:1: AMERICAN LUNG ASSOCIATION®
 1· Fighting for Air 

AlbertA. Rizzo, M.D. 

Chair 

National Board of Directors 

Ross P. Lanzafame, Esq. 

Chair-Elect 

National Board of Directors 

H. james Gooden 

Past-Chair 

Christine L. Bt·yant 

SecretaryrTreasurer 

Geri Reinardy, M.P.A. 

Speaker 

Nationwide Assembly 

Marcia D. Williams, Ed.D. 

Speaker-Elect 

Nationwide Assembly 

NATIONAL HEADQUARTERS 

Charles D. Connor 

President &. 

Chief Executive Officer 

130 I Pennsylvania Ave., NW 

Suite 800 

Washington, DC 20004-1725 

Phone: (202) 785-3355 

Fax: (202) 452-1805 

14Wall St. 

Suite SC 

NewYot·k, NY 10005-2113 

Phone: (212) 31 S-8700 

Fax: (212) 608-3219 

www.LungUSA.org 

June 25, 2012 

The Honorable Lisa Jackson, Administrator 

U.S. Environmental Protection Agency 

Air and Radiation Docket and Information Center 

Mail Code 2822T 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

Re: Docket ID No. EPA-HQ-OAR-2011-0660 

Dear Administrator Jackson: 

The American Lung Association writes in support of strong standards to reduce 

power plant carbon pollution. These proposed standards can play an important 

role in reducing the risk of adverse health effects associated with ozone ("smog") 

on our nation's most vulnerable populations, including children, the sick, and the 

elderly. Strong standards must be made final for the EPA to take an important 

next step toward ensuring that electricity is produced by the most modern, and 

least toxic, power plants. However, the American Lung Association urges the EPA 

to issue a strong proposal to cover existing power plant carbon pollution, the 

single largest source of greenhouse gas emissions in the United States. 

The Clean Air Act requires the EPA to regulate air pollutants from stationary 

sources. The Supreme Court ruled that greenhouse gases (GHG) met the 

definition of air pollutants in the Clean Air Act in 2007. In 2009, the EPA found 

that concentrations of GHG in the atmosphere endanger the public health and 

welfare of current and future generations by increasing temperatures and ozone 

pollution. This increase puts some of our nation's most vulnerable communities 

at greater risk for their health. 

To regulate a pollutant such as GHG, the EPA must list categories of stationary 

sources that cause or contribute to air pollution that could harm public health or 

welfare. Electric generating units (EGUs) are the largest stationary source of GHG 

in the United States. Energy accounts for 86 percent oftotal2009 GHG 

emissions,' and the electric sector represents 39 percent of all energy-related 

C02 emissions.' To regulate emissions from EGUs, the EPA must issue a new 

source performance standard (NSPS), which includes the Best System of Emission 
Administrator Lisa P. Jackson 

Environmental Protection Agency 

Comments on Docket ID No. EPA-HQ-OAR-2011-0660 

June 25, 2012 • Page 2 

Reduction (BSER), an achievable standard that considers cost and other factors. The proposed rule offers 

a new source performance standard for greenhouse gas emissions from electric utility generating units, 

commonly referred to as power plants. 

Carbon pollution can make reducing ozone much harder 

As carbon pollution builds up in the atmosphere, scientists believe that it will likely lead to increased 

temperatures. The increase in temperatures can increase the risk for formation of ground level ozone 

or smog. 

Ozone is a colorless, odorless gas that reacts chemically ("oxidizes") with internal body tissues, such as 

those in the lung. Ozone acts as a powerful respiratory irritant at the levels frequently found across the 

nation during the summer months. Breathing ozone may lead to shortness of breath and chest pain,' 

wheezing and coughing; 4 increased risk of asthma attacks;' increased susceptibility to respiratory 

infections,' and need for medical treatment and for hospitalization for people with lung diseases, such 

as asthma or chronic obstructive pulmonary disease (COPD) 7 and premature death' 

The most vulnerable individuals, including children, teens, senior citizens, people who exercise or work 

outdoors, and people with chronic lung diseases like asthma, COPD, and emphysema, are most in 

danger of being sickened by ozone 9 So-called "responders," otherwise healthy individuals who 

experience health effects at lower levels of exposure than the average person, are also susceptible to 

ozone.10 Children who grow up in areas of high ozone pollution may never develop their full lung 

capacity as adults. That could put them at greater risk of lung disease throughout their lives.11 

Many areas in the United States routinely experience concentrations of ground-level ozone that cause 

health problems. The United States has worked hard since the 1970 Clean Air Act to cut ozone levels, 

and reduced them by 13 percent between 2001 and 2010, according the EPA's most recent analysis of 

trend.12 However, millions of people live in places that still struggle to meet the 1-hour ozone standard 

set in 1979, including Los Angeles and Houston. As the evidence clearly shows that the current ozone 

standards fail to adequately protect public health, the challenge to provide air that is no longer 

burdened by unhealthful levels of ozone will continue for decades to come. 

As EPA noted in their 2009 assessment of the impact of climate change on regional air quality in the 

United States, many studies "have demonstrated connections between meteorological variability and 0 3 

concentrations and exceedances, implying the possibility of climate change leading to increasing O, 

levels in some regionS. 1113 

EPA's own modeling showed "increases in summertime 0 3 concentrations over substantial regions of 

the country as a result of simulated 2050 climate change," using the assumption that none of the 

precursor emissions decreased from "present day levels." EPA ran multiple models and in each of them 
Administrator Lisa P. Jackson 

Environmental Protection Agency 

Comments on Docket ID No. EPA-HQ-OAR-2011-0660 

June 25, 2012 • Page 3 

({climate change caused increased in summertime 0 3 concentrations" in ,,nearly every region of the 

1114 country.

As EPA noted, however, most models have not taken into account the reductions in ozone precursors 

that have been adopted and are in place. To address that challenge, a 2008 study by Wu, et al. used the 

model of the Intergovernmental Panel on Climate Change for 2050 (AlB) that incorporated decreasing 

emissions of ozone precursors in the United States, as current trends show. That study found that the 

drop in emissions reduces the U.S. summer daily ozone, but that climate change will take much of that 

back. Nor was the impact uniform: the Northeast and the Midwest were harder hit than the Southeast. 15 

The authors defined this as a "climate change penalty"-additional controls on emissions of ozone 

precursors that will be needed to reach the same level of ozone in the future than if the climate had not 

warmed. The penalty is substantial. These Harvard, NASA and Argonne National Laboratory scientists 

estimated that to reach the same ozone concentrations in 2050 will take as much as a ten percent 

greater drop in precursors such as nitrogen oxides than if climate change was not a factor. 16 

EPA's own 2009 analysis recognized this penalty and added others to the list. As EPA noted, the models 

show that the ozone season could be longer. The changes in weather patterns could affect the variability 

from year to year in the annual levels and extremes of ozone episodes. This will require more 

challenging assessment and planning, as well as more strategies to look at long-term air quality 

controls. 17 

The full impact of climate on ozone and other air pollutants is complicated. However, the best 

understanding shows that carbon pollution-aided climate change will increase the challenge to meeting 

future national air quality standards for ozone. The "climate change penalty" will add complications 

going forward. 

