Six Threats to the Nation's Air Quality
Our nation has made significant strides in cleaning up our air, as shown by this report over the past 19 years. Stopping or retreating cannot be an option. Our nation's historic legal commitment to protect the health of millions of Americans requires more work to reduce the burden of air pollution. Cleaning up air pollution requires a strong and coordinated effort on the part of our federal and state leaders.
Unfortunately, EPA Administrator Scott Pruitt, supported by the President, has taken many steps to roll back or create loopholes in many of the protections in place under the Clean Air Act in the past year. Members of Congress, governors and state leaders all have a key role to play, and while some are supportive, others are not.
Below are six key threats to the nation's progress toward cleaner, healthier air. The Lung Association continues to fight for healthy air and oppose these threats.
Threat 1: Weakening the Clean Air Act
Congress must make certain that the Clean Air Act remains strong, fully implemented and fully enforced.
The Clean Air Act remains a strong public health law put in place by an overwhelming bipartisan majority in Congress more than 45 years ago. Congress wrote the Clean Air Act to set up science-based, technology-fostering steps to protect public health by reducing pollution. Under the Clean Air Act, Congress directed EPA and each state to take steps to clean up the air. For 19 years, the "State of the Air" report has chronicled the slow but steady improvement in the nation’s air quality thanks to the Clean Air Act—a trend that continues even as climate change makes pollution clean-up more difficult.
Now, that positive trend is threatened, and not just by the impacts of climate change. Unfortunately, some in Congress seek changes to the Clean Air Act that would dismantle key provisions of the law and threaten the progress made over nearly five decades. Undermining the Act itself is one of the fundamental goals of polluters and their allies. They have repeatedly challenged Clean Air Act provisions in court, and have repeatedly lost, so now they seek to weaken the law. Recent proposed efforts include exempting certain polluting facilities from some emissions controls, delaying science-based updates to air pollution standards, and undermining public health as the core premise of the Act’s key pollution limits. To protect the lives and health of millions of Americans, the Lung Association calls on Congress to reject attempts to weaken the Clean Air Act and make certain the law remains strong, fully implemented and fully enforced.
Threat 2: Repealing plans to reduce carbon pollution from power plants
To protect public health, the nation must act to fight climate change; core to that is cutting carbon pollution. Unfortunately, the current EPA has taken steps that would dismantle our nation's first and only federal plan to limit carbon pollution from power plants.
Scientists tell us that carbon pollution contributes to a warming climate, enhancing conditions for ozone formation and making it harder to reduce this lethal pollutant. The increased ozone problems reflected in this year's report came in large part because 2016 was the second warmest year in U.S. history. Climate change also leads to particle pollution from increased droughts and wildfires, leading to many of the high particle-pollution days recorded in 2014-2016 also documented in this report.
The Lung Association opposes efforts to repeal the Clean Power Plan and will continue to push for a system-wide reduction in carbon dioxide emissions from power plants.
Power plants comprise the largest industrial-scale source of carbon pollution in the United States. The electric sector contributed 35 percent of all energy-related carbon dioxide (CO2) emissions in 2015.1 Taking system-wide steps to reduce carbon pollution from electricity generation will also reduce ozone and particle pollution from these plants at the same time. Despite that, in 2017, EPA Administrator Pruitt proposed to repeal the Clean Power Plan, the only nationwide strategic approach to cutting carbon pollution from these plants.
Adopted in 2015, the Clean Power Plan delivers a flexible, practical toolkit for states to reduce carbon pollution from power plants approximately 32 percent (below 2005 levels) by 2030. States can choose a variety of ways to cut carbon pollution with these tools. They can choose to require cleaner fuels for existing utilities, improve energy efficiency, produce more clean energy or partner with other states to jointly reduce carbon pollution.
Reducing carbon to tackle climate change is only one of the benefits from the Clean Power Plan. Steps to reduce carbon using the tools in the Clean Power Plan also reduce other air pollutants that themselves worsen asthma, cause cardiovascular harm and cause premature deaths. EPA's original analysis estimated that these co-benefits can prevent up to 3,600 premature deaths and up to 90,000 asthma attacks in children in 2030.2 In an updated analysis published along with EPA's proposal to repeal the Plan, the Agency projected even greater benefits from putting the Plan in place, including preventing up to 4,500 premature deaths in 2030.3
The Clean Air Act requires that EPA act to reduce carbon pollution, which means that EPA must clean up carbon pollution from power plants. Unfortunately, Administrator Pruitt has kicked off a very long, slow process to collect information on possible alternative approaches, rather than moving quickly to propose a replacement plan. Worse, EPA has signaled a preferred replacement plan that, if adopted, could likely result in more deadly pollution from power plants, not less. Not only would the plan have less impact on reducing carbon pollution, independent scientists found that this type of approach could actually increase emissions of at least one other dangerous air pollutant and, with that, increase the risk of premature deaths and asthma attacks.4
The American Lung Association calls on governors to direct their states to develop strong plans to reduce carbon pollution from power plants and protect public health. The Lung Association will continue to oppose efforts to repeal the Clean Power Plan and push for a system-wide reduction in carbon dioxide emissions from power plants and other sources.
