worst air
in the nation. We also can't tell people that the proposed standard
will solve the asthma problem when we don't know that. The underlying
cause of asthma is unknown. It is highly unlikely that outdoor
air pollution is causing the increase because air pollution
levels have been decreasing.
Governor Whitman supports the new standard because she thinks
it levels the playing field. But, there will be non-attainment
in all of New Jersey's counties if we adopt the new standard.
My organization thinks that we should keep the current standard
and do more research on the effects of PM 2.5.
REVEREND JOSEPH PARRISH, Rector - St. John Episcopal
Church, Elizabeth, NJ
We urge NJDEP to tighten air quality standards. In and around
Elizabeth we have an 800% greater incidence of childhood asthma
that the national average and 1,000 to 5,000 % greater incidence
of childhood asthma deaths than the national average. Although
ozone is decreasing, smoke shade in Elizabeth is increasing
and is the highest in the State. Our air quality is unacceptable
for human health. Since 1990 we have not had a significant increase
in industrial facilities or power plants, but we have four incinerators.
Some of these plants do not have adequate controls. There are
current plans to site another incinerator in our area and a
new medical waste treatment plant in Linden. With the New Jersey
Turnpike and Newark Airport we have excessive mobile sources
We believe a PM 2.5 standard would be helpful because the
greatest threat is from these small biologically active particulates
which become entrapped in our lungs. We urge the immediate closing
of all four incinerators. We urge blocking the expansion of
the New Jersey Turnpike and Newark Airport. We urge a total
moratorium on incinerators anywhere in the State.
I have a degree in medical science from Harvard and in my
estimation the PM 2.5 seems the most lethal of the particulates.
Inert particles, such as sand or glass are not as problematic
as biologically active particulates. The variability in PM 2.5
may come from the fact that fine particles could be composed
of such things as dioxin or radioactive particles. Research
into the nature of fine particulates is essential to the public
EDWARD HOZZOURI - Sun Oil Company
Sun Oil Company opposes the revision of the particulate matter
standard at this time and recommends that EPA initiate a comprehensive
data collection and analysis effort to re-examine the standard
in five years.
Sun supplies over 750 million gallons of gasoline to New Jersey
through all channels of distribution. New Jersey is a core stat
in Sun's business planning. Sun's stake in revision to the NAAQS
for particulate matter derives from stationary and mobile sources.
The more stringent standards will require significant emission
reductions from manufacturing sources and from autos and trucks.
Sun has voluntarily participated in programs aimed at reducing
air pollution and increasing energy conservation. Sun has demonstrated
continuous improvement in environmental performance. The reasons
we oppose any change in NAAQS are as follows:
- The Clean Air Act does not mandate revision but requires
review of the standard every five years.
- Air quality is improving and the reduction in PM 10 concentrations
has been substantial. From 1988 to 1995 PM declined 22%. These
improvements occurred while vehicle miles traveled increased,
population grew and the economy was fairly robust.
- Reservation about the health benefits accruing from the
revision have been expressed by the CASAC. There is no established
causal connection between particulate matter and health effects.
- With no statutory requirement and incomplete data, EPA should
not impose a massive new environmental regulations at this
The cost is between six to 18 billion dollars per year. Technology
is not available to enable sources to comply. Jobs will be lost
as well. In the Philadelphia region over 1400 jobs will be lost.
On the national scale 1.3 million jobs will be lost. The health
disbenefits of job loss are well documented. Additional controls,
such as enhanced I/M and NOx controls should be allowed time
to be effective and more research on PM 2.5 should be conducted.
DEBRA DILORENZO - Chamber of Commerce Southern New
The Chamber of Commerce of Southern New Jersey is
the largest state regional chamber with over 1,400 member companies
employing over 250,000 people. Many of the chamber's member
companies would be adversely impacted if EPA proposed standard
The Chamber supports the goals of the Clean Air Act to protect
the public health and recognizes the gains that have been made
in clean air quality, a 36% improvement over the past decade.
A more stringent PM 2.5 standard would significantly increase
the number of non-attainment areas in New Jersey. Studies show
that over one half of New Jersey counties would be out of compliance.
The standard would significantly increase cost to businesses.
The cost of compliance far outweighs the health benefits.
A study conducted by New York University indicated that hospital
admissions will decrease only minimally under the new standard.
There are so many questions and uncertainties associated with
the PM 2.5 standard that the Chamber believes EPA should implement
a research program into PM 2.5 and leave the PM 10 standard
NJ DEPARTMENT OF HEALTH AND SENIOR SERVICES
The NJ Department of Health and Senior Services (NJDHSS) supports
the EPA's proposal to maintain current PM 10 standards and to
propose additional annual and daily standards for PM 2.5. The
new standards are needed to protect the public health.
Particulate matter is associated with premature death, hospital
admissions and Emergency Room visits, asthma and bronchitis.
The current PM 10 standard alone is insufficient.
The fine particulate fraction formed through the process of
fossil fuel combustion contains the most toxic portion of the
particles (organics, ammonium, sulfates and nitrates) providing
biologically plausible mechanism for causality.