Strong standards will support the cleanest sources of electricity. 

Coal-based Electricity 

The American Lung Association opposes the construction of new conventional coal-fired power plants. 

The American Lung Association believes that the U.S. should not continue to expand its coal-fired 

generating capacity because of the extensive scope of health risks associated with the use of coal and 

the disproportionate impact on local communities. 

No other source of electricity has a greater impact on health and air quality. From the resource intensity 

of mining, to the air pollution associated with combustion, coal use generates a dominant share of the 

sector's impact. 
Administrator Lisa P. Jackson 

Environmental Protection Agency 

Comments on Docket ID No. EPA-HQ-OAR-2011-0660 

June 25, 2012 • Page 4 

Coal mining is one of the United States' most dangerous professions. The yearly fatality rate in the 

industry is 0.23 per thousand workers, making the industry about five times as hazardous as the average 

private workplace 18 The CDC has estimated that over 6,000 former miners died of coal workers' 

pneumoconiosis, also known as black lung disease since 2000. 19 The inhalation and accumulation of coal 

dust into the lungs also increases the risk of developing emphysema, chronic bronchitis, and chronic 

obstructive pulmonary disease. According to a study published in the American Journal of Public Health, 

people in coal mining communities have a 70 percent increased risk for developing kidney disease, 64 

percent have an increased risk of developing chronic obstructive pulmonary disease such as 

emphysema, and 30 percent are more likely to report high blood pressure (hypertension). 20 

Coal-fired power plants produce over 386,000 tons of 84 separate hazardous air pollutants from plants 

in 46 states, according to the most current data In the National Emissions lnventory21 • These plants 

produce 40 percent of all hazardous air pollutants released from industrial sources into the atmosphere, 

more than any other industrial pollution source. In addition, the combustion of coal to generate 

electricity also produces 76 percent of the total volume of acid gases, 60 percent of arsenic, and 46 

percent of mercury released into the atmosphere". 

Coal-fired power plants also produce nitrogen oxides (NOx) and sulfur dioxide that are harmful 

themselves, but also are precursors to ozone itself and particulate matter, especially in the eastern 

United States. 23 24 Evidence shows that PM 2.

5 causes cardiovascular harm and premature mortality and 

is likely to cause respiratory harm. The evidence suggests that long-term exposure to PM,_,causes 

reproductive and developmental effects as well as cancer, mutagenicity and genotoxicity-'5

• 

Even the transportation of coal increases health risks. The majority of coal is shipped by rail, with 72 

percent of all shipments in 2008 occurring by that mode of transportation. 26 Diesel locomotives are a 

source of NOx and PM emissions. Dust from coal stored in piles before transport or before it is 

com busted can become airborne particulate matter that adds to the burden on local air quality, 

especially on nearby communities. 

Because of these concerns, the American Lung Association supports the phase-out of conventional coalfired power plants as the nation transitions to a clean energy future. This includes support for policies 

that: (1) require the installation and operation of state-of-the-art air pollution control technologies and 

(2) encourage conversion to cleaner energy resources and/or permanent retirement of coal-fired power 

plants. 

As part of the transition to a clean energy future, the American Lung Association supports providing 

assistance to retrain coal industry workers and to help impacted communities transition to other 

economic opportunities. The American Lung Association additionally supports measures to improve the 

health and safety of coal mine workers, and the communities where they live, including protection from 
Administrator Usa P. Jackson 

Environmental Protection Agency 

Comments on Docket 10 No. EPA-HQ-OAR-2011-0660 

June 25, 2012 • Page 5 

harmful air pollutants. The American Lung Association firmly believes it is time to move 0way from 

using coal to produce electricity. 

Advanced Coal-based Electricity Technologies 

The American Lung Association does not support the construction of new advanced coal-based 

generating facilities, including carbon capture and sequestration and integrated gasification combined 

cycle plants. The Department of Energy has directed significant resources to the research and 

development of advanced coal technologies such as integrated gasification combined cycle (IGCC) 

power plants and carbon capture and storage (CCS). 

While each part of the CCS chain has been demonstrated, the technologies have not been integrated 

and demonstrated on a commercial-scale (greater than 300 MW) coal-fired power plant. Beyond the 

greenhouse gas benefits, CCS could also potentially drive 502 reductions. The current technologies for 

removing C02 from a power plant exhaust gas are very sensitive to 502 levels. As a result, conventional 

plants would have to install state-of-the-art scrubbers to remove so, from the flue gas prior to installing 

equipment to capture C02• 

Furthermore, neither IGCC nor CCS addresses the upstream impacts of coal use or the solid waste 

byproducts of the gasification or combustion. Additionally, the use of carbon capture technologies with 

IGCC or with conventional coal technologies can reduce the power generating capability ofthat plant by 

20 to 30 percent. This penalty increases the amount of coal that must be used to generate a unit of 

electricity at the plant. However, at a macroeconomic scale, it is not clear if the energy penalty would 

increase coal use. As the technologies increase the cost of coal-based electricity, they may dampen the 

demand for coal-based electricity. 

Since these advanced coal technologies have not demonstrated a reliable degree of technological 

certainty, operational capacity or cost feasibility, the American Lung Association does not support the 

construction of new advanced coal-based power plants. It also does not support the use of CCS or IGCC 

in existing coal-fired power plants. 

Biomass Combustion for Electricity 

The American Lung Association does not support biomass combustion for electricity production, a 

category that includes wood, wood products, agricultural residues or forest wastes, and potentially 

highly toxic feedstocks, such as construction and demolition waste. If biomass is combusted, state-ofthe-art pollution controls must be required. 