Threat 3: Removing limits on emissions from oil and gas operations
Oil and gas production wells, processing plants, transmission pipelines and storage units have long emitted harmful gases, including methane, volatile organic compounds and other pollutants. For the last few years, "State of the Air" has reported elevated levels of unhealthy ozone in places where oil and gas production has expanded, even in largely rural counties in the West. Despite this, EPA has recently proposed steps to weaken or roll back health-protective standards the Agency had adopted in 2016 to reduce harmful emissions of these gases from new and modified sources within the oil and natural gas industry.5
Rolling back limits on emissions from oil and gas operations means more people will be forced to breathe cancer-causing and other toxic gases that also worsen ozone and climate change.
Nor does EPA offer any protection from emissions from the existing oil and gas infrastructure. EPA even backed off collecting data from the oil and gas industry about the location and size of their facilities. Gathering this information is a required step for EPA to eventually limit harmful emissions from these existing sources, and EPA requested it in 2016. The industry objected, and in March 2017, EPA withdrew its request for updated information on their facilities.
All of these standards would not only help to mitigate climate change and its associated health risks by curtailing emissions of methane, an especially potent greenhouse gas, but would also limit emissions of major precursors to ozone, as well as other toxic and carcinogenic air pollutants, benefiting public health in communities across the country. EPA's continued rollback of these protections reflects a much higher priority on eliminating so-called “burdensome regulations” on polluters than protecting the health of the American people.6
Threat 4: Opening doors for more polluting trucks and cars
Dirtiest diesel. Over many years, heavy-duty diesel trucks standards have become much tighter, reducing emissions recognized as causing cancer, heart attacks, asthma attacks and premature death. Thanks to the long-adopted requirements for cleaner fuels and engines, people living near heavily traveled highways and busy city streets have had to breathe less of these dangerous emissions. But now, that progress is threatened by a loophole that the current EPA seeks to open.
The loophole benefits "gliders." "Gliders" is the name used for trucks that embed an old, dirty engine in a new truck body. Originally conceived to help truck owners whose truck body had been damaged, but whose engine remained intact, the use of gliders has expanded to become a cottage industry repackaging old, polluting diesel engines in new truck bodies. One EPA study found that these engines produced emissions up to 450 times higher than a comparable 2014 or 2015 model year truck.7 In 2016, EPA put in place a new rule to require that these glider trucks meet the same limits on emissions as all new trucks, a position that the trucking industry fully supported.
EPA's proposed glider loophole exempts trucks that emit up to 450 times more than other diesel trucks from having to clean up.
However, in 2017, EPA proposed a rollback of that requirement that would create a loophole for these dirtier trucks, despite broad opposition from the rest of the trucking industry.8 The Lung Association spoke up to oppose this in the public hearing and in comments with eleven other health and medical groups, and continues to oppose this loophole.9
More polluting cars. Administrator Pruitt has also signaled that EPA will examine ways to block or roll back stronger limits on emissions from cars, SUVs and personal trucks. In 2012, EPA and the Department of Transportation developed new national standards that would cut 6 billion metric tons of greenhouse gas emissions for these vehicles for model years 2017 through 2025. Automobile industry representatives had called on Pruitt to withdraw these standards in February 2017,11 despite having supported them previously.12 On April 2, 2018, Pruitt announced that EPA and the Department of Transportation would proposed new rules to weaken these standards and threaten California’s authority to set tighter standards.13
In addition to maintaining their standards through 2025, California is considering setting stronger standards for 2026 and beyond, and Pruitt has sent signals opposing the state's action.14 Under the Clean Air Act, California has the right to establish its own emission standards for cars and trucks. Other states also have the option of adopting California's standards, and many states have done so. California's ability to set more protective emissions standards has helped drive lifesaving reductions in harmful pollution from vehicles nationwide; maintaining this authority is critical.
Threat 5: Cutting funding and expertise needed to clean up the air
The Trump Administration's proposed budget would greatly reduce the ability of EPA to protect public health.
The Clean Air Act set up smart, open processes for protecting Americans from air pollution, which have enabled the U.S. to reduce some of the most common pollutants by more than 70 percent, as shown in this chart. Still, these processes only work if EPA has the funding, staffing and scientific advisors it needs to enable them to implement and enforce the law. The Trump Administration proposed a budget that would greatly reduce the ability of EPA to protect public health, including slashing overall funding for the agency and reducing grants to support the work of state and local agencies and tribes to implement the requirements of the Clean Air Act and other critical laws. The proposed budget for FY 2019 claims to put a priority on "improving air quality" but would cut EPA funding for that work significantly.15
The Lung Association calls on Congress to ensure that EPA has sufficient funding to protect public health with the full range of programs, including state, local and tribal grants.
