The Washington Post is reporting that the White House—again—is interfering with the EPA’s ability to set scientific air pollution standards. Last time, it was the president who prevented the EPA from strengthening the air quality standard for ozone, despite the unanimous advice of the agency’s independent scientific advisory committee. This time, the interference is coming from the White House Office of Management and Budget (OMB).

According to the Post, emails show that the OMB told the EPA to water down a proposal for a scientific standard for particulate matter (the principal component of soot) that the agency had prepared for public comment. The Clean Air Act requires the EPA to set particulate matter and other air pollution standards based solely on the best available scientific information. Nothing else. Nada.

Other factors can legitimately be considered in the implementation of the standard. But the authors of the Clean Air Act wisely understood that what level of pollution is safe for human exposure is a scientific determination, not a political one.

The Fisk Generating Station, a coal-fired power plant, spews pollution over my hometown of Chicago. A 2010 National Research Council study found that the Fisk and Crawford power plants in Chicago impose a $127 million annual burden in health costs. Photo: Flickr user swanksalot

The OMB has a history of interfering in science, not only softening scientific conclusions but also killing new rules by holding them hostage. This is the same OMB that has stalled a proposal to protect workers from toxic silica dust for 16 months and counting. A recent Public Citizen report found that the OMB missed its 120-day review deadlines on more than half of the rules it received.

That same report found that the government missed 78 percent of congressionally mandated deadlines for establishing new rules or refining old ones. Furthermore, the report documents that as regulations have become a favorite punching bag for Congress, the OMB has slowed down its work considerably.

These delayed rules matter. They are aimed at modernizing food safety inspections, improving the safety of automobiles, and increasing the energy efficiency of federal buildings.

Incredibly, the Obama administration has issued fewer regulations than either the George W. Bush or Clinton administrations. But that hasn’t stopped the House of Representatives from vociferously touting some kind of imaginary regulatory overreach.

Redefining Regicide
The House of Representatives is preparing to redefine the word regicide by voting next week on a suite of misguided bills that could effectively bring the regulatory process to a standstill, making it virtually impossible for the government to respond to new and emerging threats to public health and the environment, or to refine existing public protections to be in line with new research. For example, the so-called Regulatory Freeze for Jobs Act would stop all “significant regulatory action” for two years or until the national unemployment rate falls below six percent—this, despite the fact that small business owners do not see sensible safeguards as a major impediment to job growth.

This interference with needed science-based regulations is only likely to get worse as we get closer to the election—unless we push back. If you believe that the Obama Administration should stand up to special interests and set science based rules on air pollution and other issues, please let the president, and the Office of Management and Budget, know.

The Chevron oil refinery in Richmond, California — one of the largest in the country — had an explosion and serious fire on August 6 that spewed toxic black smoke across the sky. News reports indicate that more than 4,000 area residents sought medical treatment, primarily for respiratory ailments including chest pain and problems breathing, related to the fire.

Almost immediately, the disruption in production at Chevron pushed gas prices up for West Coast consumers, with ripple effects to other nearby states expected.  It was the most recent in a series of fires and explosions that have rocked Bay Area refineries in recent years, not to mention devastating oil spills in the San Francisco Bay.

Smoke darkens the sky above Richmond, CA on San Francisco Bay from the August 6th Chevron refinery fire. (Photo by DH Parks)

The August 6 fire reignites a longstanding debate about Chevron’s plan to upgrade its bayside refinery so it can produce more gasoline and be able to process different grades of crude oil — including heavy, low-quality crudes that are highly polluting. Environmental advocacy groups and many residents of the surrounding community — more than a third live below the federal poverty level — are opposed to Chevron’s plans because of concerns about the persistent problem with pollution from the refinery.

A report commissioned by the Union of Concerned Scientists last year revealed that California refineries already have the highest carbon emissions intensities in the United States, averaging about 30 percent higher than those on the East Coast and in the Midwest.

Chevron’s expansion plan was approved by the city of Richmond, but later blocked by a judge who said the oil company’s environmental impact report was inadequate. Unfortunately, no single public policy or environmental impact report will reduce the likelihood of similar accidents. The long-term solution to refinery pollution is to dramatically reduce our consumption of oil.

That’s why the UCS “Half the Oil” plan makes so much sense. The best part about the plan to cut the United States’ projected oil use in half over 20 years is that it relies on technologies available today to improve the efficiency of our vehicles, homes, and businesses.

California has a head-start on this progress with solution-oriented policies that reduce petroleum consumption, including using more non-petroleum, low-carbon fuels and more vehicles that use little or no conventional fossil fuel.  Sadly, oil companies are using their huge profits and political clout to fight these rules, both in court and in Sacramento.

By reducing our use of oil and the emissions it creates, we protect ourselves from the most dangerous impacts of climate change while saving money for consumers and businesses. Perhaps most importantly, we can reduce the likelihood of refinery accidents in the future that force tens of thousands of people to “shelter in place” for hours at a time and pose serious threats to public health.

The Environmental Protection Agency will revise the air pollution standard for particulate matter today to be in line with the best available science, reports the Washington Post. Particulate matter is the primary component of soot. It is encouraging to see the agency following the Clean Air Act, especially in the face of strong industry pressure to ignore science again.

The law is clear: the Clean Air Act requires air pollution standards to be based solely on the best available science regarding what is protective of health. Other factors, such as costs, can be considered when the standards are implemented. But it is science that should determine what level of pollution is safe for humans.

Today , the EPA is expected to comply with the Clean Air Act and set a standard for soot pollution that is consistent with current public health science. Photo: Flickr user cylon359

This makes absolute sense. I think it’s reasonable to depend on scientific studies, not the price of beef, to understand what level of cholesterol is safe for my body and what level is not. The same goes for air pollution.

EPA staff scientists determined that a standard between 11 and 13 micrograms per cubic meter would be sufficiently protective of public health. This was consistent with the advice of the agency’s Clean Air Science Advisory Committee. Today, the EPA is expected to set the standard at 12 micrograms per cubic meter.

Unfortunately, there is a long history of political interference in setting the particulate matter standard. The current annual standard of 15 micrograms per cubic meter was set in 1997. The Clean Air Act requires the standard to be reviewed every five years. In 2006, the EPA misrepresented and disregarded analysis from its staff scientists in setting a standard that was not protective of public health. Epidemiologist Bart Ostro charged at the time that the agency allowed the White House to insert “last-minute opinions and edits” that “circumvented the entire peer review process.” In February 2009, a court held that the Bush administration particulate matter standards violated the Clean Air Act “in several respects,” and told the agency to follow the science in its 2011 review of the standards.

The Obama White House was accused earlier this year of attempting to water down the particulate matter standard.  Fortunately, it seems that the EPA will stand firm on its original proposal.

It could be that the Obama administration’s backbone is growing stronger now that we’re past the election. Hopefully this means that the administration will side with the science on other issues, too.

The American Lung Association is happy. And so am I. But some industries, and some in Congress, are not.

The House Science Committee yesterday complained that the EPA was being secretive about the data supporting its forthcoming decision. I’m not sure if anyone at the committee knows that the agency has a website, so I’ll save them some time. The Integrated Science Assessment for Particulate Matter is available here. At more than two thousand pages, the report should keep staffers busy for a while.

Of my many childhood memories, most of which can be looked back at with a smile and involved sports in some way, one that stands out with a great deal of clarity was my first asthma attack. It was during August football practice in the 8^th grade. I had suffered from allergies as a card-carrying, weekly allergy shot club member; mild to very annoying respiratory issues were not unusual.

The asthma attack was an entirely different experience, though. What followed has gotten foggy over the years, but after some time, which must’ve seemed an eternity, the attack cleared up. I got the news that it was likely an asthma attack and given an inhaler as a constant companion. But over the years it diminished as a concern and labored breathing chalked up to being woefully out of shape.

Ozone pollution is bad for everyone, but children and adults over age 65 are particularly vulnerable to its effects. Source: iStockphoto.com/Chris Rogers

But asthma is a serious concern. Nearly 26 million Americans suffer from asthma (which works out to about 1 in every 12 Americans). This number includes 7 million children, which is eye-opening as a parent — and brings back thoughts of how truly frightening an attack was for me, especially not knowing what was happening. (And only slightly less frightening when I did know what was going on.)

Asthma is a real drag on the economy — to the tune of $56 billion each year from hospital costs, missed school and work, and treatment. More importantly, it can be deadly. In 2009, it was estimated that asthma accounted for over 3300 deaths and that was not an extraordinary year.

So asthma deserves awareness and attention as a serious public health threat. In keeping with that, May is Asthma awareness month. Much of the activity is focused on providing information about what asthma actually is, what exacerbates asthma and can lead to attacks (including numerous triggers in your home), and outlets for information and guidance, such as Centers for Disease Control, National Institutes of Health, and American Lung Association. You can even get tips on how to tell your asthma story to the media.

The recipe for dangerous air

Outside of the home, outdoor air pollution is a primary driver of asthma attacks and risk of experiencing one. More to the point, ozone is a leading culprit. Mention ozone and people may think of the ozone hole, which indeed would be correct. This, though, is ozone we want around as it protects people and wildlife from damaging ultraviolet radiation from the sun by blocking it very high up in the atmosphere. Ozone closer to the ground, on the other hand, is very harmful to human health and a primary component of smog.

Ozone is not emitted directly into the air. Instead, it takes a handful of ingredients to form this “bad air soup”. On the chemical pollutant side, nitrogen oxides (NOx) and volatile organic compounds (VOCs) are the main ingredients. Sources for these include activities such as driving cars, electric power generation from fossil fuels, and some industrial processes. The other two key ingredients for dangerous ozone being formed are heat and sunlight, which is why ozone alerts tend to be most common with the elevated temperatures of summer. It’s probably not surprising then that high ozone levels often occur in urban areas. It’s also these areas that are densely populated with more people at risk for exposure to ozone pollution.