Biomass electricity generation involves extracting the energy from organic materials that part of the 

active carbon cycle (i.e. not fossil fuels). Most biomass facilities in the United States combust fuel to boil 

water and drive a steam turbine, similar to conventional fossil fuel operations. A variety of sources, 
Administrator Lisa P. Jackson 

Environmental Protection Agency 

Comments on Docket ID No. EPA-HQ-OAR-2011-0660 

June 25, 2012 • Page 6 

known as feedstocks, can potentially be used for biomass power production, including wood or wood 

pellets, forest wastes, and agricultural residues. Paper mill residue and lumber mill scraps may also be 

considered biomass. 

The environmental and health impact of biomass power is directly related to the feedstock from which 

the energy is derived. The choice of biomass feedstocks often presents a trade-off between cost, fuelquality, and environmental and health impacts. For example, urban waste, such as construction or 

demolition debris, is usually inexpensive relative to other biomass feedstocks, and combusting this 

debris at a biomass plant diverts it away from landfills. However, such waste may be of low-quality, 

meaning that more feedstock is required to produce a given amount of electricity, or contain high-levels 

of impurities/ resulting in greater air emissions. 

Biomass combustion increases the risk of the emission of noncarbon air pollutants. Electricity 

production from biomass releases many of the same air pollutants as fossil-fuel generation, although 

the quantities may differ substantially on per MWh basis. Particulate matter (PM) emissions are the 

most significant health threat from biomass power plants. Without controls, combustion of wood and 

wood wastes for power production can result in PM emissions that are more than 20 percent higher 

than emissions from an uncontrolled coal plant. Emissions of carbon monoxide and volatile organic 

compounds (VOCs) can be more than 400 percent and 2,000 percent higher than emissions from a coal 

plant, respectively. In contrast, NOx emissions may be nearly 60 percent lower and 502 emissions are 

virtually eliminated27 

Wood wastes, such as construction and demolition debris, may also contain toxic air pollutants." The 

potential for toxic emissions from construction and demolition debris varies, depending on state fuel 

standards"). Like fossil fuels, biomass combustion also emits other hazardous air pollutants. The 

impact of these emissions on human health is generally similar to the impact of emissions from fossil 

fuel combustion. Limited data are available on how various feedstocks affect overall emissions from 

biomass power. 

Producing electricity from biomass also releases C02 into the atmosphere, as well as small amounts of 

methane and nitrous oxide. Biomass energy has the potential to reduce carbon dioxide emissions 

because the C02 released can be balanced by the C02 captured in growing the feedstock. However, the 

overall C02 benefit depends on how much energy was used to grow, harvest, and process the fuel. 

The American Lung Association acknowledges that pollution from the combustion of wood and other 

biomass sources poses a significant threat to human health, and supports measures to transition away 

from using these products for heat production. 

Natural Gas-based Electricity 
Administrator Lisa P. Jackson 

Environmental Protection Agency 

Comments on Docket ID No. EPA-HQ-OAR-2011-0660 

June 25, 2012 • Page 7 

The American Lung Association supports the increased use of natural gas as a transitional fuel for the 

production of electricity as a cleaner alternative to biomass, coal and other fossil fuels. Natural gas 

exploration, extraction, production and transmission can create air pollution, including emissions from 

the use of diesel engines. While the American Lung Association has recommended that EPA strengthen 

proposed rules for natural gas extraction, the emissions from natural gas combustion for electricity 

generation are much lower than that of coal. As the National Research Council report stated the 

comparison: "[O]n average, nonclimate-change-related damages associated with electricity generation 

from natural gas are an order of magnitude lower than damages from coal-fired electricity 

generation." 30 The report also concluded that natural gas powered electricity plants emitted 

approximated halfthe co,." 

The American Lung Association supports public policies requiring the installation and operation of stateof-the-art pollution control systems at new and existing natural gas-fired power plants. The American 

Lung Association also supports programs and policies to protect air, water, and other environmental 

resources during the exploration, extraction, production, and transmission of natural gas, including 

hydraulic fracturing. 

The proposed rule will not limit power plant development. 

Department of Energy projections indicate that the proposed rule would have little to no impact on the 

development of future power plants, because it is estimated that almost all future power plants will 

employ a natural gas combined cycle (NGCC). This is due to low natural gas prices, renewable portfolio 

standards, and new technology. The NGCC model can easily meet the proposed standard, because, on 

average natural gas combustion results in half the C02 emissions of coal per MWh of energy 

generated." In fact, 95% of the NGCC facilities that started between 2006 and 2010 already meet the 

proposed standard." The proposed rule supports the increasing industry standard of natural gas 

combined cycle technology. 

If coal-fired power plants are built in the future, these power plants must install sufficient carbon 

capture and storage (CCS) technology and other controls to reduce CO, and other air emissions. As 

noted earlier, however, this will not address the upstream impacts of coal extraction nor the 

downstream impacts of the byproducts of coal combustion. 

The American Lung Association does not support coal-fired power plants or CCS technology. The Lung 

Association does support the increased use of natural gas as a transitional fuel for the production of 

electricity, as a cleaner alternative to biomass, coal and other fossil fuels. 

EPA should strengthen the proposed rule. 
Administrator Lisa P. Jackson 

Environmental Protection Agency 

Comments on Docket ID No. EPA-HQ-OAR-2011-0660 

June 25, 2012 • Page 8 

The American Lung Association supports the proposed rule because it will reduce harm-inducing C02 

from the atmosphere by reinforcing incentives for cleaner electric generation, without imposing 

hardship on the electric power industry. However, the Lung Association urges EPA to take several steps 

to strengthen the rule and reduce the potential for unintended consequences. 

Carbon pollution limits should be tighter. 

The EPA is proposing a carbon pollution limit of 1,000 lbs of C02 per MW hr. The American Lung 

Association urges EPA to set a lower carbon pollution standard. The EPA has noted the overwhelming 

trend towards natural gas combined cycles, which easily meet the proposed standard. The proposed 

rule notes that "(a]lmost all the stationary combined cycle gas turbines built in the U.S. in the last five 

years can meet the proposed standard."34 It would appear that a higher standard for NGCC would be 

easily met. In fact, New York State is proposing a carbon pollution limit of 925 lbs of C02 • New York 

State's proposed limit includes an conservative emission allowance to accommodate uncertainties in 

technical issues about technical issues, and allows oil-based power production for up to 45 days a year. 

Reporting and Enforcement mechanisms should be strong 

The American Lung Association supports power plant pollution reporting on a 12-month rolling average 

basis. This arrangement benefits power plants, the EPA, and the public. A 12-month reporting 

requirement allows power plants to account for variable pollution levels throughout a month, and 

allows the EPA to intervene quickly if pollution levels are too high. A 12-month rolling period would also 

allow the public to view emission levels every six months. This transparency and accountability is vital as 

the EPA moves forward with regulating carbon pollution. 

