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 s ervice organization of health professionals in the state of Utah. UPHE has over 2 00 members, most of whom are physicians or other health professionals. The rema inder are individuals educated in and practicing toxicology, chemical engineering, air qu ality modeling and permitting, biology, earth sciences and other related disciplin es.

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 havi ng a significant detrimental impact on regional air quality. Smog forming compounds an d other air toxics are released at virtually every phase of oil and gas drilling. Dril ling rigs emit a variety of air pollutants including NOx, carbon monoxide and VOCs. During we ll completion, tons of VOCs and methane may be vented or flared. Oil and natural g as condensate tanks and glycol dehydrators release VOCs. Compressor stations emit a variety of ozone-forming compounds, as well as other air pollutants. The in creased diesel truck activity will also significantly increase the total emissions of the d rilling projects.

According to data compiled by Rocky Mountain Clean Air Action and presented in 2007 to the Western Governors Association, a single EnC ana natural gas processing plant in Rio Blanco County has the potential to release nitr ogen oxides, carbon monoxide and volatile organic compounds equal to the emissions f rom 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 cit ies that consistently rank in the top ten worst in the country for acute spikes in air pollut ion, especially particulate matter. This past winter has been typical of the air pollution w e experience. The urbanized counties of Utah have had the highest levels of PM 2.5 in the country on several days, including one day where the PM 2.5 levels reached a value of 123ug/m 3 – exceeding EPA’s 35 ug/m 3
standard by 3.5 times!

During dust storms this spring we have had two days where the PM2.5 exceeded 250ug/m 3 ! Since the beginning of November, 2009, the most populated county in Utah, Salt Lake County, has had “yellow alert day” condit ions (>25 ug/cm3 PM 2.5 ) 22 times, and “red alert day” conditions (>35 ug/cm3 PM 2.5 ) 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 PM 2.5 and even smaller particles, the “ultrafines,” are responsible for health consequenc es far beyond what was understood even ten years ago. Because of the Wasatch Front’s indisputable problem with particulatematter (PM 10, PM 2.5 and ultrafines) and frequent exceedances of ozone s tandards, we

wish to stress the importance of the EPA considerin g cumulative impacts when reviewing standards and rules for oil and gas drilling that w ill further degrade our air quality and exacerbate the public health consequences.

To that extent I would like to give you a brief out line of the health consequences of air pollution so that you can appreciate why UPHE is co ncerned about permitting activity that will make our problem even worse.

As you can no doubt appreciate, the bureaucratic pr ocess virtually guarantees that the National Ambient Air Quality Standards ( NAAQS) enf orced through the Clean Air Act, lag behind current science often by many years. NA AQS have been steadily tightened since their inception as new medical research is re viewed. At present the EPA has proposed further tightening of the two criteria com ponents of pollution, PM 2.5 and ozone. Regional energy plans that call for more fossil fue l 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 increa sed understanding of the consequences of fossil fuel generated air pollution

.

Over 2,000 medical studies in the last ten years cl early 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 thre shold below which there is no health

effect. 3 For each 10ug/cm 3 increase in PM 2.5 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 healt h endpoints. These adverse effects are seen at low and ‘common’ concentrations of particul ate pollution. A Dutch study demonstrated risks for cardiopulmonary mortality ev en 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 PM 2.5 was associated with an increase in the risk of acut e ischemic coronary artery events (unstable angina and myocardial infar ction) of 4.5% 5 . Not only does PM 2.5 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 PM 2.5 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 resident s of the urban areas of Utah has the same type and magnitude of biologic effect as livin g 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 smok ing, PM pollution and ozone causeincreased systemic oxidative stress leading to path ologic vascular changes including

progression of atherosclerotic plaques to vulnerabl e forms, prothrombotic states, endothelial dysfunction and altered autonomic nervo us system control 8

.

Industry apologists often dismiss the significance of our air pollution spikes with the observation that our annual average PM concentratio ns are not extraordinarily high. This however is false comfort because many medical studi es show that impacts from pollution are seen very quickly and can last long after the a ir 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 a ssociated with increased rates of heart attacks as much as 300% compared to non-exposed ind ividuals 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 statem ent confirms the existence of a small, yet consistent association between increased mortal ity and short-term elevations in PM 10 and PM 2.5 approximately equal to a 0.4% to 1.0% increase in d aily mortality (and cardiovascular death specifically) due to a 10 ug/m 3 elevation in PM 2.5 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 jou rnal of the AHA, using data from over 1 million people, demonstrated that when cardiac mo rtality, the signature air pollution health outcome, was plotted against PM from air pol lution, first and second hand cigarette smoke, all three sources showed a steep c urve at low doses. In other words, per unit dose of exposure, low levels of PM actually ca used higher rates of mortality 12

.