Chemicals emitted from human activities mix together in hot, sunny conditions to form ground-level ozone. A warming climate provides one of the ingredients for this harmful air. Source: EPA.

We have a few control knobs with which we can dial down ozone levels and reduce asthma risk. There has been success in dealing with the chemical pollutants that form ozone. Thanks to the Clean Air Act, NOx emissions have dropped by 52 percent in the U.S. over the past three decades. Likewise, VOCs emissions fell by 63 percent over the same period. And most likely as a result, average ground-level ozone concentrations have dropped by 28 percent. This is good news and shows that those particular control knobs can work, though most states in the U.S. still have counties that violate current EPA ozone standards.

The “climate penalty factor”

There is also a climate story here and one that threatens to offset some of the success we’ve had in cleaning up the air. I came to this connection through an EPA study that found a relationship between increased temperatures and higher ozone levels based on numerous measurements throughout the eastern half of the U.S. They termed the resulting number (i.e. the increased amount of ozone per degree of warming) the “climate penalty factor” on ozone. This relationship between temperature and ozone has also been confirmed in many other modeling studies and measurements.  The risk climate change poses to harmful ozone levels has also been highlighted in the “Human Health” chapter of the recent draft National Climate Assessment report.

Rising temperatures, worsening ozone pollution, real impacts

A colleague and I at UCS took this concept a step further and asked what this climate penalty factor means in a future, warmer U.S. Basically, we used projections of warming temperatures for the country under a couple of widely used future climate scenarios (which may be optimistic based on recent carbon emission trends) and determined how much ozone levels could increase from this warming in the years 2020 and 2050. We then ran these numbers through the EPA’s BenMAP model to see what the health and economic impacts are from these ozone increases.

The full report is of course worth reading (author bias, perhaps), but the top-line finding is that climate change’s potential impact on ozone may indeed be costly (economic and otherwise). Health impacts could total an additional $5.4 billion in 2020 alone. It’s projected that there could be 2.8 million more occurrences of acute respiratory symptoms, such as asthma attacks. And most importantly between 260 and 510 additional premature deaths are projected in that single year. All of these numbers go up in 2050 with further warming in the U.S. Not surprisingly the states projected to be hardest hit are those that are most populated, with California, Texas, and New York leading the way.

Steps in the right direction

It’s fitting that this month of asthma awareness has seen a couple of important steps in dealing with the problem. First, Representative Lois Capps of California introduced the Climate Change Health Protection and Promotion Act last week. This bill directs the Secretary of Health and Human Services to develop a national plan to help the health community in creating plans for both responding to and preparing for public health impacts of climate change. Although, not named specifically, ozone pollution would surely fall under this effort.

It is also an acknowledgement of the growing body of evidence of adverse and costly climate impacts on public health in addition to air quality concerns. Also, it is not just a matter of responding to climate impacts here and those on the way, but there remain the critical efforts to reduce climate change itself to limit the severity of the impacts. Fortunately, there are myriad solutions for that, but much room for improvement on actually implementing them.

Activities and efforts to raise awareness around asthma is also a critically important step, but perhaps should extend beyond the month of May into the summer months when ozone levels are elevated and people are at higher risk. I’m not sure how to penetrate through to people’s lists of concerns beyond a steady drumbeat and clear explanation of risks.

Turning the lens on myself, having lived in areas prone to extreme weather of various sorts I’m very aware of and tuned into warnings around the more “acute” events (fairly infrequent, but high impact). On the other hand, even having studied the serious impacts associated with bad air, I still don’t notice air quality warnings until they become a deep shade of purple. That goes for heat advisories and warnings, as well.

The more “chronic” events that don’t appear as destructive and happen more frequently than say a hurricane or a blizzard tend to get minimized.  But ask anyone who has lost someone to a heat-related death or an asthma attack and you’ll see quickly how it takes just one instance of high ozone or a day of extreme heat to change lives.

There’s undoubtedly more to be done, but there are clear solutions and fortunately people out there talking about them.  Now we need to do some listening.

• TAKE ACTION: Urge the EPA to Move Ahead with Clean Fuel and Tailpipe Standards

Echoing back to classic Cold War struggles, Russia has blocked Western European and U.S. efforts by apparently scuttling international plans to reduce hazardous pollution from ships starting in 2016. The “Tier III” amendment to the International Maritime Organization’s MARPOL standards would have required new engines that power the largest ships to include pollution control devices. These devices — such as selective catalytic reduction (SCR) — dramatically reduce the amount of nitric oxide and nitrogen dioxide (collectively known as NO_x) gases leaving a ship’s funnels.

The soot coming from this ship is a easy to spot. The NO_x pollution isn’t visible, but is hazardous nonetheless. Photo: Roberto Venturini/Flickr

NO_x pollution causes serious health effects. It can both cause and exacerbate lung diseases like asthma and emphysema and can aggravate heart disease. NO_x also reacts with volatile organic compounds in the presence of heat and sunlight to produce ground-level ozone, another harmful air pollutant. An international maritime NO_x standard is an important and needed tool to reduce air pollution from ship engines. Because many of the cargo ships entering U.S. ports are foreign-registered, international agreements are the most effective way to reduce harmful NO_x emissions in our ports and most importantly, the communities that surround them.

The U.S., along with Canada, has designated the waters around North America as the North American Emission Control Area (ECA) in an effort to reduce the impact of marine transportation on air quality. Limits on emissions from the largest ships were set because they are quickly becoming a major source of pollution in cities with busy ports. The EPA has estimated that large ships would be responsible for over a quarter of all NO_x pollution from mobile sources in cities like Seattle and Miami if the ECA and MARPOL standards were not enacted. In the North American ECA, the standards would have reduced annual NO_x emissions in 2020 by 320,000 tons, a 23 percent reduction.

The move by Russia to delay the standards will move the date for requiring devices like SCR on ship engines from 2016 to 2021. However, the delay is not final and has to be adopted by the IMO at the next meeting of the Marine Environment Protection Committee, which is currently scheduled for March 2014. The IMO could reverse its position on the delay and the U.S. has voiced strong opposition to the delay.

If Russia is successful and the delay is adopted, there are clear winners. Shipbuilders and shipping lines that are unconcerned about NO_x pollution and have ignored the SCR requirement avoid changes to their operations while companies that have made a good faith effort to research the compliance technology will be at a disadvantage. Of course, the clear losers are the residents of U.S. port cities who will have to needlessly suffer through years of NO_x pollution from dirty ships.

Over the last two weeks, large numbers of fires have broken out on the Indonesian island of Sumatra, and once again this has led to massive air pollution, carried to neighboring countries such as Singapore and Malaysia. This time, however, people could see not only the choking, dangerous “haze,” but also the locations of the fires, including which ones were on lands used by companies to produce palm, oil, pulpwood, timber, and other commodities. GIS technology and publicly available data, rapidly analyzed by scientists, brought a transparency to the issue that is so sorely lacking in the air over Singapore.

The leader in this analysis has been the World Resources Institute, as part of its Global Forest Watch 2.0 project. With an initial analysis released last Friday, followed up by a second on Monday and a third one just yesterday, they have mapped the fires, calculated how many were on each company’s land, and shown how the distribution of fires among land use types and companies has been changing from day to day. They have also compared this year’s fire season (so far) to previous years, demonstrating that the current situation is not an anomalous one.

As you would expect, there has been criticism of these results from the industries involved, but in fact UCS’s own independent analysis of the data confirms WRI’s findings. Our work on this was completely unplanned; it came about because Stu Sheppard, who does GIS studies as a consultant for UCS, happened to be traveling through Singapore last Friday and witnessed the air pollution firsthand. Here’s part of the message he sent us:

Wow! I’m in Singapore right now and can’t even leave the hotel. The air quality is the worst ever! Far worse than it was in 1997 even. Singapore is, to say the least not happy with Indonesia right now. They have live updates on tv… three hours ago it was 220 and they had announcements to stay indoors. Last live update says it is 368 now!!! (more sat images: http://www.nea.gov.sg/psi/)

He sent along an initial GIS map of the fires that he had done using NASA data that he downloaded from the National University of Singapore web site:

Map of the fires causing air pollution in southeast Asia, initially prepared by Stu Sheppard using two days worth of data

and also a picture indicating just how thick the pollution was:

Then he and UCS consultant Earl Saxon did a GIS analysis of two days of fire data (June 19-20), overlaying the fire locations with other layers such as the boundaries of concessions, the companies they belonged to, and the areas protected by Indonesia’s moratorium on deforestation and peat clearing.

Although Sheppard and Saxon used only two days’ worth of data (compared to nine in the initial WRI analysis), and got the NASA fire data from a different source, their findings were quite consistent with those of WRI. While few of the fires were  in logging leases, 21 percent were on oil palm concessions and 28 percent were on pulpwood plantations. Both groups also identified the same two commercial groups (Sinar Mas and APRIL) as the largest pulpwood plantation lessees. Here’s the data table showing the distribution of fire pixels in the province of Riau:

Table 1. Ownership, land use, number and proportion of Riau fires (19-20 June) prepared by UCS consultants Stu Sheppard and Earl Saxon.

You can see the full dataset that they used, in Excel format, at this UCS web location. As the table above shows, just over half of the fires are on land that can only be described as not-forest, not-peat, not-protected, and not-concession, because Indonesia has not released land tenure data since 2010. If current data, prepared for the Forest Moratorium maps, were in the public domain, then the relative roles of different business groups and government agencies would be clearer.

