Review of the National Ambient Air Quality Standards for Particulate Matter, 24094-24144 [2020-08143]
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Federal Register / Vol. 85, No. 84 / Thursday, April 30, 2020 / Proposed Rules
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 50
[EPA–HQ–OAR–2015–0072; FRL–10008–31–
OAR]
RIN 2060–AS50
Review of the National Ambient Air
Quality Standards for Particulate
Matter
Environmental Protection
Agency (EPA).
ACTION: Proposed action.
AGENCY:
SUMMARY: Based on the Environmental
Protection Agency’s (EPA’s) review of
the air quality criteria and the national
ambient air quality standards (NAAQS)
for particulate matter (PM), the
Administrator has reached proposed
decisions on the primary and secondary
PM NAAQS. With regard to the primary
standards meant to protect against fine
particle exposures (i.e., annual and 24hour PM2.5 standards), the primary
standard meant to protect against coarse
particle exposures (i.e., 24-hour PM10
standard), and the secondary PM2.5 and
PM10 standards, the EPA proposes to
retain the current standards, without
revision.
Comments must be received on
or before June 29, 2020.
Public Hearings: The EPA will hold
one or more virtual public hearings on
this proposed rule. These will be
announced in a separate Federal
Register notice that provides details,
including specific dates, times, and
contact information for these hearings.
ADDRESSES: You may submit comments,
identified by Docket ID No. EPA–HQ–
OAR–2015–0072, by any of the
following means:
• Federal eRulemaking Portal:
https://www.regulations.gov (our
preferred method). Follow the online
instructions for submitting comments.
• Email: a-and-r-Docket@epa.gov.
Include the Docket ID No. EPA–HQ–
OAR–2015–0072 in the subject line of
the message.
Instructions: All submissions received
must include the Docket ID No. for this
document. Comments received may be
posted without change to https://
www.regulations.gov, including any
personal information provided. For
detailed instructions on sending
comments, see the SUPPLEMENTARY
INFORMATION section of this document.
Out of an abundance of caution for
members of the public and our staff, the
EPA Docket Center and Reading Room
was closed to public visitors on March
31, 2020, to reduce the risk of
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DATES:
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transmitting COVID–19. Our Docket
Center staff will continue to provide
remote customer service via email,
phone, and webform. We encourage the
public to submit comments via https://
www.regulations.gov or email, as there
is a temporary suspension of mail
delivery to EPA, and no hand deliveries
are currently accepted. For further
information of EPA Docket Center
services and the current status, please
visit us online at https://www.epa.gov/
dockets.
FOR FURTHER INFORMATION CONTACT: Dr.
Scott Jenkins, Health and
Environmental Impacts Division, Office
of Air Quality Planning and Standards,
U.S. Environmental Protection Agency,
Mail Code C504–06, Research Triangle
Park, NC 27711; telephone: (919) 541–
1167; fax: (919) 541–5315; email:
jenkins.scott@epa.gov.
SUPPLEMENTARY INFORMATION:
General Information
Written Comments: Submit your
comments, identified by Docket ID No.
EPA–HQ–OAR–2015–0072, at https://
www.regulations.gov (our preferred
method), or the other methods
identified in the ADDRESSES section.
Once submitted, comments cannot be
edited or removed from the docket. The
EPA may publish any comment received
to its public docket. Do not submit
electronically any information you
consider to be Confidential Business
Information (CBI) or other information
whose disclosure is restricted by statute.
Multimedia submissions (audio, video,
etc.) must be accompanied by a written
submission. The written submission is
considered the official submission and
should include discussion of all points
you wish to make. The EPA will
generally not consider submissions or
submission content located outside of
the primary submission (i.e., on the
web, cloud, or other file sharing
system). For additional submission
methods, the full EPA public comment
policy, information about CBI or
multimedia submissions, and general
guidance on making effective
comments, please visit https://
www.epa.gov/dockets/commenting-epadockets.
The EPA is temporarily suspending
its Docket Center and Reading Room for
public visitors to reduce the risk of
transmitting COVID–19. Written
comments submitted by mail are
temporarily suspended and no hand
deliveries will be accepted. Our Docket
Center staff will continue to provide
remote customer service via email,
phone, and webform. We encourage the
public to submit comments via https://
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www.regulations.gov. For further
information and updates on EPA Docket
Center services, please visit us online at
https://www.epa.gov/dockets.
The EPA continues to carefully and
continuously monitor information from
the Centers for Disease Control and
Prevention (CDC), local area health
departments, and our Federal partners
so that we can respond rapidly as
conditions change regarding COVID–19.
Availability of Information Related to
This Action
A number of the documents that are
relevant to this proposed decision are
available through the EPA’s website at
https://www.epa.gov/naaqs/particulatematter-pm-air-quality-standards. These
documents include the Integrated
Review Plan for the National Ambient
Air Quality Standards for Particulate
Matter (U.S. EPA, 2016), available at
https://www3.epa.gov/ttn/naaqs/
standards/pm/data/201612-finalintegrated-review-plan.pdf, the
Integrated Science Assessment for
Particulate Matter (U.S. EPA, 2019),
available at https://cfpub.epa.gov/ncea/
isa/recordisplay.cfm?deid=347534, and
the Policy Assessment for the Review of
the National Ambient Air Quality
Standards for Particulate Matter (U.S.
EPA, 2020), available at https://
www.epa.gov/naaqs/particulate-matterpm-standards-policy-assessmentscurrent-review-0. These and other
related documents are also available for
inspection and copying in the EPA
docket identified above.
Table of Contents
The following topics are discussed in this
preamble:
Executive Summary
I. Background
A. Legislative Requirements
B. Related PM Control Programs
C. Review of the Air Quality Criteria and
Standards for Particulate Matter
1. Reviews Completed in 1971 and 1987
2. Review Completed in 1997
3. Review Completed in 2006
4. Review Completed in 2012
5. Current Review
D. Air Quality Information
1. Distribution of Particle Size in Ambient
Air
2. Sources and Emissions Contributing to
PM in the Ambient Air
3. Monitoring of Ambient PM
4. Ambient Concentrations and Trends
a. PM2.5 mass
b. PM2.5 components
c. PM10
d. PM10-2.5
a. UFP
5. Background PM
II. Rationale for Proposed Decisions on the
Primary PM2.5 Standards
A. General Approach
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1. Approach Used in the Last Review
a. Indicator
b. Averaging Time
c. Form
d. Level
2. Approach in the Current Review
B. Health Effects Related to Fine Particle
Exposures
1. Nature of Effects
a. Mortality
b. Cardiovascular Effects
c. Respiratory Effects
d. Cancer
e. Nervous System Effects
2. Populations at Risk of PM2.5-Related
Health Effects
3. CASAC Advice
C. Proposed Conclusions on the Current
Primary PM2.5 Standards
1. Evidence- and Risk-Based
Considerations in the Policy Assessment
a. Evidence-Based Considerations
b. Risk-Based Considerations
2. CASAC Advice
3. Administrator’s Proposed Decision on
the Current Primary PM2.5 Standards
III. Rationale for Proposed Decisions on the
Primary PM10 Standard
A. General Approach
1. Approach Used in the Last Review
2. Approach in the Current Review
B. Health Effects Related to Thoracic
Coarse Particle Exposures
1. Mortality
a. Long-Term Exposures
b. Short-Term Exposures
2. Cardiovascular Effects
a. Long-Term Exposures
b. Short-Term Exposures
3. Respiratory Effects—Short-Term
Exposures
4. Cancer—Long-Term Exposures
5. Metabolic Effects—Long-Term
Exposures
6. Nervous System Effects—Long-Term
Exposures
C. Proposed Conclusions on the Current
Primary PM10 Standard
1. Evidence-Based Considerations in the
Policy Assessment
2. CASAC Advice
3. Administrator’s Proposed Decision on
the Current Primary PM10 Standard
IV. Rationale for Proposed Decisions on the
Secondary PM Standards
A. General Approach
1. Approach Used in the Last Review
a. Non-Visibility Effects
b. Visibility Effects
2. Approach for the Current Review
B. PM-Related Visibility Impairment
1. Nature of PM-Related Visibility
Impairment
2. Relationship between Ambient PM and
Visibility
3. Public Perception of Visibility
Impairment
C. Other PM-Related Welfare Effects
1. Climate
2. Materials
D. Proposed Conclusions on the Current
Secondary PM Standards
1. Evidence- and Quantitative InformationBased Considerations in the Policy
Assessment
2. CASAC Advice
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3. Administrator’s Proposed Decision on
the Current Secondary PM Standards
V. Statutory and Executive Order Reviews
A. Executive Order 12866: Regulatory
Planning and Review and Executive
Order 13563: Improving Regulation and
Regulatory Review
B. Executive Order 13771: Reducing
Regulations and Controlling Regulatory
Costs
C. Paperwork Reduction Act (PRA)
D. Regulatory Flexibility Act (RFA)
E. Unfunded Mandates Reform Act
(UMRA)
F. Executive Order 13132: Federalism
G. Executive Order 13175: Consultation
and Coordination With Indian Tribal
Governments
H. Executive Order 13045: Protection of
Children From Environmental Health
and Safety Risks
I. Executive Order 13211: Actions
Concerning Regulations That
Significantly Affect Energy Supply,
Distribution or Use
J. National Technology Transfer and
Advancement Act (NTTAA)
K. Executive Order 12898: Federal Actions
to Address Environmental Justice in
Minority Populations and Low-Income
Populations
L. Determination Under Section 307(d)
References
Executive Summary
This document presents the
Administrator’s proposed decisions on
the primary (health-based) and
secondary (welfare-based) National
Ambient Air Quality Standards
(NAAQS) for particulate matter (PM). In
ambient air, PM is a mixture of
substances suspended as small liquid
and/or solid particles. Particles in the
atmosphere range in size from less than
0.01 to more than 10 micrometers (mm)
in diameter. Particulate matter and its
precursors are emitted from both
anthropogenic sources (e.g., electricity
generating units, cars and trucks,
agricultural operations) and natural
sources (e.g., sea salt, wildland fires,
biological aerosols).
When describing PM, subscripts are
used to denote particle size. For
example, PM2.5 includes particles with
diameters generally less than or equal to
2.5 mm and PM10 includes particles with
diameters generally less than or equal to
10 mm.
The EPA has established primary
(health-based) and secondary (welfarebased) NAAQS for PM2.5 and PM10. This
includes two primary PM2.5 standards,
an annual average standard with a level
of 12.0 mg/m3 and a 24-hour standard
with a 98th percentile form and a level
of 35 mg/m3. It also includes a primary
PM10 standard with a 24-hour averaging
time, a 1-expected exceedance form, and
a level of 150 mg/m3. Secondary PM
standards are set equal to the primary
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standards, except that the level of the
secondary annual PM2.5 standard is 15.0
mg/m3. In reaching proposed decisions
on these PM standards in the current
review, the Administrator has
considered the available scientific
evidence assessed in the Integrated
Science Assessment (ISA), analyses in
the Policy Assessment (PA), and advice
from the Clean Air Scientific Advisory
Committee (CASAC).
For the primary PM2.5 standards, the
Administrator proposes to conclude that
there are important uncertainties in the
evidence for adverse health effects
below the current standards and in the
potential public health impacts of
reducing ambient PM2.5 concentrations
below those standards. As a result, he
proposes to conclude that the available
evidence and information do not call
into question the adequacy of the
current primary PM2.5 standards, and he
proposes to retain those standards (i.e.,
both the annual and 24-hour standards)
without revision in this review.
For the primary PM10 standard, the
Administrator observes that, while the
available health effects evidence has
expanded, recent studies are subject to
the same types of uncertainties that
were judged important in the last
review. He proposes to conclude that
the newly available evidence does not
call into question the adequacy of the
current primary PM10 standard, and he
proposes to retain that standard without
revision in this review.
For the secondary standards, the
Administrator observes that the
expanded evidence for non-ecological
welfare effects is consistent with the last
review 1 and that updated quantitative
analyses show results similar to those in
the last review. Therefore, he proposes
to conclude that the newly available
evidence and updated analyses do not
call into question the adequacy of the
current secondary PM standards, and he
proposes to retain those standards
without revision in this review.
These proposed decisions are
consistent with the CASAC’s consensus
advice on the primary 24-hour PM2.5
standard, the primary PM10 standard,
and the secondary standards. The
CASAC did not reach consensus on the
primary annual PM2.5 standard, with
some committee members
1 The welfare effects considered in this review
include visibility impairment, climate effects, and
materials effects. Ecological effects associated with
PM, and the adequacy of protection provided by the
secondary PM standards for those effects, are being
addressed in the separate review of the secondary
NAAQS for oxides of nitrogen, oxides of sulfur and
PM. Information on the current review of these
secondary NAAQS can be found at https://
www.epa.gov/naaqs/nitrogen-dioxide-no2-andsulfur-dioxide-so2-secondary-air-quality-standards.
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recommending that EPA retain the
current standard and other members
recommending revision of that standard.
I. Background
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A. Legislative Requirements
Two sections of the Clean Air Act
(CAA) govern the establishment and
revision of the NAAQS. Section 108 (42
U.S.C. 7408) directs the Administrator
to identify and list certain air pollutants
and then to issue air quality criteria for
those pollutants. The Administrator is
to list those pollutants ‘‘emissions of
which, in his judgment, cause or
contribute to air pollution which may
reasonably be anticipated to endanger
public health or welfare’’; ‘‘the presence
of which in the ambient air results from
numerous or diverse mobile or
stationary sources’’; and for which he
‘‘plans to issue air quality criteria . . . .
’’ (42 U.S.C. 7408(a)(1)). Air quality
criteria are intended to ‘‘accurately
reflect the latest scientific knowledge
useful in indicating the kind and extent
of all identifiable effects on public
health or welfare which may be
expected from the presence of [a]
pollutant in the ambient air . . . . ’’ (42
U.S.C. 7408(a)(2)).
Section 109 [42 U.S.C. 7409] directs
the Administrator to propose and
promulgate ‘‘primary’’ and ‘‘secondary’’
NAAQS for pollutants for which air
quality criteria are issued [42 U.S.C.
7409(a)]. Section 109(b)(1) defines
primary standards as ones ‘‘the
attainment and maintenance of which in
the judgment of the Administrator,
based on such criteria and allowing an
adequate margin of safety, are requisite
to protect the public health.’’ 2 Under
section 109(b)(2), a secondary standard
must ‘‘specify a level of air quality the
attainment and maintenance of which,
in the judgment of the Administrator,
based on such criteria, is requisite to
protect the public welfare from any
known or anticipated adverse effects
associated with the presence of [the]
pollutant in the ambient air.’’ 3
In setting primary and secondary
standards that are ‘‘requisite’’ to protect
2 The legislative history of section 109 indicates
that a primary standard is to be set at ‘‘the
maximum permissible ambient air level . . . which
will protect the health of any [sensitive] group of
the population,’’ and that for this purpose
‘‘reference should be made to a representative
sample of persons comprising the sensitive group
rather than to a single person in such a group.’’ S.
Rep. No. 91–1196, 91st Cong., 2d Sess. 10 (1970).
3 Under CAA section 302(h) (42 U.S.C. 7602(h)),
effects on welfare include, but are not limited to,
‘‘effects on soils, water, crops, vegetation, manmade
materials, animals, wildlife, weather, visibility, and
climate, damage to and deterioration of property,
and hazards to transportation, as well as effects on
economic values and on personal comfort and wellbeing.’’
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public health and welfare, respectively,
as provided in section 109(b), the EPA’s
task is to establish standards that are
neither more nor less stringent than
necessary. In so doing, the EPA may not
consider the costs of implementing the
standards. See generally Whitman v.
American Trucking Associations, 531
U.S. 457, 465–472, 475–76 (2001).
Likewise, ‘‘[a]ttainability and
technological feasibility are not relevant
considerations in the promulgation of
national ambient air quality standards.’’
American Petroleum Institute v. Costle,
665 F.2d 1176, 1185 (D.C. Cir. 1981);
accord Murray Energy Corporation v.
EPA, 936 F.3d 597, 623–24 (D.C. Cir.
2019).
The requirement that primary
standards provide an adequate margin
of safety was intended to address
uncertainties associated with
inconclusive scientific and technical
information available at the time of
standard setting. It was also intended to
provide a reasonable degree of
protection against hazards that research
has not yet identified. See Lead
Industries Association v. EPA, 647 F.2d
1130, 1154 (D.C. Cir 1980); American
Petroleum Institute v. Costle, 665 F.2d at
1186; Coalition of Battery Recyclers
Ass’n v. EPA, 604 F.3d 613, 617–18
(D.C. Cir. 2010); Mississippi v. EPA, 744
F.3d 1334, 1353 (D.C. Cir. 2013). Both
kinds of uncertainties are components
of the risk associated with pollution at
levels below those at which human
health effects can be said to occur with
reasonable scientific certainty. Thus, in
selecting primary standards that include
an adequate margin of safety, the
Administrator is seeking not only to
prevent pollution levels that have been
demonstrated to be harmful but also to
prevent lower pollutant levels that may
pose an unacceptable risk of harm, even
if the risk is not precisely identified as
to nature or degree. The CAA does not
require the Administrator to establish a
primary NAAQS at a zero-risk level or
at background concentration levels, see
Lead Industries Ass’n v. EPA, 647 F.2d
at 1156 n.51, Mississippi v. EPA, 744
F.3d at 1351, but rather at a level that
reduces risk sufficiently so as to protect
public health with an adequate margin
of safety.
In addressing the requirement for an
adequate margin of safety, the EPA
considers such factors as the nature and
severity of the health effects involved,
the size of the sensitive population(s),
and the kind and degree of
uncertainties. The selection of any
particular approach to providing an
adequate margin of safety is a policy
choice left specifically to the
Administrator’s judgment. See Lead
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Industries Ass’n v. EPA, 647 F.2d at
1161–62; Mississippi v. EPA, 744 F.3d at
1353.
Section 109(d)(1) of the Act requires
the review every five years of existing
air quality criteria and, if appropriate,
the revision of those criteria to reflect
advances in scientific knowledge on the
effects of the pollutant on public health
and welfare. Under the same provision,
the EPA is also to review every five
years and, if appropriate, revise the
NAAQS, based on the revised air quality
criteria.
Section 109(d)(2) addresses the
appointment and advisory functions of
an independent scientific review
committee. Section 109(d)(2)(A)
requires the Administrator to appoint
this committee, which is to be
composed of ‘‘seven members including
at least one member of the National
Academy of Sciences, one physician,
and one person representing State air
pollution control agencies.’’ Section
109(d)(2)(B) provides that the
independent scientific review
committee ‘‘shall complete a review of
the criteria . . . and the national
primary and secondary ambient air
quality standards . . . and shall
recommend to the Administrator any
new . . . standards and revisions of
existing criteria and standards as may be
appropriate. . . .’’ Since the early
1980s, this independent review function
has been performed by the Clean Air
Scientific Advisory Committee (CASAC)
of the EPA’s Science Advisory Board. A
number of other advisory functions are
also identified for the committee by
section 109(d)(2)(C), which reads:
Such committee shall also (i) advise the
Administrator of areas in which additional
knowledge is required to appraise the
adequacy and basis of existing, new, or
revised national ambient air quality
standards, (ii) describe the research efforts
necessary to provide the required
information, (iii) advise the Administrator on
the relative contribution to air pollution
concentrations of natural as well as
anthropogenic activity, and (iv) advise the
Administrator of any adverse public health,
welfare, social, economic, or energy effects
which may result from various strategies for
attainment and maintenance of such national
ambient air quality standards.
As previously noted, the Supreme
Court has held that section 109(b)
‘‘unambiguously bars cost
considerations from the NAAQS-setting
process.’’ Whitman v. Am. Trucking
Associations, 531 U.S. 457, 471 (2001).
Accordingly, while some of these issues
regarding which Congress has directed
the CASAC to advise the Administrator
are ones that are relevant to the standard
setting process, others are not. Issues
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that are not relevant to standard setting
may be relevant to implementation of
the NAAQS once they are established.4
B. Related PM Control Programs
States are primarily responsible for
ensuring attainment and maintenance of
ambient air quality standards once the
EPA has established them. Under
section 110 and 171–190 of the CAA,
and related provisions and regulations,
states are to submit, for EPA’s approval,
state implementation plans (SIPs) that
provide for the attainment and
maintenance of such standards through
control programs directed to sources of
the pollutants involved. The states, in
conjunction with the EPA, also
administer the Prevention of Significant
Deterioration (PSD) program (CAA
sections 160 to 169). In addition,
Federal programs provide for
nationwide reductions in emissions of
PM and other air pollutants through the
Federal motor vehicle and motor vehicle
fuel control program under title II of the
Act (CAA sections 202 to 250), which
involves controls for emissions from
mobile sources and controls for the fuels
used by these sources, and new source
performance standards for stationary
sources under section 111 of the CAA.
C. Review of the Air Quality Criteria and
Standards for Particulate Matter
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1. Reviews Completed in 1971 and 1987
The EPA first established NAAQS for
PM in 1971 (36 FR 8186, April 30,
1971), based on the original Air Quality
Criteria Document (AQCD) (DHEW,
1969).5 The federal reference method
(FRM) specified for determining
attainment of the original standards was
4 Some aspects of the CASAC’s advice may not be
relevant to the EPA’s process of setting primary and
secondary standards that are requisite to protect
public health and welfare. Indeed, were EPA to
consider costs of implementation when reviewing
and revising the standards ‘‘it would be grounds for
vacating the NAAQS.’’ Whitman, 531 U.S. at 471
n.4. At the same time, the CAA directs the CASAC
to provide advice on ‘‘any adverse public health,
welfare, social, economic, or energy effects which
may result from various strategies for attainment
and maintenance’’ of the NAAQS to the
Administrator under section 109(d)(2)(C)(iv). In
Whitman, the Court clarified that most of that
advice would be relevant to implementation but not
standard setting, as it ‘‘enable[s] the Administrator
to assist the States in carrying out their statutory
role as primary implementers of the NAAQS.’’ Id.
at 470 (emphasis in original). However, the Court
also noted that the CASAC’s ‘‘advice concerning
certain aspects of ‘adverse public health . . .
effects’ from various attainment strategies is
unquestionably pertinent’’ to the NAAQS
rulemaking record and relevant to the standard
setting process. Id. at 470 n.2.
5 Prior to the review initiated in 2007 (see below),
the AQCD provided the scientific foundation (i.e.,
the air quality criteria) for the NAAQS. Beginning
in that review, the Integrated Science Assessment
(ISA) has replaced the AQCD.
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the high-volume sampler, which
collects PM up to a nominal size of 25
to 45 mm (referred to as total suspended
particulates or TSP). The primary
standards were set at 260 mg/m3, 24hour average, not to be exceeded more
than once per year, and 75 mg/m3,
annual geometric mean. The secondary
standards were set at 150 mg/m3, 24hour average, not to be exceeded more
than once per year, and 60 mg/m3,
annual geometric mean.
In October 1979 (44 FR 56730,
October 2, 1979), the EPA announced
the first periodic review of the air
quality criteria and NAAQS for PM.
Revised primary and secondary
standards were promulgated in 1987 (52
FR 24634, July 1, 1987). In the 1987
decision, the EPA changed the indicator
for particles from TSP to PM10, in order
to focus on the subset of inhalable
particles small enough to penetrate to
the thoracic region of the respiratory
tract (including the tracheobronchial
and alveolar regions), referred to as
thoracic particles.6 The level of the 24hour standards (primary and secondary)
was set at 150 mg/m3, and the form was
one expected exceedance per year, on
average over three years. The level of
the annual standards (primary and
secondary) was set at 50 mg/m3, and the
form was annual arithmetic mean,
averaged over three years.
2. Review Completed in 1997
In April 1994, the EPA announced its
plans for the second periodic review of
the air quality criteria and NAAQS for
PM, and in 1997 the EPA promulgated
revisions to the NAAQS (62 FR 38652,
July 18, 1997). In the 1997 decision, the
EPA determined that the fine and coarse
fractions of PM10 should be considered
separately. This determination was
based on evidence that serious health
effects were associated with short- and
long-term exposures to fine particles in
areas that met the existing PM10
standards. The EPA added new
standards, using PM2.5 as the indicator
for fine particles (with PM2.5 referring to
particles with a nominal mean
aerodynamic diameter less than or equal
to 2.5 mm). The new primary standards
were as follows: (1) An annual standard
with a level of 15.0 mg/m3, based on the
3-year average of annual arithmetic
mean PM2.5 concentrations from single
or multiple community-oriented
monitors; 7 and (2) a 24-hour standard
6 PM
10 refers to particles with a nominal mean
aerodynamic diameter less than or equal to 10 mm.
More specifically, 10 mm is the aerodynamic
diameter for which the efficiency of particle
collection is 50 percent.
7 The 1997 annual PM
2.5 standard was compared
with measurements made at the community-
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with a level of 65 mg/m3, based on the
3-year average of the 98th percentile of
24-hour PM2.5 concentrations at each
monitor within an area. Also, the EPA
established a new reference method for
the measurement of PM2.5 in the
ambient air and adopted rules for
determining attainment of the new
standards. To continue to address the
health effects of the coarse fraction of
PM10 (referred to as thoracic coarse
particles or PM10-2.5; generally including
particles with a nominal mean
aerodynamic diameter greater than 2.5
mm and less than or equal to 10 mm), the
EPA retained the primary annual PM10
standard and revised the form of the
primary 24-hour PM10 standard to be
based on the 99th percentile of 24-hour
PM10 concentrations at each monitor in
an area. The EPA revised the secondary
standards by setting them equal in all
respects to the primary standards.
Following promulgation of the 1997
PM NAAQS, petitions for review were
filed by several parties, addressing a
broad range of issues. In May 1999, the
U.S. Court of Appeals for the District of
Columbia Circuit (D.C. Circuit) upheld
the EPA’s decision to establish fine
particle standards, holding that ‘‘the
growing empirical evidence
demonstrating a relationship between
fine particle pollution and adverse
health effects amply justifies
establishment of new fine particle
standards.’’ American Trucking
Associations, Inc. v. EPA, 175 F. 3d
1027, 1055–56 (D.C. Cir. 1999). The D.C.
Circuit also found ‘‘ample support’’ for
the EPA’s decision to regulate coarse
particle pollution, but vacated the 1997
PM10 standards, concluding that the
EPA had not provided a reasonable
explanation justifying use of PM10 as an
indicator for coarse particles. American
Trucking Associations v. EPA, 175 F. 3d
at 1054–55. Pursuant to the D.C.
Circuit’s decision, the EPA removed the
vacated 1997 PM10 standards, and the
pre-existing 1987 PM10 standards
remained in place (65 FR 80776,
December 22, 2000). The D.C. Circuit
also upheld the EPA’s determination not
to establish more stringent secondary
standards for fine particles to address
oriented monitoring site recording the highest
concentration or, if specific constraints were met,
measurements from multiple community-oriented
monitoring sites could be averaged (i.e., ‘‘spatial
averaging’’). In the last review (completed in 2012)
the EPA replaced the term ‘‘community-oriented’’
monitor with the term ‘‘area-wide’’ monitor. Areawide monitors are those sited at the neighborhood
scale or larger, as well as those monitors sited at
micro- or middle-scales that are representative of
many such locations in the same core-based
statistical area (CBSA) (78 FR 3236, January 15,
2013).
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effects on visibility. American Trucking
Associations v. EPA, 175 F. 3d at 1027.
The D.C. Circuit also addressed more
general issues related to the NAAQS,
including issues related to the
consideration of costs in setting NAAQS
and the EPA’s approach to establishing
the levels of NAAQS. Regarding the cost
issue, the court reaffirmed prior rulings
holding that in setting NAAQS the EPA
is ‘‘not permitted to consider the cost of
implementing those standards.’’
American Trucking Associations v.
EPA, 175 F. 3d at 1040–41. Regarding
the levels of NAAQS, the court held that
the EPA’s approach to establishing the
level of the standards in 1997 (i.e., both
for PM and for the ozone NAAQS
promulgated on the same day) effected
‘‘an unconstitutional delegation of
legislative authority.’’ American
Trucking Associations v. EPA, 175 F. 3d
at 1034–40. Although the court stated
that ‘‘the factors EPA uses in
determining the degree of public health
concern associated with different levels
of ozone and PM are reasonable,’’ it
remanded the rule to the EPA, stating
that when the EPA considers these
factors for potential non-threshold
pollutants ‘‘what EPA lacks is any
determinate criterion for drawing lines’’
to determine where the standards
should be set.
The D.C. Circuit’s holding on the cost
and constitutional issues were appealed
to the United States Supreme Court. In
February 2001, the Supreme Court
issued a unanimous decision upholding
the EPA’s position on both the cost and
constitutional issues. Whitman v.
American Trucking Associations, 531
U.S. 457, 464, 475–76. On the
constitutional issue, the Court held that
the statutory requirement that NAAQS
be ‘‘requisite’’ to protect public health
with an adequate margin of safety
sufficiently guided the EPA’s discretion,
affirming the EPA’s approach of setting
standards that are neither more nor less
stringent than necessary.
The Supreme Court remanded the
case to the D.C. Circuit for resolution of
any remaining issues that had not been
addressed in that court’s earlier rulings.
Id. at 475–76. In a March 2002 decision,
the D.C. Circuit rejected all remaining
challenges to the standards, holding that
the EPA’s PM2.5 standards were
reasonably supported by the
administrative record and were not
‘‘arbitrary and capricious.’’ American
Trucking Associations v. EPA, 283 F. 3d
355, 369–72 (D.C. Cir. 2002).
3. Review Completed in 2006
In October 1997, the EPA published
its plans for the third periodic review of
the air quality criteria and NAAQS for
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PM (62 FR 55201, October 23, 1997).
After the CASAC and public review of
several drafts, the EPA’s National Center
for Environmental Assessment (NCEA)
finalized the AQCD in October 2004
(U.S. EPA, 2004). The EPA’s Office of
Air Quality Planning and Standards
(OAQPS) finalized a Risk Assessment
and Staff Paper in December 2005 (Abt
Associates, 2005, U.S. EPA, 2005).8 On
December 20, 2005, the EPA announced
its proposed decision to revise the
NAAQS for PM and solicited public
comment on a broad range of options
(71 FR 2620, January 17, 2006). On
September 21, 2006, the EPA
announced its final decisions to revise
the primary and secondary NAAQS for
PM to provide increased protection of
public health and welfare, respectively
(71 FR 61144, October 17, 2006). With
regard to the primary and secondary
standards for fine particles, the EPA
revised the level of the 24-hour PM2.5
standards to 35 mg/m3, retained the level
of the annual PM2.5 standards at 15.0
mg/m3, and revised the form of the
annual PM2.5 standards by narrowing
the constraints on the optional use of
spatial averaging. With regard to the
primary and secondary standards for
PM10, the EPA retained the 24-hour
standards, with levels at 150 mg/m3, and
revoked the annual standards.9 The
Administrator judged that the available
evidence generally did not suggest a
link between long-term exposure to
existing ambient levels of coarse
particles and health or welfare effects.
In addition, a new reference method
was added for the measurement of
PM10-2.5 in the ambient air in order to
provide a basis for approving federal
equivalent methods (FEMs) and to
promote the gathering of scientific data
to support future reviews of the PM
NAAQS.
8 Prior to the review initiated in 2007, the Staff
Paper presented the EPA staff’s considerations and
conclusions regarding the adequacy of existing
NAAQS and, when appropriate, the potential
alternative standards that could be supported by the
evidence and information. More recent reviews
present this information in the Policy Assessment.
9 In the 2006 proposal, the EPA proposed to
revise the 24-hour PM10 standard in part by
establishing a new PM10-2.5 indicator for thoracic
coarse particles (i.e., particles generally between 2.5
and 10 mm in diameter). The EPA proposed to
include any ambient mix of PM10-2.5 that was
dominated by resuspended dust from high density
traffic on paved roads and by PM from industrial
sources and construction sources. The EPA
proposed to exclude any ambient mix of PM10-2.5
that was dominated by rural windblown dust and
soils and by PM generated from agricultural and
mining sources. In the final decision, the existing
PM10 standard was retained, in part due to an
‘‘inability . . . to effectively and precisely identify
which ambient mixes are included in the [PM10-2.5]
indicator and which are not’’ (71 FR 61197, October
17, 2006).
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Several parties filed petitions for
review following promulgation of the
revised PM NAAQS in 2006. These
petitions addressed the following issues:
(1) Selecting the level of the primary
annual PM2.5 standard; (2) retaining
PM10 as the indicator of a standard for
thoracic coarse particles, retaining the
level and form of the 24-hour PM10
standard, and revoking the PM10 annual
standard; and (3) setting the secondary
PM2.5 standards identical to the primary
standards. On February 24, 2009, the
D.C. Circuit issued its opinion in the
case American Farm Bureau Federation
v. EPA, 559 F. 3d 512 (D.C. Cir. 2009).
The court remanded the primary annual
PM2.5 NAAQS to the EPA because the
Agency had failed to adequately explain
why the standards provided the
requisite protection from both shortand long-term exposures to fine
particles, including protection for at-risk
populations. Id. at 520–27. With regard
to the standards for PM10, the court
upheld the EPA’s decisions to retain the
24-hour PM10 standard to provide
protection from thoracic coarse particle
exposures and to revoke the annual
PM10 standard. Id. at 533–38. With
regard to the secondary PM2.5 standards,
the court remanded the standards to the
EPA because the Agency failed to
adequately explain why setting the
secondary PM standards identical to the
primary standards provided the
required protection for public welfare,
including protection from visibility
impairment. Id. at 528–32. The EPA
responded to the court’s remands as part
of the next review of the PM NAAQS,
which was initiated in 2007 (discussed
below).
4. Review Completed in 2012
In June 2007, the EPA initiated the
fourth periodic review of the air quality
criteria and the PM NAAQS by issuing
a call for information (72 FR 35462, June
28, 2007). Based on the NAAQS review
process, as revised in 2008 and again in
2009,10 the EPA held science/policy
issue workshops on the primary and
secondary PM NAAQS (72 FR 34003,
June 20, 2007; 72 FR 34005, June 20,
2007), and prepared and released the
planning and assessment documents
that comprise the review process (i.e.,
IRP (U.S. EPA, 2008), ISA (U.S. EPA,
2009c), REA planning documents for
health and welfare (U.S. EPA, 2009b,
U.S. EPA, 2009a), a quantitative health
risk assessment (U.S. EPA, 2010a) and
an urban-focused visibility assessment
10 The history of the NAAQS review process,
including revisions to the process, is discussed at
https://www.epa.gov/naaqs/historical-informationnaaqs-review-process.
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(U.S. EPA, 2010a), and PA (U.S. EPA,
2011)). In June 2012, the EPA
announced its proposed decision to
revise the NAAQS for PM (77 FR 38890,
June 29, 2012).
In December 2012, the EPA
announced its final decisions to revise
the primary NAAQS for PM to provide
increased protection of public health (78
FR 3086, January 15, 2013). With regard
to primary standards for PM2.5, the EPA
revised the level of the annual PM2.5
standard 11 to 12.0 mg/m3 and retained
the 24-hour PM2.5 standard, with its
level of 35 mg/m3. For the primary PM10
standard, the EPA retained the 24-hour
standard to continue to provide
protection against effects associated
with short-term exposure to thoracic
coarse particles (i.e., PM10-2.5). With
regard to the secondary PM standards,
the EPA generally retained the 24-hour
and annual PM2.5 standards 12 and the
24-hour PM10 standard to address
visibility and non-visibility welfare
effects.
As with previous reviews, petitioners
challenged the EPA’s final rule.
Petitioners argued that the EPA acted
unreasonably in revising the level and
form of the annual standard and in
amending the monitoring network
provisions. On judicial review, the
revised standards and monitoring
requirements were upheld in all
respects. NAM v. EPA, 750 F.3d 921
(D.C. Cir. 2014).
5. Current Review
In December 2014, the EPA
announced the initiation of the current
periodic review of the air quality criteria
for PM and of the PM2.5 and PM10
NAAQS and issued a call for
information (79 FR 71764, December 3,
2014). On February 9 to 11, 2015, the
EPA’s NCEA and OAQPS held a public
workshop to inform the planning for the
current review of the PM NAAQS
(announced in 79 FR 71764, December
3, 2014). Workshop participants,
including a wide range of external
experts as well as EPA staff representing
a variety of areas of expertise (e.g.,
epidemiology, human and animal
toxicology, risk/exposure analysis,
atmospheric science, visibility
impairment, climate effects), were asked
to highlight significant new and
emerging PM research, and to make
recommendations to the Agency
regarding the design and scope of this
review. This workshop provided for a
public discussion of the key science and
11 The EPA also eliminated the option for spatial
averaging.
12 Consistent with the primary standard, the EPA
eliminated the option for spatial averaging with the
annual standard.
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policy-relevant issues around which the
EPA has structured the current review
of the PM NAAQS and of the most
meaningful new scientific information
that would be available in this review to
inform understanding of these issues.
The input received at the workshop
guided the EPA staff in developing a
draft IRP, which was reviewed by the
CASAC Particulate Matter Panel and
discussed on public teleconferences
held in May 2016 (81 FR 13362, March
14, 2016) and August 2016 (81 FR
39043, June 15, 2016). Advice from the
CASAC, supplemented by the
Particulate Matter Panel, and input from
the public were considered in
developing the final IRP (U.S. EPA,
2016). The final IRP discusses the
approaches to be taken in developing
key scientific, technical, and policy
documents in this review and the key
policy-relevant issues.
In May 2018, the Administrator
issued a memorandum describing a
‘‘back-to-basics’’ process for reviewing
the NAAQS (Pruitt, 2018). This memo
announced the Agency’s intention to
conduct the current review of the PM
NAAQS in such a manner as to ensure
that any necessary revisions are
finalized by December 2020. Following
this memo, on October 10, 2018 the
Administrator additionally announced
that the role of reviewing the key
assessments developed as part of the
ongoing review of the PM NAAQS (i.e.,
drafts of the ISA and PA) would be
performed by the seven-member
chartered CASAC (i.e., rather than the
CASAC Particulate Matter Panel that
reviewed the draft IRP).13
The EPA released the draft ISA in
October 2018 (83 FR 53471, October 23,
2018). The draft ISA was reviewed by
the chartered CASAC at a public
meeting held in Arlington, VA in
December 2018 (83 FR 55529, November
6, 2018) and was discussed on a public
teleconference in March 2019 (84 FR
8523, March 8, 2019). The CASAC
provided its advice on the draft ISA in
a letter to the EPA Administrator dated
April 11, 2019 (Cox, 2019b). In that
letter, the CASAC’s recommendations
address both the draft ISA’s assessment
of the science for PM-related effects and
the process under which this review of
the PM NAAQS is being conducted.
Regarding the assessment of the
evidence, the CASAC letter states that
13 The CASAC charter is available at: https://
yosemite.epa.gov/sab/sabproduct.nsf/WebCASAC/
2019casaccharter/$File/CASAC%202019%20
Renewal%20Charter%203.21.19%20-%20final.pdf.
The Administrator’s announcement is available at:
https://archive.epa.gov/epa/newsreleases/actingadministrator-wheeler-announces-science-advisorskey-clean-air-act-committee.html.
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‘‘the Draft ISA does not provide a
sufficiently comprehensive, systematic
assessment of the available science
relevant to understanding the health
impacts of exposure to particulate
matter (PM)’’ (Cox, 2019b, p. 1 of letter).
The CASAC recommended that this and
other limitations (i.e., ‘‘[i]nadequate
evidence for altered causal
determinations’’ and the need for a
‘‘[c]learer discussion of causality and
causal biological mechanisms and
pathways’’) be remedied in a revised
ISA (Cox, 2019b, p. 1 of letter).
Given the Administrator’s timeline for
this review, as noted above (Pruitt,
2018), the EPA did not prepare a second
draft ISA. Rather, the EPA has taken
steps to address the CASAC’s comments
in the Final PM ISA (U.S. EPA, 2019).
In particular, the final ISA includes
additional text and a new appendix to
clarify the comprehensive and
systematic process employed by the
EPA to develop the PM ISA. In addition,
several causality determinations were
re-examined and, consistent with the
CASAC advice, the final ISA reflects a
revised causality determination for longterm ultrafine particle (UFP) exposures
and nervous system effects (i.e., from
‘‘likely to be causal’’ to ‘‘suggestive of,
but not sufficient to infer, a causal
relationship’’).14 The final ISA also
contains additional text to clarify the
evidence for biological pathways of
particular PM-related effects and the
role of that evidence in causality
determinations.
Among its comments on the process,
the chartered CASAC recommended
‘‘that the EPA reappoint the previous
CASAC PM panel (or appoint a panel
with similar expertise)’’ (Cox, 2019b).
The Agency’s response to this advice
was provided in a letter from the
Administrator to the CASAC chair dated
July 25, 2019.15 In that letter, the
Administrator announced his intention
to identify a pool of non-member subject
matter expert consultants to support the
CASAC’s review activities for the PM
and ozone NAAQS. A Federal Register
notice requesting the nomination of
scientists from a broad range of
disciplines ‘‘with demonstrated
expertise and research in the field of air
pollution related to PM and ozone’’ was
published in August 2019 (84 FR 38625,
14 Based on the CASAC’s comments, the EPA also
re-examined the causality determinations for cancer
and for nervous system effects following long-term
PM2.5 exposures. The EPA’s consideration of these
comments in the final ISA is discussed below in
sections II.B.1.d and II.B.1.e.
15 Available at: https://yosemite.epa.gov/sab/
sabproduct.nsf/0/6CBCBBC3025
E13B4852583D90047B352/$File/EPA-CASAC-19002_Response.pdf.
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August 7, 2019). The Administrator
selected consultants from among those
nominated, and input from members of
this pool of consultants informed the
CASAC’s review of the draft PA.
The EPA released the draft PA in
September 2019 (84 FR 47944,
September 11, 2019). The draft PA drew
from the assessment of the evidence in
the draft ISA. It was reviewed by the
chartered CASAC and discussed in
October 2019 at a public meeting held
in Cary, NC. Public comments were
received via a separate public
teleconference (84 FR 51555, September
30, 2019). A public meeting to discuss
the chartered CASAC letter and
response to charge questions on the
draft PA was held in Cary, NC in
December 2019 (84 FR 58713, November
1, 2019), and the CASAC provided its
advice on the draft PA, including its
advice on the current primary and
secondary PM standards, in a letter to
the EPA Administrator dated December
16, 2019 (Cox, 2019a).
With regard to the primary standards,
the CASAC recommended retaining the
current 24-hour PM2.5 and PM10
standards but did not reach consensus
on the adequacy of the current annual
PM2.5 standard. With regard to the
secondary standards, the CASAC
recommended retaining the current
standards. The CASAC’s advice on the
primary and secondary PM standards,
and the Administrator’s consideration of
that advice in reaching proposed
decisions, is discussed in detail in
sections II.C.2 and II.C.3 (primary PM2.5
standards), III.C.2 and III.C.3 (primary
PM10 standards), and IV.D.2 and IV.D.3
(secondary standards) of this document.
The CASAC additionally made a
number of recommendations regarding
the information and analyses presented
in the draft PA. Specifically, the CASAC
recommended that a revised PA include
(1) additional discussion of the current
CASAC and NAAQS review process; (2)
additional characterization of PMrelated emissions, monitoring and air
quality information, including
uncertainties in that information; (3)
additional discussion and examination
of uncertainties in the PM2.5 health
evidence and the risk assessment; (4)
updates to reflect changes in the ISA’s
causality determinations; and (5)
additional discussion of the evidence
for PM-related welfare effects, including
uncertainties (Cox, 2019a, pp. 2–3 in
letter). In response to the CASAC’s
comments, the final PA 16 incorporated
16 Given the Administrator’s timeline for this
review, as noted above (Pruitt, 2018), the EPA did
not prepare a second draft PA. Rather, the CASAC’s
advice was considered in developing the final PA
(U.S. EPA, 2020).
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a number of changes, including the
following (U.S. EPA, 2020):
• Text was added to Chapter 1 to
clarify the process followed for this
review of the PM NAAQS, including
how the process has evolved since the
initiation of the review.
• Text and figures were added to
Chapter 2 on emissions of PM and PM
precursors, and a section discussing
uncertainty in emissions estimates was
added. A discussion of measurement
uncertainty for FRM, FEM, CSN, and
IMPROVE monitors was also added.
• Chapter 3 and Appendices B and C
include a number of changes, including:
Æ An expanded characterization and
discussion of the evidence related to
exposure measurement error, the
potential confounders examined by key
studies, the shapes of concentrationresponse functions, and the results of
causal inference and quasi-experimental
studies.
Æ An expanded and clarified
discussion of uncertainties in the risk
assessment, and additional air quality
model performance evaluations for each
of the urban study areas included in the
risk assessment.
Æ Additional detail on the procedure
used to derive concentration-response
functions used in the risk assessment.
Æ Changes in the text to reflect the
change in the final ISA’s causality
determination from ‘‘likely to be causal’’
to ‘‘suggestive of, but not sufficient to
infer, a causal relationship.’’
• Throughout the document
(Chapters 3, 4 and 5), summaries of the
CASAC advice on the PM standards are
included, and expanded discussions of
data gaps and areas for future research
in the health and welfare effects
evidence are presented.
D. Air Quality Information
This section provides a summary of
basic information related to PM ambient
air quality. It summarizes information
on the distribution of particle size in
ambient air (I.D.1), sources and
emissions contributing to PM in the
ambient air (I.D.2), monitoring of
ambient PM in the U.S. (I.D.3), ambient
PM concentrations and trends in the
U.S. (I.D.4), and background PM (I.D.5).
Additional detail on PM air quality can
be found in Chapter 2 of the Policy
Assessment (U.S. EPA, 2020; PA).
1. Distribution of Particle Size in
Ambient Air
In ambient air, PM is a mixture of
substances suspended as small liquid
and/or solid particles (U.S. EPA, 2019,
section 2.2). Particle size is an important
consideration for PM, as distinct health
and welfare effects have been linked
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with exposures to particles of different
sizes. Particles in the atmosphere range
in size from less than 0.01 to more than
10 mm in diameter (U.S. EPA, 2019,
section 2.2). When describing PM,
subscripts are used to denote the
aerodynamic diameter 17 of the particle
size range, in mm, of 50% cut points of
sampling devices. The EPA defines
PM2.5, also referred to as fine particles,
as particles with aerodynamic diameters
generally less than or equal to 2.5 mm.
The size range for PM10-2.5, also called
coarse or thoracic coarse particles,
includes those particles with
aerodynamic diameters generally greater
than 2.5 mm and less than or equal to
10 mm. PM10, which is comprised of
both fine and coarse fractions, includes
those particles with aerodynamic
diameters generally less than or equal to
10 mm. In addition, UFP are often
defined as particles with a diameter of
less than 0.1 mm based on physical size,
thermal diffusivity or electrical mobility
(U.S. EPA, 2019, section 2.2).
Atmospheric distributions of particle
size generally exhibit distinct modes
that roughly align with the PM size
fractions defined above. The nucleation
mode is made up of freshly generated
particles, formed either during
combustion or by atmospheric reactions
of precursor gases. The nucleation mode
is especially prominent near sources
like heavy traffic, industrial emissions,
biomass burning, or cooking (Vu et al.,
2015). While nucleation mode particles
are only a minor contributor to overall
ambient PM mass and surface area, they
are the main contributors to ambient
particle number (U.S. EPA, 2019,
section 2.2). By number, most
nucleation mode particles fall into the
UFP size range, though some fraction of
the nucleation mode number
distribution can extend above 0.1 mm in
diameter. Nucleation mode particles can
grow rapidly through coagulation or
uptake of gases by particle surfaces,
giving rise to the accumulation mode.
The accumulation mode is typically the
predominant contributor to PM2.5 mass,
though only a minor contributor to
particle number (U.S. EPA, 2019,
section 2.2). PM2.5 sampling methods
measure most of the accumulation mode
mass, although a small fraction of
particles that make up the accumulation
mode are greater than 2.5 mm in
diameter. Coarse mode particles are
formed by mechanical generation, and
through processes like dust
resuspension and sea spray formation
17 Aerodynamic diameter is the size of a sphere
of unit density (i.e., 1 g/cm3) that has the same
terminal settling velocity as the particle of interest
(U.S. EPA, 2019, section 4.1.1).
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(Whitby et al., 1972). Most coarse mode
mass is captured by PM10-2.5 sampling,
but small fractions of coarse mode mass
can be smaller than 2.5 mm or greater
than 10 mm in diameter (U.S. EPA, 2019,
section 2.2).
Most particles are found in the lower
troposphere, where they can have
residence times ranging from a few
hours to weeks. Particles are removed
from the atmosphere by wet deposition,
such as when they are carried by rain or
snow, or by dry deposition, when
particles settle out of suspension due to
gravity. Atmospheric lifetimes are
generally longest for PM2.5, which often
remains in the atmosphere for days to
weeks (U.S. EPA, 2019, Table 2–1)
before being removed by wet or dry
deposition. In contrast, atmospheric
lifetimes for UFP and PM10-2.5 are
shorter. Within hours, UFP can undergo
coagulation and condensation that lead
to formation of larger particles in the
accumulation mode, or can be removed
from the atmosphere by evaporation,
deposition, or reactions with other
atmospheric components. PM10-2.5 are
also generally removed from the
atmosphere within hours, through wet
or dry deposition (U.S. EPA, 2019, Table
2–1).
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2. Sources and Emissions Contributing
to PM in the Ambient Air
PM is composed of both primary
(directly emitted particles) and
secondary particles. Primary PM is
derived from direct particle emissions
from specific PM sources while
secondary PM originates from gas-phase
chemical compounds present in the
atmosphere that have participated in
new particle formation or condensed
onto existing particles (U.S. EPA, 2019,
section 2.3). As discussed further in the
ISA (U.S. EPA, 2019, section 2.3.2.1),
secondary PM is formed in the
atmosphere by photochemical oxidation
reactions of both inorganic and organic
gas-phase precursors. Precursor gases
include sulfur dioxide (SO2), nitrogen
oxides (NOX), and volatile organic
compounds (VOC) (U.S. EPA, 2019,
section 2.3.2.1). Ammonia also plays an
important role in the formation of
nitrate PM by neutralizing sulfuric acid
and nitric acid. Sources and emissions
of PM are discussed in more detail in
section 2.1.1 of the PA (U.S. EPA, 2020).
Direct emissions of PM have remained
relatively unchanged in recent years,
while emissions of some precursor gases
have declined substantially.18 From
18 More information on these trends, including
details on methods and explanations on the noted
changes over time is available at https://
gispub.epa.gov/neireport/2014/.
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1990 to 2014, SO2 emissions have
undergone the largest declines while
NH3 emissions have undergone the
smallest change. Declining SO2
emissions during this time period are
primarily a result of reductions at
stationary sources such as EGUs, with
substantial reductions also from mobile
sources (U.S. EPA, 2019, section
2.3.2.1).19
3. Monitoring of Ambient PM
To promote uniform enforcement of
the air quality standards set forth under
the CAA and to achieve the degree of
public health and welfare protection
intended for the NAAQS, the EPA
established PM Federal Reference
Methods (FRMs) 20 for both PM10 and
PM2.5 (40 CFR appendix J and L to Part
50) and performance requirements for
approval of Federal Equivalent Methods
(FEMs) (40 CFR part 53). Amended
following the 2006 and 2012 p.m.
NAAQS reviews, the current PM
monitoring network relies on FRMs and
automated continuous FEMs, in part to
support changes necessary for
implementation of the revised PM
standards. The requirements for
measuring ambient air quality and
reporting ambient air quality data and
related information are the basis for 40
CFR appendices A through E to Part 58.
More information on PM ambient
monitoring networks is available in
section 2.2 of the PA (U.S. EPA, 2020).
4. Ambient Concentrations and Trends
This section summarizes available
information on recent ambient PM
concentrations in the U.S. and on trends
in PM air quality. Sections I.D.4.a and
I.D.4.b summarize information on PM2.5
mass and components, respectively.
Section I.D.4.c summarizes information
on PM10. Sections I.D.4.d and I.D.4.e
summarize the more limited
information on PM10-2.5 and UFP,
respectively. Additional detail on PM
air quality and trends can be found in
section 2.3 of the PA (U.S. EPA, 2020).
a. PM2.5 Mass
At monitoring sites in the U.S.,
annual PM2.5 concentrations from 2015
to 2017 averaged 8.0 mg/m3 (and ranged
19 State-specific emission trends data for 1990 to
2014 can be found at: https://www.epa.gov/airemissions-inventories/air-pollutant-emissionstrends-data.
20 FRMs provide the methodological basis for
comparison to the NAAQS and also serve as the
‘‘gold-standard’’ for the comparison of other
methods being reviewed for potential approval as
equivalent methods. The EPA keeps a complete list
of designated reference and equivalent methods
available on its Ambient Monitoring Technology
Information Center (AMTIC) website (https://
www.epa.gov/amtic/air-monitoring-methodscriteria-pollutants).
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from 3.0 to 18.2 mg/m3) and the 98th
percentiles of 24-hour concentrations
averaged 20.9 mg/m3 (and ranged from
9.2 to 111 mg/m3) (U.S. EPA, 2020,
section 2.3.2.1). The highest ambient
PM2.5 concentrations occur in the west,
particularly in California and the Pacific
northwest (U.S. EPA, 2020, Figure 2–8).
Much of the eastern U.S. has lower
ambient concentrations, with annual
average concentrations generally at or
below 12.0 mg/m3 and 98th percentiles
of 24-hour concentrations generally at or
below 30 mg/m3 (U.S. EPA, 2020, section
2.3.2).
Recent ambient PM2.5 concentrations
reflect the substantial reductions that
have occurred across much of the U.S.
(U.S. EPA, 2020, section 2.3.2.1). From
2000 to 2017, national annual average
PM2.5 concentrations have declined
from 13.5 mg/m3 to 8.0 mg/m3, a 41%
decrease (U.S. EPA, 2020, section
2.3.2.1).21 These declines have occurred
at urban and rural monitoring sites,
although urban PM2.5 concentrations
remain consistently higher than those in
rural areas (Chan et al., 2018) due to the
impact of local sources in urban areas.
Analyses at individual monitoring sites
indicate that declines in ambient PM2.5
concentrations have been most
consistent across the eastern U.S. and in
parts of coastal California, where both
annual average and 98th percentiles of
24-hour concentrations have declined
significantly (U.S. EPA, 2020, section
2.3.2.1). In contrast, trends in ambient
PM2.5 concentrations have been less
consistent over much of the western
U.S., with no significant changes since
2000 observed at some sites in the
Pacific northwest, the northern Rockies
and plains, and the southwest,
particularly for 98th percentiles of 24hour concentrations (U.S. EPA, 2020,
section 2.3.2.1).
The recent deployment of PM2.5
monitors near major roads in large
urban areas provides information on
PM2.5 concentrations near an important
emissions source. Of the 25 CBSAs with
valid design values at near-road
monitoring sites,22 52% measured the
highest annual design value at the nearroad site while 24% measured the
highest 24-hour design value at the
near-road site (U.S. EPA, 2020, section
2.3.2.2). Of the CBSAs with highest
21 See https://www.epa.gov/air-trends/particulatematter-pm25-trends and https://www.epa.gov/airtrends/particulate-matter-pm25-trends#pmnat for
more information.
22 A design value is considered valid if it meets
the data handling requirements given in 40 CFR
appendix N to Part 50. Several large CBSAs such
as Chicago-Naperville-Elgin, IL–IN–WI and
Houston-The Woodlands-Sugar Land, TX had nearroad sites that did not have valid PM2.5 design
values for the 2015–2017 period.
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annual design values at near-road sites,
those design values were, on average,
0.7 mg/m3 higher than at the highest
measuring non-near-road sites (range is
0.1 to 2.0 mg/m3 higher at near-road
sites). Although most near-road
monitoring sites do not have sufficient
data to evaluate long-term trends in
near-road PM2.5 concentrations,
analyses of the data at one near-roadlike site in Elizabeth, NJ,23 show that the
annual average near-road increment has
generally decreased between 1999 and
2017 from about 2.0 mg/m3 to about 1.3
mg/m3 (U.S. EPA, 2020, section 2.3.2.2).
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b. PM2.5 Components
Based on recent air quality data, the
major chemical components of PM2.5
have distinct spatial distributions.
Sulfate concentrations tend to be
highest in the eastern U.S., while in the
Ohio Valley, Salt Lake Valley, and
California nitrate concentrations are
highest, and relatively high
concentrations of organic carbon are
widespread across most of the
continental U.S. (U.S. EPA, 2020,
section 2.3.2.3). Elemental carbon,
crustal material, and sea-salt are found
to have the highest concentrations in the
northeast U.S., southwest U.S., and
coastal areas, respectively.
An examination of PM2.5 composition
trends can provide insight into the
factors contributing to overall
reductions in ambient PM2.5
concentrations. The biggest change in
PM2.5 composition that has occurred in
recent years is the reduction in sulfate
concentrations due to reductions in SO2
emissions. Between 2000 and 2015, the
nationwide annual average sulfate
concentration decreased by 17% at
urban sites and 20% at rural sites. This
change in sulfate concentrations is most
evident in the eastern U.S. and has
resulted in organic matter or nitrate now
being the greatest contributor to PM2.5
mass in many locations (U.S. EPA, 2019,
Figure 2–19). The overall reduction in
sulfate concentrations has contributed
substantially to the decrease in national
average PM2.5 concentrations as well as
the decline in the fraction of PM10 mass
accounted for by PM2.5 (U.S. EPA, 2019,
section 2.5.1.1.6; U.S. EPA, 2020,
section 2.3.1).
c. PM10
At monitoring sites in the U.S., the
2015–2017 average of 2nd highest 24hour PM10 concentration was 56 mg/m3
(ranging from 18 to 173 mg/m3) (U.S.
23 The
Elizabeth Lab site in Elizabeth, NJ is
situated approximately 30 meters from travel lanes
of the Interchange 13 toll plaza of the New Jersey
Turnpike and within 200 meters of travel lanes for
Interstate 278 and the New Jersey Turnpike.
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EPA, 2020, section 2.3.2.4).24 The
highest PM10 concentrations tend to
occur in the western U.S. Seasonal
analyses indicate that ambient PM10
concentrations are generally higher in
the summer months than at other times
of year, though the most extreme high
concentration events are more likely in
the spring (U.S. EPA, 2019, Table 2–5).
This is due to fact that the major PM10
emission sources, dust and agriculture,
are more active during the warmer and
drier periods of the year.
Recent ambient PM10 concentrations
reflect reductions that have occurred
across much of the U.S. (U.S. EPA,
2020, section 2.3.2.4). From 2000 to
2017, annual second highest 24-hour
PM10 concentrations have declined by
about 30% (U.S. EPA, 2020, section
2.3.2.4).25 These PM10 concentrations
have generally declined in the eastern
U.S., while concentrations in the much
of the midwest and western U.S. have
remained unchanged or increased since
2000 (U.S. EPA, 2020, section 2.3.2.4).
Analyses at individual monitoring sites
indicate that annual average PM10
concentrations have also declined at
most sites across the U.S., with much of
the decrease in the eastern U.S.
associated with reductions in PM2.5
concentrations.
d. PM10-2.5
Since the last review, the availability
of PM10-2.5 ambient concentration data
has greatly increased. As illustrated in
the PA (U.S. EPA, 2020, section 2.3.2.5),
annual average and 98th percentile
PM10-2.5 concentrations exhibit less
distinct differences between the eastern
and western U.S. than for either PM2.5
or PM10. Additionally, compared to
PM2.5 and PM10, changes in PM10-2.5
concentrations have been small in
magnitude and inconsistent in direction
(U.S. EPA, 2020, section 2.3.2.5).
e. UFP
Compared to PM2.5 mass, there is
relatively little data on U.S. particle
number concentrations, which are
dominated by UFP. Based on
measurements in two urban areas (New
York City, Buffalo) and at a background
site (Steuben County) in New York,
urban particle number counts were
several times higher than at the
background site (U.S. EPA, 2020,
section 2.3.2.6; U.S. EPA, 2019, Figure
2–18). The highest particle number
counts in an urban area with multiple
24 The form of the current 24-hour PM
10 standard
is one-expected-exceedance, averaged over three
years.
25 For more information, see https://
www.epa.gov/air-trends/particulate-matter-pm10trends#pmnat.
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sites (Buffalo) were observed at a nearroad location.
Long-term trends in UFP are not
routinely available at U.S. monitoring
sites. At one site in Illinois with longterm data available, the annual average
particle number concentration declined
between 2000 and 2017, closely
matching the reductions in annual PM2.5
mass over that same period (U.S. EPA,
2020, section 2.3.2.6). In addition, a
small number of published studies have
examined UFP trends over time. While
limited, these studies also suggest that
UFP number concentrations have
declined over time along with decreases
in PM2.5 (U.S. EPA, 2020, section
2.3.2.6).
5. Background PM
In this review, background PM is
defined as all particles that are formed
by sources or processes that cannot be
influenced by actions within the
jurisdiction of concern. U.S. background
PM is defined as any PM formed from
emissions other than U.S. anthropogenic
(i.e. manmade) emissions. Potential
sources of U.S. background PM include
both natural sources (i.e., PM that would
exist in the absence of any
anthropogenic emissions of PM or PM
precursors) and transboundary sources
originating outside U.S. borders.
Background PM is discussed in more
detail in section 2.4 of the PA (U.S.
EPA, 2020).
At annual and national scales,
estimated background PM
concentrations in the U.S. are small
compared to contributions from
domestic anthropogenic emissions. For
example, based on zero-out modeling in
the last review of the PM NAAQS,
annual background PM2.5
concentrations were estimated to range
from 0.5–3 mg/m3 across the sites
examined. In addition, speciated
monitoring data from IMPROVE sites
can provide some insights into how
contributions from different PM sources,
including sources of background PM,
may have changed over time. As
discussed further in the PA (U.S. EPA,
2020, section 2.4), such data suggests
that estimates of background
concentrations at IMPROVE monitors
are around 1–3 mg/m3, and have not
changed significantly since the last PM
NAAQS Review.
As discussed further in the PA (U.S.
EPA, 2020, section 2.4), sources that
contribute to natural background PM
include dust from the wind erosion of
natural surfaces, sea salt, wildland fires,
primary biological aerosol particles such
as bacteria and pollen, oxidation of
biogenic hydrocarbons such as isoprene
and terpenes to produce secondary
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organic aerosols (SOA), and geogenic
sources such as sulfate formed from
volcanic production of SO2 and oceanic
production of dimethyl-sulfide. While
most of these sources release or
contribute predominantly to fine
aerosol, some sources including
windblown dust, and sea salt also
produce particles in the coarse size
range (U.S. EPA, 2019, section 2.3.3).
The magnitude and sources of
background PM can vary widely by
region and time of year. Coastal sites
may experience a consistent
contribution of PM from sea spray
aerosol, while other areas covered with
dense vegetation may be impacted by
biogenic aerosol production during the
summertime. Sources of background PM
also operate across a range of time
scales. While some sources like biogenic
aerosol vary at monthly to seasonal
scales, many sources of background PM
are episodic in nature. These episodic
sources (e.g., large wildfires) can be
characterized by infrequent
contributions to high-concentration
events occurring over shorter periods of
time (e.g., hours to several days). Such
episodic events are sporadic and do not
necessarily occur in all years. While
these exceptional episodes can lead to
exceedances of the 24-hour PM2.5
standard (35 mg/m3) in some cases
(Schweizer et al., 2017), such events are
routinely screened for and usually
identifiable in the monitoring data. As
described further in the PA (U.S. EPA,
2020, section 2.4), contributions to
background PM in the U.S. result
mainly from sources within North
America. Contributions from
intercontinental events have also been
documented (e.g., transport from dust
storms occurring in deserts in North
Africa and Asia), but these events are
less frequent and represent a relatively
small fraction of background PM in
most places.