The EPA should not exempt modified and reconstructed power plants. 

The American Lung Association does not support exempting carbon pollution from existing power plants 

that are modified or reconstructed in future years. EPA states that it does not have an "adequate 

basis...to develop standards of performance for modifications,''" but does not consider other 

alternatives to the outright exemption of carbon pollution controls. The exemptions in the proposed 

rule may lead to unintended consequences. For example, inefficient, aging power plants could avoid 

decommission by expanding capacity under the guise of a modification or reconstruction. Such an 

increase in capacity would lead to an increase in unchecked carbon pollution. 

Rather than exempt all reconstructions and modifications, the American Lung Association urges the EPA 

to set a threshold for this exemption. The State of New York is finalizing carbon pollution regulations 

that require an existing power plant, which is otherwise exempt, to be treated as a new power plant 

once it expands capacity by 2SMW or more. In its analysis, New York found that this requirement would 

not affect changes made to increase efficiency." The American Lung Association supports a similar 
Administrator Lisa P. Jackson 

Environmental Protection Agency 

Comments on Docket ID No. EPA-HQ-OAR-2011-0660 

June 25, 2012 • Page 9 

threshold for modified or reconstructed power plants. Otherwise, the EPA risks creating a loophole for 

power plants to expand capacity without being accountable for additional carbon pollution. 

The Lung Association is particularly concerned that this broad exemption could circumvent or 

undermine the application of the "new source review" authority under Section 111 of the Clean Air Act. 

The U.S. Supreme Court ruled unanimously in 2007 that new source review requirements applied to any 

physical or operational change that increases a plant's actual annual air pollution emissions." New 

sources include sources that modify or reconstruct their facilities and increase emissions must not be 

exempted from review in the future. 

The EPA should not exempt biomass-fueled power plants. 

As stated previously, the American Lung Association does not support biomass combustion for 

electricity production. The proposed rule exempts biomass-fired boilers that co-fire with less than 250 

MMBtu/h of fossil fuel. The American Lung Association opposes exempting any level of biomass-fired 

electricity. 

The environmental and health impacts of biomass power are directly related to the feedstock from 

which the energy is derived. The choice of biomass feedstocks often presents a trade-off between cost, 

fuel-quality, and environmental and health impacts. Biomass-fueled electricity increases the risk of 

additional amounts of carbon monoxide, VOCs, and particulate matter. Any overall CO, benefit depends 

on how much energy was used to grow, harvest, and process the fuel. In 2011, the EPA itself noted it 

must "conduct a detailed examination ofthe science associated with biogenic C02 emissions from 

stationary sources, ... and resolve technical issues in order to account for biogenic C02 emissions in ways 

that are scientifically sound and also manageable in practice"" while determining biogenic C02 pollution 

from PSD and Title V applicability under the Clean Air Act. 

The American Lung Association urges the EPA to strike the biomass exemption, given the complexity of 

determining biomass feedstocks, overall C02 pollution, and impacts of biomass-fired electricity on air 

quality. 

The EPA should not exempt simple cycle turbines. 

The American Lung Association does not support the exemption of simple cycle turbines. Though simple 

cycle turbines are not often used for baseload generation, the high carbon pollution associated them 

and the potential for perverse incentives require the EPA to devise a standard for with simple cycle 

turbines. 

Because they do not recapture waste heat, simple cycle turbines are generally less efficient and pollute 

more carbon than combined cycle turbines, but they are less expensive than a combined cycle unit. 

Simple cycle turbines are often used to provide electricity during peak times or to offset the startup 
Administrator Lisa P. Jackson 

Environmental Protection Agency 

Comments on Docket 10 No. EPA-HQ-OAR-2011-0660 

June 25, 2012 • Page 10 

delays of a combined cycle, and the proposed standard notes that few simple cycle turbines generate 

more than one-third of their output for sale. However, this is not an insignificant amount of output, or 

an insignificant amount of associated pollution. The outright exclusion of simple cycle units from the 

proposed rule creates an incentive for power plants to use these less expensive, less efficient and more 

polluting units. Under the proposed rule, if a future power plant needs to generate more electricity, it 

could be less expensive, albeit less efficient, to add pollution-exempt simple cycle turbines than a moreefficient combined cycle unit that is subject to carbon pollution standards. 

The EPA should note that the State of New York is poised to regulate carbon pollution for simple cycle 

turbines. New York's proposed standard limits simple cycle carbon pollution to 1,400 lbs C0 2 per MWh. 

This standard was developed with considerations for the necessity for peak usage and allows simple 

cycle turbines to operate on oil85 percent to 100 percent of the time. 

The EPA should not exempt power plants that combust solid waste. 

The American Lung Association does not support the proposed rule exemption of power plants subject 


to Clean Air Act §129 (solid waste combustion). Solid waste combustion, i.e., the direct combustion of 


municipal solid waste or the use of gas captured at landfills, raises environmental and air quality issues. 


Municipal solid waste contains a diverse mix of waste materials, some benign and some very toxic. 


Toxic materials include trace metals such as lead, cadmium and mercury, and trace organics, such as 


dioxins and furans. These taxies pose public health and environmental problems if they are released 


into the air with power plant pollutants. Additionally, landfill gas consists primarily of carbon dioxide, 


methane, and non-methane organic compounds. Without strict controls on taxies and carbon pollution, 


the proposed rule could increase the dangerous emissions from the use of solid waste-fueled electricity. 


The EPA should not exempt combined heat and power units. 

The American lung Association does not support the exemption of combined heat and power (CHP) 

units. Combined heat and power (CHP) systems, also known as cogeneration, generate electricity and 

useful thermal energy in a single, integrated system. 

CHP is more method than technology. Heat that is normally wasted in conventional power generation is 

recovered as useful energy, which avoids the losses that would otherwise be incurred from separate 

generation of heat and power. Though the American Lung Association supports federal policies that will 

drive the deployment of the cleanest and most fuel-efficient energy technologies, the Lung Association 

does not condone exempting CHP units from the proposed standard. The source of the heat and power 

to be combined does matter. 

The proposed standard states that most CHP units generate on-site power, and that such units would 

not generate enough electricity to fall under the proposed rule. The EPA further notes that there is a 

"small amount of projected coal-fired CHP." 39 Though large-scale CHP power plants are not currently the 
Administrator Lisa P. Jackson 

Environmental Protection Agency 

Comments on Docket ID No. EPA-HQ-OAR-2011-0660 

June 25, 2012 • Page 11 

norm, this exemption would create a perverse incentive to build new power plants (or modify old ones) 

using CHP. The proposed standard additionally notes that the EPA could subject CHP to the 1,000 lbs of 

C02/MW hour standard-but chooses not to.40 This sends a strong message to power plants that 

installing less efficient CHP units is easier than complying with pollution limits. The EPA should set a 

standard for CHP units instead of exempting them entirely. 