The excellent analysis done by WRI, in a matter of days, show just how much the ability of science to show what’s going on has advanced. Using data available on public websites, derived from satellite images and other kinds of remote sensing, analysts can quickly explain what’s happening based on evidence and not just opinion. Furthermore, other scientists can check and confirm their results, as has been so important with deforestation data from Brazil, gathered by the government agency INPE but independently analyzed by the NGO IMAZON. It’s what has long been fundamental to science – conclusions based on shared evidence and reviewed by one’s peers – but now it can be done in a matter of days.

To a scientist, having new data to study is like a child having a new candy store to explore. With the EPA’s release of new air pollution rules, I’ve just learned of the Willy Wonka Factory of data in my field of study. The rules require new air quality monitors near major roadways in US cities. The new data will ultimately help us better protect from harmful air pollutants the millions of Americans who live, work, and play close to major roads.

Fighting the good fight for clean air

Now before I out-nerd myself thinking about data analysis possibilities, let me explain why this is so significant (and exciting). As we’ve written about before, federally funded scientific research is being cut left and right. Science is taking hits from both budget cuts and political attacks. This is precisely the reason why it is so notable that we are seeing the launch of a large research undertaking.

Emissions from cars and trucks are the primary source of air pollution in many US cities and scientists know these emissions are harmful to the people living nearby. Measuring pollution near roadways can help make this science more robust. Photo Credit: Federal Highway Administration

And the project was not approved easily. This is the culmination of nearly 10 years of efforts by scientists—both in and outside the EPA—as well as other agency officials and advocacy groups. Under the new rules, many major metropolitan areas will be required, starting next January, to place four air pollution monitors within about 160 feet of major roadways, and some smaller cities will be required to place fewer monitors. The monitors will measure nitrogen oxides, fine particulate matter (soot) and carbon monoxide. All told, more than 100 US cities will have new monitors installed when the program is fully implemented.

Air quality matters

As a graduate student and postdoc, I studied the relationship between outdoor air pollutants and health effects. Specifically, I looked at the challenges health scientists face in studying this relationship because of the limited number of air quality monitors we have in US cities.

Are these monitors representative of air pollution across a city? Do the monitors capture the air pollution levels that people actually breathe in? And what about exposure to air pollution close to its sources—like near roadways and power plants? Are these sources responsible for the health effects we see?

These are the questions my research and the work of many other scientists seek to answer.

Having new measurements near roadways will greatly enhance our ability to answer these important questions and ultimately they will help us determine what policies and practices are needed to better protect people from harmful levels of air pollution. The implementation of the new rules will be essential, of course. Monitors will need to be placed close enough to roadways to capture the ultrafine particulates associated with cars and trucks, but there is great potential here. Strong evidence already exists that emissions from today’s cars and trucks are harmful to people. As more people move to cities, near-roadway exposures will only increase. And importantly, some populations are more affected than others. Research suggests that children may be more susceptible to health effects from road emissions and certain populations, including low-income populations, are more likely to live close to major roads.

On behalf of breathers… thanks

In order to address issues like these, we need the tools to help us get there. Only if we continue to collect basic monitoring data, can we begin to solve the science-based challenges we face as a nation and as a globe. And as a recent poll indicated, many scientists agree, believing that long-term, continuous monitoring and data collection is the biggest gap in our funding of scientific research.

Kudos to the EPA for implementing this rule, kudos to the countless scientists who demonstrated the need for this data, and kudos to the individual decision makers who helped make this happen. As Bob Yuhnke, former director of the transportation program at the Environmental Defense Fund who was integral to efforts to enact this change, said in response,  “On behalf of babies yet unborn, boomers with aging hearts and lungs, and breathers everywhere, many thanks.”

• TAKE ACTION: Urge New EPA Administrator McCarthy to Make Cleaner Gasoline and Tailpipes a Top Priority

Rep. Lamar Smith, Chairman of the House Science Committee seems to be implying that unless the raw data from two major studies are made available to him and his colleagues, that the science used by the EPA in crafting some air quality regulations is secret.  The Center for Science and Democracy at UCS was formed to advance the role of science and scientific evidence in public policy.  So should we be supporting Chairman Smith’s demand, which he has backed up by a subpoena?

Scientific evidence is more than raw data

I think not. Scientific evidence comes from a well-established and defined process. It includes the raw data, of course, but is so much more than just that. The process of science also includes the study design, data collection, analysis, interpretation, and peer review. And as part of this process, safeguarding the integrity of that science by revealing conflicts of interest, respecting the rights and privacy of research subjects, and ensuring the results are not manipulated by financial and political interests.

Chairman Smith is only focused on one piece of this process and is ignoring all the others, with no assurances of any kind that they will be respected. He has demanded, following a long line of industry complaints and previous objections to clean air rules, the raw data from two major studies, one conducted by researchers led by the Harvard School of Public Health, the other by the American Cancer Society.

Both studies, of course, had to comply with institutional and granting agency (both public and private in this case for both studies) requirements with regard to ethics, confidentiality, and research standards. As former Dean of Life Sciences and Agriculture at University of New Hampshire and for my own research, I can affirm that those requirements take time and attention, and they are never to be treated lightly. For example, academic institutions must have a review panel to evaluate any research proposal and make sure it complies with standards for the ethical treatment of any people involved in the study. If interviews are conducted or if any other data is collected from study volunteers, their privacy must be respected, including the confidentiality of any data collected from them. Further, institutions and granting agencies require conflict of interest disclosures in most cases, and the proposals undergo extensive, independent peer review as part of the selection process for funding.

Following approval by such research ethics boards, both of the original studies had to pass through independent peer review for journal publication as well as for consideration by the EPA in the course of crafting regulations. Because they concerned a highly controversial topic, the connection between particulates largely from fossil fuel burning (soot) and respiratory diseases including lung cancer, there were multiple layers of re-analysis and review by independent scientists. And it is apparent that these studies are part of a much larger body of scientific literature affirming the connection between soot and mortality.

Let’s not treat peer-reviewed science like a defendant on Court TV

Much of the discussion of the release of the data to the House Committee and the public has centered on confidentiality of the subjects.  But the larger issues are concerning the science process and what appears to be “shopping” for analysts to give a different result more to some interest groups’ liking. If the science process was followed, and a careful review was conducted of the analysis, why is it that the Chairman wants “independent” analysis of more than 20-year-old raw data?  Were not all the other studies in the literature independent? And if another analysis came to a different result, what would that mean? In the process of developing scientific evidence, there certainly are disagreements in methodology and interpretation. That’s all to the good. But my sense here is that Rep. Smith is viewing the scientific study as if in a courtroom, with the Perry Mason moment at hand as a new analysis is dramatically thrown in front of the witness. Good TV (for 40 years ago) but not much to do with scientific integrity.

The EPA has a tough job: implementing the laws that Congress has passed to protect the American public from the impacts of pollution. One of those impacts is clearly, from the scientific evidence, particulate matter or soot from burning fossil fuels. The Agency has made great strides in cleaning up our air, though a lot is still left to do. I am sure they would welcome additional scientific data collection and analysis on health risks from air pollution. Perhaps Congress should focus on funding new studies instead of simply criticizing already robust results they don’t like.

If you’ve been following the discussion of pollution risks around the unconventional oil and gas development that has been enabled by hydraulic fracturing and other technologies, then you’ve probably heard a lot about water contamination risks. These risks are certainly worth discussing, but discussion of air pollution risks also deserves some attention. We want to take the time to talk about air quality concerns—not just because this is where Gretchen’s past interests lie—but also because current research suggests there may be real risks from air pollution near oil and gas activities.

The UCS Center for Science and Democracy’s Branscomb Forum, Science, Democracy, and Community Decisions on Fracking, brought together experts to participate in discussions of these risks. One thing that struck us was just how multi-faceted the answer to a simple question was:

How does unconventional oil and gas development affect air quality?

The answer required participants to consider multiple pollutants—ozone, particulate matter, and hazardous air pollutants—being emitted from multiple places—well sites, compressor stations, roadways, and pipelines. Developing a simple answer quickly became challenging. One thing was clear: the question was most meaningful when all of the stages of oil and gas development, not simply the well completion step of hydraulic fracturing, were considered. Here’s what the research tells us and what we still need to know.

Risks to water quality may receive more attention but unconventional oil and gas development also raises concerns about air quality. Air pollution can be emitted at the well site and from truck traffic to and from the site. These risks vary widely by location. Credit: NIEHS/NIH

At the well site: measuring and modeling exposures

We know that exposure to elevated levels of the air pollutants mentioned above, from any activity, can lead to adverse health outcomes, including respiratory symptoms, cardiovascular disease, and cancer. And one recent study found that residents living less than half a mile from unconventional gas well sites were at greater risk of health effects from air pollution from natural gas development than those living farther from the well sites. Although the study relied on older data and used questionable exposure calculations, it does still imply that further study is needed on this subject to understand the level at which workers and nearby residents may be exposed to harmful air pollutants.

Air pollution from oil and gas development may be of greatest concern during the well completion phase, when most of the water and chemicals flow back from a well to the surface, and there is significant venting and flaring of gases. But because the venting and flaring occur at specific stages of the process and are not continuously emitting, their impact will vary depending on such factors as the number of oil and gas operations concentrated in a particular area and the existing air quality in a region. In addition, different regions of the country have different requirements for air pollution controls on oil and gas facilities, further adding to the variability of this concern. Southern California, for example, has much tighter air quality requirements for oil and gas operations than other areas.

