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before the Subcommittees on Health and Environment and Oversight and Investigation of the Committee on Commerce U.S. House of Representatives

05/15/1997
  Oral Testimony of Carol M. Browner, Administrator
              U.S. Environmental Protection Agency
before the                      
            Subcommittees on Health and Environment
                              and
                  Oversight and Investigation
                             of the
                     Committee on Commerce
                 U.S. House of Representatives
                          May 15, 1997



     Mr. Chairman, members of the subcommittees, 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 -- one that is designed by law 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.

     And second, to achieve the goal, set forth in the Clean Air Act, that every American shall breathe clean, healthy air -- as determined by the latest and best scientific information.

     All of the requirements, procedures, and directives that we must follow when we consider setting or revising air quality standards -- all of them -- must be viewed in light of the Clean Air Act's mandate that, first and foremost, we do what we can to protect every American from the adverse health effects of breathing polluted air.

     The Act sets forth a specific procedure for periodic review of the air standards.  It lays out a process for determining what the best, available science is.  It requires EPA to obtain outside, independent review by leading scientists from academia, research institutes, public health organizations and industry.  It obligates us to consider comments from anyone who wants to weigh in on proposed revisions.  And Congress wisely decided to require this review every five years to ensure public health protections are based on the best science.

     Finally, 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.

     Last December, as you know, EPA proposed to tighten the standards for smog and soot.

     Was this the "irresponsible rush to judgment" that some have made it out to be?

     Hardly.  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.

     Are the EPA proposals short on scientific evidence to back them up?

     Not at all.  These proposals are based on a total of more than 250 of the latest, best scientific studies on ozone and PM -- 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.

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

     For particulate matter, we have 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.  In other words, we are still engaged in a review process and have not made 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 -- the concerns expressed by businesses, the comments of public health officials who have said that EPA is not going far enough, and the ordinary citizens who have weighed in.

     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.

     Let me assure the committee that, at the end of the line, there will be a decision -- to revise or not to revise the standards.  That is what the Clean Air Act promised.  That is what we will do.

     Finally, what about the cost of these proposals to industry?

     In fact, Mr. Chairman, 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.

     And, on that note, we 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 subcommittees may have.