Subpopulations are at higher risk from fine particulates.
These include senior citizens, who die prematurely or are admitted
to hospitals; children, whose respiratory systems are more susceptible
too environmental threats; asthmatics, whose asthma is aggravated
by fine particles and lastly, persons with respiratory and cardiovascular
The NJDHSS believes that the current PM standard is inadequate
and supports EPA's proposal to add daily and annual standard
CHEMICAL INDUSTRY COUNCIL OF NEW JERSEY (CIC/NJ)
The CIC/NJ is a trade association representing 105 members of
the chemical process industry and 50 environmental consultants
and legal firms. We represent a significant portion of the regulated
community who will be impacted by the PM standard revisions.
We believe that the proposed changes in PM 10 would force
much of New Jersey into non-compliance. Currently, on a hot
summer day with winds blowing south and north, New Jersey fails
to meet existing standards. To adopt even more stringent standards
will only result in penalizing New Jersey industry without benefits
of air quality improvement. CIC/NJ believes that while downwind
pollutants from other states are a major problem facing New
Jersey, the current air standards are more than adequate.
Further, new standards will destroy existing and future employment
opportunities in New Jersey. It will require draconian control
measure that will weigh heavily on our fragile manufacturing
sector. The public health risks associated with unemployment
and poverty outweigh the inadequately justified health benefits
of this new standard. It appears that special interest politics
play a far greater role than science, public health or cost.
ELIZABETH GRIFFITHS MT/ASCP and DR. JONATHAN S. GRIFFITHS,
As a medical professional and a chemist we find the scientific
data supporting the increased PM standard unequivocal. We know
that tiny particles in the air can lodge in the lung and cause
life-threatening difficulties for millions of Americans. Particles
smaller than 2.5 micrograms behave like gases, getting deep
into the lungs and causing serious damage. Both the law and
the findings of science require that EPA move forward with new
and better standards for our nation's air quality.
We urge the EPA to set a standard of 18 micrograms of particulates
per cubic meter of air over a 24 hour period. The 50 micrograms
currently being proposed seems to us below what should be standard.
It is time to decide that people are more important that the
financial gain of specific industries. Collective health is
not worth the risk of lowering air quality standards. We have
asthmatic children and are aware of the danger of poor air quality.
New and higher air quality standards need to be implemented.
I wish to question the relationship between the new
standard for particulates and dust from dredged spoils in our
harbors. These materials dry and break down with the outer layers
obtaining a dusty-like texture. Why is there no testing of the
contents of the dredged spoils?
I have noticed that the dredge spoils coming from the "Orion
Project" in Elizabeth produces a lot of dust and I am concerned
that this dredged material needs to be tested.
MARC LAVIETES, M.D. - NJ Physicians for Social Responsibility,
Clean air should not be an issue for political debate or political
compromise. It should be a matter of public health. New information
concerning pollutants makes it important to review the clean
air standards every five years. The review of the PM standard
resulted in New a new standard being proposed. A Harvard study
linked levels of PM in over 150 cities with increased mortality
rates. Living or coming to work in many of our major cities
constitutes a threat to heart and lung health.
The public should be aware of the proposed standards and the
fact that averaging will be misleading in terms of the air quality
in a given area. It is time to set air quality standards which
protect the health of our children, the sick and the elderly.
The following concerned parties
sent the same letter in written testimony:
KENNETH R. WINTER - Winter Yacht Basin, President
and General Manager
ALAN DAVIDSON - Marine Trades Association of New Jersey,
ROBERT G. LANGE, JR., - Holiday Harbor Marina, Owner
CHRIS SABATINI - Somers Point Marina, President
JILLIAM KOCI - Cape May Marina
MICHAEL MOCK - Sportsman's Marina
KENNETH R. WINTER - Winter Yacht Basin, President
ALAN DAVIDSON - Marine Trades Association of NJ, Legislative
We are opposed to the EPA's proposal to revise the
National Ambient Air Quality Standard for particulate matter
from PM 10 to PM 2.5. This new standard will adversely impact
both the manufacturer of boats and the end-user. There may even
be episodic bans on recreational boating as a mean of meeting
the requirement of the SIP.
Existing boat plants are already severely regulated and more
stringent standards will create undue pressures for facilities
so that boat builders could face a freeze on new construction
and new jobs. For the boating industry the new standard threatens
our jobs and survival. We suggest that a careful cost benefit
analysis be done to resolve this matter.
ADELAIDE FRANKLIN - Main One Marina, Inc., President
Years ago there was a study done on the travel patterns of New
Jersey employees to determine how a reduction in auto emissions
might be achieved. I question what became of that study. The
marine industry has been hit hard with regulatory restrictions.
We complied with the many requirements but it is inconceivable
that we now might be faced with the prospect of boating being
restricted on weekends. Marinas and other related businesses
will have to go out of business. Marine engines are now being
built to specifications which will greatly reduce toxic emissions.
This should be enough.
Editor: Eileen Hogan, M.A.
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