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II. Rationale for Proposed Decisions on
the Primary PM2.5 Standards
This section provides the rationale
supporting the Administrator’s
proposed decisions on the primary
PM2.5 standards. Section II.A describes
the Agency’s approach to reaching
decisions on the primary PM2.5
standards in the last review and
summarizes the general approach to
reaching proposed decisions in this
review. Section II.B summarizes the
scientific evidence for PM2.5-related
health effects. Section II.C presents the
Administrator’s proposed conclusions
regarding the adequacy of the current
primary PM2.5 standards and his
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proposed decision to retain those
standards in this review.26
A. General Approach
1. Approach Used in the Last Review
The last review of the primary PM
NAAQS was completed in 2012 (78 FR
3086, January 15, 2013). As noted above
(section 1.3), in the last review the EPA
lowered the level of the primary annual
PM2.5 standard from 15.0 to 12.0 mg/
m3,27 and retained the existing 24-hour
PM2.5 standard with its level of 35 mg/
m3. The 2012 decision to strengthen the
suite of primary PM2.5 standards was
based on the prior Administrator’s
consideration of the extensive body of
scientific evidence assessed in the 2009
ISA (U.S. EPA, 2009c); the quantitative
risk analyses presented in the 2010
health risk assessment (U.S. EPA,
2010a); the advice and
recommendations of the CASAC (Samet,
2009; Samet, 2010c; Samet, 2010b); and
public comments on the proposed rule
(78 FR 3086, January 15, 2013; U.S.
EPA, 2012a). She particularly noted the
‘‘strong and generally robust body of
evidence of serious health effects
associated with both long- and shortterm exposures to PM2.5’’ (78 FR 3120,
January 15, 2013). This included
epidemiologic studies reporting health
effect associations based on long-term
average PM2.5 concentrations ranging
from about 15.0 mg/m3 or above (i.e., at
or above the level of the then-existing
annual standard) to concentrations
‘‘significantly below the level of the
annual standard’’ (78 FR 3120, January
15, 2013). Based on her ‘‘confidence in
the association between exposure to
PM2.5 and serious public health effects,
combined with evidence of such an
association in areas that would meet the
current standards’’ (78 FR 3120, January
15, 2013), the prior Administrator
concluded that revision of the suite of
primary PM2.5 standards was necessary
in order to provide increased public
health protection.
The prior Administrator next
considered what specific revisions to
the existing primary PM2.5 standards
were appropriate, given the available
evidence and quantitative risk
information. She considered both the
annual and 24-hour PM2.5 standards,
focusing on the basic elements of those
standards (i.e., indicator, averaging
time, form, and level). These
26 Sections
III and IV provide the rationales
supporting the Administrator’s proposed decisions
on the primary PM10 standard and secondary
standards, respectively.
27 The Agency also eliminated spatial averaging
provisions as part of the form of the annual
standard.
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considerations, and the prior
Administrator’s conclusions, are
summarized in sections II.A.1.a to
II.A.1.d below.
a. Indicator
In the last review, the EPA considered
issues related to the appropriate
indicator for fine particles, with a focus
on evaluating support for the existing
PM2.5 mass-based indicator and for
potential alternative indicators based on
the UFP fraction or on fine particle
composition (78 FR 3121, January 15,
2013).28 With regard to PM2.5 mass, as
in the 1997 and 2006 reviews, the health
studies available during the last review
continued to link adverse health
outcomes (e.g., premature mortality,
hospital admissions, emergency
department visits) with long- and shortterm exposures to fine particles indexed
largely by PM2.5 mass (78 FR 3121,
January 15, 2013). With regard to the
ultrafine fraction of ambient PM, the
2011 PA noted the limited body of
health evidence assessed in the 2009
ISA (summarized in U.S. EPA, 2009c,
section 2.3.5 and Table 2–6) and the
limited monitoring information
available to characterize ambient
concentrations of UFP (U.S. EPA, 2011,
section 1.3.2). With regard to PM
composition, the 2009 ISA concluded
that ‘‘the evidence is not yet sufficient
to allow differentiation of those
constituents or sources that are more
closely related to specific health
outcomes’’ (U.S. EPA, 2009c, pp. 2–26
and 6–212; 78 FR 3123, January 15,
2013). The 2011 PA further noted that
‘‘many different constituents of the fine
particle mixture as well as groups of
components associated with specific
source categories of fine particles are
linked to adverse health effects’’ (U.S.
EPA, 2011, p. 2–55; 78 FR 3123, January
15, 2013). Consistent with the
considerations and conclusions in the
2011 PA, the CASAC advised that it was
appropriate to consider retaining PM2.5
as the indicator for fine particles. In
light of the evidence and the CASAC’s
advice, the prior Administrator
concluded that it was ‘‘appropriate to
retain PM2.5 as the indicator for fine
particles’’ (78 FR 3123, January 15,
2013).
28 In the last review, the ISA defined UFP as
generally including particles with a mobility
diameter less than or equal to 0.1 mm. Mobility
diameter is defined as the diameter of a particle
having the same diffusivity or electrical mobility in
air as the particle of interest, and is often used to
characterize particles of 0.5 mm or smaller (U.S.
EPA, 2009c, pp. 3–2 to 3–3).
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b. Averaging Time
In 1997, the EPA set an annual PM2.5
standard to provide protection from
health effects associated with long- and
short-term exposures to PM2.5, and a 24hour standard to supplement the
protection afforded by the annual
standard (62 FR 38667 to 38668, July 18,
1997). In the 2006 review, the EPA
retained both annual and 24-hour
averaging times (71 FR 61164, October
17, 2006). In the last review, the EPA
again considered issues related to the
appropriate averaging times for PM2.5
standards, with a focus on evaluating
support for the existing annual and 24hour averaging times and for potential
alternative averaging times based on
sub-daily or seasonal metrics.
Based on the evidence assessed in the
ISA, the 2011 PA noted that the
overwhelming majority of studies that
had been conducted since the 2006
review continued to utilize annual (or
multi-year) or 24-hour PM averaging
periods (U.S. EPA, 2011, section 2.3.2).
Given this, and limitations in the data
for alternatives, the 2011 PA reached the
overall conclusions that the available
information provided strong support for
considering retaining the current annual
and 24-hour averaging times (U.S. EPA,
2011, p. 2–58). The CASAC agreed that
these conclusions were reasonable
(Samet, 2010a, p. 13). The prior
Administrator concurred with the PA
conclusions and with the CASAC’s
advice. Specifically, she judged that it
was ‘‘appropriate to retain the current
annual and 24-hour averaging times for
the primary PM2.5 standards to protect
against health effects associated with
long- and short-term exposure periods’’
(78 FR 3124, January 15, 2013).
c. Form
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In 1997, the EPA established the form
of the annual PM2.5 standard as an
annual arithmetic mean, averaged over
3 years, from single or multiple
community-oriented monitors.29 That
is, the level of the annual standard was
to be compared to measurements made
at each community-oriented monitoring
site or, if specific criteria were met,
measurements from multiple
community-oriented monitoring sites
could be averaged together (i.e., spatial
29 In the last review, the EPA replaced the term
‘‘community-oriented’’ monitor with the term
‘‘area-wide’’ monitor (U.S. EPA, 2020, section 1.3).
Area-wide monitors are those sited at the
neighborhood scale or larger, as well as those
monitors sited at micro- or middle scales that are
representative of many such locations in the same
core-based statistical area (CBSA; 78 FR 3236,
January 15, 2013). CBSAs are required to have at
least one area-wide monitor sited in the area of
expected maximum PM2.5 concentration.
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averaging) 30 (62 FR 38671 to 38672,
July 18, 1997). In the 1997 review, the
EPA also established the form of the 24hour PM2.5 standard as the 98th
percentile of 24-hour concentrations at
each monitor within an area (i.e., no
spatial averaging), averaged over three
years (62 FR at 38671 to 38674, July 18,
1997). In the 2006 review, the EPA
retained these standard forms but
tightened the criteria for using spatial
averaging with the annual standard (71
FR 61167, October 17, 2006).31
In the last review, the EPA’s
consideration of the form of the annual
PM2.5 standard again included a focus
on the issue of spatial averaging. An
analysis of air quality and population
demographic information indicated that
the highest PM2.5 concentrations in a
given area tended to be measured at
monitors in locations where the
surrounding populations were more
likely to live below the poverty line and
to include larger percentages of racial
and ethnic minorities (U.S. EPA, 2011,
p. 2–60). Based on this analysis, the
2011 PA concluded that spatial
averaging could result in
disproportionate impacts in at-risk
populations, including minority
populations and populations with lower
socioeconomic status (SES). Therefore,
the PA concluded that it was
appropriate to consider revising the
form of the annual PM2.5 standard such
that it did not allow for the use of
spatial averaging across monitors (U.S.
EPA, 2011, p. 2–60). The CASAC agreed
with the PA conclusions that it was
‘‘reasonable’’ for the EPA to eliminate
the spatial averaging provisions (Samet,
2010c, p. 2).
The prior Administrator concluded
that public health would not be
protected with an adequate margin of
safety in all locations, as required by
law, if disproportionately higher PM2.5
concentrations in low income and
minority communities were averaged
together with lower concentrations
measured at other sites in a large urban
area. Therefore, she concluded that the
form of the annual PM2.5 standard
should be revised to eliminate spatial
30 The original criteria for spatial averaging
included: (1) The annual mean concentration at
each site shall be within 20% of the spatially
averaged annual mean, and (2) the daily values for
each monitoring site pair shall yield a correlation
coefficient of at least 0.6 for each calendar quarter
(62 FR 38671 to 38672, July 18, 1997).
31 Specifically, the Administrator revised spatial
averaging criteria such that ‘‘(1) [t]he annual mean
concentration at each site shall be within 10 percent
of the spatially averaged annual mean, and (2) the
daily values for each monitoring site pair shall yield
a correlation coefficient of at least 0.9 for each
calendar quarter (71 FR 61167, October 17, 2006).
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averaging provisions (78 FR 3124,
January 15, 2013).
In the last review, the EPA also
considered the form of the 24-hour
PM2.5 standard. The Agency recognized
that the existing 98th percentile form for
the 24-hour standard was originally
selected to provide a balance between
limiting the occurrence of peak 24-hour
PM2.5 concentrations and identifying a
stable target for risk management
programs.32 Updated air quality
analyses in the last review provided
additional support for the increased
stability of the 98th percentile PM2.5
concentration, compared to the 99th
percentile (U.S. EPA, 2011, Figure 2–2,
p. 2–62). Consistent with the PA
conclusions based on this analysis, the
prior Administrator concluded that it
was appropriate to retain the 98th
percentile form for the 24-hour PM2.5
standard (78 FR 3127, January 15, 2013).
d. Level
The EPA’s approach to considering
alternative levels of the PM2.5 standards
in the last review was based on
evaluating the public health protection
afforded by the annual and 24-hour
standards, taken together, against
mortality and morbidity effects
associated with long-term or short-term
PM2.5 exposures. This approach
recognized that it is appropriate to
consider the protection provided by
attaining the air quality needed to meet
the suite of standards, and that there is
no bright line clearly directing the
choice of levels. Rather, the choice of
what is appropriate is a public health
policy judgment entrusted to the
Administrator. See Mississippi, 744 F.3d
at 1358, Lead Industries Ass’n, 647 F.2d
at 1147.
In selecting the levels of the annual
and 24-hour PM2.5 standard, the prior
Administrator placed the greatest
emphasis on health endpoints for which
the evidence was strongest, based on the
assessment of the evidence in the ISA
and on the ISA’s causality
determinations (U.S. EPA, 2009c,
section 2.3.1). She particularly noted
that the evidence was sufficient to
conclude a causal relationship exists
between PM2.5 exposures and mortality
and cardiovascular effects (i.e., for both
long- and short-term exposures) and that
the evidence was sufficient to conclude
a causal relationship is ‘‘likely’’ to exist
between PM2.5 exposures and
respiratory effects (i.e., for both long32 See ATA III, 283 F.3d at 374–76 which
concludes that it is legitimate for the EPA to
consider overall stability of the standard and its
resulting promotion of overall effectiveness of
NAAQS control programs in setting a standard that
is requisite to protect the public health.
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and short-term exposures). She also
noted additional, but more limited,
evidence for a broader range of health
endpoints, including evidence
‘‘suggestive of a causal relationship’’
between long-term exposures and
developmental and reproductive effects
as well as carcinogenic effects (78 FR
3158, January 15, 2013).
To inform her decisions on an
appropriate level for the annual
standard, the prior Administrator
considered the degree to which
epidemiologic studies indicate
confidence in the reported health effect
associations over distributions of
ambient PM2.5 concentrations. She
noted that a level of 12.0 mg/m3 was
below the long-term mean PM2.5
concentrations reported in key
epidemiologic studies that provided
evidence of an array of serious health
effects (78 FR 3161, January 15, 2013).
She further noted that 12.0 mg/m3
generally corresponded to the lower
portions (i.e., about the 25th percentile)
of distributions of health events in the
limited number of epidemiologic
studies for which population-level
information was available. A level of
12.0 mg/m3 also reflected placing some
weight on studies of reproductive and
developmental effects, for which the
evidence was more uncertain (78 FR
3161–3162, January 15, 2013).33
Given the uncertainties remaining in
the scientific information, the prior
Administrator judged that an annual
standard level below 12.0 mg/m3 was not
supported. She specifically noted
uncertainties related to understanding
the relative toxicity of the different
components in the fine particle mixture,
the role of PM2.5 in the complex ambient
mixture, exposure measurement errors
in epidemiologic studies, and the nature
and magnitude of estimated risks at
relatively low ambient PM2.5
concentrations. Furthermore, she noted
that epidemiologic studies had reported
heterogeneity in responses both within
and between cities and in geographic
regions across the U.S. She recognized
that this heterogeneity may be
attributed, in part, to differences in fine
particle composition in different regions
33 With respect to cancer, mutagenic, and
genotoxic effects, the Administrator observed that
the PM2.5 concentrations reported in studies
evaluating these effects generally included ambient
concentrations that are equal to or greater than
ambient concentrations observed in studies that
reported mortality and cardiovascular and
respiratory effects (U.S. EPA, 2009c, section 7.5).
Therefore, the Administrator concluded that, in
selecting a standard level that provides protection
from mortality and cardiovascular and respiratory
effects, it is reasonable to anticipate that protection
will also be provided for carcinogenic effects (78 FR
3161–3162, January 15, 2013).
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and cities. With regard to evidence for
reproductive and developmental effects,
the prior Administrator recognized that
there were a number of limitations
associated with this body of evidence,
including the following: The limited
number of studies evaluating such
effects; uncertainties related to
identifying the relevant exposure time
periods of concern; and limited
toxicological evidence providing little
information on the mode of action(s) or
biological plausibility for an association
between long-term PM2.5 exposures and
adverse birth outcomes. On balance, she
found that the available evidence,
interpreted in light of these remaining
uncertainties, did not justify an annual
standard level set below 12.0 mg/m3 as
being ‘‘requisite’’ to protect public
health with an adequate margin of safety
(i.e., a standard with a lower level
would have been more stringent than
necessary).
In conjunction with a revised annual
standard with a level of 12.0 mg/m3, the
prior Administrator concluded that the
evidence supported retaining the 35 mg/
m3 level of the 24-hour PM2.5 standard.
She noted that the existing 24-hour
standard, with its 35 mg/m3 level and
98th percentile form, would provide
supplemental protection, particularly
for areas with high peak-to-mean ratios
possibly associated with strong seasonal
sources and for areas with PM2.5-related
effects that may be associated with
shorter than daily exposure periods (78
FR 3163, January 15, 2013). Thus, she
concluded that the available evidence
and information, interpreted in light of
remaining uncertainties, supported an
annual standard with a level of 12.0 mg/
m3 combined with a 24-hour standard
with a level of 35 mg/m3.
2. Approach in the Current Review
The EPA’s approach to reaching
proposed decisions on the primary
PM2.5 standards in the current review
builds on the decisions made in the last
review. Consistent with that review, the
approach focuses on evaluating the
public health protection afforded by the
annual and 24-hour standards, taken
together, against mortality and
morbidity associated with long-term or
short-term PM2.5 exposures. As
discussed in the PA (U.S. EPA, 2020,
section 3.1.2), in adopting this approach
the EPA recognizes that changes in
PM2.5 air quality designed to meet an
annual standard would likely result not
only in lower annual average PM2.5
concentrations, but also in fewer and
lower short-term peak PM2.5
concentrations. Additionally, changes
designed to meet a 24-hour standard,
with a 98th percentile form, would
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result not only in fewer and lower peak
24-hour PM2.5 concentrations, but also
in lower annual average PM2.5
concentrations. Thus, the EPA’s
approach recognizes that it is
appropriate to consider the protection
provided by attaining the air quality
needed to meet the suite of standards.
This approach to reviewing the
primary PM2.5 standards is based most
fundamentally on considering the
available scientific evidence and
technical information as assessed and
discussed in the ISA (U.S. EPA, 2019)
and PA (U.S. EPA, 2020), including the
uncertainties inherent in that evidence
and information, and on consideration
of advice received from the CASAC in
this review (Cox, 2019a). The EPA
emphasizes the health outcomes for
which the ISA determines that the
evidence supports either a ‘‘causal’’ or
a ‘‘likely to be causal’’ relationship with
PM2.5 exposures (U.S. EPA, 2019). This
approach focuses proposed decisions on
the health outcomes for which the
evidence is strongest. Such a focus,
which is supported by the CASAC (Cox,
2019a, p. 12 of consensus responses),
recognizes that standards set based on
evidence supporting ‘‘causal’’ and
‘‘likely to be causal’’ health outcomes
will also provide some measure of
protection against the broader range of
PM2.5-associated outcomes, including
those for which the evidence is less
certain.
As in past reviews, the EPA’s
approach recognizes that there is no
bright line clearly directing the choice
of standards. Rather, the choice of what
is appropriate is a public health policy
judgment entrusted to the
Administrator. Specifically, the CAA
requires primary standards that, in the
judgment of the Administrator, are
requisite to protect public health with
an adequate margin of safety. In setting
primary standards that are ‘‘requisite’’ to
protect public health, the EPA’s task is
to establish standards that are neither
more nor less stringent than necessary
for this purpose. Thus, as discussed
above (I.A), the CAA does not require
that primary standards be set at a zerorisk level, but rather at a level that, in
the judgment of the Administrator,
limits risk sufficiently so as to protect
public health with an adequate margin
of safety. As in previous reviews, this
judgment includes consideration of the
strengths and limitations of the
scientific and technical information,
and the appropriate inferences to be
drawn from that information.
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B. Health Effects Related to Fine Particle
Exposures
This section draws from the EPA’s
synthesis and assessment of the
scientific evidence presented in the ISA
(U.S. EPA, 2019) and the summary of
that evidence in the PA (U.S. EPA, 2020,
section 3.2.1). The ISA uses a weight-ofevidence framework for characterizing
the strength of the available scientific
evidence for health effects attributable
to PM exposures (U.S. EPA, 2015,
Preamble, Section 5). As in the last
review (U.S. EPA, 2009c), the ISA for
this review has adopted a five-level
hierarchy to classify the overall weightof-evidence into one of the following
categories: Causal relationship; a likely
to be causal relationship; suggestive of,
but not sufficient to infer, a causal
relationship; 34 inadequate to infer the
presence or absence of a causal
relationship; and not likely to be a
causal relationship (U.S. EPA, 2015,
Preamble Table II). In using the weightof-evidence approach to inform
judgments about the likelihood that
various health effects are caused by PM
exposures, evidence is evaluated for
major outcome categories or groups of
related outcomes (e.g., respiratory
effects), integrating evidence from
across disciplines, including
epidemiologic, controlled human
exposure, and animal toxicological
studies and evaluating the coherence of
evidence across a spectrum of related
endpoints as well as biological
plausibility of the effects observed (U.S.
EPA, 2015, Preamble, Section 5.c.).
Based on application of this approach,
the EPA believes that the final ISA
‘‘accurately reflects the latest scientific
knowledge useful in indicating the kind
and extent of all identifiable effects on
public health or welfare which may be
expected from the presence of [PM] in
the ambient air, in varying quantities’’
as required by the CAA (42 U.S.C.
7408(a)(2)).
In this review of the NAAQS, the EPA
considers the full body of health
evidence, placing the greatest emphasis
on the health effects for which the
evidence has been judged in the ISA to
demonstrate a ‘‘causal’’ or a ‘‘likely to be
causal’’ relationship with PM exposures.
The ISA defines these causality
determinations as follows (U.S. EPA,
2019, p. p–20):
• Causal relationship: The pollutant
has been shown to result in health
effects at relevant exposures based on
studies encompassing multiple lines of
evidence and chance, confounding, and
34 As
noted in the 2019 p.m. ISA (U.S. EPA, 2019,
p. ES–15), this causality determination language has
been updated since the last review.
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other biases can be ruled out with
reasonable confidence.
• Likely to be a causal relationship:
There are studies in which results are
not explained by chance, confounding,
or other biases, but uncertainties remain
in the health effects evidence overall.
For example, the influence of cooccurring pollutants is difficult to
address, or evidence across scientific
disciplines may be limited or
inconsistent.
The sections below briefly summarize
the health effects evidence determined
in the ISA to support either a ‘‘causal’’
or a ‘‘likely to be causal’’ relationship
with fine particle exposures (II.B.1), the
populations potentially at increased risk
for PM-related effects (II.B.2), and the
CASAC’s advice on the draft ISA
(II.B.3). Additional detail on these
topics can be found in the ISA (U.S.
EPA, 2019) and in the PA (U.S. EPA,
2020, section 3.2).
1. Nature of Effects
Drawing from the assessment of the
evidence in the ISA (U.S. EPA, 2019),
and the summaries of that assessment in
the PA (U.S. EPA, 2020), the sections
below summarize the evidence for
relationships between long- or shortterm PM2.5 exposures and mortality
(II.B.1.a), cardiovascular effects
(II.B.1.b), respiratory effects (II.B.1.c),
cancer (II.B.1.d), and nervous system
effects (II.B.1.e). For these outcomes, the
ISA concludes that the evidence
supports either a ‘‘causal’’ or a ‘‘likely
to be causal’’ relationship with PM2.5
exposures.
a. Mortality
i. Long-term PM2.5 exposures
In the last review, the 2009 PM ISA
reported that the evidence was
‘‘sufficient to conclude that the
relationship between long-term PM2.5
exposures and mortality is causal’’ (U.S.
EPA, 2009c, p. 7–96). The strongest
evidence supporting this conclusion
was provided by epidemiologic studies,
particularly those examining two
seminal cohorts, the American Cancer
Society (ACS) cohort and the Harvard
Six Cities cohort. Analyses of the
Harvard Six Cities cohort included
demonstrations that reductions in
ambient PM2.5 concentrations are
associated with reduced mortality risk
(Laden et al., 2006) and with increases
in life expectancy (Pope et al., 2009).
Further support was provided by other
cohort studies conducted in North
America and Europe that also reported
positive associations between long-term
PM2.5 exposures and risk of mortality
(U.S. EPA, 2009c).
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Recent cohort studies, which have
become available since the 2009 ISA,
continue to provide consistent evidence
of positive associations between longterm PM2.5 exposures and mortality.
These studies add support for
associations with total and nonaccidental mortality,35 as well as with
specific causes of death, including
cardiovascular disease and respiratory
disease (U.S. EPA, 2019, section 11.2.2).
Many of these recent studies have
extended the follow-up periods
originally evaluated in the ACS and
Harvard Six Cities cohort studies and
continue to observe positive
associations between long-term PM2.5
exposures and mortality (U.S. EPA,
2019, section 11.2.2.1; Figures 11–18
and 11–19). Adding to recent
evaluations of the ACS and Six Cities
cohorts, studies conducted with other
cohorts also show consistent, positive
associations between long-term PM2.5
exposure and mortality across various
demographic groups (e.g., age, sex,
occupation), spatial and temporal
extents, exposure assessment metrics,
and statistical techniques (U.S. EPA,
2019, sections 11.2.2.1, 11.2.5). This
includes some of the largest cohort
studies conducted to date, with analyses
of the U.S. Medicare cohort that include
nearly 61 million enrollees (Di et al.,
2017b) and studies that control for a
range of individual and ecological
covariates.
A recent series of retrospective
studies has additionally tested the
hypothesis that past reductions in
ambient PM2.5 concentrations have been
associated with increased life
expectancy or a decreased mortality rate
(U.S. EPA, 2019, section 11.2.2.5). Pope
et al. (2009) conducted a cross-sectional
analysis using air quality data from 51
metropolitan areas across the U.S.,
beginning in the 1970s through the early
2000s, and found that a 10 mg/m3
decrease in long-term PM2.5
concentration was associated with a
0.61-year increase in life expectancy. In
a subsequent analysis, the authors
extended the period of analysis to
include 2000 to 2007 (Correia et al.,
2013), a time period with lower ambient
PM2.5 concentrations. In this follow-up
study, a decrease in long-term PM2.5
concentration continued to be
associated with an increase in life
expectancy, though the magnitude of
the increase was smaller than during the
earlier time period (i.e., a 10 mg/m3
decrease in long-term PM2.5
35 The majority of these studies examined nonaccidental mortality outcomes, though some
Medicare studies lack cause-specific death
information and, therefore, examine total mortality.
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concentration was associated with a
0.35-year increase in life expectancy).
Additional studies conducted in the
U.S. or Europe similarly report that
reductions in ambient PM2.5 are
associated with improvements in
longevity (U.S. EPA, 2019, section
11.2.2.5).
The 2019 ISA specifically evaluates
the degree to which recent studies that
examine the relationship between longterm PM2.5 exposure and mortality have
addressed key policy-relevant issues
and/or previously identified data gaps
in the scientific evidence. For example,
based on its assessment of the evidence,
the ISA concludes that positive
associations between long-term PM2.5
exposures and mortality are robust
across analyses examining a variety of
study designs (e.g., U.S. EPA, 2019,
section 11.2.2.4), approaches to
estimating PM2.5 exposures (U.S. EPA,
2019, section 11.2.5.1), approaches to
controlling for confounders (U.S. EPA,
2019, sections 11.2.3 and 11.2.5),
geographic regions and populations, and
temporal periods (U.S. EPA, 2019,
sections 11.2.2.5 and 11.2.5.3). Recent
evidence further demonstrates that
associations with mortality remain
robust in copollutant analyses (U.S.
EPA, 2019, section 11.2.3), and that
associations persist in analyses
restricted to long-term exposures below
12 mg/m3 (Di et al., 2017b) or 10 mg/m3
(Shi et al., 2016).
An additional important
consideration in characterizing the
public health impacts associated with
PM2.5 exposure is whether
concentration-response relationships are
linear across the range of concentrations
or if nonlinear relationships exist along
any part of this range. Several recent
studies examine this issue, and continue
to provide evidence of linear, nothreshold relationships between longterm PM2.5 exposures and all-cause and
cause-specific mortality (U.S. EPA,
2019, section 11.2.4). However,
interpreting the shapes of these
relationships, particularly at PM2.5
concentrations near the lower end of the
air quality distribution, can be
complicated by relatively low data
density in the lower concentration
range, the possible influence of
exposure measurement error, and
variability among individuals with
respect to air pollution health effects.
These sources of variability and
uncertainty tend to smooth and
‘‘linearize’’ population-level
concentration-response functions, and
thus could obscure the existence of a
threshold or nonlinear relationship
(U.S. EPA, 2015, Preamble section 6.c).
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The biological plausibility of PM2.5attributable mortality is supported by
the coherence of effects across scientific
disciplines (i.e., animal toxicological,
controlled human exposure studies, and
epidemiologic), including in recent
studies evaluating the morbidity effects
that are the largest contributors to total
(nonaccidental) mortality. The ISA
outlines the available evidence for
plausible pathways by which inhalation
exposure to PM2.5 could progress from
initial events (e.g., respiratory tract
inflammation, autonomic nervous
system modulation) to endpoints
relevant to population outcomes,
particularly those related to
cardiovascular diseases such as
ischemic heart disease, stroke and
atherosclerosis (U.S. EPA, 2019, section
6.2.1), and to metabolic disease and
diabetes (U.S. EPA, 2019, section 7.2.1).
The ISA notes ‘‘more limited evidence
from respiratory morbidity’’ (U.S. EPA,
2019, p. 11–101) to support the
biological plausibility of mortality due
to long-term PM2.5 exposures (U.S. EPA,
2019, section 11.2.1).
Taken together, recent studies
reaffirm and further strengthen the body
of evidence from the 2009 ISA for the
relationship between long-term PM2.5
exposure and mortality. Recent
epidemiologic studies consistently
report positive associations with
mortality across different geographic
locations, populations, and analytic
approaches. Such studies reduce key
uncertainties identified in the last
review, including those related to
potential copollutant confounding, and
provide additional information on the
shape of the concentration-response
curve. Recent experimental and
epidemiologic evidence for
cardiovascular effects, and respiratory
effects to a more limited degree,
supports the plausibility of mortality
due to long-term PM2.5 exposures. The
2019 ISA concludes that, ‘‘collectively,
this body of evidence is sufficient to
conclude that a causal relationship
exists between long-term PM2.5 exposure
and total mortality’’ (U.S. EPA, 2019,
section 11.2.7; p. 11–102).
ii. Short-term PM2.5 exposures
The 2009 PM ISA concluded that ‘‘a
causal relationship exists between shortterm exposure to PM2.5 and mortality’’
(U.S. EPA, 2009c). This conclusion was
based on the evaluation of both multiand single-city epidemiologic studies
that consistently reported positive
associations between short-term PM2.5
exposure and non-accidental mortality.
These associations were strongest, in
terms of magnitude and precision,
primarily at lags of 0 to 1 days.
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Examination of the potential
confounding effects of gaseous
copollutants was limited, though
evidence from single-city studies
indicated that gaseous copollutants have
minimal effect on the PM2.5-mortality
relationship (i.e., associations remain
robust to inclusion of other pollutants in
copollutant models). The evaluation of
cause-specific mortality found that
effect estimates were larger in
magnitude, but also had larger
confidence intervals, for respiratory
mortality compared to cardiovascular
mortality. Although the largest mortality
risk estimates were for respiratory
mortality, the interpretation of the
results was complicated by the limited
coherence from studies of respiratory
morbidity. However, the evidence from
studies of cardiovascular morbidity
provided both coherence and biological
plausibility for the relationship between
short-term PM2.5 exposure and
cardiovascular mortality.
Recent multicity studies evaluated
since the 2009 ISA continue to provide
evidence of primarily positive
associations between daily PM2.5
exposures and mortality, with percent
increases in total mortality ranging from
0.19% (Lippmann et al., 2013) to 2.80%
(Kloog et al., 2013) 36 at lags of 0 to 1
days in single-pollutant models.
Whereas most studies rely on assigning
exposures using data from ambient
monitors, associations are also reported
in recent studies that employ hybrid
modeling approaches using additional
PM2.5 data (i.e., from satellites, land use
information, and modeling, in addition
to monitors), allowing for the inclusion
of more rural locations in analyses
(Kloog et al., 2013, Shi et al., 2016, Lee
et al., 2015).
Some recent studies have expanded
the examination of potential
confounders (e.g., U.S. EPA, 2019,
section 11.1.5.1), including
copollutants. Associations between
short-term PM2.5 exposures and
mortality remain positive and relatively
unchanged in copollutant models with
both gaseous pollutants and PM10-2.5
(U.S. EPA, 2019, Section 11.1.4).
Additionally, the low (r < 0.4) to
moderate correlations (r = 0.4–0.7)
between PM2.5 and gaseous pollutants
and PM10-2.5 increase the confidence in
PM2.5 having an independent effect on
mortality (U.S. EPA, 2019, section
11.1.4).
The generally positive associations
reported with mortality are supported
36 As detailed in the Preface to the ISA, risk
estimates are for a 10 mg/m3 increase in 24-hour avg
PM2.5 concentrations, unless otherwise noted (U.S.
EPA, 2019).
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by a small group of studies employing
causal inference or quasi-experimental
statistical approaches (U.S. EPA, 2019,
section 11.1.2.1). For example, a recent
study examines whether a specific
regulatory action in Tokyo, Japan (i.e., a
diesel emission control ordinance)
resulted in a subsequent reduction in
daily mortality (Yorifuji et al., 2016).
The authors report a reduction in
mortality in Tokyo due to the ordinance,
compared to Osaka, which did not have
a similar diesel emission control
ordinance in place.
The positive associations for total
mortality reported across the majority of
studies evaluated are further supported
by analyses reporting generally
consistent, positive associations with
both cardiovascular and respiratory
mortality (U.S. EPA, 2019, section
11.1.3). For both cardiovascular and
respiratory mortality, there has been
only limited assessment of potential
copollutant confounding, though initial
evidence indicates that associations
remain positive and relatively
unchanged in models with gaseous
pollutants and PM10-2.5. This evidence
further supports the copollutant
analyses conducted for total mortality.
The evidence for ischemic events and
heart failure, as detailed in the
assessment of cardiovascular morbidity
(U.S. EPA, 2019, Chapter 6), provides
biological plausibility for PM2.5-related
cardiovascular mortality, which
comprises the largest percentage of total
mortality (i.e., ∼33%) (U.S. National
Institutes of Health, 2013). Although
there is evidence for exacerbations of
chronic obstructive pulmonary disease
(COPD) and asthma, the collective body
of evidence, particularly from controlled
human exposure studies of respiratory
effects, provides only limited support
for the biological plausibility of PM2.5related respiratory mortality (U.S. EPA,
2019, Chapter 5).
In the 2009 ISA, one of the main
uncertainties identified was the regional
and city-to-city heterogeneity in PM2.5mortality associations. Recent studies
examine both city-specific as well as
regional characteristics to identify the
underlying contextual factors that could
contribute to this heterogeneity (U.S.
EPA, 2019, section 11.1.6.3). Analyses
focusing on effect modification of the
PM2.5-mortality relationship by PM2.5
components, regional patterns in PM2.5
components and city-specific
differences in composition and sources
indicate some differences in the PM2.5
composition and sources across cities
and regions, but these differences do not
fully explain the observed
heterogeneity. Additional studies find
that factors related to potential exposure
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differences, such as housing stock and
commuting, as well as city-specific
factors (e.g., land-use, port volume, and
traffic information), may explain some
of the observed heterogeneity (U.S. EPA,
2019, section 11.1.6.3). Collectively,
recent studies indicate that the
heterogeneity in PM2.5-mortality risk
estimates cannot be attributed to one
factor, but instead a combination of
factors including, but not limited to, PM
composition and sources as well as
community characteristics that could
influence exposures (U.S. EPA, 2019,
section 11.1.12).
A number of recent studies conducted
systematic evaluations of the lag
structure of associations for the PM2.5mortality relationship by examining
either a series of single-day or multiday
lags and these studies continue to
support an immediate effect (i.e., lag 0
to 1 days) of short-term PM2.5 exposures
on mortality (U.S. EPA, 2019, section
11.1.8.1). Recent studies also conducted
analyses comparing the traditional 24hour average exposure metric with a
sub-daily metric (i.e., 1-hour max).
These initial studies provide evidence
of a similar pattern of associations for
both the 24-hour average and 1-hour
max metric, with the association larger
in magnitude for the 24-hour average
metric.
Recent multicity studies indicate that
positive and statistically significant
associations with mortality persist in
analyses restricted to short-term PM2.5
exposures below 35 mg/m3 (Lee et al.,
2015),37 below 30 mg/m3 (Shi et al.,
2016), and below 25 mg/m3 (Di et al.,
2017a). Additional studies examine the
shape of the concentration-response
relationship and whether a threshold
exists specifically for PM2.5 (U.S. EPA,
2019, section 11.1.10). These studies
have used various statistical approaches
and consistently found linear
relationships with no evidence of a
threshold. Recent analyses provide
initial evidence indicating that PM2.5mortality associations persist and may
be stronger (i.e., a steeper slope) at lower
concentrations (e.g., Di et al., 2017a;
Figure 11–12 in U.S. EPA, 2019).
However, given the limited data
available at the lower end of the
distribution of ambient PM2.5
concentrations, the shape of the
concentration-response curve remains
uncertain at these low concentrations
and, to date, studies have not conducted
extensive analyses exploring
alternatives to linearity when examining
37 Lee et al. (2015) also report that positive and
statistically significant associations between shortterm PM2.5 exposures and mortality persist in
analyses restricted to areas with long-term
concentrations below 12 mg/m3.
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the shape of the PM2.5-mortality
concentration-response relationship.
Overall, recent epidemiologic studies
build upon and extend the conclusions
of the 2009 ISA for the relationship
between short-term PM2.5 exposures and
total mortality. Supporting evidence for
PM2.5-related cardiovascular morbidity,
and more limited evidence from
respiratory morbidity, provides
biological plausibility for mortality due
to short-term PM2.5 exposures. The
primarily positive associations observed
across studies conducted in diverse
geographic locations is further
supported by the results from copollutant analyses indicating robust
associations, along with evidence from
analyses of the concentration-response
relationship. The 2019 ISA states that,
collectively, ‘‘this body of evidence is
sufficient to conclude that a causal
relationship exists between short-term
PM2.5 exposure and total mortality’’
(U.S. EPA, 2019, pp. 11–58).
b. Cardiovascular Effects
i. Long-Term PM2.5 Exposures
The scientific evidence reviewed in
the 2009 PM ISA was ‘‘sufficient to infer
a causal relationship between long-term
PM2.5 exposure and cardiovascular
effects’’ (U.S. EPA, 2009c). The strongest
line of evidence comprised findings
from several large epidemiologic studies
of U.S. cohorts that consistently showed
positive associations between long-term
PM2.5 exposure and cardiovascular
mortality (Pope et al., 2004, Krewski et
al., 2009, Miller et al., 2007, Laden et
al., 2006). Studies of long-term PM2.5
exposure and cardiovascular morbidity
were limited in number. Biological
plausibility and coherence with the
epidemiologic findings were provided
by studies using genetic mouse models
of atherosclerosis demonstrating
enhanced atherosclerotic plaque
development and inflammation, as well
as changes in measures of impaired
heart function, following 4- to 6-month
exposures to PM2.5 concentrated
ambient particles (CAPs), and by a
limited number of studies reporting
CAPs-induced effects on coagulation
factors, vascular reactivity, and
worsening of experimentally induced
hypertension in mice (U.S. EPA, 2009c).
Studies conducted since the last
review continue to support the
relationship between long-term
exposure to PM2.5 and cardiovascular
effects. As discussed above, results from
recent U.S. and Canadian cohort studies
consistently report positive associations
between long-term PM2.5 exposure and
cardiovascular mortality (U.S. EPA,
2019, Figure 6–19) in evaluations
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conducted at varying spatial scales and
employing a variety of exposure
assessment and statistical methods (U.S.
EPA, 2019, section 6.2.10). Positive
associations between long-term PM2.5
exposures and cardiovascular mortality
are generally robust in copollutant
models adjusted for ozone, NO2,
PM10-2.5, or SO2. In addition, most of the
results from analyses examining the
shape of the concentration-response
relationship for cardiovascular mortality
support a linear relationship with longterm PM2.5 exposures and do not
identify a threshold below which effects
do not occur (U.S. EPA, 2019, section
6.2.16; Table 6–52).38
The body of literature examining the
relationship between long-term PM2.5
exposure and cardiovascular morbidity
has greatly expanded since the 2009 PM
ISA, with positive associations reported
in several cohorts (U.S. EPA, 2019,
section 6.2). Though results for
cardiovascular morbidity are less
consistent than those for cardiovascular
mortality (U.S. EPA, 2019, section 6.2),
recent studies provide some evidence
for associations between long-term
PM2.5 exposures and the progression of
cardiovascular disease. Positive
associations with cardiovascular
morbidity (e.g., coronary heart disease,
stroke) and atherosclerosis progression
(e.g., coronary artery calcification) are
observed in several epidemiologic
studies (U.S. EPA, 2019, sections 6.2.2.
to 6.2.9). Associations in such studies
are supported by toxicological evidence
for increased plaque progression in mice
following long-term exposure to PM2.5
collected from multiple locations across
the U.S. (U.S. EPA, 2019, section
6.2.4.2). A small number of
epidemiologic studies also report
positive associations between long-term
PM2.5 exposure and heart failure,
changes in blood pressure, and
hypertension (U.S. EPA, 2019, sections
6.2.5 and 6.2.7). Associations with heart
failure are supported by animal
toxicological studies demonstrating
decreased cardiac contractility and
function, and increased coronary artery
wall thickness following long-term
PM2.5 exposure (U.S. EPA, 2019, section
6.2.5.2). Similarly, a limited number of
animal toxicological studies
demonstrating a relationship between
long-term exposure to PM2.5 and
consistent increases in blood pressure in
rats and mice are coherent with
epidemiologic studies reporting positive
38 As
noted above for mortality, uncertainty in the
shape of the concentration-response relationship
increases near the upper and lower ends of the
concentration distribution where the data are
limited.
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associations between long-term
exposure to PM2.5 and hypertension.
Longitudinal epidemiologic analyses
also report positive associations with
markers of systemic inflammation (U.S.
EPA, 2019, section 6.2.11), coagulation
(U.S. EPA, 2019, section 6.2.12), and
endothelial dysfunction (U.S. EPA,
2019, section 6.2.13). These results are
coherent with animal toxicological
studies generally reporting increased
markers of systemic inflammation,
oxidative stress, and endothelial
dysfunction (U.S. EPA, 2019, section
6.2.12.2 and 6.2.14).
In summary, the 2019 ISA concludes
that there is consistent evidence from
multiple epidemiologic studies
illustrating that long-term exposure to
PM2.5 is associated with mortality from
cardiovascular causes. Associations
with CHD, stroke and atherosclerosis
progression were observed in several
additional epidemiologic studies
providing coherence with the mortality
findings. Results from copollutant
models generally support an
independent effect of PM2.5 exposure on
mortality. Additional evidence of the
independent effect of PM2.5 on the
cardiovascular system is provided by
experimental studies in animals, which
support the biological plausibility of
pathways by which long-term exposure
to PM2.5 could potentially result in
outcomes such as CHD, stroke, CHF and
cardiovascular mortality. The
combination of epidemiologic and
experimental evidence results in the
ISA conclusion that ‘‘a causal
relationship exists between long-term
exposure to PM2.5 and cardiovascular
effects’’ (U.S. EPA, 2019, p. 6–222).
ii. Short-Term PM2.5 Exposures
The 2009 PM ISA concluded that ‘‘a
causal relationship exists between shortterm exposure to PM2.5 and
cardiovascular effects’’ (U.S. EPA,
2009c). The strongest evidence in the
2009 PM ISA was from epidemiologic
studies of emergency department visits
and hospital admissions for ischemic
heart disease (IHD) and heart failure
(HF), with supporting evidence from
epidemiologic studies of cardiovascular
mortality (U.S. EPA, 2009c). Animal
toxicological studies provided
coherence and biological plausibility for
the positive associations reported with
myocardial ischemia, emergency
department visits, and hospital
admissions. These included studies
reporting reduced myocardial blood
flow during ischemia and studies
indicating altered vascular reactivity. In
addition, effects of PM2.5 exposure on a
potential indicator of ischemia (i.e., ST
segment depression on an
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electrocardiogram) were reported in
both animal toxicological and
epidemiologic panel studies.39 Key
uncertainties from the last review
resulted from inconsistent results across
disciplines with respect to the
relationship between short-term
exposure to PM2.5 and changes in blood
pressure, blood coagulation markers,
and markers of systemic inflammation.
In addition, while the 2009 PM ISA
identified a growing body of evidence
from controlled human exposure and
animal toxicological studies,
uncertainties remained with respect to
biological plausibility.
A large body of recent evidence
confirms and extends the evidence from
the 2009 ISA supporting the
relationship between short-term PM2.5
exposure and cardiovascular effects.
This includes generally positive
associations observed in multicity
epidemiologic studies of emergency
department visits and hospital
admissions for IHD, HF, and combined
cardiovascular-related endpoints. In
particular, nationwide studies of older
adults (65 years and older) using
Medicare records report positive
associations between PM2.5 exposures
and hospital admissions for HF (U.S.
EPA, 2019, section 6.1.3.1). Additional
multicity studies conducted in the
northeast U.S. report positive
associations between short-term PM2.5
exposures and emergency department
visits or hospital admissions for IHD
(U.S. EPA, 2019, section 6.1.2.1) while
studies conducted in the U.S. and
Canada reported positive associations
between short-term PM2.5 exposures and
emergency department visits for HF.
Epidemiologic studies conducted in
single cities contribute some support,
though associations reported in singlecity studies are less consistently
positive than in multicity studies, and
include a number of studies reporting
null associations (U.S. EPA, 2019,
sections 6.1.2 and 6.1.3). When
considered as a whole; however, the
recent body of IHD and HF
epidemiologic evidence supports the
evidence from previous ISAs reporting
mainly positive associations between
short-term PM2.5 concentrations and
emergency department visits and
hospital admissions.
In addition, a number of more recent
controlled human exposure, animal
toxicological, and epidemiologic panel
studies provide evidence that PM2.5
39 Some animal studies included in the 2009 PM
ISA examined exposures to mixtures, such as motor
vehicle exhaust or woodsmoke. In these studies, it
was unclear if the resulting cardiovascular effects
could be attributed specifically to the particulate
components of the mixture.
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exposure could plausibly result in IHD
or HF through pathways that include
endothelial dysfunction, arterial
thrombosis, and arrhythmia (U.S. EPA,
2019, section 6.1.1). The most consistent
evidence from recent controlled human
exposure studies is for endothelial
dysfunction, as measured by changes in
brachial artery diameter or flow
mediated dilation. All but one of the
available controlled human exposure
studies examining the potential for
endothelial dysfunction report an effect
of PM2.5 exposure on measures of blood
flow (U.S. EPA, 2019, section 6.1.13.2).
These studies report variable results
regarding the timing of the effect and
the mechanism by which reduced blood
flow occurs (i.e., availability vs
sensitivity to nitric oxide). Some
controlled human exposure studies
using PM2.5 CAPs report evidence for
small increases in blood pressure (U.S.
EPA, 2019, section 6.1.6.3). In addition,
although not entirely consistent, there is
also some evidence across controlled
human exposure studies for conduction
abnormalities/arrhythmia (U.S. EPA,
2019, section 6.1.4.3), changes in heart
rate variability (HRV) (U.S. EPA, 2019,
section 6.1.10.2), changes in hemostasis
that could promote clot formation (U.S.
EPA, 2019, section 6.1.12.2), and
increases in inflammatory cells and
markers (U.S. EPA, 2019, section
6.1.11.2). Thus, when taken as a whole,
controlled human exposure studies are
coherent with epidemiologic studies in
that they provide evidence that shortterm exposures to PM2.5 may result in
the types of cardiovascular endpoints
that could lead to emergency
department visits and hospital
admissions in some people.
Animal toxicological studies
published since the 2009 ISA also
support a relationship between shortterm PM2.5 exposure and cardiovascular
effects. A recent study demonstrating
decreased cardiac contractility and left
ventricular pressure in mice is coherent
with the results of epidemiologic
studies that report associations between
short-term PM2.5 exposure and heart
failure (U.S. EPA, 2019, section 6.1.3.3).
In addition, and as with controlled
human exposure studies, there is
generally consistent evidence in animal
toxicological studies for indicators of
endothelial dysfunction (U.S. EPA,
2019, section 6.1.13.3). Studies in
animals also provide evidence for
changes in a number of other
cardiovascular endpoints following
short-term PM2.5 exposure. Although
not entirely consistent, these studies
provide some evidence of conduction
abnormalities and arrhythmia (U.S.
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EPA, 2019, section 6.1.4.4), changes in
HRV (U.S. EPA, 2019, section 6.1.10.3),
changes in blood pressure (U.S. EPA,
2019, section 6.1.6.4), and evidence for
systemic inflammation and oxidative
stress (U.S. EPA, 2019, section 6.1.11.3).
In summary, recent evidence supports
the conclusions reported in the 2009
ISA indicating relationships between
short-term PM2.5 exposures and hospital
admissions and ED visits for IHD and
HF, along with cardiovascular mortality.
Epidemiologic studies reporting robust
associations in copollutant models are
supported by direct evidence from
controlled human exposure and animal
toxicological studies reporting
independent effects of PM2.5 exposures
on endothelial dysfunction as well as
endpoints indicating impaired cardiac
function, increased risk of arrhythmia,
changes in HRV, increases in BP, and
increases in indicators of systemic
inflammation, oxidative stress, and
coagulation (U.S. EPA, 2019, section
6.1.16). Epidemiologic panel studies,
although not entirely consistent,
provide some evidence that PM2.5
exposures are associated with
cardiovascular effects, including
increased risk of arrhythmia, decreases
in HRV, increases in BP, and ST
segment depression. Overall, the results
from epidemiologic panel, controlled
human exposure, and animal
toxicological studies (in particular those
related to endothelial dysfunction,
impaired cardiac function, ST segment
depression, thrombosis, conduction
abnormalities, and changes in blood
pressure) provide coherence and
biological plausibility for the consistent
results from epidemiologic studies
reporting positive associations between
short-term PM2.5 exposures and IHD and
HF, and ultimately cardiovascular
mortality. The 2019 ISA concludes that,
overall, ‘‘there continues to be sufficient
evidence to conclude that a causal
relationship exists between short-term
PM2.5 exposure and cardiovascular
effects’’ (U.S. EPA, 2019, p. 6–138).
c. Respiratory Effects
i. Long-Term PM2.5 Exposures
The 2009 PM ISA concluded that ‘‘a
causal relationship is likely to exist
between long-term PM2.5 exposure and
respiratory effects’’ (U.S. EPA, 2009c).
This conclusion was based mainly on
epidemiologic evidence demonstrating
associations between long-term PM2.5
exposure and changes in lung function
or lung function growth in children.
Biological plausibility was provided by
a single animal toxicological study
examining pre- and post-natal exposure
to PM2.5 CAPs, which found impaired
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lung development. Epidemiologic
evidence for associations between longterm PM2.5 exposure and other
respiratory outcomes, such as the
development of asthma, allergic disease,
and COPD; respiratory infection; and
the severity of disease was limited, both
in the number of studies available and
the consistency of the results.
Experimental evidence for other
outcomes was also limited, with one
animal toxicological study reporting
that long-term exposure to PM2.5 CAPs
results in morphological changes in the
nasal airways of healthy animals. Other
animal studies examined exposure to
mixtures, such as motor vehicle exhaust
and woodsmoke, and effects were not
attributed specifically to the particulate
components of the mixture.
Recent cohort studies provide
additional support for the relationship
between long-term PM2.5 exposure and
decrements in lung function growth (as
a measure of lung development),
indicating a robust and consistent
association across study locations,
exposure assessment methods, and time
periods (U.S. EPA, 2019, section 5.2.13).
This relationship is further supported
by a recent retrospective study that
reports an association between
declining PM2.5 concentrations and
improvements in lung function growth
in children (U.S. EPA, 2019, section
5.2.11). Epidemiologic studies also
examine asthma development in
children (U.S. EPA, 2019, section 5.2.3),
with recent prospective cohort studies
reporting generally positive
associations, though several are
imprecise (i.e., they report wide
confidence intervals). Supporting
evidence is provided by studies
reporting associations with asthma
prevalence in children, with childhood
wheeze, and with exhaled nitric oxide,
a marker of pulmonary inflammation
(U.S. EPA, 2019, section 5.2.13). A
recent animal toxicological study
showing the development of an allergic
phenotype and an increase in a marker
of airway responsiveness supports the
biological plausibility of the
development of allergic asthma (U.S.
EPA, 2019, section 5.2.13). Other
epidemiologic studies report a PM2.5related acceleration of lung function
decline in adults, while improvement in
lung function was observed with
declining PM2.5 concentrations (U.S.
EPA, 2019, section 5.2.11). A recent
longitudinal study found declining
PM2.5 concentrations are also associated
with an improvement in chronic
bronchitis symptoms in children,
strengthening evidence reported in the
2009 ISA for a relationship between
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increased chronic bronchitis symptoms
and long-term PM2.5 exposure (U.S.
EPA, 2019, section 5.2.11). A common
uncertainty across the epidemiologic
evidence is the lack of examination of
copollutants to assess the potential for
confounding. While there is some
evidence that associations remain robust
in models with gaseous pollutants, a
number of these studies examining
copollutant confounding were
conducted in Asia, and thus have
limited generalizability due to high
annual pollutant concentrations.
When taken together, the 2019 ISA
concludes that the ‘‘epidemiologic
evidence strongly supports a
relationship with decrements in lung
function growth in children’’ (U.S. EPA,
2019, p. 1–34). Additional
epidemiologic evidence ‘‘supports a
relationship with asthma development
in children, increased bronchitic
symptoms in children with asthma,
acceleration of lung function decline in
adults, and respiratory mortality,
including cause-specific respiratory
mortality for COPD and respiratory
infection’’ (U.S. EPA, 2019, p. 1–34). In
support of the biological plausibility of
such associations reported in
epidemiologic studies of respiratory
health effects, animal toxicological
studies continue to provide direct
evidence that long-term exposure to
PM2.5 results in a variety of respiratory
effects. Recent animal studies show
pulmonary oxidative stress,
inflammation, and morphologic changes
in the upper (nasal) and lower airways.
Other results show that changes are
consistent with the development of
allergy and asthma, and with impaired
lung development. Overall, the ISA
concludes that ‘‘the collective evidence
is sufficient to conclude a likely to be
causal relationship between long-term
PM2.5 exposure and respiratory effects’’
(U.S. EPA, 2019, p. 5–220).
ii. Short-Term PM2.5 Exposures
The 2009 PM ISA (U.S. EPA, 2009c)
concluded that a ‘‘causal relationship is
likely to exist’’ between short-term
PM2.5 exposure and respiratory effects.
This conclusion was based mainly on
the epidemiologic evidence
demonstrating positive associations
with various respiratory effects.
Specifically, the 2009 ISA described
epidemiologic evidence as consistently
showing PM2.5-associated increases in
hospital admissions and emergency
department visits for COPD and
respiratory infection among adults or
people of all ages, as well as increases
in respiratory mortality. These results
were supported by studies reporting
associations with increased respiratory
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symptoms and decreases in lung
function in children with asthma,
though the available epidemiologic
evidence was inconsistent for hospital
admissions or emergency department
visits for asthma. Studies examining
copollutant models showed that PM2.5
associations with respiratory effects
were robust to inclusion of CO or SO2
in the model, but often were attenuated
(though still positive) with inclusion of
O3 or NO2. In addition to the
copollutant models, evidence
supporting an independent effect of
PM2.5 exposure on the respiratory
system was provided by animal
toxicological studies of PM2.5 CAPs
demonstrating changes in some
pulmonary function parameters, as well
as inflammation, oxidative stress,
injury, enhanced allergic responses, and
reduced host defenses. Many of these
effects have been implicated in the
pathophysiology for asthma
exacerbation, COPD exacerbation, or
respiratory infection. In the few
controlled human exposure studies
conducted in individuals with asthma
or COPD, PM2.5 exposure mostly had no
effect on respiratory symptoms, lung
function, or pulmonary inflammation.
Available studies in healthy people also
did not clearly find respiratory effects
following short-term PM2.5 exposures.
Recent epidemiologic studies provide
evidence for a relationship between
short-term PM2.5 exposure and several
respiratory-related endpoints, including
asthma exacerbation (U.S. EPA, 2019,
section 5.1.2.1), COPD exacerbation
(U.S. EPA, 2019, section 5.1.4.1), and
combined respiratory-related diseases
(U.S. EPA, 2019, section 5.1.6),
particularly from studies examining
emergency department visits and
hospital admissions. The generally
positive associations between short-term
PM2.5 exposure and asthma and COPD
emergency department visits and
hospital admissions are supported by
epidemiologic studies demonstrating
associations with other respiratoryrelated effects such as symptoms and
medication use that are indicative of
asthma and COPD exacerbations (U.S.
EPA, 2019, sections 5.1.2.2 and 5.4.1.2).
The collective body of epidemiologic
evidence for asthma exacerbation is
more consistent in children than in
adults. Additionally, epidemiologic
studies examining the relationship
between short-term PM2.5 exposure and
respiratory mortality provide evidence
of consistent positive associations,
demonstrating a continuum of effects
(U.S. EPA, 2019, section 5.1.9).
Building on the studies evaluated in
the 2009 ISA, recent epidemiologic
studies expand the assessment of
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potential copollutant confounding.
There is some evidence that PM2.5
associations with asthma exacerbation,
combined respiratory-related diseases,
and respiratory mortality remain
relatively unchanged in copollutant
models with gaseous pollutants (i.e., O3,
NO2, SO2, with more limited evidence
for CO) and other particle sizes (i.e.,
PM10-2.5) (U.S. EPA, 2019, section
5.1.10.1).
Insight into whether there is an
independent effect of PM2.5 on
respiratory health is provided by
findings from animal toxicological
studies. Specifically, short-term
exposure to PM2.5 has been shown to
enhance asthma-related responses in an
animal model of allergic airways disease
and lung injury and inflammation in an
animal model of COPD (U.S. EPA, 2019,
sections 5.1.2.4.4 and 5.1.4.4.3). The
experimental evidence provides
biological plausibility for some
respiratory-related endpoints, including
limited evidence of altered host defense
and greater susceptibility to bacterial
infection as well as consistent evidence
of respiratory irritant effects. Animal
toxicological evidence for other
respiratory effects is inconsistent and
controlled human exposure studies
provide limited evidence of respiratory
effects (U.S. EPA, 2019, section 5.1.12).
The 2019 ISA concludes that ‘‘[t]he
strongest evidence of an effect of shortterm PM2.5 exposure on respiratory
effects is provided by epidemiologic
studies of asthma and COPD
exacerbation. While animal
toxicological studies provide biological
plausibility for these findings, some
uncertainty remains with respect to the
independence of PM2.5 effects’’ (U.S.
EPA, 2019, p. 5–155). When taken
together, the ISA concludes that this
evidence ‘‘is sufficient to conclude a
likely to be causal relationship between
short-term PM2.5 exposure and
respiratory effects’’ (U.S. EPA, 2019, p.
5–155).
d. Cancer
The 2009 ISA concluded that the
overall body of evidence was
‘‘suggestive of a causal relationship
between relevant PM2.5 exposures and
cancer’’ (U.S. EPA, 2009c). This
conclusion was based primarily on
positive associations observed in a
limited number of epidemiologic
studies of lung cancer mortality. The
few epidemiologic studies that had
evaluated PM2.5 exposure and lung
cancer incidence or cancers of other
organs and systems generally did not
show evidence of an association.
Toxicological studies did not focus on
exposures to specific PM size fractions,
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but rather investigated the effects of
exposures to total ambient PM, or other
source-based PM such as wood smoke.
Collectively, results of in vitro studies
were consistent with the larger body of
evidence demonstrating that ambient
PM and PM from specific combustion
sources are mutagenic and genotoxic.
However, animal inhalation studies
found little evidence of tumor formation
in response to chronic exposures. A
small number of studies provided
preliminary evidence that PM exposure
can lead to changes in methylation of
DNA, which may contribute to
biological events related to cancer.
Since the 2009 ISA, additional cohort
studies provide evidence that long-term
PM2.5 exposure is positively associated
with lung cancer mortality and with
lung cancer incidence, and provide
initial evidence for an association with
reduced cancer survival (U.S. EPA,
2019, section 10.2.5). Reanalyses of the
ACS cohort using different years of
PM2.5 data and follow-up, along with
various exposure assignment
approaches, provide consistent evidence
of positive associations between longterm PM2.5 exposure and lung cancer
mortality (U.S. EPA, 2019, Figure 10–3).
Additional support for positive
associations with lung cancer mortality
is provided by recent epidemiologic
studies using individual-level data to
control for smoking status, by studies of
people who have never smoked (though
such studies generally report wide
confidence intervals due to the small
number of lung cancer mortality cases
within this population), and in analyses
of cohorts that relied upon proxy
measures to account for smoking status
(U.S. EPA, 2019, section 10.2.5.1.1).
Although studies that evaluate lung
cancer incidence, including studies of
people who have never smoked, are
limited in number, recent studies
generally report positive associations
with long-term PM2.5 exposures (U.S.
EPA, 2019, section 10.2.5.1.2). A subset
of the studies focusing on lung cancer
incidence also examined histological
subtype, providing some evidence of
positive associations for
adenocarcinomas, the predominate
subtype of lung cancer observed in
people who have never smoked (U.S.
EPA, 2019, section 10.2.5.1.2).
Associations between long-term PM2.5
exposure and lung cancer incidence
were found to remain relatively
unchanged, though in some cases
confidence intervals widened, in
analyses that attempted to reduce
exposure measurement error by
accounting for length of time at
residential address or by examining
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different exposure assignment
approaches (U.S. EPA, 2019, section
10.2.5.1.2).
The 2019 ISA evaluates the degree to
which recent epidemiologic studies
have addressed the potential for
confounding by copollutants and the
shape of the concentration-response
relationship. To date, relatively few
studies have evaluated the potential for
copollutant confounding of the
relationship between long-term PM2.5
exposure and lung cancer mortality or
incidence. The small number of such
studies have generally focused on O3
and report that PM2.5 associations
remain relatively unchanged in
copollutant models (U.S. EPA, 2019,
section 10.2.5.1.3). However, available
studies have not systematically
evaluated the potential for copollutant
confounding by other gaseous pollutants
or by other particle size fractions (U.S.
EPA, 2019, section 10.2.5.1.3).
Compared to total (non-accidental)
mortality (discussed above), fewer
studies have examined the shape of the
concentration-response curve for causespecific mortality outcomes, including
lung cancer. Several studies have
reported no evidence of deviations from
linearity in the shape of the
concentration-response relationship
(Lepeule et al., 2012; Raaschou-Nielsen
et al., 2013; Puett et al., 2014), though
authors provided only limited
discussions of results (U.S. EPA, 2019,
section 10.2.5.1.4).
In support of the biological
plausibility of an independent effect of
PM2.5 on cancer, the 2019 ISA notes
evidence from recent experimental
studies demonstrating that PM2.5
exposure can lead to a range of effects
indicative of mutagenicity, genotoxicity,
and carcinogenicity, as well as
epigenetic effects (U.S. EPA, 2019,
section 10.2.7). For example, both in
vitro and in vivo toxicological studies
have shown that PM2.5 exposure can
result in DNA damage (U.S. EPA, 2019,
section 10.2.2). Although such effects do
not necessarily equate to
carcinogenicity, the evidence that PM
exposure can damage DNA, and elicit
mutations, provides support for the
plausibility of epidemiologic
associations with lung cancer mortality
and incidence. Additional supporting
studies indicate the occurrence of
micronuclei formation and
chromosomal abnormalities (U.S. EPA,
2019, section 10.2.2.3), and differential
expression of genes that may be relevant
to cancer pathogenesis, following PM
exposures. Experimental and
epidemiologic studies that examine
epigenetic effects indicate changes in
DNA methylation, providing some
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support for PM2.5 exposure contributing
to genomic instability (U.S. EPA, 2019,
section 10.2.3).
Epidemiologic evidence for
associations between PM2.5 exposure
and lung cancer mortality and
incidence, together with evidence
supporting the biological plausibility of
such associations, contributes to the
2019 ISA’s conclusion that the evidence
‘‘is sufficient to conclude there is a
likely to be causal relationship between
long-term PM2.5 exposure and cancer’’
(U.S. EPA, 2019, p. 10–77).
In its letter to the Administrator on
the draft ISA, the CASAC states that
‘‘the Draft ISA does not present
adequate evidence to conclude that
there is likely to be a causal relationship
between long-term PM2.5 exposure and
. . . cancer’’ (Cox, 2019a, p. 1 of letter).
The CASAC specifically states that this
causality determination ‘‘relies largely
on epidemiology studies that . . . do
not provide exposure time frames that
are appropriate for cancer causation and
that there are no animal studies showing
direct effects of PM2.5 on cancer
formation’’ (Cox, 2019a, p. 20 of
consensus responses).
With respect to the latency period, it
is well recognized that ‘‘air pollution
exposures experienced over an extended
historical time period are likely more
relevant to the etiology of lung cancer
than air pollution exposures
experienced in the more recent past’’
(Turner et al. 2011). However, many
epidemiologic studies conducted within
the U.S. that examine long-term PM2.5
exposure and lung cancer incidence and
lung cancer mortality rely on more
recent air quality data because routine
PM2.5 monitoring did not start until
1999–2000. An exception to this is the
American Cancer Society (ACS) study
that had PM2.5 concentration data from
two time periods, 1979–1983 and from
1999–2000. Turner et al. (2011),
conducted a comparison of PM2.5
concentrations between these two time
periods and found that they were highly
correlated (r >0.7), with the relative rank
order of metropolitan statistical areas
(MSAs) by PM2.5 concentrations being
‘‘generally retained over time.’’
Therefore, areas where PM2.5
concentrations were high remained high
over decades (or low remained low)
relative to other locations. Long-term
exposure epidemiologic studies rely on
spatial contrasts between locations;
therefore, if a location with high PM2.5
concentrations continues to have high
concentrations over decades relative to
other locations a relationship between
the PM2.5 exposure and cancer should
persist. This was confirmed in a
sensitivity analysis conducted by
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Turner et al. (2011), where the authors
reported a similar hazard ratio (HR) for
lung cancer mortality for participants
assigned exposure to PM2.5 (1979–1983)
and PM2.5 (1999–2000) in two separate
analyses.
