Dear Mr. Parsons: 

My name is Dr. Brian Moench. I am the President of the Utah Physicians for a Healthy 

Environment (UPHE). UPHE is the largest community service organization of health 

professionals in the state of Utah. UPHE has over 200 members, most of whom are 

physicians or other health professionals. The remainder are individuals educated in and 

practicing toxicology, chemical engineering, air quality modeling and permitting, 

biology, earth sciences and other related disciplines. 

 

Our primary concern is the air pollution in Utah. There is no question that the rapid oil 

and gas development in the Colorado Plateau is having a significant detrimental impact 

on regional air quality. Smog forming compounds and other air toxics are released at 

virtually every phase of oil and gas drilling. Drilling rigs emit a variety of air pollutants 

including NOx, carbon monoxide and VOCs. During well completion, tons of VOCs and 

methane may be vented or flared. Oil and natural gas condensate tanks and glycol 

dehydrators release VOCs. Compressor stations emit a variety of ozone-forming 

compounds, as well as other air pollutants. The increased diesel truck activity will also 

significantly increase the total emissions of the drilling projects. 

According to data compiled by Rocky Mountain Clean Air Action and presented in 2007 

to the Western Governors Association, a single EnCana natural gas processing plant in 

Rio Blanco County has the potential to release nitrogen oxides, carbon monoxide and 

volatile organic compounds equal to the emissions from 43,000 cars! Oil and gas drilling 

in the Rocky Mountain region is expected to release 251,948 tons of nitrogen oxides 

annually by 2018, as much as over 13 million cars. 

As you may already be aware, the majority of Utah’s population lives in a very urbanized 

area covering several counties all of whom have cities that consistently rank in the top ten 

worst in the country for acute spikes in air pollution, especially particulate matter. This 

past winter has been typical of the air pollution we experience. The urbanized counties 

of Utah have had the highest levels of PM2.5 in the country on several days, including one 

day where the PM2.5 levels reached a value of 123ug/m3

 – exceeding EPA’s 35 ug/m3

standard by 3.5 times! 

During dust storms this spring we have had two days where the PM2.5 exceeded 

250ug/m3

! Since the beginning of November, 2009, the most populated county in Utah, 

Salt Lake County, has had “yellow alert day” conditions (>25 ug/cm3 PM2.5) 22 times, 

and “red alert day” conditions (>35 ug/cm3 PM2.5) an additional 22 times, 44 times in 

total so far this winter season. Furthermore, the entire Western US is having a steady 

increase in pollution from wild fires and new data suggest that represents an extremely 

toxic form of air pollution.1 

The most current health data suggests that PM2.5 and even smaller particles, the 

“ultrafines,” are responsible for health consequences far beyond what was understood 

even ten years ago. Because of the Wasatch Front’s indisputable problem with particulate 
matter (PM10, PM2.5 and ultrafines) and frequent exceedances of ozone standards, we 

wish to stress the importance of the EPA considering cumulative impacts when reviewing 

standards and rules for oil and gas drilling that will further degrade our air quality and 

exacerbate the public health consequences. 

To that extent I would like to give you a brief outline of the health consequences of air 

pollution so that you can appreciate why UPHE is concerned about permitting activity 

that will make our problem even worse. 

As you can no doubt appreciate, the bureaucratic process virtually guarantees that the 

National Ambient Air Quality Standards ( NAAQS) enforced through the Clean Air Act, 

lag behind current science often by many years. NAAQS have been steadily tightened 

since their inception as new medical research is reviewed. At present the EPA has 

proposed further tightening of the two criteria components of pollution, PM2.5 and ozone. 

Regional energy plans that call for more fossil fuel extraction and combustion will 

conflict with our compliance with current standards, let alone stricter standards. 

Regardless of the NAAQS, EPA rule making officials should be aware of the latest 

medical science that opens the window to our increased understanding of the 

consequences of fossil fuel generated air pollution. 