Any onsite processing to separate gases from oil or other substances may also contribute air pollutants, especially ozone precursors. Residents of the town of Dish, Texas, for example, believe the health effects they have experienced—including nosebleeds, pain, and cancer—are the result of natural gas compressor stations that were installed in the town starting in 2005. To date, the residents have not been successful in proving the link. Some studies have found elevated concentrations of a number of carcinogenic and otherwise hazardous compounds in and around residential areas in Dish, but scientists have yet to find an association between the residents’ health concerns and the local gas facilities.

On the roads: the effect of truck traffic

While air pollution emitted from well sites may be of more interest, the bigger air quality change some communities experience may be from traffic. This is especially true in more rural areas, where the increase in truck traffic will be more significant. All kinds of truck traffic, including that for transporting water and materials to and from the well site, produce diesel emissions. Diesel emissions include particulate matter, which has been linked to decreased lung function, asthma, and respiratory symptoms such as coughing and difficulty breathing.

Air pollution from traffic may be worsened in North Dakota by the use of unpaved roads that incorporate gravel containing a fibrous mineral called erionite, which has properties similar to asbestos. Trucks driving over such gravel roads can release harmful dust plumes into the air, which could present health risks for workers and area residents

For some communities, the most significant air quality change from oil and gas operations may be from truck traffic carrying materials and waste to and from the well site. Credit: US Geological Survey

What about climate change?

While the potential health effects related to toxic air contaminants discussed above may be the immediate concern for most communities, the burning of any carbon-based fuel including natural gas contributes to global warming pollution. From a climate standpoint, use of natural gas is less attractive than lower- and zero-carbon alternatives, such as energy efficiency and renewable energy. On the other hand, the availability of relatively inexpensive and abundant supplies of natural gas has contributed to a reduction in coal generation and power sector carbon emissions in the United States.

However, several studies are underway that evaluate the leakage of methane during the life cycle of natural gas production, transport, and use. Methane is a potent heat-trapping gas, and the leakage studies suggest that the benefits of switching from coal to natural gas may be less than initially predicted. Last week UCS released a report on the climate risks of an increased reliance on natural gas for electricity. The report shows that transitioning from a coal- to a natural-gas- dominated electricity system would not be sufficient to meet U.S. climate goals.

Why don’t we know more? Restrictions on research and lacking laws

Research on air pollution from unconventional oil and gas development has been limited by a lack of information on and access to well sites and other facilities. Without access to such locations to carry out measurements and obtain information on the timing of different stages of extraction, it can be difficult to determine the source and extent of emissions and how and when people may be exposed to health risks.

 The federal Clean Air Act regulates the release of pollutants into the air from stationary and mobile sources and authorizes the EPA to set national ambient air quality standards, but the law included an exemption for certain groups of oil and gas wells. Pollution from such wells cannot be aggregated for the purpose of determining regulatory standards.

At the state level, few states require air quality monitoring near wells. Though some states do regulate venting or flaring at well sites, most do not have any comprehensive monitoring program. Such monitoring is needed for two important reasons: First, to detect any changes in air quality from oil and gas activities and potential for health risks for workers and nearby residents; and second, so that we know when and how to regulate air pollution from such activities to protect people.

Clearing the air: what can be done

Under new federal regulations, green completion technologies will have to be installed on most new gas wells by January 2015. The technologies capture air emissions from flowback water and fractured wells, capture a large percentage of volatile organic compounds (VOCs) and methane. Additional air emission restrictions will apply to certain wellhead compressors, storage vessels, pneumatic controllers, and other equipment.

Still, there have been remarkably few studies assessing health risks from air pollution near wells that employ hydraulic fracturing. To fully know the risks and to fully address them, researchers need access to well sites, stronger monitoring programs need to be in place, and companies need to provide information to researchers and regulators. We’ve got a ways to go before we can clear the air on air pollution from unconventional oil and gas development, but hopefully, these new regulations are a good start.

This week the EPA’s Clean Air Science Advisory Committee (CASAC) meets to discuss the science behind the national air pollution standard for ozone. The independent committee, which is comprised of air pollution and public health experts from a variety of institutions outside of the EPA, meets regularly to discuss the science on air pollution and health and to make recommendations to EPA on its air pollution rules. But this meeting in particular has greater interest from scientists, industry, and the public.

Overall, air quality in the US has improved in recent decades, but ozone pollution continues to be at levels that endanger public health in many places.

Why so much attention? Let’s recap the Obama Administration’s history on the ozone standard. Under the Clean Air Act, the EPA—every five years—must revisit its standards for ambient air pollutants (i.e. outdoor air pollutants) as part of the National Ambient Air Quality Standards (NAAQS). In 2011, the EPA reconsidered the standard for ground-level ozone, a pollutant that forms in the air from emissions of automobiles, industrial sources, and natural emissions. Following CASAC recommendations, the EPA concluded that the ozone standard should be set between 0.60 and 0.70 parts per million (ppm) in order to be protective of public health. This range would tighten the standard from the 2008 standard of 0.75 ppm. CASAC’s recommendation was sent to the White House for approval, but the administration chose not to update the standard despite the scientific evidence. Instead, the administration opted to kick the can down the road and wait until the next cycle of ozone standard review—the one CASAC is currently discussing—to consider whether the standard needs tightening.

The Power of NAAQS: Science

This 2011 political move wouldn’t be as notable if the White House had flexibility in setting the standard, but it doesn’t. Air pollution standards under NAAQS must be based on the science. This is written in the Clean Air Act and was affirmed by the U.S. Supreme Court in Whitman v. American Trucking Associations in 2001. In question was whether or not then-EPA Administrator Christine Todd Whitman could consider implementation costs in setting air pollution standards. The court affirmed that the administrator could not, writing that the Clean Air Act instructs the EPA to set “ambient air quality standards “the attainment and maintenance of which … are requisite to protect the public health.” (If, like me, you think the history of air pollution regulation is interesting, you might like this webinar I did for Engineers for a Sustainable World).

So why did the White House fail to follow the science in 2011? As my colleague Michael wrote then, the administration appeared to be influenced by a few factors. On top of the upcoming 2012 elections, industry was placing pressure on the agency and on the administration for the alleged costs associated with a tighter ozone standard. As we know from visitor logs, industry representatives met with White House staff and with EPA staff to discuss their concerns.

As a secondary pollutant, ozone forms in the atmosphere from emissions from a variety of sources, including automobiles and industrial pollutant sources. Photo: EPA AirNow

A science-based ozone standard in 2015?

But what will happen this time around? Will we see a science-based ozone standard in 2015? CASAC is currently discussing the state of science on ozone and its impacts on public health and welfare. In fact, you can watch it! For the first time, the meeting is being webcast here. They will review the Integrated Science Assessment (ISA), a 1,251-page document produced by EPA scientists that surveys the current scientific literature on ozone (including, I am proud to say, one of my own papers). Next, the committee of independent scientists will consider that science in making a recommendation to EPA for the ambient ozone standard.

Will the EPA and the Administration set a standard that listens to the advice of their scientific experts? For now, we know that the agency—and even their external scientific experts—appear to be getting the same pressure from industry we saw in 2011. Yesterday, 36 industry trade associations wrote a letter to CASAC—not to the EPA Administrator, mind you, but to the independent committee of scientists—pleading with the committee to consider and advise EPA about the “astronomical” costs to industry they claim will result from a tighter ozone standard. There is, of course, a place to discuss the economic impacts of EPA rules, but that place is not within a scientific advisory committee charged with assessing the scientific basis for a rule to protect public health and welfare.

We will be waiting to see if the agency and the administration can set a science-based standard, despite this and other pressure they might receive to do otherwise. In the meantime, let’s talk about the science.

A few months ago, the House Committee on Science, Space, and Technology took interest in a small piece of the tremendous amount of research—and funding of research—that EPA does on air pollution and its health effects. What were the lawmakers concerned about? They were purportedly worried about the adverse health impacts for people who participate in air pollution studies. The committee (whose direction and focus seem to have shifted in the past few years) requested that the EPA Inspector General (IG) investigate. That IG report was released yesterday and its conclusion is as follows:

“The EPA followed applicable regulations when it exposed 81 human study subjects to concentrated airborne particles or diesel exhaust emissions in five EPA studies conducted during 2010 and 2011. However, we identified improvements that could be made to the EPA’s policies and guidance to enhance its protection of study subjects.”

Our national air pollution laws rely on scientific studies of how air pollution affects our health–from biological and toxicology studies to large-scale population studies.

Despite this conclusion, the headline on the press release from the House science committee suggests something more sinister, in what can only be understood as the third installment in the committee’s efforts to attack the science that informs air pollution standards. (You can read about the prior attacks here and here). What the report actually found was some areas in which EPA could update its existing policies in order to better inform study participants of risks.

Why Do We Experiment on Humans?

But let’s bring it back to what these studies actually are. Since the nation’s air quality standards are based on science, it is essential that we have a solid and continually advancing understanding of how air pollution affects our health. To address this, EPA does research in areas ranging from toxicology studies to large-scale studies of populations in multiple cities.  All these studies contribute a different puzzle piece to our overall comprehension of air pollution’s health impacts. We need population studies to show us what is happening in real world conditions, we need laboratory studies to understand the biological mechanisms through which air pollution harms us, and we need people who participate in studies to understand how pollutants affect the human body.

Importantly, many scientific areas must work with people to move forward. Ever seen an advertisement for a clinical trial before? For drug development, scientists do a ton of research in laboratories to determine if drugs are safe and effective. But before that drug hits the market, it ultimately needs to be tested with people, not just on animals or on cells in a petri dish. So scientists conduct clinical trials with volunteers.