While experimental studies showing a
direct effect of PM2.5 on cancer
formation were limited to an animal
model of urethane-induced tumor
initiation, a large number of
experimental studies report that PM2.5
exhibits several key characteristics of
carcinogens, as indicated by genotoxic
effects, oxidative stress, electrophilicity,
and epigenetic alterations, all of which
provide biological plausibility that
PM2.5 exposure can contribute to cancer
development. The experimental
evidence, in combination with multiple
recent and previously evaluated
epidemiologic studies examining the
relationship between long-term PM2.5
exposure and both lung cancer
incidence and lung cancer mortality that
reported generally positive associations
across different cohorts, exposure
assignment methods, and in analyses of
never smokers further addresses
uncertainties identified in the 2009 PM
ISA. Therefore, upon re-evaluating the
causality determination for cancer,
when considering CASAC comments on
the Draft PM ISA and applying the
causal framework as described (U.S.
EPA, 2015; U.S. EPA, 2019, section
A.3.2.1), the EPA continues to conclude
in the 2019 Final PM ISA that the
evidence for long-term PM2.5 exposure
and cancer supports a ‘‘likely to be
causal relationship’’ (U.S. EPA, 2019, p.
10–77).
e. Nervous System Effects
Reflecting the very limited evidence
available in the last review, the 2009
ISA did not make a causality
determination for long-term PM2.5
exposures and nervous system effects
(U.S. EPA, 2009c). Since the last review,
this body of evidence has grown
substantially (U.S. EPA, 2019, section
8.2). Recent studies in adult animals
report that long-term PM2.5 exposures
can lead to morphologic changes in the
hippocampus and to impaired learning
and memory. This evidence is
consistent with epidemiologic studies
reporting that long-term PM2.5 exposure
is associated with reduced cognitive
function (U.S. EPA, 2019, section 8.2.5).
Further, while the evidence is limited,
early markers of Alzheimer’s disease
pathology have been reported in rodents
following long-term exposure to PM2.5
CAPs. These findings support reported
associations with neurodegenerative
changes in the brain (i.e., decreased
brain volume), all-cause dementia, and
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hospitalization for Alzheimer’s disease
in a small number of epidemiologic
studies (U.S. EPA, 2019, section 8.2.6).
Additionally, loss of dopaminergic
neurons in the substantia nigra, a
hallmark of Parkinson disease, has been
reported in mice following long-term
PM2.5 exposures (U.S. EPA, 2019,
section 8.2.4), though epidemiologic
studies provide only limited support for
associations with Parkinson’s disease
(U.S. EPA, 2019, section 8.2.6). Overall,
the lack of consideration of copollutant
confounding introduces some
uncertainty in the interpretation of
epidemiologic studies of nervous system
effects, but this uncertainty is partly
addressed by the evidence for an
independent effect of PM2.5 exposures
provided by experimental animal
studies.
In addition to the findings described
above, which are most relevant to older
adults, several recent studies of
neurodevelopmental effects in children
have also been conducted. Positive
associations between long-term
exposure to PM2.5 during the prenatal
period and autism spectrum disorder
(ASD) are observed in multiple
epidemiologic studies (U.S. EPA, 2019,
section 8.2.7.2), while studies of
cognitive function provide little support
for an association (U.S. EPA, 2019,
section 8.2.5.2). Interpretation of these
epidemiologic studies is limited due to
the small number of studies, their lack
of control for potential confounding by
copollutants, and uncertainty regarding
the critical exposure windows.
Biological plausibility is provided for
the ASD findings by a study in mice that
found inflammatory and morphologic
changes in the corpus collosum and
hippocampus, as well as
ventriculomegaly (i.e., enlarged lateral
ventricles) in young mice following
prenatal exposure to PM2.5 CAPs.
Taken together, the 2019 ISA
concludes that the strongest evidence of
an effect of long-term exposure to PM2.5
on the nervous system is provided by
toxicological studies that show
inflammation, oxidative stress,
morphologic changes, and
neurodegeneration in multiple brain
regions following long-term exposure of
adult animals to PM2.5 CAPs. These
findings are coherent with
epidemiologic studies reporting
consistent associations with cognitive
decrements and with all-cause
dementia. There is also initial, and
limited, evidence for
neurodevelopmental effects, particularly
ASD. The ISA determines that
‘‘[o]verall, the collective evidence is
sufficient to conclude a likely to be
causal relationship between long-term
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PM2.5 exposure and nervous system
effects’’ (U.S. EPA, 2019, p. 8–61).
In its letter to the Administrator on
the draft ISA, the CASAC states that
‘‘the Draft ISA does not present
adequate evidence to conclude that
there is likely to be a causal relationship
between long-term PM2.5 exposure and
nervous system effects’’ (Cox, 2019a, p.
1 of letter). The CASAC specifically
states that ‘‘[f]or a likely causal
conclusion, there would have to be
evidence of health effects in studies
where results are not explained by
chance, confounding, and other biases,
but uncertainties remain in the overall
evidence’’ (Cox, 2019a, p. 20 of
consensus responses). These
uncertainties in the eyes of CASAC
reflect that animal toxicological studies
‘‘have largely been done by a single
group’’ (P.20), and for epidemiologic
studies that examined brain volume that
‘‘brain volumes can vary . . . between
normal people’’ and the results from
studies of cognitive function were
‘‘largely non-statistically significant’’.
With these concerns in mind, the EPA
re-evaluated the evidence and note that
animal toxicological studies were
conducted in ‘‘multiple research groups
[and show a range of effects including]
inflammation, oxidative stress,
morphologic changes, and
neurodegeneration in multiple brain
regions following long-term exposure of
adult animals to PM2.5 CAPs’’ (U.S. EPA,
2019, p. 8–61). The results from the
animal toxicological studies ‘‘are
coherent with a number of
epidemiologic studies reporting
consistent associations with cognitive
decrements and with all-cause
dementia’’ (U.S. EPA, 2019, p. 8–61).
Additionally, as discussed in the
Preamble to the ISAs (U.S. EPA, 2015):
‘‘. . . the U.S. EPA emphasizes the
importance of examining the pattern of
results across various studies and does not
focus solely on statistical significance or the
magnitude of the direction of the association
as criteria of study reliability. Statistical
significance is influenced by a variety of
factors including, but not limited to, the size
of the study, exposure and outcome
measurement error, and statistical model
specifications. Statistical significance . . . is
just one of the means of evaluating
confidence in the observed relationship and
assessing the probability of chance as an
explanation. Other indicators of reliability
such as the consistency and coherence of a
body of studies as well as other confirming
data may be used to justify reliance on the
results of a body of epidemiologic studies,
even if results in individual studies lack
statistical significance . . . [Therefore, the
U.S. EPA] . . . does not limit its focus or
consideration to statistically significant
results in epidemiologic studies.’’
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Therefore, upon re-evaluating the
causality determination, when
considering the CASAC comments on
the Draft PM ISA and applying the
causal framework as described (U.S.
EPA, 2015; U.S. EPA, 2019, section
A.3.2.1), the EPA continues to conclude
in the 2019 Final PM ISA that the
evidence for long-term PM2.5 exposure
and nervous system effects supports a
‘‘likely to be causal relationship’’ (U.S.
EPA, 2019, p. 8–61).
2. Populations at Risk of PM2.5-Related
Health Effects
The NAAQS are meant to protect the
population as a whole, including groups
that may be at increased risk for
pollutant-related health effects. In the
last review, based on the evidence
assessed in the 2009 ISA (U.S. EPA,
2009c), the 2011 PA focused on
children, older adults, people with preexisting heart and lung diseases, and
those of lower socioeconomic status as
populations that are ‘‘likely to be at
increased risk of PM-related effects’’
(U.S. EPA, 2011, p. 2–31). In the current
review, the 2019 ISA cites extensive
evidence indicating that ‘‘both the
general population as well as specific
populations and lifestages are at risk for
PM2.5-related health effects’’ (U.S. EPA,
2019, p. 12–1). For example, in support
of its ‘‘causal’’ and ‘‘likely to be causal’’
determinations, the ISA cites substantial
evidence for:
• PM-related mortality and
cardiovascular effects in older adults
(U.S. EPA, 2019, sections 11.1, 11.2, 6.1,
and 6.2);
• PM-related cardiovascular effects in
people with pre-existing cardiovascular
disease (U.S. EPA, 2019, section 6.1);
• PM-related respiratory effects in
people with pre-existing respiratory
disease, particularly asthma
exacerbations in children (U.S. EPA,
2019, section 5.1); and
• PM-related impairments in lung
function growth and asthma
development in children (U.S. EPA,
2019, sections 5.1 and 5.2; 12.5.1.1).
The ISA additionally notes that
stratified analyses (i.e., analyses that
directly compare PM-related health
effects across groups) provide support
for racial and ethnic differences in PM2.5
exposures and in PM2.5-related health
risk (U.S. EPA, 2019, section 12.5.4).
Drawing from such studies, the ISA
concludes that ‘‘[t]here is strong
evidence demonstrating that black and
Hispanic populations, in particular,
have higher PM2.5 exposures than nonHispanic white populations’’ and that
‘‘there is consistent evidence across
multiple studies demonstrating an
increase in risk for nonwhite
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populations’’ (U.S. EPA, 2019, p. 12–
38). Stratified analyses focusing on
other groups also suggest that
populations with pre-existing
cardiovascular or respiratory disease,
populations that are overweight or
obese, populations that have particular
genetic variants, populations that are of
low socioeconomic status, and current/
former smokers could be at increased
risk for PM2.5-related adverse health
effects (U.S. EPA, 2019, Chapter 12).
Thus, the groups at risk of PM2.5related health effects represent a
substantial portion of the total U.S.
population. In evaluating the primary
PM2.5 standards, an important
consideration is the potential PM2.5related public health impacts in these
populations.
3. CASAC Advice
In its review of the draft ISA, the
CASAC provided advice on the
assessment of the scientific evidence for
PM-related health and welfare effects
and on the process under which this
review of the PM NAAQS is being
conducted (Cox, 2019b). With regard to
the assessment of the evidence, the
CASAC recommended that a revised
ISA should ‘‘provide a clearer and more
complete description of the process and
criteria for study quality assessment’’
and that it should include a ‘‘[c]learer
discussion of causality and causal
biological mechanisms and pathways’’
(Cox, 2019b, p. 1 of letter). The CASAC
further advised that the draft ISA ‘‘does
not present adequate evidence to
conclude that there is likely to be a
causal relationship between long-term
PM2.5 exposure and nervous system
effects; between long-term ultrafine
particulate (UFP) exposure and nervous
system effects; or between long-term
PM2.5 exposure and cancer’’ (Cox,
2019b, p. 1 of letter).
As discussed above in section I.C.5,
and as detailed in the final ISA, to
address these comments the EPA: (1)
Added text to the Preface and developed
a new Appendix to more clearly
articulate the process of ISA
development; (2) added text to the
Preface and to the health effects
chapters to clarify the discussion of
biological plausibility and its role in
forming causality determinations; and
(3) revised the determination for longterm UFP exposure and nervous system
effects to suggestive of, but not sufficient
to infer, a causal relationship. The
EPA’s rationales for not revising the
other causality determinations
questioned by the CASAC are discussed
above in sections II.B.1.d (i.e., for
cancer) and II.B.1.e (i.e., for nervous
system effects).
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With regard to the process for
reviewing the PM NAAQS, the CASAC
requested the opportunity to review a
2nd draft ISA (Cox, 2019b, p. 1 of letter)
and recommended that ‘‘the EPA
reappoint the previous CASAC PM
panel (or appoint a panel with similar
expertise)’’ (Cox, 2019b, p. 2 of letter).
As discussed above in section I.C.5, the
Agency’s responses to these
recommendations were described in a
letter from the Administrator to the
CASAC chair.40
In addition to the consensus advice
noted above, the CASAC did not reach
consensus on some issues related to the
assessment of the PM2.5 health effects
evidence. In particular, the CASAC
members ‘‘had varying opinions on
whether there is robust and convincing
evidence to support the EPA’s
conclusion that there is a causal
relationship between PM2.5 exposure
and mortality’’ (Cox, 2019b, p. 3 of
letter). ‘‘Some members of the CASAC’’
concluded that ‘‘the EPA must better
justify their determination that shortterm or long-term exposure to PM2.5
causes mortality’’ (Cox, 2019b, p. 1 of
consensus responses). These members
recommended that the ISA should
specifically address the biological action
of PM and how exposures to low
concentrations of PM2.5 could cause
mortality; the geographic heterogeneity
in effect estimates between PM2.5
exposure and mortality; concentration
concordance across epidemiologic,
controlled human exposure and animal
toxicological studies (i.e., how the
continuum of effects is impacted by the
concentrations at which different effects
have been observed); uncertainties in
the shapes of concentration-response
functions and in the potential for
thresholds to exist; how results compare
between and within studies; and
whether PM2.5 exposures result in
mortality in animal studies (Cox, 2019b,
pp. 1–2).
In contrast, ‘‘[o]ther members of the
CASAC are of the opinion that, although
uncertainties remain, the evidence
supporting the causal relationship
between PM2.5 exposure and mortality is
robust, diverse, and convincing’’ (Cox,
2019b, p. 3 of consensus responses).
These members noted that
epidemiologic observations ‘‘have been
reproduced around the world in
communities with widely varying
exposures’’ and that ‘‘the findings of
many of the largest studies have been
repeatedly reanalyzed, with
40 Available at: https://yosemite.epa.gov/sab/
sabproduct.nsf/0/
6CBCBBC3025E13B4852583D90047B352/$File/
EPA-CASAC-19-002_Response.pdf.
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confirmation of the original findings’’
(Cox, 2019b, p. 3). These committee
members additionally stated that the
ISA’s causality determinations consider
‘‘a wide range of evidence from a variety
of sources, including human clinical
exposure and animal toxicology studies
that have provided rational biological
plausibility and potential mechanisms’’
(Cox, 2019b, p. 3). They highlighted the
fact that there is new evidence in the
current review from epidemiologic
studies supporting associations between
PM2.5 and mortality and new evidence
from toxicology studies informing the
biological plausibility of mechanisms
that could lead to mortality (Cox, 2019b,
p. 3).
C. Proposed Conclusions on the Current
Primary PM2.5 Standards
This section describes the
Administrator’s proposed conclusions
regarding the adequacy of the current
primary PM2.5 standards. His approach
to reaching these proposed conclusions
draws from the ISA’s assessment of the
scientific evidence for health effects
attributable to PM2.5 exposures (U.S.
EPA, 2019) and the analyses in the PA
(U.S. EPA, 2020), including
uncertainties in the evidence and
analyses. Section II.C.1 discusses the
evidence- and risk-based considerations
in the PA. Section II.C.2 summarizes
CASAC advice on the current primary
PM2.5 standards, based on its review of
the draft PA (Cox, 2019a). Section II.C.3
presents the Administrator’s proposed
decision to retain the current primary
PM2.5 standards.
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1. Evidence- and Risk-Based
Considerations in the Policy Assessment
The Administrator’s proposed
decision in this review draws from his
consideration of the PM2.5 health
evidence assessed in the ISA (U.S. EPA,
2019) and the evidence- and risk-based
analyses presented in the PA (U.S. EPA,
2020), including the uncertainties
inherent in the evidence and analyses.
The sections below summarize the
consideration of the evidence-based
information (II.C.1.a) and risk-based
information (II.C.1.b) in the PA.
a. Evidence-Based Considerations
The PA considers the degree to which
the available scientific evidence
provides support for the current and
potential alternative standards in terms
of the basic elements of those standards
(i.e., indicator, averaging time, form,
and level). With regard to the current
indicator, averaging times, and forms,
the PA concludes that the available
evidence continues to support these
elements in the current review. For
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indicator, the PA specifically concludes
that available studies provide strong
support for health effects following
long- and short-term PM2.5 exposures
and that the evidence is too limited to
support potential alternatives (U.S. EPA,
2020, section 3.5.2.1). For averaging
time, the PA notes that epidemiologic
studies continue to provide strong
support for health effects based on
annual (or multiyear) and 24-hour PM2.5
averaging periods and concludes that
the evidence does not support
considering alternatives (U.S. EPA,
2020, section 3.5.2.2). For form, the PA
notes that the foremost consideration is
the adequacy of the public health
protection provided by the combination
of the form and the other elements of
the standard. It concludes that (1) the
form of the current annual standard (i.e.,
arithmetic mean, averaged over three
years) remains appropriate for targeting
protection against the annual and daily
PM2.5 exposures around the middle
portion of the PM2.5 air quality
distribution, and (2) the form of the
current 24-hour standard (98th
percentile, averaged over three years)
continues to provide an appropriate
balance between limiting the occurrence
of peak 24-hour PM2.5 concentrations
and identifying a stable target for risk
management programs (U.S. EPA, 2020,
section 3.5.2.3).
With regard to level, the
considerations in the PA reflect analyses
of the PM2.5 exposures and ambient
concentrations in studies reporting
PM2.5-related health effects (U.S. EPA,
2020). As noted above, the focus is on
health outcomes for which the ISA
concludes the evidence supports a
‘‘causal’’ or a ‘‘likely to be causal’’
relationship with PM exposures.41
While the causality determinations in
the ISA are informed by studies
evaluating a wide range of PM2.5
concentrations, the PA considers the
degree to which the evidence supports
the occurrence of PM-related effects at
concentrations relevant to informing
conclusions on the primary PM2.5
standards. Section II.C.1.a.i below
summarizes the PA’s consideration of
exposure concentrations that have been
evaluated in experimental studies and
section II.C.1.a.ii summarizes the PA’s
consideration of ambient concentrations
in locations evaluated by epidemiologic
studies.
41 As discussed above in II.A.2, such a focus
recognizes that standards set to provide protection
based on evidence for ‘‘causal’’ and ‘‘likely to be
causal’’ health outcomes will also provide some
measure of protection against the broader range of
PM2.5-associated outcomes, including those for
which the evidence is less certain.
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i. PM2.5 Exposure Concentrations
Evaluated in Experimental Studies
Evidence for a particular PM2.5-related
health outcome is strengthened when
results from experimental studies
demonstrate biologically plausible
mechanisms through which adverse
human health outcomes could occur
(U.S. EPA, 2015, Preamble p. 20). Two
types of experimental studies are of
particular importance in understanding
the effects of PM exposures: Controlled
human exposure and animal toxicology
studies. In such studies, investigators
expose human volunteers or laboratory
animals, respectively, to known
concentrations of air pollutants under
carefully regulated environmental
conditions and activity levels. Thus,
controlled human exposure and animal
toxicology studies can provide
information on the health effects of
experimentally administered pollutant
exposures under well-controlled
laboratory conditions (U.S. EPA, 2015,
Preamble, p. 11). The sections below
summarize the PA’s evaluation of the
PM2.5 exposure concentrations that have
been examined in controlled human
exposure studies and animal toxicology
studies.
Controlled Human Exposure Studies
Controlled human exposure studies
have reported that PM2.5 exposures
lasting from less than one hour up to
five hours can impact cardiovascular
function (U.S. EPA, 2019, section 6.1).
The most consistent evidence from
these studies is for impaired vascular
function (U.S. EPA, 2019, section
6.1.13.2). In addition, although less
consistent, the ISA notes that studies
examining PM2.5 exposures also provide
evidence for increased blood pressure
(U.S. EPA, 2019, section 6.1.6.3),
conduction abnormalities/arrhythmia
(U.S. EPA, 2019, section 6.1.4.3),
changes in heart rate variability (U.S.
EPA, 2019, section 6.1.10.2), changes in
hemostasis that could promote clot
formation (U.S. EPA, 2019, section
6.1.12.2), and increases in inflammatory
cells and markers (U.S. EPA, 2019,
section 6.1.11.2).
Table 3–2 in the PA (U.S. EPA, 2020)
summarizes information from the ISA
on available controlled human exposure
studies that evaluate effects on markers
of cardiovascular function following
exposures to PM2.5. Most of the
controlled human exposure studies in
Table 3–2 of the PA have evaluated
average PM2.5 exposure concentrations
at or above about 100 mg/m3, with
exposure durations typically up to about
two hours. Statistically significant
effects on one or more indicators of
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cardiovascular function are often,
though not always, reported following
2-hour exposures to average PM2.5
concentrations at and above about 120
mg/m3, with less consistent evidence for
effects following exposures to lower
concentrations. Impaired vascular
function, the effect identified in the ISA
as the most consistent across studies
(U.S. EPA, 2019, section 6.1.13.2), is
shown following 2-hour exposures to
PM2.5 concentrations at and above 149
mg/m3. Mixed results are reported in the
few studies that evaluate longer
exposure durations (i.e., longer than 2
hours) and lower PM2.5 concentrations
(U.S. EPA, 2020, section 3.2.3.1).
To provide some insight into what
these studies may indicate regarding the
primary PM2.5 standards, analyses in the
PA examine monitored 2-hour PM2.5
concentrations at sites meeting the
current standards (U.S. EPA, 2020,
section 3.2.3.1). At these sites, most
2-hour concentrations are below 11 mg/
m3, and they almost never exceed 32 mg/
m3. Even the highest 2-hour
concentrations remain well-below the
exposure concentrations consistently
shown to cause effects in controlled
human exposure studies (i.e., 99.9th
percentile of 2-hour concentrations is 68
mg/m3 during the warm season). Thus,
while controlled human exposure
studies support the plausibility of the
serious cardiovascular effects that have
been linked with ambient PM2.5
exposures (U.S. EPA, 2019, Chapter 6),
the PA notes that the PM2.5 exposures
evaluated in most of these studies are
well-above the ambient concentrations
typically measured in locations meeting
the current primary standards (U.S.
EPA, 2020, section 3.2.3.2.1).
Animal Toxicology Studies
The ISA relies on animal toxicology
studies to support the plausibility of a
wide range of PM2.5-related health
effects. While animal toxicology studies
often examine more severe health
outcomes and longer exposure durations
than controlled human exposure
studies, there is uncertainty in
extrapolating the effects seen in
animals, and the PM2.5 exposures and
doses that cause those effects, to human
populations.
As with controlled human exposure
studies, most of the animal toxicology
studies assessed in the ISA have
examined effects following exposures to
PM2.5 concentrations well-above the
concentrations likely to be allowed by
the current PM2.5 standards. Such
studies have generally examined shortterm exposures to PM2.5 concentrations
from 100 to >1,000 mg/m3 and long-term
exposures to concentrations from 66 to
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>400 mg/m3 (e.g., see U.S. EPA, 2019,
Table 1–2). Two exceptions are a study
reporting impaired lung development
following long-term exposures (i.e., 24
hours per day for several months
prenatally and postnatally) to an average
PM2.5 concentration of 16.8 mg/m3
(Mauad et al., 2008) and a study
reporting increased carcinogenic
potential following long-term exposures
(i.e., 2 months) to an average PM2.5
concentration of 17.7 mg/m3 (Cangerana
Pereira et al., 2011). These two studies
report serious effects following longterm exposures to PM2.5 concentrations
close to the ambient concentrations
reported in some PM2.5 epidemiologic
studies (U.S. EPA, 2019, Table 1–2),
though still above the ambient
concentrations likely to occur in areas
meeting the current primary standards.
Thus, as is the case with controlled
human exposure studies, animal
toxicology studies support the
plausibility of various adverse effects
that have been linked to ambient PM2.5
exposures (U.S. EPA, 2019), but have
not evaluated PM2.5 exposures likely to
occur in areas meeting the current
primary standards.
ii. Ambient Concentrations in Locations
of Epidemiologic Studies
As summarized above in section
II.B.1, epidemiologic studies examining
associations between daily or annual
average PM2.5 exposures and mortality
or morbidity represent a large part of the
evidence base supporting several of the
ISA’s ‘‘causal’’ and ‘‘likely to be causal’’
determinations for cardiovascular
effects, respiratory effects, cancer, and
mortality. The PA uses two approaches
to consider what information from
epidemiologic studies may indicate
regarding primary PM2.5 standards (U.S.
EPA, 2020, section 3.2.3.2). In one
approach, the PA evaluates the PM2.5 air
quality distributions reported by key
epidemiologic studies, with a focus on
overall mean PM2.5 concentrations (i.e.,
averages over the study period of the
daily or annual PM2.5 concentrations
used to estimate exposures) and the
concentrations somewhat below these
overall means (i.e., corresponding to the
lower quartiles of exposure or health
data) (U.S. EPA, 2020, section 3.2.3.2.1).
In another approach, the PA calculates
study area air quality metrics similar to
PM2.5 design values (i.e., referred to as
pseudo-design values) and considers the
degree to which such metrics indicate
that study area air quality would likely
have met or violated the current
standards during study periods (U.S.
EPA, 2020, section 3.2.3.2.2). These
approaches are discussed briefly below.
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PM2.5 Air Quality Distributions
Associated With Mortality or Morbidity
The PA evaluates the PM2.5 air quality
distributions over which epidemiologic
studies support health effect
associations and the degree to which
such distributions are likely to occur in
areas meeting the current standards. As
discussed further in the PA (U.S. EPA,
2020, section 3.2.3.2.1), epidemiologic
studies generally provide the strongest
support for reported health effect
associations over the part of the air
quality distribution corresponding to
the bulk of the underlying data (i.e.,
estimated exposures and/or health
events), often falling in the middle part
of the distribution (i.e., rather than at
the extreme upper or lower ends). Thus,
in considering PM2.5 air quality data
from epidemiologic studies, the PA
evaluates study-reported means (or
medians) of daily and annual average
PM2.5 concentrations as proxies for the
middle portions of the air quality
distributions that support reported
associations. When data are available,
the PA also considers the broader PM2.5
air quality distributions around the
overall mean concentrations, with a
focus on the lower quartiles of data to
provide insight into the concentrations
below which data supporting reported
associations become relatively sparse.
Based on its evaluation of studyreported PM2.5 concentrations, the PA
notes that key epidemiologic studies
conducted in the U.S. or Canada report
generally positive and statistically
significant associations between
estimated PM2.5 exposures (short- or
long-term) and mortality or morbidity
across a wide range of ambient PM2.5
concentrations (U.S. EPA, 2020, section
3.2.3.2.1). With regard to these studyreported concentrations, the PA makes a
number of observations, including the
following:
• For the large majority of key
studies, the PM2.5 air quality
distributions that support reported
associations are characterized by overall
mean (or median) PM2.5 concentrations
ranging from just above 8.0 mg/m3 to just
above 16.0 mg/m3. Most of these key
studies, including all but one U.S.
study, report overall mean (or median)
concentrations at or above 9.6 mg/m3.
• Several U.S. studies report positive
and statistically significant health effect
associations in analyses restricted to
annual average PM2.5 concentrations
<12 mg/m3 (Lee et al. (2015); Shi et al.
(2016); Di et al., 2017b). Studies also
report positive and statistically
significant health effect associations in
analyses restricted to days with 24-hour
average PM2.5 concentrations <35 mg/m3
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(Lee et al. (2015); Shi et al. (2016); Di
et al. (2017a)).
• For some key studies, information
on the broader distributions of PM2.5
exposure estimates and/or health events
is available. In these studies, ambient
PM2.5 concentrations corresponding to
25th percentiles of the underlying data
(i.e., estimated exposures or health
events) are generally >6.0 mg/m3.
• A small group of studies report
increased life expectancy, decreased
mortality, and decreased respiratory
effects following past declines in
ambient PM2.5 concentrations. These
studies have examined ‘‘starting’’
annual average PM2.5 concentrations
(i.e., prior to the reductions being
evaluated) ranging from about 13 to >20
mg/m3 (i.e., U.S. EPA, 2020, Table 3–3).
The PA concludes that the overall
mean PM2.5 concentrations reported by
several of these key epidemiologic
studies are likely below the long-term
mean concentrations (i.e., averaged
across space and over time) in areas just
meeting the current annual PM2.5
standard (U.S. EPA, 2020, section
3.2.3.3). The PA also concludes that
there are uncertainties in using studyreported concentrations to inform
conclusions on the primary PM2.5
standards (U.S. EPA, 2020, section
3.2.3.2.1). For example, the overall
mean PM2.5 concentrations reported by
key epidemiologic studies are not the
same as the ambient concentrations
used by the EPA to determine whether
areas meet or violate the PM NAAQS.
Overall mean PM2.5 concentrations in
key studies reflect averaging of short- or
long-term PM2.5 exposure estimates
across locations (i.e., across multiple
monitors or across modeled grid cells)
and over time (i.e., over several years).
In contrast, to determine whether areas
meet or violate the NAAQS, the EPA
measures air pollution concentrations at
individual monitors (i.e., concentrations
are not averaged across monitors) and
calculates ‘‘design values’’ at monitors
meeting appropriate data quality and
completeness criteria. For the annual
PM2.5 standard, design values are
calculated as the annual arithmetic
mean PM2.5 concentration, averaged
over 3 years (described in appendix N
of 40 CFR part 50). For an area to meet
the NAAQS, all valid design values in
that area, including the highest
monitored values, must be at or below
the level of the standard. Additional
uncertainties associated with using the
PM2.5 concentrations reported by key
epidemiologic studies to inform
conclusions on the primary PM2.5
standards result from the fact that (1)
epidemiologic studies do not identify
specific PM2.5 exposures that result in
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health effects or exposures below which
effects do not occur and (2) exposure
estimates in some recent studies are
based on hybrid modeling approaches
for which performance depends on the
availability of monitoring data and
varies by location. These results and
uncertainties are discussed in detail in
the PA (U.S. EPA, 2020, section
3.2.3.2.1).
PM2.5 Pseudo-Design Values in
Epidemiologic Study Locations
As noted above, a key uncertainty in
using study-reported PM2.5
concentrations to inform conclusions on
the primary PM2.5 standards is that they
reflect the averages of daily or annual
PM2.5 air quality concentrations or
exposure estimates in the study
population over the years examined by
the study, and are not the same as the
PM2.5 design values used by the EPA to
determine whether areas meet the
NAAQS. Therefore, the PA also
considers a second approach to
evaluating information from
epidemiologic studies. In this approach,
the PA calculates study area air quality
metrics similar to PM2.5 design values
(i.e., referred to in the PA as pseudodesign values; U.S. EPA, 2020, section
3.2.3.2.2) and considers the degree to
which such metrics indicate that study
area air quality would likely have met
or violated the current standards during
study periods. When pseudo-design
values in individual study locations are
linked with the populations living in
those locations, or with the number of
study-specific health events recorded in
those locations, these values can
provide insight into the degree to which
reported health effect associations are
based on air quality likely to have met
or violated the current (or alternative)
primary PM2.5 standards. The results of
these analyses are summarized below in
Table 1 (from U.S. EPA, 2020, Appendix
B, Tables B–5 and B–6).
TABLE 1—SUMMARY OF RESULTS
FROM ANALYSIS OF PM2.5 PSEUDODESIGN VALUES IN LOCATIONS OF
KEY U.S. AND CANADIAN MULTICITY
STUDIES
[From U.S. EPA, 2020, Table B–5]
Percent of population/
health events in
locations meeting
current standards
>
>
>
<
25%
50%
75%
25%
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Number of studies
(of the 29 evaluated)
........................
........................
........................
........................
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9
4
12
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Given the results of these analyses,
the PA concludes that several key
epidemiologic studies report positive
and statistically significant PM2.5 health
effect associations based largely, or
entirely, on air quality likely to be
allowed by the current primary PM2.5
standards (U.S. EPA, 2020, section
3.2.3.3). The PA also concludes that
there are important uncertainties to
consider when using this information to
inform conclusions on the primary
PM2.5 standards. For example, for most
key multicity studies, some study
locations would likely have met the
current primary standards over study
periods while others would likely have
violated one or both standards,
complicating the interpretation of these
analyses. In addition, pseudo-design
values are averaged over multiyear
study periods of varying lengths, rather
than reflecting the three-year averages of
actual design values; analyses
necessarily focus on locations with at
least one PM2.5 monitor, while
unmonitored areas are not included;
and recent changes to PM2.5 monitoring
requirements are not reflected in
analyses of pseudo-design values. These
results and uncertainties are discussed
in greater detail in the PA (U.S. EPA,
2020, section 3.2.3.2.2).
b. Risk-Based Considerations
In addition to evaluating PM2.5
concentrations in locations of key
epidemiologic studies, the PA includes
a risk assessment that estimates
population-level health risks associated
with PM2.5 air quality that has been
adjusted to simulate air quality
scenarios of policy interest (e.g., ‘‘just
meeting’’ the current standards). The
general approach to estimating PM2.5associated health risks combines
concentration-response functions from
epidemiologic studies with model-based
PM2.5 air quality surfaces, baseline
health incidence data, and population
demographics for forty-seven urban
study areas (U.S. EPA, 2020, section 3.3,
Figure 3–10 and Appendix C).
The risk assessment estimates that the
current primary PM2.5 standards could
allow a substantial number of PM2.5associated deaths in the U.S. For
example, when air quality in the 47
study areas is adjusted to simulate just
meeting the current standards, the risk
assessment estimates from about 16,000
to 17,000 long-term PM2.5 exposurerelated deaths from ischemic heart
disease in a single year (i.e., confidence
intervals range from about 12,000 to
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21,000 deaths).42 Compared to the
current annual standard, meeting a
revised annual standard with a lower
level is estimated to reduce PM2.5associated health risks by about 7 to 9%
for a level of 11.0 mg/m3, 14 to 18% for
a level of 10.0 mg/m3, and 21 to 27% for
a level of 9.0 mg/m3.
Limitations in the underlying data
and risk assessment approaches lead to
uncertainty in these estimates of PM2.5associated risks (e.g., in the size of risk
estimates). Uncertainty in risk estimates
results from a number of factors,
including assumptions about the shape
of the concentration-response
relationship with mortality at low
ambient PM concentrations, the
potential for confounding and/or
exposure measurement error in the
underlying epidemiologic studies, and
the methods used to adjust PM2.5 air
quality. The PA characterizes these and
other sources of uncertainty in risk
estimates using a combination of
quantitative and qualitative approaches
(U.S. EPA, 2020, Appendix C, section
C.3).
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2. CASAC Advice
As part of its review of the draft PA,
the CASAC has provided advice on the
adequacy of the public health protection
afforded by the current primary PM2.5
standards.43 Its advice is documented in
a letter sent to the EPA Administrator
(Cox, 2019a). In this letter, the
committee recommends retaining the
current 24-hour PM2.5 standard but does
not reach consensus on whether the
scientific and technical information
support retaining or revising the current
annual standard. In particular, though
the CASAC agrees that there is a longstanding body of health evidence
supporting relationships between PM2.5
exposures and various health outcomes,
including mortality and serious
morbidity effects, individual CASAC
members ‘‘differ in their assessments of
the causal and policy significance of
these associations’’ (Cox, 2019a, p. 8 of
consensus responses). Drawing from
this evidence, ‘‘some CASAC members’’
express support for retaining the current
42 For the only other cause-specific mortality
endpoint evaluated (i.e., lung cancer), substantially
fewer deaths were estimated (U.S. EPA, 2020,
section 3.3.2, e.g., Figure 3–5). Risk estimates were
not generated for other ‘‘likely to be causal’’
outcome categories (i.e., respiratory effects, nervous
system effects).
43 The CASAC also provided advice on the draft
ISA’s assessment of the scientific evidence (Cox,
2019b) and on the analyses and information in the
draft PA (Cox, 2019a), which drew from the draft
ISA. That advice, and the resulting changes made
in the final ISA and final PA, are summarized above
in sections I.C.5, II.B.1.d, II.B.1.e and II.B.3, and in
the final ISA (U.S. EPA, 2019, ES–3 to ES–4) and
the final PA (U.S. EPA, 2020, section 1.4).
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annual standard while ‘‘other members’’
express support for revising that
standard in order to increase public
health protection (Cox, 2019a, p.1 of
letter). These views are summarized
below.
The CASAC members who support
retaining the current annual standard
express the view that substantial
uncertainty remains in the evidence for
associations between PM2.5 exposures
and mortality or serious morbidity
effects. These committee members assert
that ‘‘such associations can reasonably
be explained in light of uncontrolled
confounding and other potential sources
of error and bias’’ (Cox, 2019a, p. 8 of
consensus responses). They note that
associations do not necessarily reflect
causal effects, and they contend that
recent epidemiologic studies reporting
positive associations at lower estimated
exposure concentrations mainly confirm
what was anticipated or already
assumed in setting the 2012 NAAQS. In
particular, they conclude that such
studies have some of the same
limitations as prior studies and do not
provide new information calling into
question the existing standard. They
further assert that ‘‘accountability
studies provide potentially crucial
information about whether and how
much decreasing PM2.5 causes decreases
in future health effects’’ (Cox, 2019a, p.
10), and they cite recent reviews (i.e.,
Henneman et al., 2017; Burns et al.,
2019) to support their position that in
such studies, ‘‘reductions of PM2.5
concentrations have not clearly reduced
mortality risks’’ (Cox, 2019a, p. 8 of
consensus responses). Thus, the
committee members who support
retaining the current annual standard
advise that, ‘‘while the data on
associations should certainly be
carefully considered, this data should
not be interpreted more strongly than
warranted based on its methodological
limitations’’ (Cox, 2019a, p. 8 of
consensus responses).
These members of the CASAC further
conclude that the PM2.5 risk assessment
does not provide a valid basis for
revising the current standards. This
conclusion is based on concerns that (1)
‘‘the risk assessment treats regression
coefficients as causal coefficients with
no justification or validation provided
for this decision;’’ (2) the estimated
regression concentration-response
functions ‘‘have not been adequately
adjusted to correct for confounding,
errors in exposure estimates and other
covariates, model uncertainty, and
heterogeneity in individual biological
(causal) [concentration-response]
functions;’’ (3) the estimated
concentration-response functions ‘‘do
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not contain quantitative uncertainty
bands that reflect model uncertainty or
effects of exposure and covariate
estimation errors;’’ and (4) ‘‘no
regression diagnostics are provided
justifying the use of proportional
hazards . . . and other modeling
assumptions’’ (Cox, 2019a, p. 9 of
consensus responses). These committee
members also contend that details
regarding the derivation of
concentration-response functions,
including specification of the beta
values and functional forms, are not
well-documented, hampering the ability
of readers to evaluate these design
details. Thus, these members ‘‘think that
the risk characterization does not
provide useful information about
whether the current standard is
protective’’ (Cox, 2019a, p. 11 of
consensus responses).
Drawing from their evaluation of the
evidence and the risk assessment, these
committee members conclude that ‘‘the
Draft PM PA does not establish that new
scientific evidence and data reasonably
call into question the public health
protection afforded by the current 2012
PM2.5 annual standard’’ (Cox, 2019a, p.1
of letter).
In contrast, ‘‘[o]ther members of
CASAC conclude that the weight of the
evidence, particularly reflecting recent
epidemiology studies showing positive
associations between PM2.5 and health
effects at estimated annual average
PM2.5 concentrations below the current
standard, does reasonably call into
question the adequacy of the 2012
annual PM2.5 [standard] to protect
public health with an adequate margin
of safety’’ (Cox, 2019a, p.1 of letter). The
committee members who support this
conclusion note that the body of health
evidence for PM2.5 includes not only the
repeated demonstration of associations
in epidemiologic studies, but also
includes support for biological
plausibility established by controlled
human exposure and animal toxicology
studies. They point to recent studies
demonstrating that the associations
between PM2.5 and health effects occur
in a diversity of locations, in different
time periods, with different
populations, and using different
exposure estimation and statistical
methods. They conclude that ‘‘the entire
body of evidence for PM health effects
justifies the causality determinations
made in the Draft PM ISA’’ (Cox, 2019a,
p. 8 of consensus responses).
The members of the CASAC who
support revising the current annual
standard particularly emphasize recent
findings of associations with PM2.5 in
areas with average long-term PM2.5
concentrations below the level of the
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annual standard and studies that show
positive associations even when
estimated exposures above 12 mg/m3 are
excluded from analyses. They find it
‘‘highly unlikely’’ that the extensive
body of evidence indicating positive
associations at low estimated exposures
could be fully explained by
confounding or by other non-causal
explanations (Cox, 2019a, p. 8 of
consensus responses). They additionally
conclude that ‘‘the risk characterization
does provide a useful attempt to
understand the potential impacts of
alternate standards on public health
risks’’ (Cox, 2019a, p. 11 of consensus
responses). These committee members
conclude that the evidence available in
this review reasonably calls into
question the protection provided by the
current primary PM2.5 standards and
supports revising the annual standard to
increase that protection (Cox, 2019a).
3. Administrator’s Proposed Decision on
the Current Primary PM2.5 Standards
This section summarizes the
Administrator’s considerations and
conclusions related to the current
primary PM2.5 standards and presents
his proposed decision to retain those
standards, without revision. As
described above (section II.A.2), his
approach to considering the adequacy of
the current standards focuses on
evaluating the public health protection
afforded by the annual and 24-hour
standards, taken together, against
mortality and morbidity associated with
long- or short-term PM2.5 exposures.
This approach recognizes that changes
in PM2.5 air quality designed to meet
either the annual or the 24-hour
standard would likely result in changes
to both long-term average and shortterm peak PM2.5 concentrations and that
the protection provided by the suite of
standards results from the combination
of all of the elements of those standards
(i.e., indicator, averaging time, form,
level). Thus, the Administrator’s
consideration of the public health
protection provided by the current
primary PM2.5 standards is based on his
consideration of the combination of the
annual and 24-hour standards,
including the indicators (PM2.5),
averaging times, forms (arithmetic mean
and 98th percentile, averaged over three
years), and levels (12.0 mg/m3, 35 mg/m3)
of those standards.
In establishing primary standards
under the Act that are ‘‘requisite’’ to
protect public health with an adequate
margin of safety, the Administrator is
seeking to establish standards that are
neither more nor less stringent than
necessary for this purpose. He
recognizes that the requirement to
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provide an adequate margin of safety
was intended to address uncertainties
associated with inconclusive scientific
and technical information and to
provide a reasonable degree of
protection against hazards that research
has not yet identified. However, the Act
does not require that primary standards
be set at a zero-risk level; rather, the
NAAQS must be sufficiently protective,
but not more stringent than necessary.
Given these requirements, the
Administrator’s final decision in this
review will be a public health policy
judgment drawing upon scientific and
technical information examining the
health effects of PM2.5 exposures,
including how to consider the range and
magnitude of uncertainties inherent in
that information. This public health
policy judgment will be based on an
interpretation of the scientific and
technical information that neither
overstates nor understates its strengths
and limitations, nor the appropriate
inferences to be drawn, and will be
informed by the Administrator’s
consideration of advice from the CASAC
and public comments received on this
proposal document.
With regard to the CASAC, the
Administrator recognizes that while the
committee supports retaining the
current 24-hour PM2.5 standard, it does
not reach consensus on the annual
standard (Cox, 2019a, pp. 1–3 of letter).
In particular, some members of the
CASAC conclude that the new scientific
evidence and data do not reasonably
call into question the public health
protection afforded by the current
annual standard, while other members
conclude that the weight of the evidence
does reasonably call into question the
adequacy of that standard (Cox, 2019a,
p. 1 of letter).
As discussed above (II.C.2), the
CASAC members who support retaining
the annual standard emphasize their
concerns with available PM2.5
epidemiologic studies. They assert that
recent studies ‘‘mainly confirmed what
had already been anticipated or
assumed in setting the 2012 NAAQS’’
(Cox, 2019a, p. 8 consensus responses)
and do not provide a basis for revising
the current standards. They also identify
several key concerns regarding the
associations reported in PM2.5
epidemiologic studies and conclude that
‘‘while the data on associations should
certainly be carefully considered, this
data should not be interpreted more
strongly than warranted based on its
methodological limitations’’ (Cox,
2019a, p. 8 consensus responses).
One of the methodological limitations
highlighted by these committee
members is that associations reported in
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24119
epidemiologic studies are not
necessarily indicative of causal
relationships and such associations
‘‘can reasonably be explained in light of
uncontrolled confounding and other
potential sources of error and bias’’
(Cox, 2019a, p. 8). Thus, these
committee members do not think that
recent epidemiologic studies reporting
health effect associations at PM2.5 air
quality concentrations likely to have
met the current primary standards
support revising those standards.
Consistent with the views expressed
by these CASAC members, the
Administrator recognizes that
epidemiologic studies examine
associations between distributions of
PM2.5 air quality and health outcomes,
and they do not identify particular PM2.5
exposures that cause effects (U.S. EPA,
2020, section 3.1.2). In contrast, he
notes that experimental studies (i.e.,
controlled human exposure, animal
toxicology) do provide evidence for
health effects following particular PM2.5
exposures under carefully controlled
laboratory conditions (e.g., U.S. EPA,
2015, Preamble Chapters 5 and 6). He
further notes that the evidence for a
given PM2.5-related health outcome is
strengthened when results from
experimental studies demonstrate
biologically plausible mechanisms
through which such an outcome could
occur (e.g., U.S. EPA, 2015, Preamble p.
20). Thus, when using the PM2.5 health
evidence to inform conclusions on the
adequacy of the current primary
standards, the Administrator is most
confident in the potential for PM2.5
exposures to cause adverse effects at
concentrations supported by multiple
types of studies, including experimental
studies as well as epidemiologic studies.
In light of this approach to
considering the evidence, the
Administrator recognizes that controlled
human exposure and animal toxicology
studies report a wide range of effects,
many of which are plausibly linked to
the serious cardiovascular and
respiratory outcomes reported in
epidemiologic studies (including
mortality), though the PM2.5 exposures
examined in these studies are above the
concentrations typically measured in
areas meeting the current annual and
24-hour standards (U.S. EPA, 2020,
section 3.2.3.1). In the absence of
evidence from experimental studies that
PM2.5 exposures typical of areas meeting
the current annual and 24-hour
standards can activate biological
pathways that plausibly contribute to
serious health outcomes, the
Administrator is cautious about placing
too much weight on reported PM2.5
health effect associations for air quality
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meeting those standards. He concludes
that such associations alone, without
supporting experimental evidence at
similar PM2.5 concentrations, leave
important questions unanswered
regarding the degree to which the
typical PM2.5 exposures likely to occur
in areas meeting the current standards
can cause the mortality or morbidity
outcomes reported in epidemiologic
studies. Given this concern, the
Administrator does not think that recent
epidemiologic studies reporting health
effect associations at PM2.5 air quality
concentrations likely to have met the
current primary standards support
revising those standards. Rather, he
judges that the overall body of evidence,
including controlled human exposure
and animal toxicological studies, in
addition to epidemiologic studies,
indicates continuing uncertainty in the
degree to which adverse effects could
result from PM2.5 exposures in areas
meeting the current annual and 24-hour
standards.
The Administrator additionally
considers the emerging body of
evidence from studies examining past
reductions in ambient PM2.5, and the
degree to which those reductions have
resulted in public health improvements.
As an initial matter, he notes the
observation from some CASAC members
(i.e., those who support retaining the
current annual standard) that in
accountability studies, ‘‘reductions of
PM2.5 concentrations have not clearly
reduced mortality risks, especially when
confounding was tightly controlled’’
(Cox, 2019a, p. 8). The Administrator
recognizes that interpreting such studies
in the context of the current primary
PM2.5 standards is also complicated by
the fact that some of the available
studies have not evaluated PM2.5
specifically (e.g., as opposed to PM10 or
total suspended particulates), did not
show changes in PM2.5 air quality, or
have not been able to disentangle health
impacts of the interventions from
background trends in health (U.S. EPA,
2020, section 3.5.1). He further
recognizes that the small number of
available studies that do report public
health improvements following past
declines in ambient PM2.5 have not
examined air quality meeting the
current standards (U.S. EPA, 2020,
Table 3–3). This includes recent U.S.
studies that report increased life
expectancy, decreased mortality, and
decreased respiratory effects following
past declines in ambient PM2.5
concentrations. Such studies have
examined ‘‘starting’’ annual average
PM2.5 concentrations (i.e., prior to the
reductions being evaluated) ranging
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from about 13 to > 20 mg/m3 (i.e., U.S.
EPA, 2020, Table 3–3). It also includes
a recent study conducted in Japan that
reports reduced mortality following
reductions in ambient PM2.5 due to the
introduction of diesel emission controls
(Yorifuji et al., 2016). As in the U.S.
studies, ambient PM2.5 concentrations in
this study were above those allowed by
the current primary PM2.5 standards.
Given the lack of studies reporting
public health improvements attributable
to reductions in ambient PM2.5 in
locations meeting the current standards,
together with his broader concerns
regarding the lack of experimental
studies examining PM2.5 exposures
typical of areas meeting the current
standards (discussed above), the
Administrator judges that there is
considerable uncertainty in the
potential for increased public health
protection from further reductions in
ambient PM2.5 concentrations beyond
those achieved under the current
primary PM2.5 standards.
In addition to the evidence, the
Administrator considers the potential
implications of the risk assessment for
his proposed decision. In doing so, he
notes that all risk assessments have
limitations and that, in previous
reviews, these limitations have often
resulted in less weight being placed on
quantitative estimates of risk than on
the underlying scientific evidence itself
(e.g., 78 FR 3128, January 15, 2013).
Such limitations in risk estimates can
result from uncertainty in the shapes of
concentration-response functions,
particularly at low concentrations;
uncertainties in the methods used to
adjust air quality; and uncertainty in
estimating risks for populations,
locations and air quality distributions
different from those examined in the
underlying epidemiologic study (U.S.
EPA, 2020, section 3.3.2.4).
In addition to these general
uncertainties with risk assessments, the
Administrator notes the concerns
expressed by members of the CASAC
who support retaining the current
standards. Their concerns largely reflect
their overall views on the limitations in
the PM2.5 epidemiologic evidence,
which provides key inputs to the risk
assessment. These committee members
assert that ‘‘the conclusions from the
risk assessment do not comprise valid
empirical evidence or grounds for
revising the current NAAQS’’ (Cox,
2019a, p. 9 consensus responses). As
discussed above, the Administrator
agrees with the broad concerns
expressed by these members of the
CASAC regarding associations at PM2.5
concentrations meeting the current
standards. He further notes their
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concerns regarding the characterization
of uncertainty in the risk assessment
and the evaluation of modeling
assumptions (Cox, 2019a). In light of
these concerns, together with the more
general uncertainty in risk estimates
summarized above, the Administrator
judges it appropriate to place little
weight on quantitative estimates of
PM2.5-associated mortality risk in
reaching conclusions on the primary
PM2.5 standards.
When the above considerations are
taken together, the Administrator
proposes to conclude that the scientific
evidence that has become available
since the last review of the PM NAAQS,
together with the analyses in the PA
based on that evidence, does not call
into question the public health
protection provided by the current
annual and 24-hour PM2.5 standards. In
particular, the Administrator judges that
there is considerable uncertainty in the
potential public health impacts of
reductions in ambient PM2.5 below the
concentrations achieved under the
current primary standards and,
therefore, that standards more stringent
than the current standards (e.g., with
lower levels) are not supported. That is,
he judges that such standards would be
more than requisite to protect the public
health with an adequate margin of
safety. As described above, this
judgment reflects his consideration of
the uncertainties in the potential
implications of recent epidemiologic
studies due in part to the lack of
supporting evidence from experimental
studies and retrospective accountability
studies conducted at PM2.5
concentrations meeting the current
standards.
For the 24-hour standard, he notes
that this judgment is consistent with the
consensus advice of the CASAC (Cox,
2019). For the annual standard, this
judgment is consistent with the advice
of some CASAC members and reflects
the Administrator’s disagreement with
the ‘‘[o]ther members of CASAC’’ who
recommend revising the current annual
standard based largely on evidence from
recent epidemiology studies (Cox,
2019a, p. 1 of letter).
In addition, based on the
Administrator’s review of the science,
including experimental and
accountability studies conducted at
levels just above the current standard,
he judges that the degree of public
health protection provided by the
current standard is not greater than
warranted. This judgment, together with
the fact that no CASAC member
expressed support for a less stringent
standard, leads the Administrator to
conclude that standards less stringent
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than the current standards (e.g., with
higher levels) are also not supported.
When the above information is taken
together, the Administrator proposes to
conclude that the available scientific
evidence and technical information
continue to support the current annual
and 24-hour PM2.5 standards. This
proposed conclusion reflects the fact
that important limitations in the
evidence remain. The Administrator
proposes to conclude that these
limitations lead to considerable
uncertainty regarding the potential
public health implications of revising
the existing suite of PM2.5 standards.
Given this uncertainty, and the advice
from some CASAC members, he
proposes to conclude that the current
suite of primary standards, including
the current indicators (PM2.5), averaging
times (annual and 24-hour), forms
(arithmetic mean and 98th percentile,
averaged over three years) and levels
(12.0 mg/m3, 35 mg/m3), when taken
together, remain requisite to protect the
public health. Therefore, the
Administrator proposes to retain the
current suite of primary PM2.5
standards, without revision, in this
review. He solicits comment on this
proposed decision and on the
supporting rationale described above.
III. Rationale for Proposed Decisions on
the Primary PM10 Standard
The current primary PM10 standard is
intended to protect the public health
against exposures to PM10-2.5 (78 FR
3164, January 15, 2013). This section
provides the rationale supporting the
Administrator’s proposed decision to
retain the current primary PM10
standard. Section III.A summarizes the
Agency’s approach to reaching a
decision on the primary PM10 standard
in the last review and presents the
general approach to reaching a proposed
decision in this review. Section III.B
summarizes the scientific evidence for
PM10-2.5-related health effects. Section
III.C presents the Administrator’s
proposed conclusions regarding the
adequacy of the current primary PM10
standard.
A. General Approach
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1. Approach Used in the Last Review
The last review of the PM NAAQS
was completed in 2012 (78 FR 3086,
January 15, 2013). In that review the
EPA retained the existing primary 24hour PM10 standard, with its level of
150 mg/m3 and its one-expectedexceedance form on average over three
years, to continue to provide public
health protection against exposures to
PM10-2.5. In support of this decision, the
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prior Administrator emphasized her
consideration of three issues: (1) The
extent to which it was appropriate to
maintain a standard that provides some
measure of protection against all
PM10-2.5 (regardless of composition or
source or origin), (2) the extent to which
a standard with a PM10 indicator can
provide protection against exposures to
PM10-2.5, and (3) the degree of public
health protection provided by the
existing PM10 standard. Her
consideration of each of these issues is
summarized below.
First, the prior Administrator judged
that the evidence provided ‘‘ample
support for a standard that protects
against exposures to all thoracic coarse
particles, regardless of their location or
source of origin’’ (78 FR 3176, January
15, 2013). In support of this, she noted
that epidemiologic studies had reported
positive associations between PM10-2.5
and mortality or morbidity in a large
number of cities across North America,
Europe, and Asia, encompassing a
variety of environments where PM10-2.5
sources and composition are expected to
vary widely. Though most of the
available studies examined associations
in urban areas, she noted that some
studies had also linked mortality and
morbidity with relatively high ambient
concentrations of particles of non-urban
crustal origin. In light of this body of
available evidence, and consistent with
the CASAC’s advice, the prior
Administrator concluded that it was
appropriate to maintain a standard that
provides some measure of protection
against exposures to all thoracic coarse
particles, regardless of their location,
source of origin, or composition (78 FR
3176, January 15, 2013).
In reaching the conclusion that it was
appropriate to retain a PM10 indicator
for a standard meant to protect against
exposures to ambient PM10-2.5, the prior
Administrator noted that PM10 mass
includes both coarse PM (PM10-2.5) and
fine PM (PM2.5). As a result, the
concentration of PM10-2.5 allowed by a
PM10 standard set at a single level
declines as the concentration of PM2.5
increases. Because PM2.5 concentrations
tend to be higher in urban areas than
rural areas, she observed that a PM10
standard would generally allow lower
PM10-2.5 concentrations in urban areas
than in rural areas. She judged it
appropriate to maintain such a standard
given that much of the evidence for
PM10-2.5 toxicity, particularly at
relatively low particle concentrations,
came from study locations where
thoracic coarse particles were of urban
origin, and given the possibility that
PM10-2.5 contaminants in urban areas
could increase particle toxicity. Thus, in
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the last review the prior Administrator
concluded that it remained appropriate
to maintain a standard that allows lower
ambient concentrations of PM10-2.5 in
urban areas, where the evidence was
strongest that exposure to thoracic
coarse particles was associated with
morbidity and mortality, and higher
concentrations in non-urban areas,
where the public health concerns were
less certain. The prior Administrator
concluded that the varying
concentrations of coarse particles that
would be permitted in urban versus
non-urban areas under the 24-hour PM10
standard, based on the varying levels of
PM2.5 present, appropriately reflected
the differences in the strength of
evidence regarding coarse particle
health effects.
Finally, in specifically evaluating the
degree of public health protection
provided by the primary PM10 standard,
with its level of 150 mg/m3 and its oneexpected-exceedance form on average
over three years, the prior Administrator
recognized that the available health
evidence and air quality information
was much more limited for PM10-2.5 than
for PM2.5. In particular, the strongest
evidence for health effects attributable
to PM10-2.5 exposure was for
cardiovascular effects, respiratory
effects, and/or premature mortality
following short-term exposures. For
each of these categories of effects, the
2009 ISA concluded that the evidence
was ‘‘suggestive of a causal
relationship’’ (U.S. EPA, 2009c, section
2.3.3). These determinations contrasted
with those for PM2.5, as described in
Chapter 3 above, which were
determined in the ISA to be either
‘‘causal’’ or ‘‘likely to be causal’’ for
mortality, cardiovascular effects, and
respiratory effects (U.S. EPA, 2009c,
Tables 2–1 and 2–2).
The prior Administrator judged that
the important uncertainties and
limitations associated with the PM10-2.5
evidence and information raised
questions as to whether additional
public health improvements would be
achieved by revising the existing PM10
standard. She specifically noted several
uncertainties and limitations, including
the following:
• The number of epidemiologic
studies that have employed copollutant
models to address the potential for
confounding, particularly by PM2.5, was
limited. Therefore, the extent to which
PM10-2.5 itself, rather than one or more
copollutants, contributes to reported
health effects remained uncertain.
• Only a limited number of
experimental studies provided support
for the associations reported in
epidemiologic studies, resulting in
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further uncertainty regarding the
plausibility of the associations between
PM10-2.5 and mortality and morbidity
reported in epidemiologic studies.
• Limitations in PM10-2.5 monitoring
data (i.e., limited data available from
FRM/FEM sampling methods) and the
different approaches used to estimate
PM10-2.5 concentrations across
epidemiologic studies resulted in
uncertainty in the ambient PM10-2.5
concentrations at which the reported
effects occur, increasing uncertainty in
estimates of the extent to which changes
in ambient PM10-2.5 concentrations
would likely impact public health.
• While PM10-2.5 effect estimates
reported for mortality and morbidity
were generally positive, most were not
statistically significant, even in singlepollutant models. This included effect
estimates reported in some study
locations with PM10 concentrations
above those allowed by the current 24hour PM10 standard.
• The composition of PM10-2.5, and
the effects associated with various
components, were also key uncertainties
in the available evidence. Without more
information on the chemical speciation
of PM10-2.5, the apparent variability in
associations across locations was
difficult to characterize.
In considering these uncertainties and
limitations, the prior Administrator
particularly emphasized the
considerable degree of uncertainty in
the extent to which health effects
reported in epidemiologic studies are
due to PM10-2.5 itself, as opposed to one
or more co-occurring pollutants. This
uncertainty reflected the relatively small
number of PM10-2.5 studies that had
evaluated copollutant models,
particularly copollutant models that
included PM2.5, and the very limited
body of controlled human exposure
evidence supporting the plausibility of
PM10-2.5-attributable adverse effects at
ambient concentrations.
When considering the evidence as a
whole, the prior Administrator
concluded that the degree of public
health protection provided by the
current PM10 standard against exposures
to PM10-2.5 should be maintained (i.e.,
neither increased nor decreased). Her
judgment that protection did not need to
be increased was supported by her
consideration of uncertainties in the
overall body of evidence. Her judgment
that the degree of public health
protection provided by the current
standard is not greater than warranted
was supported by the observation that
positive and statistically significant
associations with mortality were
reported in some single-city U.S. study
locations likely to have violated the
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current PM10 standard. Thus, the prior
Administrator concluded that the
existing 24-hour PM10 standard, with its
one-expected exceedance form on
average over three years and a level of
150 mg/m3, was requisite to protect
public health with an adequate margin
of safety against effects that have been
associated with PM10-2.5. In light of this
conclusion, the EPA retained the
existing PM10 standard.
2. Approach in the Current Review
The approach for this review builds
on the last review, taking into account
the more recent scientific information
now available. The approach
summarized below draws from the
approach taken in the PA (U.S. EPA,
2020) and is most fundamentally based
on using the ISA’s assessment of the
current scientific evidence for health
effects of PM10-2.5 exposures (U.S. EPA,
2019).
As discussed above for PM2.5 (II.A.2),
the approach in the PA places the
greatest weight on effects for which the
evidence has been determined to
demonstrate a ‘‘causal’’ or a ‘‘likely to be
causal’’ relationship with PM exposures
(U.S. EPA, 2019). This approach focuses
policy considerations and conclusions
on health outcomes for which the
evidence is strongest. Unlike for PM2.5,
the ISA does not identify any PM10-2.5related health outcomes for which the
evidence supports either a ‘‘causal’’ or
a ‘‘likely to be causal’’ relationship.
Thus, for PM10-2.5 the PA considers the
evidence determined to be ‘‘suggestive
of, but not sufficient to infer, a causal
relationship,’’ recognizing the greater
uncertainty in such evidence.
The preamble to the ISA states that
‘‘suggestive’’ evidence is ‘‘limited, and
chance, confounding, and other biases
cannot be ruled out’’ (U.S. EPA, 2015,
Preamble Table II). In light of the
additional uncertainty in the evidence
for PM10-2.5-related health outcomes,
compared to the evidence supporting
‘‘causal’’ or ‘‘likely to be causal’’
relationships for PM2.5, the approach to
evaluating the primary PM10 standard in
this review is more limited than the
approach to evaluating the primary
PM2.5 standards (discussed in II.A.2).
Specifically, the approach for PM10 does
not include evaluations of air quality
distributions in locations of individual
epidemiologic studies, comparisons of
experimental exposures with ambient
air quality, or the quantitative
assessment of PM10-2.5 health risks. The
substantial uncertainty in such analyses,
if they were to be conducted based on
the currently available PM10-2.5 health
studies, would limit their utility for
informing conclusions on the primary
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PM10 standard. Therefore, as discussed
further below, the focus of the
evaluation of the primary PM10 standard
is on the overall body of evidence for
PM10-2.5-related health effects. This
includes consideration of the degree to
which uncertainties in the evidence
from the last review have been reduced
and the degree to which new
uncertainties have been identified.
B. Health Effects Related to Thoracic
Coarse Particle Exposures
This section briefly outlines the key
evidence for health effects associated
with PM10-2.5 exposures. This evidence
is discussed more fully in the ISA (U.S.
EPA, 2019) and the PA (U.S. EPA, 2020,
Chapter 4).
While studies conducted since the
last review have strengthened support
for relationships between PM10-2.5
exposures and some health outcomes
(discussed below), several key
uncertainties in the evidence from the
last review have, to date, ‘‘still not been
addressed’’ (U.S. EPA, 2019, section
1.4.2, p. 1–41). For example,
epidemiologic studies available in the
last review relied on various methods to
estimate PM10-2.5 exposures, and these
methods had not been systematically
compared to evaluate spatial and
temporal correlations in exposure
estimates. Methods included (1)
calculating the difference between PM10
and PM2.5 concentrations at co-located
monitors, (2) calculating the difference
between county-wide averages of
monitored PM10 and PM2.5 based on
monitors that are not necessarily colocated, and (3) direct measurement of
PM10-2.5 using a dichotomous sampler
(U.S. EPA, 2019, section 1.4.2). In the
current review, more recent
epidemiologic studies continue to use
these approaches to estimate PM10-2.5
concentrations. Additionally, some
recent studies estimate long-term
PM10-2.5 exposures as the difference
between PM10 and PM2.5 concentrations
based on information from
spatiotemporal or land use regression
(LUR) models, in addition to monitors.
