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Comments to SCAQMD Mobile Source and Stationary Source Committees

Regarding Fine Particulate Matter Health Effects

and 2012 Air Quality Management Plan

James E. Enstrom, Ph.D., M.P.H.

University of California, Los Angeles

jenstrom@ucla.edu

(310) 825-2048

January 18, 2013

1) The 2012 AQMP should comply with all provisions of California Health and Safety Code 

Section 40471 (b). Particularly important is the provision for at least one SCAQMD Governing 

Board hearing specifically devoted to the "report and peer review" of "the health impacts of 

particulate matter air pollution [PM] in the South Coast Air Basin [SCAB]." 

(http://www.leginfo.ca.gov/cgi-bin/displaycode?section=hsc&group=40001-41000&file=40460-

40471 ). No such hearings have ever been held, although they were supposed to be held in 2001, 

2004, 2007, 2010, and 2013.

2) The 2012 AQMP Appendix I Health Effects 

(http://www.aqmd.gov/aqmp/2012aqmp/DraftFinal/appI.pdf) seriously misrepresents and 

exaggerates the health effects and health impacts of PM in the SCAB and does not properly 

recognize the overwhelming evidence of NO relationship between PM (PM2.5 and PM10) and 

total mortality ("premature deaths") in the SCAB and California, as summarized in my 2012 

ASA paper (http://scientificintegrityinstitute.org/ASAS092812.pdf).

3) Many of the misrepresentations and exaggerations in the 2012 AQMP Appendix I Health 

Effects are also present in the 2003 AQMP and the 2007 AQMP. For more than one decade the 

AQMD staff has failed to properly address the serious criticism that has been raised about the 

AQMP Appendix I Health Effects. This criticism dates back at least to January 6, 2002 and 

February 8, 2002 letters from Advisory Council members to SCAQMD Executive Officer Barry 

Wallerstein ( http://www.aqmd.gov/aqmp/docs/prelim_draft_append%20Ihealth%20effects%20-Attachment%201%20Comments.pdf ).

4) The 2012 AQMP Socioeconomic Report 

(http://aqmd.gov/aqmp/2012aqmp/DraftFinalSocio.pdf) is severely flawed and must be redone 

by objective statisticians and economists. Table 3-4 on page 3-8 claims to show "the number of 

avoided cases (or person-days) by health effect when the Basin attains the PM2.5 standard in 

2014 and in 2023," with about 98% of the unit monetary value due to "mortality (adult and 

infant)." However, the unit monetary value for mortality is illusory because no deaths that will 

avoided "when the Basin attains the PM2.5 standard." There is overwhelming evidence of NO 

relationship between PM and "premature deaths" in the SCAB and California, as cited above.
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5) Until the numerous serious concerns that have raised about the 2012 AQMP are properly 

addressed, the SCAQMD Governing Board should not adopt any new regulations based on the 

2012 AQMP. In particular, there needs to be a 2013 Board hearing on PM health impacts in the 

SCAB, as per CHSC 40471 (b).

6) The Board needs to put the 2012 AQMP in perspective in light of these two highly relevant 

facts: 1) As of 2009 the SCAB had an age-adjusted total death rate lower than the death rate in 

every state except Hawaii and 2) as of September 2012 the SCAB had an unemployment rate 

higher than every state except Nevada and Rhode Island.

My full comments regarding the 2012 AQMP are 1) items U and NN in AQMP Public Comment 

Letters (http://www.aqmd.gov/aqmp/2012aqmp/commentletters/commentlist.html), 2) pages 

208-218 and pages 224-234 of AQMP Appendix I 

(http://www.aqmd.gov/aqmp/2012aqmp/DraftFinal/appI.pdf), and 3) pages 690-700 and later 

pages of the 4028-page Draft Final 2012 AQMP ( http://www.aqmd.gov/hb/attachments/2011-

2015/2012Dec/2012-Dec7-030.pdf).

http://www.bakersfieldcalifornian.com/opinion/our-view/x1801510372/Time-to-revamp-theClean-Air-Act

The Bakersfield Californian December 2, 2012

Editorial: Our View [Partial]: Time to revamp the Clean Air Act

Can you imagine banning all vehicles in the San Joaquin Valley? Or how about an all out 

prohibition on combustion of fossil fuels in the region? . . . What would happen if Los Angeles 

had to prohibit a quarter of its population from driving each day?

These are some of the more draconian requirements that would have to be imposed in order for 

the San Joaquin Valley and other regions of California and the country to meet the goals of the 

federal Clean Air Act as a result of antiquated provisions and various court rulings. . . .

As well-intentioned as the Clean Air Act is, we simply can't imagine that Congress, which 

approved the original 1970 Clean Air Act with just a single no vote in both houses, and which 

gave overwhelming bipartisan approval to major updates to the act in 1990, ever intended some 

of the consequences the law has created today. . . .

The San Joaquin Valley has a huge stake in the continued success of the Clean Air Act, but that 

success will require reforms and updates. The situation faced by air districts like the valley's and 

the numerous court rulings that have complicated implementation of the act warrant serious and 

prompt attention from federal lawmakers. . . .