Statement of Deborah Shprentz

Consultant to the American Lung Association

EPA Public Hearing

On EPA’s Proposal to Retain the E xisting National Ambient Air Quality Standards (NAAQS) for Carbon Monoxide (CO)

and to Revise the Minimum Monitoring Requirements

February 28 , 2011

Arlington, Virginia

Good Morning. My name is Deborah Shprentz and I am a consultant to the American Lung Association.

I wish to offer some preliminary comments and observations on E PA’s proposal.

In brief, we believe that EPA must strengthen both the hourly and 8

- hour average standards for CO in order to protect public health.

We support efforts to extend the monitoring network to better capture roadside

concentrations but beli eve that EPA’s proposal is insufficient to accurately characterize ambient CO concentrations in situations of highest exposures.

The heart and lungs work together to deliver oxygen throughout the body and carbon monoxide impairs these functions.

As E PA is well aware, NAAQS must be set at levels that will protect the public health with an adequate margin of safety, including the health of sensitive populations. This means that uncertainties must be resolved in favor of public health protection.

The standards are to be based solely on the medical evidence: considerations: what level of CO is safe to breathe? Standards are not to be based on estimates of risks, exposures, costs, or technology. And the law is clear: where there is doubt, the Agenc y must include a margin of safety. With this recommendation, that has not happened.

In the case of CO, EPA has ignored the advice of its Clean Air Scientific Advisory

Committee f

avoring a lower standard:2 “It is important to acknowledge the decreases in ambient CO levels over time; however this success should not preclude an objective assessment of the potential health consequences of exposures at the current CO NAAQS. While

measured concentrations infre quently reach the current NAAQS , evidence

indicate s th a t adverse health effects could occur at these levels. For that reason, CASAC expresses its preference for a lower standard.” EPA

- CASAC

10

- 013, June 8, 2010.

The air quality standards for carbon monoxide were first established 40 years ago,

and the y have not been updated since then.

In large part, EPA’s argument for not strengthening the standards relies on the assumption that concentrations (as measured at central monitoring stations) have been greatly reduced due to controls on motor vehicles an d that the EPA exposure assessment indicates few “exposures of concern.”

CASAC has repeatedly advised EPA to give more consideration to the epidemiological studies that have reported a variety of health effects

– cardiovascular, reproductive, and respirat ory occurring at contemporary

concentrations. We agree.

EPA’s proposal is based on outmoded assumptions that do not reflect today’s

realities.

In the 1970’s, concern about CO was raised in the context of urban street canyons.

Today, we have sound b arriers lining major commuting routes that may have a similar effect in concentrating pollutants. However, we have no measurements of the concentrations that commuters or truck drivers might be exposed to on a daily

basis.

Today, we have an increase in exposures from gas

- powered off

- road engines that are poorly control led, such as offboard motors, generators, lawnmowers , and construction equipment.

Today, we are concerned about the exposures that an elderly heart patient might experience as they use a snowblower to clear a sidewalk surrounded by bank s of

snow.

What about exposures that occur near to the breathing zone of gardeners , as in the case of gas

- powered leaf blowers, chain saws, or trimmers ?

What about exposures in high

- altitude areas and during the wintertime when cold start conditions prevail?3

None of these are exposure scenarios are adequately addressed by the proposed

standard. No one is adequately protected by the current standards.

Today, we are concerned about cardiovascular effects as well as neurological, respiratory and reproductive effects.

We do not believe that EPA’s 2

- city risk assessment that relied on central site monitors and considered a limited range of health endpoin ts and exposure scenarios exonerates the current standards. To the contrary, we support the strengthened standards as contemplated in the Policy Assessment and favored by

CASAC.

Additionally, we oppose any efforts to relax the form of the standard from the current single exceedance approach to a 99 th or 98 th percentile form, which would in effect amount to a weakening of the current standards. We oppose revocation of the hourly standard.

In 2006, EPA unwisely eliminated ambient monitoring requiremen ts for CO, except for the NCore network. With this proposal, EPA is proposing to partially reinstate the monitoring requirements in 53 large cities.

However, this proposal is inadequate in several respects.

First, it relies on old monitoring technol ogy, which CASAC has stated is insufficient

to capture today’s concentrations

.

Second, a proposal to deploy 77 monitors nationwide is inadequate to capture all the concentrations of potential concern.

Third, we support a coordinated effor t to monitor highway air pollution, but a proposal this narrow can only be considered a pilot project.

The American Lung Association recommend s that the EPA not retain the nation’s

outdated

, 40

- year old carbon monoxide standards. Not only do the existing

standards fail to protect public health, they cannot possibly provide the required margin of safety. Instead, we recommend tha t EPA adopt standard s that provide protect the requisite protection :

We recommend retaining both the one

- hour and the 8

- hour averaging ti mes for the standard.

We recommend an 8

- hour standard of 3 ppm using a single exceedence approach

. We recommend a 1

- hour standard of 5 ppm using a single exceedence approach

.4

We recognize that these no

- exceedence standards fl y in the face of the drive for

“ regulatory certainty.” We disagree. The Clean A ir Act provision for protecting public health will lead to tighter limits on this dangerous and deadly air pollutant if the standard recognizes that unsafe levels that finally reach the monitoring network indicate a serious and unacceptable situation.