As in the last review, the various
methods used to estimate PM10-2.5
concentrations have not been
systematically evaluated (U.S. EPA,
2019, section 3.3.1.1), contributing to
uncertainty regarding the spatial and
temporal correlations in PM10-2.5
concentrations across methods and in
the PM10-2.5 exposure estimates used in
epidemiologic studies (U.S. EPA, 2019,
section 2.5.1.2.3 and section 2.5.2.2.3).
Given the greater spatial and temporal
variability of PM10-2.5 and fewer PM10-2.5
monitoring sites, compared to PM2.5,
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this uncertainty is particularly
important for the coarse size fraction.
Beyond uncertainty associated with
PM10-2.5 exposure estimates in
epidemiologic studies, the limited
information on the potential for
confounding by copollutants and the
limited support available for the
biological plausibility of serious effects
following PM10-2.5 exposures also
continue to contribute broadly to
uncertainty in the PM10-2.5 health
evidence. Uncertainty related to
potential confounding stems from the
relatively small number of
epidemiologic studies that have
evaluated PM10-2.5 health effect
associations in copollutants models
with both gaseous pollutants and other
PM size fractions. Uncertainty related to
the biological plausibility of serious
effects caused by PM10-2.5 exposures
results from the small number of
controlled human exposure and animal
toxicology 44 studies that have evaluated
the health effects of experimental
PM10-2.5 inhalation exposures. The
evidence supporting the ISA’s
‘‘suggestive’’ causality determinations
for PM10-2.5, including uncertainties in
this evidence, is summarized below in
sections III.B.1 to III.B.7.
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1. Mortality
a. Long-Term Exposures
Due to the dearth of studies
examining the association between longterm PM10-2.5 exposure and mortality,
the 2009 PM ISA concluded that the
evidence was ‘‘inadequate to determine
if a causal relationship exists’’ (U.S.
EPA, 2009c). Since the completion of
the 2009 ISA, some recent cohort
studies conducted in the U.S. and
Europe report positive associations
between long-term PM10-2.5 exposure
and total (nonaccidental) mortality,
though results are inconsistent across
studies (U.S. EPA, 2019, Table 11–11).
The examination of copollutant models
in these studies remains limited and,
when included, PM10-2.5 effect estimates
are often attenuated after adjusting for
PM2.5 (U.S. EPA, 2019, Table 11–11).
Across studies, PM10-2.5 exposure
concentrations are estimated using a
variety of approaches, including direct
measurements from dichotomous
samplers, calculating the difference
between PM10 and PM2.5 concentrations
measured at collocated monitors, and
calculating difference of area-wide
concentrations of PM10 and PM2.5. As
44 Compared to humans, smaller fractions of
inhaled PM10-2.5 penetrate into the thoracic regions
of rats and mice (U.S. EPA, 2019, section 4.1.6),
contributing to the relatively limited evaluation of
PM10-2.5 exposures in animal studies.
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discussed above, temporal and spatial
correlations between these approaches
have not been evaluated, contributing to
uncertainty regarding the potential for
exposure measurement error (U.S. EPA,
2019, section 3.3.1.1 and Table 11–11).
The 2019 ISA concludes that this
uncertainty ‘‘reduces the confidence in
the associations observed across
studies’’ (U.S. EPA, 2019, p. 11–125).
The ISA additionally concludes that the
evidence for long-term PM10-2.5
exposures and cardiovascular effects,
respiratory morbidity, and metabolic
disease provide limited biological
plausibility for PM10-2.5-related mortality
(U.S. EPA, 2019, sections 11.4.1 and
11.4). Taken together, the 2019 ISA
concludes that, ‘‘this body of evidence
is suggestive, but not sufficient to infer,
that a causal relationship exists between
long-term PM10-2.5 exposure and total
mortality’’ (U.S. EPA, 2019,
p. 11–125).
b. Short-Term Exposures
The 2009 ISA concluded that the
evidence is ‘‘suggestive of a causal
relationship between short-term
exposure to PM10-2.5 and mortality’’
(U.S. EPA, 2009c). Since the completion
of the 2009 ISA, multicity
epidemiologic studies conducted
primarily in Europe and Asia continue
to provide consistent evidence of
positive associations between short-term
PM10-2.5 exposure and total
(nonaccidental) mortality (U.S. EPA,
2019, Table 11–9). Although these
studies contribute to increasing
confidence in the PM10-2.5-mortality
relationship, the use of a variety of
approaches to estimate PM10-2.5
exposures continues to contribute
uncertainty to the associations observed.
In addition, the 2019 ISA notes that an
analysis by Adar et al. (2014) indicates
‘‘possible evidence of publication bias,
which was not observed for PM2.5’’ (U.S.
EPA, 2019, section 11.3.2, p. 11–106).
Recent studies expand the assessment of
potential copollutant confounding of the
PM10-2.5-mortality relationship and
provide evidence that PM10-2.5
associations generally remain positive
in copollutant models, though
associations are attenuated in some
instances (U.S. EPA, 2019, section
11.3.4.1, Figure 11–28, Table 11–10).
The 2019 ISA concludes that, overall,
the assessment of potential copollutant
confounding is limited due to the lack
of information on the correlation
between PM10-2.5 and gaseous pollutants
and the small number of locations in
which copollutant analyses have been
conducted. Associations with causespecific mortality provide some support
for associations with total
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(nonaccidental) mortality, though
associations with cause-specific
mortality, particularly respiratory
mortality, are more uncertain (i.e., wider
confidence intervals) and less consistent
(U.S. EPA, 2019, section 11.3.7). The
ISA concludes that the evidence for
PM10-2.5-related cardiovascular and
respiratory effects provides only limited
support for the biological plausibility of
a relationship between short-term
PM10-2.5 exposure and cardiovascular
mortality (U.S. EPA, 2019, Section
11.3.7). Based on the overall evidence,
the 2019 ISA concludes that, ‘‘this body
of evidence is suggestive, but not
sufficient to infer, that a causal
relationship exists between short-term
PM10-2.5 exposure and total mortality’’
(U.S. EPA, 2019, p. 11–120).
2. Cardiovascular Effects
a. Long-term Exposures
In the 2009 PM ISA, the evidence
describing the relationship between
long-term exposure to PM10-2.5 and
cardiovascular effects was characterized
as ‘‘inadequate to infer the presence or
absence of a causal relationship.’’ The
limited number of epidemiologic
studies reported contradictory results
and experimental evidence
demonstrating an effect of PM10-2.5 on
the cardiovascular system was lacking
(U.S. EPA, 2019, section 6.4).
The evidence relating long-term
PM10-2.5 exposures to cardiovascular
mortality remains limited, with no
consistent pattern of associations across
studies and, as discussed above,
uncertainty stemming from the use of
various approaches to estimate PM10-2.5
concentrations (U.S. EPA, 2019, Table
6–70). The evidence for associations
with cardiovascular morbidity has
grown and, while results across studies
are not entirely consistent, some
epidemiologic studies report positive
associations with IHD and myocardial
infarction (MI) (U.S. EPA, 2019, Figure
6–34); stroke (U.S. EPA, 2019, Figure 6–
35); atherosclerosis (U.S. EPA, 2019,
section 6.4.5); venous thromboembolism
(VTE) (U.S. EPA, 2019, section 6.4.7);
and blood pressure and hypertension
(U.S. EPA, 2019, Section 6.4.6). PM10-2.5
cardiovascular mortality effect estimates
are often attenuated, but remain
positive, in copollutants models that
adjust for PM2.5. For morbidity
outcomes, associations are inconsistent
in copollutant models that adjust for
PM2.5, NO2, and chronic noise pollution
(U.S. EPA, 2019, p. 6–276). The lack of
toxicological evidence for long-term
PM10-2.5 exposures represents a
substantial data gap (U.S. EPA, 2019,
section 6.4.10), resulting in the 2019
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ISA conclusion that ‘‘evidence from
experimental animal studies is of
insufficient quantity to establish
biological plausibility’’ (U.S. EPA, 2019,
p. 6–277). Based largely on the
observation of positive associations in
some high-quality epidemiologic
studies, the ISA concludes that
‘‘evidence is suggestive of, but not
sufficient to infer, a causal relationship
between long-term PM10-2.5 exposure
and cardiovascular effects’’ (U.S. EPA,
2019, p. 6–277).
b. Short-Term Exposures
The 2009 ISA found that the available
evidence for short-term PM10-2.5
exposure and cardiovascular effects was
‘‘suggestive of a causal relationship.’’
This conclusion was based on several
epidemiologic studies reporting
associations between short-term PM10-2.5
exposure and cardiovascular effects,
including IHD hospitalizations,
supraventricular ectopy, and changes in
heart rate variability (HRV). In addition,
dust storm events resulting in high
concentrations of crustal material were
linked to increases in total
cardiovascular disease emergency
department visits and hospital
admissions. However, the 2009 ISA
noted the potential for exposure
measurement error and copollutant
confounding in these epidemiologic
studies. In addition, there was only
limited evidence of cardiovascular
effects from a small number of
experimental studies (e.g. animal
toxicological studies and controlled
human exposure studies) that examined
short-term PM10-2.5 exposures (U.S. EPA,
2009c, section 6.2.12.2). In the last
review, key uncertainties included the
potential for exposure measurement
error, copollutant confounding, and
limited evidence of biological
plausibility for cardiovascular effects
following inhalation exposure (U.S.
EPA, 2019, section 6.3.13).
The evidence for short-term PM10-2.5
exposure and cardiovascular outcomes
has expanded since the last review,
though important uncertainties remain.
The 2019 ISA notes that there are a
small number of epidemiologic studies
reporting positive associations between
short-term exposure to PM10-2.5 and
cardiovascular-related morbidity
outcomes. However, there is limited
evidence to suggest that these
associations are biologically plausible,
or independent of copollutant
confounding. The ISA also concludes
that it remains unclear how the
approaches used to estimate PM10-2.5
concentrations in epidemiologic studies
may impact exposure measurement
error. Taken together, the 2019 ISA
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concludes that ‘‘the evidence is
suggestive of, but not sufficient to infer,
a causal relationship between short-term
PM10-2.5 exposures and cardiovascular
effects’’ (U.S. EPA, 2019, p. 6–254).
3. Respiratory Effects—Short-Term
Exposures
Based on a small number of
epidemiologic studies observing
associations with some respiratory
effects and limited evidence from
experimental studies to support
biological plausibility, the 2009 ISA
(U.S. EPA, 2009c) concluded that the
relationship between short-term
exposure to PM10-2.5 and respiratory
effects is ‘‘suggestive of a causal
relationship.’’ Epidemiologic findings
were consistent for respiratory infection
and combined respiratory-related
diseases, but not for COPD. Studies
were characterized by overall
uncertainty in the exposure assignment
approach and limited information
regarding potential copollutant
confounding. Controlled human
exposure studies of short-term PM10-2.5
exposures found no lung function
decrements and inconsistent evidence
for pulmonary inflammation. Animal
toxicological studies were limited to
those using non-inhalation (e.g., intratracheal instillation) routes of PM10-2.5
exposure.
Recent epidemiologic findings
consistently link PM10-2.5 exposure to
asthma exacerbation and respiratory
mortality, with some evidence that
associations remain positive (though
attenuated in some studies of mortality)
in copollutant models that include
PM2.5 or gaseous pollutants. Studies
provide limited evidence for positive
associations with other respiratory
outcomes, including COPD
exacerbation, respiratory infection, and
combined respiratory-related diseases
(U.S. EPA, 2019, Table 5–36). As noted
above for other endpoints, an
uncertainty in these epidemiologic
studies is the lack of a systematic
evaluation of the various methods used
to estimate PM10-2.5 concentrations and
the resulting uncertainty in the spatial
and temporal variability in PM10-2.5
concentrations compared to PM2.5 (U.S.
EPA, 2019, sections 2.5.1.2.3 and
3.3.1.1). Taken together, the 2019 ISA
concludes that ‘‘the collective evidence
is suggestive of, but not sufficient to
infer, a causal relationship between
short-term PM10-2.5 exposure and
respiratory effects’’ (U.S. EPA, 2019, p.
5–270).
4. Cancer—Long-Term Exposures
In the last review, little information
was available from studies of cancer
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following inhalation exposures to
PM10-2.5. Thus, the 2009 ISA determined
the evidence was ‘‘inadequate to assess
the relationship between long-term
PM10-2.5 exposures and cancer’’ (U.S.
EPA, 2009c). Since the 2009 ISA, the
assessment of long-term PM10-2.5
exposure and cancer remains limited,
with a few recent epidemiologic studies
reporting positive, but imprecise,
associations with lung cancer incidence.
Uncertainty remains in these studies
with respect to exposure measurement
error due to the use of PM10-2.5
predictions that have not been validated
by monitored PM10-2.5 concentrations
(U.S. EPA, 2019, sections 3.3.2.3 and
10.3.4). Relatively few experimental
studies of PM10-2.5 have been conducted,
though available studies indicate that
PM10-2.5 exhibits two key characteristics
of carcinogens: Genotoxicity and
oxidative stress. While limited, such
experimental studies provide some
evidence of biological plausibility for
the findings in a small number of
epidemiologic studies (U.S. EPA, 2019,
section 10.3.4).
Taken together, the small number of
epidemiologic and experimental
studies, along with uncertainty with
respect to exposure measurement error,
contribute to the determination in the
2019 ISA that, ‘‘the evidence is
suggestive of, but not sufficient to infer,
a causal relationship between long-term
PM10-2.5 exposure and cancer’’ (U.S.
EPA, 2019, p. 10–87).
5. Metabolic Effects—Long-Term
Exposures
The 2009 ISA did not make a
causality determination for PM10-2.5related metabolic effects. Since the last
review, one epidemiologic study shows
an association between long-term
PM10-2.5 exposure and incident diabetes,
while additional cross-sectional studies
report associations with effects on
glucose or insulin homeostasis (U.S.
EPA, 2019, section 7.4). As discussed
above for other outcomes, uncertainties
with the epidemiologic evidence
include the potential for copollutant
confounding and exposure
measurement error (U.S. EPA, 2019,
Tables 7–15 and 7–15). The evidence
base to support the biological
plausibility of metabolic effects
following PM10-2.5 exposures is limited,
but a cross-sectional study that
investigated biomarkers of insulin
resistance and systemic and peripheral
inflammation may support a pathway
leading to type 2 diabetes (U.S. EPA,
2019, sections 7.4.1 and 7.4.3). Based on
the expanded, though still limited
evidence base, the 2019 ISA concludes
that, ‘‘[o]verall, the evidence is
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suggestive of, but not sufficient to infer,
a causal relationship between [long]term PM10-2.5 exposure and metabolic
effects’’ (U.S. EPA, 2019, p. 7–56).
6. Nervous System Effects—Long-Term
Exposures
The 2009 ISA did not make a
causality determination for PM10-2.5related nervous system effects. In the
current review, newly available
epidemiologic studies report
associations between PM10-2.5 and
impaired cognition and anxiety in
adults in longitudinal analyses (U.S.
EPA, 2019, Table 8–25, section 8.4.5).
Associations of long-term exposure with
neurodevelopmental effects are not
consistently reported in children (U.S.
EPA, 2019, sections 8.4.4 and 8.4.5).
Uncertainties in these studies include
the potential for copollutant
confounding, as no studies examined
copollutants models (U.S. EPA, 2019,
section 8.4.5), and for exposure
measurement error, given the use of
various model-based subtraction
methods to estimate PM10-2.5
concentrations (U.S. EPA, 2019, Table
8–25). In addition, there is only limited
animal toxicological evidence
supporting the biological plausibility of
nervous system effects (U.S. EPA, 2019,
sections 8.4.1 and 8.4.5). Overall, the
2019 ISA concludes that, ‘‘the evidence
is suggestive of, but not sufficient to
infer, a causal relationship between
long-term PM10-2.5 exposure and nervous
system effects (U.S. EPA, 2019, p. 8–75).
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C. Proposed Conclusions on the Current
Primary PM10 Standard
This section describes the
Administrator’s proposed conclusions
regarding the adequacy of the current
primary PM10 standard. The approach to
reaching these proposed conclusions
draws from the ISA’s assessment of the
scientific evidence for health effects
attributable to PM10-2.5 exposures (U.S.
EPA, 2019). Section III.C.1 discusses the
evidence-based considerations from the
PA. Section III.C.2 summarizes CASAC
advice on the current primary PM10
standard, based on its review of the
draft PA. Section III.C.3 presents the
Administrator’s proposed conclusions
on the current primary PM10 standard.
1. Evidence-Based Considerations in the
Policy Assessment
In the last review, the strongest
evidence for PM10-2.5-related health
effects was for cardiovascular effects,
respiratory effects, and premature
mortality following short-term
exposures. For each of these categories
of effects, the ISA concluded that the
evidence was ‘‘suggestive of a causal
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relationship’’ (U.S. EPA, 2009c, section
2.3.3). As summarized in the sections
above, key uncertainties in the evidence
resulted from limitations in the
approaches used to estimate ambient
PM10-2.5 concentrations in epidemiologic
studies, limited examination of the
potential for confounding by cooccurring pollutants, and limited
support for the biological plausibility of
the serious effects reported in many
epidemiologic studies. Since 2009, the
evidence base for several PM10-2.5related health effects has expanded,
broadening our understanding of the
range of health effects linked to PM10-2.5
exposures (U.S. EPA, 2020, Chapter 4).
This includes expanded evidence for
the relationships between long-term
exposures and cardiovascular effects,
metabolic effects, nervous system
effects, cancer, and mortality. However,
key limitations in the evidence that
were identified in the 2009 ISA persist
in studies that have become available
since the last review. As discussed in
the PA, these limitations include the
following:
• The use of a variety of methods to
estimate PM10-2.5 exposures in
epidemiologic studies and the lack of
systematic evaluation of these methods,
together with the relatively high spatial
and temporal variability in ambient
PM10-2.5 concentrations and the small
number of monitoring sites, results in
uncertainty in exposure estimates;
• The limited number of studies that
evaluate PM10-2.5 health effect
associations in copollutant models,
together with evidence from some
studies for attenuation of associations in
such models, results in uncertainty in
the independence of PM10-2.5 health
effect associations from co-occurring
pollutants;
• The limited number of controlled
human exposure and animal toxicology
studies of PM10-2.5 inhalation
contributes to uncertainty in the
biological plausibility of the PM10-2.5related effects reported in epidemiologic
studies.
Thus, while new evidence is available
for a broader range of health outcomes
in the current review, including an
increase in the number of studies that
report effects related to long-term
PM10-2.5 exposure, that evidence is
subject to the same types of
uncertainties that were identified in the
last review of the PM NAAQS. As in the
last review, these uncertainties
contribute to the conclusions in the
2019 ISA that the evidence for the
PM10-2.5-related health effects discussed
in this section is ‘‘suggestive of, but not
sufficient to infer’’ causal relationships.
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2. CASAC Advice
As part of its review of the draft PA,
the CASAC has provided advice on the
adequacy of the public health protection
afforded by the current primary PM10
standard. As for PM2.5 (section II.C.2),
the CASAC’s advice is documented in a
letter sent to the EPA Administrator
(Cox, 2019a).
In its comments on the draft PA, the
CASAC concurs with the draft PA’s
overall preliminary conclusions that it
is appropriate to consider retaining the
current primary PM10 standard without
revision. The CASAC finds the more
limited approach taken for PM10,
compared with the approach taken for
PM2.5, to be ‘‘reasonable and
appropriate’’ given the less certain
evidence and the conclusion that ‘‘key
uncertainties identified in the last
review remain’’ (Cox, 2019a, p. 13 of
consensus responses). To reduce these
uncertainties in future reviews, the
CASAC recommends improvements to
PM10-2.5 exposure assessment, including
a more extensive network for direct
monitoring of the PM10-2.5 fraction (Cox,
2019a, p. 13 of consensus responses).
The CASAC also recommends
additional human clinical and animal
toxicology studies of the PM10-2.5
fraction to improve the understanding of
biological causal mechanisms and
pathways (Cox, 2019a, p. 13 of
consensus responses). Overall, the
CASAC agrees with the EPA that ‘‘. . .
the available evidence does not call into
question the adequacy of the public
health protection afforded by the
current primary PM10 standard and that
evidence supports considering of
retaining the current standard in this
review’’ (Cox, 2019a, p. 3 of letter).
3. Administrator’s Proposed Decision on
the Current Primary PM10 Standard
This section summarizes the
Administrator’s considerations and
proposed conclusions related to the
current primary PM10 standard and
presents his proposed decision to retain
that standard, without revision. As
discussed above for PM2.5 (II.C.3), in
establishing primary standards under
the Act that are ‘‘requisite’’ to protect
the public health with an adequate
margin of safety, the Administrator is
seeking to establish standards that are
neither more nor less stringent than
necessary for this purpose. He
recognizes that the Act does not require
that primary standards be set at a zerorisk level; rather, the NAAQS must be
sufficiently protective, but not more
stringent than necessary.
Given these requirements, and
consistent with the primary PM2.5
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standards discussed above (II.C.3), the
Administrator’s final decision in this
review will be a public health policy
judgment that draws upon the scientific
information examining the health effects
of PM10-2.5 exposures, including how to
consider the range and magnitude of
uncertainties inherent in that
information. His decision will require
judgments based on an interpretation of
the science that neither overstates nor
understates its strengths and limitations,
nor the appropriate inferences to be
drawn.
As an initial matter, the Administrator
notes that the decision to retain the
primary PM10 standard in the last
review recognized that epidemiologic
studies had reported positive
associations between PM10-2.5 and
mortality or morbidity in cities across
North America, Europe, and Asia. These
studies encompassed a variety of
environments where PM10-2.5 sources
and composition were expected to vary
widely. Although most of these studies
examined PM10-2.5 health effect
associations in urban areas, some
studies had also linked mortality and
morbidity with relatively high ambient
concentrations of particles of non-urban
crustal origin. Drawing from this
evidence, the EPA judged it appropriate
to maintain a standard that provides
some measure of protection against
exposures to PM10-2.5, regardless of
location, source of origin, or particle
composition (78 FR 3176, January 15,
2013). The Agency further judged it
appropriate to retain a PM10 standard to
provide such protection given that the
varying concentrations of PM10-2.5
permitted in urban versus non-urban
areas under a PM10 standard, based on
the varying levels of PM2.5 present (i.e.,
lower PM10-2.5 concentrations allowed in
urban areas, where PM2.5 concentrations
tend to be higher), appropriately
reflected differences in the strength of
PM10-2.5 health effects evidence.
Since the last review, the
Administrator notes that the evidence
for several PM10-2.5-related health effects
has expanded, particularly for long-term
exposures. Recent epidemiologic studies
continue to report positive associations
with mortality and morbidity in cities
across North America, Europe, and Asia,
where PM10-2.5 sources and composition
are expected to vary widely. While the
Administrator recognizes that important
uncertainties remain, as described
below, he also recognizes that the
expansion in the evidence since the last
review has broadened the range of
effects that have been linked with
PM10-2.5 exposures. Such studies
provide an important part of the body of
evidence supporting the ISA’s
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strengthened causality determinations
(and new determinations) for long-term
PM10-2.5 exposures and mortality,
cardiovascular effects, metabolic effects,
nervous system effects and cancer (U.S.
EPA, 2019; U.S. EPA, 2020, section 4.2).
Drawing from his consideration of this
evidence, the Administrator proposes to
conclude that the scientific studies that
have become available since the last
review do not call into question the
decision to maintain a primary PM10
standard that provides some measure of
public health protection against PM10-2.5
exposures, regardless of location, source
of origin, or particle composition.
With regard to uncertainties in the
evidence, the Administrator notes that
the decision in the last review
highlighted limitations in estimates of
ambient PM10-2.5 concentrations used in
epidemiologic studies, the limited
evaluation of copollutant models to
address the potential for confounding,
and the limited number of experimental
studies supporting biologically
plausible pathways for PM10-2.5-related
effects. These and other limitations in
the PM10-2.5 evidence raised questions as
to whether additional public health
improvements would be achieved by
revising the existing PM10 standard.
In the current review, despite the
expanded body of evidence for PM10-2.5related health effects, the Administrator
recognizes that similar uncertainties
remain. As summarized above (III.B),
these include uncertainties in the
PM10-2.5 exposure estimates used in
epidemiologic studies, in the
independence of PM10-2.5 health effect
associations, and in support for the
biological plausibility of PM10-2.5-related
effects (e.g., from controlled human
exposure and animal toxicology studies)
(U.S. EPA, 2020, section 4.2). These
uncertainties contribute to the
determinations in the 2019 ISA that the
evidence for key PM10-2.5-related health
effects is ‘‘suggestive of, but not
sufficient to infer’’ causal relationships
(U.S. EPA, 2019). In light of his
emphasis on evidence supporting
‘‘causal’’ and ‘‘likely to be causal’’
relationships (II.A.2, III.A.2), the
Administrator judges that the PM10-2.5related health effects evidence provides
an uncertain scientific foundation for
making standard-setting decisions. He
further judges that, as in the last review,
limitations in this evidence raise
questions as to whether additional
public health improvements would be
achieved by revising the existing PM10
standard.
In reaching conclusions on the
primary PM10 standard, the
Administrator also considers advice
from the CASAC. As noted above, the
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CASAC recognizes the uncertainties in
the evidence for PM10-2.5-related health
effects, stating that ‘‘key uncertainties
identified in the last review remain’’
(Cox, 2019a, p. 13 of consensus
responses). Given these uncertainties,
the CASAC agrees with the PA
conclusion that the evidence ‘‘does not
call into question the adequacy of the
public health protection afforded by the
current primary PM10 standard’’ (Cox,
2019a, p. 3 of letter). The CASAC
further recommends that this evidence
‘‘supports consideration of retaining the
current standard in this review’’ (Cox,
2019a, p. 3 of letter).
When the above information is taken
together, the Administrator proposes to
conclude that the available scientific
evidence continues to support a PM10
standard to provide some measure of
protection against PM10-2.5 exposures.
This conclusion reflects the expanded
evidence for PM10-2.5-related health
effects in the current review. However,
important limitations in the evidence
remain. Consistent with the decision in
the last review, the Administrator
proposes to conclude that these
limitations lead to considerable
uncertainty regarding the potential
public health implications of revising
the existing PM10 standard. Given this
uncertainty, and consistent with the
CASAC’s advice, the Administrator
proposes to conclude that the available
evidence does not call into question the
adequacy of the public health protection
afforded by the current primary PM10
standard. Therefore, he proposes to
retain the primary PM10 standard,
without revision, in the current review.
The Administrator solicits comment on
this proposed decision and on the
supporting rationale described above.
IV. Rationale for Proposed Decisions on
the Secondary PM Standards
This section presents the rationale for
the Administrator’s proposed decision
to retain the current secondary PM
standards, without revision. This
rationale is based on a thorough review
of the latest scientific information
generally published through December
2017,45 as presented in the ISA, on nonecological public welfare effects
45 In addition to the review’s opening ‘‘call for
information’’ (79 FR 71764, December 3, 2014), ‘‘the
current ISA identified and evaluated studies and
reports that have undergone scientific peer review
and were published or accepted for publication
between January 1, 2009 and March 31, 2017. A
limited literature update identified some additional
studies that were published before December 31,
2017’’ (U.S. EPA, 2019, Appendix, p. A–3).
References that are cited in the ISA, the references
that were considered for inclusion but not cited,
and electronic links to bibliographic information
and abstracts can be found at: https://hero.epa.gov/
hero/particulate-matter.
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associated with PM and pertaining to
the presence of PM in ambient air. The
Administrator’s rationale also takes into
account the PA’s evaluation of the
policy-relevant information in the ISA
and quantitative analyses of air quality
related to visibility impairment and the
CASAC’s advice and recommendations,
as reflected in discussions of the drafts
of the ISA and PA at public meetings
and in the CASAC’s letters to the
Administrator.
In presenting the rationale for the
Administrator’s proposed decision and
its foundations, section IV.A provides
background on the general approach for
review of the secondary PM standards,
including a summary of the approach
used in the last review (section IV.A.1)
and the general approach for the current
review (section IV.A.2). Section IV.B
summarizes the currently available
evidence for PM-related visibility
impairment and section IV.C
summarizes the available information
for other PM-related welfare effects.
Section IV.D presents the
Administrator’s proposed conclusions
on the current secondary PM standards.
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A. General Approach
In the last review of the PM NAAQS,
completed in 2012, the EPA retained the
secondary 24-hour PM2.5 standard, with
its level of 35 mg/m3, and the 24-hour
PM10 standard, with its level of 150 mg/
m3 (78 FR 3228, January 15, 2013). The
EPA also retained the level, set at 15 mg/
m3, and averaging time of the secondary
annual PM2.5 standard, while revising
the form. With regard to the form of the
annual PM2.5 standard, the EPA
removed the option for spatial averaging
(78 FR 3228, January 15, 2013). Key
aspects of the Administrator’s decisions
on the secondary PM standards for nonvisibility effects and visibility effects are
described below in section IV.A.1.
1. Approach Used in the Last Review
The 2012 decision on the adequacy of
the secondary PM standards was based
on consideration of the protection
provided by those standards for
visibility and for the non-visibility
effects of materials damage, climate
effects and ecological effects. As noted
earlier, the current review of the public
welfare protection provided by the
secondary PM standards against
ecological effects is occurring in the
separate, on-going review of the
secondary NAAQS for oxides of
nitrogen and oxides of sulfur (U.S. EPA,
2016, Chapter 1, section 5.2; U.S. EPA,
2020, Chapter 1, section 5.1.1). Thus,
the consideration of ecological effects in
the 2012 review is not discussed here.
Rather, the sections below focus on the
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prior Administrator’s consideration of
climate and materials effects (section
IV.A.1.a) and visibility effects (section
IV.A.1.b).
a. Non-Visibility Effects
With regard to the role of PM in
climate, the prior Administrator
considered whether it was appropriate
to establish any distinct secondary PM
standards to address welfare effects
associated with climate impacts. In
considering the scientific evidence, she
noted the 2009 ISA conclusion ‘‘that a
causal relationship exists between PM
and effects on climate’’ and that
aerosols 46 alter climate processes
directly through radiative forcing and by
indirect effects on cloud brightness,
changes in precipitation, and possible
changes in cloud lifetimes (U.S. EPA,
2009c, section 9.3.10). Additionally, the
major aerosol components with the
potential to affect climate processes (i.e.,
black carbon (BC), organic carbon (OC),
sulfates, nitrates and mineral dusts) vary
in their reflectivity, forcing efficiencies,
and direction of climate forcing (U.S.
EPA, 2009c, section 9.3.10).
Noting the strong evidence indicating
that aerosols affect climate, the prior
Administrator further considered what
the available information indicated
regarding the adequacy of protection
provided by the secondary PM
standards. She noted that a number of
uncertainties in the scientific
information affected our ability to
quantitatively evaluate the standards in
this regard. For example, the ISA and
PA noted the spatial and temporal
heterogeneity of PM components that
contribute to climate forcing,
uncertainties in the measurement of
aerosol components, inadequate
consideration of aerosol impacts in
climate modeling, insufficient data on
local and regional microclimate
variations and heterogeneity of cloud
formations. In light of these
uncertainties and the lack of sufficient
data, the 2011 PA concluded that it was
not feasible in the last review ‘‘to
conduct a quantitative analysis for the
46 In the climate sciences research community,
PM is encompassed by what is typically referred to
as aerosol. An aerosol is defined as a solid or liquid
suspended in a gas, but PM refers to the solid or
liquid phase of an aerosol. In this review of the
secondary PM NAAQS the discussion on climate
effects of PM uses the term PM throughout for
consistency with the ISA (U.S. EPA, 2019) as well
as to emphasize that the climate processes altered
by aerosols are generally altered by the PM portion
of the aerosol. Exceptions to this practice include
the discussion of climate effects in the last review,
when aerosol was used when discussing
suspending aerosol particles, and for certain
acronyms that are widely used by the climate
community that include the term aerosol (e.g.,
aerosol optical depth, or AOD).
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purpose of informing revisions [to the
secondary PM NAAQS] based on
climate’’ (U.S. EPA, 2011, pp. 5–11 to 5–
12) and that there was insufficient
information available to base a national
ambient air quality standard on climate
impacts associated with ambient air
concentrations of PM or its constituents
(U.S. EPA, 2011, section 5.2.3). The
prior Administrator agreed with this
conclusion (78 FR 3225–3226, January
15, 2013).
With regard to materials effects, the
she also considered effects associated
with the deposition of PM (i.e., dry and
wet deposition), including both physical
damage (materials effects) and aesthetic
qualities (soiling effects). The
deposition of PM can physically affect
materials, adding to the effects of
natural weathering processes, by
promoting or accelerating the corrosion
of metals; by degrading paints; and by
deteriorating building materials such as
stone, concrete, and marble (U.S. EPA,
2009c, section 9.5). Additionally, the
deposition of PM from ambient air can
reduce the aesthetic appeal of buildings
and objects through soiling. The ISA
concluded that evidence was ‘‘sufficient
to conclude that a causal relationship
exists between PM and effects on
materials’’ (U.S. EPA, 2009c, sections
2.5.4 and 9.5.4). However, the 2011 PA
noted that quantitative relationships
were lacking between particle size,
concentrations, and frequency of
repainting and repair of surfaces and
that considerable uncertainty exists in
the contributions of co-occurring
pollutants to materials damage and
soiling processes (U.S. EPA, 2011, p. 5–
29). The 2011 PA concluded that none
of the evidence available in the last
review called into question the
adequacy of the existing secondary PM
standards to protect against material
effects (U.S. EPA, 2011, p. 5–29). The
prior Administrator agreed with this
conclusion (78 FR 3225–3226, January
15, 2013).
In considering non-visibility welfare
effects in the last review, as discussed
above, the prior Administrator
concluded that, while it is important to
maintain an appropriate degree of
control of fine and coarse particles to
address non-visibility welfare effects,
‘‘[i]n the absence of information that
would support any different standards
. . . it is appropriate to retain the
existing suite of secondary standards’’
(78 FR 3225–3226, January 15, 2013).
Her decision was consistent with the
CASAC advice related to non-visibility
effects. Specifically, the CASAC agreed
with the 2011 PA conclusions that,
while these effects are important, ‘‘there
is not currently a strong technical basis
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to support revisions of the current
standards to protect against these other
welfare effects’’ (Samet, 2010a, p. 5).
Thus, the prior Administrator
concluded that it was appropriate to
retain all aspects of the existing 24-hour
PM2.5 and PM10 secondary standards.
With regard to the secondary annual
PM2.5 standard, she concluded that it
was appropriate to retain a level of 15.0
mg/m3 while revising only the form of
the standard to remove the option for
spatial averaging (78 FR 3225–3226,
January 15, 2013).
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b. Visibility Effects
Having reached the conclusion to
retain the existing secondary PM
standards to protect against nonvisibility welfare effects, the prior
Administrator next considered the level
of protection that would be requisite to
protect public welfare against PMrelated visibility impairment and
whether to adopt a distinct secondary
standard to achieve this level of
protection. In reaching her final
decision that the existing 24-hour PM2.5
standard provides sufficient protection
against PM-related visibility impairment
(78 FR 3228, January 15, 2013), she
considered the evidence assessed in the
2009 ISA (U.S. EPA, 2009c) and the
analyses included in the Urban-Focused
Visibility Assessment (2010 UFVA; U.S.
EPA, 2010b) and the 2011 PA (U.S. EPA,
2011). She also considered the degree of
protection for visibility that would be
provided by the existing secondary
standard, focusing specifically on the
secondary 24-hour PM2.5 standard with
its level of 35 mg/m3. These
considerations, and the prior
Administrator’s conclusions regarding
visibility are discussed in more detail
below.
In the last review, the ISA concluded
that, ‘‘collectively, the evidence is
sufficient to conclude that a causal
relationship exists between PM and
visibility impairment’’ (U.S. EPA,
2009c, p. 2–28). Visibility impairment is
caused by light scattering and
absorption by suspended particles and
gases, including water content of
aerosols.47 The available evidence in the
last review indicated that specific
components of PM have been shown to
contribute to visibility impairment. For
47 All particles scatter light and, although a larger
particle scatters more light than a similarly shaped
smaller particle of the same composition, the light
scattered per unit of mass is greatest for particles
with diameters from ∼0.3–1.0 mm (U.S. EPA, 2009c,
section 2.5.1). Particles with hygroscopic
components (e.g., particulate sulfate and nitrate)
contribute more to light extinction at higher relative
humidity than at lower relative humidity because
they change size in the atmosphere in response to
relative humidity.
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example, at sufficiently high relative
humidity values, sulfate and nitrate are
the PM components that scatter more
light and thus contribute most
efficiently to visibility impairment.
Elemental carbon (EC) and organic
carbon (OC) are also important
contributors, especially in the
northwestern U.S. where their
contribution to PM2.5 mass is higher.
Crustal materials can be significant
contributors to visibility impairment,
particularly for remote areas in the arid
southwestern U.S. (U.S. EPA, 2009c,
section 2.5.1).
Visibility impairment can have
implications for people’s enjoyment of
daily activities and for their overall
sense of well-being (U.S. EPA, 2009c,
section 9.2). In consideration of the
potential public welfare implication of
various degrees of PM-related visibility
impairment, the prior Administrator
considered the available visibility
preference studies that were part of the
overall body of evidence in the 2009
ISA and reviewed as a part of the 2010
UFVA. These preference studies
provided information about the
potential public welfare implications of
visibility impairment from surveys in
which participants were asked
questions about their preferences or the
values they placed on various visibility
conditions, as displayed to them in
scenic photographs or in images with a
range of known light extinction levels.48
In noting the relationship between PM
concentrations and PM-related light
extinction, the prior Administrator
focused on identifying an adequate level
of protection against visibility-related
welfare effects. She first concluded that
a standard in terms of a PM2.5 visibility
index would provide a measure of
protection against PM-related light
extinction that directly takes into
account the factors (i.e., species
composition and relative humidity) that
influence the relationship between
PM2.5 in ambient air and PM-related
visibility impairment. A PM2.5 visibility
index standard would afford a relatively
high degree of uniformity of visual air
quality protection in areas across the
country by directly incorporating the
effects of differences of PM2.5
48 Preference studies were available in four urban
areas in the last review. Three western preference
studies were available, including one in Denver,
Colorado (Ely et al., 1991), one in the lower Fraser
River valley near Vancouver, British Columbia,
Canada (Pryor, 1996), and one in Phoenix, Arizona
(BBC Research & Consulting, 2003). A pilot focus
group study was also conducted for Washington,
DC (Abt Associates, 2001), and a replicate study
with 26 participants was also conducted for
Washington, DC (Smith and Howell, 2009). More
details about these studies are available in
Appendix D of the PA.
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composition and relative humidity. In
defining a target level of protection in
terms of a PM2.5 visibility index, as
discussed below, she considered
specific elements of the index,
including the basis for its derivation, as
well as an appropriate averaging time,
level, and form.
With regard to the basis for derivation
of a visibility index, the prior
Administrator concluded that it was
appropriate to use an adjusted version
of the original IMPROVE algorithm,49 in
conjunction with monthly average
relative humidity data based on longterm climatological means. In so
concluding, she noted the CASAC
conclusion on the reasonableness of
reliance on a PM2.5 light extinction
indicator calculated from PM2.5
chemical composition and relative
humidity. In considering alternative
approaches for a focus on visibility, she
recognized that the available mass
monitoring methods did not include
measurement of the full water content of
ambient PM2.5, nor did they provide
information on the composition of
PM2.5, both of which contribute to
visibility impacts (77 FR 38980, June 29,
2012). In addition, at the time of the
proposal, she recognized that suitable
equipment and performance-based
verification procedures did not then
exist for direct measurement of light
extinction and could not be developed
within the time frame of the review (77
FR 38980–38981, June 29, 2012).
With regard to the averaging time of
the index, the prior Administrator
concluded that a 24-hour averaging time
would be appropriate for a visibility
index (78 FR 3226, January 15, 2013).
Although she recognized that hourly or
sub-daily (4- to 6-hour) averaging times,
within daylight hours and excluding
hours with relatively high humidity, are
more directly related to the short-term
nature of the perception of PM-related
visibility impairment and relevant
exposure periods for segments of the
viewing public than a 24-hour averaging
time, she also noted that there were data
quality uncertainties associated with the
instruments used to provide the hourly
PM2.5 mass measurements required for
an averaging time shorter than 24 hours.
She also considered the results of
analyses that compared 24-hour and 4hour averaging times for calculating the
index. These analyses showed good
correlation between 24-hour and 4-hour
49 The revised IMPROVE algorithm (Pitchford et
al., 2007) uses major PM chemical composition
measurements and relative humidity estimates to
calculate light extinction. For more information
about the derivation of and input data required for
the original and revised IMPROVE algorithms, see
78 FR 3168–3177, January 15, 2013.
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average PM2.5 light extinction, as
evidenced by reasonably high cityspecific and pooled R-squared values,
generally in the range of over 0.6 to over
0.8. Based on these analyses and the
2011 PA conclusions regarding them,
the prior Administrator concluded that
a 24-hour averaging time would be a
reasonable and appropriate surrogate for
a sub-daily averaging time.
With regard to the statistical form of
the index, the prior Administrator
settled on a 3-year average of annual
90th percentile values. In so doing, she
noted that a 3-year average form
provided stability from the occasional
effect of inter-annual meteorological
variability that can result in unusually
high pollution levels for a particular
year (78 FR 3198, January 15, 2013; U.S.
EPA, 2011, p. 4–58).50 Regarding the
annual statistic to be averaged, the 2010
UFVA evaluated three different
statistics: 90th, 95th, and 98th
percentiles (U.S. EPA, 2010b, chapter 4).
In considering these alternative
percentiles, the 2011 PA noted that the
Regional Haze Program targets the 20
percent most impaired days for
improvements in visual air quality in
Federal Class I areas and that the
median of the distribution of these 20
percent worst days would be the 90th
percentile. The 2011 PA further noted
that strategies that are implemented so
that 90 percent of days would have
visual air quality that is at or below the
level of the standard would reasonably
be expected to lead to improvements in
visual air quality for the 20 percent most
impaired days. Lastly, the 2011 PA
recognized that the available studies on
people’s preferences did not address
frequency of occurrence of different
levels of visibility and did not identify
a basis for a different target for urban
areas than that for Class I areas (U.S.
EPA, 2011, p. 4–59). These
considerations led the prior
Administrator to conclude that 90th
percentile form was the most
appropriate annual statistic to be
averaged across three years (78 FR 3226,
January 15, 2013).
With regard to the level of the index,
she considered the visibility preferences
studies conducted in four urban areas
(U.S. EPA, 2011, p. 4–61). Based on
these studies, the PA identified a range
50 The EPA recognized that a percentile form
averaged over multiple years offers greater stability
to the air quality management process by reducing
the possibility that statistically unusual indicator
values will lead to transient violations of the
standard, thus reducing the potential for disruption
of programs implementing the standard and
reducing the potential for disruption of the
protections provided by those programs.
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of levels from 20 to 30 deciviews (dv) 51
as being a reasonable range of
‘‘candidate protection levels’’ (CPLs).52
In considering this range of CPLs, she
noted the uncertainties and limitations
in public preference studies, including
the small number of stated preference
studies available; the relatively small
number of study participants and the
extent to which the study participants
may not be representative of the broader
study area population in some of the
studies; and the variations in the
specific materials and methods used in
each study. She concluded that the
substantial degree of variability and
uncertainty in the public preference
studies should be reflected in a target
protection level at the upper end of the
range of CPLs. Therefore, she concluded
that it was appropriate to set a target
level of protection in terms of a 24-hour
PM2.5 visibility index at 30 dv (78 FR
3226–3227, January 15, 2013).
Based on her considerations and
conclusions summarized above, the
prior Administrator concluded that the
protection provided by a secondary
standard based on a 3-year visibility
metric, defined in terms of a PM2.5
visibility index with a 24-hour
averaging time, a 90th percentile form
averaged over 3 years, and a level of 30
dv, would be requisite to protect public
welfare with regard to visual air quality
(78 FR 3227, January 15, 2013). Having
reached this conclusion, she next
determined whether an additional
distinct secondary standard in terms of
a visibility index was needed given the
degree of protection from visibility
impairment afforded by the existing
secondary standards. Specifically, she
noted that the air quality analyses
showed that all areas meeting the
existing 24-hour PM2.5 standard, with its
level of 35 mg/m3, had visual air quality
at least as good as 30 dv, based on the
visibility index defined above (Kelly et
al., 2012b, Kelly et al., 2012a). Thus, the
secondary 24-hour PM2.5 standard
would likely be controlling relative to a
24-hour visibility index set at a level of
30 dv. Additionally, areas would be
unlikely to exceed the target level of
protection for visibility of 30 dv without
also exceeding the existing secondary
24-hour standard. Thus, the prior
Administrator judged that the 24-hour
PM2.5 standard ‘‘provides sufficient
protection in all areas against the effects
51 Deciview (dv) refers to a scale for
characterizing visibility that is defined directly in
terms of light extinction. The deciview scale is
frequently used in the scientific and regulatory
literature on visibility.
52 For comparison, 20 dv, 25 dv, and 30 dv are
equivalent to 64, 112, and 191 megameters
(Mm¥.1), respectively.
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of visibility impairment—i.e., that the
existing 24-hour PM2.5 standard would
provide at least the target level of
protection for visual air quality of 30 dv
which [she] judges appropriate’’ (78 FR
3227, January 15, 2013). She further
judged that ‘‘[s]ince sufficient protection
from visibility impairment would be
provided for all areas of the country
without adoption of a distinct secondary
standard, and adoption of a distinct
secondary standard will not change the
degree of over-protection for some areas
of the country. . . adoption of such a
distinct secondary standard is not
needed to provide requisite protection
for both visibility and nonvisibility
related welfare effects’’ (78 FR 3228,
January 15, 2013).
2. Approach for the Current Review
To evaluate whether it is appropriate
to consider retaining the current
secondary PM standards, or whether
consideration of revision is appropriate,
the EPA has adopted an approach in
this review that builds upon the general
approach used in the last review and
reflects the body of evidence and
information now available. As
summarized above, past approaches
have been based most fundamentally on
using information from studies of PMrelated visibility effects, quantitative
analyses of PM-related visibility
impairment, information from studies of
non-visibility welfare effects, advice
from the CASAC, and public comments
to inform the selection of secondary PM
standards that, in the Administrator’s
judgment, protect the public welfare
from any known or anticipated effects.
Similarly, in this review, the EPA
draws on the available evidence and
quantitative assessments pertaining to
the public welfare impacts of PM in
ambient air. In considering the scientific
and technical information, the Agency
considers both the information available
at the time of the last review and the
information that is newly available in
this review. This includes information
on PM-related visibility and nonvisibility effects. Consistent with the
approach in the last review, the
quantitative air quality analyses for PMrelated visibility effects provide a
context for interpreting the evidence of
visibility impairment and the potential
public welfare significance of PM
concentrations in ambient air associated
with recent air quality conditions.
B. PM-Related Visibility Impairment
The information summarized here is
based on the EPA’s scientific assessment
of the latest evidence on visibility
effects associated with PM; this
assessment is documented in the ISA
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and its policy implications are further
discussed in the PA. In considering the
scientific and technical information, the
PA reflects upon both the information
available in the last review and
information that is newly available
since the last review. Policy
implications of the currently available
evidence are discussed in the PA (as
summarized in section IV.D.1). The
subsections below briefly summarize
the following aspects of the evidence:
The nature of PM-related visibility
impairment (section IV.B.1), the
relationship between ambient PM and
visibility (section IV.B.2), and public
perception of visibility impairment
(section IV.B.3).
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1. Nature of PM-Related Visibility
Impairment
Visibility refers to the visual quality
of a human’s view with respect to color
rendition and contrast definition. It is
the ability to perceive landscape form,
colors, and textures. Visibility involves
optical and psychophysical properties
involving human perception, judgment,
and interpretation. Light between the
observer and the object can be scattered
into or out of the sight path and
absorbed by PM or gases in the sight
path. The conclusions of the ISA that
‘‘the evidence is sufficient to conclude
that a causal relationship exists between
PM and visibility impairment’’ is
consistent with conclusions of causality
in the last review (U.S. EPA, 2019,
section 13.2.6). These conclusions are
based on strong and consistent evidence
that ambient PM can impair visibility in
both urban and remote areas (U.S. EPA,
2019, section 13.1; U.S. EPA, 2009c,
section 9.2.5).
2. Relationship Between Ambient PM
and Visibility
The fundamental relationship
between light extinction and PM mass,
and the EPA’s understanding of this
relationship, has changed little since the
2009 ISA (U.S. EPA, 2009c). The
combined effect of light scattering and
absorption by particles and gases is
characterized as light extinction, i.e., the
fraction of light that is scattered or
absorbed per unit of distance in the
atmosphere. Light extinction is
measured in units of 1/distance, which
is often expressed in the technical
literature as visibility per megameter
(abbreviated Mm¥1). Higher values of
light extinction (usually given in units
of Mm¥1 or dv) correspond to lower
visibility. When PM is present in the air,
its contribution to light extinction is
typically much greater than that of gases
(U.S. EPA, 2019, section 13.2.1). The
impact of PM on light scattering
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depends on particle size and
composition, as well as relative
humidity. All particles scatter light, as
described by the Mie theory, which
relates light scattering to particle size,
shape, and index of refraction (U.S.
EPA, 2019, section 13.2.3; Van de Hulst,
1981; Mie, 1908). Fine particles scatter
more light than coarse particles on a per
unit mass basis and include sulfates,
nitrates, organics, light-absorbing
carbon, and soil (Malm et al., 1994).
Hygroscopic particles like ammonium
sulfate, ammonium nitrate, and sea salt
increase in size as relative humidity
increases, leading to increased light
scattering (U.S. EPA, 2019, section
13.2.3).
Direct measurements of PM light
extinction, scattering, and absorption
are considered more accurate for
quantifying visibility than PM massbased estimates because measurements
do not depend on assumptions about
particle characteristics (e.g., size, shape,
density, component mixture, etc.) (U.S.
EPA, 2019, section 13.2.2.2).
Measurements of light extinction can be
made with high time resolution,
allowing for characterization of subdaily
temporal patterns of visibility
impairment. A variety of measurement
methods have been used (e.g.,
transmissometers, integrating
nephelometers, teleradiometers,
telephotometers, and photography and
photographic modeling), each with its
own strengths and limitations (U.S.
EPA, 2019, Table 13–1). However, there
are no common performance-based
criteria to evaluate these methods and
none have been deployed broadly across
the U.S. for routine measurement of
visibility impairment.
In the absence of a robust monitoring
network for the routine measurement of
light extinction across the U.S.,
estimation of light extinction based on
existing PM monitoring can be used. A
theoretical relationship between light
extinction and PM characteristics has
been derived from Mie theory (U.S.
EPA, 2019, Equation 13.5) and can be
used to estimate light extinction by
combining mass scattering efficiencies
of particles with particle concentrations
(U.S. EPA, 2019, section 13.2.3; U.S.
EPA, 2009c, sections 9.2.2.2 and
9.2.3.1). However, routine ambient air
monitoring rarely includes
measurements of particle size and
composition information with sufficient
detail for these calculations.
Accordingly, a much simpler algorithm
has been developed to make estimating
light extinction more practical.
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This algorithm, known as the
IMPROVE algorithm,53 provides for the
estimation of light extinction (bext), in
units of Mm¥1, using routinely
monitored components of fine (PM2.5)
and coarse (PM10-2.5) PM. Relative
humidity data are also needed to
estimate the contribution by liquid
water that is in solution with the
hygroscopic components of PM. To
estimate each component’s contribution
to light extinction, their concentrations
are multiplied by extinction coefficients
and are additionally multiplied by a
water growth factor that accounts for
their expansion with moisture. Both the
extinction efficiency coefficients and
water growth factors of the IMPROVE
algorithm have been developed by a
combination of empirical assessment
and theoretical calculation using
particle size distributions associated
with each of the major aerosol
components (U.S. EPA, 2019, section
13.2.3.1, section 13.2.3.3).
The original IMPROVE algorithm, so
referenced here to distinguish it from
subsequent variations developed later,
was found to underestimate the highest
light scattering values and overestimate
the lowest values at IMPROVE monitors
throughout the U.S. (Malm and Hand,
2007; Ryan et al., 2005; Lowenthal and
Kumar, 2004) and at sites in China (U.S.
EPA, 2019, section 13.2.3.3). To resolve
these biases, a revised IMPROVE
equation was developed (Pitchford et
al., 2007). Since the last review,
Lowenthal and Kumar (2016) further
offered a number of modifications to the
revised IMPROVE equation, with a
focus of the application of the IMPROVE
equation in remote sites. In particular,
one of the modifications was to increase
the multiplier to estimate the
concentration of organic matter, [OM],
from the concentration of organic
carbon, [OC]. This modification was
based on their evaluations of monitoring
data from remote IMPROVE sites, which
showed that in areas further away from
PM sources, PM mass is often more
oxygenated and contains a larger
amount of organic PM. (U.S. EPA, 2019,
section 13.2.3.3). As discussed below in
section IV.D.1, analyses conducted in
the current review estimate PM-related
visibility impairment using each of
these versions of the IMPROVE
equation.
53 The algorithm is referred to as the IMPROVE
algorithm as it was developed specifically to use
monitoring data generated at IMPROVE network
sites and with equipment specifically designed to
support the IMPROVE program and was evaluated
using IMPROVE optical measurements at the subset
of monitoring sites that make those measurements
(Malm et al., 1994).
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3. Public Perception of Visibility
Impairment
In the last review, visibility
preference studies were available from
four areas in North America.54 Study
participants were queried regarding
multiple images that, depending on the
study, were either photographs of the
same location and scenery that had been
taken on different days on which
measured extinction data were available
or digitized photographs onto which a
uniform ‘‘haze’’ had been
superimposed. Results of those studies
indicated a wide range of judgments on
what study participants considered to
be acceptable visibility across the
different study areas, depending on the
setting depicted in each photograph. As
a part of the 2010 UFVA, each study
was evaluated separately, and figures
were developed to display the
percentage of participants that rated the
visual air quality depicted as
‘‘acceptable’’ (U.S. EPA, 2010b). Based
on the results of the studies in the four
cities, a range encompassing the PM2.5
visibility index values from images that
were judged to be acceptable by at least
50% of study participants across all four
of the urban preference studies was
identified (U.S. EPA, 2010b, p. 4–24;
PA, Figure 5–2). Much lower visibility
(considerably more haze resulting in
higher values of light extinction) was
considered acceptable in Washington,
DC, than was in Denver, and 30 dv
reflected the highest degree of visibility
impairment judged to be acceptable by
at least 50 percent of study participants
(78 FR 3226–3227, January 15, 2013).
Since the time of the last review, no
new visibility preference studies have
been conducted in the U.S. Similarly,
there is little newly available
information regarding acceptable levels
of visibility impairment in the U.S.
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C. Other PM-Related Welfare Effects
The information summarized here is
based on the EPA’s scientific assessment
of the latest evidence on the nonvisibility welfare effects associated with
PM. This assessment is documented in
the ISA and its policy implications are
further discussed in the PA. In
considering the scientific and technical
information, the PA reflects
consideration of both the information
available in the last review and
information that is newly available
since the last review. The subsections
54 Preference
studies were available in four urban
areas in the last review: Denver, Colorado (Ely et
al., 1991), Vancouver, British Columbia, Canada
(Pryor, 1996), Phoenix, Arizona (BBC Research &
Consulting, 2003), and Washington, DC (Abt
Associates, 2001; Smith and Howell, 2009).
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below briefly summarize the evidence
related to climate effects (section IV.C.1)
and materials effects (section IV.C.2).
1. Climate
In this review, as in the last review,
the ISA concludes that ‘‘overall the
evidence is sufficient to conclude that a
causal relationship exists between PM
and climate effects’’ (U.S. EPA, 2019,
section 13.3.9). Since the last review,
climate impacts have been extensively
studied and recent research reinforces
and strengthens the evidence evaluated
in the 2009 ISA. New evidence provides
greater specificity about the details of
radiative forcing effects 55 and increases
the understanding of additional climate
impacts driven by PM radiative effects.
The Intergovernmental Panel on Climate
Change (IPCC) assesses the role of
anthropogenic activity in past and
future climate change, and since the last
review, has issued the Fifth IPCC
Assessment Report (AR5; IPCC, 2013)
which summarizes any key scientific
advances in understanding the climate
effects of PM since the previous report.
As in the last review, the ISA draws
substantially on the IPCC report to
summarize climate effects. As discussed
in more detail below, the general
conclusions are similar between the
IPCC AR4 and AR5 reports with regard
to effects of PM on global climate.
Atmospheric PM has the potential to
affect climate in multiple ways,
including absorbing and scattering of
incoming solar radiation, alterations in
terrestrial radiation, effects on the
hydrological cycle, and changes in
cloud properties (U.S. EPA, 2019,
section 13.3.1). Atmospheric PM
interacts with incoming solar radiation.
Many species of PM (e.g., sulfate and
nitrate) efficiently scatter solar energy.
By enhancing reflection of solar energy
back to space, scattering PM exerts a
cooling effects on the surface below.
Certain species of PM such as black
carbon (BC), brown carbon (BrC), or
dust can also absorb incoming sunlight.
A recent study found that whether
absorbing PM warms or cools the
underlying surface depends on several
factors, including the altitude of the PM
55 Radiative forcing (RF) for a given atmospheric
constituent is defined as the perturbation in net
radiative flux, at the tropopause (or the top of the
atmosphere) caused by that constituent, in watts per
square meter (Wm–2), after allowing for
temperatures in the stratosphere to adjust to the
perturbation but holding all other climate responses
constant, including surface and tropospheric
temperatures (Fiore et al., 2015; Myhre et al., 2013).
A positive forcing indicates net energy trapped in
the Earth system and suggests warming of the
Earth’s surface, whereas a negative forcing indicates
net loss of energy and suggests cooling (U.S. EPA,
2019, section 13.3.2.2).
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layer relative to cloud cover and the
albedo (i.e., reflectance) of the surface
(Ban-Weiss et al., 2014). PM also
perturbs incoming solar radiation by
influencing cloud cover and cloud
lifetime. For example, PM provides
nuclei upon which water vapor
condenses, forming cloud droplets.
Finally, absorbing PM deposited on
snow and ice can diminish surface
albedo and lead to regional warming
(U.S. EPA, 2019, section 13.3.2).
PM has direct and indirect effects on
climate processes. PM interactions with
solar radiation through scattering and
absorption, collectively referred to as
aerosol-radiation interactions (ARI), are
also known as the direct effects on
climate, as opposed to the indirect
effects that involve aerosol-cloud
interactions (ACI). The direct effects of
PM on climate result primarily from
particles scattering light away from
Earth and sending a fraction of solar
energy back into space, decreasing the
transmission of visible radiation to the
surface of the Earth and resulting in a
decrease in the heating rate of the
surface and the lower atmosphere. The
IPCC AR5, taking into account both
model simulations and satellite
observations, reports a radiative forcing
from aerosol-radiation interactions
(RFari) from anthropogenic PM of
¥0.35 ± 0.5 watts per square meter
(Wm¥2) (Boucher, 2013), which is
comparable to AR4 (¥0.5 ± 0.4 Wm¥2).
Estimates of effective radiative forcing 56
from aerosol-radiation interactions
(ERFari), which include the rapid
feedback effects of temperature and
cloud cover, rely mainly on model
simulations, as this forcing is complex
and difficult to observe (U.S. EPA, 2019,
section 13.3.4.1). The IPCC AR5 best
estimate for ERFari is ¥0.45 ± 0.5
Wm¥2, which reflects this uncertainty
(Boucher, 2013).
By providing cloud condensation
nuclei, PM increases cloud droplet
number, thereby increasing cloud
droplet surface area and albedo
(Twomey, 1977). The climate effects of
these perturbations are more difficult to
quantify than the direct effects of
aerosols with RF but likely enhance the
cooling influence of clouds by
increasing cloud reflectivity
(traditionally referred to as the first
indirect effect) and lengthening cloud
lifetime (second indirect effect). These
effects are reported as the radiative
56 Effective radiative forcing (ERF), new in the
IPCC AR5, takes into account not just the
instantaneous forcing but also a set of climate
feedbacks, involving atmospheric temperature,
cloud cover, and water vapor, that occur naturally
in response to the initial radiative perturbation
(U.S. EPA, 2019, section 13.3.2.2).
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forcing from aerosol-cloud interaction
(ERFaci) (U.S. EPA, 2019, section
13.3.3.2).57 IPCC AR5 estimates ERFaci
at ¥0.45 Wm¥2, with a 90% confidence
interval of ¥1.2 to 0 Wm¥2 (U.S. EPA,
2019, section 13.3.4.2). Studies have
also calculated the combined effective
radiative forcing from aerosol-radiation
and aerosol-cloud interactions
(ERFari+aci) (U.S. EPA, 2019, section
13.3.4.3). IPCC AR5 reports a best
estimate of ERFari+aci of ¥0.90 (¥1.9
to ¥0.1) Wm¥2, consistent with these
estimates (Boucher, 2013).
PM can also strongly reflect incoming
solar radiation in areas of high albedo,
such as snow- and ice-covered surfaces.
The transport and subsequent
deposition of absorbing PM such as BC
to snow- and ice-covered regions can
decrease the local surface albedo,
leading to surface heating. The absorbed
energy can then melt the snow and ice
cover and further depress the albedo,
resulting in a positive feedback loop
(U.S. EPA, 2019, section 13.3.3.3; Bond
et al., 2013; U.S. EPA, 2012b).
Deposition of absorbing PM, such as BC,
may also affect surface temperatures
over glacial regions (U.S. EPA, 2019,
section 13.3.3.3). The IPCC AR5 best
estimate of RF from the albedo effects is
+0.04 Wm¥2, with an uncertainty range
of +0.02 to +0.09 Wm¥2 (Boucher,
2013).
A number of new studies are available
since the last review that have exampled
the individual climate effects associated
with key PM components, including
sulfate, nitrate, OC, BC, and dust, along
with updated quantitative estimate of
the radiative forcing with the individual
species. Sulfate particles form through
oxidation of SO2 by OH in the gas phase
and in the aqueous phase by a number
of pathways, including in particular
those involving ozone and H2O2 (U.S.
EPA, 2019, section 13.3.5.1). The main
source of anthropogenic sulfate is from
coal-fired power plants, and global
trends in the anthropogenic SO2
emissions are estimated to have
increased dramatically during the 20th
and early 21st centuries, although the
recent implementation of more stringent
air pollution controls on sources has led
to a reversal in such trends in many
places (U.S. EPA, 2019, section 13.3.5.1;
U.S. EPA, 2020, section 2.3.1). Sulfate
particles are highly reflective.
Consistent with other recent estimates
(Takemura, 2012, Zelinka et al., 2014,
Adams et al., 2001, described below), on
57 While the ISA includes estimates of RFaci and
ERFaci from a number of studies (U.S. EPA, 2019,
sections 13.3.4.2, 13.3.4.3, 13.3.3.3), this discussion
focuses on the single best estimate with a range of
uncertainty, as reported in the IPCC AR5 (Boucher,
2013).
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a global scale, the IPCC AR5 estimates
that sulfate contributes more than other
PM types to RF, with RFari of ¥0.4
(¥0.6 to ¥0.2) Wm¥2, where the 5%
and 95% uncertainty range is
represented by the numbers in the
parentheses (Myhre et al., 2013), which
is the same estimate from AR4. Sulfate
is also a major contributor to the
influence of PM on clouds (Takemura,
2012). A total effective radiative forcing
(ERFari+aci) for anthropogenic sulfate
has been estimated to be nearly ¥1.0
Wm¥2 (Zelinka et al., 2014, Adams et
al., 2001).
Nitrate particles form through the
oxidation of nitrogen oxides and occur
mainly in the form of ammonium
nitrate. Ammonium preferentially
associates with sulfate rather than
nitrate, leading to formation of
ammonium sulfate at the expense of
ammonium nitrate (Adams et al., 2001).
As anthropogenic emissions of SO2
decline, more ammonium will be
available to react with nitrate,
potentially leading to future increases in
ammonium nitrate particles in the
atmosphere (U.S. EPA, 2019, section
13.3.5.2; Hauglustaine et al., 2014; Lee
et al., 2013; Shindell et al., 2013).
Warmer global temperatures, however,
may decrease nitrate abundance given
that it is highly volatile at higher
temperatures (Tai et al., 2010). The IPCC
AR5 estimates RFari of nitrate of ¥0.11
(¥0.3 to ¥0.03) Wm¥2 (Boucher, 2013),
which is one-fourth of the RFari of
sulfate.
