May 1997 Oral Testimony of Administrator Carol M. Browner in front of the Subcommittee on Energy and Environment of the Committee on Science U.S. House of Representatives

Mr. Chairman, members of the subcommittee, thank you for inviting me here to discuss the Environmental Protection Agency's proposed revisions to the national ambient air quality standards for particulate matter and ozone -- better known as soot and smog.

As you all know, EPA is nearing the end of a process -- a lengthy, comprehensive, exhaustive (and, frankly, exhausting) process -- -- a process that is set forth in the Clean Air Act -- and one that is designed to do primarily two things:

First, to ensure that government is truthful with the American people about the quality of the air they are breathing and how it affects their health -- as determined by the latest, best-available science.

And second, to achieve the goal, set forth in the Clean Air Act, that Americans shall breathe clean, healthy air -- again, as determined by the latest and best available science.

Mr. Chairman, I know that you and some other members of the subcommittee have questions about the quality of the science that led EPA to propose new, stronger standards for smog and for soot. I will be delighted to answer them.

But first, let me assure you that this was not the "irresponsible rush to judgment" that some have made it out to be. These proposed standards are based on the most thorough and most extensive scientific review ever conducted by our agency for a rulemaking.

Our review of particulate matter has taken nearly 10 years. And it has been nearly 20 years since the last time the ozone standard was thoroughly reviewed.

These proposals are based on a total of more than 250 of the latest, best scientific studies on ozone and PM -- comprising thousands of pages -- all of them published, peer-reviewed, fully-debated and thoroughly analyzed by the independent scientific committee, CASAC. We're talking literally peer review of peer review of peer review.

As George Wolff, who chairs the CASAC's ozone and PM panels, told this subcommittee a couple of months ago, the criteria document summarizing the relevant science for the proposed ozone standard is a three volume set containing 1500 pages, while the document for PM is more than 2400 pages.

Compare this, if you will, to the documents for the original ozone and PM standards in 1970. Each of them were about 200 pages long.

Mr. Chairman, this is good science. This is solid science.

There are studies linking smog with increased hospital admissions, and with lung damage equal to more than half that of a pack-a-day smoker. There are inhalation-chamber studies showing breathing problems in young adults simulating routine outdoor construction work at ozone levels equal to the current standard. There is a summer camp study that found consistent loss of lung function in children at levels below the current standard.

For particulate matter, there is a study based on personal health diaries collected by the American Cancer Society that tracked 300,000 Americans in 50 cities and found that the risk of early death is 15 to 17 percent higher in areas where levels of fine particulates are highest. Another study, published in 1993 in the New England Journal of Medicine, showed that exposure to fine particulates in the air increases the risk of early death by 26 percent and, in the most polluted cities, shortens individual lives by an average of one to two years. Still another showed that air with higher soot levels was directly associated with higher numbers of elderly people going to the hospital for respiratory and cardiovascular illnesses.

The overwhelming body of independently-reviewed evidence has told us that the current standards for smog and for soot are not sufficient to protect the public's health with an adequate margin of safety.

That is why, in accordance with the law, EPA has proposed to tighten them and, as required by the law, sought public comment.

We are completing our review of those comments and concluding interagency discussions -- thereby ensuring we have heard from all. Then, and only then, will we make a final decision.

We are carefully analyzing the public comment on these proposals -- the thousands upon thousands of letters, e-mails and calls to our toll-free hotline.

I can tell you that the comments, in general, show a great deal of support for these proposals. And, again, while we have not yet reached a final decision, I can also say that we have not found anything in the public comments that causes us to question the science upon which these proposals are based.

Listen to some of the comments we have received from organizations supporting these proposed standards -- and some of them urging even tighter standards than EPA has proposed.

From the American Academy of Pediatrics: "There are few elements more basic to the health of our children than ensuring that the air they breathe is clean."

From the American Public Health Association: "When considered in terms of the 74 million people exposed to unsafe levels of particulate matter, there is clearly serious public health concern requiring adoption of a new standard."

From the National Association of City and County Health Officials: "EPA has presented a strong and solid case, based on a thorough review of epidemiological evidence, for strengthening the standards for particulate matter and ozone."

And on and on. Doctors, public health officials, children's health specialists.

I ask you, Mr. Chairman, are these the kinds of organizations and individuals that would support junk science? Do you think they would put their reputations on the line if they were not impressed by the thoroughness of this scientific review?

Some might say: But these are mostly doctors. What do they care about the costs of these proposals to industry?

And that is exactly the point. The Clean Air Act says that EPA cannot consider the costs to industry of reducing their pollution of the public's air at the standard-setting stage of the process.

The law says we have to go where the science takes us. We have to put the public health first. We have to save consideration of cost-benefit analyses for the implementation phase.

On that note, let me point out that if the science warrants a revision in the standards, the law sets forth a reasonable and rational procedure for implementation and assuring that it is carried out in the most common sense, cost-effective way -- over a lengthy phase-in period.

We at EPA take very seriously our responsibility to work with states, with local governments, communities, businesses large and small -- and, yes, with members of Congress -- to find the most common sense and cost-effective ways to implement any revisions to the air standards -- if, in the end, revisions are adopted.

Thank you, Mr. Chairman.  I am happy to answer any questions you or other members of the subcommittee may have.