Comments for Health and Medical Organizations: Opposition to Proposed Cleaner Cars Rollback
The letter below is designed for sign-on by health, medical and nursing organizations and will be submitted as a public comment to the U.S. Environmental Protection Agency and the National Highway Traffic Safety Administration. If you represent a health, medical or nursing organization and are authorized to sign letters on behalf of your organization, please fill out the form at the bottom of this page. Please also send a copy of your organization’s logo to [email protected].
The Honorable Andrew Wheeler
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
The Honorable Heidi King
National Highway Traffic Safety Administration
U.S. Department of Transportation
1200 New Jersey Avenue, S.E.
Washington, DC 20590
Submitted via www.regulations.gov
Subject: Public Health Organizations’ Opposition to the Proposed “Safer Affordable Fuel-Efficient Vehicles Rule” for Model Years 2021–2026 Passenger Cars and Light Trucks. Docket No. EPA-HQ-OAR2018-0283; NHTSA-2018-0067.
Dear Acting Administrator Wheeler and Deputy Administrator King:
The undersigned health and medical organizations write to express our opposition to the joint Notice of Proposed Rule Making issued by the United States Environmental Protection Agency (U.S. EPA) and National Highway Traffic Safety Administration (NHTSA) to reduce the stringency of existing vehicle emission and efficiency standards and to revoke states’ Clean Air Act authority to adequately protect citizens from harmful pollution.
Our organizations are dedicated to the protection of public health, and support policies that safeguard health and improve health outcomes. By design, the proposed standards would increase fossil fuels burned and harmful pollution emitted into the atmosphere. The steps outlined to roll back vehicle emission and efficiency standards from 2020 to 2026, and to strip California and other states of their authority to implement more protective standards, are directly at odds with the interests of protecting and improving public health and the air we breathe. Because the existing science-based and thoroughly reviewed federal and California vehicle emission standards for greenhouse gases are vital to the protection of public health, healthy air and a safe and stable environment for all Americans, we strongly oppose the proposal.
We urge the administration to reject this proposal and adhere to the existing effective, appropriate and feasible national program through 2025, and respect decades of Clean Air Act implementation with regard to state authority.
We Oppose the Proposal and Support Implementing the Existing Standards
Federal and state vehicle emissions, efficiency and technology standards adopted in 2012 were carefully researched and negotiated between U.S. EPA, NHTSA and California with significant public and stakeholder input. These standards are providing meaningful pollution reductions and fuel savings and are being achieved ahead of schedule in a cost-effective manner 1,2. , The transportation sector has become the leading source of harmful carbon pollution in the United States 3, demanding the robust policy response to reduce carbon pollution reflected in the existing standards.
No rational basis exists for curtailing advancement of vehicle technologies that reduce harmful levels of emissions, fuel consumption and consumer costs. The proposed standards will lead to the consumption of an additional half million barrels of oil a day 4, raising direct health impacts associated with criteria air pollutants and carcinogenic toxic emissions for communities already most impacted by the “upstream” pollution associated with the extraction, transportation and refining of petroleum products, and creating an overall increase in particle pollution as compared to the existing standards in 2025 and beyond. 5
By contrast, the existing standards remain an appropriate reflection of the urgent action needed to protect public health against climate change health impacts and an ongoing over-dependence on fossil fuels. The health consequences of climate change have never been clearer; worsened wildfires, storms, and heatwaves are just some of the climate-related impacts harming health today. It is simply the wrong approach to roll back these critical health-protective standards and leave states unable to offer their citizens necessary levels of protection against harmful emissions that contribute to climate change. We urge the Administration to reject this proposal and focus on implementation of the existing standards.