Primary organic carbonaceous PM,
including BrC, are emitted from
wildfires, agricultural fires, and fossil
fuel and biofuel combustion. SOA form
when anthropogenic or biogenic
nonmethane hydrocarbons are oxidized
in the atmosphere, leading to less
volatile products that may partition into
PM (U.S. EPA, 2019, section 13.3.5.3).
Organic particles are generally
reflective, but in the case of BrC, a
portion is significantly absorbing at
shorter wavelengths (<400 nm). The
IPCC AR5 estimates an RFari for
primary organic PM from fossil fuel
combustion and biofuel use of ¥0.09
(¥0.16 to ¥0.03) Wm¥2 and an RFari
estimate for SOA from these sources of
¥0.03 (¥0.27 to +0.20) Wm¥2 (Myhre
et al., 2013). Changes in the RFari
estimates for individual PM components
since AR4 have generally been modest,
with one exception for the estimate for
primary organic PM from fossil fuel
combustion and biofuel use (Myhre et
al., 2013).58 The wide range in these
estimates, including inconsistent signs
58 The estimate of RFari for SOA is new in AR5
and was not included in AR4 (Myhre et al., 2013).
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for forcing, reflect uncertainties in the
optical properties of organic PM and its
atmospheric budgets, including the
production pathways of anthropogenic
SOA (Scott et al., 2014; Myhre et al.,
2013; McNeill et al., 2012; Heald et al.,
2010). The IPCC AR5 also estimates an
RFari of ¥0.2 Wm¥2 for primary
organic PM arising from biomass
burning (Boucher, 2013).
Black carbon (BC) particles occur as a
result of inefficient combustion of
carbon-containing fuels. Like directly
emitted organic PM, BC is emitted from
biofuel and fossil fuel combustion and
by biomass burning. BC is absorbing at
all wavelengths and likely has a large
impact on the Earth’s energy budget
(Bond et al., 2013). The IPCC AR5
estimates a RFari from anthropogenic
fossil fuel and biofuel use of +0.4 (+0.5
to +0.8) Wm¥2 (Myhre et al., 2013).
Biomass burning contributes an
additional +0.2 (+0.03 to +0.4) Wm¥2 to
BC RFari, while the albedo effect of BC
on snow and ice adds another +0.04
(+0.02 to +0.09) Wm¥2 (Myhre et al.,
2013; U.S. EPA, 2019, section 13.3.5.4,
section 13.3.4.4).
Dust, or mineral dust, is mobilized
from dry or disturbed soils as a result
of both meteorological and
anthropogenic activities. Dust has
traditionally been classified as
scattering, but a recent study found that
dust may be substantially coarser than
currently represented in climate models,
and thus more light-absorbing (Kok et
al., 2017). The IPCC AR5 estimates
RFari as ¥0.1 ± 0.2 Wm¥2 (Boucher,
2013), although the results of the study
by Kok et al. (2017) would suggest that
in some regions dust may have led to
warming, not cooling (U.S. EPA, 2019,
section 13.3.5.5).
The new research available in this
review expands upon the evidence
available at the time of the last review.
Consistent with the evidence available
in the last review, the key PM
components, including sulfate, nitrate,
OC, BC, and dust, that contribute to
climate processes vary in their
reflectivity, forcing efficiencies, and
direction of forcing.
Radiative forcing due to PM elicits a
number of responses in the climate
system that can lead to significant
effects on weather and climate over a
range of spatial and temporal scales,
mediated by a number of feedbacks that
link PM and climate. Since the last
review, the evidence base has expanded
with respect to the mechanisms of
climate responses and feedbacks to PM
radiative forcing. However, the new
literature published since the last
review does not reduce the considerable
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uncertainties that continue to exist
related to these mechanisms.
Unlike well-mixed, long-lived
greenhouse gases in the atmosphere, PM
has a very heterogenous distribution
across the Earth. As such, patterns of
RFari and RFaci tend to correlate with
PM loading, with the greatest forcings
centralized over continental regions.
The climate response to this PM forcing,
however, is more complicated since the
perturbation to one climate variable
(e.g., temperature, cloud cover,
precipitation) can lead to a cascade of
effects on other variables. While the
initial PM radiative forcing may be
concentrated regionally, the eventual
climate response can be much broader
spatially or be concentrated in remote
regions, and may be quite complex,
affecting multiple climate variables with
possible differences in the sign of the
response in different regions or for
different variables (U.S. EPA, 2019,
section 13.3.6). The complex climate
system interactions lead to variation
among climate models, with some
studies showing relatively close
correlation between forcing and surface
response temperatures (e.g.,
Leibensperger et al., 2012), while other
studies show much less correlation (e.g.,
Levy et al., 2013). Many studies have
examined observed trends in PM and
temperature in the U.S. Climate models
have suggested a range of factors which
can influence large-scale meteorological
processes and may affect temperature,
including local feedback effects
involving soil moisture and cloud cover,
changes in the hygroscopicity of the PM,
and interactions with clouds alone (U.S.
EPA, 2019, section 13.3.7). While
evidence in this review suggests that PM
influenced temperature trends across
the southern and eastern U.S. in the
20th century, this evidence is not
conclusive and significant uncertainties
continue to exist. Further research is
needed to better characterize the effects
of PM on regional climate in the U.S.
before PM climate effects can be
quantified.
While expanded since the last review,
the evidence of PM-related climate
effects is still limited by significant
uncertainties, particularly for
understanding effects at regional scales.
Large spatial and temporal
heterogeneities in direct and indirect
PM radiative forcing, and associated
climate effects, can occur for a number
of reasons, including the frequency and
distribution of emissions of key PM
components contributing to climate
forcing, the chemical and microphysical
processing that occurs in the
atmosphere, and the atmospheric
lifetime of PM relative to other
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pollutants contributing to radiative
forcing (U.S. EPA, 2019, section 13.3).
In addition to the uncertainty in
characterizing radiative forcing, large
uncertainty exists in quantifying
changes in specific climate variables
associated with PM-related radiative
forcing. Moreover, studies have shown
that predicting climate variables for
regions within the U.S. (which is of
particular interest for the review of the
PM NAAQS) is more uncertain than
predicting climate variables globally
due to natural climate variability (e.g.,
Deser et al., 2012) and uncertainties in
the representation of key atmospheric
processes in state-of-the-art climate
models. Furthermore, quantifying the
influence of incremental changes in U.S.
anthropogenic emissions on regional
climate is subject to even greater
uncertainty because the signal of U.S.
anthropogenic emissions is relatively
small compared with the global
emissions considered in the studies
cited above. Overall, these limitations
and uncertainties make it difficult to
quantify how incremental changes in
the level of PM mass in ambient air in
the U.S. would result in changes to
climate in the U.S. Thus, as in the last
review, the PA concludes that the data
remain insufficient to conduct
quantitative analyses for PM effects on
climate in the current review (U.S. EPA,
2020, section 5.2.2.2.1).
2. Materials
In considering the evidence available
in the current review of PM-related
materials effects, the current evidence
continues to support the conclusion
from the last review that there is a
causal relationship between PM
deposition and materials effects. Effects
of deposited PM, particularly sulfates
and nitrates, to materials include both
physical damage and impaired aesthetic
qualities. Because of their electrolytic,
hygroscopic, and acidic properties and
their ability to sorb corrosive gases,
particles contribute to materials damage
by adding to the effects of natural
weathering processes, by potentially
promoting or accelerating the corrosion
of metals, degradation of painted
surfaces, deterioration of building
materials, and weakening of material
components.59 The newly available
evidence on materials effects of PM in
59 As discussed in the ISA (U.S. EPA, 2019,
section 13.4.1), corrosion typically involves
reactions of acidic PM (i.e., acidic sulfate or nitrate)
with material surfaces, but gases like SO2 and nitric
acid (HNO3) also contribute. Because ‘‘the impacts
of gaseous and particulate N and S wet deposition
cannot be clearly distinguished’’ (U.S. EPA, 2019,
p. 13–1), the assessment of the evidence in the ISA
considers the combined impacts.
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this review are primarily from studies
conducted outside of the U.S. on
buildings and other items of cultural
heritage and at concentrations greater
than those typically observed in the
U.S.; however, they provide limited new
data for consideration in this review
(U.S. EPA, 2019, section 13.4).
Materials damage from PM generally
involves one or both of two processes:
soiling and corrosion (U.S. EPA, 2019,
section 13.4.2). Soiling and corrosion
are complex, interdependent processes,
typically beginning with deposition of
atmospheric PM or SO2 to exposed
surfaces. Constituents of deposited PM
can interact directly with materials or
undergo further chemical and/or
physical transformation to cause soiling,
corrosion, and physical damage.
Weathering, including exposure to
moisture, ultraviolet (UV) radiation and
temperature fluctuations, affects the rate
and degree of damage (U.S. EPA, 2019,
section 13.4.2).
Soiling is the result of PM
accumulation on an object that alters its
optical characteristics or appearance.
These soiling effects can impact the
aesthetic value of a structure or result in
reversible or irreversible damage to the
surface. The presence of air pollution
can increase the frequency and duration
of cleaning and can enhance
biodeterioration processes on the
surface of materials. For example,
deposition of carbonaceous components
of PM can lead to the formation of black
crusts on surfaces, and the buildup of
microbial biofilms 60 can discolor
surfaces by trapping PM more efficiently
(U.S. EPA, 2009c, p. 9–195; U.S. EPA,
2019, section 13.4.2). The presence of
PM may alter light transmission or
change the reflectivity of a surface.
Additionally, the organic and nutrient
content of deposited PM may enhance
microbial growth on surfaces.
Since the last review, very little new
evidence has become available related
to deposition of SO2 to materials such
as limestone, granite, and metal.
Deposition of SO2 onto limestone can
transform the limestone into gypsum,
resulting in a rougher surface, which
allows for increased surface area for
accumulation of deposited PM (Camuffo
and Bernardi, 1993; U.S. EPA, 2019,
section 13.4.2). Oxidation of deposited
SO2 that contributes to the
transformation of limestone to gypsum
can be enhanced by the formation of
surface coatings from deposited
60 Microbial biofilms are communities of
microorganisms, which may include bacteria, algae,
fungi and lichens, that colonize an inert surface.
Microbial biofilms can contribute to
biodeterioration of materials via modification of the
chemical environment.
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carbonaceous PM (both elemental and
organic carbon) (McAlister et al., 2008,
Grossi et al., 2007). Ozga et al. (2011)
characterized damage to two concrete
buildings in Poland and Italy. Gypsum
was the main damage product on
surfaces of these buildings that were
sheltered from rain runoff, while PM
embedded in the concrete, particularly
carbonaceous particles, were
responsible for darkening of the
building walls (Ozga et al., 2011).
Building on the evidence available in
the 2009 ISA, research has progressed
on the theoretical understanding of
soiling of cultural heritage in a number
of studies. Barca et al. (2010) developed
and tested a new methodological
approach for characterizing trace
elements and heavy metals in black
crusts on stone monuments to identify
the origin of the chemicals and the
relationship between the concentrations
of elements in the black crusts and local
environmental conditions. Recent
research has also used isotope tracers to
distinguish between contributions from
local sources versus atmospheric
pollution to black crusts on historical
monuments in France (Kloppmann et
al., 2011). A study in Portugal found
that biological activity played a major
role in soiling, specifically in the
development of colored layers and in
the detachment process (de Oliveira et
al., 2011). Another study found damage
to cement renders, often used for
restoration, consolidation, and
decorative purposes on buildings,
following exposure to sulfuric acid,
resulting in the formation of gypsum
(Lanzon and Garcia-Ruiz, 2010).
Corrosion of stone and the decay of
stone building materials by acid
deposition and sulfate salts were
described in the 2009 ISA (U.S. EPA,
2009c, section 9.5.3). Since that time,
advances have been made on the
quantification of degradation rates and
further characterization of the factors
that influence damage of stone materials
(U.S. EPA, 2019, section 13.4.2). Decay
rates of marble grave stones were found
to be greater in heavily polluted areas
compared to a relatively pristine area
(Mooers et al., 2016). The time of
wetness and the number of dissolution/
crystallization cycles were identified as
hazard indicators for stone materials,
with greater hazard during the spring
and fall when these indicators are
relatively high (Casati et al., 2015).
A study examining the corrosion of
steel as a function of PM composition
and particle size found that changes in
the composition of resulting rust
gradually changed with particle size
(Lau et al., 2008). In a study of damage
to metal materials under in Hong Kong,
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which generally has much higher PM
concentrations than those observed in
the U.S., Liu et al. (2015) found that iron
and steel were corroded by both PM and
gaseous pollutants (SO2 and NO2), while
copper and copper alloys were mainly
corroded by gaseous pollutants (SO2 and
O3) and aluminum and aluminum alloy
corrosion was mainly attributed to PM
and NO2.
A number of studies have also found
materials damage from PM components
besides sulfate and black carbon and
atmospheric gases besides SO2. Studies
have characterized impacts of nitrates,
NOX, and organic compounds on direct
materials damage or on chemical
reactions that enhance materials damage
(U.S. EPA, 2019, section 13.4.2). Other
studies have found that soiling of
building materials can be attributed to
enhanced biological processes and
colonization, including the
development and thickening of biofilms,
resulting from the deposition of PM
components and atmospheric gases
(U.S. EPA, 2019, section 13.4.2).
Since the last review, other materials
have been studied for damage
attributable to PM, including glass and
photovoltaic panels. Soiling of glass can
impact its optical and thermal
properties and can lead to increased
cleaning costs and frequency. The
development of haze 61 on modern glass
has been measured and modeled, with
a strong correlation between the size
distribution of particles and the
evolution of the mass deposited on the
surface of the glass. Measurements
showed that, under sheltered
conditions, mass deposition accelerated
regularly with time in areas closest to
sources of PM (i.e., near roadways) and
coarse mineral particles were more
prevalent compared to other sites
(Alfaro et al., 2012). Model predictions
were found to correctly simulate the
development of haze at site locations
when compared with measurements
(Alfaro et al., 2012).
Soiling of photovoltaic panels can
lead to decreased energy efficiency. For
example, soiling by carbonaceous PM
decreased solar efficiency by nearly
38%, while soil particles reduced
efficiency by almost 70% (Radonjic et
al., 2017). The rate of photovoltaic
power output can also be degraded by
soiling and has been found to be related
61 In this discussion of non-visibility welfare
effects, haze is used as it has been defined in the
scientific literature on soiling of glass, i.e., the ratio
of diffuse transmitted light to direct transmitted
light (Lombardo et al., 2010). This differs from the
definition of haze as used in the discussion of
visibility welfare effects in section V.B above,
where it is used as a qualitative description of the
blockage of sunlight by dust, smoke, and pollution.
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to the rate of dust accumulation. In five
sites in the U.S. representing different
meteorological and climatological
conditions,62 photovoltaic module
power transmission was reduced by
approximately 3% for every g/m2 of PM
deposited on the cover plate of the
photovoltaic panel, independent of
geographical location (Boyle et al.,
2017). Another study found that
photovoltaic module power output was
reduced by 40% after 10 months of
exposure without cleaning, although a
number of anti-reflective coatings can
generally mitigate power reduction
resulting from dust deposition (Walwil
et al., 2017). Energy efficiency can also
be impacted by the soiling of building
materials, such as light-colored marble
panels on building exteriors, that are
used to reflect a large portion of solar
radiation for passive cooling and to
counter the urban heat island effect.
Exposure to acidic pollutants in urban
environments have been found to
reduce the solar reflectance of marble,
decreasing the cooling effect (Rosso et
al., 2016). Highly reflective roofs, or
cool roofs, have been designed and
constructed to increase reflectance from
buildings in urban areas, to both
decrease air conditioning needs and
urban heat island effects, but these
efforts can be impeded by soiling of
materials used for constructing cool
roofs. Methods have been developed for
accelerating the aging process of roofing
materials to better characterize the
impact of soiling and natural weather on
materials used in constructing cool roofs
(Sleiman et al., 2014).
Some progress has been made since
the last review in the development of
dose-response relationships for soiling
of building materials, yet some key
relationships remain poorly
characterized. The first general doseresponse relationships for soiling of
materials were generated by measuring
contrast reflectance of a soiled surface to
the reflectance of the unsoiled substrate
for different materials, including acrylic
house paint, cedar siding, concrete,
brick, limestone, asphalt shingles, and
window glass with varying total
suspended particulate (TSP)
concentrations (Beloin and Haynie,
1975; U.S. EPA, 2019, section 13.4.3).
Continued efforts to develop doseresponse curves for soiling have led to
some advancements for modern
materials, but these relationships
62 Of the five sites studied, three were in rural,
suburban, and urban areas representing a semi-arid
environment (Front Range of Colorado), one site
represented a hot and humid environment (Cocoa,
Florida), and one represented a hot and arid
environment (Albuquerque, New Mexico) (U.S.
EPA, 2019, section 13.4.2; Boyle et al., 2017).
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remain poorly characterized for
limestone. One study quantified the
dose-response relationships between
PM10 and soiling for painted steel, white
plastic, and polycarbonate filter
material, but there was too much scatter
in the data to produce a dose-response
relationship for limestone (Watt et al.,
2008). A dose-response relationship for
silica-soda-lime window glass soiling by
PM10, NO2, and SO2 was quantified
based on 31 different locations
(Lombardo et al., 2010; U.S. EPA, 2019,
section 13.4.3, Figure 13–32, Equation
13–8). The development of this doseresponse relationship required several
years of observation time and had
inconsistent data reporting across the
locations.
Since the time of the last review, there
has also been progress in developing
methods to more rapidly evaluate
soiling of different materials by PM
mixtures. Modern buildings typically
have simpler lines, less detailed
surfaces, and a greater use of glass, tile,
and metal, which are easier to clean
than stone. There have also been major
changes in the types of materials used
for buildings, including a variety of
polymers available for use as coatings
and sealants. New economic and
environmental considerations beyond
aesthetic appeal and structural damage
are emerging (U.S. EPA, 2019, section
13.4.3). Changes in building materials
and design, coupled with new
approaches in quantifying the doseresponse relationship between PM and
materials effects, may reduce the
amount of time needed for observations
to support the development of materialspecific dose-response relationships.
In addition to dose-response
functions, damage functions have also
been used to quantify material decay as
a function of pollutant type and load.
Damage can be determined from sample
surveys or inspection of actual damage
and a damage function can be
developed to link the rate of material
damage to time of replacement or
maintenance. A cost function can then
link the time for replacement and
maintenance to a monetary cost, and an
economic function links cost to the dose
of pollution based on the dose-response
relationship (U.S. EPA, 2019, section
13.4.3). Damage functions are difficult
to assess because it depends on human
perception of the level of soiling
deemed to be acceptable and evidence
in this area remains limited in the
current review. Since the last review,
damage functions for a wide range of
building materials (i.e., stone,
aluminum, zinc, copper, plastic, paint,
rubber, stone) have been developed and
reviewed (Brimblecombe and Grossi,
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2010). One study estimated long-term
deterioration of building materials and
found that damage to durable building
material (such as limestone, iron,
copper, and discoloration of stone) is no
longer controlled by pollution as was
historically documented but rather that
natural weathering is a more important
influence on these materials in modern
times (Brimblecombe and Grossi, 2009).
Even as PM-attributable damage to stone
and metals has decreased over time, it
has been predicted that there will be
potentially higher degradation rates for
polymeric materials, plastic, paint, and
rubber due to increased oxidant
concentrations and solar radiation
(Brimblecombe and Grossi, 2009).
As at the time of the last review and
described just above, sufficient evidence
is not available to conduct a quantitative
assessment of PM mass or componentrelated soiling and corrosion effects.
While soiling associated with PM can
lead to increased cleaning frequency
and repainting of surfaces, no
quantitative relationships have been
established between characteristics of
PM or the frequency of cleaning or
repainting that would help to inform the
EPA’s understanding of the public
welfare implications of soiling (U.S.
EPA, 2019, section 13.4). Similarly,
while some information is available
with regard to microbial deterioration of
surfaces and the contribution of
carbonaceous PM to the formation of
black crusts that contribute to soiling,
the available evidence does not support
quantitative analyses (U.S. EPA, 2019,
section 13.4). While some new evidence
is available with respect to PMattributable materials effects, the data
are insufficient to conduct quantitative
analyses for PM effects on materials in
the current review.
D. Proposed Conclusions on the Current
Secondary PM Standards
In reaching proposed conclusions on
the current secondary PM standards, the
Administrator takes into account policyrelevant evidence-based and
quantitative information-based
considerations, as well as advice from
the CASAC. Evidence-based
considerations draw from the EPA’s
assessment and integrated synthesis of
the scientific evidence of PM-related
welfare effects in the ISA (U.S. EPA,
2019, section 13.2). Quantitative
information-based considerations draw
from the EPA’s assessment of recent air
quality and associated PM-related
visibility impairment in the PA (U.S.
EPA, 2020, Chapter 5). Section IV.D.1
below summarizes evidence- and
quantitative information-based
considerations and the associated
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conclusions reached in the PA. Section
IV.D.2 describes advice received from
the CASAC on the secondary standards.
Section IV.D.3 presents the
Administrator’s proposed decision on
the current secondary PM standards.
1. Evidence- and Quantitative
Information-Based Considerations in the
Policy Assessment
The PA considers the degree to which
the available scientific evidence and
quantitative information supports or
calls into question the adequacy of the
protection afforded by the current
secondary PM standards. In doing so,
the PA considers the evidence assessed
in the ISA, including the extent to
which the new evidence for PM-related
visibility impairment, climate effects, or
materials effects alters key conclusions
from the last review. The PA also
considers quantitative analyses of
visibility impairment and the extent to
which they may indicate different
conclusions from those in the last
review regarding the degree of
protection from adverse effects provided
by the current secondary standards.
With regard to visibility impairment,
the PA presents updated analyses based
on recent air quality information, with
a focus on locations meeting the current
24-hour PM2.5 and PM10 standards. In
the absence of advances in the
monitoring methods for directly
measuring light extinction, and given
the lack of a robust monitoring network
for the routine measurement of light
extinction across the U.S. (section
IV.B.2), as in the last review, the PA
analyses use calculated light extinction
to estimate PM-related visibility
impairment (U.S. EPA, 2020, section
5.2.1.1). Compared to the last review,
updated analyses incorporate several
refinements. These include (1) the
evaluation of three versions of the
IMPROVE equation 63 to calculate light
extinction (U.S. EPA, 2020, Appendix
D, Equations D–1 through D–3) in order
to better understand the influence of
variability in equation inputs; 64 (2) the
63 Given the lack of new information to inform a
different visibility metric, the metric used in the PA
is that defined by the EPA in the last review as the
target level of protection for visibility (discussed
above in section IV.A.1): A PM2.5 visibility index
with a 24-hour averaging time, a 90th percentile
form averaged over 3 year, and a level of 30 dv (U.S.
EPA, 2020, section 5.2.1.2).
64 While the PM
2.5 monitoring network has an
increasing number of continuous FEM monitors
reporting hourly PM2.5 mass concentrations, there
continue to be data quality uncertainties associated
with providing hourly PM2.5 mass and component
measurements that could be input into IMPROVE
equation calculations for sub-daily visibility
impairment estimates. Therefore, the inputs to these
light extinction calculations are based on 24-hour
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use of 24-hour relative humidity data,
rather than monthly average relative
humidity as was used in the last review
(U.S. EPA, 2020, section 5.2.1.2,
Appendix D); and (3) the inclusion of
the coarse fraction in the estimation of
light extinction in the subset of areas
with PM10-2.5 monitoring data available
for the time period of interest (U.S. EPA,
2020, section 5.2.1.2, Appendix D). The
PA’s updated analyses include 67
monitoring sites that measure PM2.5,
including 20 sites that measure both
PM10 and PM2.5, that are geographically
distributed across the U.S. in both urban
and rural areas (U.S. EPA, 2020,
Appendix D, Figure D–1).65
In areas that meet the current 24-hour
PM2.5 standard for the 2015–2017 time
period, all sites have light extinction
estimates at or below 27 dv using the
original and revised IMPROVE
equations (and most areas are below 25
dv; U.S. EPA, 2020, section 5.2.1.2). In
addition, the one location that exceeds
the current 24-hour PM2.5 standard also
has light extinction estimates at or
below 27 dv (U.S. EPA, 2020, Figure 53). These findings are consistent with
the findings of the analysis in the last
review with older air quality data from
102 sites (Kelly et al., 2012b; 78 FR
3201, January 15, 2013).
When light extinction is calculated
using the updated IMPROVE equation
from Lowenthal and Kumar (2016), the
resulting 3-year visibility metrics are
slightly higher at all sites compared to
light extinction calculated using the
IMPROVE equations used in previous
reviews (U.S. EPA, 2020, Figure 5-4).
These results are consistent with the
higher OC multiplier included in the
IMPROVE equation from Lowenthal and
Kumar (2016), reflecting the use of data
from remote areas with higher
concentrations of organic PM when
validating that equation. As such, it is
important to note that the Lowenthal
and Kumar (2016) version of the
IMPROVE equation may overestimate
light extinction in non-remote areas,
including in the urban areas in the PA’s
analyses.
Nevertheless, when light extinction is
calculated using the Lowenthal and
Kumar (2016) equation for those sites
that meet the current 24-hour PM2.5
standard, the 3-year visibility metric is
average measurements of PM2.5 mass and
components, rather than sub-daily information.
65 These sites are those that have a valid 24-hour
PM2.5 design value for the 2015–2017 period and
met strict criteria for PM species for this analysis,
based on 24-hour average PM2.5 mass and
component data that were available from monitors
in the IMPROVE network, CSN, and NCore
Multipollutant Monitoring Network (U.S. EPA,
2020, Appendix D). PM10-2.5 monitoring data is
available for 20 of the 67 sites examined.
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generally at or below 30 dv. The one
exception to this is a site in Fairbanks,
Alaska that just meets the current 24hour PM2.5 standard in 2015–17 and has
a 3-year visibility index value just above
30 dv, rounding to 31 dv (compared to
27 dv when light extinction is
calculated with the original and revised
IMPROVE equations) (U.S. EPA, 2020,
Appendix D, Table D–3). However, the
unique conditions at this urban site
(e.g., higher OC concentrations, much
lower temperatures, and the complete
lack of sunlight for long periods) affect
quantitative relationships between OC,
OM and visibility (e.g., Hand et al.,
2012; Hand et al., 2013), making the
most appropriate approach for
characterizing light extinction in this
area unclear.
In the last review, the EPA noted that
PM2.5 is the size fraction of PM
responsible for most of the visibility
impairment in urban areas (77 FR
38980, June 29, 2012). Data available at
the time of the last review suggested
that PM10-2.5 is often a minor contributor
to visibility impairment (U.S. EPA,
2010b), though it may make a larger
contribution in some areas in the desert
southwestern region of the U.S.
However, at the time of the last review,
there was little data available from
PM10-2.5 monitors to quantify the
contribution of coarse PM to calculated
light extinction.
Since the last review, an expansion of
PM10-2.5 monitoring efforts has increased
the availability of data for use in
estimating light extinction with both
PM2.5 and PM10-2.5 concentrations
included as inputs in the equations. For
2015–2017, 20 of the 67 PM2.5 sites
analyzed in the PA have collocated
PM10-2.5 monitoring data available.
These 20 sites meet both the 24-hour
PM2.5 standard and 24-hour PM10
standard. All of these sites have 3-year
visibility metrics at or below 30 dv
regardless of whether light extinction is
calculated with or without the coarse
fraction, and for all three versions of the
IMPROVE equation. Generally, the
contribution of the coarse fraction to
light extinction at these sites is minimal,
contributing less than 1 dv to the 3-year
visibility metric. However, these 20
locations would be expected to have
relatively low concentrations of coarse
PM. If PM10 and PM10-2.5 data were
available in locations with higher
concentrations of coarse PM, such as in
the southwestern U.S., the coarse
fraction may be a more important
contributor to light extinction and
visibility impairment than in the
locations examined in the PA analyses.
In summary, the findings of these
updated quantitative analyses are
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consistent with those in the last review.
The 3-year visibility metric is generally
at or below 27 dv in areas that meet the
current secondary standards, with only
small differences observed for the three
versions of the IMPROVE equation.
Though such differences are modest, the
IMPROVE equation from Lowenthal and
Kumar (2016) always results in higher
light extinction values, which is
expected given the higher OC multiplier
included in the equation and its
validation using data from remote areas
far away from emissions sources. There
is very little difference in estimates of
light extinction when PM10-2.5 is
included in the equation, although a
somewhat larger coarse fraction
contribution to light extinction would
be expected in areas with higher coarse
particle concentrations. Overall, the PA
finds that updated quantitative analyses
indicate that the current secondary PM
standards provide a degree of protection
against visibility impairment similar to
the target level of protection identified
in the last review, defined in terms of
a PM visibility index.
With regard to PM-related climate
effects, the PA recognizes that while the
evidence base has expanded since the
last review, the new evidence has not
appreciably improved the
understanding of the spatial and
temporal heterogeneity of PM
components that contribute to climate
forcing (U.S. EPA, 2020, sections
5.2.2.1.1 and 5.4). Despite continuing
research, there are still significant
limitations in quantifying the
contributions of PM and PM
components to the direct and indirect
effects on climate forcing (e.g., changes
to the pattern of rainfall, changes to
wind patterns, effects on vertical mixing
in the atmosphere) (U.S. EPA, 2020,
sections 5.2.2.1.1 and 5.4). In addition,
while a number of improvements and
refinements have been made to climate
models since the last review, these
models continue to exhibit variability in
estimates of the PM-related climate
effects on regional scales (e.g., ∼100 km)
compared to simulations at the global
scale (U.S. EPA, 2020, sections 5.2.2.1.1
and 5.4). While new research has added
to the understanding of climate forcing
on a global scale, there remain
significant limitations to quantifying
potential adverse effects from PM on
climate in the U.S. and how they would
vary in response to incremental changes
in PM concentrations in the U.S.
Overall, the PA recognizes that while
new research is available on climate
forcing on a global scale, the remaining
uncertainties and limitations are
significant, and the new global scale
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research does not translate directly to
use at regional spatial scales. Thus, the
evidence does not provide a clear
understanding at the spatial scales
needed for the NAAQS of a quantitative
relationship between concentrations of
PM mass in ambient air and the
associated climate-related effects (U.S.
EPA, 2020, sections 5.2.2.2.1 and 5.4).
The PA concludes that the evidence
does not call into question the adequacy
of the current secondary PM standards
for climate effects.
With regard to materials effects, the
PA notes the availability of new
evidence in this review related to the
soiling process and the types of
materials that are affected. Such
evidence provides some limited
information to inform dose-response
relationships and damage functions
associated with PM, though most recent
studies have been conducted outside the
U.S. (U.S. EPA, 2020, section 5.2.2.1.2;
U.S. EPA, 2019, section 13.4). The
recent evidence includes studies
examining PM-related effects on the
energy efficiency of solar panels and
passive cooling building materials,
though there remains insufficient
evidence to establish quantitative
relationships between PM in ambient air
and these or other materials effects (U.S.
EPA, 2020, section 5.2.2.1.2). While new
research has expanded the body of
evidence for PM-related materials
effects, the PA recognizes the lack of
information to inform quantitative
analyses assessing materials effects or
the potential public welfare
implications of such effects. Thus, the
PA concludes that the evidence does not
call into question the adequacy of the
current secondary PM standards for
materials effects.
Overall, the PA recognizes that the
newly available welfare effects
evidence, critically assessed in the ISA
as part of the full body of evidence,
reaffirms the conclusions on the
visibility, climate, and materials effects
of PM as recognized in the last review
(U.S. EPA, 2020, sections 5.2.1.1.,
5.2.2.1, and 5.4). Further, there is a
general consistency of the currently
available evidence with the evidence
that was available in the last review,
including with regard to key aspects of
the decision to retain the standards in
the last review (U.S. EPA, 2020, sections
5.2.1.1, 5.2.2.1, and 5.4). The
quantitative analyses for visibility
impairment for recent air quality
conditions indicate a similar level of
protection against visibility effects
considered to be adverse in the last
review (U.S. EPA, 2020, sections 5.2.1.2
and 5.4). Collectively, the PA finds that
the evidence and quantitative
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information-based considerations
support consideration of retaining the
current secondary PM standards,
without revision (U.S. EPA, 2020,
section 5.4).
2. CASAC Advice
As part of its review of the draft PA,
the CASAC has provided advice on the
adequacy of the current secondary PM
standards. In its comments on the draft
PA, the CASAC concurs with staff’s
overall preliminary conclusions that it
is appropriate to consider retaining the
current secondary PM standards
without revision (Cox, 2019a). The
CASAC ‘‘finds much of the information
. . . on visibility and materials effects of
PM2.5 to be useful, while recognizing
that uncertainties and controversies
remain about the best ways to evaluate
these effects’’ (Cox, 2019a, p. 13 of
consensus responses). Regarding
climate, while the CASAC agrees that
research on PM-related effects has
expanded since the last review, it also
concludes that ‘‘there are still
significant uncertainties associated with
the accurate measurement of PM
contributions to the direct and indirect
effects of PM on climate’’ (Cox, 2019a,
pp. 13–14 of consensus responses). The
committee recommends that the EPA
summarize the ‘‘current scientific
knowledge and quantitative modeling
results for effects of reducing PM2.5’’ on
several climate-related outcomes (Cox,
2019a, p. 14 of consensus responses),
while also recognizing that ‘‘it is
appropriate to acknowledge
uncertainties in climate change impacts
and resulting welfare impacts in the
United States of reductions in PM2.5
levels’’ (Cox, 2019a, p. 14 of consensus
responses). When considering the
overall body of scientific information for
PM-related effects on visibility,
materials, and climate, the CASAC
agrees that ‘‘the available evidence does
not call into question the protection
afforded by the current secondary PM
standards and concurs that they should
be retained’’ (Cox, 2019a, p. 3 of letter).
3. Administrator’s Proposed Decision on
the Current Secondary PM Standards
This section summarizes the
Administrator’s considerations and
conclusions related to the current
secondary PM2.5 and PM10 standards
and presents his proposed decision to
retain those standards, without revision.
In establishing secondary standards
under the Act that are ‘‘requisite’’ to
protect the public welfare from any
known or anticipated adverse effects,
the Administrator is seeking to establish
standards that are neither more nor less
stringent than necessary for this
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24137
purpose. He notes that secondary
standards are not meant to protect
against all known or anticipated effects,
but rather those that are judged to be
adverse to the public welfare. Consistent
with the primary standards discussed
above (sections II.C.3 and III.C.3), the
Act does not require standards to be set
at a zero-risk level; but rather at a level
that limits risk sufficiently so as to
protect the public welfare, but not more
stringent than necessary to do so.
Given these requirements, the
Administrator’s final decision in this
review will be a public welfare policy
judgment that draws upon the scientific
and technical information examining
PM-related visibility impairment,
climate effects and materials effects,
including how to consider the range and
magnitude of uncertainties inherent in
that information. The Administrator
recognizes that his final decision will be
based on an interpretation of the
scientific evidence and technical
analyses that neither overstates nor
understates their strengths and
limitations, nor the appropriate
inferences to be drawn.
As an initial matter in considering the
secondary standards, the Administrator
notes the longstanding body of evidence
for PM-related visibility impairment. As
in the last review, this evidence
continues to demonstrate a causal
relationship between ambient PM and
effects on visibility (U.S. EPA, 2019,
section 13.2). The Administrator
recognizes that visibility impairment
can have implications for people’s
enjoyment of daily activities and for
their overall sense of well-being.
Therefore, as in previous reviews, he
considers the degree to which the
current secondary standards protect
against PM-related visibility
impairment.
In doing so, the Administrator adopts
an approach consistent with the
approach used in the last review
(section IV.A.1). That is, he first defines
an appropriate target level of protection
in terms of a PM visibility index that
accounts for the factors that influence
the relationship between particles in the
ambient air and visibility (i.e., size
fraction, species composition, and
relative humidity). He then considers air
quality analyses examining this PM
visibility index in locations meeting the
current 24-hour PM2.5 and PM10
standards (U.S. EPA, 2020, section
5.2.1.2).
To identify a target level of protection,
the Administrator first defines the
specific characteristics of the visibility
index. He notes that in the last review,
the EPA used an index based on
estimates of light extinction by PM2.5
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components calculated using an
adjusted version of the original
IMPROVE algorithm. As described
above (sections IV.B and IV.D.1), this
algorithm allows the estimation of light
extinction using routinely monitored
components of PM2.5 and PM10-2.5,66
along with estimates of relative
humidity. While revisions have been
made to the IMPROVE algorithm since
the last review (U.S. EPA, 2020, section
5.2.1.1), the Administrator recognizes
that our fundamental understanding of
the relationship between ambient PM
and light extinction has changed little
and that the various IMPROVE
algorithms can appropriately reflect this
relationship across the U.S. In the
absence of a robust monitoring network
to directly measure light extinction
(sections IV.B.2 and IV.D.1), he judges
that estimated light extinction, as
calculated using the IMPROVE
algorithms, continues to provide a
reasonable basis for defining a target
level of protection against PM-related
visibility impairment in the current
review.
In further defining the characteristics
of a visibility index based on estimates
of light extinction, the Administrator
considers the appropriate averaging
time, form, and level of the index. With
regard to the averaging time and form,
the Administrator judges that the
decisions made in the last review
remain reasonable. In that review, a 24hour averaging time was selected and
the form was defined as the 3-year
average of annual 90th percentile
values. The decision on averaging time
recognized the relatively strong
correlations between 24-hour and subdaily (i.e., 4-hour average) PM2.5 light
extinction (78 FR 3226, January 15,
2013), indicating that a 24-hour
averaging time is an appropriate
surrogate for the sub-daily time periods
relevant for visual perception. This
decision also recognized that the longer
averaging time may be less influenced
by atypical conditions and/or atypical
instrument performance (78 FR 3226,
January 15, 2013). The decision to set
the form as the 3-year average of annual
90th percentile values noted that (1) a
3-year average provides stability from
the occasional effect of inter-annual
meteorological variability (78 FR 3198,
January 15, 2013; U.S. EPA, 2011, p. 4–
58); (2) the 90th percentile corresponds
to the median of the distribution of the
20 percent worst days for visibility,
66 In the last review, the focus was on PM
2.5
components given their prominent role in PMrelated visibility impairment in urban areas and the
limited data available for PM10-2.5 (77 FR 38980,
June 29, 2012; U.S. EPA, 2020, section 5.2.1.2).
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which are targeted in Class I areas by
the Regional Haze Program; 67 and (3)
available studies on people’s visibility
preferences did not identify a basis for
a different target than that identified for
Class I areas (U.S. EPA, 2011, p. 4–59).
Given the similar information available
in the current review, the Administrator
judges that these decisions remain
reasonable and, therefore, that it
remains appropriate to define a
visibility index in terms of a 24-hour
averaging time and a form based on the
3-year average of annual 90th percentile
values.
The level of the index was set at 30
dv in the last review, reflecting the
highest degree of visibility impairment
judged to be acceptable by at least 50%
of study participants in the available
visibility preference studies (78 FR
3226–3227, January 15, 2013). The focus
on 30 dv, rather than a lower level, was
supported in light of the important
uncertainties and limitations in the
underlying public preference studies.
Consistent with the last review, the
Administrator notes the following
uncertainties and limitations in these
studies (U.S. EPA, 2020, section 5.2.1.1):
• The available studies may not
capture the full range of visibility
preferences in the U.S. population,
particularly given the potential for
preferences to vary based on the
visibility conditions commonly
encountered and the types of scenes
being viewed.
• The available preference studies
were conducted 15 to 30 years ago and
may not reflect the visibility preferences
of the U.S. population today.
• The available preference studies
have used a variety of methods,
potentially influencing responses as to
what level of visibility impairment is
deemed acceptable.
• Factors that are not captured by the
methods used in available preference
studies may influence people’s
judgments on acceptable visibility,
including the duration of visibility
impairment, the time of day during
which light extinction is greatest, and
the frequency of episodes of visibility
impairment.
Because no visibility preference
studies have been conducted in the U.S.
since the last review, the Administrator
recognizes that these uncertainties and
limitations persist. Therefore, in the
current review his consideration of the
67 In the last review, 90th, 95th, and 98th
percentile forms were evaluated (U.S. EPA, 2010b,
section 4.3.3; 78 FR 3198, January 15, 2013), and
a standard with a 90th percentile form was
reasonably expected to limit the occurrence of days
with peak PM-related light extinction (78 FR 3198,
January 15, 2013).
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degree of visibility impairment
constituting an adverse public welfare
impact is based on the same preference
studies, with the same uncertainties and
limitations, that were available in the
last review. Drawing from this
information, the Administrator judges it
appropriate to again use 30 dv as the
level of the visibility index.
Having concluded that it remains
appropriate in this review to define the
target level of protection in terms of a
visibility index based on estimated light
extinction as described above (i.e., with
a 24-hour averaging time; a 3-year, 90th
percentile form; and a level of 30 dv),
the Administrator next considers the
degree of protection from visibility
impairment afforded by the existing
secondary standards. He considers the
updated analyses of PM-related
visibility impairment presented in the
PA (U.S. EPA, 2020, section 5.2.1.2),
which reflect several improvements
over the previous review. Specifically,
the updated analyses examine multiple
versions of the IMPROVE algorithm,
including the version incorporating
revisions since the last review (section
IV.D.1). This approach provides an
improved understanding of how
variation in equation inputs impacts
calculated light extinction (U.S. EPA,
2020, Appendix D). In addition, for a
subset of monitoring sites with available
PM10-2.5 data, updated analyses better
characterize the influence of the coarse
fraction on light extinction (U.S. EPA,
2020, section 5.2.1.2).
The Administrator notes that the
results of these updated analyses are
consistent with the results from the last
review. Regardless of the IMPROVE
equation used, they demonstrate that
the 3-year visibility metric is at or below
about 30 dv in all areas meeting the
current 24-hour PM2.5 standard,68 and
below 25 dv in most of those areas
(section IV.D.1). In the locations with
available PM10-2.5 monitoring, which
met both the current 24-hour PM2.5 and
PM10 standards, 3-year visibility metrics
were at or below 30 dv regardless of
whether the coarse fraction was
included in the calculation (U.S. EPA,
2020, section 5.2.1.2). Given the results
of these analyses, the Administrator
concludes that the updated scientific
68 As discussed in the PA (U.S. EPA, 2020,
section 5.2.1.2), one site in Fairbanks, Alaska just
meets the current 24-hour PM2.5 standard and has
a 3-year visibility index value of 27 dv based on the
original IMPROVE equation and 31 dv based on the
Lowenthal and Kumar (2016) equation. At this site,
use of the Lowenthal and Kumar (2016) equation
may not be appropriate given that PM composition
and meteorological conditions may differ
considerably from those under which revisions to
the equation have been validated (U.S. EPA, 2020,
section 5.2.1.2).
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evidence and technical information
support the adequacy of the current
secondary PM2.5 and PM10 standards to
protect against PM-related visibility
impairment. While the inclusion of the
coarse fraction had a relatively modest
impact on calculated light extinction in
these analyses, he nevertheless
recognizes the continued importance of
the PM10 standard given the potential
for larger impacts in locations with
higher coarse particle concentrations,
such as in the southwestern U.S., which
were not included in the PA’s analyses
due to insufficient coarse particle data
(U.S. EPA, 2019, section 13.2.4.1; U.S.
EPA, 2020, section 5.2.1.2).
With respect to non-visibility welfare
effects, the Administrator considers the
evidence for PM-related impacts on
climate and on materials and concludes
that it is generally appropriate to retain
the existing secondary standards and
that it is not appropriate to establish any
distinct secondary PM standards to
address non-visibility PM-related
welfare effects. With regard to climate,
he recognizes that a number of
improvements and refinements have
been made to climate models since the
time of the last review. However,
despite continuing research and the
strong evidence supporting a causal
relationship with climate effects (U.S.
EPA, 2019, section 13.3.9), the
Administrator notes that there are still
significant limitations in quantifying the
contributions of the direct and indirect
effects of PM and PM components on
climate forcing (U.S. EPA, 2020,
sections 5.2.2.1.1 and 5.4). He also
recognizes that models continue to
exhibit considerable variability in
estimates of PM-related climate impacts
at regional scales (e.g., ∼100 km),
compared to simulations at the global
scale (U.S. EPA, 2020, sections 5.2.2.1.1
and 5.4). The resulting uncertainty leads
the Administrator to conclude that the
scientific information available in the
current review remains insufficient to
quantify, with confidence, the impacts
of ambient PM on climate in the U.S.
(U.S. EPA, 2020, section 5.2.2.2.1) and
that there is insufficient information at
this time to base a national ambient
standard on climate impacts.
With respect to materials effects, the
Administrator notes that the evidence
available in the current review
continues to support the conclusion that
there is a causal relationship with PM
deposition (U.S. EPA, 2019, section
13.4). He recognizes that deposition of
particles in the fine or coarse fractions
can result in physical damage and/or
impaired aesthetic qualities. Particles
can contribute to materials damage by
adding to the effects of natural
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weathering processes and by promoting
the corrosion of metals, the degradation
of painted surfaces, the deterioration of
building materials, and the weakening
of material components. While some
new evidence on materials effects of PM
is available in this review, the
Administrator notes that this evidence
is primarily from studies conducted
outside of the U.S. (U.S. EPA, 2019,
section 13.4). Given the more limited
amount of information on the
quantitative relationships between PM
and materials effects in the U.S., and
uncertainties in the degree to which
those effects could be adverse to the
public welfare, the Administrator judges
that the scientific information available
in the current review remains
insufficient to quantify, with
confidence, the public welfare impacts
of ambient PM on materials and that
there is insufficient information at this
time to support a distinct national
ambient standard based on materials
impacts.
Taken together, the Administrator
concludes that the scientific and
technical information for PM-related
visibility impairment, climate impacts,
and materials effects, with its attendant
uncertainties and limitations, supports
the current level of protection provided
by the secondary PM standards as being
requisite to protect against known and
anticipated adverse effects on public
welfare. For visibility impairment, this
conclusion reflects his consideration of
the evidence for PM-related light
extinction, together with his
consideration of updated analyses of the
protection provided by the current
secondary PM2.5 and PM10 standards.
For climate and materials effects, this
conclusion reflects his judgment that,
although it remains important to
maintain secondary PM2.5 and PM10
standards to provide some degree of
control over long- and short-term
concentrations of both fine and coarse
particles, it is generally appropriate to
retain the existing secondary standards
and that it is not appropriate to establish
any distinct secondary PM standards to
address non-visibility PM-related
welfare effects. His conclusions on the
secondary standards are consistent with
advice from the CASAC, which agrees
‘‘that the available evidence does not
call into question the protection
afforded by the current secondary PM
standards’’ and recommends that the
secondary standards ‘‘should be
retained’’ (Cox, 2019a, p. 3 of letter).
Thus, based on his consideration of the
evidence and analyses for PM-related
welfare effects, as described above, and
his consideration of CASAC advice on
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24139
the secondary standards, the
Administrator proposes to retain those
standards (i.e., the current 24-hour and
annual PM2.5 standards, 24-hour PM10
standard), without revision.
V. Statutory and Executive Order
Reviews
Additional information about these
statutes and Executive Orders can be
found at https://www2.epa.gov/lawsregulations/laws-and-executive-orders.
A. Executive Order 12866: Regulatory
Planning and Review and Executive
Order 13563: Improving Regulation and
Regulatory Review
The Office of Management and Budget
(OMB) determined that this action is a
significant regulatory action and it was
submitted to OMB for review. Any
changes made in response to OMB
recommendations have been
documented in the docket. Because this
action does not propose to change the
existing NAAQS for PM, it does not
impose costs or benefits relative to the
baseline of continuing with the current
NAAQS in effect. Thus, the EPA has not
prepared a Regulatory Impact Analysis
for this action.
B. Executive Order 13771: Reducing
Regulations and Controlling Regulatory
Costs
This action is not expected to be an
Executive Order 13771 regulatory
action. There are no quantified cost
estimates for this proposed action
because EPA is proposing to retain the
current standards.
C. Paperwork Reduction Act (PRA)
This action does not impose an
information collection burden under the
PRA. There are no information
collection requirements directly
associated with a decision to retain a
NAAQS without any revision under
section 109 of the CAA and this action
proposes to retain the current PM
NAAQS without any revisions.
D. Regulatory Flexibility Act (RFA)
I certify that this action will not have
a significant economic impact on a
substantial number of small entities
under the RFA. This action will not
impose any requirements on small
entities. Rather, this action proposes to
retain, without revision, existing
national standards for allowable
concentrations of PM in ambient air as
required by section 109 of the CAA. See
also American Trucking Associations v.
EPA, 175 F.3d 1027, 1044–45 (D.C. Cir.
1999) (NAAQS do not have significant
impacts upon small entities because
NAAQS themselves impose no
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Federal Register / Vol. 85, No. 84 / Thursday, April 30, 2020 / Proposed Rules
regulations upon small entities), rev’d in
part on other grounds, Whitman v.
American Trucking Associations, 531
U.S. 457 (2001).
J. National Technology Transfer and
Advancement Act (NTTAA)
This action does not involve technical
standards.
E. Unfunded Mandates Reform Act
(UMRA)
K. Executive Order 12898: Federal
Actions To Address Environmental
Justice in Minority Populations and
Low-Income Populations
The EPA believes that this action does
not have disproportionately high and
adverse human health or environmental
effects on minority, low-income
populations and/or indigenous peoples,
as specified in Executive Order 12898
(59 FR 7629, February 16, 1994). The
documentation related to this is
contained in sections II through IV
above. The action proposed in this
document is to retain, without revision,
the existing NAAQS for PM based on
the Administrator’s conclusion that the
existing standards protect public health,
including the health of sensitive groups,
with an adequate margin of safety and
protect the public welfare. As discussed
in section II, the EPA expressly
considered the available information
regarding health effects among at-risk
populations in reaching the proposed
decision that the existing standard is
requisite.
This action does not contain any
unfunded mandate as described in the
UMRA, 2 U.S.C. 1531–1538, and does
not significantly or uniquely affect small
governments. This action imposes no
enforceable duty on any state, local, or
tribal governments or the private sector.
F. Executive Order 13132: Federalism
This action does not have federalism
implications. It will not have substantial
direct effects on the states, on the
relationship between the national
government and the states, or on the
distribution of power and
responsibilities among the various
levels of government.
G. Executive Order 13175: Consultation
and Coordination With Indian Tribal
Governments
This action does not have tribal
implications, as specified in Executive
Order 13175. It does not have a
substantial direct effect on one or more
Indian Tribes. This action does not
change existing regulations; it proposes
to retain the current primary NAAQS for
PM, without revision. Executive Order
13175 does not apply to this action.
H. Executive Order 13045: Protection of
Children From Environmental Health
Risks and Safety Risks
This action is not subject to Executive
Order 13045 because it is not
economically significant as defined in
Executive Order 12866. The health
effects evidence for this action, which
includes evidence for effects in
children, is summarized in section II.B
above and is described in the ISA and
PA, copies of which are in the public
docket for this action.
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I. Executive Order 13211: Actions
Concerning Regulations That
Significantly Affect Energy Supply,
Distribution or Use
This action is not subject to Executive
Order 13211, because it is not likely to
have a significant adverse effect on the
supply, distribution, or use of energy.
The purpose of this document is to
propose to retain the current PM
NAAQS. This proposal does not change
existing requirements. Thus, the EPA
concludes that this proposal does not
constitute a significant energy action as
defined in Executive Order 13211.
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L. Determination Under Section 307(d)
Section 307(d)(1)(V) of the CAA
provides that the provisions of section
307(d) apply to ‘‘such other actions as
the Administrator may determine.’’
Pursuant to section 307(d)(1)(V), the
Administrator determines that this
action is subject to the provisions of
section 307(d).
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Andrew Wheeler,
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[FR Doc. 2020–08143 Filed 4–29–20; 8:45 am]
BILLING CODE 6560–50–P
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[Federal Register Volume 85, Number 84 (Thursday, April 30, 2020)]
[Proposed Rules]
[Pages 24094-24144]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-08143]
[[Page 24093]]
Vol. 85
Thursday,
No. 84
April 30, 2020
Part II
Environmental Protection Agency
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40 CFR Part 50
Review of the National Ambient Air Quality Standards for Particulate
Matter; Proposed Rule
Federal Register / Vol. 85 , No. 84 / Thursday, April 30, 2020 /
Proposed Rules
[[Page 24094]]
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ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 50
[EPA-HQ-OAR-2015-0072; FRL-10008-31-OAR]
RIN 2060-AS50
Review of the National Ambient Air Quality Standards for
Particulate Matter
AGENCY: Environmental Protection Agency (EPA).
ACTION: Proposed action.
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SUMMARY: Based on the Environmental Protection Agency's (EPA's) review
of the air quality criteria and the national ambient air quality
standards (NAAQS) for particulate matter (PM), the Administrator has
reached proposed decisions on the primary and secondary PM NAAQS. With
regard to the primary standards meant to protect against fine particle
exposures (i.e., annual and 24-hour PM2.5 standards), the
primary standard meant to protect against coarse particle exposures
(i.e., 24-hour PM10 standard), and the secondary
PM2.5 and PM10 standards, the EPA proposes to
retain the current standards, without revision.
DATES: Comments must be received on or before June 29, 2020.
Public Hearings: The EPA will hold one or more virtual public
hearings on this proposed rule. These will be announced in a separate
Federal Register notice that provides details, including specific
dates, times, and contact information for these hearings.
ADDRESSES: You may submit comments, identified by Docket ID No. EPA-HQ-
OAR-2015-0072, by any of the following means:
Federal eRulemaking Portal: https://www.regulations.gov
(our preferred method). Follow the online instructions for submitting
comments.
Email: [email protected]. Include the Docket ID No.
EPA-HQ-OAR-2015-0072 in the subject line of the message.
Instructions: All submissions received must include the Docket ID
No. for this document. Comments received may be posted without change
to https://www.regulations.gov, including any personal information
provided. For detailed instructions on sending comments, see the
SUPPLEMENTARY INFORMATION section of this document. Out of an abundance
of caution for members of the public and our staff, the EPA Docket
Center and Reading Room was closed to public visitors on March 31,
2020, to reduce the risk of transmitting COVID-19. Our Docket Center
staff will continue to provide remote customer service via email,
phone, and webform. We encourage the public to submit comments via
https://www.regulations.gov or email, as there is a temporary
suspension of mail delivery to EPA, and no hand deliveries are
currently accepted. For further information of EPA Docket Center
services and the current status, please visit us online at https://www.epa.gov/dockets.
FOR FURTHER INFORMATION CONTACT: Dr. Scott Jenkins, Health and
Environmental Impacts Division, Office of Air Quality Planning and
Standards, U.S. Environmental Protection Agency, Mail Code C504-06,
Research Triangle Park, NC 27711; telephone: (919) 541-1167; fax: (919)
541-5315; email: [email protected].
SUPPLEMENTARY INFORMATION:
General Information
Written Comments: Submit your comments, identified by Docket ID No.
EPA-HQ-OAR-2015-0072, at https://www.regulations.gov (our preferred
method), or the other methods identified in the ADDRESSES section. Once
submitted, comments cannot be edited or removed from the docket. The
EPA may publish any comment received to its public docket. Do not
submit electronically any information you consider to be Confidential
Business Information (CBI) or other information whose disclosure is
restricted by statute. Multimedia submissions (audio, video, etc.) must
be accompanied by a written submission. The written submission is
considered the official submission and should include discussion of all
points you wish to make. The EPA will generally not consider
submissions or submission content located outside of the primary
submission (i.e., on the web, cloud, or other file sharing system). For
additional submission methods, the full EPA public comment policy,
information about CBI or multimedia submissions, and general guidance
on making effective comments, please visit https://www.epa.gov/dockets/commenting-epa-dockets.
The EPA is temporarily suspending its Docket Center and Reading
Room for public visitors to reduce the risk of transmitting COVID-19.
Written comments submitted by mail are temporarily suspended and no
hand deliveries will be accepted. Our Docket Center staff will continue
to provide remote customer service via email, phone, and webform. We
encourage the public to submit comments via https://www.regulations.gov. For further information and updates on EPA Docket
Center services, please visit us online at https://www.epa.gov/dockets.
The EPA continues to carefully and continuously monitor information
from the Centers for Disease Control and Prevention (CDC), local area
health departments, and our Federal partners so that we can respond
rapidly as conditions change regarding COVID-19.
Availability of Information Related to This Action
A number of the documents that are relevant to this proposed
decision are available through the EPA's website at https://www.epa.gov/naaqs/particulate-matter-pm-air-quality-standards. These
documents include the Integrated Review Plan for the National Ambient
Air Quality Standards for Particulate Matter (U.S. EPA, 2016),
available at https://www3.epa.gov/ttn/naaqs/standards/pm/data/201612-final-integrated-review-plan.pdf, the Integrated Science Assessment for
Particulate Matter (U.S. EPA, 2019), available at https://cfpub.epa.gov/ncea/isa/recordisplay.cfm?deid=347534, and the Policy
Assessment for the Review of the National Ambient Air Quality Standards
for Particulate Matter (U.S. EPA, 2020), available at https://www.epa.gov/naaqs/particulate-matter-pm-standards-policy-assessments-current-review-0. These and other related documents are also available
for inspection and copying in the EPA docket identified above.
Table of Contents
The following topics are discussed in this preamble:
Executive Summary
I. Background
A. Legislative Requirements
B. Related PM Control Programs
C. Review of the Air Quality Criteria and Standards for
Particulate Matter
1. Reviews Completed in 1971 and 1987
2. Review Completed in 1997
3. Review Completed in 2006
4. Review Completed in 2012
5. Current Review
D. Air Quality Information
1. Distribution of Particle Size in Ambient Air
2. Sources and Emissions Contributing to PM in the Ambient Air
3. Monitoring of Ambient PM
4. Ambient Concentrations and Trends
a. PM2.5 mass
b. PM2.5 components
c. PM10
d. PM10-2.5
a. UFP
5. Background PM
II. Rationale for Proposed Decisions on the Primary PM2.5
Standards
A. General Approach
[[Page 24095]]
1. Approach Used in the Last Review
a. Indicator
b. Averaging Time
c. Form
d. Level
2. Approach in the Current Review
B. Health Effects Related to Fine Particle Exposures
1. Nature of Effects
a. Mortality
b. Cardiovascular Effects
c. Respiratory Effects
d. Cancer
e. Nervous System Effects
2. Populations at Risk of PM2.5-Related Health
Effects
3. CASAC Advice
C. Proposed Conclusions on the Current Primary PM2.5
Standards
1. Evidence- and Risk-Based Considerations in the Policy
Assessment
a. Evidence-Based Considerations
b. Risk-Based Considerations
2. CASAC Advice
3. Administrator's Proposed Decision on the Current Primary
PM2.5 Standards
III. Rationale for Proposed Decisions on the Primary PM10
Standard
A. General Approach
1. Approach Used in the Last Review
2. Approach in the Current Review
B. Health Effects Related to Thoracic Coarse Particle Exposures
1. Mortality
a. Long-Term Exposures
b. Short-Term Exposures
2. Cardiovascular Effects
a. Long-Term Exposures
b. Short-Term Exposures
3. Respiratory Effects--Short-Term Exposures
4. Cancer--Long-Term Exposures
5. Metabolic Effects--Long-Term Exposures
6. Nervous System Effects--Long-Term Exposures
C. Proposed Conclusions on the Current Primary PM10
Standard
1. Evidence-Based Considerations in the Policy Assessment
2. CASAC Advice
3. Administrator's Proposed Decision on the Current Primary
PM10 Standard
IV. Rationale for Proposed Decisions on the Secondary PM Standards
A. General Approach
1. Approach Used in the Last Review
a. Non-Visibility Effects
b. Visibility Effects
2. Approach for the Current Review
B. PM-Related Visibility Impairment
1. Nature of PM-Related Visibility Impairment
2. Relationship between Ambient PM and Visibility
3. Public Perception of Visibility Impairment
C. Other PM-Related Welfare Effects
1. Climate
2. Materials
D. Proposed Conclusions on the Current Secondary PM Standards
1. Evidence- and Quantitative Information-Based Considerations
in the Policy Assessment
2. CASAC Advice
3. Administrator's Proposed Decision on the Current Secondary PM
Standards
V. Statutory and Executive Order Reviews
A. Executive Order 12866: Regulatory Planning and Review and
Executive Order 13563: Improving Regulation and Regulatory Review
B. Executive Order 13771: Reducing Regulations and Controlling
Regulatory Costs
C. Paperwork Reduction Act (PRA)
D. Regulatory Flexibility Act (RFA)
E. Unfunded Mandates Reform Act (UMRA)
F. Executive Order 13132: Federalism
G. Executive Order 13175: Consultation and Coordination With
Indian Tribal Governments
H. Executive Order 13045: Protection of Children From
Environmental Health and Safety Risks
I. Executive Order 13211: Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution or Use
J. National Technology Transfer and Advancement Act (NTTAA)
K. Executive Order 12898: Federal Actions to Address
Environmental Justice in Minority Populations and Low-Income
Populations
L. Determination Under Section 307(d)
References
Executive Summary
This document presents the Administrator's proposed decisions on
the primary (health-based) and secondary (welfare-based) National
Ambient Air Quality Standards (NAAQS) for particulate matter (PM). In
ambient air, PM is a mixture of substances suspended as small liquid
and/or solid particles. Particles in the atmosphere range in size from
less than 0.01 to more than 10 micrometers ([mu]m) in diameter.
Particulate matter and its precursors are emitted from both
anthropogenic sources (e.g., electricity generating units, cars and
trucks, agricultural operations) and natural sources (e.g., sea salt,
wildland fires, biological aerosols).
When describing PM, subscripts are used to denote particle size.
For example, PM2.5 includes particles with diameters
generally less than or equal to 2.5 [mu]m and PM10 includes
particles with diameters generally less than or equal to 10 [mu]m.
The EPA has established primary (health-based) and secondary
(welfare-based) NAAQS for PM2.5 and PM10. This
includes two primary PM2.5 standards, an annual average
standard with a level of 12.0 [mu]g/m\3\ and a 24-hour standard with a
98th percentile form and a level of 35 [mu]g/m\3\. It also includes a
primary PM10 standard with a 24-hour averaging time, a 1-
expected exceedance form, and a level of 150 [mu]g/m\3\. Secondary PM
standards are set equal to the primary standards, except that the level
of the secondary annual PM2.5 standard is 15.0 [mu]g/m\3\.
In reaching proposed decisions on these PM standards in the current
review, the Administrator has considered the available scientific
evidence assessed in the Integrated Science Assessment (ISA), analyses
in the Policy Assessment (PA), and advice from the Clean Air Scientific
Advisory Committee (CASAC).
For the primary PM2.5 standards, the Administrator
proposes to conclude that there are important uncertainties in the
evidence for adverse health effects below the current standards and in
the potential public health impacts of reducing ambient
PM2.5 concentrations below those standards. As a result, he
proposes to conclude that the available evidence and information do not
call into question the adequacy of the current primary PM2.5
standards, and he proposes to retain those standards (i.e., both the
annual and 24-hour standards) without revision in this review.
For the primary PM10 standard, the Administrator
observes that, while the available health effects evidence has
expanded, recent studies are subject to the same types of uncertainties
that were judged important in the last review. He proposes to conclude
that the newly available evidence does not call into question the
adequacy of the current primary PM10 standard, and he
proposes to retain that standard without revision in this review.
For the secondary standards, the Administrator observes that the
expanded evidence for non-ecological welfare effects is consistent with
the last review \1\ and that updated quantitative analyses show results
similar to those in the last review. Therefore, he proposes to conclude
that the newly available evidence and updated analyses do not call into
question the adequacy of the current secondary PM standards, and he
proposes to retain those standards without revision in this review.
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\1\ The welfare effects considered in this review include
visibility impairment, climate effects, and materials effects.
Ecological effects associated with PM, and the adequacy of
protection provided by the secondary PM standards for those effects,
are being addressed in the separate review of the secondary NAAQS
for oxides of nitrogen, oxides of sulfur and PM. Information on the
current review of these secondary NAAQS can be found at https://www.epa.gov/naaqs/nitrogen-dioxide-no2-and-sulfur-dioxide-so2-secondary-air-quality-standards.
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These proposed decisions are consistent with the CASAC's consensus
advice on the primary 24-hour PM2.5 standard, the primary
PM10 standard, and the secondary standards. The CASAC did
not reach consensus on the primary annual PM2.5 standard,
with some committee members
[[Page 24096]]
recommending that EPA retain the current standard and other members
recommending revision of that standard.