Threat 6: Stacking the deck to deny the scientific evidence
A core driver of the success of the Clean Air Act is its requirement that up-to-date science be the basis for decisions and actions to protect public health. This requires ensuring that independent expert scientists regularly analyze up-to-date, peer-reviewed research and then provide their conclusions and perspectives to the EPA staff scientists and the administrator. Unfortunately, the current EPA has taken steps to remove independent science advisors from key advisory committees, including the Clean Air Scientific Advisory Committee, and replace them with people paid by polluting industries.16 A group of physicians, scientists and professional associations are challenging EPA's decision to remove experts who have received funding from EPA from key advisory committees.17
EPA has also taken steps to remove independent science advisors from key advisory committees.
Administrator Pruitt has also signaled that the agency will restrict the research that it will allow scientists to consider, proposing to eliminate major scientific research that supports strong clean air safeguards.18 Some members of Congress have proposed similar limitations that would block EPA from using studies that cannot make all the underlying data fully open for public review. Many databases scientists use today do allow unrestricted access to the information, but others do not, because of patient confidentiality for subjects included in the research. Such arguments have been raised before and resolved, and these studies were established as core evidence of the harm from air pollution.19 Blocking the use of key studies that have been through multiple independent reviews and show widespread harm from outdoor air pollutants introduces dangerous bias that could limit the evidence, risking weaker air pollution safeguards.
EPA is stacking the deck to deny the evidence.
The Lung Association calls on EPA to return to its historic practice of appointing qualified, independent scientists to these review committees and for accepting peer-reviewed research without artificial limitations.
- U.S. Environmental Protection Agency. Inventory of Greenhouse Gas Emissions and Sinks: 1990-2015. Washington, DC: U.S. EPA, 2016. EPA 430-P-17-001.
- U.S. EPA. Regulatory Impact Analysis for the Clean Power Plant Final Rule. August 2015. EPA-452/R-15-003.
- U.S. EPA. Regulatory Impact Analysis for the Review of the Clean Power Plant: Proposal (RIA). October 2017. EPA-452/R-17-004.
- Driscoll C, Buonocore J, Levy J, Lambert K, et al. 2015 US power plant carbon standards and clean air and health co-benefits. Nature Climate Change 5: 525-540. Schwartz J, Buonocore J, Levy J, Driscoll C, Fallon Lambert K, and Reid S. Health Co-Benefits of Carbon Standard for existing Power Plants: Part 2 of the Co-Benefits of Carbon Standards Study. September 30, 2014. Harvard School of Public Health, Syracuse University, Boston University. Available at Health Co-Benefits of Carbon Standards for Existing Power Plants.
- U.S. EPA. Controlling Air Pollution from the Oil and Natural Gas Industry: Actions and Notices about Oil and Natural Gas Air Pollution Standards. Accessed March 16, 2018.
- U.S. EPA. EPA Year in Review: 2017-2018. March 5, 2018.
- U.S. EPA. 2017. Chassis Dynamometer Testing of Two Recent Model Year Heavy-Duty On-Highway Diesel Glider Vehicles. p. 3. Accessed at https://www.regulations.gov/document?D=EPA-HQ-OAR-2014-0827-2417
- 82 Federal Register 53442.
- All these comments are available at http://www.lung.org/get-involved/become-an-advocate/advocacy-archive.html.
- Schwartz J and Bryan V. "VW's Dieselgate bill hits $30 bln after another charge." Reuters, September 29, 2017.
- Eilperin J and Overly S. "Automakers ask EPA to overturn recent review of fuel-efficiency standards." Washington Post. February 22, 2017; Letter to G. Scott Pruitt, Administrator, U.S. EPA, from Mitch Bainwol, President and CEO, Auto Alliance, February 21, 2017.
- The White House. "Obama Administration Finalizes Historic 54.5 MPG Fuel Efficiency Standards." August 28, 2012.
- U.S. EPA. News Release: EPA Administrator Pruitt: GHG Emissions Standards for Cars and Light Trucks Should Be Revised. April 2, 2018.
- Dloughy JA, Beene R, and Lippert J. "EPA Chief Signals Showdown With California on Fuel Emission Standards." Bloomberg, March 13, 2018.
- U.S. EPA. FY 2019: EPA Budget in Brief. February 2018. EPA 190-R-18-002.
- Memo from EPA Administrator Scott Pruitt. Subject: Strengthening and Improving Membership on EPA Federal Advisory Committees. October 31, 2017.
- Earthjustice. Doctors and Scientists Challenge Removal of EPA Science Advisors. Dec. 21, 2017. Press Release.
- Waldman S and Bravender R. "Pruitt is expected to restrict science. Here's what it means." E & E News. March 16, 2018.
- Health Effects Institute. Reanalysis of the Harvard Six Cities Study and the American Cancer Society Study of Particulate Air Pollution and Mortality. Cambridge, Mass. Health Effects Institute, 2000.