Comments of Bonnie Holmes-Gen
Assistant V.P., Government Relations
American Lung Association of California

Before the California Air Resources Board
June 20, 2002
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California and national health and environmental organizations have weighed in with the California Air Resources Board to urge adoption of the proposed ambient air quality standards for PM10 and PM2.5, and subsequent review of the 24-hour PM2.5 standard.
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The California Air Quality Advisory Committee (AQAC) met on January 23 and 24, 2002, to consider a draft report prepared by the Air Resources Board (ARB) and the Office of Environmental Health Hazarad Assessment regarding recommended changes to the state ambient air quality standards for particulate matter. The major conclusion from the meeting was that staff report needed to be revised to include a 24-hour standard for PM2.5.
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California’s air quality standards for particulate matter are in critical need of updating and strengthening in light of the hundreds of studies published in the last decade demonstrating associations between particulate air pollution, illness, emergency room visits, hospitalization, and premature death, at levels well below the current standards, according to comments filed by the American Lung Association® together with the American Lung Association® of California and its medical section, the California Thoracic Society, joined by the Natural Resources Defense Council, Environmental Working Group, Committee For Law, Air, Water and Species, and the Transportation Solutions Defense and Education Fund.
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In November 2001, the California Air Resources Board (ARB) and the Office of Environmental Health Hazard Assessment (OEHHA) released a staff paper for public comment which recommends a stringent new annual average standard for fine particles (PM2.5), but makes no recommendation on a short-term, 24-hour standard.

The staff paper also recommends substantially tightening the annual average PM10 standard, and retaining the existing 24-hour PM10 standard.

The staff paper claims that evidence of strictly short-term effects of particulate exposures is not compelling (that effects are more likely a result of chronic exposures), and that if short-term effects are of concern, they will be prevented by compliance with an annual average standard.

The American Lung Association® disagrees, and urges establishment of a strict 24-hour PM2.5 standard to protect sensitive populations from the harmful effects of short-term peak exposures to fine particle pollution.
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