The Power of People

Clinic trials and other studies with volunteers help researchers advance scientific understanding and enable new medical advances and better public health protections. Photo: NIH

Before a university, a federal agency, or an individual does any sort of research using human subjects, it needs to get approved by an Institutional Review Board (IRB). IRBs have been around for decades. They uphold consistent and strict ethics standards for experiments that involve people. They were first developed in response to the notoriously unethical experiments in World War II and in Tuskegee. That’s why it is so offensive that that the former American Tradition Institute (now the Energy and Environment Legal Institute)  and Steve Milloy–who runs JunkScience.com and has a history of interfering with science–have made such extreme comparisons between these EPA studies and experiments conducted against people’s will and without their consent. This comparison is not only inaccurate, but insulting to the men and women who perform air pollution and health studies as well as the people who choose to participate in them.

Today, for drug trials, air pollution exposure studies, and anything else that involves people, participants first volunteer for such studies, and second, must sign informed consent documents. This means participants are provided with information about the risks posed. In the case of EPA, this procedure was followed. What the IG report did say about this was that the procedure should be improved by being applied more consistently across studies and that some additional risks should be noted, even if their probability is very small.

This is an important point. Volunteers deserve to know about any risks posed by their participation. In fact, this is their right. The EPA should take these recommendations from the IG report seriously and I hope they are implemented. But suggesting a policy improvement is very different than accusing a federal agency of conducting unethical experiments

Using Science, Saving Lives

The irony here is what actually saves lives when it comes to air pollution.  Let’s look at the numbers, shall we? The IG report concerned 81 study subjects, six of whom experienced “adverse effects” of any kind. The studies were done over a two-year period. In one year, air pollution causes some 200,000 premature deaths per year in the United States (and 35 times that number globally).  EPA air pollution standards save tens of thousands of lives every year compared to the air quality we would otherwise experience. But at what cost, you ask? Actually, economic analyses have shown that the existence of the Clean Air Act programs have had a net benefit of $22 trillion.

In other words, the same lawmakers who claim to be concerned with the wellbeing of 81 volunteers have opposed standards that prevent death and sickness of thousands of Americans. So is this really about public health? Or is it about attacking the EPA on any possible grounds? The latter seems more likely. If lawmakers are truly concerned about the health of the American people, I would recommend they do a simple scale analysis and focus their efforts on where they’re most needed.

Today the EPA’s chartered Clean Air Scientific Advisory Committee (CASAC) agreed on a recommendation to Administrator McCarthy regarding an update to the ambient air pollution standard for ozone (To get up to speed on the ozone standard update process, see my previous post on the topic). The deliberation of the committee and the Ozone Review Panel exemplified the challenges of translating science to policy and it was clear that the scientific experts on the panel had differing opinions on how this should be done.

The science-based ambient air pollution standard for ozone is updated every five years with input from scientific experts, the public, and other stakeholders.

What does the science tell us about ozone and health?

The Clean Air Act charges CASAC with recommending a value (or as they typically do, a range of values), to the EPA administrator based on what limit on pollution levels the science indicates will be protective of public health with an adequate margin of safety.

What should that value be for ozone? The panel agreed that 60 parts per billion (ppb) should be the lower limit of the range (note: this is the same lower limit that CASAC recommended in 2011). The committee concluded that 60 ppb continues to be the lowest level for which we have strong scientific evidence of health benefits. But what should the upper limit of the range be?

One way the committee thinks about this question is by focusing on susceptible populations, including children and the elderly. For these groups, we see marginal improvements in health outcomes at lower concentration of ozone, i.e. there are incremental improvements for lower and lower ozone levels. With this observation in the health studies, what then is the least restrictive standard that we consider to be “protective of public health with an adequate margin of safety”? The committee agreed that an upper limit of 72 ppb was inadequate to protect public health and that 70 ppb may be protective but only with a limited margin of safety.  Some members of CASAC pushed to go as low as 65 ppb based on scientific evidence, while others felt that there wasn’t sufficient evidence for this recommendation. “The question of what is an adequate margin of safety is a policy question, not a science one,” argued one CASAC member.

The making of a science policy decision

The conclusion? The committee ultimately agreed to recommend to Administrator McCarthy a range of 60-70 ppb for the primary ozone standard with the qualifier that the standard of 70 ppb ozone would have a limited margin of safety and thus would be less protective of public health than a lower standard would.  This qualifier provides additional scientific information for the administrator to consider in setting the standard, but the real question is how will the administrator interpret this scientific language in making her decision? Will she consider 70 ppb an adequate standard if it is included in the recommended range? Or will she consider this qualifying language to indicate that the science supports a lower standard to be protective of health? “We should recognize that this recommendation would mean that the administrator may set the standard at 70 ppb, recognizing it as our upper limit, and we [CASAC] would need to be comfortable with that outcome,” Christopher Fry, Chair of CASAC, noted in the meeting as the committee was deliberating this decision.

The ultimate question, of course, is how the administrator will interpret this. Next, CASAC will revise its draft letter to the administrator to reflect this morning’s discussion and we will wait and see how Administrator McCarthy decides to consider the scientific recommendations from its Clean Air Scientific Advisory Committee, when the final recommendation is on her desk.

Ever think that your rural backyard could face air pollution levels in excess of 100 times EPA health standards?  Jeff and Rhonda Locker of Wyoming didn’t think so either. But a new peer-reviewed study out in Environmental Health today suggests that such spikes in air pollution in your backyard are possible if you live next to an oil and gas facility.

Community exposure to chemicals

Citizens living near oil and gas facilities were trained to collect air samples, which were analyzed for volatile compounds. Photo: © Denny Larson

The study, released today by Coming Clean and Global Community Monitor, analyzed air samples at the fence line of oil and gas facilities in six states (Arkansas, Colorado, New York, Ohio, Pennsylvania, and Wyoming). Citizens living near the facilities were trained to collect air samples when they observed emitting activities at nearby facilities or when they experienced health changes such as dizziness, headaches, or breathing problems.

When the samples were analyzed, the results were concerning: Living near an oil and gas facility could be exposing you to unsafe levels of some pollutants including formaldehyde, benzene, 1,3-butadiene, and hydrogen sulfide.

The study is significant given how little research has been done on air quality around oil and gas facilities. More attention has focused on water quality impacts and the air pollution work that has been published is limited in scope. This study is unique in that it captures multiple U.S. locations, multiple types of facilities (well pad, compressor, waste pond, separator, work-over rig, and discharge canal), and was designed to capture elevated emissions.

This latter point is especially important because prior work has found that emissions from oil and gas facilities can vary widely, with some facilities only having major emission events during a narrow timeframe of activities (e.g. during the venting and flaring of natural gas). By having nearby residents take samples when such emissions appear to be present, we can get a better sense of what those peak emissions might look like and how they might be affecting the health of those living near such facilities.

Shedding light on fracking’s air quality impacts

But why hasn’t there been more research on air pollution at oil and gas facilities? As outlined in a recent UCS report, there are a few reasons for this.  Some researchers have had trouble conducting the research, given limited access to sites, limited knowledge of processes occurring (to pinpoint the step in the process causing particular emissions), and limited data sharing between companies, state agencies, and scientists.

Like all scientific studies, this research has limitations. It’s worth noting that this study is likely to capture worse cases of exposure because of when observations were taken and assuming some self-selection of participants. However, the fact that citizens are in fact experiencing these unsafe levels of pollutants at their place of residence, even if intermittently, is concerning for their health and does raise questions about the kind of exposures that aren’t being captured by state-run monitoring programs. As the study notes “state regulators’ studies are incomplete.”

Improving air pollution monitoring and protecting public health

This new research shows that we clearly need more research to inform air pollution management at oil and gas sites. We need better information about emissions—their frequency, severity, and the timeframes in which they occur. How widespread are the harmful levels of pollutants found in this study? Are workers adequately protected from these emissions?  Are there long-term health effects associated with living near oil and gas facilities? This research raises more research questions that need answering.

Two recommendations in the report echo those that UCS advocates:

• Better monitoring. We need baseline and ongoing monitoring programs to detect changes in air quality from oil and gas development. This can help us better manage emissions and their impact on public health because we would better understand when and how emissions occur. The monitoring results of this study demonstrate the urgent need for this.
• Full chemical disclosure. As the report notes, “regulators, public health officials, workers and citizens cannot properly safeguard public health if they are kept in the dark about chemicals in their communities.” Public safety should be prioritized over proprietary business information.

The results of this new study should help catalyze these changes.

UPDATE, November 18, 6:30 PM (see below)

Today and tomorrow, the lame duck House of Representatives will vote on two disingenuous bills that would prevent the EPA from using the best available science to protect human health and the environment.

Please call your member of Congress and ask for a NO vote on the EPA Science Advisory Board Reform Act and the Secret Science Reform Act. More information and talking points are here.

Don’t let Congress get away with sabotaging the science behind the EPA’s work to protect our health and safety. Call Congress today. Photo: NIAID

Even if you think your member of Congress has already made up her or his mind, she or he needs to know we are watching. It’s clear that the House leadership is trying to throw down the gauntlet regarding the type of legislation they plan to advance in 2015, and are trying to figure out how radical they will be permitted to be.

Here’s the skinny on each bill:

The EPA Science Advisory Board (SAB) Reform Act would expand corporate influence over the EPA by making it easier for scientists with financial ties to regulated industries to serve on the agency’s Science Advisory Board. At the same time the bill would make it more difficult for independent scientists to discuss their own research while advising the agency. This bill should receive a vote later today.

The Secret Science Reform Act would greatly limit the type of scientific information that the EPA can use to create and update public health protections, and would give businesses more ability to withhold critical data from the agency. We expect it to come up tomorrow.