Climate Change Increases Public Health Risks and Emergencies
Climate change poses grave threats to public health. The changing climate threatens the health of Americans alive now and that of future generations. Growing evidence clearly demonstrates that climate change amplifies multiple and profound risks to public health for all Americans, from extreme heat events to hurricanes to winter storms to wildfires. According to the National Oceanic and Atmospheric Administration, 2017 was the third warmest year nationally, behind 2012 and 2016 6. This heat has contributed to widespread increases in unhealthy ozone pollution. 7
The western states are experiencing historic and catastrophic wildfires at an alarming rate, with particulate matter and other pollutant exposures impacting large swaths of the United States. Millions of Americans have been displaced by storms, flooding and other extreme weather events, such as Hurricanes Harvey, Maria, and Florence, that grow more commonplace each year. The most recent national climate assessment conducted by the US Global Change Research Program (USGCRP) highlights the fact that recent years have seen “record-breaking, climate-related weather extremes, and the last three years have been the warmest years on record for the globe. These trends are expected to continue…8” The USGCRP’s 2016 assessment of health impacts of climate change in the Unites States detailed the wide – and increasing – range of risks that “endanger our health by affecting our food and water sources, the air we breathe, the weather we experience, and our interactions with the built and natural environments.”9
These analyses echo reports previously produced by several of our organizations: the American Academy of Pediatrics’ technical report in 2007 (updated in 2015) on “Global Climate Change and Children’s Health” 10; Trust for America’s Health, Health Problems Heat Up: Climate Change and the Public’s Health, in October 2009 11; the Asthma and Allergy Foundation of America’s Extreme Allergies and Global Warming, issued with the National Wildlife Foundation in 2010 12; the American Public Health Association’s Climate Change: Mastering the Public Health Role, in April 2011 13; and the American Thoracic Society’s workshop on Climate Change and Human Health, published in 2012 14.
Millions of Americans suffer greater vulnerability to these threats. Many people face greater risk or exposure, as documented in the USGCRP’s recent health assessment 15. Children court special risks because their bodies are growing and because they are so active 16. Risks are also greater for pregnant women and their pregnancies.17 Older adults are more likely to die during high heat events 18. People with chronic respiratory diseases like asthma and chronic obstructive pulmonary disease, people with cardiovascular diseases and people with diabetes also risk greater harm from increased pollution.19. Low income people and some racial and ethnic groups are among those who often confront higher exposure to pollutants and who may experience greater responses to such pollution. Many studies have explored the differences in harm from air pollution to racial or ethnic groups and people who are in a low socioeconomic position, have less education, or live nearer to major sources 20. Even healthy adults can be affected by increased air pollution, especially if their work requires them to be outdoors, as the study of lifeguards in Galveston, Texas demonstrated. 21
Many different vulnerable groups and disadvantaged communities, including seniors, children and those with disabilities, will have a harder time responding to the threats, especially if electricity is lost or relocation or evacuation is required 22. Hurricane Katrina demonstrated that many people in these groups had difficulty evacuating and relocating after a major weather event 23. Native American and other tribal communities may face threats to food supplies and difficulty relocating due to tribal land locations.24
The Proposed Standards Would Increase Health Risks
Current vehicle standards benefit Americans with fewer harmful emissions and associated impacts to our air and climate. In addition to worsening climate change, ozone, and particulate matter, rolling back these standards would increase the risk to health from direct emissions from these vehicles.
Today, nearly 40 percent of Americans – more than 124 million – live in communities in nonattainment for ozone and particulate matter, with many residents impacted more severely by local pollution sources, including near-road pollution.25
Near-road pollution has been found to increase asthma attacks in children, cardiovascular health impacts, impaired lung function and premature death.26 For example, several Volatile Organic Compounds (VOCs) from gasoline emissions are recognized carcinogens, including benzene, 1,3-butadiene and formaldehyde.27 Reducing VOC emissions will help reduce the burden of these carcinogens on many communities, especially those living or working near these roadways.
Instead, the proposed standards would lead to the consumption of an additional half million barrels of oil a day,28 raising direct health impacts associated with criteria air pollutants and carcinogenic toxic emissions for communities already most impacted by the “upstream” pollution associated with the extraction, transportation and refining of petroleum products, and creating an overall increase in particle pollution and sulfur dioxide emissions as compared to the existing standards in 2025 and beyond.29 Fine particulate matter causes cardiovascular and respiratory harm, including lung cancer, and causes premature death.30 Sulfur dioxide causes difficulty breathing and asthma attacks and has been linked to premature death.31
In contrast to the carefully designed existing standards, the proposal to roll back the rate of vehicle emissions improvements in 2020 through 2026 would lock out emissions reductions needed to protect public health, and lock in less protective standards for a longer timeframe.
The Existing Standards are the Best Way to Protect Health
The existing standards remain an appropriate reflection of the urgent action needed to protect public health against climate change health impacts. As discussed above, the health consequences of climate change have never been clearer; in recent years, rising temperatures, extreme heatwaves, droughts and catastrophic wildfires linked to climate change have ravaged American communities. These events ratchet up the formation of ground-level ozone, create stagnant conditions for trapping unhealthy air and affect vast regions of the country – far from the flames – with wildfire smoke. Rolling back these critical health-protective standards and leaving states unable to offer their citizens necessary levels of protection against emissions that contribute to climate change is the wrong approach. Recognizing the threats posed by transportation pollution, Americans overwhelmingly support maintaining the existing vehicle standards 32.