Over 2,000 medical studies in the last ten years clearly reveal that, certainly for PM and 

likely also for ozone, there is no “safe level” of exposure. Even levels previously thought 

to be benign we now know are not. There is no threshold below which there is no health 

effect.3 For each 10ug/cm3

 increase in PM2.5 long term average there is an increase in all 

cause community mortality rate of about 10%.3

. 

Since the late 1980’s more than 150 epidemiological studies reporting associations 

between daily changes in particulate air pollution and respiratory and cardiovascular 

mortality, hospitalizations and other related health endpoints. These adverse effects are 

seen at low and ‘common’ concentrations of particulate pollution. A Dutch study 

demonstrated risks for cardiopulmonary mortality even at what are considered 

‘background’ levels of particulate pollution 4

. 

A study done in our own area demonstrated that each short-term 10 mcg/cubic meter 

increase in PM2.5 was associated with an increase in the risk of acute ischemic coronary 

artery events (unstable angina and myocardial infarction) of 4.5%5

. Not only does PM2.5

result in an increase in death from cardiovascular causes but there is also an increased 

risk for non-fatal events 6

. For each 10 mcg/cubic meter increase in PM2.5 there was a 

24% increase in risk of a cardiovascular event and a 76% increase in the risk of death. 

There was also an increase risk of cerebrovascular events 7

. It should be noted that this 

rate of increase approaches that demonstrated from a chronic active smoking habit. 

Air pollution at the levels experienced by residents of the urban areas of Utah has the 

same type and magnitude of biologic effect as living with an active smoker. That should 

not be a surprise because most of the chemicals are the same. About the only one 

missing in air pollution is nicotine. As with smoking, PM pollution and ozone cause 
increased systemic oxidative stress leading to pathologic vascular changes including 

progression of atherosclerotic plaques to vulnerable forms, prothrombotic states, 

endothelial dysfunction and altered autonomic nervous system control 8

. 

 

Industry apologists often dismiss the significance of our air pollution spikes with the 

observation that our annual average PM concentrations are not extraordinarily high. This 

however is false comfort because many medical studies show that impacts from pollution 

are seen very quickly and can last long after the air has cleared. For example, within as 

little as 30 minutes exposure to particulate matter is associated with increases in blood 

pressure 9

, followed within hours by increased rates of heart attacks and strokes. 

Community mortality rates stay elevated for 30 days after an air pollution episode even if 

the episode lasts less than 24 hours. 

Within one hour, exposure to traffic pollution is associated with increased rates of heart 

attacks as much as 300% compared to non-exposed individuals 10. Other studies show 

rates of strokes and heart attacks in the community increase within hours after air 

pollution spikes 11

. 

Quoting from the American Heart Association (AHA)’s updated scientific statement 

published in May 2010 3

: “The overall evidence from time-series analyses conducted 

worldwide since publication of the first AHA statement confirms the existence of a small, 

yet consistent association between increased mortality and short-term elevations in PM10 

and PM2.5 approximately equal to a 0.4% to 1.0% increase in daily mortality (and 

cardiovascular death specifically) due to a 10 ug/m3

 elevation in PM2.5 during the 

preceding 1 to 5 days.” 

Not only have numerous studies shown that there is no safe level of PM exposure, but a 

recent landmark study published in the flagship journal of the AHA, using data from over 

1 million people, demonstrated that when cardiac mortality, the signature air pollution 

health outcome, was plotted against PM from air pollution, first and second hand 

cigarette smoke, all three sources showed a steep curve at low doses. In other words, per 

unit dose of exposure, low levels of PM actually caused higher rates of mortality 12

. 

Long term exposure to PM air pollution is associated with an average rise in blood 

pressure for urban populations chronically exposed. Average blood pressure was found 

to rise 1.7 mmHg for an increase of 2.4ug/m3.in PM2.5. A similar association was found 

with the coarser PM10. The rise was found in both systolic and diastolic blood pressure 13

. 

Chronic exposure to PM has been shown to increase the thickening of arterial walls 

which is a known end result of higher blood pressure

 14

.

 These finding are especially 

significant because they demonstrate community wide effects, impairing the health of 

everyone exposed, not just a susceptible population. 