The alternative compliance mechanism is unnecessary and ineffective. 

The American Lung Association does not support the alternative compliance mechanism (ACM). The 

ACM ignores a forty-year history of the Clean Air Act driving standards through enforcement. 

Furthermore, giving power plants a decade of higher carbon pollution standards will not spur the 

pollution reduction or technological advances that are needed for a new generation of cleaner power 

plants. 

The proposed ACM offers new, coal-fired power plants a 30-year period to comply with emissions 

standards. Instead of meeting the permanent limit of 1,000 lbs of C02 per gross Megawatt hr (MWh), 

the ACM allows a coal-fired power plant to emit 1,800 lbs of COJMWh on a 12-month average during its 

first ten years of operation. After that first decade, carbon pollution is limited to 600 lbs of COJMWh 

per 12-month average for the following 20 years. The proposed rule offers no end date for this 

alternative compliance mechanism. 

The American lung Association does not support the ACM because the timeline creates a loophole that 

would encourage the continued expansion of coal-powered units without carbon controls under the 

guise of future adoption ofthe CCS. However, should the EPA finalize this provision of the rule, the 

American Lung Association believes that the ACM must be temporary. Without a sunset provision for 

this mechanism, the carbon capture and sequestration (CCS) industry has less support to improve CCS 

technology, and power plants have less incentive to use the best CCS system. EPA must end the ACM at 

a date certain to meet its goals of reducing life-threatening carbon pollution and improving CCS 

technology. 

The EPA notes that the proposed rule is "an important component"41 to promoting CCS, and that the 

Agency "expect[s CCS costs] to decrease as CCS becomes more mature and less expensive."42 It further 

notes that "ten years ... provides early adopters sufficient time to address any startup challenges."" This 

language indicates that the EPA views the first decade of this rule as be a "startup" period, followed by 

clarity and greater certainty about CCS. It is counter-productive at best, and confusing at worst, for EPA 

to claim that CCS technology will become more certain and simultaneously support a never-ending 

alternative compliance mechanism. 
Administrator Lisa P. Jackson 

Environmental Protection Agency 

Comments on Docket ID No. EPA-HQ-OAR-2011-0660 

June 25, 2012 • Page 12 

The alternative compliance mechanism should only serve as a startup period that will allow CCS 

technology to improve. Without an end date for the alternative compliance mechanism, coal-fired 

power plants for the next hundred years-or more-will have an incentive to opt for the lowest cost, 

highest emitting CCS technology, spend a decade spewing higher levels of carbon, and avoid the 

additional cost of better CCS technology until as late as possible. This will not create a market demand 

for the most efficient CCS technology. If the EPA believes that the proposed standard can support the 

development of CCS technology, then it should include a date certain at which power plants-and CCS 

manufacturers-can expect power plants to emit no more than 1,000 pounds of C02 per gross 

Megawatt hour (MWh). 

If the EPA Administrator determines to allow the use of an alternative compliance mechanism, she must 

set an end date for the compliance not later than 2020, a date which coincides with the obligation to 

review and revise each NSPS every eight years under CAA section 111(b)(1)(B). However, ALA strongly 

opposes waiting eight years for an end date to be determined. An eight-year period of uncertainty does 

not encourage the market to develop the most efficient CCS technology. The American Lung Association 

urges the EPA to terminate the ACM in 2020. A 2020 termination date would create incentives for more 

efficient CCS technology. If CCS technology has not sufficiently improved by 2020, the Administrator 

would have the authority to extend the ACM termination date if it appears realistic that feasible CCS 

technology can be adapted for system-wide emissions reductions, though that extension should be 

limited to one additional defined short-term period. The American Lung Association supports striking 

the ACM provisions in the proposed rule, and finalizing strong reporting and enforcement mechanisms. 

EPA must regulate carbon pollution from existing power plants. 

The American Lung Association believes that limits for power plant carbon pollution must include 

existing power plants, not just new ones. There are more than 500 existing coal-fired power plants 

spewing carbon and other pollutants on a daily basis.44 As the National Research Council states: "The 

emissions of C02 from coal-fired power are the largest single source of GHG emissions in the United 

States."45 We cannot ignore the impact of carbon pollution from these existing power plants. 

The proposed standard not only exempts existing power plants, it ignores the fact that they can-and 

will likely-continue to pollute the air for future generations. In Sunbury, Pennsylvania, the Shamokin 

Dam power plant has been operating since 1949 and will finally switch to natural gas in 2015 46 Existing 

power plants aren't disappearing, and they should be included in carbon pollution limits. 

The public wants EPA to cut pollution levels. 

We also write inform you of the views of the public as it relates to more protective standards for power 

plant carbon pollution. According to a March 2012 bipartisan survey conducted by Democratic polling 
Administrator Lisa P. Jackson 

Environmental Protection Agency 

Comments on Docket ID No. EPA-HQ-OAR-2011-0660 

June 25, 2012 • Page 13 

firm Greenberg Quinlan Rosner Research and Republican firm Perception Insight, nearly three-quarters 

of likely voters (73 percent) nationwide support the view that it is possible to protect public health 

through stronger air quality standards while achieving a healthy economy, over the notion that we must 

choose between public health or a strong economy. This overwhelming support includes 78 percent of 

independents, 60 percent of Republicans and 62 percent of conservatives, as well as significant support 

in Maine, Pennsylvania and Ohio. Additionally, a substantial majority of voters support the EPA 

implementing these standards, even after hearing opposing arguments that stricter standards will 

damage the economic recovery. A substantial majority of voters also support the EPA implementing 

standards for power plant carbon pollution. Initially, 72 percent of voters nationwide support the new 

protections on carbon pollution from power plants, including overwhelming majorities of both 

Democrats and independents and a majority of Republicans. After listening to a balanced debate with 

messages both for and against setting new carbon standards, support still remained robust with a near 

2-to-1 margin (63 percent in favor and 33 percent opposed). 

In summary, the American lung Association urges EPA to strike proposed exclusions for modified or 

reconstructed plants, biomass-fired power plants, simple cycle turbines, solid waste-fueled power plants 

and CHP units. Furthermore, the American Lung Association supports removing the ACM provision. 