I. Background
A. Legislative Requirements
Two sections of the Clean Air Act (CAA) govern the establishment
and revision of the NAAQS. Section 108 (42 U.S.C. 7408) directs the
Administrator to identify and list certain air pollutants and then to
issue air quality criteria for those pollutants. The Administrator is
to list those pollutants ``emissions of which, in his judgment, cause
or contribute to air pollution which may reasonably be anticipated to
endanger public health or welfare''; ``the presence of which in the
ambient air results from numerous or diverse mobile or stationary
sources''; and for which he ``plans to issue air quality criteria . . .
. '' (42 U.S.C. 7408(a)(1)). Air quality criteria are intended to
``accurately reflect the latest scientific knowledge useful in
indicating the kind and extent of all identifiable effects on public
health or welfare which may be expected from the presence of [a]
pollutant in the ambient air . . . . '' (42 U.S.C. 7408(a)(2)).
Section 109 [42 U.S.C. 7409] directs the Administrator to propose
and promulgate ``primary'' and ``secondary'' NAAQS for pollutants for
which air quality criteria are issued [42 U.S.C. 7409(a)]. Section
109(b)(1) defines primary standards as ones ``the attainment and
maintenance of which in the judgment of the Administrator, based on
such criteria and allowing an adequate margin of safety, are requisite
to protect the public health.'' \2\ Under section 109(b)(2), a
secondary standard must ``specify a level of air quality the attainment
and maintenance of which, in the judgment of the Administrator, based
on such criteria, is requisite to protect the public welfare from any
known or anticipated adverse effects associated with the presence of
[the] pollutant in the ambient air.'' \3\
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\2\ The legislative history of section 109 indicates that a
primary standard is to be set at ``the maximum permissible ambient
air level . . . which will protect the health of any [sensitive]
group of the population,'' and that for this purpose ``reference
should be made to a representative sample of persons comprising the
sensitive group rather than to a single person in such a group.'' S.
Rep. No. 91-1196, 91st Cong., 2d Sess. 10 (1970).
\3\ Under CAA section 302(h) (42 U.S.C. 7602(h)), effects on
welfare include, but are not limited to, ``effects on soils, water,
crops, vegetation, manmade materials, animals, wildlife, weather,
visibility, and climate, damage to and deterioration of property,
and hazards to transportation, as well as effects on economic values
and on personal comfort and well-being.''
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In setting primary and secondary standards that are ``requisite''
to protect public health and welfare, respectively, as provided in
section 109(b), the EPA's task is to establish standards that are
neither more nor less stringent than necessary. In so doing, the EPA
may not consider the costs of implementing the standards. See generally
Whitman v. American Trucking Associations, 531 U.S. 457, 465-472, 475-
76 (2001). Likewise, ``[a]ttainability and technological feasibility
are not relevant considerations in the promulgation of national ambient
air quality standards.'' American Petroleum Institute v. Costle, 665
F.2d 1176, 1185 (D.C. Cir. 1981); accord Murray Energy Corporation v.
EPA, 936 F.3d 597, 623-24 (D.C. Cir. 2019).
The requirement that primary standards provide an adequate margin
of safety was intended to address uncertainties associated with
inconclusive scientific and technical information available at the time
of standard setting. It was also intended to provide a reasonable
degree of protection against hazards that research has not yet
identified. See Lead Industries Association v. EPA, 647 F.2d 1130, 1154
(D.C. Cir 1980); American Petroleum Institute v. Costle, 665 F.2d at
1186; Coalition of Battery Recyclers Ass'n v. EPA, 604 F.3d 613, 617-18
(D.C. Cir. 2010); Mississippi v. EPA, 744 F.3d 1334, 1353 (D.C. Cir.
2013). Both kinds of uncertainties are components of the risk
associated with pollution at levels below those at which human health
effects can be said to occur with reasonable scientific certainty.
Thus, in selecting primary standards that include an adequate margin of
safety, the Administrator is seeking not only to prevent pollution
levels that have been demonstrated to be harmful but also to prevent
lower pollutant levels that may pose an unacceptable risk of harm, even
if the risk is not precisely identified as to nature or degree. The CAA
does not require the Administrator to establish a primary NAAQS at a
zero-risk level or at background concentration levels, see Lead
Industries Ass'n v. EPA, 647 F.2d at 1156 n.51, Mississippi v. EPA, 744
F.3d at 1351, but rather at a level that reduces risk sufficiently so
as to protect public health with an adequate margin of safety.
In addressing the requirement for an adequate margin of safety, the
EPA considers such factors as the nature and severity of the health
effects involved, the size of the sensitive population(s), and the kind
and degree of uncertainties. The selection of any particular approach
to providing an adequate margin of safety is a policy choice left
specifically to the Administrator's judgment. See Lead Industries Ass'n
v. EPA, 647 F.2d at 1161-62; Mississippi v. EPA, 744 F.3d at 1353.
Section 109(d)(1) of the Act requires the review every five years
of existing air quality criteria and, if appropriate, the revision of
those criteria to reflect advances in scientific knowledge on the
effects of the pollutant on public health and welfare. Under the same
provision, the EPA is also to review every five years and, if
appropriate, revise the NAAQS, based on the revised air quality
criteria.
Section 109(d)(2) addresses the appointment and advisory functions
of an independent scientific review committee. Section 109(d)(2)(A)
requires the Administrator to appoint this committee, which is to be
composed of ``seven members including at least one member of the
National Academy of Sciences, one physician, and one person
representing State air pollution control agencies.'' Section
109(d)(2)(B) provides that the independent scientific review committee
``shall complete a review of the criteria . . . and the national
primary and secondary ambient air quality standards . . . and shall
recommend to the Administrator any new . . . standards and revisions of
existing criteria and standards as may be appropriate. . . .'' Since
the early 1980s, this independent review function has been performed by
the Clean Air Scientific Advisory Committee (CASAC) of the EPA's
Science Advisory Board. A number of other advisory functions are also
identified for the committee by section 109(d)(2)(C), which reads:
Such committee shall also (i) advise the Administrator of areas
in which additional knowledge is required to appraise the adequacy
and basis of existing, new, or revised national ambient air quality
standards, (ii) describe the research efforts necessary to provide
the required information, (iii) advise the Administrator on the
relative contribution to air pollution concentrations of natural as
well as anthropogenic activity, and (iv) advise the Administrator of
any adverse public health, welfare, social, economic, or energy
effects which may result from various strategies for attainment and
maintenance of such national ambient air quality standards.
As previously noted, the Supreme Court has held that section 109(b)
``unambiguously bars cost considerations from the NAAQS-setting
process.'' Whitman v. Am. Trucking Associations, 531 U.S. 457, 471
(2001). Accordingly, while some of these issues regarding which
Congress has directed the CASAC to advise the Administrator are ones
that are relevant to the standard setting process, others are not.
Issues
[[Page 24097]]
that are not relevant to standard setting may be relevant to
implementation of the NAAQS once they are established.\4\
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\4\ Some aspects of the CASAC's advice may not be relevant to
the EPA's process of setting primary and secondary standards that
are requisite to protect public health and welfare. Indeed, were EPA
to consider costs of implementation when reviewing and revising the
standards ``it would be grounds for vacating the NAAQS.'' Whitman,
531 U.S. at 471 n.4. At the same time, the CAA directs the CASAC to
provide advice on ``any adverse public health, welfare, social,
economic, or energy effects which may result from various strategies
for attainment and maintenance'' of the NAAQS to the Administrator
under section 109(d)(2)(C)(iv). In Whitman, the Court clarified that
most of that advice would be relevant to implementation but not
standard setting, as it ``enable[s] the Administrator to assist the
States in carrying out their statutory role as primary implementers
of the NAAQS.'' Id. at 470 (emphasis in original). However, the
Court also noted that the CASAC's ``advice concerning certain
aspects of `adverse public health . . . effects' from various
attainment strategies is unquestionably pertinent'' to the NAAQS
rulemaking record and relevant to the standard setting process. Id.
at 470 n.2.
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B. Related PM Control Programs
States are primarily responsible for ensuring attainment and
maintenance of ambient air quality standards once the EPA has
established them. Under section 110 and 171-190 of the CAA, and related
provisions and regulations, states are to submit, for EPA's approval,
state implementation plans (SIPs) that provide for the attainment and
maintenance of such standards through control programs directed to
sources of the pollutants involved. The states, in conjunction with the
EPA, also administer the Prevention of Significant Deterioration (PSD)
program (CAA sections 160 to 169). In addition, Federal programs
provide for nationwide reductions in emissions of PM and other air
pollutants through the Federal motor vehicle and motor vehicle fuel
control program under title II of the Act (CAA sections 202 to 250),
which involves controls for emissions from mobile sources and controls
for the fuels used by these sources, and new source performance
standards for stationary sources under section 111 of the CAA.
C. Review of the Air Quality Criteria and Standards for Particulate
Matter
1. Reviews Completed in 1971 and 1987
The EPA first established NAAQS for PM in 1971 (36 FR 8186, April
30, 1971), based on the original Air Quality Criteria Document (AQCD)
(DHEW, 1969).\5\ The federal reference method (FRM) specified for
determining attainment of the original standards was the high-volume
sampler, which collects PM up to a nominal size of 25 to 45 [micro]m
(referred to as total suspended particulates or TSP). The primary
standards were set at 260 [micro]g/m\3\, 24-hour average, not to be
exceeded more than once per year, and 75 [micro]g/m\3\, annual
geometric mean. The secondary standards were set at 150 [micro]g/m\3\,
24-hour average, not to be exceeded more than once per year, and 60
[micro]g/m\3\, annual geometric mean.
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\5\ Prior to the review initiated in 2007 (see below), the AQCD
provided the scientific foundation (i.e., the air quality criteria)
for the NAAQS. Beginning in that review, the Integrated Science
Assessment (ISA) has replaced the AQCD.
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In October 1979 (44 FR 56730, October 2, 1979), the EPA announced
the first periodic review of the air quality criteria and NAAQS for PM.
Revised primary and secondary standards were promulgated in 1987 (52 FR
24634, July 1, 1987). In the 1987 decision, the EPA changed the
indicator for particles from TSP to PM10, in order to focus
on the subset of inhalable particles small enough to penetrate to the
thoracic region of the respiratory tract (including the
tracheobronchial and alveolar regions), referred to as thoracic
particles.\6\ The level of the 24-hour standards (primary and
secondary) was set at 150 [micro]g/m\3\, and the form was one expected
exceedance per year, on average over three years. The level of the
annual standards (primary and secondary) was set at 50 [micro]g/m\3\,
and the form was annual arithmetic mean, averaged over three years.
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\6\ PM10 refers to particles with a nominal mean
aerodynamic diameter less than or equal to 10 [micro]m. More
specifically, 10 [micro]m is the aerodynamic diameter for which the
efficiency of particle collection is 50 percent.
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2. Review Completed in 1997
In April 1994, the EPA announced its plans for the second periodic
review of the air quality criteria and NAAQS for PM, and in 1997 the
EPA promulgated revisions to the NAAQS (62 FR 38652, July 18, 1997). In
the 1997 decision, the EPA determined that the fine and coarse
fractions of PM10 should be considered separately. This
determination was based on evidence that serious health effects were
associated with short- and long-term exposures to fine particles in
areas that met the existing PM10 standards. The EPA added
new standards, using PM2.5 as the indicator for fine
particles (with PM2.5 referring to particles with a nominal
mean aerodynamic diameter less than or equal to 2.5 [micro]m). The new
primary standards were as follows: (1) An annual standard with a level
of 15.0 [micro]g/m\3\, based on the 3-year average of annual arithmetic
mean PM2.5 concentrations from single or multiple community-
oriented monitors; \7\ and (2) a 24-hour standard with a level of 65
[micro]g/m\3\, based on the 3-year average of the 98th percentile of
24-hour PM2.5 concentrations at each monitor within an area.
Also, the EPA established a new reference method for the measurement of
PM2.5 in the ambient air and adopted rules for determining
attainment of the new standards. To continue to address the health
effects of the coarse fraction of PM10 (referred to as
thoracic coarse particles or PM10-2.5; generally including
particles with a nominal mean aerodynamic diameter greater than 2.5
[micro]m and less than or equal to 10 [micro]m), the EPA retained the
primary annual PM10 standard and revised the form of the
primary 24-hour PM10 standard to be based on the 99th
percentile of 24-hour PM10 concentrations at each monitor in
an area. The EPA revised the secondary standards by setting them equal
in all respects to the primary standards.
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\7\ The 1997 annual PM2.5 standard was compared with
measurements made at the community-oriented monitoring site
recording the highest concentration or, if specific constraints were
met, measurements from multiple community-oriented monitoring sites
could be averaged (i.e., ``spatial averaging''). In the last review
(completed in 2012) the EPA replaced the term ``community-oriented''
monitor with the term ``area-wide'' monitor. Area-wide monitors are
those sited at the neighborhood scale or larger, as well as those
monitors sited at micro- or middle-scales that are representative of
many such locations in the same core-based statistical area (CBSA)
(78 FR 3236, January 15, 2013).
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Following promulgation of the 1997 PM NAAQS, petitions for review
were filed by several parties, addressing a broad range of issues. In
May 1999, the U.S. Court of Appeals for the District of Columbia
Circuit (D.C. Circuit) upheld the EPA's decision to establish fine
particle standards, holding that ``the growing empirical evidence
demonstrating a relationship between fine particle pollution and
adverse health effects amply justifies establishment of new fine
particle standards.'' American Trucking Associations, Inc. v. EPA, 175
F. 3d 1027, 1055-56 (D.C. Cir. 1999). The D.C. Circuit also found
``ample support'' for the EPA's decision to regulate coarse particle
pollution, but vacated the 1997 PM10 standards, concluding
that the EPA had not provided a reasonable explanation justifying use
of PM10 as an indicator for coarse particles. American
Trucking Associations v. EPA, 175 F. 3d at 1054-55. Pursuant to the
D.C. Circuit's decision, the EPA removed the vacated 1997
PM10 standards, and the pre-existing 1987 PM10
standards remained in place (65 FR 80776, December 22, 2000). The D.C.
Circuit also upheld the EPA's determination not to establish more
stringent secondary standards for fine particles to address
[[Page 24098]]
effects on visibility. American Trucking Associations v. EPA, 175 F. 3d
at 1027.
The D.C. Circuit also addressed more general issues related to the
NAAQS, including issues related to the consideration of costs in
setting NAAQS and the EPA's approach to establishing the levels of
NAAQS. Regarding the cost issue, the court reaffirmed prior rulings
holding that in setting NAAQS the EPA is ``not permitted to consider
the cost of implementing those standards.'' American Trucking
Associations v. EPA, 175 F. 3d at 1040-41. Regarding the levels of
NAAQS, the court held that the EPA's approach to establishing the level
of the standards in 1997 (i.e., both for PM and for the ozone NAAQS
promulgated on the same day) effected ``an unconstitutional delegation
of legislative authority.'' American Trucking Associations v. EPA, 175
F. 3d at 1034-40. Although the court stated that ``the factors EPA uses
in determining the degree of public health concern associated with
different levels of ozone and PM are reasonable,'' it remanded the rule
to the EPA, stating that when the EPA considers these factors for
potential non-threshold pollutants ``what EPA lacks is any determinate
criterion for drawing lines'' to determine where the standards should
be set.
The D.C. Circuit's holding on the cost and constitutional issues
were appealed to the United States Supreme Court. In February 2001, the
Supreme Court issued a unanimous decision upholding the EPA's position
on both the cost and constitutional issues. Whitman v. American
Trucking Associations, 531 U.S. 457, 464, 475-76. On the constitutional
issue, the Court held that the statutory requirement that NAAQS be
``requisite'' to protect public health with an adequate margin of
safety sufficiently guided the EPA's discretion, affirming the EPA's
approach of setting standards that are neither more nor less stringent
than necessary.
The Supreme Court remanded the case to the D.C. Circuit for
resolution of any remaining issues that had not been addressed in that
court's earlier rulings. Id. at 475-76. In a March 2002 decision, the
D.C. Circuit rejected all remaining challenges to the standards,
holding that the EPA's PM2.5 standards were reasonably
supported by the administrative record and were not ``arbitrary and
capricious.'' American Trucking Associations v. EPA, 283 F. 3d 355,
369-72 (D.C. Cir. 2002).
3. Review Completed in 2006
In October 1997, the EPA published its plans for the third periodic
review of the air quality criteria and NAAQS for PM (62 FR 55201,
October 23, 1997). After the CASAC and public review of several drafts,
the EPA's National Center for Environmental Assessment (NCEA) finalized
the AQCD in October 2004 (U.S. EPA, 2004). The EPA's Office of Air
Quality Planning and Standards (OAQPS) finalized a Risk Assessment and
Staff Paper in December 2005 (Abt Associates, 2005, U.S. EPA, 2005).\8\
On December 20, 2005, the EPA announced its proposed decision to revise
the NAAQS for PM and solicited public comment on a broad range of
options (71 FR 2620, January 17, 2006). On September 21, 2006, the EPA
announced its final decisions to revise the primary and secondary NAAQS
for PM to provide increased protection of public health and welfare,
respectively (71 FR 61144, October 17, 2006). With regard to the
primary and secondary standards for fine particles, the EPA revised the
level of the 24-hour PM2.5 standards to 35 [micro]g/m\3\,
retained the level of the annual PM2.5 standards at 15.0
[micro]g/m\3\, and revised the form of the annual PM2.5
standards by narrowing the constraints on the optional use of spatial
averaging. With regard to the primary and secondary standards for
PM10, the EPA retained the 24-hour standards, with levels at
150 [micro]g/m\3\, and revoked the annual standards.\9\ The
Administrator judged that the available evidence generally did not
suggest a link between long-term exposure to existing ambient levels of
coarse particles and health or welfare effects. In addition, a new
reference method was added for the measurement of PM10-2.5
in the ambient air in order to provide a basis for approving federal
equivalent methods (FEMs) and to promote the gathering of scientific
data to support future reviews of the PM NAAQS.
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\8\ Prior to the review initiated in 2007, the Staff Paper
presented the EPA staff's considerations and conclusions regarding
the adequacy of existing NAAQS and, when appropriate, the potential
alternative standards that could be supported by the evidence and
information. More recent reviews present this information in the
Policy Assessment.
\9\ In the 2006 proposal, the EPA proposed to revise the 24-hour
PM10 standard in part by establishing a new
PM10-2.5 indicator for thoracic coarse particles (i.e.,
particles generally between 2.5 and 10 [micro]m in diameter). The
EPA proposed to include any ambient mix of PM10-2.5 that
was dominated by resuspended dust from high density traffic on paved
roads and by PM from industrial sources and construction sources.
The EPA proposed to exclude any ambient mix of PM10-2.5
that was dominated by rural windblown dust and soils and by PM
generated from agricultural and mining sources. In the final
decision, the existing PM10 standard was retained, in
part due to an ``inability . . . to effectively and precisely
identify which ambient mixes are included in the
[PM10-2.5] indicator and which are not'' (71 FR 61197,
October 17, 2006).
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Several parties filed petitions for review following promulgation
of the revised PM NAAQS in 2006. These petitions addressed the
following issues: (1) Selecting the level of the primary annual
PM2.5 standard; (2) retaining PM10 as the
indicator of a standard for thoracic coarse particles, retaining the
level and form of the 24-hour PM10 standard, and revoking
the PM10 annual standard; and (3) setting the secondary
PM2.5 standards identical to the primary standards. On
February 24, 2009, the D.C. Circuit issued its opinion in the case
American Farm Bureau Federation v. EPA, 559 F. 3d 512 (D.C. Cir. 2009).
The court remanded the primary annual PM2.5 NAAQS to the EPA
because the Agency had failed to adequately explain why the standards
provided the requisite protection from both short- and long-term
exposures to fine particles, including protection for at-risk
populations. Id. at 520-27. With regard to the standards for
PM10, the court upheld the EPA's decisions to retain the 24-
hour PM10 standard to provide protection from thoracic
coarse particle exposures and to revoke the annual PM10
standard. Id. at 533-38. With regard to the secondary PM2.5
standards, the court remanded the standards to the EPA because the
Agency failed to adequately explain why setting the secondary PM
standards identical to the primary standards provided the required
protection for public welfare, including protection from visibility
impairment. Id. at 528-32. The EPA responded to the court's remands as
part of the next review of the PM NAAQS, which was initiated in 2007
(discussed below).
4. Review Completed in 2012
In June 2007, the EPA initiated the fourth periodic review of the
air quality criteria and the PM NAAQS by issuing a call for information
(72 FR 35462, June 28, 2007). Based on the NAAQS review process, as
revised in 2008 and again in 2009,\10\ the EPA held science/policy
issue workshops on the primary and secondary PM NAAQS (72 FR 34003,
June 20, 2007; 72 FR 34005, June 20, 2007), and prepared and released
the planning and assessment documents that comprise the review process
(i.e., IRP (U.S. EPA, 2008), ISA (U.S. EPA, 2009c), REA planning
documents for health and welfare (U.S. EPA, 2009b, U.S. EPA, 2009a), a
quantitative health risk assessment (U.S. EPA, 2010a) and an urban-
focused visibility assessment
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(U.S. EPA, 2010a), and PA (U.S. EPA, 2011)). In June 2012, the EPA
announced its proposed decision to revise the NAAQS for PM (77 FR
38890, June 29, 2012).
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\10\ The history of the NAAQS review process, including
revisions to the process, is discussed at https://www.epa.gov/naaqs/historical-information-naaqs-review-process.
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In December 2012, the EPA announced its final decisions to revise
the primary NAAQS for PM to provide increased protection of public
health (78 FR 3086, January 15, 2013). With regard to primary standards
for PM2.5, the EPA revised the level of the annual
PM2.5 standard \11\ to 12.0 [micro]g/m\3\ and retained the
24-hour PM2.5 standard, with its level of 35 [micro]g/m\3\.
For the primary PM10 standard, the EPA retained the 24-hour
standard to continue to provide protection against effects associated
with short-term exposure to thoracic coarse particles (i.e.,
PM10-2.5). With regard to the secondary PM standards, the
EPA generally retained the 24-hour and annual PM2.5
standards \12\ and the 24-hour PM10 standard to address
visibility and non-visibility welfare effects.
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\11\ The EPA also eliminated the option for spatial averaging.
\12\ Consistent with the primary standard, the EPA eliminated
the option for spatial averaging with the annual standard.
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As with previous reviews, petitioners challenged the EPA's final
rule. Petitioners argued that the EPA acted unreasonably in revising
the level and form of the annual standard and in amending the
monitoring network provisions. On judicial review, the revised
standards and monitoring requirements were upheld in all respects. NAM
v. EPA, 750 F.3d 921 (D.C. Cir. 2014).
5. Current Review
In December 2014, the EPA announced the initiation of the current
periodic review of the air quality criteria for PM and of the
PM2.5 and PM10 NAAQS and issued a call for
information (79 FR 71764, December 3, 2014). On February 9 to 11, 2015,
the EPA's NCEA and OAQPS held a public workshop to inform the planning
for the current review of the PM NAAQS (announced in 79 FR 71764,
December 3, 2014). Workshop participants, including a wide range of
external experts as well as EPA staff representing a variety of areas
of expertise (e.g., epidemiology, human and animal toxicology, risk/
exposure analysis, atmospheric science, visibility impairment, climate
effects), were asked to highlight significant new and emerging PM
research, and to make recommendations to the Agency regarding the
design and scope of this review. This workshop provided for a public
discussion of the key science and policy-relevant issues around which
the EPA has structured the current review of the PM NAAQS and of the
most meaningful new scientific information that would be available in
this review to inform understanding of these issues.
The input received at the workshop guided the EPA staff in
developing a draft IRP, which was reviewed by the CASAC Particulate
Matter Panel and discussed on public teleconferences held in May 2016
(81 FR 13362, March 14, 2016) and August 2016 (81 FR 39043, June 15,
2016). Advice from the CASAC, supplemented by the Particulate Matter
Panel, and input from the public were considered in developing the
final IRP (U.S. EPA, 2016). The final IRP discusses the approaches to
be taken in developing key scientific, technical, and policy documents
in this review and the key policy-relevant issues.
In May 2018, the Administrator issued a memorandum describing a
``back-to-basics'' process for reviewing the NAAQS (Pruitt, 2018). This
memo announced the Agency's intention to conduct the current review of
the PM NAAQS in such a manner as to ensure that any necessary revisions
are finalized by December 2020. Following this memo, on October 10,
2018 the Administrator additionally announced that the role of
reviewing the key assessments developed as part of the ongoing review
of the PM NAAQS (i.e., drafts of the ISA and PA) would be performed by
the seven-member chartered CASAC (i.e., rather than the CASAC
Particulate Matter Panel that reviewed the draft IRP).\13\
---------------------------------------------------------------------------
\13\ The CASAC charter is available at: https://
yosemite.epa.gov/sab/sabproduct.nsf/WebCASAC/2019casaccharter/$File/
CASAC%202019%20Renewal%20Charter%203.21.19%20-%20final.pdf. The
Administrator's announcement is available at: https://archive.epa.gov/epa/newsreleases/acting-administrator-wheeler-announces-science-advisors-key-clean-air-act-committee.html.
---------------------------------------------------------------------------
The EPA released the draft ISA in October 2018 (83 FR 53471,
October 23, 2018). The draft ISA was reviewed by the chartered CASAC at
a public meeting held in Arlington, VA in December 2018 (83 FR 55529,
November 6, 2018) and was discussed on a public teleconference in March
2019 (84 FR 8523, March 8, 2019). The CASAC provided its advice on the
draft ISA in a letter to the EPA Administrator dated April 11, 2019
(Cox, 2019b). In that letter, the CASAC's recommendations address both
the draft ISA's assessment of the science for PM-related effects and
the process under which this review of the PM NAAQS is being conducted.
Regarding the assessment of the evidence, the CASAC letter states
that ``the Draft ISA does not provide a sufficiently comprehensive,
systematic assessment of the available science relevant to
understanding the health impacts of exposure to particulate matter
(PM)'' (Cox, 2019b, p. 1 of letter). The CASAC recommended that this
and other limitations (i.e., ``[i]nadequate evidence for altered causal
determinations'' and the need for a ``[c]learer discussion of causality
and causal biological mechanisms and pathways'') be remedied in a
revised ISA (Cox, 2019b, p. 1 of letter).
Given the Administrator's timeline for this review, as noted above
(Pruitt, 2018), the EPA did not prepare a second draft ISA. Rather, the
EPA has taken steps to address the CASAC's comments in the Final PM ISA
(U.S. EPA, 2019). In particular, the final ISA includes additional text
and a new appendix to clarify the comprehensive and systematic process
employed by the EPA to develop the PM ISA. In addition, several
causality determinations were re-examined and, consistent with the
CASAC advice, the final ISA reflects a revised causality determination
for long-term ultrafine particle (UFP) exposures and nervous system
effects (i.e., from ``likely to be causal'' to ``suggestive of, but not
sufficient to infer, a causal relationship'').\14\ The final ISA also
contains additional text to clarify the evidence for biological
pathways of particular PM-related effects and the role of that evidence
in causality determinations.
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\14\ Based on the CASAC's comments, the EPA also re-examined the
causality determinations for cancer and for nervous system effects
following long-term PM2.5 exposures. The EPA's
consideration of these comments in the final ISA is discussed below
in sections II.B.1.d and II.B.1.e.
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Among its comments on the process, the chartered CASAC recommended
``that the EPA reappoint the previous CASAC PM panel (or appoint a
panel with similar expertise)'' (Cox, 2019b). The Agency's response to
this advice was provided in a letter from the Administrator to the
CASAC chair dated July 25, 2019.\15\ In that letter, the Administrator
announced his intention to identify a pool of non-member subject matter
expert consultants to support the CASAC's review activities for the PM
and ozone NAAQS. A Federal Register notice requesting the nomination of
scientists from a broad range of disciplines ``with demonstrated
expertise and research in the field of air pollution related to PM and
ozone'' was published in August 2019 (84 FR 38625,
[[Page 24100]]
August 7, 2019). The Administrator selected consultants from among
those nominated, and input from members of this pool of consultants
informed the CASAC's review of the draft PA.
---------------------------------------------------------------------------
\15\ Available at: https://yosemite.epa.gov/sab/sabproduct.nsf/
0/6CBCBBC3025E13B4852583D90047B352/$File/EPA-CASAC-19-
002_Response.pdf.
---------------------------------------------------------------------------
The EPA released the draft PA in September 2019 (84 FR 47944,
September 11, 2019). The draft PA drew from the assessment of the
evidence in the draft ISA. It was reviewed by the chartered CASAC and
discussed in October 2019 at a public meeting held in Cary, NC. Public
comments were received via a separate public teleconference (84 FR
51555, September 30, 2019). A public meeting to discuss the chartered
CASAC letter and response to charge questions on the draft PA was held
in Cary, NC in December 2019 (84 FR 58713, November 1, 2019), and the
CASAC provided its advice on the draft PA, including its advice on the
current primary and secondary PM standards, in a letter to the EPA
Administrator dated December 16, 2019 (Cox, 2019a).
With regard to the primary standards, the CASAC recommended
retaining the current 24-hour PM2.5 and PM10
standards but did not reach consensus on the adequacy of the current
annual PM2.5 standard. With regard to the secondary
standards, the CASAC recommended retaining the current standards. The
CASAC's advice on the primary and secondary PM standards, and the
Administrator's consideration of that advice in reaching proposed
decisions, is discussed in detail in sections II.C.2 and II.C.3
(primary PM2.5 standards), III.C.2 and III.C.3 (primary
PM10 standards), and IV.D.2 and IV.D.3 (secondary standards)
of this document.
The CASAC additionally made a number of recommendations regarding
the information and analyses presented in the draft PA. Specifically,
the CASAC recommended that a revised PA include (1) additional
discussion of the current CASAC and NAAQS review process; (2)
additional characterization of PM-related emissions, monitoring and air
quality information, including uncertainties in that information; (3)
additional discussion and examination of uncertainties in the
PM2.5 health evidence and the risk assessment; (4) updates
to reflect changes in the ISA's causality determinations; and (5)
additional discussion of the evidence for PM-related welfare effects,
including uncertainties (Cox, 2019a, pp. 2-3 in letter). In response to
the CASAC's comments, the final PA \16\ incorporated a number of
changes, including the following (U.S. EPA, 2020):
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\16\ Given the Administrator's timeline for this review, as
noted above (Pruitt, 2018), the EPA did not prepare a second draft
PA. Rather, the CASAC's advice was considered in developing the
final PA (U.S. EPA, 2020).
---------------------------------------------------------------------------
Text was added to Chapter 1 to clarify the process
followed for this review of the PM NAAQS, including how the process has
evolved since the initiation of the review.
Text and figures were added to Chapter 2 on emissions of
PM and PM precursors, and a section discussing uncertainty in emissions
estimates was added. A discussion of measurement uncertainty for FRM,
FEM, CSN, and IMPROVE monitors was also added.
Chapter 3 and Appendices B and C include a number of
changes, including:
[cir] An expanded characterization and discussion of the evidence
related to exposure measurement error, the potential confounders
examined by key studies, the shapes of concentration-response
functions, and the results of causal inference and quasi-experimental
studies.
[cir] An expanded and clarified discussion of uncertainties in the
risk assessment, and additional air quality model performance
evaluations for each of the urban study areas included in the risk
assessment.
[cir] Additional detail on the procedure used to derive
concentration-response functions used in the risk assessment.
[cir] Changes in the text to reflect the change in the final ISA's
causality determination from ``likely to be causal'' to ``suggestive
of, but not sufficient to infer, a causal relationship.''
Throughout the document (Chapters 3, 4 and 5), summaries
of the CASAC advice on the PM standards are included, and expanded
discussions of data gaps and areas for future research in the health
and welfare effects evidence are presented.
D. Air Quality Information
This section provides a summary of basic information related to PM
ambient air quality. It summarizes information on the distribution of
particle size in ambient air (I.D.1), sources and emissions
contributing to PM in the ambient air (I.D.2), monitoring of ambient PM
in the U.S. (I.D.3), ambient PM concentrations and trends in the U.S.
(I.D.4), and background PM (I.D.5). Additional detail on PM air quality
can be found in Chapter 2 of the Policy Assessment (U.S. EPA, 2020;
PA).
1. Distribution of Particle Size in Ambient Air
In ambient air, PM is a mixture of substances suspended as small
liquid and/or solid particles (U.S. EPA, 2019, section 2.2). Particle
size is an important consideration for PM, as distinct health and
welfare effects have been linked with exposures to particles of
different sizes. Particles in the atmosphere range in size from less
than 0.01 to more than 10 [mu]m in diameter (U.S. EPA, 2019, section
2.2). When describing PM, subscripts are used to denote the aerodynamic
diameter \17\ of the particle size range, in [micro]m, of 50% cut
points of sampling devices. The EPA defines PM2.5, also
referred to as fine particles, as particles with aerodynamic diameters
generally less than or equal to 2.5 [mu]m. The size range for
PM10-2.5, also called coarse or thoracic coarse particles,
includes those particles with aerodynamic diameters generally greater
than 2.5 [mu]m and less than or equal to 10 [mu]m. PM10,
which is comprised of both fine and coarse fractions, includes those
particles with aerodynamic diameters generally less than or equal to 10
[mu]m. In addition, UFP are often defined as particles with a diameter
of less than 0.1 [mu]m based on physical size, thermal diffusivity or
electrical mobility (U.S. EPA, 2019, section 2.2).
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\17\ Aerodynamic diameter is the size of a sphere of unit
density (i.e., 1 g/cm\3\) that has the same terminal settling
velocity as the particle of interest (U.S. EPA, 2019, section
4.1.1).
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Atmospheric distributions of particle size generally exhibit
distinct modes that roughly align with the PM size fractions defined
above. The nucleation mode is made up of freshly generated particles,
formed either during combustion or by atmospheric reactions of
precursor gases. The nucleation mode is especially prominent near
sources like heavy traffic, industrial emissions, biomass burning, or
cooking (Vu et al., 2015). While nucleation mode particles are only a
minor contributor to overall ambient PM mass and surface area, they are
the main contributors to ambient particle number (U.S. EPA, 2019,
section 2.2). By number, most nucleation mode particles fall into the
UFP size range, though some fraction of the nucleation mode number
distribution can extend above 0.1 [mu]m in diameter. Nucleation mode
particles can grow rapidly through coagulation or uptake of gases by
particle surfaces, giving rise to the accumulation mode. The
accumulation mode is typically the predominant contributor to
PM2.5 mass, though only a minor contributor to particle
number (U.S. EPA, 2019, section 2.2). PM2.5 sampling methods
measure most of the accumulation mode mass, although a small fraction
of particles that make up the accumulation mode are greater than 2.5
[mu]m in diameter. Coarse mode particles are formed by mechanical
generation, and through processes like dust resuspension and sea spray
formation
[[Page 24101]]
(Whitby et al., 1972). Most coarse mode mass is captured by
PM10-2.5 sampling, but small fractions of coarse mode mass
can be smaller than 2.5 [mu]m or greater than 10 [mu]m in diameter
(U.S. EPA, 2019, section 2.2).
Most particles are found in the lower troposphere, where they can
have residence times ranging from a few hours to weeks. Particles are
removed from the atmosphere by wet deposition, such as when they are
carried by rain or snow, or by dry deposition, when particles settle
out of suspension due to gravity. Atmospheric lifetimes are generally
longest for PM2.5, which often remains in the atmosphere for
days to weeks (U.S. EPA, 2019, Table 2-1) before being removed by wet
or dry deposition. In contrast, atmospheric lifetimes for UFP and
PM10-2.5 are shorter. Within hours, UFP can undergo
coagulation and condensation that lead to formation of larger particles
in the accumulation mode, or can be removed from the atmosphere by
evaporation, deposition, or reactions with other atmospheric
components. PM10-2.5 are also generally removed from the
atmosphere within hours, through wet or dry deposition (U.S. EPA, 2019,
Table 2-1).
2. Sources and Emissions Contributing to PM in the Ambient Air
PM is composed of both primary (directly emitted particles) and
secondary particles. Primary PM is derived from direct particle
emissions from specific PM sources while secondary PM originates from
gas-phase chemical compounds present in the atmosphere that have
participated in new particle formation or condensed onto existing
particles (U.S. EPA, 2019, section 2.3). As discussed further in the
ISA (U.S. EPA, 2019, section 2.3.2.1), secondary PM is formed in the
atmosphere by photochemical oxidation reactions of both inorganic and
organic gas-phase precursors. Precursor gases include sulfur dioxide
(SO2), nitrogen oxides (NOX), and volatile
organic compounds (VOC) (U.S. EPA, 2019, section 2.3.2.1). Ammonia also
plays an important role in the formation of nitrate PM by neutralizing
sulfuric acid and nitric acid. Sources and emissions of PM are
discussed in more detail in section 2.1.1 of the PA (U.S. EPA, 2020).
Direct emissions of PM have remained relatively unchanged in recent
years, while emissions of some precursor gases have declined
substantially.\18\ From 1990 to 2014, SO2 emissions have
undergone the largest declines while NH3 emissions have
undergone the smallest change. Declining SO2 emissions
during this time period are primarily a result of reductions at
stationary sources such as EGUs, with substantial reductions also from
mobile sources (U.S. EPA, 2019, section 2.3.2.1).\19\
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\18\ More information on these trends, including details on
methods and explanations on the noted changes over time is available
at https://gispub.epa.gov/neireport/2014/.
\19\ State-specific emission trends data for 1990 to 2014 can be
found at: https://www.epa.gov/air-emissions-inventories/air-pollutant-emissions-trends-data.
---------------------------------------------------------------------------
3. Monitoring of Ambient PM
To promote uniform enforcement of the air quality standards set
forth under the CAA and to achieve the degree of public health and
welfare protection intended for the NAAQS, the EPA established PM
Federal Reference Methods (FRMs) \20\ for both PM10 and
PM2.5 (40 CFR appendix J and L to Part 50) and performance
requirements for approval of Federal Equivalent Methods (FEMs) (40 CFR
part 53). Amended following the 2006 and 2012 p.m. NAAQS reviews, the
current PM monitoring network relies on FRMs and automated continuous
FEMs, in part to support changes necessary for implementation of the
revised PM standards. The requirements for measuring ambient air
quality and reporting ambient air quality data and related information
are the basis for 40 CFR appendices A through E to Part 58. More
information on PM ambient monitoring networks is available in section
2.2 of the PA (U.S. EPA, 2020).
---------------------------------------------------------------------------
\20\ FRMs provide the methodological basis for comparison to the
NAAQS and also serve as the ``gold-standard'' for the comparison of
other methods being reviewed for potential approval as equivalent
methods. The EPA keeps a complete list of designated reference and
equivalent methods available on its Ambient Monitoring Technology
Information Center (AMTIC) website (https://www.epa.gov/amtic/air-monitoring-methods-criteria-pollutants).
---------------------------------------------------------------------------
4. Ambient Concentrations and Trends
This section summarizes available information on recent ambient PM
concentrations in the U.S. and on trends in PM air quality. Sections
I.D.4.a and I.D.4.b summarize information on PM2.5 mass and
components, respectively. Section I.D.4.c summarizes information on
PM10. Sections I.D.4.d and I.D.4.e summarize the more
limited information on PM10-2.5 and UFP, respectively.
Additional detail on PM air quality and trends can be found in section
2.3 of the PA (U.S. EPA, 2020).
a. PM2.5 Mass
At monitoring sites in the U.S., annual PM2.5
concentrations from 2015 to 2017 averaged 8.0 [mu]g/m\3\ (and ranged
from 3.0 to 18.2 [mu]g/m\3\) and the 98th percentiles of 24-hour
concentrations averaged 20.9 [mu]g/m\3\ (and ranged from 9.2 to 111
[mu]g/m\3\) (U.S. EPA, 2020, section 2.3.2.1). The highest ambient
PM2.5 concentrations occur in the west, particularly in
California and the Pacific northwest (U.S. EPA, 2020, Figure 2-8). Much
of the eastern U.S. has lower ambient concentrations, with annual
average concentrations generally at or below 12.0 [mu]g/m\3\ and 98th
percentiles of 24-hour concentrations generally at or below 30 [mu]g/
m\3\ (U.S. EPA, 2020, section 2.3.2).
Recent ambient PM2.5 concentrations reflect the
substantial reductions that have occurred across much of the U.S. (U.S.
EPA, 2020, section 2.3.2.1). From 2000 to 2017, national annual average
PM2.5 concentrations have declined from 13.5 [mu]g/m\3\ to
8.0 [mu]g/m\3\, a 41% decrease (U.S. EPA, 2020, section 2.3.2.1).\21\
These declines have occurred at urban and rural monitoring sites,
although urban PM2.5 concentrations remain consistently
higher than those in rural areas (Chan et al., 2018) due to the impact
of local sources in urban areas. Analyses at individual monitoring
sites indicate that declines in ambient PM2.5 concentrations
have been most consistent across the eastern U.S. and in parts of
coastal California, where both annual average and 98th percentiles of
24-hour concentrations have declined significantly (U.S. EPA, 2020,
section 2.3.2.1). In contrast, trends in ambient PM2.5
concentrations have been less consistent over much of the western U.S.,
with no significant changes since 2000 observed at some sites in the
Pacific northwest, the northern Rockies and plains, and the southwest,
particularly for 98th percentiles of 24-hour concentrations (U.S. EPA,
2020, section 2.3.2.1).
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\21\ See https://www.epa.gov/air-trends/particulate-matter-pm25-trends and https://www.epa.gov/air-trends/particulate-matter-pm25-trends#pmnat for more information.
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The recent deployment of PM2.5 monitors near major roads
in large urban areas provides information on PM2.5
concentrations near an important emissions source. Of the 25 CBSAs with
valid design values at near-road monitoring sites,\22\ 52% measured the
highest annual design value at the near-road site while 24% measured
the highest 24-hour design value at the near-road site (U.S. EPA, 2020,
section 2.3.2.2). Of the CBSAs with highest
[[Page 24102]]
annual design values at near-road sites, those design values were, on
average, 0.7 [mu]g/m\3\ higher than at the highest measuring non-near-
road sites (range is 0.1 to 2.0 [mu]g/m\3\ higher at near-road sites).
Although most near-road monitoring sites do not have sufficient data to
evaluate long-term trends in near-road PM2.5 concentrations,
analyses of the data at one near-road-like site in Elizabeth, NJ,\23\
show that the annual average near-road increment has generally
decreased between 1999 and 2017 from about 2.0 [mu]g/m\3\ to about 1.3
[mu]g/m\3\ (U.S. EPA, 2020, section 2.3.2.2).
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\22\ A design value is considered valid if it meets the data
handling requirements given in 40 CFR appendix N to Part 50. Several
large CBSAs such as Chicago-Naperville-Elgin, IL-IN-WI and Houston-
The Woodlands-Sugar Land, TX had near-road sites that did not have
valid PM2.5 design values for the 2015-2017 period.
\23\ The Elizabeth Lab site in Elizabeth, NJ is situated
approximately 30 meters from travel lanes of the Interchange 13 toll
plaza of the New Jersey Turnpike and within 200 meters of travel
lanes for Interstate 278 and the New Jersey Turnpike.
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b. PM2.5 Components
Based on recent air quality data, the major chemical components of
PM2.5 have distinct spatial distributions. Sulfate
concentrations tend to be highest in the eastern U.S., while in the
Ohio Valley, Salt Lake Valley, and California nitrate concentrations
are highest, and relatively high concentrations of organic carbon are
widespread across most of the continental U.S. (U.S. EPA, 2020, section
2.3.2.3). Elemental carbon, crustal material, and sea-salt are found to
have the highest concentrations in the northeast U.S., southwest U.S.,
and coastal areas, respectively.
An examination of PM2.5 composition trends can provide
insight into the factors contributing to overall reductions in ambient
PM2.5 concentrations. The biggest change in PM2.5
composition that has occurred in recent years is the reduction in
sulfate concentrations due to reductions in SO2 emissions.
Between 2000 and 2015, the nationwide annual average sulfate
concentration decreased by 17% at urban sites and 20% at rural sites.
This change in sulfate concentrations is most evident in the eastern
U.S. and has resulted in organic matter or nitrate now being the
greatest contributor to PM2.5 mass in many locations (U.S.
EPA, 2019, Figure 2-19). The overall reduction in sulfate
concentrations has contributed substantially to the decrease in
national average PM2.5 concentrations as well as the decline
in the fraction of PM10 mass accounted for by
PM2.5 (U.S. EPA, 2019, section 2.5.1.1.6; U.S. EPA, 2020,
section 2.3.1).
c. PM10
At monitoring sites in the U.S., the 2015-2017 average of 2nd
highest 24-hour PM10 concentration was 56 [mu]g/m\3\
(ranging from 18 to 173 [mu]g/m\3\) (U.S. EPA, 2020, section
2.3.2.4).\24\ The highest PM10 concentrations tend to occur
in the western U.S. Seasonal analyses indicate that ambient
PM10 concentrations are generally higher in the summer
months than at other times of year, though the most extreme high
concentration events are more likely in the spring (U.S. EPA, 2019,
Table 2-5). This is due to fact that the major PM10 emission
sources, dust and agriculture, are more active during the warmer and
drier periods of the year.
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\24\ The form of the current 24-hour PM10 standard is
one-expected-exceedance, averaged over three years.
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Recent ambient PM10 concentrations reflect reductions
that have occurred across much of the U.S. (U.S. EPA, 2020, section
2.3.2.4). From 2000 to 2017, annual second highest 24-hour
PM10 concentrations have declined by about 30% (U.S. EPA,
2020, section 2.3.2.4).\25\ These PM10 concentrations have
generally declined in the eastern U.S., while concentrations in the
much of the midwest and western U.S. have remained unchanged or
increased since 2000 (U.S. EPA, 2020, section 2.3.2.4). Analyses at
individual monitoring sites indicate that annual average
PM10 concentrations have also declined at most sites across
the U.S., with much of the decrease in the eastern U.S. associated with
reductions in PM2.5 concentrations.
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\25\ For more information, see https://www.epa.gov/air-trends/particulate-matter-pm10-trends#pmnat.
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d. PM10-2.5
Since the last review, the availability of PM10-2.5
ambient concentration data has greatly increased. As illustrated in the
PA (U.S. EPA, 2020, section 2.3.2.5), annual average and 98th
percentile PM10-2.5 concentrations exhibit less distinct
differences between the eastern and western U.S. than for either
PM2.5 or PM10. Additionally, compared to
PM2.5 and PM10, changes in PM10-2.5
concentrations have been small in magnitude and inconsistent in
direction (U.S. EPA, 2020, section 2.3.2.5).
e. UFP
Compared to PM2.5 mass, there is relatively little data
on U.S. particle number concentrations, which are dominated by UFP.
Based on measurements in two urban areas (New York City, Buffalo) and
at a background site (Steuben County) in New York, urban particle
number counts were several times higher than at the background site
(U.S. EPA, 2020, section 2.3.2.6; U.S. EPA, 2019, Figure 2-18). The
highest particle number counts in an urban area with multiple sites
(Buffalo) were observed at a near-road location.
Long-term trends in UFP are not routinely available at U.S.
monitoring sites. At one site in Illinois with long-term data
available, the annual average particle number concentration declined
between 2000 and 2017, closely matching the reductions in annual
PM2.5 mass over that same period (U.S. EPA, 2020, section
2.3.2.6). In addition, a small number of published studies have
examined UFP trends over time. While limited, these studies also
suggest that UFP number concentrations have declined over time along
with decreases in PM2.5 (U.S. EPA, 2020, section 2.3.2.6).
5. Background PM
In this review, background PM is defined as all particles that are
formed by sources or processes that cannot be influenced by actions
within the jurisdiction of concern. U.S. background PM is defined as
any PM formed from emissions other than U.S. anthropogenic (i.e.
manmade) emissions. Potential sources of U.S. background PM include
both natural sources (i.e., PM that would exist in the absence of any
anthropogenic emissions of PM or PM precursors) and transboundary
sources originating outside U.S. borders. Background PM is discussed in
more detail in section 2.4 of the PA (U.S. EPA, 2020).
At annual and national scales, estimated background PM
concentrations in the U.S. are small compared to contributions from
domestic anthropogenic emissions. For example, based on zero-out
modeling in the last review of the PM NAAQS, annual background
PM2.5 concentrations were estimated to range from 0.5-3
[micro]g/m\3\ across the sites examined. In addition, speciated
monitoring data from IMPROVE sites can provide some insights into how
contributions from different PM sources, including sources of
background PM, may have changed over time. As discussed further in the
PA (U.S. EPA, 2020, section 2.4), such data suggests that estimates of
background concentrations at IMPROVE monitors are around 1-3 [micro]g/
m\3\, and have not changed significantly since the last PM NAAQS
Review.
As discussed further in the PA (U.S. EPA, 2020, section 2.4),
sources that contribute to natural background PM include dust from the
wind erosion of natural surfaces, sea salt, wildland fires, primary
biological aerosol particles such as bacteria and pollen, oxidation of
biogenic hydrocarbons such as isoprene and terpenes to produce
secondary
[[Page 24103]]
organic aerosols (SOA), and geogenic sources such as sulfate formed
from volcanic production of SO2 and oceanic production of
dimethyl-sulfide. While most of these sources release or contribute
predominantly to fine aerosol, some sources including windblown dust,
and sea salt also produce particles in the coarse size range (U.S. EPA,
2019, section 2.3.3).
The magnitude and sources of background PM can vary widely by
region and time of year. Coastal sites may experience a consistent
contribution of PM from sea spray aerosol, while other areas covered
with dense vegetation may be impacted by biogenic aerosol production
during the summertime. Sources of background PM also operate across a
range of time scales. While some sources like biogenic aerosol vary at
monthly to seasonal scales, many sources of background PM are episodic
in nature. These episodic sources (e.g., large wildfires) can be
characterized by infrequent contributions to high-concentration events
occurring over shorter periods of time (e.g., hours to several days).
Such episodic events are sporadic and do not necessarily occur in all
years. While these exceptional episodes can lead to exceedances of the
24-hour PM2.5 standard (35 [micro]g/m\3\) in some cases
(Schweizer et al., 2017), such events are routinely screened for and
usually identifiable in the monitoring data. As described further in
the PA (U.S. EPA, 2020, section 2.4), contributions to background PM in
the U.S. result mainly from sources within North America. Contributions
from intercontinental events have also been documented (e.g., transport
from dust storms occurring in deserts in North Africa and Asia), but
these events are less frequent and represent a relatively small
fraction of background PM in most places.
II. Rationale for Proposed Decisions on the Primary PM2.5 Standards
This section provides the rationale supporting the Administrator's
proposed decisions on the primary PM2.5 standards. Section
II.A describes the Agency's approach to reaching decisions on the
primary PM2.5 standards in the last review and summarizes
the general approach to reaching proposed decisions in this review.
Section II.B summarizes the scientific evidence for PM2.5-
related health effects. Section II.C presents the Administrator's
proposed conclusions regarding the adequacy of the current primary
PM2.5 standards and his proposed decision to retain those
standards in this review.\26\
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\26\ Sections III and IV provide the rationales supporting the
Administrator's proposed decisions on the primary PM10
standard and secondary standards, respectively.
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A. General Approach
1. Approach Used in the Last Review
The last review of the primary PM NAAQS was completed in 2012 (78
FR 3086, January 15, 2013). As noted above (section 1.3), in the last
review the EPA lowered the level of the primary annual PM2.5
standard from 15.0 to 12.0 [mu]g/m\3\,\27\ and retained the existing
24-hour PM2.5 standard with its level of 35 [mu]g/m\3\. The
2012 decision to strengthen the suite of primary PM2.5
standards was based on the prior Administrator's consideration of the
extensive body of scientific evidence assessed in the 2009 ISA (U.S.
EPA, 2009c); the quantitative risk analyses presented in the 2010
health risk assessment (U.S. EPA, 2010a); the advice and
recommendations of the CASAC (Samet, 2009; Samet, 2010c; Samet, 2010b);
and public comments on the proposed rule (78 FR 3086, January 15, 2013;
U.S. EPA, 2012a). She particularly noted the ``strong and generally
robust body of evidence of serious health effects associated with both
long- and short-term exposures to PM2.5'' (78 FR 3120,
January 15, 2013). This included epidemiologic studies reporting health
effect associations based on long-term average PM2.5
concentrations ranging from about 15.0 [mu]g/m\3\ or above (i.e., at or
above the level of the then-existing annual standard) to concentrations
``significantly below the level of the annual standard'' (78 FR 3120,
January 15, 2013). Based on her ``confidence in the association between
exposure to PM2.5 and serious public health effects,
combined with evidence of such an association in areas that would meet
the current standards'' (78 FR 3120, January 15, 2013), the prior
Administrator concluded that revision of the suite of primary
PM2.5 standards was necessary in order to provide increased
public health protection.
---------------------------------------------------------------------------
\27\ The Agency also eliminated spatial averaging provisions as
part of the form of the annual standard.
---------------------------------------------------------------------------
The prior Administrator next considered what specific revisions to
the existing primary PM2.5 standards were appropriate, given
the available evidence and quantitative risk information. She
considered both the annual and 24-hour PM2.5 standards,
focusing on the basic elements of those standards (i.e., indicator,
averaging time, form, and level). These considerations, and the prior
Administrator's conclusions, are summarized in sections II.A.1.a to
II.A.1.d below.
a. Indicator
In the last review, the EPA considered issues related to the
appropriate indicator for fine particles, with a focus on evaluating
support for the existing PM2.5 mass-based indicator and for
potential alternative indicators based on the UFP fraction or on fine
particle composition (78 FR 3121, January 15, 2013).\28\ With regard to
PM2.5 mass, as in the 1997 and 2006 reviews, the health
studies available during the last review continued to link adverse
health outcomes (e.g., premature mortality, hospital admissions,
emergency department visits) with long- and short-term exposures to
fine particles indexed largely by PM2.5 mass (78 FR 3121,
January 15, 2013). With regard to the ultrafine fraction of ambient PM,
the 2011 PA noted the limited body of health evidence assessed in the
2009 ISA (summarized in U.S. EPA, 2009c, section 2.3.5 and Table 2-6)
and the limited monitoring information available to characterize
ambient concentrations of UFP (U.S. EPA, 2011, section 1.3.2). With
regard to PM composition, the 2009 ISA concluded that ``the evidence is
not yet sufficient to allow differentiation of those constituents or
sources that are more closely related to specific health outcomes''
(U.S. EPA, 2009c, pp. 2-26 and 6-212; 78 FR 3123, January 15, 2013).
The 2011 PA further noted that ``many different constituents of the
fine particle mixture as well as groups of components associated with
specific source categories of fine particles are linked to adverse
health effects'' (U.S. EPA, 2011, p. 2-55; 78 FR 3123, January 15,
2013). Consistent with the considerations and conclusions in the 2011
PA, the CASAC advised that it was appropriate to consider retaining
PM2.5 as the indicator for fine particles. In light of the
evidence and the CASAC's advice, the prior Administrator concluded that
it was ``appropriate to retain PM2.5 as the indicator for
fine particles'' (78 FR 3123, January 15, 2013).
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\28\ In the last review, the ISA defined UFP as generally
including particles with a mobility diameter less than or equal to
0.1 [micro]m. Mobility diameter is defined as the diameter of a
particle having the same diffusivity or electrical mobility in air
as the particle of interest, and is often used to characterize
particles of 0.5 [micro]m or smaller (U.S. EPA, 2009c, pp. 3-2 to 3-
3).
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[[Page 24104]]
b. Averaging Time
In 1997, the EPA set an annual PM2.5 standard to provide
protection from health effects associated with long- and short-term
exposures to PM2.5, and a 24-hour standard to supplement the
protection afforded by the annual standard (62 FR 38667 to 38668, July
18, 1997). In the 2006 review, the EPA retained both annual and 24-hour
averaging times (71 FR 61164, October 17, 2006). In the last review,
the EPA again considered issues related to the appropriate averaging
times for PM2.5 standards, with a focus on evaluating
support for the existing annual and 24-hour averaging times and for
potential alternative averaging times based on sub-daily or seasonal
metrics.
Based on the evidence assessed in the ISA, the 2011 PA noted that
the overwhelming majority of studies that had been conducted since the
2006 review continued to utilize annual (or multi-year) or 24-hour PM
averaging periods (U.S. EPA, 2011, section 2.3.2). Given this, and
limitations in the data for alternatives, the 2011 PA reached the
overall conclusions that the available information provided strong
support for considering retaining the current annual and 24-hour
averaging times (U.S. EPA, 2011, p. 2-58). The CASAC agreed that these
conclusions were reasonable (Samet, 2010a, p. 13). The prior
Administrator concurred with the PA conclusions and with the CASAC's
advice. Specifically, she judged that it was ``appropriate to retain
the current annual and 24-hour averaging times for the primary
PM2.5 standards to protect against health effects associated
with long- and short-term exposure periods'' (78 FR 3124, January 15,
2013).
c. Form
In 1997, the EPA established the form of the annual
PM2.5 standard as an annual arithmetic mean, averaged over 3
years, from single or multiple community-oriented monitors.\29\ That
is, the level of the annual standard was to be compared to measurements
made at each community-oriented monitoring site or, if specific
criteria were met, measurements from multiple community-oriented
monitoring sites could be averaged together (i.e., spatial averaging)
\30\ (62 FR 38671 to 38672, July 18, 1997). In the 1997 review, the EPA
also established the form of the 24-hour PM2.5 standard as
the 98th percentile of 24-hour concentrations at each monitor within an
area (i.e., no spatial averaging), averaged over three years (62 FR at
38671 to 38674, July 18, 1997). In the 2006 review, the EPA retained
these standard forms but tightened the criteria for using spatial
averaging with the annual standard (71 FR 61167, October 17, 2006).\31\
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\29\ In the last review, the EPA replaced the term ``community-
oriented'' monitor with the term ``area-wide'' monitor (U.S. EPA,
2020, section 1.3). Area-wide monitors are those sited at the
neighborhood scale or larger, as well as those monitors sited at
micro- or middle scales that are representative of many such
locations in the same core-based statistical area (CBSA; 78 FR 3236,
January 15, 2013). CBSAs are required to have at least one area-wide
monitor sited in the area of expected maximum PM2.5
concentration.
\30\ The original criteria for spatial averaging included: (1)
The annual mean concentration at each site shall be within 20% of
the spatially averaged annual mean, and (2) the daily values for
each monitoring site pair shall yield a correlation coefficient of
at least 0.6 for each calendar quarter (62 FR 38671 to 38672, July
18, 1997).
\31\ Specifically, the Administrator revised spatial averaging
criteria such that ``(1) [t]he annual mean concentration at each
site shall be within 10 percent of the spatially averaged annual
mean, and (2) the daily values for each monitoring site pair shall
yield a correlation coefficient of at least 0.9 for each calendar
quarter (71 FR 61167, October 17, 2006).
---------------------------------------------------------------------------
In the last review, the EPA's consideration of the form of the
annual PM2.5 standard again included a focus on the issue of
spatial averaging. An analysis of air quality and population
demographic information indicated that the highest PM2.5
concentrations in a given area tended to be measured at monitors in
locations where the surrounding populations were more likely to live
below the poverty line and to include larger percentages of racial and
ethnic minorities (U.S. EPA, 2011, p. 2-60). Based on this analysis,
the 2011 PA concluded that spatial averaging could result in
disproportionate impacts in at-risk populations, including minority
populations and populations with lower socioeconomic status (SES).
Therefore, the PA concluded that it was appropriate to consider
revising the form of the annual PM2.5 standard such that it
did not allow for the use of spatial averaging across monitors (U.S.
EPA, 2011, p. 2-60). The CASAC agreed with the PA conclusions that it
was ``reasonable'' for the EPA to eliminate the spatial averaging
provisions (Samet, 2010c, p. 2).
The prior Administrator concluded that public health would not be
protected with an adequate margin of safety in all locations, as
required by law, if disproportionately higher PM2.5
concentrations in low income and minority communities were averaged
together with lower concentrations measured at other sites in a large
urban area. Therefore, she concluded that the form of the annual
PM2.5 standard should be revised to eliminate spatial
averaging provisions (78 FR 3124, January 15, 2013).
In the last review, the EPA also considered the form of the 24-hour
PM2.5 standard. The Agency recognized that the existing 98th
percentile form for the 24-hour standard was originally selected to
provide a balance between limiting the occurrence of peak 24-hour
PM2.5 concentrations and identifying a stable target for
risk management programs.\32\ Updated air quality analyses in the last
review provided additional support for the increased stability of the
98th percentile PM2.5 concentration, compared to the 99th
percentile (U.S. EPA, 2011, Figure 2-2, p. 2-62). Consistent with the
PA conclusions based on this analysis, the prior Administrator
concluded that it was appropriate to retain the 98th percentile form
for the 24-hour PM2.5 standard (78 FR 3127, January 15,
2013).
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\32\ See ATA III, 283 F.3d at 374-76 which concludes that it is
legitimate for the EPA to consider overall stability of the standard
and its resulting promotion of overall effectiveness of NAAQS
control programs in setting a standard that is requisite to protect
the public health.
---------------------------------------------------------------------------
d. Level
The EPA's approach to considering alternative levels of the
PM2.5 standards in the last review was based on evaluating
the public health protection afforded by the annual and 24-hour
standards, taken together, against mortality and morbidity effects
associated with long-term or short-term PM2.5 exposures.
This approach recognized that it is appropriate to consider the
protection provided by attaining the air quality needed to meet the
suite of standards, and that there is no bright line clearly directing
the choice of levels. Rather, the choice of what is appropriate is a
public health policy judgment entrusted to the Administrator. See
Mississippi, 744 F.3d at 1358, Lead Industries Ass'n, 647 F.2d at 1147.
In selecting the levels of the annual and 24-hour PM2.5
standard, the prior Administrator placed the greatest emphasis on
health endpoints for which the evidence was strongest, based on the
assessment of the evidence in the ISA and on the ISA's causality
determinations (U.S. EPA, 2009c, section 2.3.1). She particularly noted
that the evidence was sufficient to conclude a causal relationship
exists between PM2.5 exposures and mortality and
cardiovascular effects (i.e., for both long- and short-term exposures)
and that the evidence was sufficient to conclude a causal relationship
is ``likely'' to exist between PM2.5 exposures and
respiratory effects (i.e., for both long-
[[Page 24105]]
and short-term exposures). She also noted additional, but more limited,
evidence for a broader range of health endpoints, including evidence
``suggestive of a causal relationship'' between long-term exposures and
developmental and reproductive effects as well as carcinogenic effects
(78 FR 3158, January 15, 2013).
To inform her decisions on an appropriate level for the annual
standard, the prior Administrator considered the degree to which
epidemiologic studies indicate confidence in the reported health effect
associations over distributions of ambient PM2.5
concentrations. She noted that a level of 12.0 [micro]g/m\3\ was below
the long-term mean PM2.5 concentrations reported in key
epidemiologic studies that provided evidence of an array of serious
health effects (78 FR 3161, January 15, 2013). She further noted that
12.0 [micro]g/m\3\ generally corresponded to the lower portions (i.e.,
about the 25th percentile) of distributions of health events in the
limited number of epidemiologic studies for which population-level
information was available. A level of 12.0 [micro]g/m\3\ also reflected
placing some weight on studies of reproductive and developmental
effects, for which the evidence was more uncertain (78 FR 3161-3162,
January 15, 2013).\33\
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\33\ With respect to cancer, mutagenic, and genotoxic effects,
the Administrator observed that the PM2.5 concentrations
reported in studies evaluating these effects generally included
ambient concentrations that are equal to or greater than ambient
concentrations observed in studies that reported mortality and
cardiovascular and respiratory effects (U.S. EPA, 2009c, section
7.5). Therefore, the Administrator concluded that, in selecting a
standard level that provides protection from mortality and
cardiovascular and respiratory effects, it is reasonable to
anticipate that protection will also be provided for carcinogenic
effects (78 FR 3161-3162, January 15, 2013).