Based on extrapolations from numerous studies and the afore mentioned AHA scientific 

statement, UPHE estimates that between 1,000 and 2,000 premature deaths occur every 

year in Utah from air pollution. The American Heart Association has estimated that 
residents of most cities in the U.S. lose between one and three years of life expectancy 

due to air pollution 15

. 

There is a remarkable correlation between rates of deep vein thrombosis an increased 

levels of PM, beginning at very modest levels 16. A likely mechanism of this clinical 

outcome is revealed by studies that show PM10 causes excessive platelet aggregation in 

diabetics 17

. 

Oxidative stress (OS) appears to be the biological genesis of numerous diseases processes 

and a major contributor to the aging phenomenon. OS is the mechanism behind air 

pollution's role in central nervous system dysfunction, neuroinflammation, cortical stress, 

cognitive impairment and memory loss in children and neurodegenerative diseases such 

as Alzheimer's. Numerous studies show such specific clinical outcomes as impaired 

intellect among children who grow up breathing more air pollution18-23. Even rates of 

neurobehavioral disorders correlate with NOx and PM10 levels 24

. 

It is intuitive that PM and ozone would have adverse impacts on the pulmonary system. 

Indeed, numerous studies show increased rates of asthma and virtually all other 

respiratory diseases including lung cancer where air pollution is higher. Ozone is 

associated with increased rates of respiratory death 25. Equally disturbing are less 

obvious outcomes. Even young healthy people demonstrate rapid decrease in lung 

function from brief exposure to ozone or PM that persists for several days after the 

exposure has ended 26,27. Again, this contradicts any comfort derived from the 

perspective that Utah’s air pollution problem is episodic and therefore less of a problem. 

Just as chronic exposure to second hand smoke causes a permanent loss of lung function 

growth in children, so does air pollution 28,29. Not only does that permanently impair the 

exercise capacity of individuals so affected, few physiologic outcomes have more of an 

ultimate impact on longevity than lung function. 

Air pollution, especially PM, may have its largest impact on public health through its 

affect on the human embryo. A study in laboratory animals demonstrated a change in 

morphology of the placenta that compromised blood flow to the fetus 30. Exposure of 

pregnant women to air pollution results in intrauterine growth retardation including 

smaller head size, increased rates of spontaneous abortions, premature births and low 

birth weight syndrome. Genetic damage and epigenetic changes can have virtually 

identical consequences and both can be passed on to subsequence generations. Newborn 

babies whose mothers are exposed to more air pollution show increases in both, and the 

life long disease burden that results can include higher rates of metabolic disorders, 

reactive airway disease, cardiovascular disease, cancer, Alzheimer's and all the diseases 

consequent to immunosuppression. Epigenetic changes can be seen within as little as 

three days after exposure to air pollution 31-37. 

Various forms of cancer show increased rates with higher concentrations of community 

air pollution. Especially troubling are the numerous studies that show increases in 

childhood leukemia among more exposed populations 39,39

. 
That all these outcomes can be the result of pregnant women smoking is easy for 

physicians and the lay public alike to comprehend and the sight of a pregnant woman 

smoking is now repulsive to society at large. It is a new thought process, but equally 

scientifically based, to think that the same thing happens when a pregnant woman has to 

breathe air pollution. Again, regarding impact on the human embryo there appears to be 

no safe threshold of exposure.

. 

PM air pollution, even well below NAAQS, and even occurring in brief spikes or 

episodic patterns, as often exists in Utah, has substantial public health consequence. The 

implications for energy policy in the area of the Colorado Plateau is difficult to overstate. 

UPHE has reviewed the recently made public Synapse Study that was commissioned by 

the state of Utah to explore the externality costs of the public health impacts of fossil fuel 

generated electricity in Utah. The relevant finding of the study was that approximately 

$1.7 billion was the current cost and by 2020 that was anticipated to rise to $2.4 billion. 

The signature health outcome of the study was premature death and its conclusion was 

that 202 such deaths occur annually because of these fossil fuel (primarily coal) power 

plants. 