However, if the ACM loophole is allowed, then EPA should terminate that option in 2020. As the EPA 

finalizes the proposed standard, the American Lung Association urges the EPA to develop carbon 

pollution limits on existing power plants as well. 

In conclusion, the risks of carbon pollution on ozone levels and public health and the obligations under 

current law require the EPA to develop carbon pollution limits for power plants. The American Lung 

Association supports EPA setting protective standards for power plant carbon pollution. The proposed 

standard will continue EPA's critical steps to protect Americans from the documented harm from 

emissions from power plants. However, the American Lung Association believes the Best System of 

Emission Reduction is stronger than the proposed pollution limits. By setting strong power plant 

pollution limits, EPA can favor our children's future over future power plants. 

Sincerely, 

Paul G. Billings 

Vice President, National Policy and Advocacy 
Administrator Lisa P. Jackson 

Environmental Protection Agency 

Comments on Docket ID No. EPA-HQ-OAR-2011-0660 

June 25, 2012 • Page 14 

1

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relationships for 6.6-hour exposures with five hours of moderate exercise to 0.08, 0.10, and 0.12 ppm. Am Rev Respir Ols1990; 

42:1158-1163; McDonnell WF, Stewart PW, Smith MV, Pan WK, Pan J. Ozone-induced respiratory symptoms: exposureresponse models and association with lung function. Eur Respir J 1999;14:845-853. 4 Triche EW, GentJF, Holford TR, Belanger K, Bracken MB, Beckett WS, Naeher L, McSharry JE, Leaderer BP. Low~leve\ ozone 

exposure and respiratory symptoms in infants. Environ Health Perspect 2006;114:911-916. 

5 Mortimer KM, Neas LM, Dockery OW, Redline S, Tager lB. The effect of air pollution on inner~city children with asthma. fur 

Respir J 2002; 19:699-705. 6 Hollingsworth JW, Kleeberger SR, Foster WM. Ozone and pulmonary innate immunity. ProcAm Thorac Soc 2007;4:240~246. 

7 Cakmak, S; Dales, RE; Judek, S. Respiratory health effects of air pollution gases: Modification by education and income. Arch 

Environ Occup Health 2006: 61: 5~10; Dales, RE; Cakmak, S; Doiron, MS. Gaseous air pollutants and hospitalization for 

respiratory disease in the neonatal period. Environ Health Perspeet, 2006; 114: 1751~1754.; Katsouyanni, K; Samet, JM; 

Anderson, HR; Atkinson, R; Le Tertre, A; Medina, S; Samoli, E; Touloumi, G; Burnett, RT; Krewski, D; Ramsay, T; Dominici, F; 

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National Morbidity, Mortality, and Air Pollution Study. Epidemiology 2005; 16:436~445. Levy Jl, Chermerynski SM, Sarnat JA. 

Ozone Exposure and Mortality: an empiric Bayes metaregression analysis. Epidemiology 2005; 16:458~468. Ito K, De Leon SF, 

Lippmann M. Associations Between Ozone and Daily Mortality: analysis and meta~analysis. Epidemiology 2005; 16:446~429. 

8 Bates DV. Ambient Ozone and Mortality. Epidemiology 2005; 16:427~429. 9 Gent JF, Triche EW, Holford TR, Belanger K, Bracken MB, Beckett WS, Leaderer BP. Association of Low~Level Ozone and Fine 

Particles with Respiratory Symptoms in Children with Asthma. JAMA 2003; 290:1859~1867Desqueyroux H, Pujet JC, Prosper M, 

Le Moullec Y, Mamas I. Effects of air pollution on adults with chronic obstructive pulmonary disease. Arch Environ Health 

2002;57:554-560; Desqueyroux H, Pujet JC, Prosper M, Squinazi F, Mamas I. Short-Term Effects of Low-Level Air Pollution on 

Respiratory Health of Adults Suffering from Moderate to Severe Asthma. Environ Res 2002; 89:29-37; 72:24-31and HOppe P, 

Peters A, Rabe G, Pram\ G, Lindner J, Jakob\ G, Fruhmann G, Nowak D. Environmental ozone effects in different population 

subgroups. lnt J Hyg Environ Health 2003;206:505-516; 

10 Devlin RB. identification of subpopulations that are sensitive to ozone exposure: Use of end points currently available and 

potential use of laboratory-based end points under development. Environ Health Perspect 1993;101:225-230 

11 Kunzli N, Lurmann F, Segal M, Ngo L, Balmes J, Tager lB. Association Between Lifetime Ambient Ozone Exposure and 

Pulmonary Function in College Freshmen-Results of a Pilot Study. Environmental Research 1997; 72: .8-23. 

12 U.S. EPA. Our Nation's Air: Status and Trends through 2010. February 2012. EPA-454/R-12-001. 

13 U.S. EPA. Assessment of the Impacts of Global Change on Regional U.S. Air Quality: A synthesis of climate change impacts on 

ground-level mone. April2009. EPA/600/R-07/094F 14• U.S. EPA, 2009. 
Administrator Lisa P. Jackson 

Environmental Protection Agency 

Comments on Docket ID No. EPA-HQ-OAR-2011-0660 

June 25, 2012 • Page 15 

15 Wu S, Mickley U, Leibensperger EM, Jacob DJ, Rind D and Streets DG. Effects of 2000-2050 global change on ozne air quality 

in the United States. J. Geophys. Res. 113: 006302, 2008. 
 16 Wu et al., 2008. 
 17 U.S. EPA, 2009. 
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 19 U.S. Centers for Disease Control and Prevention. Coal workers' pneumoconiosis: Number of deaths, crude and age-adjusted 

death rates, U.S. residents age 15 and over, 1968-2007. March 2012, Accessed June 25, 2012 at 

http: f/www2a. cdc.govI drds/W a r!dReportData/ Figure T a bleDetails.asp?FigureTabIelo-2568&GroupRefNumber=FO2-01. 

20 Hendryx, Michael and Melissa M. Ahern. Relations Between Health Indicators and Residential Proximity to Coal Mining in 

West Virginia. Am J Public Health. 2008; 98(4):669-71. 21 U.S. EPA. 2007. National Emissions Inventory {NEl) 2002: Inventory Data: Point Sector Data- ALLNEl HAP Annual 01232008. 


Web Link: http:Uwww.epa.gov/ttn/chief/net/2002inventory.html#inventorydata iAccessed 11 January 2011]. 


22 U.S. EPA, 2007. 


23 u.s. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (2006 Final). U.S. Environmental Protection 


Agency, Washington, DC, EPA/600/R·05/004af-cf, 2006. 24 U.S. EPA. Integrated Science Assessment/or Particulate Matter, 2009. U.S. Environmental Protection Agency, Washington, 

DC, EPA 600/R-08/139F. Available at http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=216546. 