The administration realizes what a bad deal this would be for the EPA, as President Obama has issued veto threats (here and here) for both bills.

If you care about limiting political and corporate influence over EPA science, call right now.

UPDATE, November 18, 6:30pm: The EPA Science Advisory Board Reform Act just passed the House. The good news is that it was almost exclusively a party line vote, with only one of the  four Democrats who voted for the bill returning to Congress in January (Minnesota Rep. Collin Peterson). In addition, one Republican (New York Rep. Chris Gibson) voted against the bill. A lack of bipartisan support makes bills like these less likely to make it into law.

The second bill will be up tomorrow, so there’s still time to call your representative and urge a NO vote on the Secret Science Reform Act. You can also express your gratitude if your representative voted NO today and your disappointment if she or he voted YES. See how your representative voted.

On a recent trip to Singapore, after the day’s discussion about how best to stop deforestation in Southeast Asia had ceased and the jet-lag was just beginning to take a hold of me, I hopped into bed to fall asleep. Or probably more accurately, I collapsed into bed. I turned on the television and what I saw on the screen was surprising.

The jolt wasn’t because of a startling newscast or culture shock. It was because of the presence of a small information box on the top left side of the screen reading, “24H PSI 53-55”–letting all residents know the current air quality in Singapore.

While watching television in Singapore, I noticed a 24 hour and three hour PSI or, Pollution Standards Index. The prominence of having it on the television served to highlight just how important (and changeable) air quality in the region is in the lives of residents. Photo: Lael K. Goodman

Days of haze

I shouldn’t have been surprised at the place the air quality index held in Singaporean everyday life. I’ve written before on the haze issue and I was finishing up a report, Clearing the Air: Palm Oil, Peat Destruction, and Air Pollution, on the effects of air pollution in Southeast Asia and its linkages to the palm oil industry. So I knew very well that haze frequently blankets areas in Southeast Asia, impeding daily life and causing health problems. These photos, taken in 2013 just three days apart, show just how thick the pollution can be.

These photos, looking toward Marine Parade Road in Singapore, compare the haze conditions on June, 21, 2013, to the clear conditions on June 24, 2013. The June 2013 haze event was particularly acute, severely limiting visibility in the region. Photos: Wikimedia Commons/Wolcott

The haze is composed of chemicals and particulate matter that come from large fires burning in the region. Winds spread these pollutants across Southeast Asia, affecting areas far from the original fire location.

The fact is that these fires and their resulting haze occur every year. The fires used to be much less frequent and on a smaller scale, but their frequency and magnitude have increased as the landscape in Indonesia and Malaysia has shifted towards agriculture, of which oil palm plantations comprise a significant amount.  When forests are cleared and peatlands (carbon-rich swampy soils) are drained to clear land for oil palm plantations, the landscape becomes much more flammable.

In early 2014, an analysis traced 11 percent of recent fires in Sumatra, Indonesia, to oil palm plantations. During the haze episode in the summer of 2013, around 20 percent of fires were located on land designated for oil palm plantations. And this number likely underestimates the contribution of the palm oil industry because not all of the land planted with oil palm or cleared for these plantations is in a database that allows land to be traced to a specific crop.

Fire is often used as a cheap agricultural tool to prepare land for planting. However, the combination of ecosystem destruction, a dry season that will likely only get drier in the future because of climate change, and the use of fire is a recipe for disaster.

Dangers to human health

What photos can’t show are the very real impacts of haze on human health. I feel lucky that when I was there, the air quality fell within the moderate zone, meaning that all persons, even those with higher risk factors, are recommended to maintain their normal activities. Although the air quality when I was in Singapore was not problematic, millions of others in the region are often exposed to this highly polluted air for days at a time.

And residents must simply endure. Many of the particles can infiltrate walls, so staying indoors is not a solution. The World Health Organization recommends that people stay in spaces with filtered air, such as air-conditioning – a luxury to which many do not have access.

Many residents will not experience any health impacts because of the haze. But others will. While there are a number of risk factors, such as the very young or old, those with preexisting conditions, or an occupation that involves physical labor during the haze episodes, anyone can be affected. Health impacts range from eye and skin irritation to breathing issues, cardiovascular problems, and even death. In fact, each year there are around 110,000 deaths associated with these landscape fires.

Something to talk about

The link between ecosystem destruction, landscape fires, and human health is so direct and so incredibly problematic that I wonder why more people aren’t talking about it around the world.

They certainly are in Southeast Asia. Besides the devastating impact the haze has on human health, it causes economic disruptions and puts on strain on diplomatic relations. Singapore took the unprecedented step of passing a bill last year, the Transboundary Haze Pollution Act, as an effort to hold entities (such as corporations or even individuals) liable for any involvement in landscape fires polluting Singapore’s air.

So while I escaped my trip to Singapore unscathed by the haze, I know I am lucky. Millions of others are affected with no recourse for action. But luckily there is something we can all do, by continuing to demand that companies ensure the palm oil they use is not contributing to the problem by making flammable landscapes through cutting down forests and draining peatlands.

And hopefully one day we may reach a point where residents don’t need daily reminders of air quality on their televisions because they can be assured that the air they breathe isn’t making them sick.

I’ve talked here, here, and here about the EPA National Ambient Air Quality Standards (NAAQS) update to the ozone standard.  Today is the last day of the EPA’s public comment period (to which I have submitted a comment). So I thought it would be a good time to do a quick review of the top five reasons the ozone standard should be strengthened in order to provide an adequate margin of safety for the most vulnerable populations—including the elderly, children, and those with lung diseases.

1. Ozone pollution causes health impacts, including respiratory problems, especially for vulnerable populations such as children, the elderly, and those with lung diseases like asthma. Photo: Gretchen Goldman

   The Science. As part of the update to the ozone standard, EPA conducts the Integrated Science Assessment (ISA). The 1,251-page document is produced by EPA scientists and surveys the current scientific literature on ozone (including, I am proud to say, one of my own papers). The peer-reviewed document finds several “causal” and “likely causal” relationships between ozone pollution and health effects. Of note, the report identifies “a very large amount of evidence spanning several decades [that] supports a relationship between exposure to O₃ and a broad range of respiratory effects.” In addition, the report finds associations between ozone and short-term cardiovascular effects and total mortality, along with long-term respiratory effects.

2. The Science. As I’ve written before, the Clean Air Science Advisory Committee (CASAC), or the group of external independent subject-matter experts that EPA uses to provide scientific recommendations for the standard, came to the conclusion that the standard should be tightened. In its letter to the EPA administrator, the science advisors recommended a range of 60-70 ppb for the standard. In addition, the committee concluded that although 70 ppb was included in its recommended range, such a standard would not provide an “adequate margin of safety,” as the Clean Air Act mandates.  The committee goes on to note that with a 70-ppb standard there is “substantial scientific evidence of adverse effects … including decrease in lung function, increase in respiratory symptoms, and increase in airway inflammation.”
3. The Science. The Ozone Review Panel is an additional set of external independent experts that works with CASAC to discuss the state of the science and review the ISA. These experts are brought in to provide additional expertise specific to ozone. This panel largely concurred with lowering the standard to something in the 60 to 70 ppb range as well, noting that a standard below 70 ppb would be more protective of public health.
4. The Science—including the old science. It’s worth reiterating that the above voices recommending a lower standard are joining those from the previous years. In fact, CASAC first proposed that the ozone standard be in the 60 to 70 ppb range back in 2007. (2007!)  To put that in perspective, in 2007 I still used a PalmPilot and hadn’t heard of Taylor Swift.  Our technology and music have evolved since then, and so too has ozone science.
5. The Science. The bottom line and the reason that these top five reasons are all one reason is precisely that. The law requires setting the ozone standard based on science and science alone. The administration must set a standard that is protective of public health with an adequate margin of safety and cannot legally consider economic arguments.  This latter point is notable given the degree of effort that some have been putting into making economic arguments against lowering the standard.  It sounds like some might need to review these five reasons—not cost arguments—that the standard needs to be lowered.

If you feel so inclined, please join me in supporting a science-based ozone standard by submitting a public comment here.

As I’ve been following, the Environmental Protection Agency is in the process of updating the national ambient air quality standard for ozone pollution. The standard is likely to be strengthened below the current standard of 75 ppb, due to the compelling scientific evidence linking ozone to adverse health impacts at this concentration. The EPA has proposed a standard between 65 and 70 ppb, narrowing the range advised by its independent science committee of 60-70 ppb, and the agency will issue a final rule by October.

Houston, Texas–with its sunny skies, hot temperatures and high volume vehicle traffic–is one of many U.S. cities that struggles with meeting the ozone standard. The proposed stronger EPA standard will better protect Houstonians from harmful ozone pollution. Photo: Flickr/Theodore Scott

This is an important issue in many cities that already have problems with ozone pollution. Houston, Texas, has struggled to meet the current ozone standard, leaving much of its population exposed to harmful ozone concentrations.  Meanwhile, the state also struggles with misinformation about the value of a tightened ozone standard.

To help dispel some myths and share the science of ozone pollution, I sat down with Adrian Shelley, Executive Director of Air Alliance Houston. Our interview, which was originally published in Air Alliance Houston’s weekly newsletter Air Currents, is copied below.

Adrian Shelley: Why is a new ozone standard necessary?

Dr. Gretchen Goldman: A new standard is a long time coming. For several years, scientists have been calling for a stronger ozone standard that better protects public health. Exposure to ozone pollution can cause several adverse health effects, including respiratory ailments, cardiovascular effects, and even death. Ozone exacerbates asthma, resulting in millions of missed school and work days for Americans. More and more, we are seeing these health problems occur even when ozone levels meet the current standard of 75 parts per billion (ppb). We know that this standard is not protective of public health, like the Clean Air Act requires.