---------------------------------------------------------------------------
Given the uncertainties remaining in the scientific information,
the prior Administrator judged that an annual standard level below 12.0
[micro]g/m\3\ was not supported. She specifically noted uncertainties
related to understanding the relative toxicity of the different
components in the fine particle mixture, the role of PM2.5
in the complex ambient mixture, exposure measurement errors in
epidemiologic studies, and the nature and magnitude of estimated risks
at relatively low ambient PM2.5 concentrations. Furthermore,
she noted that epidemiologic studies had reported heterogeneity in
responses both within and between cities and in geographic regions
across the U.S. She recognized that this heterogeneity may be
attributed, in part, to differences in fine particle composition in
different regions and cities. With regard to evidence for reproductive
and developmental effects, the prior Administrator recognized that
there were a number of limitations associated with this body of
evidence, including the following: The limited number of studies
evaluating such effects; uncertainties related to identifying the
relevant exposure time periods of concern; and limited toxicological
evidence providing little information on the mode of action(s) or
biological plausibility for an association between long-term
PM2.5 exposures and adverse birth outcomes. On balance, she
found that the available evidence, interpreted in light of these
remaining uncertainties, did not justify an annual standard level set
below 12.0 [micro]g/m\3\ as being ``requisite'' to protect public
health with an adequate margin of safety (i.e., a standard with a lower
level would have been more stringent than necessary).
In conjunction with a revised annual standard with a level of 12.0
[micro]g/m\3\, the prior Administrator concluded that the evidence
supported retaining the 35 [micro]g/m\3\ level of the 24-hour
PM2.5 standard. She noted that the existing 24-hour
standard, with its 35 [micro]g/m\3\ level and 98th percentile form,
would provide supplemental protection, particularly for areas with high
peak-to-mean ratios possibly associated with strong seasonal sources
and for areas with PM2.5-related effects that may be
associated with shorter than daily exposure periods (78 FR 3163,
January 15, 2013). Thus, she concluded that the available evidence and
information, interpreted in light of remaining uncertainties, supported
an annual standard with a level of 12.0 [micro]g/m\3\ combined with a
24-hour standard with a level of 35 [micro]g/m\3\.
2. Approach in the Current Review
The EPA's approach to reaching proposed decisions on the primary
PM2.5 standards in the current review builds on the
decisions made in the last review. Consistent with that review, the
approach focuses on evaluating the public health protection afforded by
the annual and 24-hour standards, taken together, against mortality and
morbidity associated with long-term or short-term PM2.5
exposures. As discussed in the PA (U.S. EPA, 2020, section 3.1.2), in
adopting this approach the EPA recognizes that changes in
PM2.5 air quality designed to meet an annual standard would
likely result not only in lower annual average PM2.5
concentrations, but also in fewer and lower short-term peak
PM2.5 concentrations. Additionally, changes designed to meet
a 24-hour standard, with a 98th percentile form, would result not only
in fewer and lower peak 24-hour PM2.5 concentrations, but
also in lower annual average PM2.5 concentrations. Thus, the
EPA's approach recognizes that it is appropriate to consider the
protection provided by attaining the air quality needed to meet the
suite of standards.
This approach to reviewing the primary PM2.5 standards
is based most fundamentally on considering the available scientific
evidence and technical information as assessed and discussed in the ISA
(U.S. EPA, 2019) and PA (U.S. EPA, 2020), including the uncertainties
inherent in that evidence and information, and on consideration of
advice received from the CASAC in this review (Cox, 2019a). The EPA
emphasizes the health outcomes for which the ISA determines that the
evidence supports either a ``causal'' or a ``likely to be causal''
relationship with PM2.5 exposures (U.S. EPA, 2019). This
approach focuses proposed decisions on the health outcomes for which
the evidence is strongest. Such a focus, which is supported by the
CASAC (Cox, 2019a, p. 12 of consensus responses), recognizes that
standards set based on evidence supporting ``causal'' and ``likely to
be causal'' health outcomes will also provide some measure of
protection against the broader range of PM2.5-associated
outcomes, including those for which the evidence is less certain.
As in past reviews, the EPA's approach recognizes that there is no
bright line clearly directing the choice of standards. Rather, the
choice of what is appropriate is a public health policy judgment
entrusted to the Administrator. Specifically, the CAA requires primary
standards that, in the judgment of the Administrator, are requisite to
protect public health with an adequate margin of safety. In setting
primary standards that are ``requisite'' to protect public health, the
EPA's task is to establish standards that are neither more nor less
stringent than necessary for this purpose. Thus, as discussed above
(I.A), the CAA does not require that primary standards be set at a
zero-risk level, but rather at a level that, in the judgment of the
Administrator, limits risk sufficiently so as to protect public health
with an adequate margin of safety. As in previous reviews, this
judgment includes consideration of the strengths and limitations of the
scientific and technical information, and the appropriate inferences to
be drawn from that information.
[[Page 24106]]
B. Health Effects Related to Fine Particle Exposures
This section draws from the EPA's synthesis and assessment of the
scientific evidence presented in the ISA (U.S. EPA, 2019) and the
summary of that evidence in the PA (U.S. EPA, 2020, section 3.2.1). The
ISA uses a weight-of-evidence framework for characterizing the strength
of the available scientific evidence for health effects attributable to
PM exposures (U.S. EPA, 2015, Preamble, Section 5). As in the last
review (U.S. EPA, 2009c), the ISA for this review has adopted a five-
level hierarchy to classify the overall weight-of-evidence into one of
the following categories: Causal relationship; a likely to be causal
relationship; suggestive of, but not sufficient to infer, a causal
relationship; \34\ inadequate to infer the presence or absence of a
causal relationship; and not likely to be a causal relationship (U.S.
EPA, 2015, Preamble Table II). In using the weight-of-evidence approach
to inform judgments about the likelihood that various health effects
are caused by PM exposures, evidence is evaluated for major outcome
categories or groups of related outcomes (e.g., respiratory effects),
integrating evidence from across disciplines, including epidemiologic,
controlled human exposure, and animal toxicological studies and
evaluating the coherence of evidence across a spectrum of related
endpoints as well as biological plausibility of the effects observed
(U.S. EPA, 2015, Preamble, Section 5.c.). Based on application of this
approach, the EPA believes that the final ISA ``accurately reflects the
latest scientific knowledge useful in indicating the kind and extent of
all identifiable effects on public health or welfare which may be
expected from the presence of [PM] in the ambient air, in varying
quantities'' as required by the CAA (42 U.S.C. 7408(a)(2)).
---------------------------------------------------------------------------
\34\ As noted in the 2019 p.m. ISA (U.S. EPA, 2019, p. ES-15),
this causality determination language has been updated since the
last review.
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In this review of the NAAQS, the EPA considers the full body of
health evidence, placing the greatest emphasis on the health effects
for which the evidence has been judged in the ISA to demonstrate a
``causal'' or a ``likely to be causal'' relationship with PM exposures.
The ISA defines these causality determinations as follows (U.S. EPA,
2019, p. p-20):
Causal relationship: The pollutant has been shown to
result in health effects at relevant exposures based on studies
encompassing multiple lines of evidence and chance, confounding, and
other biases can be ruled out with reasonable confidence.
Likely to be a causal relationship: There are studies in
which results are not explained by chance, confounding, or other
biases, but uncertainties remain in the health effects evidence
overall. For example, the influence of co-occurring pollutants is
difficult to address, or evidence across scientific disciplines may be
limited or inconsistent.
The sections below briefly summarize the health effects evidence
determined in the ISA to support either a ``causal'' or a ``likely to
be causal'' relationship with fine particle exposures (II.B.1), the
populations potentially at increased risk for PM-related effects
(II.B.2), and the CASAC's advice on the draft ISA (II.B.3). Additional
detail on these topics can be found in the ISA (U.S. EPA, 2019) and in
the PA (U.S. EPA, 2020, section 3.2).
1. Nature of Effects
Drawing from the assessment of the evidence in the ISA (U.S. EPA,
2019), and the summaries of that assessment in the PA (U.S. EPA, 2020),
the sections below summarize the evidence for relationships between
long- or short-term PM2.5 exposures and mortality
(II.B.1.a), cardiovascular effects (II.B.1.b), respiratory effects
(II.B.1.c), cancer (II.B.1.d), and nervous system effects (II.B.1.e).
For these outcomes, the ISA concludes that the evidence supports either
a ``causal'' or a ``likely to be causal'' relationship with
PM2.5 exposures.
a. Mortality
i. Long-term PM2.5 exposures
In the last review, the 2009 PM ISA reported that the evidence was
``sufficient to conclude that the relationship between long-term
PM2.5 exposures and mortality is causal'' (U.S. EPA, 2009c,
p. 7-96). The strongest evidence supporting this conclusion was
provided by epidemiologic studies, particularly those examining two
seminal cohorts, the American Cancer Society (ACS) cohort and the
Harvard Six Cities cohort. Analyses of the Harvard Six Cities cohort
included demonstrations that reductions in ambient PM2.5
concentrations are associated with reduced mortality risk (Laden et
al., 2006) and with increases in life expectancy (Pope et al., 2009).
Further support was provided by other cohort studies conducted in North
America and Europe that also reported positive associations between
long-term PM2.5 exposures and risk of mortality (U.S. EPA,
2009c).
Recent cohort studies, which have become available since the 2009
ISA, continue to provide consistent evidence of positive associations
between long-term PM2.5 exposures and mortality. These
studies add support for associations with total and non-accidental
mortality,\35\ as well as with specific causes of death, including
cardiovascular disease and respiratory disease (U.S. EPA, 2019, section
11.2.2). Many of these recent studies have extended the follow-up
periods originally evaluated in the ACS and Harvard Six Cities cohort
studies and continue to observe positive associations between long-term
PM2.5 exposures and mortality (U.S. EPA, 2019, section
11.2.2.1; Figures 11-18 and 11-19). Adding to recent evaluations of the
ACS and Six Cities cohorts, studies conducted with other cohorts also
show consistent, positive associations between long-term
PM2.5 exposure and mortality across various demographic
groups (e.g., age, sex, occupation), spatial and temporal extents,
exposure assessment metrics, and statistical techniques (U.S. EPA,
2019, sections 11.2.2.1, 11.2.5). This includes some of the largest
cohort studies conducted to date, with analyses of the U.S. Medicare
cohort that include nearly 61 million enrollees (Di et al., 2017b) and
studies that control for a range of individual and ecological
covariates.
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\35\ The majority of these studies examined non-accidental
mortality outcomes, though some Medicare studies lack cause-specific
death information and, therefore, examine total mortality.
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A recent series of retrospective studies has additionally tested
the hypothesis that past reductions in ambient PM2.5
concentrations have been associated with increased life expectancy or a
decreased mortality rate (U.S. EPA, 2019, section 11.2.2.5). Pope et
al. (2009) conducted a cross-sectional analysis using air quality data
from 51 metropolitan areas across the U.S., beginning in the 1970s
through the early 2000s, and found that a 10 [micro]g/m\3\ decrease in
long-term PM2.5 concentration was associated with a 0.61-
year increase in life expectancy. In a subsequent analysis, the authors
extended the period of analysis to include 2000 to 2007 (Correia et
al., 2013), a time period with lower ambient PM2.5
concentrations. In this follow-up study, a decrease in long-term
PM2.5 concentration continued to be associated with an
increase in life expectancy, though the magnitude of the increase was
smaller than during the earlier time period (i.e., a 10 [micro]g/m\3\
decrease in long-term PM2.5
[[Page 24107]]
concentration was associated with a 0.35-year increase in life
expectancy). Additional studies conducted in the U.S. or Europe
similarly report that reductions in ambient PM2.5 are
associated with improvements in longevity (U.S. EPA, 2019, section
11.2.2.5).
The 2019 ISA specifically evaluates the degree to which recent
studies that examine the relationship between long-term
PM2.5 exposure and mortality have addressed key policy-
relevant issues and/or previously identified data gaps in the
scientific evidence. For example, based on its assessment of the
evidence, the ISA concludes that positive associations between long-
term PM2.5 exposures and mortality are robust across
analyses examining a variety of study designs (e.g., U.S. EPA, 2019,
section 11.2.2.4), approaches to estimating PM2.5 exposures
(U.S. EPA, 2019, section 11.2.5.1), approaches to controlling for
confounders (U.S. EPA, 2019, sections 11.2.3 and 11.2.5), geographic
regions and populations, and temporal periods (U.S. EPA, 2019, sections
11.2.2.5 and 11.2.5.3). Recent evidence further demonstrates that
associations with mortality remain robust in copollutant analyses (U.S.
EPA, 2019, section 11.2.3), and that associations persist in analyses
restricted to long-term exposures below 12 [mu]g/m\3\ (Di et al.,
2017b) or 10 [mu]g/m\3\ (Shi et al., 2016).
An additional important consideration in characterizing the public
health impacts associated with PM2.5 exposure is whether
concentration-response relationships are linear across the range of
concentrations or if nonlinear relationships exist along any part of
this range. Several recent studies examine this issue, and continue to
provide evidence of linear, no-threshold relationships between long-
term PM2.5 exposures and all-cause and cause-specific
mortality (U.S. EPA, 2019, section 11.2.4). However, interpreting the
shapes of these relationships, particularly at PM2.5
concentrations near the lower end of the air quality distribution, can
be complicated by relatively low data density in the lower
concentration range, the possible influence of exposure measurement
error, and variability among individuals with respect to air pollution
health effects. These sources of variability and uncertainty tend to
smooth and ``linearize'' population-level concentration-response
functions, and thus could obscure the existence of a threshold or
nonlinear relationship (U.S. EPA, 2015, Preamble section 6.c).
The biological plausibility of PM2.5-attributable
mortality is supported by the coherence of effects across scientific
disciplines (i.e., animal toxicological, controlled human exposure
studies, and epidemiologic), including in recent studies evaluating the
morbidity effects that are the largest contributors to total
(nonaccidental) mortality. The ISA outlines the available evidence for
plausible pathways by which inhalation exposure to PM2.5
could progress from initial events (e.g., respiratory tract
inflammation, autonomic nervous system modulation) to endpoints
relevant to population outcomes, particularly those related to
cardiovascular diseases such as ischemic heart disease, stroke and
atherosclerosis (U.S. EPA, 2019, section 6.2.1), and to metabolic
disease and diabetes (U.S. EPA, 2019, section 7.2.1). The ISA notes
``more limited evidence from respiratory morbidity'' (U.S. EPA, 2019,
p. 11-101) to support the biological plausibility of mortality due to
long-term PM2.5 exposures (U.S. EPA, 2019, section 11.2.1).
Taken together, recent studies reaffirm and further strengthen the
body of evidence from the 2009 ISA for the relationship between long-
term PM2.5 exposure and mortality. Recent epidemiologic
studies consistently report positive associations with mortality across
different geographic locations, populations, and analytic approaches.
Such studies reduce key uncertainties identified in the last review,
including those related to potential copollutant confounding, and
provide additional information on the shape of the concentration-
response curve. Recent experimental and epidemiologic evidence for
cardiovascular effects, and respiratory effects to a more limited
degree, supports the plausibility of mortality due to long-term
PM2.5 exposures. The 2019 ISA concludes that,
``collectively, this body of evidence is sufficient to conclude that a
causal relationship exists between long-term PM2.5 exposure
and total mortality'' (U.S. EPA, 2019, section 11.2.7; p. 11-102).
ii. Short-term PM2.5 exposures
The 2009 PM ISA concluded that ``a causal relationship exists
between short-term exposure to PM2.5 and mortality'' (U.S.
EPA, 2009c). This conclusion was based on the evaluation of both multi-
and single-city epidemiologic studies that consistently reported
positive associations between short-term PM2.5 exposure and
non-accidental mortality. These associations were strongest, in terms
of magnitude and precision, primarily at lags of 0 to 1 days.
Examination of the potential confounding effects of gaseous
copollutants was limited, though evidence from single-city studies
indicated that gaseous copollutants have minimal effect on the
PM2.5-mortality relationship (i.e., associations remain
robust to inclusion of other pollutants in copollutant models). The
evaluation of cause-specific mortality found that effect estimates were
larger in magnitude, but also had larger confidence intervals, for
respiratory mortality compared to cardiovascular mortality. Although
the largest mortality risk estimates were for respiratory mortality,
the interpretation of the results was complicated by the limited
coherence from studies of respiratory morbidity. However, the evidence
from studies of cardiovascular morbidity provided both coherence and
biological plausibility for the relationship between short-term
PM2.5 exposure and cardiovascular mortality.
Recent multicity studies evaluated since the 2009 ISA continue to
provide evidence of primarily positive associations between daily
PM2.5 exposures and mortality, with percent increases in
total mortality ranging from 0.19% (Lippmann et al., 2013) to 2.80%
(Kloog et al., 2013) \36\ at lags of 0 to 1 days in single-pollutant
models. Whereas most studies rely on assigning exposures using data
from ambient monitors, associations are also reported in recent studies
that employ hybrid modeling approaches using additional
PM2.5 data (i.e., from satellites, land use information, and
modeling, in addition to monitors), allowing for the inclusion of more
rural locations in analyses (Kloog et al., 2013, Shi et al., 2016, Lee
et al., 2015).
---------------------------------------------------------------------------
\36\ As detailed in the Preface to the ISA, risk estimates are
for a 10 [micro]g/m\3\ increase in 24-hour avg PM2.5
concentrations, unless otherwise noted (U.S. EPA, 2019).
---------------------------------------------------------------------------
Some recent studies have expanded the examination of potential
confounders (e.g., U.S. EPA, 2019, section 11.1.5.1), including
copollutants. Associations between short-term PM2.5
exposures and mortality remain positive and relatively unchanged in
copollutant models with both gaseous pollutants and PM10-2.5
(U.S. EPA, 2019, Section 11.1.4). Additionally, the low (r < 0.4) to
moderate correlations (r = 0.4-0.7) between PM2.5 and
gaseous pollutants and PM10-2.5 increase the confidence in
PM2.5 having an independent effect on mortality (U.S. EPA,
2019, section 11.1.4).
The generally positive associations reported with mortality are
supported
[[Page 24108]]
by a small group of studies employing causal inference or quasi-
experimental statistical approaches (U.S. EPA, 2019, section 11.1.2.1).
For example, a recent study examines whether a specific regulatory
action in Tokyo, Japan (i.e., a diesel emission control ordinance)
resulted in a subsequent reduction in daily mortality (Yorifuji et al.,
2016). The authors report a reduction in mortality in Tokyo due to the
ordinance, compared to Osaka, which did not have a similar diesel
emission control ordinance in place.
The positive associations for total mortality reported across the
majority of studies evaluated are further supported by analyses
reporting generally consistent, positive associations with both
cardiovascular and respiratory mortality (U.S. EPA, 2019, section
11.1.3). For both cardiovascular and respiratory mortality, there has
been only limited assessment of potential copollutant confounding,
though initial evidence indicates that associations remain positive and
relatively unchanged in models with gaseous pollutants and
PM10-2.5. This evidence further supports the copollutant
analyses conducted for total mortality. The evidence for ischemic
events and heart failure, as detailed in the assessment of
cardiovascular morbidity (U.S. EPA, 2019, Chapter 6), provides
biological plausibility for PM2.5-related cardiovascular
mortality, which comprises the largest percentage of total mortality
(i.e., ~33%) (U.S. National Institutes of Health, 2013). Although there
is evidence for exacerbations of chronic obstructive pulmonary disease
(COPD) and asthma, the collective body of evidence, particularly from
controlled human exposure studies of respiratory effects, provides only
limited support for the biological plausibility of PM2.5-
related respiratory mortality (U.S. EPA, 2019, Chapter 5).
In the 2009 ISA, one of the main uncertainties identified was the
regional and city-to-city heterogeneity in PM2.5-mortality
associations. Recent studies examine both city-specific as well as
regional characteristics to identify the underlying contextual factors
that could contribute to this heterogeneity (U.S. EPA, 2019, section
11.1.6.3). Analyses focusing on effect modification of the
PM2.5-mortality relationship by PM2.5 components,
regional patterns in PM2.5 components and city-specific
differences in composition and sources indicate some differences in the
PM2.5 composition and sources across cities and regions, but
these differences do not fully explain the observed heterogeneity.
Additional studies find that factors related to potential exposure
differences, such as housing stock and commuting, as well as city-
specific factors (e.g., land-use, port volume, and traffic
information), may explain some of the observed heterogeneity (U.S. EPA,
2019, section 11.1.6.3). Collectively, recent studies indicate that the
heterogeneity in PM2.5-mortality risk estimates cannot be
attributed to one factor, but instead a combination of factors
including, but not limited to, PM composition and sources as well as
community characteristics that could influence exposures (U.S. EPA,
2019, section 11.1.12).
A number of recent studies conducted systematic evaluations of the
lag structure of associations for the PM2.5-mortality
relationship by examining either a series of single-day or multiday
lags and these studies continue to support an immediate effect (i.e.,
lag 0 to 1 days) of short-term PM2.5 exposures on mortality
(U.S. EPA, 2019, section 11.1.8.1). Recent studies also conducted
analyses comparing the traditional 24-hour average exposure metric with
a sub-daily metric (i.e., 1-hour max). These initial studies provide
evidence of a similar pattern of associations for both the 24-hour
average and 1-hour max metric, with the association larger in magnitude
for the 24-hour average metric.
Recent multicity studies indicate that positive and statistically
significant associations with mortality persist in analyses restricted
to short-term PM2.5 exposures below 35 [mu]g/m\3\ (Lee et
al., 2015),\37\ below 30 [mu]g/m\3\ (Shi et al., 2016), and below 25
[mu]g/m\3\ (Di et al., 2017a). Additional studies examine the shape of
the concentration-response relationship and whether a threshold exists
specifically for PM2.5 (U.S. EPA, 2019, section 11.1.10).
These studies have used various statistical approaches and consistently
found linear relationships with no evidence of a threshold. Recent
analyses provide initial evidence indicating that PM2.5-
mortality associations persist and may be stronger (i.e., a steeper
slope) at lower concentrations (e.g., Di et al., 2017a; Figure 11-12 in
U.S. EPA, 2019). However, given the limited data available at the lower
end of the distribution of ambient PM2.5 concentrations, the
shape of the concentration-response curve remains uncertain at these
low concentrations and, to date, studies have not conducted extensive
analyses exploring alternatives to linearity when examining the shape
of the PM2.5-mortality concentration-response relationship.
---------------------------------------------------------------------------
\37\ Lee et al. (2015) also report that positive and
statistically significant associations between short-term
PM2.5 exposures and mortality persist in analyses
restricted to areas with long-term concentrations below 12 [mu]g/
m\3\.
---------------------------------------------------------------------------
Overall, recent epidemiologic studies build upon and extend the
conclusions of the 2009 ISA for the relationship between short-term
PM2.5 exposures and total mortality. Supporting evidence for
PM2.5-related cardiovascular morbidity, and more limited
evidence from respiratory morbidity, provides biological plausibility
for mortality due to short-term PM2.5 exposures. The
primarily positive associations observed across studies conducted in
diverse geographic locations is further supported by the results from
co-pollutant analyses indicating robust associations, along with
evidence from analyses of the concentration-response relationship. The
2019 ISA states that, collectively, ``this body of evidence is
sufficient to conclude that a causal relationship exists between short-
term PM2.5 exposure and total mortality'' (U.S. EPA, 2019,
pp. 11-58).
b. Cardiovascular Effects
i. Long-Term PM2.5 Exposures
The scientific evidence reviewed in the 2009 PM ISA was
``sufficient to infer a causal relationship between long-term
PM2.5 exposure and cardiovascular effects'' (U.S. EPA,
2009c). The strongest line of evidence comprised findings from several
large epidemiologic studies of U.S. cohorts that consistently showed
positive associations between long-term PM2.5 exposure and
cardiovascular mortality (Pope et al., 2004, Krewski et al., 2009,
Miller et al., 2007, Laden et al., 2006). Studies of long-term
PM2.5 exposure and cardiovascular morbidity were limited in
number. Biological plausibility and coherence with the epidemiologic
findings were provided by studies using genetic mouse models of
atherosclerosis demonstrating enhanced atherosclerotic plaque
development and inflammation, as well as changes in measures of
impaired heart function, following 4- to 6-month exposures to
PM2.5 concentrated ambient particles (CAPs), and by a
limited number of studies reporting CAPs-induced effects on coagulation
factors, vascular reactivity, and worsening of experimentally induced
hypertension in mice (U.S. EPA, 2009c).
Studies conducted since the last review continue to support the
relationship between long-term exposure to PM2.5 and
cardiovascular effects. As discussed above, results from recent U.S.
and Canadian cohort studies consistently report positive associations
between long-term PM2.5 exposure and cardiovascular
mortality (U.S. EPA, 2019, Figure 6-19) in evaluations
[[Page 24109]]
conducted at varying spatial scales and employing a variety of exposure
assessment and statistical methods (U.S. EPA, 2019, section 6.2.10).
Positive associations between long-term PM2.5 exposures and
cardiovascular mortality are generally robust in copollutant models
adjusted for ozone, NO2, PM10-2.5, or
SO2. In addition, most of the results from analyses
examining the shape of the concentration-response relationship for
cardiovascular mortality support a linear relationship with long-term
PM2.5 exposures and do not identify a threshold below which
effects do not occur (U.S. EPA, 2019, section 6.2.16; Table 6-52).\38\
---------------------------------------------------------------------------
\38\ As noted above for mortality, uncertainty in the shape of
the concentration-response relationship increases near the upper and
lower ends of the concentration distribution where the data are
limited.
---------------------------------------------------------------------------
The body of literature examining the relationship between long-term
PM2.5 exposure and cardiovascular morbidity has greatly
expanded since the 2009 PM ISA, with positive associations reported in
several cohorts (U.S. EPA, 2019, section 6.2). Though results for
cardiovascular morbidity are less consistent than those for
cardiovascular mortality (U.S. EPA, 2019, section 6.2), recent studies
provide some evidence for associations between long-term
PM2.5 exposures and the progression of cardiovascular
disease. Positive associations with cardiovascular morbidity (e.g.,
coronary heart disease, stroke) and atherosclerosis progression (e.g.,
coronary artery calcification) are observed in several epidemiologic
studies (U.S. EPA, 2019, sections 6.2.2. to 6.2.9). Associations in
such studies are supported by toxicological evidence for increased
plaque progression in mice following long-term exposure to
PM2.5 collected from multiple locations across the U.S.
(U.S. EPA, 2019, section 6.2.4.2). A small number of epidemiologic
studies also report positive associations between long-term
PM2.5 exposure and heart failure, changes in blood pressure,
and hypertension (U.S. EPA, 2019, sections 6.2.5 and 6.2.7).
Associations with heart failure are supported by animal toxicological
studies demonstrating decreased cardiac contractility and function, and
increased coronary artery wall thickness following long-term
PM2.5 exposure (U.S. EPA, 2019, section 6.2.5.2). Similarly,
a limited number of animal toxicological studies demonstrating a
relationship between long-term exposure to PM2.5 and
consistent increases in blood pressure in rats and mice are coherent
with epidemiologic studies reporting positive associations between
long-term exposure to PM2.5 and hypertension.
Longitudinal epidemiologic analyses also report positive
associations with markers of systemic inflammation (U.S. EPA, 2019,
section 6.2.11), coagulation (U.S. EPA, 2019, section 6.2.12), and
endothelial dysfunction (U.S. EPA, 2019, section 6.2.13). These results
are coherent with animal toxicological studies generally reporting
increased markers of systemic inflammation, oxidative stress, and
endothelial dysfunction (U.S. EPA, 2019, section 6.2.12.2 and 6.2.14).
In summary, the 2019 ISA concludes that there is consistent
evidence from multiple epidemiologic studies illustrating that long-
term exposure to PM2.5 is associated with mortality from
cardiovascular causes. Associations with CHD, stroke and
atherosclerosis progression were observed in several additional
epidemiologic studies providing coherence with the mortality findings.
Results from copollutant models generally support an independent effect
of PM2.5 exposure on mortality. Additional evidence of the
independent effect of PM2.5 on the cardiovascular system is
provided by experimental studies in animals, which support the
biological plausibility of pathways by which long-term exposure to
PM2.5 could potentially result in outcomes such as CHD,
stroke, CHF and cardiovascular mortality. The combination of
epidemiologic and experimental evidence results in the ISA conclusion
that ``a causal relationship exists between long-term exposure to
PM2.5 and cardiovascular effects'' (U.S. EPA, 2019, p. 6-
222).
ii. Short-Term PM2.5 Exposures
The 2009 PM ISA concluded that ``a causal relationship exists
between short-term exposure to PM2.5 and cardiovascular
effects'' (U.S. EPA, 2009c). The strongest evidence in the 2009 PM ISA
was from epidemiologic studies of emergency department visits and
hospital admissions for ischemic heart disease (IHD) and heart failure
(HF), with supporting evidence from epidemiologic studies of
cardiovascular mortality (U.S. EPA, 2009c). Animal toxicological
studies provided coherence and biological plausibility for the positive
associations reported with myocardial ischemia, emergency department
visits, and hospital admissions. These included studies reporting
reduced myocardial blood flow during ischemia and studies indicating
altered vascular reactivity. In addition, effects of PM2.5
exposure on a potential indicator of ischemia (i.e., ST segment
depression on an electrocardiogram) were reported in both animal
toxicological and epidemiologic panel studies.\39\ Key uncertainties
from the last review resulted from inconsistent results across
disciplines with respect to the relationship between short-term
exposure to PM2.5 and changes in blood pressure, blood
coagulation markers, and markers of systemic inflammation. In addition,
while the 2009 PM ISA identified a growing body of evidence from
controlled human exposure and animal toxicological studies,
uncertainties remained with respect to biological plausibility.
---------------------------------------------------------------------------
\39\ Some animal studies included in the 2009 PM ISA examined
exposures to mixtures, such as motor vehicle exhaust or woodsmoke.
In these studies, it was unclear if the resulting cardiovascular
effects could be attributed specifically to the particulate
components of the mixture.
---------------------------------------------------------------------------
A large body of recent evidence confirms and extends the evidence
from the 2009 ISA supporting the relationship between short-term
PM2.5 exposure and cardiovascular effects. This includes
generally positive associations observed in multicity epidemiologic
studies of emergency department visits and hospital admissions for IHD,
HF, and combined cardiovascular-related endpoints. In particular,
nationwide studies of older adults (65 years and older) using Medicare
records report positive associations between PM2.5 exposures
and hospital admissions for HF (U.S. EPA, 2019, section 6.1.3.1).
Additional multicity studies conducted in the northeast U.S. report
positive associations between short-term PM2.5 exposures and
emergency department visits or hospital admissions for IHD (U.S. EPA,
2019, section 6.1.2.1) while studies conducted in the U.S. and Canada
reported positive associations between short-term PM2.5
exposures and emergency department visits for HF. Epidemiologic studies
conducted in single cities contribute some support, though associations
reported in single-city studies are less consistently positive than in
multicity studies, and include a number of studies reporting null
associations (U.S. EPA, 2019, sections 6.1.2 and 6.1.3). When
considered as a whole; however, the recent body of IHD and HF
epidemiologic evidence supports the evidence from previous ISAs
reporting mainly positive associations between short-term
PM2.5 concentrations and emergency department visits and
hospital admissions.
In addition, a number of more recent controlled human exposure,
animal toxicological, and epidemiologic panel studies provide evidence
that PM2.5
[[Page 24110]]
exposure could plausibly result in IHD or HF through pathways that
include endothelial dysfunction, arterial thrombosis, and arrhythmia
(U.S. EPA, 2019, section 6.1.1). The most consistent evidence from
recent controlled human exposure studies is for endothelial
dysfunction, as measured by changes in brachial artery diameter or flow
mediated dilation. All but one of the available controlled human
exposure studies examining the potential for endothelial dysfunction
report an effect of PM2.5 exposure on measures of blood flow
(U.S. EPA, 2019, section 6.1.13.2). These studies report variable
results regarding the timing of the effect and the mechanism by which
reduced blood flow occurs (i.e., availability vs sensitivity to nitric
oxide). Some controlled human exposure studies using PM2.5
CAPs report evidence for small increases in blood pressure (U.S. EPA,
2019, section 6.1.6.3). In addition, although not entirely consistent,
there is also some evidence across controlled human exposure studies
for conduction abnormalities/arrhythmia (U.S. EPA, 2019, section
6.1.4.3), changes in heart rate variability (HRV) (U.S. EPA, 2019,
section 6.1.10.2), changes in hemostasis that could promote clot
formation (U.S. EPA, 2019, section 6.1.12.2), and increases in
inflammatory cells and markers (U.S. EPA, 2019, section 6.1.11.2).
Thus, when taken as a whole, controlled human exposure studies are
coherent with epidemiologic studies in that they provide evidence that
short-term exposures to PM2.5 may result in the types of
cardiovascular endpoints that could lead to emergency department visits
and hospital admissions in some people.
Animal toxicological studies published since the 2009 ISA also
support a relationship between short-term PM2.5 exposure and
cardiovascular effects. A recent study demonstrating decreased cardiac
contractility and left ventricular pressure in mice is coherent with
the results of epidemiologic studies that report associations between
short-term PM2.5 exposure and heart failure (U.S. EPA, 2019,
section 6.1.3.3). In addition, and as with controlled human exposure
studies, there is generally consistent evidence in animal toxicological
studies for indicators of endothelial dysfunction (U.S. EPA, 2019,
section 6.1.13.3). Studies in animals also provide evidence for changes
in a number of other cardiovascular endpoints following short-term
PM2.5 exposure. Although not entirely consistent, these
studies provide some evidence of conduction abnormalities and
arrhythmia (U.S. EPA, 2019, section 6.1.4.4), changes in HRV (U.S. EPA,
2019, section 6.1.10.3), changes in blood pressure (U.S. EPA, 2019,
section 6.1.6.4), and evidence for systemic inflammation and oxidative
stress (U.S. EPA, 2019, section 6.1.11.3).
In summary, recent evidence supports the conclusions reported in
the 2009 ISA indicating relationships between short-term
PM2.5 exposures and hospital admissions and ED visits for
IHD and HF, along with cardiovascular mortality. Epidemiologic studies
reporting robust associations in copollutant models are supported by
direct evidence from controlled human exposure and animal toxicological
studies reporting independent effects of PM2.5 exposures on
endothelial dysfunction as well as endpoints indicating impaired
cardiac function, increased risk of arrhythmia, changes in HRV,
increases in BP, and increases in indicators of systemic inflammation,
oxidative stress, and coagulation (U.S. EPA, 2019, section 6.1.16).
Epidemiologic panel studies, although not entirely consistent, provide
some evidence that PM2.5 exposures are associated with
cardiovascular effects, including increased risk of arrhythmia,
decreases in HRV, increases in BP, and ST segment depression. Overall,
the results from epidemiologic panel, controlled human exposure, and
animal toxicological studies (in particular those related to
endothelial dysfunction, impaired cardiac function, ST segment
depression, thrombosis, conduction abnormalities, and changes in blood
pressure) provide coherence and biological plausibility for the
consistent results from epidemiologic studies reporting positive
associations between short-term PM2.5 exposures and IHD and
HF, and ultimately cardiovascular mortality. The 2019 ISA concludes
that, overall, ``there continues to be sufficient evidence to conclude
that a causal relationship exists between short-term PM2.5
exposure and cardiovascular effects'' (U.S. EPA, 2019, p. 6-138).
c. Respiratory Effects
i. Long-Term PM2.5 Exposures
The 2009 PM ISA concluded that ``a causal relationship is likely to
exist between long-term PM2.5 exposure and respiratory
effects'' (U.S. EPA, 2009c). This conclusion was based mainly on
epidemiologic evidence demonstrating associations between long-term
PM2.5 exposure and changes in lung function or lung function
growth in children. Biological plausibility was provided by a single
animal toxicological study examining pre- and post-natal exposure to
PM2.5 CAPs, which found impaired lung development.
Epidemiologic evidence for associations between long-term
PM2.5 exposure and other respiratory outcomes, such as the
development of asthma, allergic disease, and COPD; respiratory
infection; and the severity of disease was limited, both in the number
of studies available and the consistency of the results. Experimental
evidence for other outcomes was also limited, with one animal
toxicological study reporting that long-term exposure to
PM2.5 CAPs results in morphological changes in the nasal
airways of healthy animals. Other animal studies examined exposure to
mixtures, such as motor vehicle exhaust and woodsmoke, and effects were
not attributed specifically to the particulate components of the
mixture.
Recent cohort studies provide additional support for the
relationship between long-term PM2.5 exposure and decrements
in lung function growth (as a measure of lung development), indicating
a robust and consistent association across study locations, exposure
assessment methods, and time periods (U.S. EPA, 2019, section 5.2.13).
This relationship is further supported by a recent retrospective study
that reports an association between declining PM2.5
concentrations and improvements in lung function growth in children
(U.S. EPA, 2019, section 5.2.11). Epidemiologic studies also examine
asthma development in children (U.S. EPA, 2019, section 5.2.3), with
recent prospective cohort studies reporting generally positive
associations, though several are imprecise (i.e., they report wide
confidence intervals). Supporting evidence is provided by studies
reporting associations with asthma prevalence in children, with
childhood wheeze, and with exhaled nitric oxide, a marker of pulmonary
inflammation (U.S. EPA, 2019, section 5.2.13). A recent animal
toxicological study showing the development of an allergic phenotype
and an increase in a marker of airway responsiveness supports the
biological plausibility of the development of allergic asthma (U.S.
EPA, 2019, section 5.2.13). Other epidemiologic studies report a
PM2.5-related acceleration of lung function decline in
adults, while improvement in lung function was observed with declining
PM2.5 concentrations (U.S. EPA, 2019, section 5.2.11). A
recent longitudinal study found declining PM2.5
concentrations are also associated with an improvement in chronic
bronchitis symptoms in children, strengthening evidence reported in the
2009 ISA for a relationship between
[[Page 24111]]
increased chronic bronchitis symptoms and long-term PM2.5
exposure (U.S. EPA, 2019, section 5.2.11). A common uncertainty across
the epidemiologic evidence is the lack of examination of copollutants
to assess the potential for confounding. While there is some evidence
that associations remain robust in models with gaseous pollutants, a
number of these studies examining copollutant confounding were
conducted in Asia, and thus have limited generalizability due to high
annual pollutant concentrations.
When taken together, the 2019 ISA concludes that the
``epidemiologic evidence strongly supports a relationship with
decrements in lung function growth in children'' (U.S. EPA, 2019, p. 1-
34). Additional epidemiologic evidence ``supports a relationship with
asthma development in children, increased bronchitic symptoms in
children with asthma, acceleration of lung function decline in adults,
and respiratory mortality, including cause-specific respiratory
mortality for COPD and respiratory infection'' (U.S. EPA, 2019, p. 1-
34). In support of the biological plausibility of such associations
reported in epidemiologic studies of respiratory health effects, animal
toxicological studies continue to provide direct evidence that long-
term exposure to PM2.5 results in a variety of respiratory
effects. Recent animal studies show pulmonary oxidative stress,
inflammation, and morphologic changes in the upper (nasal) and lower
airways. Other results show that changes are consistent with the
development of allergy and asthma, and with impaired lung development.
Overall, the ISA concludes that ``the collective evidence is sufficient
to conclude a likely to be causal relationship between long-term
PM2.5 exposure and respiratory effects'' (U.S. EPA, 2019, p.
5-220).
ii. Short-Term PM2.5 Exposures
The 2009 PM ISA (U.S. EPA, 2009c) concluded that a ``causal
relationship is likely to exist'' between short-term PM2.5
exposure and respiratory effects. This conclusion was based mainly on
the epidemiologic evidence demonstrating positive associations with
various respiratory effects. Specifically, the 2009 ISA described
epidemiologic evidence as consistently showing PM2.5-
associated increases in hospital admissions and emergency department
visits for COPD and respiratory infection among adults or people of all
ages, as well as increases in respiratory mortality. These results were
supported by studies reporting associations with increased respiratory
symptoms and decreases in lung function in children with asthma, though
the available epidemiologic evidence was inconsistent for hospital
admissions or emergency department visits for asthma. Studies examining
copollutant models showed that PM2.5 associations with
respiratory effects were robust to inclusion of CO or SO2 in
the model, but often were attenuated (though still positive) with
inclusion of O3 or NO2. In addition to the
copollutant models, evidence supporting an independent effect of
PM2.5 exposure on the respiratory system was provided by
animal toxicological studies of PM2.5 CAPs demonstrating
changes in some pulmonary function parameters, as well as inflammation,
oxidative stress, injury, enhanced allergic responses, and reduced host
defenses. Many of these effects have been implicated in the
pathophysiology for asthma exacerbation, COPD exacerbation, or
respiratory infection. In the few controlled human exposure studies
conducted in individuals with asthma or COPD, PM2.5 exposure
mostly had no effect on respiratory symptoms, lung function, or
pulmonary inflammation. Available studies in healthy people also did
not clearly find respiratory effects following short-term
PM2.5 exposures.
Recent epidemiologic studies provide evidence for a relationship
between short-term PM2.5 exposure and several respiratory-
related endpoints, including asthma exacerbation (U.S. EPA, 2019,
section 5.1.2.1), COPD exacerbation (U.S. EPA, 2019, section 5.1.4.1),
and combined respiratory-related diseases (U.S. EPA, 2019, section
5.1.6), particularly from studies examining emergency department visits
and hospital admissions. The generally positive associations between
short-term PM2.5 exposure and asthma and COPD emergency
department visits and hospital admissions are supported by
epidemiologic studies demonstrating associations with other
respiratory-related effects such as symptoms and medication use that
are indicative of asthma and COPD exacerbations (U.S. EPA, 2019,
sections 5.1.2.2 and 5.4.1.2). The collective body of epidemiologic
evidence for asthma exacerbation is more consistent in children than in
adults. Additionally, epidemiologic studies examining the relationship
between short-term PM2.5 exposure and respiratory mortality
provide evidence of consistent positive associations, demonstrating a
continuum of effects (U.S. EPA, 2019, section 5.1.9).
Building on the studies evaluated in the 2009 ISA, recent
epidemiologic studies expand the assessment of potential copollutant
confounding. There is some evidence that PM2.5 associations
with asthma exacerbation, combined respiratory-related diseases, and
respiratory mortality remain relatively unchanged in copollutant models
with gaseous pollutants (i.e., O3, NO2,
SO2, with more limited evidence for CO) and other particle
sizes (i.e., PM10-2.5) (U.S. EPA, 2019, section 5.1.10.1).
Insight into whether there is an independent effect of
PM2.5 on respiratory health is provided by findings from
animal toxicological studies. Specifically, short-term exposure to
PM2.5 has been shown to enhance asthma-related responses in
an animal model of allergic airways disease and lung injury and
inflammation in an animal model of COPD (U.S. EPA, 2019, sections
5.1.2.4.4 and 5.1.4.4.3). The experimental evidence provides biological
plausibility for some respiratory-related endpoints, including limited
evidence of altered host defense and greater susceptibility to
bacterial infection as well as consistent evidence of respiratory
irritant effects. Animal toxicological evidence for other respiratory
effects is inconsistent and controlled human exposure studies provide
limited evidence of respiratory effects (U.S. EPA, 2019, section
5.1.12).
The 2019 ISA concludes that ``[t]he strongest evidence of an effect
of short-term PM2.5 exposure on respiratory effects is
provided by epidemiologic studies of asthma and COPD exacerbation.
While animal toxicological studies provide biological plausibility for
these findings, some uncertainty remains with respect to the
independence of PM2.5 effects'' (U.S. EPA, 2019, p. 5-155).
When taken together, the ISA concludes that this evidence ``is
sufficient to conclude a likely to be causal relationship between
short-term PM2.5 exposure and respiratory effects'' (U.S.
EPA, 2019, p. 5-155).
d. Cancer
The 2009 ISA concluded that the overall body of evidence was
``suggestive of a causal relationship between relevant PM2.5
exposures and cancer'' (U.S. EPA, 2009c). This conclusion was based
primarily on positive associations observed in a limited number of
epidemiologic studies of lung cancer mortality. The few epidemiologic
studies that had evaluated PM2.5 exposure and lung cancer
incidence or cancers of other organs and systems generally did not show
evidence of an association. Toxicological studies did not focus on
exposures to specific PM size fractions,
[[Page 24112]]
but rather investigated the effects of exposures to total ambient PM,
or other source-based PM such as wood smoke. Collectively, results of
in vitro studies were consistent with the larger body of evidence
demonstrating that ambient PM and PM from specific combustion sources
are mutagenic and genotoxic. However, animal inhalation studies found
little evidence of tumor formation in response to chronic exposures. A
small number of studies provided preliminary evidence that PM exposure
can lead to changes in methylation of DNA, which may contribute to
biological events related to cancer.
Since the 2009 ISA, additional cohort studies provide evidence that
long-term PM2.5 exposure is positively associated with lung
cancer mortality and with lung cancer incidence, and provide initial
evidence for an association with reduced cancer survival (U.S. EPA,
2019, section 10.2.5). Reanalyses of the ACS cohort using different
years of PM2.5 data and follow-up, along with various
exposure assignment approaches, provide consistent evidence of positive
associations between long-term PM2.5 exposure and lung
cancer mortality (U.S. EPA, 2019, Figure 10-3). Additional support for
positive associations with lung cancer mortality is provided by recent
epidemiologic studies using individual-level data to control for
smoking status, by studies of people who have never smoked (though such
studies generally report wide confidence intervals due to the small
number of lung cancer mortality cases within this population), and in
analyses of cohorts that relied upon proxy measures to account for
smoking status (U.S. EPA, 2019, section 10.2.5.1.1). Although studies
that evaluate lung cancer incidence, including studies of people who
have never smoked, are limited in number, recent studies generally
report positive associations with long-term PM2.5 exposures
(U.S. EPA, 2019, section 10.2.5.1.2). A subset of the studies focusing
on lung cancer incidence also examined histological subtype, providing
some evidence of positive associations for adenocarcinomas, the
predominate subtype of lung cancer observed in people who have never
smoked (U.S. EPA, 2019, section 10.2.5.1.2). Associations between long-
term PM2.5 exposure and lung cancer incidence were found to
remain relatively unchanged, though in some cases confidence intervals
widened, in analyses that attempted to reduce exposure measurement
error by accounting for length of time at residential address or by
examining different exposure assignment approaches (U.S. EPA, 2019,
section 10.2.5.1.2).
The 2019 ISA evaluates the degree to which recent epidemiologic
studies have addressed the potential for confounding by copollutants
and the shape of the concentration-response relationship. To date,
relatively few studies have evaluated the potential for copollutant
confounding of the relationship between long-term PM2.5
exposure and lung cancer mortality or incidence. The small number of
such studies have generally focused on O3 and report that
PM2.5 associations remain relatively unchanged in
copollutant models (U.S. EPA, 2019, section 10.2.5.1.3). However,
available studies have not systematically evaluated the potential for
copollutant confounding by other gaseous pollutants or by other
particle size fractions (U.S. EPA, 2019, section 10.2.5.1.3). Compared
to total (non-accidental) mortality (discussed above), fewer studies
have examined the shape of the concentration-response curve for cause-
specific mortality outcomes, including lung cancer. Several studies
have reported no evidence of deviations from linearity in the shape of
the concentration-response relationship (Lepeule et al., 2012;
Raaschou-Nielsen et al., 2013; Puett et al., 2014), though authors
provided only limited discussions of results (U.S. EPA, 2019, section
10.2.5.1.4).
In support of the biological plausibility of an independent effect
of PM2.5 on cancer, the 2019 ISA notes evidence from recent
experimental studies demonstrating that PM2.5 exposure can
lead to a range of effects indicative of mutagenicity, genotoxicity,
and carcinogenicity, as well as epigenetic effects (U.S. EPA, 2019,
section 10.2.7). For example, both in vitro and in vivo toxicological
studies have shown that PM2.5 exposure can result in DNA
damage (U.S. EPA, 2019, section 10.2.2). Although such effects do not
necessarily equate to carcinogenicity, the evidence that PM exposure
can damage DNA, and elicit mutations, provides support for the
plausibility of epidemiologic associations with lung cancer mortality
and incidence. Additional supporting studies indicate the occurrence of
micronuclei formation and chromosomal abnormalities (U.S. EPA, 2019,
section 10.2.2.3), and differential expression of genes that may be
relevant to cancer pathogenesis, following PM exposures. Experimental
and epidemiologic studies that examine epigenetic effects indicate
changes in DNA methylation, providing some support for PM2.5
exposure contributing to genomic instability (U.S. EPA, 2019, section
10.2.3).
Epidemiologic evidence for associations between PM2.5
exposure and lung cancer mortality and incidence, together with
evidence supporting the biological plausibility of such associations,
contributes to the 2019 ISA's conclusion that the evidence ``is
sufficient to conclude there is a likely to be causal relationship
between long-term PM2.5 exposure and cancer'' (U.S. EPA,
2019, p. 10-77).
In its letter to the Administrator on the draft ISA, the CASAC
states that ``the Draft ISA does not present adequate evidence to
conclude that there is likely to be a causal relationship between long-
term PM2.5 exposure and . . . cancer'' (Cox, 2019a, p. 1 of
letter). The CASAC specifically states that this causality
determination ``relies largely on epidemiology studies that . . . do
not provide exposure time frames that are appropriate for cancer
causation and that there are no animal studies showing direct effects
of PM2.5 on cancer formation'' (Cox, 2019a, p. 20 of
consensus responses).
With respect to the latency period, it is well recognized that
``air pollution exposures experienced over an extended historical time
period are likely more relevant to the etiology of lung cancer than air
pollution exposures experienced in the more recent past'' (Turner et
al. 2011). However, many epidemiologic studies conducted within the
U.S. that examine long-term PM2.5 exposure and lung cancer
incidence and lung cancer mortality rely on more recent air quality
data because routine PM2.5 monitoring did not start until
1999-2000. An exception to this is the American Cancer Society (ACS)
study that had PM2.5 concentration data from two time
periods, 1979-1983 and from 1999-2000. Turner et al. (2011), conducted
a comparison of PM2.5 concentrations between these two time
periods and found that they were highly correlated (r >0.7), with the
relative rank order of metropolitan statistical areas (MSAs) by
PM2.5 concentrations being ``generally retained over time.''
Therefore, areas where PM2.5 concentrations were high
remained high over decades (or low remained low) relative to other
locations. Long-term exposure epidemiologic studies rely on spatial
contrasts between locations; therefore, if a location with high
PM2.5 concentrations continues to have high concentrations
over decades relative to other locations a relationship between the
PM2.5 exposure and cancer should persist. This was confirmed
in a sensitivity analysis conducted by
[[Page 24113]]
Turner et al. (2011), where the authors reported a similar hazard ratio
(HR) for lung cancer mortality for participants assigned exposure to
PM2.5 (1979-1983) and PM2.5 (1999-2000) in two
separate analyses.
While experimental studies showing a direct effect of
PM2.5 on cancer formation were limited to an animal model of
urethane-induced tumor initiation, a large number of experimental
studies report that PM2.5 exhibits several key
characteristics of carcinogens, as indicated by genotoxic effects,
oxidative stress, electrophilicity, and epigenetic alterations, all of
which provide biological plausibility that PM2.5 exposure
can contribute to cancer development. The experimental evidence, in
combination with multiple recent and previously evaluated epidemiologic
studies examining the relationship between long-term PM2.5
exposure and both lung cancer incidence and lung cancer mortality that
reported generally positive associations across different cohorts,
exposure assignment methods, and in analyses of never smokers further
addresses uncertainties identified in the 2009 PM ISA. Therefore, upon
re-evaluating the causality determination for cancer, when considering
CASAC comments on the Draft PM ISA and applying the causal framework as
described (U.S. EPA, 2015; U.S. EPA, 2019, section A.3.2.1), the EPA
continues to conclude in the 2019 Final PM ISA that the evidence for
long-term PM2.5 exposure and cancer supports a ``likely to
be causal relationship'' (U.S. EPA, 2019, p. 10-77).
e. Nervous System Effects
Reflecting the very limited evidence available in the last review,
the 2009 ISA did not make a causality determination for long-term
PM2.5 exposures and nervous system effects (U.S. EPA,
2009c). Since the last review, this body of evidence has grown
substantially (U.S. EPA, 2019, section 8.2). Recent studies in adult
animals report that long-term PM2.5 exposures can lead to
morphologic changes in the hippocampus and to impaired learning and
memory. This evidence is consistent with epidemiologic studies
reporting that long-term PM2.5 exposure is associated with
reduced cognitive function (U.S. EPA, 2019, section 8.2.5). Further,
while the evidence is limited, early markers of Alzheimer's disease
pathology have been reported in rodents following long-term exposure to
PM2.5 CAPs. These findings support reported associations
with neurodegenerative changes in the brain (i.e., decreased brain
volume), all-cause dementia, and hospitalization for Alzheimer's
disease in a small number of epidemiologic studies (U.S. EPA, 2019,
section 8.2.6). Additionally, loss of dopaminergic neurons in the
substantia nigra, a hallmark of Parkinson disease, has been reported in
mice following long-term PM2.5 exposures (U.S. EPA, 2019,
section 8.2.4), though epidemiologic studies provide only limited
support for associations with Parkinson's disease (U.S. EPA, 2019,
section 8.2.6). Overall, the lack of consideration of copollutant
confounding introduces some uncertainty in the interpretation of
epidemiologic studies of nervous system effects, but this uncertainty
is partly addressed by the evidence for an independent effect of
PM2.5 exposures provided by experimental animal studies.
In addition to the findings described above, which are most
relevant to older adults, several recent studies of neurodevelopmental
effects in children have also been conducted. Positive associations
between long-term exposure to PM2.5 during the prenatal
period and autism spectrum disorder (ASD) are observed in multiple
epidemiologic studies (U.S. EPA, 2019, section 8.2.7.2), while studies
of cognitive function provide little support for an association (U.S.
EPA, 2019, section 8.2.5.2). Interpretation of these epidemiologic
studies is limited due to the small number of studies, their lack of
control for potential confounding by copollutants, and uncertainty
regarding the critical exposure windows. Biological plausibility is
provided for the ASD findings by a study in mice that found
inflammatory and morphologic changes in the corpus collosum and
hippocampus, as well as ventriculomegaly (i.e., enlarged lateral
ventricles) in young mice following prenatal exposure to
PM2.5 CAPs.
Taken together, the 2019 ISA concludes that the strongest evidence
of an effect of long-term exposure to PM2.5 on the nervous
system is provided by toxicological studies that show inflammation,
oxidative stress, morphologic changes, and neurodegeneration in
multiple brain regions following long-term exposure of adult animals to
PM2.5 CAPs. These findings are coherent with epidemiologic
studies reporting consistent associations with cognitive decrements and
with all-cause dementia. There is also initial, and limited, evidence
for neurodevelopmental effects, particularly ASD. The ISA determines
that ``[o]verall, the collective evidence is sufficient to conclude a
likely to be causal relationship between long-term PM2.5
exposure and nervous system effects'' (U.S. EPA, 2019, p. 8-61).
In its letter to the Administrator on the draft ISA, the CASAC
states that ``the Draft ISA does not present adequate evidence to
conclude that there is likely to be a causal relationship between long-
term PM2.5 exposure and nervous system effects'' (Cox,
2019a, p. 1 of letter). The CASAC specifically states that ``[f]or a
likely causal conclusion, there would have to be evidence of health
effects in studies where results are not explained by chance,
confounding, and other biases, but uncertainties remain in the overall
evidence'' (Cox, 2019a, p. 20 of consensus responses). These
uncertainties in the eyes of CASAC reflect that animal toxicological
studies ``have largely been done by a single group'' (P.20), and for
epidemiologic studies that examined brain volume that ``brain volumes
can vary . . . between normal people'' and the results from studies of
cognitive function were ``largely non-statistically significant''.
With these concerns in mind, the EPA re-evaluated the evidence and
note that animal toxicological studies were conducted in ``multiple
research groups [and show a range of effects including] inflammation,
oxidative stress, morphologic changes, and neurodegeneration in
multiple brain regions following long-term exposure of adult animals to
PM2.5 CAPs'' (U.S. EPA, 2019, p. 8-61). The results from the
animal toxicological studies ``are coherent with a number of
epidemiologic studies reporting consistent associations with cognitive
decrements and with all-cause dementia'' (U.S. EPA, 2019, p. 8-61).
Additionally, as discussed in the Preamble to the ISAs (U.S. EPA,
2015):
``. . . the U.S. EPA emphasizes the importance of examining the
pattern of results across various studies and does not focus solely
on statistical significance or the magnitude of the direction of the
association as criteria of study reliability. Statistical
significance is influenced by a variety of factors including, but
not limited to, the size of the study, exposure and outcome
measurement error, and statistical model specifications. Statistical
significance . . . is just one of the means of evaluating confidence
in the observed relationship and assessing the probability of chance
as an explanation. Other indicators of reliability such as the
consistency and coherence of a body of studies as well as other
confirming data may be used to justify reliance on the results of a
body of epidemiologic studies, even if results in individual studies
lack statistical significance . . . [Therefore, the U.S. EPA] . . .
does not limit its focus or consideration to statistically
significant results in epidemiologic studies.''
[[Page 24114]]
Therefore, upon re-evaluating the causality determination, when
considering the CASAC comments on the Draft PM ISA and applying the
causal framework as described (U.S. EPA, 2015; U.S. EPA, 2019, section
A.3.2.1), the EPA continues to conclude in the 2019 Final PM ISA that
the evidence for long-term PM2.5 exposure and nervous system
effects supports a ``likely to be causal relationship'' (U.S. EPA,
2019, p. 8-61).
2. Populations at Risk of PM2.5-Related Health Effects
The NAAQS are meant to protect the population as a whole, including
groups that may be at increased risk for pollutant-related health
effects. In the last review, based on the evidence assessed in the 2009
ISA (U.S. EPA, 2009c), the 2011 PA focused on children, older adults,
people with pre-existing heart and lung diseases, and those of lower
socioeconomic status as populations that are ``likely to be at
increased risk of PM-related effects'' (U.S. EPA, 2011, p. 2-31). In
the current review, the 2019 ISA cites extensive evidence indicating
that ``both the general population as well as specific populations and
lifestages are at risk for PM2.5-related health effects''
(U.S. EPA, 2019, p. 12-1). For example, in support of its ``causal''
and ``likely to be causal'' determinations, the ISA cites substantial
evidence for:
PM-related mortality and cardiovascular effects in older
adults (U.S. EPA, 2019, sections 11.1, 11.2, 6.1, and 6.2);
PM-related cardiovascular effects in people with pre-
existing cardiovascular disease (U.S. EPA, 2019, section 6.1);
PM-related respiratory effects in people with pre-existing
respiratory disease, particularly asthma exacerbations in children
(U.S. EPA, 2019, section 5.1); and
PM-related impairments in lung function growth and asthma
development in children (U.S. EPA, 2019, sections 5.1 and 5.2;
12.5.1.1).
The ISA additionally notes that stratified analyses (i.e., analyses
that directly compare PM-related health effects across groups) provide
support for racial and ethnic differences in PM2.5 exposures
and in PM2.5-related health risk (U.S. EPA, 2019, section
12.5.4). Drawing from such studies, the ISA concludes that ``[t]here is
strong evidence demonstrating that black and Hispanic populations, in
particular, have higher PM2.5 exposures than non-Hispanic
white populations'' and that ``there is consistent evidence across
multiple studies demonstrating an increase in risk for nonwhite
populations'' (U.S. EPA, 2019, p. 12-38). Stratified analyses focusing
on other groups also suggest that populations with pre-existing
cardiovascular or respiratory disease, populations that are overweight
or obese, populations that have particular genetic variants,
populations that are of low socioeconomic status, and current/former
smokers could be at increased risk for PM2.5-related adverse
health effects (U.S. EPA, 2019, Chapter 12).
Thus, the groups at risk of PM2.5-related health effects
represent a substantial portion of the total U.S. population. In
evaluating the primary PM2.5 standards, an important
consideration is the potential PM2.5-related public health
impacts in these populations.
3. CASAC Advice
In its review of the draft ISA, the CASAC provided advice on the
assessment of the scientific evidence for PM-related health and welfare
effects and on the process under which this review of the PM NAAQS is
being conducted (Cox, 2019b). With regard to the assessment of the
evidence, the CASAC recommended that a revised ISA should ``provide a
clearer and more complete description of the process and criteria for
study quality assessment'' and that it should include a ``[c]learer
discussion of causality and causal biological mechanisms and pathways''
(Cox, 2019b, p. 1 of letter). The CASAC further advised that the draft
ISA ``does not present adequate evidence to conclude that there is
likely to be a causal relationship between long-term PM2.5
exposure and nervous system effects; between long-term ultrafine
particulate (UFP) exposure and nervous system effects; or between long-
term PM2.5 exposure and cancer'' (Cox, 2019b, p. 1 of
letter).
As discussed above in section I.C.5, and as detailed in the final
ISA, to address these comments the EPA: (1) Added text to the Preface
and developed a new Appendix to more clearly articulate the process of
ISA development; (2) added text to the Preface and to the health
effects chapters to clarify the discussion of biological plausibility
and its role in forming causality determinations; and (3) revised the
determination for long-term UFP exposure and nervous system effects to
suggestive of, but not sufficient to infer, a causal relationship. The
EPA's rationales for not revising the other causality determinations
questioned by the CASAC are discussed above in sections II.B.1.d (i.e.,
for cancer) and II.B.1.e (i.e., for nervous system effects).
With regard to the process for reviewing the PM NAAQS, the CASAC
requested the opportunity to review a 2nd draft ISA (Cox, 2019b, p. 1
of letter) and recommended that ``the EPA reappoint the previous CASAC
PM panel (or appoint a panel with similar expertise)'' (Cox, 2019b, p.
2 of letter). As discussed above in section I.C.5, the Agency's
responses to these recommendations were described in a letter from the
Administrator to the CASAC chair.\40\
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\40\ Available at: https://yosemite.epa.gov/sab/sabproduct.nsf/
0/6CBCBBC3025E13B4852583D90047B352/$File/EPA-CASAC-19-
002_Response.pdf.
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In addition to the consensus advice noted above, the CASAC did not
reach consensus on some issues related to the assessment of the
PM2.5 health effects evidence. In particular, the CASAC
members ``had varying opinions on whether there is robust and
convincing evidence to support the EPA's conclusion that there is a
causal relationship between PM2.5 exposure and mortality''
(Cox, 2019b, p. 3 of letter). ``Some members of the CASAC'' concluded
that ``the EPA must better justify their determination that short-term
or long-term exposure to PM2.5 causes mortality'' (Cox,
2019b, p. 1 of consensus responses). These members recommended that the
ISA should specifically address the biological action of PM and how
exposures to low concentrations of PM2.5 could cause
mortality; the geographic heterogeneity in effect estimates between
PM2.5 exposure and mortality; concentration concordance
across epidemiologic, controlled human exposure and animal
toxicological studies (i.e., how the continuum of effects is impacted
by the concentrations at which different effects have been observed);
uncertainties in the shapes of concentration-response functions and in
the potential for thresholds to exist; how results compare between and
within studies; and whether PM2.5 exposures result in
mortality in animal studies (Cox, 2019b, pp. 1-2).
In contrast, ``[o]ther members of the CASAC are of the opinion
that, although uncertainties remain, the evidence supporting the causal
relationship between PM2.5 exposure and mortality is robust,
diverse, and convincing'' (Cox, 2019b, p. 3 of consensus responses).
These members noted that epidemiologic observations ``have been
reproduced around the world in communities with widely varying
exposures'' and that ``the findings of many of the largest studies have
been repeatedly reanalyzed, with
[[Page 24115]]
confirmation of the original findings'' (Cox, 2019b, p. 3). These
committee members additionally stated that the ISA's causality
determinations consider ``a wide range of evidence from a variety of
sources, including human clinical exposure and animal toxicology
studies that have provided rational biological plausibility and
potential mechanisms'' (Cox, 2019b, p. 3). They highlighted the fact
that there is new evidence in the current review from epidemiologic
studies supporting associations between PM2.5 and mortality
and new evidence from toxicology studies informing the biological
plausibility of mechanisms that could lead to mortality (Cox, 2019b, p.
3).
C. Proposed Conclusions on the Current Primary PM2.5
Standards
This section describes the Administrator's proposed conclusions
regarding the adequacy of the current primary PM2.5
standards. His approach to reaching these proposed conclusions draws
from the ISA's assessment of the scientific evidence for health effects
attributable to PM2.5 exposures (U.S. EPA, 2019) and the
analyses in the PA (U.S. EPA, 2020), including uncertainties in the
evidence and analyses. Section II.C.1 discusses the evidence- and risk-
based considerations in the PA. Section II.C.2 summarizes CASAC advice
on the current primary PM2.5 standards, based on its review
of the draft PA (Cox, 2019a). Section II.C.3 presents the
Administrator's proposed decision to retain the current primary
PM2.5 standards.