"U.S. EPA, 2009. 26 U.S. Energy Information Administration. Rail Coal Transportation Rates to the Electric Power Sector. June 22, 2011. Accessed 

June 24, 2012 at httP://205.254.135.7/coal(transportationrates/ 

27 Washington Department of Natural Resources. Forest Biomass and Air Emissions. September 2010. Accessed June 25, 2012 

from www.dnr.wa.gov/Publications/em forest biomass and air emissions factsheet 8.pdf 

28 Nather LP, Brauer B, Lipsettt M, Ze\ikoff JT, Simpson CD, KoenigJQ, Smith KR. Woodsmoke Health Effects: A Review. 

Inhalation Toxicology. 2007. Jan;19(1):67-106. 

29 Northeast States for Coordinated Air Use Management. Emissions from Burning Wood Fuels Derived from Construction and 

Demolition Debris. May 2006. Accessed June 25,2012 at www.nescaum.org/documents/2006-0710­

emiss from burning wood fuels derived from c-d report.pdf 

3

°Committee on Health, Environmental, and Other External Costs and Benefits of Energy Production and Consumption, 

National Research Council. Hidden Costs of Energy: Unpriced Consequences of Energy Production and Use. Washington, DC: 

National Academy of Sciences, 2010. 

31 National Research Council, 2010. 

32 National Research Council, 2010. 

"Proposed 40 CF.R. §60.S509 (http://epa.gov/carbonpollutionstandard/pdfs/20120327proposal.pdf, pll5.) 

"Proposed 40 C.F.R. §60.SS09 (http://epa.gov/carbonpollutionstandard/pdfs/20120327proposal.pdf, p24.) 

"Proposed 40 C.F.R. §60.5S09 (http://epa.gov/carbonpollutionstandard/pdfs/20120327proposal.pdf, p147.) 36 New York State Department of Environmental Conservation. Proposed Part 251 C02 Performance Standards for Major 


Electric Generating Facilities: Regulatory Impact Statement 6 NYCRR Parts 251 and 200. Comments closed March 15, 2012. 


Accessed June 25, 2012 at http:Uwww.dec.nv.gov/regu\ations/79541.html. 


37 Environmental Defense v. Duke Energy Corp., 127 S.Ct. 1423 {2007).) 


"76 fed. Reg. 43490,43496 (July 20, 2011). 


"Proposed 40 C.F.R. §60.S509 (http://epa.gov/carbonpollutionstandard/pdfs/20120327proposal.pdf, p206.) 
 40 Proposed 40 CF.R. §60.5509 \http:/ fepa.gov/carbonpollutionstandard/pdfs/20120327proposal.pdf, p206.) 


"Proposed 40 C.f.R. §60.SS09 (http://epa.gov/carbonpollutionstandard/pdfs/20120327proposal.pdf, p127.) 


"Proposed 40 C. f. R. §60.5S09 (http://epa.gov/carbonpollutionstandard/pdfs/20120327proposal.pdf, p32.) 
 43 Proposed 40 C.F.R. §60.5509 (http://epa.gov/carbonpollutionstandard/pdfs/20120327proposa\.pdf, p144.) 
Administrator Lisa P. Jackson 

Environmental Protection Agency 

Comments on Docket ID No. EPA-HQ-OAR-2011-0660 

June 25, 2012 • Page 16 

44 U.S. Energy Information Administration. Electric Power Annua12010 Data Tables. November 9, 2011, Accessed on June 24, 

2012 at http://205.254.135.7/electricity/annua1/html/table5.1.cfm. 45 National Research Council, 2010. 


46 Esther Tanquintic-Misa, "Oldest U.S. Coal-Fired Plant Converts to Gas." International Business Times, December 29, 2011. 


Accessed on June 25, 2012 at http://au.ibtimes.com/articles/273795/20111228/oldest-u-s-coal-fired-plant-converts.htm 
Testimony of 


Daniel M. Dolan-Laughlin, 


Volunteer for the American Lung Association in Illinois 


Before the U.S. Environmental Protection Agency 


Regarding the Proposed Power Plant Carbon Pollution Standard 


May 24,2012 


Chicago, Illinois 


Good moming. My name is Daniel M. Dolan-Laughlin. I am appearing here today to 

testify how pollution controls, like the carbon pollution limits the EPA is proposing today, 

impact millions of people who suffer from respiratory illnesses. Although, I am not a scientist, 

nor a doctor, I am someone who suffered, suffered nearly fatally from COPD. I am someone who 

received a double-lung transplant; and someone for whom pollution controls still, and will mean 

the difference between life and death. 

I suffered from Chronic Obstructive Pulmonary Disease, or COPD, for decades. As the 

disease progressed, I could no longer work. My quality of life declined. Slowly at first, then 

more rapidly as I approached end-stage. I required round-the-clock oxygen therapy to perform 

even basic functions. Eventually, I wound up in the hospital with end-stage COPD. My doctor 

told me words no one is ever prepared to hear-that I had only several days left to live without 

mechanical support. And yet, a miracle occurred. Through organ donation, I was given the gift of 

life and hope ... a healthy pair oflungs. 

Even with this life-changing gift, I must be vigilant about pollution levels. Poor air 

quality during high ozone days forces me to stay indoors. Pollution, literally, makes me sick. I 

depend on healthy air to breathe and live. And there are many, many others who depend on it 

too! 

I'm not here simply to talk about my own battle for healthy air. I'm here as an advocate 

for everyone with lung diseases. Asthma sufferers, COPD patients, and others rely on pollution 

controls to simply get through another day. Lung disease impacts people young and old, rich and 

poor, all over the country. Every single one of them deserves the right to breathe healthy air. On 

behalf of these people, I support EPA's limits on carbon pollution from new power plants. By 

having the courage to implement this rule, you will reduce the carbon pollution and smog that 
Addressing Green Matters at the White House: A Climate Change Discussion 

Patricia W. Finn, MD 

Beyond the threats to human life posed by extreme weather, the 

health effects of a planet that is getting relentlessly hotter are already 

taking their toll on vulnerable populations every day. This is the 

message I tried to convey during a White House meeting in June that 

was coincidentally scheduled for the day President Obama announced 

his plan to address global warming. 

Valerie Jarrett, the president's lead advisor on environmental issues, convened the meeting with a 

half dozen medical and health groups, including the ATS, the National Association of County 

and City Health Officials, the American Lung Association, the Children's National Medical 

Center, the Asthma and Allergy Foundation ofAmerica, and the March of Dimes, and with 

climate change experts on her staff. 