Long term exposure to PM air pollution is associate d 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/m 3. in PM 2.5. A similar association was found

with the coarser PM 10. The rise was found in both systolic and diastolic b lood pressure 13

. Chronic exposure to PM has been shown to increase t he thickening of arterial walls which is a known end result of higher blood pressur e 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 t he 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 Hear t Association has estimated thatresidents of most cities in the U.S. lose between o ne 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 PM 10 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. O S is the mechanism behind air pollution's role in central nervous system dysfunct ion, neuroinflammation, cortical stress, cognitive impairment and memory loss in children an d neurodegenerative diseases such as Alzheimer's. Numerous studies show such specifi c clinical outcomes as impaired intellect among children who grow up breathing more air pollution 18-23 . Even rates of

neurobehavioral disorders correlate with NO

x and PM 10 levels 24

.

It is intuitive that PM and ozone would have advers e impacts on the pulmonary system. Indeed, numerous studies show increased rates of as thma and virtually all other respiratory diseases including lung cancer where ai r pollution is higher. Ozone is associated with increased rates of respiratory deat h 25 . Equally disturbing are less obvious outcomes. Even young healthy people demons trate rapid decrease in lung function from brief exposure to ozone or PM that pe rsists 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 ep isodic and therefore less of a problem.

Just as chronic exposure to second hand smoke cause s 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 p hysiologic 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 f low to the fetus 30 . Exposure of pregnant women to air pollution results in intraute rine growth retardation including smaller head size, increased rates of spontaneous a bortions, premature births and low birth weight syndrome. Genetic damage and epigenet ic changes can have virtually identical consequences and both can be passed on to subsequence generations. Newborn babies whose mothers are exposed to more air pollut ion show increases in both, and the life long disease burden that results can include h igher rates of metabolic disorders, reactive airway disease, cardiovascular disease, ca ncer, Alzheimer's and all the diseases consequent to immunosuppression. Epigenetic change s can be seen within as little as three days after exposure to air pollution 31-37

.

Various forms of cancer show increased rates with h igher concentrations of community air pollution. Especially troubling are the numero us studies that show increases in childhood leukemia among more exposed populations 39,39

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

physicians and the lay public alike to comprehend a nd the sight of a pregnant woman smoking is now repulsive to society at large. It i s 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 o ccurring in brief spikes or episodic patterns, as often exists in Utah, has sub stantial public health consequence. The implications for energy policy in the area of the C olorado 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 findin g 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 prema ture death and its conclusion was that 202 such deaths occur annually because of thes e 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 S cience 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 admi ssions, asthma-related emergency room visits and minor restricted activity days (MRA Ds), days in which people had to reduce their activities due to symptoms but could s till work.

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

of such outcomes as were mentioned above such as li fe long impaired lung function, increased rates of cancer, adverse consequences to pregnancy and embryonic development, increased rates of immunosuppression-r elated diseases, chromosomal damage, diabetes, and especially loss of intellectu al capacity and neurodegenerative diseases. If these pollution related consequences were to be calculated for their economic impact then the total externality costs would likel y 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 con tributing to air pollution have significant adverse economic consequences. Certainly this is t he case with the emissions of drilling

in the Colorado Plateau.

It is imperative that the EPA understand what the s cientific community has concluded about this unprecedented threat to the global envir onment and the human population. OnOct. 22, 2009, a cross section of Utah physicians a nd climate scientists organized by

UPHE, made a presentation to the public and the pre ss regarding the public health consequences of the climate crisis. Public health i n Utah and our individual patients are being impacted by climate change and will be even m ore 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 c limate consequences of the greenhouse gas phenomenon, “The biggest global health threat o f the 21st century,” and will, “put the lives and well being of billions of people at incre ased risk. Even the most conservative (climate) estimates are profoundly disturbing and d emand action. Less conservative climate scenarios are so catastrophic that adaptati on might be unachievable.” The American Medical Association has joined numerous ot her international medical organizations in acknowledging this threat and is c alling 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 ga ses” and recognized that “public education is critical to modifying behavior regardi ng greenhouse gas emissions.”

The scientific organizations throughout the world i n 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 jus t 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 proj ections are that Utah will see average temperatures as much as 10 degrees hotter by 2100.

Global public health consequences will be unprecede nted, 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 b e affected the most, no country will be spared and Utah will not be spared.

World wide food production and food security are al ready 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 clima te caused geopolitical destabilization that our own federal intelligence a gencies acknowledge represents the greatest future security threat to this country.

The climate crisis will have direct, predictable im pacts on public health in Utah including: more ozone pollution, more heat related illness, more frequent and intense dust storms, more wild fire pollution 1 , more vector borne and other infectious diseases, more vulnerability to pandemics and more exposure t o mercury contamination.Oil and gas drilling in the Colorado Plateau will h ave profound, direct and indirect public

health consequences. UPHE urges the EPA to conside r tight regulation of the industry part of its obligation to protect public health in Utah.

On behalf of the Utah Physicians for a Healthy Envi ronment Dr. Brian Moench, President

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