Maintain States’ Rights; Reject Proposal to Preempt States
Our organizations oppose the proposal to revoke long-standing authority of states to take stronger steps to reduce pollution. Because of the extreme air pollution burdens faced in California, the Clean Air Act appropriately authorizes California to act to protect its residents through emission control programs that are more protective than federal standards 33. The Clean Air Act also gave other states the authority to opt into these more protective standards 34. The proposal to revoke California’s waiver and preempt states’ authority to enact more protective emissions standards endangers progress to meet the public health goals of the Clean Air Act.
Thirteen states and the District of Columbia have taken affirmative legislative or administrative actions to ensure the cleanest vehicle technologies operate in their jurisdictions, with nine of those states also following California’s zero-emission vehicle program to ensure technology advancement needed to achieve clean air and climate standards. The proposal to revoke California’s waiver and preempt states’ rights represents an unjustifiable departure from the effective historical state-federal collaborative approach to protecting public health. Our organizations strongly oppose this proposed revocation and urge a return to negotiations between federal agencies and California to ensure protective, efficient and appropriate standards remain in place through 2025 and are strengthened into the future.
To protect our communities and the public, the United States must significantly reduce greenhouse gases from all sources, including from transportation sources. The existing 2025 standards offer a significant level of protection and confidence that the harms caused to our environment by the transportation sector will be reduced. Conversely, the proposal to roll back the standards would unnecessarily increase the levels of carbon pollution, health impacts from associated air pollution and an increased level of risk due to climate change impacts.
The undersigned health and medical organizations from across the United States urge the U.S. EPA and NHTSA to drop this unprecedented attack on states’ rights, health protections and energy solutions for a sustainable world and withdraw this proposed rule, and instead work in cooperation with California to implement the existing state and federal greenhouse gas emissions standards and federal rules to improve fuel economy. The health of our patients and our communities depends on it.
Health and Medical Organizational Sign-On
Please send copy of your logo to: [email protected].
1U.S. Environmental Protection Agency. Final Determination on the Appropriateness of the Model Year 2022-2025 Light-Duty Vehicle Greenhouse Gas Emissions Standards under the Midterm Evaluation. EPA-420-R-17-001. January 2017. Accessed at https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100QQ91.pdf.
2California Air Resources Board. 2017. California’s Advanced Clean Cars Midterm Review: Summary Report for the Technical Analysis of the Light Duty Vehicle Standards. Page ES-61. Available at https://www.arb.ca.gov/msprog/acc/mtr/acc_mtr_finalreport_full.pdf
3U.S. EPA. Inventory of Greenhouse Gas Emissions and Sinks, 1990-2016. Published April 2018. p. ES-24. https://www.epa.gov/sites/production/files/2018-01/documents/2018_complete_report.pdf
483 Federal Register 42986. U.S. EPA and National Highway Transportation Safety Administration. The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021-2026. Passenger Cars and Light Trucks.
583 Federal Register 43323-43335; California Air Resources Board. Proposed Amendments to the Low-Emission Vehicle III Greenhouse Gas Emission Regulation. Standardized Regulatory Impact Assessment (SRIA) Equivalent Document. Monetized Health Impacts and health case impacts to California due to weakened federal standards described Pages 22-24. June 2018. http://www.dof.ca.gov/Forecasting/Economics/Major_Regulations/Major_Regulations_Table/documents/LEV%20III%20GHG%20Regulation%20Amendments.pdf
6National Oceanic and Atmospheric Administration. National Centers for Environmental Information, State of the Climate: National Climate Report for Annual 2017, published online January 2018.
7American Lung Association. State of the Air 2018. Published April 2018.
8USGCRP, 2017: Climate Science Special Report: Fourth National Climate Assessment, Volume I [Wuebbles, D.J., D.W. Fahey, K.A. Hibbard, D.J. Dokken, B.C. Stewart, and T.K. Maycock (eds.)]. U.S. Global Change Research Program, Washington, DC, USA, 470 pp, doi: 10.7930/J0J964J6.
9USGCRP, 2016. The Impacts of Climate Change on Human Health in the United States: A Scientific Assessment. Crimmins A, Balbus J, Gamble JL, Beard CB, et al. Eds. U.S. Global Change Research Program, Washington DC.