In welcoming us, Ms. Jarrett said that she looked to the ATS and the other organizations to 

identify and support the development of the best science to inform the discussion about the 

public health policy needed to meet a complex global problem. 

The meeting was originally scheduled for 30 minutes but went a full hour as representatives of 

the invited organizations spoke urgently about the challenges we face from our different 

perspective of the health problems posed by an overheated planet. 

When it was my tum to speak, I focused on three issues and tried to emphasize that, like me, 

many of the clinicians in the Society are already seeing the effects of climate change in their 

patients: 

Climate and pollen. Climate change is creating earlier, longer, and more intense pollen seasons. 

Research has shown that pollen season is beginning about a day earlier at the equator and about 

23 days earlier in northern climates. Increased carbon dioxide concentrations are also yielding 

more intense allergenic pollen blooms. 

Climate and heat spikes and premature mortality. Recent heat spikes in cities around the 

world have resulted in premature deaths. While heat-spike related deaths are infrequent, it is 

important to note that these deaths were not among those expected to die soon under normal 

conditions. They were among people whose primary risk factor was the extreme heat they 

experienced. 

1 
Copyrighted page(s) removed. Copyrighted 

material is not available in Regulations.gov since 

it may not be reproduced without consent of the 

copyright holder. 

Removed pages can be viewed at the USEPA 

Docket Center, Public Reading Room. 

Address: 1301 Constitution Ave, NW 

Room 3334 

Washington, DC 20004 

Telephone: 202-566-1744 

Email: docket-customerservice@epa.gov
American Lung Association • American Public Health Association • Asthma and Allergy 


Foundation of America • Healthcare Without Harm • National Association of County and City 


Health Officials • Physicians for Social Responsibility 


June 25, 2012 

The Honorable Lisa Jackson, Administrator 

U.S. Environmental Protection Agency 

Air and Radiation Docket and Information Center 

Mail Code 2822T 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

Re: Docket ID No. EPA-HQ-OAR-2011-0660 

Dear Administrator Jackson: 

We write in support of strong standards to reduce power plant carbon pollution. These proposed 

standards can play an important role in reducing the risk of adverse health effects associated with 

ozone ("smog") on our nation's most vulnerable populations, including children, sick, and the 

elderly. These standards must be finalized for the U.S. Environmental Protection Agency (EPA) 

to take an important first step toward ensuring that electricity is produced by the most modern, 

and least toxic, power plants. Furthermore, we ask that EPA begin work on a carbon pollution 

standard for existing power plants. 

The Clean Air Act requires the EPA to regulate air pollutants if they are found to endanger the 

public's health. The Supreme Court ruled that greenhouse gases (GHG) met the definition of air 

pollutants in the Clean Air Act in 2007 and directed EPA to assess whether or not GHGs do 

endanger health. In 2009, the EPA found that concentrations of GHG in the atmosphere endanger 

the health and welfare of current and future generations by increasing temperatures and ozone 

pollution. This increase puts some of our nation's most vulnerable communities at greater risk 

for their health. 

To regulate a pollutant such as GHG, the EPA must list categories of stationary sources that 

cause or contribute to air pollution, which may adversely impact the public's health or welfare. 

Electricity generating units (EGUs) are the largest stationary source of GHG in the United States. 

Energy accounts for 86 percent of total 2009 GHG emissions,' and the electric sector represents 

39 percent of all energy-related C02 emissions.ii To regulate emissions from EGUs, the EPA 

must issue a new source performance standard (NSPS), which includes the achievable, best 

system to reduce emissions (BESR) considering cost and other factors. The proposed rule offers 

a NSPS for greenhouse gas emissions from electric utility generating units, commonly referred to 

as power plants. 
Peter M. Iwanowicz 

Assistant Vice President 

American Lung Association 

Donald Hoppert 

Director, Government Relations 

American Public Health Association 

Charlotte Collins, J.D. 

Vice President, Policy and Programs 

Asthma and Allergy Foundation of America 

Gary Cohen 

Executive Director 

Healthcare Without Harm 

Laura Hanen, 

Chief, Government and Public Affairs 

National Association of County and City Health Officials 

Catherine Thomasson, MD 

Executive Director 

Physicians for Social Responsibility 

Citations 

i "Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2009," Report EPA 430-R-11-005, United States Environmental 

Protection Agency. AprillS, 2011. Table ES-4. 

il "Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2009," Report EPA430-R-11-005, United States Environmental 

Protection Agency. AprillS, 2011. Table ES-2. 

iii Horstman DH, Folinsbee LJ, lves PJ, Abdui-Salaam S, McDonnell WF. Ozone concentration and pulmonary response 


relationships for 6.6-hour exposures with five hours of moderate exercise to 0.08, 0.10, and 0.12 ppm. Am Rev Respir Dis1990; 


42:1158-1163; McDonnell WF, Stewart PW, Smith MV, Pan WK, Pan J. Ozone-induced respiratory symptoms: exposure­


response models and association with lung function. Eur Respir J 1999;14:845-853. 


iv Triche EW, Gent JF, Holford TR, Belanger K, Bracken MB, Beckett WS, Naeher L, McSharry JE, Leaderer BP. Low-level ozone 


exposure and respiratory symptoms in infants. Environ Health Perspect 2006;114:911-916. 


v Mortimer KM, Neas LM, Dockery DW, Red lineS, Tager lB. The effect of air pollution on inner-city children with asthma. Eur 


Respir J 2002; 19:699-705. 


vi Hollingsworth JW, Kleeberger SR, Foster WM. Ozone and pulmonary innate immunity. Proc Am Thorac Soc 2007;4:240-246. 


vii Cakmak, S; Dales, RE; Judek, S. {2006b). Respiratory health effects of air pollution gases: Modification by education and 


income. Arch Environ Occup Health 61: 5-10. http:!/dx.doi.org/10.3200/AEOH.61.1.5-10; Dales, RE; Cakmak, S; Doiron, MS. 


{2006). Gaseous air pollutants and hospitalization for respiratory disease in the neonatal period. Environ Health Perspect 114: 


1751-1754. http://dx.doi.org/10.1289/ehp.9044; Katsouyanni, K; Samet, JM; Anderson, HR; Atkinson, R; Le Tertre, A; Medina, S; 


Samoli, E; Touloumi, G; Burnett, RT; Krewski, D; Ramsay, T; Dominici, F; Peng, RD; Schwartz, J; Zanobetti, A. {2009). Air pollution