AS: The EPA’s own Clean Air Scientific Advisory Committee (CASAC) recommended a standard between 60 and 70 parts per billion. What should the new standard be?

GG: We know the standard needs to be stronger. CASAC recommended the EPA set the standard between 60 and 70 ppb, but the group of scientific experts also noted that a 70-ppb standard might not protect public health with an adequate margin of safety. The scientists found that at 70 ppb of ozone, there is still “substantial scientific evidence of adverse effects … including decrease in lung function, increase in respiratory symptoms, and increase in airway inflammation.” Even though CASAC included 70 ppb in their recommended range, the scientific evidence suggests the standard should be lower. Some studies show that the standard should be 60 ppb in order to better protect public health of vulnerable populations, such as children, the elderly, and people with respiratory diseases.

AS: In Texas, we have heard from our state agency, the Texas Commission on Environmental Quality (TCEQ), that a new standard isn’t necessary. Is this true?

GG: This is untrue. The science and the law tell us that a new standard is absolutely necessary. It’s important to remember the history here. This isn’t new science. Back in 2007, the scientific experts on EPA’s CASAC recommended the ozone standard be set at 60 to 70 ppb. The group made the same recommendation in 2011 and today. The science has only gotten stronger. The Clean Air Act requires that standards be based on public health. Period.

AS: The TCEQ says that Texans are obese, and that it is more important that they go outside and exercise than worry about ozone pollution. Is that true?

GG: Yes and no. If you are a healthy adult, you are probably better off getting outside. Children, the elderly, and individuals with respiratory problems should pay closer attention to air pollution levels. We can all be more conscious of air pollution levels by knowing when harmful ozone days are likely. Check out houstoncleanairnetwork.com or the OzoneMap app for iPhone and Android, and sign up for ozone action days alerts at airnow.gov. It is also important to remember that there are typically only a handful of “bad air days” a year. Breathing high ozone concentrations isn’t something you need to worry about on a daily basis.

AS: What about the TCEQ’s argument that most people spend 90% of their time indoors, so EPA’s models of outdoor ozone pollution exposure are inaccurate?

GG: This argument doesn’t hold any weight. EPA uses lots of different kinds of evidence to assess the link between ozone pollution and health effects in order to ensure we have the best understanding. For example, EPA uses large epidemiologic studies that look at health impacts across entire cities. These studies specifically link outdoor ozone concentrations to health outcomes like asthma attacks, heart attacks, and even death. Science shows that outdoor air pollution affects our health.

AS: The TCEQ also points to an EPA study that shows that deaths in Houston could actually increase as we try to decrease pollution. What is that about?

GG: It is true that the complexity of ozone chemistry can sometimes lead to unexpected results. This is why scientists helping to develop State Implementation Plans to reduce ozone emissions need to evaluate how best to decrease ozone without making other pollutants worse. Ozone needs several ingredients to form: sunlight, nitrogen oxides (NOx), and volatile organic compounds (VOCs). NOx and VOCs are emitted directly from sources like cars and trucks, industrial sources, and some natural sources. In different parts of the country, ozone production is limited by either the amount of NOx or VOCs in the atmosphere. In order to reduce ozone, planners and scientists need to reduce emissions of the limiting compound. Ideally, ozone reduction plans should reduce both NOx and VOCs to ensure that ozone levels decline.

AS: TCEQ’s Chief Toxicologist Dr. Michael Honeycutt claims that this study shows that either lowering the ozone standard is a bad idea, or EPA doesn’t understand ozone science. Is this true?

GG: Let’s talk about the EPA’s understanding of ozone science. Every five years, the agency revisits the state of science on ozone. EPA scientists produce a 1,000+ page document called the Integrated Science Assessment that surveys all current scientific information on ozone and its impacts on human health. To help ensure that the assessment is comprehensive, the agency consults with its Clean Air Scientific Advisory Committee and creates an additional Ozone Review Panel of experts specifically on ozone. Overall, the EPA goes through several stages of scientific and external review to ensure that a high quality of science is informing their decision. If Dr. Honeycutt thinks the EPA doesn’t understand ozone science, I suggest he start reading their 1,251-page Integrated Science Assessment.

AS: So a strategy that reduces both nitrogen oxides and volatile organic compounds would potentially avoid this result. Are there any other benefits?

GG: Sure. Strategies for reducing ozone pollution are likely to have co-benefits. VOCs, for example, are associated with their own adverse health impacts, so by reducing VOCs, more people are protected from the harms of both ozone pollution and VOC pollution. We also can see benefits from having cleaner and more efficient industrial processes. These technologies decrease ozone but can also save energy, save money, and reduce many other harmful pollutants. Look at Corporate Average Fuel Economy (CAFE) standards, for example. These have decreased ozone along with a host of other pollutants and have also results in tremendous gas mileage improvements for Americans.

AS: What can Houstonians do to avoid the harmful effects of ozone pollution?

GG: Pay attention! First and foremost, Houstonians can stay tuned to houstoncleanairnetwork.com to monitor ozone in real time and limit their outdoor activities. To benefit their long-term exposure to ozone, Houstonians can tell decision makers they want an ozone standard that protects public health. The EPA takes public comments on its standards for ozone and other pollutants and Houstonians can always tell their representatives to support a science-based ozone standard that protects public health and follows the advice of EPA’s science advisors. Public support is key.

AS: What can Houstonians do to limit their contribution to ozone pollution?

GG: Driving less is a big one. Consider your commute time when you are choosing a place to live and choose more fuel efficient cars. Because our energy often comes from sources like coal and natural gas that emit air pollutants when burned, energy savings can also go a long way in terms of limiting your contribution to ozone and other air pollution. Get an energy audit, keep thermostats high in the summer and improve home insulation, for example. These things will limit pollution and also save you cash.

AS: Thank you for speaking with me today!

GG: Thanks so much for having me!

Do you own a 2.0L diesel vehicle made by Volkswagen or Audi from 2009 or after? I’m sorry to inform you, but according to the EPA your car has been polluting the environment at a level between 10 and 40 times its legal limit. Volkswagen and Audi, who manufacture the majority of diesel vehicles in the United States, have been cheating emissions tests instead of complying with more stringent smog-forming pollution standards.

Why this is a big deal

In 2007, EPA reduced the upper limit of nitrogen oxide (NO_x) emissions as part of its Tier 2 emissions program to address air pollution from passenger vehicles. Coincident with this, Volkswagen suspended sales of its diesel passenger vehicles, which could not comply with these standards that now forced diesel vehicles to be just as clean as their gasoline counterparts.

By 2009, however, the turbodiesels were reintroduced by Volkswagen—apparently under false pretenses. Volkswagen (under vehicles sold under both the VW and Audi brands) implemented software in the emissions controls package that only fully turned the emissions control systems on when the car was being smog-tested. This allowed it to pass emissions tests—but during normal driving conditions the vehicles continued to emit smog-forming pollutants at pre-Tier II levels, which were 10-40 times higher than required by law.

Roughly speaking, this means that even though diesel vehicles made up just less than 1% of vehicles sold last year, they could be emitting as much as 10-25% of all NO_x emissions from 2014 passenger vehicles on-road.

A disillusioned VW Bug sheds a tear upon hearing that its manufacturer showed such disregard for the environment. (Photo courtesy of David Preston)

This is exactly what the Tier 2 (and Tier 3) standards for which UCS has fought so hard was designed to protect against. Passenger vehicles should be held to the same standards, regardless of how they are fueled. It is critical that both the Environmental Protection Agency and California Air Resources Board take swift action to protect our environment, and they are: nearly 500,000 VW/Audi vehicles are now being recalled under the Clean Air Act to address this issue. Civil penalties could amount to as much as $18 billion in fines, as well as additional costs incurred as a result of fixing the issue.

What does this mean for diesel?

Volkswagen chose to game the system instead of complying, but not because they were forced. Diesel cars are capable of meeting stringent emissions standards—as a report from the International Council on Clean Transportation that played a significant role in uncovering this incident showed, real-world clean diesels do exist. While their high fuel economy does not directly translate into low global warming emissions, diesel can play a role in reducing global warming emissions without adversely impacting smog-forming pollution. What is critical, however, is that we continue to test and retest in conditions that most accurately represent how the vehicle is being driven in the real world to ensure that emissions standards are being met and environmental benefits truly achieved.

I’m personally exceptionally disappointed to see today a repeat of some of some of the gamesmanship we saw in the nineties with heavy-duty trucks—in my naïveté, I thought everyone agreed that cleaner air is a good thing. It seems like the “people’s car” might need to work a little bit harder in the future to make sure what it’s doing is good for the people and not just the bottomline.

Concerned your vehicle is one of the ones that might be emitting more pollution than you wanted? These are the affected vehicles that will be recalled: 2009-2015 VW Beetle 2.0L TDI; 2009-2015 VW Golf 2.0L TDI; 2009-2015 VW Jetta 2.0L TDI; 2009-2015 Audi A3 2.0L TDI; and 2014-2015 VW Passat 2.0L TDI.  If you own one of these vehicles, you should expect to hear from VW as part of the recall process, and it is VW’s responsibility to remedy this issue as soon as is feasible.

Last year, we released our semi-regular report card on the auto industry, the Automaker Rankings, where Volkswagen tied for 3^rd place behind Hyundai-Kia and Honda. However, the astounding news this month around VW’s diesel vehicles is not only a black eye on the company—it also calls into question just how “green” the VW fleet truly is. We’ve received a lot of questions about the impact this scandal has on their environmental performance, so I’d like to take the opportunity to address some of those questions.

Just how much pollution did VW’s vehicles really emit?