UPHE believes the study was well done and credible. We note that the methodology 

used has been widely accepted by the EPA, the EPA Science Advisory Board, the 

academic literature, the U.S. Office of Management and Budget and the National 

Academy of Sciences. 

Furthermore, UPHE considered the estimate of health related economic impacts in this 

study to be a gross underestimate because the study limited its assessments to deaths, 

cardiovascular and respiratory caused hospital admissions, asthma-related emergency 

room visits and minor restricted activity days (MRADs), days in which people had to 

reduce their activities due to symptoms but could still work. 

This study clearly did not and could not reliably estimate the further costs of the long list 

of such outcomes as were mentioned above such as life long impaired lung function, 

increased rates of cancer, adverse consequences to pregnancy and embryonic 

development, increased rates of immunosuppression-related diseases, chromosomal 

damage, diabetes, and especially loss of intellectual capacity and neurodegenerative 

diseases. If these pollution related consequences were to be calculated for their economic 

impact then the total externality costs would likely be even many times higher. 

The relevance of this study to the issue of the EPA’s setting of standards for oil and gas 

drilling is that it is evidence that activities contributing to air pollution have significant 

adverse economic consequences. Certainly this is the case with the emissions of drilling 

in the Colorado Plateau. 

It is imperative that the EPA understand what the scientific community has concluded 

about this unprecedented threat to the global environment and the human population. On 
Oct. 22, 2009, a cross section of Utah physicians and climate scientists organized by 

UPHE, made a presentation to the public and the press regarding the public health 

consequences of the climate crisis. Public health in Utah and our individual patients are 

being impacted by climate change and will be even more so in the future. This adds an 

entirely new dimension to the urgency of addressing this evolving global crisis and 

should be part of the consideration for permitting drilling in the Colorado Plateau. 

The main stream medical literature is calling the climate consequences of the greenhouse 

gas phenomenon, “The biggest global health threat of the 21st century,” and will, “put the 

lives and well being of billions of people at increased risk. Even the most conservative 

(climate) estimates are profoundly disturbing and demand action. Less conservative 

climate scenarios are so catastrophic that adaptation might be unachievable.” The 

American Medical Association has joined numerous other international medical 

organizations in acknowledging this threat and is calling for actions to address it. The 

Utah Medical Association House of Delegates passed a resolution last year calling on the 

governor “to develop a plan to reduce greenhouse gases” and recognized that “public 

education is critical to modifying behavior regarding greenhouse gas emissions.” 

The scientific organizations throughout the world in are in agreement, that we have 

entered into the early stages of a climate crisis, the driving force of which is primarily 

man made. The scientific evidence for this is just as unassailable as the evidence that 

smoking causes cancer. 

The climate disturbances will include not just much hotter temperatures, but greater 

extremes of weather, especially drought and severe disruptions of the ecosystems that 

support the human population. Current climate projections are that Utah will see average 

temperatures as much as 10 degrees hotter by 2100. 

Global public health consequences will be unprecedented, and threaten the lives and 

health of billions of people with as much as 30% of the world’s population becoming 

climate refugees. Although poorer countries will be affected the most, no country will be 

spared and Utah will not be spared. 

 

World wide food production and food security are already under severe stress and almost 

certain to become much worse as the climate crisis deepens. Utah will be secondarily 

affected by increased commodity prices and by climate caused geopolitical 

destabilization that our own federal intelligence agencies acknowledge represents the 

greatest future security threat to this country. 

 

The climate crisis will have direct, predictable impacts on public health in Utah 

including: more ozone pollution, more heat related illness, more frequent and intense 

dust storms, more wild fire pollution1

, more vector borne and other infectious diseases, 

more vulnerability to pandemics and more exposure to mercury contamination. 
Oil and gas drilling in the Colorado Plateau will have profound, direct and indirect public 

health consequences. UPHE urges the EPA to consider tight regulation of the industry 

part of its obligation to protect public health in Utah. 

On behalf of the Utah Physicians for a Healthy Environment 

Dr. Brian Moench, President 

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