10Shea KM and the Committee on Environmental Health. 2007. Global Climate Change and Children’s Health. Pediatrics,; 120; e1359; Adhoot, et al., 2015.
11Trust for America’s Health, Health Problems Heat Up: Climate Change and the Public’s Health,
12National Wildlife Federation and Asthma and Allergy Foundation of America. Extreme Allergies and Global Warming. National Wildlife Foundation, 2010. Accessed at http://www.nwf.org/pdf/Reports/NWF_AllergiesFinal.pdf.
13American Public Health Association. Climate Change: Mastering the Public Health Role. A Practical Guidebook. April 2011. Accessed at http://www.apha-environment.org/ClimateandHealth.aspx.
14Pinkerton KE et al., An Official American Thoracic Society Workshop Report: Climate change and Human Health. Proceedings American Thoracic Society 2012; 9: 1: 3-8.
16Shea KM and the Committee on Environmental Health. Global Climate Change and Children’s Health. Pediatrics, 2007. ; 120; e1359; American Academy of Pediatrics Committee on Environmental Health, Ambient Air Pollution: health hazards to children. Pediatrics. 2004; 114: 1699-1707. Statement was reaffirmed in 2010.
17Gamble JL, Balbus J, Berger K, et. al. Ch9: Populations of Concern. The Impacts of Climate Change on Human Health in the United States: A Scientific Assessment. U.S. Global Change Research Program, Washington, DC, 247-286. http//dx.doi.org/10.7930/J0Q81B0T
18Zanobetti A, et al. Summer temperature variability and long-term survival among elderly people with chronic disease. Proceedings of the National Academy of Sciences, 2012. 109: 6608-6613.
19U.S. EPA. Integrated Science Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-08/139F, 2009; U.S. Environmental Protection Agency. Integrated Science Assessment of Ozone and Related Photochemical Oxidants (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-10/076F, 2013.
20Institute of Medicine. Toward Environmental Justice: Research, Education, and Health Policy Needs. Washington, DC: National Academy Press, 1999; O’Neill MS, Jerrett M, Kawachi I, Levy JI, Cohen AJ, Gouveia N, Wilkinson P, Fletcher T, Cifuentes L, Schwartz J et al. Health, Wealth, and Air Pollution: Advancing Theory and Methods. Environ Health Perspect. 2003: 111: 1861-1870; Finkelstein MM; Jerrett M; DeLuca P; Finkelstein N; Verma DK, Chapman K, Sears MR. Relation Between Income, Air Pollution And Mortality: A Cohort Study. CMAJ. 2003; 169: 397-402; Ostro B, Broadwin R, Green S, Feng W, Lipsett M. Fine Particulate Air Pollution and Mortality in Nine California Counties: Results from CALFINE. Environ Health Perspect. 2005: 114: 29-33; Zeka A, Zanobetti A, Schwartz J. Short term effects of particulate matter on cause specific mortality: effects of lags and modification by city characteristics. Occup Environ Med. 2006: 62: 718-725.
21Thaller EI, Petronell SA, Hochman D, Howard S, Chhikara RS, Brooks EG. Moderate Increases in Ambient PM 2.5 and Ozone Are Associated With Lung Function Decreases in Beach Lifeguards. J Occp Environ Med. 2008; 50: 202-211.
22US GCRP, 2016; APHA, 2011.
23US GCRP, 2016.
24US GCRP, 2016
25US. EPA. Nonattainment Areas for Criteria Pollutants (Green Book). Updated August 31, 2018. Accessed September 11, 2018.
26Health Effects Institute Panel on the Health Effects of Traffic-Related Air Pollution, Traffic-Related Air Pollution: A Critical Review of the Literature on Emissions, Exposure, and Health Effects. Health Effects Institute: Boston, 2010. www.healtheffects.org.
27Health Effects Institute Panel on the Health Effects of Traffic-Related Air Pollution, Traffic-Related Air Pollution: A Critical Review of the Literature on Emissions, Exposure, and Health Effects. Health Effects Institute: Boston, 2010. Available at www.healtheffects.org.
2883 Federal Register 42986.
2983 Federal Register 43323-43335 CARB, June 2018.
30U.S. EPA, 2009.
31U.S.EPA. Integrated Science Assessment for Sulfur Oxides—Health Criteria. EPA/600/R-17/451. December 2017.
32American Lung Association. Voters Support Strong EPA Fuel Efficiency Standards. March 2018.
3342. U.S.C. § 7543.
3442. U.S.C. § 7507.
Page Last Updated: October 9, 2018