It’s a little difficult to assess the full extent of environmental damage all of the VW vehicles have caused given the limited data available thus far and the array of diesel vehicles affected. However, the vehicles that were tested have the exact same engines and emissions strategies used by the vehicles covered in our Automaker Rankings (from the 2013 model year), so we can reasonably extrapolate these results.

Using the data from on-road tests meant to represent “city” and “highway” driving, our assessment is that on average the 2013 Jetta, Golf, Beetle, and Audi A3 had on-road emissions of nitrogen oxides (NO_x) of 1.9 grams per mile (±0.7)—this is more than 25 times the allowable limit. The 2013 Passat had emissions of 1.0 grams per miles (±0.3), about 15 times the allowable limit.

For context, this adjustment means that the fleet of all-new vehicles sold in the US in 2013 emits about 8 percent more smog-forming pollution from the tailpipe than previously estimated, with Volkswagen’s diesel vehicles making up 8 percent of all smog-forming tailpipe emissions despite just 0.7 percent of overall sales (smog-forming pollutants include not just NO_x but also volatile organic compounds, which are typically emitted at higher levels in gasoline-powered vehicles). That means Volkswagen’s vehicles have been emitting far more than their fair share of these tailpipe emissions that contribute to smog and are linked to increases in hospitalizations and emergency room visits and even premature death.

Does the “defeat device” have an impact on fuel economy?

Given the limited data, it is difficult to say exactly what impact Volkswagen’s deception has on fuel economy, and even more difficult to say what would happen to the fuel economy of these vehicles with any sort of “fix” as they begin to recall these vehicles.

Looking at the data available, the Jetta Sportwagen reproduced its fuel economy label values in on-road performance, almost precisely and well within error. However, the Passat performed slightly below its label value in the on-road tests compared to its fuel economy label, though this discrepancy was not statistically significant. Therefore, while it is certainly possible and even perhaps likely that the “defeat device” may have resulted in inaccurate fuel economy testing, based on the limited available data we cannot say that there is any statistically significant impact on fuel economy. It’s also possible that once the defeat device is corrected, fuel economy performance of these vehicles could change. Without further information available, we’ve left the fuel economy values for 2013 VW’s unchanged.

Revising Volkswagen’s smog score to reflect the real on-road emissions of its diesel fleet shifts its score from 92.6 up to 114.8, tying it with Chrysler for the “dirtiest tailpipe” in the industry. (For reference, 100.0 represents the industry average.)

How does this affect the Automaker Rankings?

Adjusting for the on-road performance of Volkswagen’s diesel vehicles, Volkswagen’s score for smog-forming emissions increases by nearly 50 percent, from 93.1 up to 136.0. For context, this smog score is actually worse than the average 2005 vehicle!

Correcting Volkswagen’s smog score takes them from an overall 3-way tie for third place (with Toyota and Nissan) all the way down to a tie for seventh place with Chrysler. In other words, Chrysler now has company at the bottom—Volkswagen and Chrysler have the dirtiest tailpipes in the industry.

What does Volkswagen need to do now?

We have already heard from the CEO of Volkswagen America that there will need to be both software and hardware upgrades to the vehicles already sold in order for them to meet emissions regulations, and in the coming year they will begin a recall process to fix the issue. But what about new vehicles?

As Volkswagen looks to clean up both its image and its vehicle fleet, I urge them to examine the recommendation I made last year in our Automaker Rankings, which perhaps is even more true today: “[Volkswagen’s] diesel offerings offer only a small improvement over gasoline versions in global warming emissions. The company could do much more to reduce emissions from its overall fleet by promoting cleaner vehicles such as the Jetta Hybrid and new plug-in electric models such as the e-Golf.”

This Thursday, Volkswagen will be laying its cards on the table as to the severity of its diesel pollution problem and a path forward. It is required to present to a U.S. district court: 1) whether or not these vehicles can be fixed, 2) a definitive answer as to whether or not the EPA and Volkswagen have agreed on a remediation process for these vehicles; and 3) a timeline for this process. Because these vehicles also violated California’s own Low-Emission Vehicle program (LEV), any plan for remediation will also involve the California Air Resources Board (CARB).

As noted previously, the diesel vehicles that Volkswagen sold represent not just a black eye for the auto industry, but an environmental tragedy that must be remedied. Since I last posted on this subject, there has been a lot of news on the issue on how this could be resolved—while we will learn more on March 24^th, I think it’s important that we lay out some of the issues surrounding this situation now six months on.

VW might not be able to fix all vehicles…

When this scandal broke, it was clear that it might not be possible for VW to remedy all vehicles—after all, if they could have done this easily, why bother exposing the company to as much as $18 billion in penalties by cheating?

The first “clean diesel” car that VW sold in the U.S. was the 2009 Jetta; it used exhaust gas recirculation (EGR) to reduce smog-forming pollution during combustion along with a lean NOx trap (LNT) that adsorbs pollution from the exhaust, similar to the catalytic converter on a gas-powered car. This engine and emissions control system was later used in the Beetle, Golf, and Audi A3.

When VW adapted this engine for use in the Passat in 2012, engineers added selective catalytic reduction (SCR), which uses a chemical reaction between the exhaust and a liquid catalyst (typically urea) to reduce smog-forming pollution. In 2015, they then introduced an entirely new diesel engine platform that also used a combination of SCR and EGR, but with improved efficiency.

When the 2009 diesels came out on the road, their competitors wondered how VW could manage to meet emissions standards with just the EGR system to reduce smog-forming emissions. Now we know that the answer is that they couldn’t. These “first gen” vehicles would almost certainly require an added SCR system to meet the standards they were originally certified to, requiring hardware upgrades and modifications that may not be possible given the compact size of these vehicles. While it is much more likely that the second and third generation of vehicles which already have SCR could meet certification with modifications, to-date VW has not been able to prove that it is possible.

…but they may allowed to be left on the road anyway

From an environmental perspective, one of the most alarming things that has come to light recently is a statement at a California hearing by Todd Sax , chief of the California Air Resources Board enforcement division: “Our goal has been to fix these vehicles….Unfortunately, this may not be possible.  We will have to decide what the best approach is to dealing with these vehicles, and one of the options potentially would be to accept something less than a full fix.” (emphasis added)

Given the environmental damage these vehicles have done already and the continued damage that would be caused by allowing them to remain on the road, this is a concerning statement and it raises the question as to what should be done with any vehicles that cannot meet the standards to which they were originally certified. Forcing VW to buy back any vehicles that could not be fully fixed would not just eliminate future environmental risks, but it would also compensate consumers who were deceived by VW and have seen the resale value of these vehicles plummet. However, should EPA and/or CARB allow these vehicles to remain on the road, VW must be forced to offset the continuing damages.

The Volkswagen e-Golf is a lot more environmentally friendly than its diesel counterpart, but selling a few more of them won’t undo the environmental damage that “dieselgate” has caused.

Volkswagen could be “forced” to sell electric vehicles

Last month, a story broke that suggested EPA was going to force Volkswagen to produce electric vehicles at its Chattanooga plant as part of the settlement around “dieselgate.” Electric vehicles are a more environmentally friendly option than diesel, both in terms of global warming emissions and criteria pollution, and we are certainly in favor of increasing production of EVs as part of a sustainable transportation system.

However, it seems odd to include such a push as part of this settlement. CARB already requires that a certain fraction of Volkswagen’s sales must be electric as part of its Zero Emission Vehicle program, along with 9 other states who’ve adopted the program—therefore, Volkswagen will already be selling more EVs!

They’ve also already committed to spending millions on EV infrastructure. Moreover, with EVs expected to be a growing part of the fleet mix, any such “penalty” would simply be requiring VW to do what it’s already planning on doing—investing in technology to move it forward in the industry. This is not an appropriate trade-off to reduce penalties for environmental violations.

A better solution is about fixing the environment, not padding VW’s bottom line

If these diesel vehicles are here to stay, it is more important than ever that VW remedy the health of the public affected by these dirty vehicles. For that reason, EPA and CARB should be specifically targeting projects that would lead to the biggest smog reductions for the communities most impacted by the harmful effects of smog. Heavy-duty trucks emit more smog-forming pollution per mile than light-duty vehicles and remain on the road longer, which can make cleaning up this sector more difficult. Rather than focusing on cars, EPA and CARB may choose to focus on trucks.

Between 2003 and 2010, smog-forming emissions from a new heavy-duty diesel engine were reduced by 95 percent. However, the lifetime of heavy-duty trucks can be measured in decades, which means that vehicles manufactured well before 2010 continue to remain on the road, belching particulates and smog-forming NOx which poses health risks for the surrounding communities.

As part of any settlement, the EPA has the authority to set up a Supplemental Environmental Project, which would be funded by Volkswagen and can then be used for any remedial project. One strategy could be to set up a fund similar to the Diesel Emissions Reductions Act, which could accelerate fleet turnover and reduce emissions by retrofits or replacements. A portion of this fund could even be set aside for zero emission trucks, which are critical to reducing the impact of freight in densely trafficked areas such as ports and inner cities. Another area of critical importance could be to reduce the emissions from school buses, since children represent a particularly vulnerable population.

Volkswagen must be held accountable for its deception

Whatever we learn on Thursday, it is of the utmost importance that VW pay for its deception and remedy the damages of this corporate malfeasance. It is the role of the EPA and CARB to protect human health and the environment—a slap on the wrist and a nudge towards electrification is neither a suitable punishment nor remedy for the magnitude of this scandal. I look forward to seeing how Volkswagen, EPA, and CARB plan to make things right, and I hope above all that the settlement fits the magnitude of the crime, for the sake of the public and the environment.