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COMMENTS ON THE DRAFT REPORT

APPENDIX C
C OMMENTS ON THE DRAFT REPORT • APPENDIX C

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Full comments on the draft HBHP report can be accessed

through the OAR docket (see the box on the right). A summary of

the comments is provided below. Comments were received from

over 40 individuals and organizations and represented a wide

array of perspectives.

A number of state officials acknowledged how important the

indoor environment is to public health, and that increased attention and resources are needed at the state and local level in order

to effect positive change. We agree with this, and hope that state

and local governments, as resources permit, seriously consider

implementing some of the potential actions contained in this

report. In addition, EPA and others need to partner with state,

local, and tribal governments as we begin to take action to

improve the indoor environment. Moreover, federal and state legislators need to consider funding sources for state, local, and tribal

involvement.

Several commentors wanted a more explicit recognition of the

interrelationship between indoor and outdoor air pollution, and

the important contribution that ambient pollution makes to the

indoor environment through natural and mechanical ventilation.

We recognize this important relationship, and have modified the

principles outlined in the final report to more fully make this connection. Moreover, the Office of Air and Radiation at EPA has

recently begun an air toxics pilot project in the City of Cleveland

to take an integrated look at both the outdoor and indoor sources

of air toxics, given the strong interrelationship between outdoor

and indoor air. When this pilot is successfully completed, EPA

hopes to replicate it in other urban areas across the country.

A number of commentors wanted us to more explicitly recognize

that combinations of pollutants (i.e., mixtures) may also be

responsible for poor indoor environmental quality. We agree with

this; the draft report specifically recognizes the dearth of research

on mixtures and calls for such research as part of any cross-Agency

research strategy in the “Potential Actions”section associated with

Goal 1.

ACCESS TO C OMMENTS

IN THE OAR DOCKET

Full comments on the draft

report can be accessed in docket number A-98-05 at:

Air and Radiation Docket and

Information Center 

Mail Code 6102 

Room Number M1500 

401 M Street, SW 

Washington, DC 20460

Phone: 202.260.7549

Fax: 202.260.4400

E-mail: a-and-r-docket@epa.gov
Some commentors wanted us to add much more specificity to the “Potential

Actions”section. For example, some commentors wanted us to specify particular building types, and, for each type, detail associated actions. We intentionally 

avoided this type of approach because certain universal needs exist across all 

building types. For example, under Goal 2, generating good cost/benefit data,

creating integrated designs, marketing attractive incentives, and promoting

good IEQ standards are common to all building types.

A number of commentors expressed concern that there were not more distinct 

references in the draft report to the importance of ventilation to good IEQ. We 

agree with the commentors on the importance of adequate ventilation and

good IEQ. While not explicitly addressed in many places in the draft, we

believe that ventilation issues will be addressed by several of the potential

action areas. For example, ventilation issues will be captured in “risk management research”under Goal 1, and are an integral part of “excellent IEQ 

standards of care”under Goal 3. However, we have made several changes 

in the final report to more specifically recognize the important link between

ventilation and IEQ.

Finally, some commentors pointed out that a section was needed to address

the legislative and regulatory (including building code) changes that will be

necessary to realize the goals outlined in the draft report. We acknowledge

that many approaches, voluntary, as well as regulatory, will be needed in order

to achieve healthier indoor environments. Those who embrace the vision and

goals of the HBHP report will need to decide the most effective approach to

implement the potential actions identified.

APPENDIX C • C OMMENTS ON THE DRAFT REPORT 99