1. Evidence- and Risk-Based Considerations in the Policy Assessment
The Administrator's proposed decision in this review draws from his
consideration of the PM2.5 health evidence assessed in the
ISA (U.S. EPA, 2019) and the evidence- and risk-based analyses
presented in the PA (U.S. EPA, 2020), including the uncertainties
inherent in the evidence and analyses. The sections below summarize the
consideration of the evidence-based information (II.C.1.a) and risk-
based information (II.C.1.b) in the PA.
a. Evidence-Based Considerations
The PA considers the degree to which the available scientific
evidence provides support for the current and potential alternative
standards in terms of the basic elements of those standards (i.e.,
indicator, averaging time, form, and level). With regard to the current
indicator, averaging times, and forms, the PA concludes that the
available evidence continues to support these elements in the current
review. For indicator, the PA specifically concludes that available
studies provide strong support for health effects following long- and
short-term PM2.5 exposures and that the evidence is too
limited to support potential alternatives (U.S. EPA, 2020, section
3.5.2.1). For averaging time, the PA notes that epidemiologic studies
continue to provide strong support for health effects based on annual
(or multiyear) and 24-hour PM2.5 averaging periods and
concludes that the evidence does not support considering alternatives
(U.S. EPA, 2020, section 3.5.2.2). For form, the PA notes that the
foremost consideration is the adequacy of the public health protection
provided by the combination of the form and the other elements of the
standard. It concludes that (1) the form of the current annual standard
(i.e., arithmetic mean, averaged over three years) remains appropriate
for targeting protection against the annual and daily PM2.5
exposures around the middle portion of the PM2.5 air quality
distribution, and (2) the form of the current 24-hour standard (98th
percentile, averaged over three years) continues to provide an
appropriate balance between limiting the occurrence of peak 24-hour
PM2.5 concentrations and identifying a stable target for
risk management programs (U.S. EPA, 2020, section 3.5.2.3).
With regard to level, the considerations in the PA reflect analyses
of the PM2.5 exposures and ambient concentrations in studies
reporting PM2.5-related health effects (U.S. EPA, 2020). As
noted above, the focus is on health outcomes for which the ISA
concludes the evidence supports a ``causal'' or a ``likely to be
causal'' relationship with PM exposures.\41\ While the causality
determinations in the ISA are informed by studies evaluating a wide
range of PM2.5 concentrations, the PA considers the degree
to which the evidence supports the occurrence of PM-related effects at
concentrations relevant to informing conclusions on the primary
PM2.5 standards. Section II.C.1.a.i below summarizes the
PA's consideration of exposure concentrations that have been evaluated
in experimental studies and section II.C.1.a.ii summarizes the PA's
consideration of ambient concentrations in locations evaluated by
epidemiologic studies.
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\41\ As discussed above in II.A.2, such a focus recognizes that
standards set to provide protection based on evidence for ``causal''
and ``likely to be causal'' health outcomes will also provide some
measure of protection against the broader range of PM2.5-
associated outcomes, including those for which the evidence is less
certain.
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i. PM2.5 Exposure Concentrations Evaluated in Experimental
Studies
Evidence for a particular PM2.5-related health outcome
is strengthened when results from experimental studies demonstrate
biologically plausible mechanisms through which adverse human health
outcomes could occur (U.S. EPA, 2015, Preamble p. 20). Two types of
experimental studies are of particular importance in understanding the
effects of PM exposures: Controlled human exposure and animal
toxicology studies. In such studies, investigators expose human
volunteers or laboratory animals, respectively, to known concentrations
of air pollutants under carefully regulated environmental conditions
and activity levels. Thus, controlled human exposure and animal
toxicology studies can provide information on the health effects of
experimentally administered pollutant exposures under well-controlled
laboratory conditions (U.S. EPA, 2015, Preamble, p. 11). The sections
below summarize the PA's evaluation of the PM2.5 exposure
concentrations that have been examined in controlled human exposure
studies and animal toxicology studies.
Controlled Human Exposure Studies
Controlled human exposure studies have reported that
PM2.5 exposures lasting from less than one hour up to five
hours can impact cardiovascular function (U.S. EPA, 2019, section 6.1).
The most consistent evidence from these studies is for impaired
vascular function (U.S. EPA, 2019, section 6.1.13.2). In addition,
although less consistent, the ISA notes that studies examining
PM2.5 exposures also provide evidence for increased blood
pressure (U.S. EPA, 2019, section 6.1.6.3), conduction abnormalities/
arrhythmia (U.S. EPA, 2019, section 6.1.4.3), changes in heart rate
variability (U.S. EPA, 2019, section 6.1.10.2), changes in hemostasis
that could promote clot formation (U.S. EPA, 2019, section 6.1.12.2),
and increases in inflammatory cells and markers (U.S. EPA, 2019,
section 6.1.11.2).
Table 3-2 in the PA (U.S. EPA, 2020) summarizes information from
the ISA on available controlled human exposure studies that evaluate
effects on markers of cardiovascular function following exposures to
PM2.5. Most of the controlled human exposure studies in
Table 3-2 of the PA have evaluated average PM2.5 exposure
concentrations at or above about 100 [micro]g/m\3\, with exposure
durations typically up to about two hours. Statistically significant
effects on one or more indicators of
[[Page 24116]]
cardiovascular function are often, though not always, reported
following 2-hour exposures to average PM2.5 concentrations
at and above about 120 [micro]g/m\3\, with less consistent evidence for
effects following exposures to lower concentrations. Impaired vascular
function, the effect identified in the ISA as the most consistent
across studies (U.S. EPA, 2019, section 6.1.13.2), is shown following
2-hour exposures to PM2.5 concentrations at and above 149
[micro]g/m\3\. Mixed results are reported in the few studies that
evaluate longer exposure durations (i.e., longer than 2 hours) and
lower PM2.5 concentrations (U.S. EPA, 2020, section
3.2.3.1).
To provide some insight into what these studies may indicate
regarding the primary PM2.5 standards, analyses in the PA
examine monitored 2-hour PM2.5 concentrations at sites
meeting the current standards (U.S. EPA, 2020, section 3.2.3.1). At
these sites, most 2-hour concentrations are below 11 [mu]g/m\3\, and
they almost never exceed 32 [mu]g/m\3\. Even the highest 2-hour
concentrations remain well-below the exposure concentrations
consistently shown to cause effects in controlled human exposure
studies (i.e., 99.9th percentile of 2-hour concentrations is 68 [mu]g/
m\3\ during the warm season). Thus, while controlled human exposure
studies support the plausibility of the serious cardiovascular effects
that have been linked with ambient PM2.5 exposures (U.S.
EPA, 2019, Chapter 6), the PA notes that the PM2.5 exposures
evaluated in most of these studies are well-above the ambient
concentrations typically measured in locations meeting the current
primary standards (U.S. EPA, 2020, section 3.2.3.2.1).
Animal Toxicology Studies
The ISA relies on animal toxicology studies to support the
plausibility of a wide range of PM2.5-related health
effects. While animal toxicology studies often examine more severe
health outcomes and longer exposure durations than controlled human
exposure studies, there is uncertainty in extrapolating the effects
seen in animals, and the PM2.5 exposures and doses that
cause those effects, to human populations.
As with controlled human exposure studies, most of the animal
toxicology studies assessed in the ISA have examined effects following
exposures to PM2.5 concentrations well-above the
concentrations likely to be allowed by the current PM2.5
standards. Such studies have generally examined short-term exposures to
PM2.5 concentrations from 100 to >1,000 [mu]g/m\3\ and long-
term exposures to concentrations from 66 to >400 [mu]g/m\3\ (e.g., see
U.S. EPA, 2019, Table 1-2). Two exceptions are a study reporting
impaired lung development following long-term exposures (i.e., 24 hours
per day for several months prenatally and postnatally) to an average
PM2.5 concentration of 16.8 [mu]g/m\3\ (Mauad et al., 2008)
and a study reporting increased carcinogenic potential following long-
term exposures (i.e., 2 months) to an average PM2.5
concentration of 17.7 [mu]g/m\3\ (Cangerana Pereira et al., 2011).
These two studies report serious effects following long-term exposures
to PM2.5 concentrations close to the ambient concentrations
reported in some PM2.5 epidemiologic studies (U.S. EPA,
2019, Table 1-2), though still above the ambient concentrations likely
to occur in areas meeting the current primary standards. Thus, as is
the case with controlled human exposure studies, animal toxicology
studies support the plausibility of various adverse effects that have
been linked to ambient PM2.5 exposures (U.S. EPA, 2019), but
have not evaluated PM2.5 exposures likely to occur in areas
meeting the current primary standards.
ii. Ambient Concentrations in Locations of Epidemiologic Studies
As summarized above in section II.B.1, epidemiologic studies
examining associations between daily or annual average PM2.5
exposures and mortality or morbidity represent a large part of the
evidence base supporting several of the ISA's ``causal'' and ``likely
to be causal'' determinations for cardiovascular effects, respiratory
effects, cancer, and mortality. The PA uses two approaches to consider
what information from epidemiologic studies may indicate regarding
primary PM2.5 standards (U.S. EPA, 2020, section 3.2.3.2).
In one approach, the PA evaluates the PM2.5 air quality
distributions reported by key epidemiologic studies, with a focus on
overall mean PM2.5 concentrations (i.e., averages over the
study period of the daily or annual PM2.5 concentrations
used to estimate exposures) and the concentrations somewhat below these
overall means (i.e., corresponding to the lower quartiles of exposure
or health data) (U.S. EPA, 2020, section 3.2.3.2.1). In another
approach, the PA calculates study area air quality metrics similar to
PM2.5 design values (i.e., referred to as pseudo-design
values) and considers the degree to which such metrics indicate that
study area air quality would likely have met or violated the current
standards during study periods (U.S. EPA, 2020, section 3.2.3.2.2).
These approaches are discussed briefly below.
PM2.5 Air Quality Distributions Associated With Mortality or
Morbidity
The PA evaluates the PM2.5 air quality distributions
over which epidemiologic studies support health effect associations and
the degree to which such distributions are likely to occur in areas
meeting the current standards. As discussed further in the PA (U.S.
EPA, 2020, section 3.2.3.2.1), epidemiologic studies generally provide
the strongest support for reported health effect associations over the
part of the air quality distribution corresponding to the bulk of the
underlying data (i.e., estimated exposures and/or health events), often
falling in the middle part of the distribution (i.e., rather than at
the extreme upper or lower ends). Thus, in considering PM2.5
air quality data from epidemiologic studies, the PA evaluates study-
reported means (or medians) of daily and annual average
PM2.5 concentrations as proxies for the middle portions of
the air quality distributions that support reported associations. When
data are available, the PA also considers the broader PM2.5
air quality distributions around the overall mean concentrations, with
a focus on the lower quartiles of data to provide insight into the
concentrations below which data supporting reported associations become
relatively sparse.
Based on its evaluation of study-reported PM2.5
concentrations, the PA notes that key epidemiologic studies conducted
in the U.S. or Canada report generally positive and statistically
significant associations between estimated PM2.5 exposures
(short- or long-term) and mortality or morbidity across a wide range of
ambient PM2.5 concentrations (U.S. EPA, 2020, section
3.2.3.2.1). With regard to these study-reported concentrations, the PA
makes a number of observations, including the following:
For the large majority of key studies, the
PM2.5 air quality distributions that support reported
associations are characterized by overall mean (or median)
PM2.5 concentrations ranging from just above 8.0 [mu]g/m\3\
to just above 16.0 [mu]g/m\3\. Most of these key studies, including all
but one U.S. study, report overall mean (or median) concentrations at
or above 9.6 [mu]g/m\3\.
Several U.S. studies report positive and statistically
significant health effect associations in analyses restricted to annual
average PM2.5 concentrations <12 [mu]g/m\3\ (Lee et al.
(2015); Shi et al. (2016); Di et al., 2017b). Studies also report
positive and statistically significant health effect associations in
analyses restricted to days with 24-hour average PM2.5
concentrations <35 [mu]g/m\3\
[[Page 24117]]
(Lee et al. (2015); Shi et al. (2016); Di et al. (2017a)).
For some key studies, information on the broader
distributions of PM2.5 exposure estimates and/or health
events is available. In these studies, ambient PM2.5
concentrations corresponding to 25th percentiles of the underlying data
(i.e., estimated exposures or health events) are generally >6.0 [mu]g/
m\3\.
A small group of studies report increased life expectancy,
decreased mortality, and decreased respiratory effects following past
declines in ambient PM2.5 concentrations. These studies have
examined ``starting'' annual average PM2.5 concentrations
(i.e., prior to the reductions being evaluated) ranging from about 13
to >20 [mu]g/m\3\ (i.e., U.S. EPA, 2020, Table 3-3).
The PA concludes that the overall mean PM2.5
concentrations reported by several of these key epidemiologic studies
are likely below the long-term mean concentrations (i.e., averaged
across space and over time) in areas just meeting the current annual
PM2.5 standard (U.S. EPA, 2020, section 3.2.3.3). The PA
also concludes that there are uncertainties in using study-reported
concentrations to inform conclusions on the primary PM2.5
standards (U.S. EPA, 2020, section 3.2.3.2.1). For example, the overall
mean PM2.5 concentrations reported by key epidemiologic
studies are not the same as the ambient concentrations used by the EPA
to determine whether areas meet or violate the PM NAAQS. Overall mean
PM2.5 concentrations in key studies reflect averaging of
short- or long-term PM2.5 exposure estimates across
locations (i.e., across multiple monitors or across modeled grid cells)
and over time (i.e., over several years). In contrast, to determine
whether areas meet or violate the NAAQS, the EPA measures air pollution
concentrations at individual monitors (i.e., concentrations are not
averaged across monitors) and calculates ``design values'' at monitors
meeting appropriate data quality and completeness criteria. For the
annual PM2.5 standard, design values are calculated as the
annual arithmetic mean PM2.5 concentration, averaged over 3
years (described in appendix N of 40 CFR part 50). For an area to meet
the NAAQS, all valid design values in that area, including the highest
monitored values, must be at or below the level of the standard.
Additional uncertainties associated with using the PM2.5
concentrations reported by key epidemiologic studies to inform
conclusions on the primary PM2.5 standards result from the
fact that (1) epidemiologic studies do not identify specific
PM2.5 exposures that result in health effects or exposures
below which effects do not occur and (2) exposure estimates in some
recent studies are based on hybrid modeling approaches for which
performance depends on the availability of monitoring data and varies
by location. These results and uncertainties are discussed in detail in
the PA (U.S. EPA, 2020, section 3.2.3.2.1).
PM2.5 Pseudo-Design Values in Epidemiologic Study Locations
As noted above, a key uncertainty in using study-reported
PM2.5 concentrations to inform conclusions on the primary
PM2.5 standards is that they reflect the averages of daily
or annual PM2.5 air quality concentrations or exposure
estimates in the study population over the years examined by the study,
and are not the same as the PM2.5 design values used by the
EPA to determine whether areas meet the NAAQS. Therefore, the PA also
considers a second approach to evaluating information from
epidemiologic studies. In this approach, the PA calculates study area
air quality metrics similar to PM2.5 design values (i.e.,
referred to in the PA as pseudo-design values; U.S. EPA, 2020, section
3.2.3.2.2) and considers the degree to which such metrics indicate that
study area air quality would likely have met or violated the current
standards during study periods. When pseudo-design values in individual
study locations are linked with the populations living in those
locations, or with the number of study-specific health events recorded
in those locations, these values can provide insight into the degree to
which reported health effect associations are based on air quality
likely to have met or violated the current (or alternative) primary
PM2.5 standards. The results of these analyses are
summarized below in Table 1 (from U.S. EPA, 2020, Appendix B, Tables B-
5 and B-6).
Table 1--Summary of Results from Analysis of PM2.5 Pseudo-Design Values
in Locations of Key U.S. and Canadian Multicity Studies
[From U.S. EPA, 2020, Table B-5]
------------------------------------------------------------------------
Percent of population/health events in Number of studies (of the
locations meeting current standards 29 evaluated)
------------------------------------------------------------------------
> 25%..................................... 17
> 50%..................................... 9
> 75%..................................... 4
< 25%..................................... 12
------------------------------------------------------------------------
Given the results of these analyses, the PA concludes that several
key epidemiologic studies report positive and statistically significant
PM2.5 health effect associations based largely, or entirely,
on air quality likely to be allowed by the current primary
PM2.5 standards (U.S. EPA, 2020, section 3.2.3.3). The PA
also concludes that there are important uncertainties to consider when
using this information to inform conclusions on the primary
PM2.5 standards. For example, for most key multicity
studies, some study locations would likely have met the current primary
standards over study periods while others would likely have violated
one or both standards, complicating the interpretation of these
analyses. In addition, pseudo-design values are averaged over multiyear
study periods of varying lengths, rather than reflecting the three-year
averages of actual design values; analyses necessarily focus on
locations with at least one PM2.5 monitor, while unmonitored
areas are not included; and recent changes to PM2.5
monitoring requirements are not reflected in analyses of pseudo-design
values. These results and uncertainties are discussed in greater detail
in the PA (U.S. EPA, 2020, section 3.2.3.2.2).
b. Risk-Based Considerations
In addition to evaluating PM2.5 concentrations in
locations of key epidemiologic studies, the PA includes a risk
assessment that estimates population-level health risks associated with
PM2.5 air quality that has been adjusted to simulate air
quality scenarios of policy interest (e.g., ``just meeting'' the
current standards). The general approach to estimating
PM2.5-associated health risks combines concentration-
response functions from epidemiologic studies with model-based
PM2.5 air quality surfaces, baseline health incidence data,
and population demographics for forty-seven urban study areas (U.S.
EPA, 2020, section 3.3, Figure 3-10 and Appendix C).
The risk assessment estimates that the current primary
PM2.5 standards could allow a substantial number of
PM2.5-associated deaths in the U.S. For example, when air
quality in the 47 study areas is adjusted to simulate just meeting the
current standards, the risk assessment estimates from about 16,000 to
17,000 long-term PM2.5 exposure-related deaths from ischemic
heart disease in a single year (i.e., confidence intervals range from
about 12,000 to
[[Page 24118]]
21,000 deaths).\42\ Compared to the current annual standard, meeting a
revised annual standard with a lower level is estimated to reduce
PM2.5-associated health risks by about 7 to 9% for a level
of 11.0 [micro]g/m\3\, 14 to 18% for a level of 10.0 [micro]g/m\3\, and
21 to 27% for a level of 9.0 [micro]g/m\3\.
---------------------------------------------------------------------------
\42\ For the only other cause-specific mortality endpoint
evaluated (i.e., lung cancer), substantially fewer deaths were
estimated (U.S. EPA, 2020, section 3.3.2, e.g., Figure 3-5). Risk
estimates were not generated for other ``likely to be causal''
outcome categories (i.e., respiratory effects, nervous system
effects).
---------------------------------------------------------------------------
Limitations in the underlying data and risk assessment approaches
lead to uncertainty in these estimates of PM2.5-associated
risks (e.g., in the size of risk estimates). Uncertainty in risk
estimates results from a number of factors, including assumptions about
the shape of the concentration-response relationship with mortality at
low ambient PM concentrations, the potential for confounding and/or
exposure measurement error in the underlying epidemiologic studies, and
the methods used to adjust PM2.5 air quality. The PA
characterizes these and other sources of uncertainty in risk estimates
using a combination of quantitative and qualitative approaches (U.S.
EPA, 2020, Appendix C, section C.3).
2. CASAC Advice
As part of its review of the draft PA, the CASAC has provided
advice on the adequacy of the public health protection afforded by the
current primary PM2.5 standards.\43\ Its advice is
documented in a letter sent to the EPA Administrator (Cox, 2019a). In
this letter, the committee recommends retaining the current 24-hour
PM2.5 standard but does not reach consensus on whether the
scientific and technical information support retaining or revising the
current annual standard. In particular, though the CASAC agrees that
there is a long-standing body of health evidence supporting
relationships between PM2.5 exposures and various health
outcomes, including mortality and serious morbidity effects, individual
CASAC members ``differ in their assessments of the causal and policy
significance of these associations'' (Cox, 2019a, p. 8 of consensus
responses). Drawing from this evidence, ``some CASAC members'' express
support for retaining the current annual standard while ``other
members'' express support for revising that standard in order to
increase public health protection (Cox, 2019a, p.1 of letter). These
views are summarized below.
---------------------------------------------------------------------------
\43\ The CASAC also provided advice on the draft ISA's
assessment of the scientific evidence (Cox, 2019b) and on the
analyses and information in the draft PA (Cox, 2019a), which drew
from the draft ISA. That advice, and the resulting changes made in
the final ISA and final PA, are summarized above in sections I.C.5,
II.B.1.d, II.B.1.e and II.B.3, and in the final ISA (U.S. EPA, 2019,
ES-3 to ES-4) and the final PA (U.S. EPA, 2020, section 1.4).
---------------------------------------------------------------------------
The CASAC members who support retaining the current annual standard
express the view that substantial uncertainty remains in the evidence
for associations between PM2.5 exposures and mortality or
serious morbidity effects. These committee members assert that ``such
associations can reasonably be explained in light of uncontrolled
confounding and other potential sources of error and bias'' (Cox,
2019a, p. 8 of consensus responses). They note that associations do not
necessarily reflect causal effects, and they contend that recent
epidemiologic studies reporting positive associations at lower
estimated exposure concentrations mainly confirm what was anticipated
or already assumed in setting the 2012 NAAQS. In particular, they
conclude that such studies have some of the same limitations as prior
studies and do not provide new information calling into question the
existing standard. They further assert that ``accountability studies
provide potentially crucial information about whether and how much
decreasing PM2.5 causes decreases in future health effects''
(Cox, 2019a, p. 10), and they cite recent reviews (i.e., Henneman et
al., 2017; Burns et al., 2019) to support their position that in such
studies, ``reductions of PM2.5 concentrations have not
clearly reduced mortality risks'' (Cox, 2019a, p. 8 of consensus
responses). Thus, the committee members who support retaining the
current annual standard advise that, ``while the data on associations
should certainly be carefully considered, this data should not be
interpreted more strongly than warranted based on its methodological
limitations'' (Cox, 2019a, p. 8 of consensus responses).
These members of the CASAC further conclude that the
PM2.5 risk assessment does not provide a valid basis for
revising the current standards. This conclusion is based on concerns
that (1) ``the risk assessment treats regression coefficients as causal
coefficients with no justification or validation provided for this
decision;'' (2) the estimated regression concentration-response
functions ``have not been adequately adjusted to correct for
confounding, errors in exposure estimates and other covariates, model
uncertainty, and heterogeneity in individual biological (causal)
[concentration-response] functions;'' (3) the estimated concentration-
response functions ``do not contain quantitative uncertainty bands that
reflect model uncertainty or effects of exposure and covariate
estimation errors;'' and (4) ``no regression diagnostics are provided
justifying the use of proportional hazards . . . and other modeling
assumptions'' (Cox, 2019a, p. 9 of consensus responses). These
committee members also contend that details regarding the derivation of
concentration-response functions, including specification of the beta
values and functional forms, are not well-documented, hampering the
ability of readers to evaluate these design details. Thus, these
members ``think that the risk characterization does not provide useful
information about whether the current standard is protective'' (Cox,
2019a, p. 11 of consensus responses).
Drawing from their evaluation of the evidence and the risk
assessment, these committee members conclude that ``the Draft PM PA
does not establish that new scientific evidence and data reasonably
call into question the public health protection afforded by the current
2012 PM2.5 annual standard'' (Cox, 2019a, p.1 of letter).
In contrast, ``[o]ther members of CASAC conclude that the weight of
the evidence, particularly reflecting recent epidemiology studies
showing positive associations between PM2.5 and health
effects at estimated annual average PM2.5 concentrations
below the current standard, does reasonably call into question the
adequacy of the 2012 annual PM2.5 [standard] to protect
public health with an adequate margin of safety'' (Cox, 2019a, p.1 of
letter). The committee members who support this conclusion note that
the body of health evidence for PM2.5 includes not only the
repeated demonstration of associations in epidemiologic studies, but
also includes support for biological plausibility established by
controlled human exposure and animal toxicology studies. They point to
recent studies demonstrating that the associations between
PM2.5 and health effects occur in a diversity of locations,
in different time periods, with different populations, and using
different exposure estimation and statistical methods. They conclude
that ``the entire body of evidence for PM health effects justifies the
causality determinations made in the Draft PM ISA'' (Cox, 2019a, p. 8
of consensus responses).
The members of the CASAC who support revising the current annual
standard particularly emphasize recent findings of associations with
PM2.5 in areas with average long-term PM2.5
concentrations below the level of the
[[Page 24119]]
annual standard and studies that show positive associations even when
estimated exposures above 12 [mu]g/m\3\ are excluded from analyses.
They find it ``highly unlikely'' that the extensive body of evidence
indicating positive associations at low estimated exposures could be
fully explained by confounding or by other non-causal explanations
(Cox, 2019a, p. 8 of consensus responses). They additionally conclude
that ``the risk characterization does provide a useful attempt to
understand the potential impacts of alternate standards on public
health risks'' (Cox, 2019a, p. 11 of consensus responses). These
committee members conclude that the evidence available in this review
reasonably calls into question the protection provided by the current
primary PM2.5 standards and supports revising the annual
standard to increase that protection (Cox, 2019a).
3. Administrator's Proposed Decision on the Current Primary
PM2.5 Standards
This section summarizes the Administrator's considerations and
conclusions related to the current primary PM2.5 standards
and presents his proposed decision to retain those standards, without
revision. As described above (section II.A.2), his approach to
considering the adequacy of the current standards focuses on evaluating
the public health protection afforded by the annual and 24-hour
standards, taken together, against mortality and morbidity associated
with long- or short-term PM2.5 exposures. This approach
recognizes that changes in PM2.5 air quality designed to
meet either the annual or the 24-hour standard would likely result in
changes to both long-term average and short-term peak PM2.5
concentrations and that the protection provided by the suite of
standards results from the combination of all of the elements of those
standards (i.e., indicator, averaging time, form, level). Thus, the
Administrator's consideration of the public health protection provided
by the current primary PM2.5 standards is based on his
consideration of the combination of the annual and 24-hour standards,
including the indicators (PM2.5), averaging times, forms
(arithmetic mean and 98th percentile, averaged over three years), and
levels (12.0 [mu]g/m\3\, 35 [mu]g/m\3\) of those standards.
In establishing primary standards under the Act that are
``requisite'' to protect public health with an adequate margin of
safety, the Administrator is seeking to establish standards that are
neither more nor less stringent than necessary for this purpose. He
recognizes that the requirement to provide an adequate margin of safety
was intended to address uncertainties associated with inconclusive
scientific and technical information and to provide a reasonable degree
of protection against hazards that research has not yet identified.
However, the Act does not require that primary standards be set at a
zero-risk level; rather, the NAAQS must be sufficiently protective, but
not more stringent than necessary.
Given these requirements, the Administrator's final decision in
this review will be a public health policy judgment drawing upon
scientific and technical information examining the health effects of
PM2.5 exposures, including how to consider the range and
magnitude of uncertainties inherent in that information. This public
health policy judgment will be based on an interpretation of the
scientific and technical information that neither overstates nor
understates its strengths and limitations, nor the appropriate
inferences to be drawn, and will be informed by the Administrator's
consideration of advice from the CASAC and public comments received on
this proposal document.
With regard to the CASAC, the Administrator recognizes that while
the committee supports retaining the current 24-hour PM2.5
standard, it does not reach consensus on the annual standard (Cox,
2019a, pp. 1-3 of letter). In particular, some members of the CASAC
conclude that the new scientific evidence and data do not reasonably
call into question the public health protection afforded by the current
annual standard, while other members conclude that the weight of the
evidence does reasonably call into question the adequacy of that
standard (Cox, 2019a, p. 1 of letter).
As discussed above (II.C.2), the CASAC members who support
retaining the annual standard emphasize their concerns with available
PM2.5 epidemiologic studies. They assert that recent studies
``mainly confirmed what had already been anticipated or assumed in
setting the 2012 NAAQS'' (Cox, 2019a, p. 8 consensus responses) and do
not provide a basis for revising the current standards. They also
identify several key concerns regarding the associations reported in
PM2.5 epidemiologic studies and conclude that ``while the
data on associations should certainly be carefully considered, this
data should not be interpreted more strongly than warranted based on
its methodological limitations'' (Cox, 2019a, p. 8 consensus
responses).
One of the methodological limitations highlighted by these
committee members is that associations reported in epidemiologic
studies are not necessarily indicative of causal relationships and such
associations ``can reasonably be explained in light of uncontrolled
confounding and other potential sources of error and bias'' (Cox,
2019a, p. 8). Thus, these committee members do not think that recent
epidemiologic studies reporting health effect associations at
PM2.5 air quality concentrations likely to have met the
current primary standards support revising those standards.
Consistent with the views expressed by these CASAC members, the
Administrator recognizes that epidemiologic studies examine
associations between distributions of PM2.5 air quality and
health outcomes, and they do not identify particular PM2.5
exposures that cause effects (U.S. EPA, 2020, section 3.1.2). In
contrast, he notes that experimental studies (i.e., controlled human
exposure, animal toxicology) do provide evidence for health effects
following particular PM2.5 exposures under carefully
controlled laboratory conditions (e.g., U.S. EPA, 2015, Preamble
Chapters 5 and 6). He further notes that the evidence for a given
PM2.5-related health outcome is strengthened when results
from experimental studies demonstrate biologically plausible mechanisms
through which such an outcome could occur (e.g., U.S. EPA, 2015,
Preamble p. 20). Thus, when using the PM2.5 health evidence
to inform conclusions on the adequacy of the current primary standards,
the Administrator is most confident in the potential for
PM2.5 exposures to cause adverse effects at concentrations
supported by multiple types of studies, including experimental studies
as well as epidemiologic studies.
In light of this approach to considering the evidence, the
Administrator recognizes that controlled human exposure and animal
toxicology studies report a wide range of effects, many of which are
plausibly linked to the serious cardiovascular and respiratory outcomes
reported in epidemiologic studies (including mortality), though the
PM2.5 exposures examined in these studies are above the
concentrations typically measured in areas meeting the current annual
and 24-hour standards (U.S. EPA, 2020, section 3.2.3.1). In the absence
of evidence from experimental studies that PM2.5 exposures
typical of areas meeting the current annual and 24-hour standards can
activate biological pathways that plausibly contribute to serious
health outcomes, the Administrator is cautious about placing too much
weight on reported PM2.5 health effect associations for air
quality
[[Page 24120]]
meeting those standards. He concludes that such associations alone,
without supporting experimental evidence at similar PM2.5
concentrations, leave important questions unanswered regarding the
degree to which the typical PM2.5 exposures likely to occur
in areas meeting the current standards can cause the mortality or
morbidity outcomes reported in epidemiologic studies. Given this
concern, the Administrator does not think that recent epidemiologic
studies reporting health effect associations at PM2.5 air
quality concentrations likely to have met the current primary standards
support revising those standards. Rather, he judges that the overall
body of evidence, including controlled human exposure and animal
toxicological studies, in addition to epidemiologic studies, indicates
continuing uncertainty in the degree to which adverse effects could
result from PM2.5 exposures in areas meeting the current
annual and 24-hour standards.
The Administrator additionally considers the emerging body of
evidence from studies examining past reductions in ambient
PM2.5, and the degree to which those reductions have
resulted in public health improvements. As an initial matter, he notes
the observation from some CASAC members (i.e., those who support
retaining the current annual standard) that in accountability studies,
``reductions of PM2.5 concentrations have not clearly
reduced mortality risks, especially when confounding was tightly
controlled'' (Cox, 2019a, p. 8). The Administrator recognizes that
interpreting such studies in the context of the current primary
PM2.5 standards is also complicated by the fact that some of
the available studies have not evaluated PM2.5 specifically
(e.g., as opposed to PM10 or total suspended particulates),
did not show changes in PM2.5 air quality, or have not been
able to disentangle health impacts of the interventions from background
trends in health (U.S. EPA, 2020, section 3.5.1). He further recognizes
that the small number of available studies that do report public health
improvements following past declines in ambient PM2.5 have
not examined air quality meeting the current standards (U.S. EPA, 2020,
Table 3-3). This includes recent U.S. studies that report increased
life expectancy, decreased mortality, and decreased respiratory effects
following past declines in ambient PM2.5 concentrations.
Such studies have examined ``starting'' annual average PM2.5
concentrations (i.e., prior to the reductions being evaluated) ranging
from about 13 to > 20 [mu]g/m\3\ (i.e., U.S. EPA, 2020, Table 3-3). It
also includes a recent study conducted in Japan that reports reduced
mortality following reductions in ambient PM2.5 due to the
introduction of diesel emission controls (Yorifuji et al., 2016). As in
the U.S. studies, ambient PM2.5 concentrations in this study
were above those allowed by the current primary PM2.5
standards. Given the lack of studies reporting public health
improvements attributable to reductions in ambient PM2.5 in
locations meeting the current standards, together with his broader
concerns regarding the lack of experimental studies examining
PM2.5 exposures typical of areas meeting the current
standards (discussed above), the Administrator judges that there is
considerable uncertainty in the potential for increased public health
protection from further reductions in ambient PM2.5
concentrations beyond those achieved under the current primary
PM2.5 standards.
In addition to the evidence, the Administrator considers the
potential implications of the risk assessment for his proposed
decision. In doing so, he notes that all risk assessments have
limitations and that, in previous reviews, these limitations have often
resulted in less weight being placed on quantitative estimates of risk
than on the underlying scientific evidence itself (e.g., 78 FR 3128,
January 15, 2013). Such limitations in risk estimates can result from
uncertainty in the shapes of concentration-response functions,
particularly at low concentrations; uncertainties in the methods used
to adjust air quality; and uncertainty in estimating risks for
populations, locations and air quality distributions different from
those examined in the underlying epidemiologic study (U.S. EPA, 2020,
section 3.3.2.4).
In addition to these general uncertainties with risk assessments,
the Administrator notes the concerns expressed by members of the CASAC
who support retaining the current standards. Their concerns largely
reflect their overall views on the limitations in the PM2.5
epidemiologic evidence, which provides key inputs to the risk
assessment. These committee members assert that ``the conclusions from
the risk assessment do not comprise valid empirical evidence or grounds
for revising the current NAAQS'' (Cox, 2019a, p. 9 consensus
responses). As discussed above, the Administrator agrees with the broad
concerns expressed by these members of the CASAC regarding associations
at PM2.5 concentrations meeting the current standards. He
further notes their concerns regarding the characterization of
uncertainty in the risk assessment and the evaluation of modeling
assumptions (Cox, 2019a). In light of these concerns, together with the
more general uncertainty in risk estimates summarized above, the
Administrator judges it appropriate to place little weight on
quantitative estimates of PM2.5-associated mortality risk in
reaching conclusions on the primary PM2.5 standards.
When the above considerations are taken together, the Administrator
proposes to conclude that the scientific evidence that has become
available since the last review of the PM NAAQS, together with the
analyses in the PA based on that evidence, does not call into question
the public health protection provided by the current annual and 24-hour
PM2.5 standards. In particular, the Administrator judges
that there is considerable uncertainty in the potential public health
impacts of reductions in ambient PM2.5 below the
concentrations achieved under the current primary standards and,
therefore, that standards more stringent than the current standards
(e.g., with lower levels) are not supported. That is, he judges that
such standards would be more than requisite to protect the public
health with an adequate margin of safety. As described above, this
judgment reflects his consideration of the uncertainties in the
potential implications of recent epidemiologic studies due in part to
the lack of supporting evidence from experimental studies and
retrospective accountability studies conducted at PM2.5
concentrations meeting the current standards.
For the 24-hour standard, he notes that this judgment is consistent
with the consensus advice of the CASAC (Cox, 2019). For the annual
standard, this judgment is consistent with the advice of some CASAC
members and reflects the Administrator's disagreement with the
``[o]ther members of CASAC'' who recommend revising the current annual
standard based largely on evidence from recent epidemiology studies
(Cox, 2019a, p. 1 of letter).
In addition, based on the Administrator's review of the science,
including experimental and accountability studies conducted at levels
just above the current standard, he judges that the degree of public
health protection provided by the current standard is not greater than
warranted. This judgment, together with the fact that no CASAC member
expressed support for a less stringent standard, leads the
Administrator to conclude that standards less stringent
[[Page 24121]]
than the current standards (e.g., with higher levels) are also not
supported.
When the above information is taken together, the Administrator
proposes to conclude that the available scientific evidence and
technical information continue to support the current annual and 24-
hour PM2.5 standards. This proposed conclusion reflects the
fact that important limitations in the evidence remain. The
Administrator proposes to conclude that these limitations lead to
considerable uncertainty regarding the potential public health
implications of revising the existing suite of PM2.5
standards. Given this uncertainty, and the advice from some CASAC
members, he proposes to conclude that the current suite of primary
standards, including the current indicators (PM2.5),
averaging times (annual and 24-hour), forms (arithmetic mean and 98th
percentile, averaged over three years) and levels (12.0 [mu]g/m\3\, 35
[mu]g/m\3\), when taken together, remain requisite to protect the
public health. Therefore, the Administrator proposes to retain the
current suite of primary PM2.5 standards, without revision,
in this review. He solicits comment on this proposed decision and on
the supporting rationale described above.
III. Rationale for Proposed Decisions on the Primary PM10 Standard
The current primary PM10 standard is intended to protect
the public health against exposures to PM10-2.5 (78 FR 3164,
January 15, 2013). This section provides the rationale supporting the
Administrator's proposed decision to retain the current primary
PM10 standard. Section III.A summarizes the Agency's
approach to reaching a decision on the primary PM10 standard
in the last review and presents the general approach to reaching a
proposed decision in this review. Section III.B summarizes the
scientific evidence for PM10-2.5-related health effects.
Section III.C presents the Administrator's proposed conclusions
regarding the adequacy of the current primary PM10 standard.
A. General Approach
1. Approach Used in the Last Review
The last review of the PM NAAQS was completed in 2012 (78 FR 3086,
January 15, 2013). In that review the EPA retained the existing primary
24-hour PM10 standard, with its level of 150 [mu]g/m\3\ and
its one-expected-exceedance form on average over three years, to
continue to provide public health protection against exposures to
PM10-2.5. In support of this decision, the prior
Administrator emphasized her consideration of three issues: (1) The
extent to which it was appropriate to maintain a standard that provides
some measure of protection against all PM10-2.5 (regardless
of composition or source or origin), (2) the extent to which a standard
with a PM10 indicator can provide protection against
exposures to PM10-2.5, and (3) the degree of public health
protection provided by the existing PM10 standard. Her
consideration of each of these issues is summarized below.
First, the prior Administrator judged that the evidence provided
``ample support for a standard that protects against exposures to all
thoracic coarse particles, regardless of their location or source of
origin'' (78 FR 3176, January 15, 2013). In support of this, she noted
that epidemiologic studies had reported positive associations between
PM10-2.5 and mortality or morbidity in a large number of
cities across North America, Europe, and Asia, encompassing a variety
of environments where PM10-2.5 sources and composition are
expected to vary widely. Though most of the available studies examined
associations in urban areas, she noted that some studies had also
linked mortality and morbidity with relatively high ambient
concentrations of particles of non-urban crustal origin. In light of
this body of available evidence, and consistent with the CASAC's
advice, the prior Administrator concluded that it was appropriate to
maintain a standard that provides some measure of protection against
exposures to all thoracic coarse particles, regardless of their
location, source of origin, or composition (78 FR 3176, January 15,
2013).
In reaching the conclusion that it was appropriate to retain a
PM10 indicator for a standard meant to protect against
exposures to ambient PM10-2.5, the prior Administrator noted
that PM10 mass includes both coarse PM (PM10-2.5)
and fine PM (PM2.5). As a result, the concentration of
PM10-2.5 allowed by a PM10 standard set at a
single level declines as the concentration of PM2.5
increases. Because PM2.5 concentrations tend to be higher in
urban areas than rural areas, she observed that a PM10
standard would generally allow lower PM10-2.5 concentrations
in urban areas than in rural areas. She judged it appropriate to
maintain such a standard given that much of the evidence for
PM10-2.5 toxicity, particularly at relatively low particle
concentrations, came from study locations where thoracic coarse
particles were of urban origin, and given the possibility that
PM10-2.5 contaminants in urban areas could increase particle
toxicity. Thus, in the last review the prior Administrator concluded
that it remained appropriate to maintain a standard that allows lower
ambient concentrations of PM10-2.5 in urban areas, where the
evidence was strongest that exposure to thoracic coarse particles was
associated with morbidity and mortality, and higher concentrations in
non-urban areas, where the public health concerns were less certain.
The prior Administrator concluded that the varying concentrations of
coarse particles that would be permitted in urban versus non-urban
areas under the 24-hour PM10 standard, based on the varying
levels of PM2.5 present, appropriately reflected the
differences in the strength of evidence regarding coarse particle
health effects.
Finally, in specifically evaluating the degree of public health
protection provided by the primary PM10 standard, with its
level of 150 [mu]g/m\3\ and its one-expected-exceedance form on average
over three years, the prior Administrator recognized that the available
health evidence and air quality information was much more limited for
PM10-2.5 than for PM2.5. In particular, the
strongest evidence for health effects attributable to
PM10-2.5 exposure was for cardiovascular effects,
respiratory effects, and/or premature mortality following short-term
exposures. For each of these categories of effects, the 2009 ISA
concluded that the evidence was ``suggestive of a causal relationship''
(U.S. EPA, 2009c, section 2.3.3). These determinations contrasted with
those for PM2.5, as described in Chapter 3 above, which were
determined in the ISA to be either ``causal'' or ``likely to be
causal'' for mortality, cardiovascular effects, and respiratory effects
(U.S. EPA, 2009c, Tables 2-1 and 2-2).
The prior Administrator judged that the important uncertainties and
limitations associated with the PM10-2.5 evidence and
information raised questions as to whether additional public health
improvements would be achieved by revising the existing PM10
standard. She specifically noted several uncertainties and limitations,
including the following:
The number of epidemiologic studies that have employed
copollutant models to address the potential for confounding,
particularly by PM2.5, was limited. Therefore, the extent to
which PM10-2.5 itself, rather than one or more copollutants,
contributes to reported health effects remained uncertain.
Only a limited number of experimental studies provided
support for the associations reported in epidemiologic studies,
resulting in
[[Page 24122]]
further uncertainty regarding the plausibility of the associations
between PM10-2.5 and mortality and morbidity reported in
epidemiologic studies.
Limitations in PM10-2.5 monitoring data (i.e.,
limited data available from FRM/FEM sampling methods) and the different
approaches used to estimate PM10-2.5 concentrations across
epidemiologic studies resulted in uncertainty in the ambient
PM10-2.5 concentrations at which the reported effects occur,
increasing uncertainty in estimates of the extent to which changes in
ambient PM10-2.5 concentrations would likely impact public
health.
While PM10-2.5 effect estimates reported for
mortality and morbidity were generally positive, most were not
statistically significant, even in single-pollutant models. This
included effect estimates reported in some study locations with
PM10 concentrations above those allowed by the current 24-
hour PM10 standard.
The composition of PM10-2.5, and the effects
associated with various components, were also key uncertainties in the
available evidence. Without more information on the chemical speciation
of PM10-2.5, the apparent variability in associations across
locations was difficult to characterize.
In considering these uncertainties and limitations, the prior
Administrator particularly emphasized the considerable degree of
uncertainty in the extent to which health effects reported in
epidemiologic studies are due to PM10-2.5 itself, as opposed
to one or more co-occurring pollutants. This uncertainty reflected the
relatively small number of PM10-2.5 studies that had
evaluated copollutant models, particularly copollutant models that
included PM2.5, and the very limited body of controlled
human exposure evidence supporting the plausibility of
PM10-2.5-attributable adverse effects at ambient
concentrations.
When considering the evidence as a whole, the prior Administrator
concluded that the degree of public health protection provided by the
current PM10 standard against exposures to
PM10-2.5 should be maintained (i.e., neither increased nor
decreased). Her judgment that protection did not need to be increased
was supported by her consideration of uncertainties in the overall body
of evidence. Her judgment that the degree of public health protection
provided by the current standard is not greater than warranted was
supported by the observation that positive and statistically
significant associations with mortality were reported in some single-
city U.S. study locations likely to have violated the current
PM10 standard. Thus, the prior Administrator concluded that
the existing 24-hour PM10 standard, with its one-expected
exceedance form on average over three years and a level of 150 [mu]g/
m\3\, was requisite to protect public health with an adequate margin of
safety against effects that have been associated with
PM10-2.5. In light of this conclusion, the EPA retained the
existing PM10 standard.
2. Approach in the Current Review
The approach for this review builds on the last review, taking into
account the more recent scientific information now available. The
approach summarized below draws from the approach taken in the PA (U.S.
EPA, 2020) and is most fundamentally based on using the ISA's
assessment of the current scientific evidence for health effects of
PM10-2.5 exposures (U.S. EPA, 2019).
As discussed above for PM2.5 (II.A.2), the approach in
the PA places the greatest weight on effects for which the evidence has
been determined to demonstrate a ``causal'' or a ``likely to be
causal'' relationship with PM exposures (U.S. EPA, 2019). This approach
focuses policy considerations and conclusions on health outcomes for
which the evidence is strongest. Unlike for PM2.5, the ISA
does not identify any PM10-2.5-related health outcomes for
which the evidence supports either a ``causal'' or a ``likely to be
causal'' relationship. Thus, for PM10-2.5 the PA considers
the evidence determined to be ``suggestive of, but not sufficient to
infer, a causal relationship,'' recognizing the greater uncertainty in
such evidence.
The preamble to the ISA states that ``suggestive'' evidence is
``limited, and chance, confounding, and other biases cannot be ruled
out'' (U.S. EPA, 2015, Preamble Table II). In light of the additional
uncertainty in the evidence for PM10-2.5-related health
outcomes, compared to the evidence supporting ``causal'' or ``likely to
be causal'' relationships for PM2.5, the approach to
evaluating the primary PM10 standard in this review is more
limited than the approach to evaluating the primary PM2.5
standards (discussed in II.A.2). Specifically, the approach for
PM10 does not include evaluations of air quality
distributions in locations of individual epidemiologic studies,
comparisons of experimental exposures with ambient air quality, or the
quantitative assessment of PM10-2.5 health risks. The
substantial uncertainty in such analyses, if they were to be conducted
based on the currently available PM10-2.5 health studies,
would limit their utility for informing conclusions on the primary
PM10 standard. Therefore, as discussed further below, the
focus of the evaluation of the primary PM10 standard is on
the overall body of evidence for PM10-2.5-related health
effects. This includes consideration of the degree to which
uncertainties in the evidence from the last review have been reduced
and the degree to which new uncertainties have been identified.
B. Health Effects Related to Thoracic Coarse Particle Exposures
This section briefly outlines the key evidence for health effects
associated with PM10-2.5 exposures. This evidence is
discussed more fully in the ISA (U.S. EPA, 2019) and the PA (U.S. EPA,
2020, Chapter 4).
While studies conducted since the last review have strengthened
support for relationships between PM10-2.5 exposures and
some health outcomes (discussed below), several key uncertainties in
the evidence from the last review have, to date, ``still not been
addressed'' (U.S. EPA, 2019, section 1.4.2, p. 1-41). For example,
epidemiologic studies available in the last review relied on various
methods to estimate PM10-2.5 exposures, and these methods
had not been systematically compared to evaluate spatial and temporal
correlations in exposure estimates. Methods included (1) calculating
the difference between PM10 and PM2.5
concentrations at co-located monitors, (2) calculating the difference
between county-wide averages of monitored PM10 and
PM2.5 based on monitors that are not necessarily co-located,
and (3) direct measurement of PM10-2.5 using a dichotomous
sampler (U.S. EPA, 2019, section 1.4.2). In the current review, more
recent epidemiologic studies continue to use these approaches to
estimate PM10-2.5 concentrations. Additionally, some recent
studies estimate long-term PM10-2.5 exposures as the
difference between PM10 and PM2.5 concentrations
based on information from spatiotemporal or land use regression (LUR)
models, in addition to monitors. As in the last review, the various
methods used to estimate PM10-2.5 concentrations have not
been systematically evaluated (U.S. EPA, 2019, section 3.3.1.1),
contributing to uncertainty regarding the spatial and temporal
correlations in PM10-2.5 concentrations across methods and
in the PM10-2.5 exposure estimates used in epidemiologic
studies (U.S. EPA, 2019, section 2.5.1.2.3 and section 2.5.2.2.3).
Given the greater spatial and temporal variability of
PM10-2.5 and fewer PM10-2.5 monitoring sites,
compared to PM2.5,
[[Page 24123]]
this uncertainty is particularly important for the coarse size
fraction.
Beyond uncertainty associated with PM10-2.5 exposure
estimates in epidemiologic studies, the limited information on the
potential for confounding by copollutants and the limited support
available for the biological plausibility of serious effects following
PM10-2.5 exposures also continue to contribute broadly to
uncertainty in the PM10-2.5 health evidence. Uncertainty
related to potential confounding stems from the relatively small number
of epidemiologic studies that have evaluated PM10-2.5 health
effect associations in copollutants models with both gaseous pollutants
and other PM size fractions. Uncertainty related to the biological
plausibility of serious effects caused by PM10-2.5 exposures
results from the small number of controlled human exposure and animal
toxicology \44\ studies that have evaluated the health effects of
experimental PM10-2.5 inhalation exposures. The evidence
supporting the ISA's ``suggestive'' causality determinations for
PM10-2.5, including uncertainties in this evidence, is
summarized below in sections III.B.1 to III.B.7.
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\44\ Compared to humans, smaller fractions of inhaled
PM10-2.5 penetrate into the thoracic regions of rats and
mice (U.S. EPA, 2019, section 4.1.6), contributing to the relatively
limited evaluation of PM10-2.5 exposures in animal
studies.
---------------------------------------------------------------------------
1. Mortality
a. Long-Term Exposures
Due to the dearth of studies examining the association between
long-term PM10-2.5 exposure and mortality, the 2009 PM ISA
concluded that the evidence was ``inadequate to determine if a causal
relationship exists'' (U.S. EPA, 2009c). Since the completion of the
2009 ISA, some recent cohort studies conducted in the U.S. and Europe
report positive associations between long-term PM10-2.5
exposure and total (nonaccidental) mortality, though results are
inconsistent across studies (U.S. EPA, 2019, Table 11-11). The
examination of copollutant models in these studies remains limited and,
when included, PM10-2.5 effect estimates are often
attenuated after adjusting for PM2.5 (U.S. EPA, 2019, Table
11-11). Across studies, PM10-2.5 exposure concentrations are
estimated using a variety of approaches, including direct measurements
from dichotomous samplers, calculating the difference between
PM10 and PM2.5 concentrations measured at
collocated monitors, and calculating difference of area-wide
concentrations of PM10 and PM2.5. As discussed
above, temporal and spatial correlations between these approaches have
not been evaluated, contributing to uncertainty regarding the potential
for exposure measurement error (U.S. EPA, 2019, section 3.3.1.1 and
Table 11-11). The 2019 ISA concludes that this uncertainty ``reduces
the confidence in the associations observed across studies'' (U.S. EPA,
2019, p. 11-125). The ISA additionally concludes that the evidence for
long-term PM10-2.5 exposures and cardiovascular effects,
respiratory morbidity, and metabolic disease provide limited biological
plausibility for PM10-2.5-related mortality (U.S. EPA, 2019,
sections 11.4.1 and 11.4). Taken together, the 2019 ISA concludes that,
``this body of evidence is suggestive, but not sufficient to infer,
that a causal relationship exists between long-term PM10-2.5
exposure and total mortality'' (U.S. EPA, 2019, p. 11-125).
b. Short-Term Exposures
The 2009 ISA concluded that the evidence is ``suggestive of a
causal relationship between short-term exposure to PM10-2.5
and mortality'' (U.S. EPA, 2009c). Since the completion of the 2009
ISA, multicity epidemiologic studies conducted primarily in Europe and
Asia continue to provide consistent evidence of positive associations
between short-term PM10-2.5 exposure and total
(nonaccidental) mortality (U.S. EPA, 2019, Table 11-9). Although these
studies contribute to increasing confidence in the PM10-2.5-
mortality relationship, the use of a variety of approaches to estimate
PM10-2.5 exposures continues to contribute uncertainty to
the associations observed. In addition, the 2019 ISA notes that an
analysis by Adar et al. (2014) indicates ``possible evidence of
publication bias, which was not observed for PM2.5'' (U.S.
EPA, 2019, section 11.3.2, p. 11-106). Recent studies expand the
assessment of potential copollutant confounding of the
PM10-2.5-mortality relationship and provide evidence that
PM10-2.5 associations generally remain positive in
copollutant models, though associations are attenuated in some
instances (U.S. EPA, 2019, section 11.3.4.1, Figure 11-28, Table 11-
10). The 2019 ISA concludes that, overall, the assessment of potential
copollutant confounding is limited due to the lack of information on
the correlation between PM10-2.5 and gaseous pollutants and
the small number of locations in which copollutant analyses have been
conducted. Associations with cause-specific mortality provide some
support for associations with total (nonaccidental) mortality, though
associations with cause-specific mortality, particularly respiratory
mortality, are more uncertain (i.e., wider confidence intervals) and
less consistent (U.S. EPA, 2019, section 11.3.7). The ISA concludes
that the evidence for PM10-2.5-related cardiovascular and
respiratory effects provides only limited support for the biological
plausibility of a relationship between short-term PM10-2.5
exposure and cardiovascular mortality (U.S. EPA, 2019, Section 11.3.7).
Based on the overall evidence, the 2019 ISA concludes that, ``this body
of evidence is suggestive, but not sufficient to infer, that a causal
relationship exists between short-term PM10-2.5 exposure and
total mortality'' (U.S. EPA, 2019, p. 11-120).
2. Cardiovascular Effects
a. Long-term Exposures
In the 2009 PM ISA, the evidence describing the relationship
between long-term exposure to PM10-2.5 and cardiovascular
effects was characterized as ``inadequate to infer the presence or
absence of a causal relationship.'' The limited number of epidemiologic
studies reported contradictory results and experimental evidence
demonstrating an effect of PM10-2.5 on the cardiovascular
system was lacking (U.S. EPA, 2019, section 6.4).
The evidence relating long-term PM10-2.5 exposures to
cardiovascular mortality remains limited, with no consistent pattern of
associations across studies and, as discussed above, uncertainty
stemming from the use of various approaches to estimate
PM10-2.5 concentrations (U.S. EPA, 2019, Table 6-70). The
evidence for associations with cardiovascular morbidity has grown and,
while results across studies are not entirely consistent, some
epidemiologic studies report positive associations with IHD and
myocardial infarction (MI) (U.S. EPA, 2019, Figure 6-34); stroke (U.S.
EPA, 2019, Figure 6-35); atherosclerosis (U.S. EPA, 2019, section
6.4.5); venous thromboembolism (VTE) (U.S. EPA, 2019, section 6.4.7);
and blood pressure and hypertension (U.S. EPA, 2019, Section 6.4.6).
PM10-2.5 cardiovascular mortality effect estimates are often
attenuated, but remain positive, in copollutants models that adjust for
PM2.5. For morbidity outcomes, associations are inconsistent
in copollutant models that adjust for PM2.5, NO2,
and chronic noise pollution (U.S. EPA, 2019, p. 6-276). The lack of
toxicological evidence for long-term PM10-2.5 exposures
represents a substantial data gap (U.S. EPA, 2019, section 6.4.10),
resulting in the 2019
[[Page 24124]]
ISA conclusion that ``evidence from experimental animal studies is of
insufficient quantity to establish biological plausibility'' (U.S. EPA,
2019, p. 6-277). Based largely on the observation of positive
associations in some high-quality epidemiologic studies, the ISA
concludes that ``evidence is suggestive of, but not sufficient to
infer, a causal relationship between long-term PM10-2.5
exposure and cardiovascular effects'' (U.S. EPA, 2019, p. 6-277).
b. Short-Term Exposures
The 2009 ISA found that the available evidence for short-term
PM10-2.5 exposure and cardiovascular effects was
``suggestive of a causal relationship.'' This conclusion was based on
several epidemiologic studies reporting associations between short-term
PM10-2.5 exposure and cardiovascular effects, including IHD
hospitalizations, supraventricular ectopy, and changes in heart rate
variability (HRV). In addition, dust storm events resulting in high
concentrations of crustal material were linked to increases in total
cardiovascular disease emergency department visits and hospital
admissions. However, the 2009 ISA noted the potential for exposure
measurement error and copollutant confounding in these epidemiologic
studies. In addition, there was only limited evidence of cardiovascular
effects from a small number of experimental studies (e.g. animal
toxicological studies and controlled human exposure studies) that
examined short-term PM10-2.5 exposures (U.S. EPA, 2009c,
section 6.2.12.2). In the last review, key uncertainties included the
potential for exposure measurement error, copollutant confounding, and
limited evidence of biological plausibility for cardiovascular effects
following inhalation exposure (U.S. EPA, 2019, section 6.3.13).
The evidence for short-term PM10-2.5 exposure and
cardiovascular outcomes has expanded since the last review, though
important uncertainties remain. The 2019 ISA notes that there are a
small number of epidemiologic studies reporting positive associations
between short-term exposure to PM10-2.5 and cardiovascular-
related morbidity outcomes. However, there is limited evidence to
suggest that these associations are biologically plausible, or
independent of copollutant confounding. The ISA also concludes that it
remains unclear how the approaches used to estimate PM10-2.5
concentrations in epidemiologic studies may impact exposure measurement
error. Taken together, the 2019 ISA concludes that ``the evidence is
suggestive of, but not sufficient to infer, a causal relationship
between short-term PM10-2.5 exposures and cardiovascular
effects'' (U.S. EPA, 2019, p. 6-254).
3. Respiratory Effects--Short-Term Exposures
Based on a small number of epidemiologic studies observing
associations with some respiratory effects and limited evidence from
experimental studies to support biological plausibility, the 2009 ISA
(U.S. EPA, 2009c) concluded that the relationship between short-term
exposure to PM10-2.5 and respiratory effects is ``suggestive
of a causal relationship.'' Epidemiologic findings were consistent for
respiratory infection and combined respiratory-related diseases, but
not for COPD. Studies were characterized by overall uncertainty in the
exposure assignment approach and limited information regarding
potential copollutant confounding. Controlled human exposure studies of
short-term PM10-2.5 exposures found no lung function
decrements and inconsistent evidence for pulmonary inflammation. Animal
toxicological studies were limited to those using non-inhalation (e.g.,
intra-tracheal instillation) routes of PM10-2.5 exposure.
Recent epidemiologic findings consistently link PM10-2.5
exposure to asthma exacerbation and respiratory mortality, with some
evidence that associations remain positive (though attenuated in some
studies of mortality) in copollutant models that include
PM2.5 or gaseous pollutants. Studies provide limited
evidence for positive associations with other respiratory outcomes,
including COPD exacerbation, respiratory infection, and combined
respiratory-related diseases (U.S. EPA, 2019, Table 5-36). As noted
above for other endpoints, an uncertainty in these epidemiologic
studies is the lack of a systematic evaluation of the various methods
used to estimate PM10-2.5 concentrations and the resulting
uncertainty in the spatial and temporal variability in
PM10-2.5 concentrations compared to PM2.5 (U.S.
EPA, 2019, sections 2.5.1.2.3 and 3.3.1.1). Taken together, the 2019
ISA concludes that ``the collective evidence is suggestive of, but not
sufficient to infer, a causal relationship between short-term
PM10-2.5 exposure and respiratory effects'' (U.S. EPA, 2019,
p. 5-270).
4. Cancer--Long-Term Exposures
In the last review, little information was available from studies
of cancer following inhalation exposures to PM10-2.5. Thus,
the 2009 ISA determined the evidence was ``inadequate to assess the
relationship between long-term PM10-2.5 exposures and
cancer'' (U.S. EPA, 2009c). Since the 2009 ISA, the assessment of long-
term PM10-2.5 exposure and cancer remains limited, with a
few recent epidemiologic studies reporting positive, but imprecise,
associations with lung cancer incidence. Uncertainty remains in these
studies with respect to exposure measurement error due to the use of
PM10-2.5 predictions that have not been validated by
monitored PM10-2.5 concentrations (U.S. EPA, 2019, sections
3.3.2.3 and 10.3.4). Relatively few experimental studies of
PM10-2.5 have been conducted, though available studies
indicate that PM10-2.5 exhibits two key characteristics of
carcinogens: Genotoxicity and oxidative stress. While limited, such
experimental studies provide some evidence of biological plausibility
for the findings in a small number of epidemiologic studies (U.S. EPA,
2019, section 10.3.4).
Taken together, the small number of epidemiologic and experimental
studies, along with uncertainty with respect to exposure measurement
error, contribute to the determination in the 2019 ISA that, ``the
evidence is suggestive of, but not sufficient to infer, a causal
relationship between long-term PM10-2.5 exposure and
cancer'' (U.S. EPA, 2019, p. 10-87).
5. Metabolic Effects--Long-Term Exposures
The 2009 ISA did not make a causality determination for
PM10-2.5-related metabolic effects. Since the last review,
one epidemiologic study shows an association between long-term
PM10-2.5 exposure and incident diabetes, while additional
cross-sectional studies report associations with effects on glucose or
insulin homeostasis (U.S. EPA, 2019, section 7.4). As discussed above
for other outcomes, uncertainties with the epidemiologic evidence
include the potential for copollutant confounding and exposure
measurement error (U.S. EPA, 2019, Tables 7-15 and 7-15). The evidence
base to support the biological plausibility of metabolic effects
following PM10-2.5 exposures is limited, but a cross-
sectional study that investigated biomarkers of insulin resistance and
systemic and peripheral inflammation may support a pathway leading to
type 2 diabetes (U.S. EPA, 2019, sections 7.4.1 and 7.4.3). Based on
the expanded, though still limited evidence base, the 2019 ISA
concludes that, ``[o]verall, the evidence is
[[Page 24125]]
suggestive of, but not sufficient to infer, a causal relationship
between [long]-term PM10-2.5 exposure and metabolic
effects'' (U.S. EPA, 2019, p. 7-56).
6. Nervous System Effects--Long-Term Exposures
The 2009 ISA did not make a causality determination for
PM10-2.5-related nervous system effects. In the current
review, newly available epidemiologic studies report associations
between PM10-2.5 and impaired cognition and anxiety in
adults in longitudinal analyses (U.S. EPA, 2019, Table 8-25, section
8.4.5). Associations of long-term exposure with neurodevelopmental
effects are not consistently reported in children (U.S. EPA, 2019,
sections 8.4.4 and 8.4.5). Uncertainties in these studies include the
potential for copollutant confounding, as no studies examined
copollutants models (U.S. EPA, 2019, section 8.4.5), and for exposure
measurement error, given the use of various model-based subtraction
methods to estimate PM10-2.5 concentrations (U.S. EPA, 2019,
Table 8-25). In addition, there is only limited animal toxicological
evidence supporting the biological plausibility of nervous system
effects (U.S. EPA, 2019, sections 8.4.1 and 8.4.5). Overall, the 2019
ISA concludes that, ``the evidence is suggestive of, but not sufficient
to infer, a causal relationship between long-term PM10-2.5
exposure and nervous system effects (U.S. EPA, 2019, p. 8-75).
C. Proposed Conclusions on the Current Primary PM10 Standard
This section describes the Administrator's proposed conclusions
regarding the adequacy of the current primary PM10 standard.
The approach to reaching these proposed conclusions draws from the
ISA's assessment of the scientific evidence for health effects
attributable to PM10-2.5 exposures (U.S. EPA, 2019). Section
III.C.1 discusses the evidence-based considerations from the PA.
Section III.C.2 summarizes CASAC advice on the current primary
PM10 standard, based on its review of the draft PA. Section
III.C.3 presents the Administrator's proposed conclusions on the
current primary PM10 standard.
1. Evidence-Based Considerations in the Policy Assessment
In the last review, the strongest evidence for PM10-2.5-
related health effects was for cardiovascular effects, respiratory
effects, and premature mortality following short-term exposures. For
each of these categories of effects, the ISA concluded that the
evidence was ``suggestive of a causal relationship'' (U.S. EPA, 2009c,
section 2.3.3). As summarized in the sections above, key uncertainties
in the evidence resulted from limitations in the approaches used to
estimate ambient PM10-2.5 concentrations in epidemiologic
studies, limited examination of the potential for confounding by co-
occurring pollutants, and limited support for the biological
plausibility of the serious effects reported in many epidemiologic
studies. Since 2009, the evidence base for several PM10-2.5-
related health effects has expanded, broadening our understanding of
the range of health effects linked to PM10-2.5 exposures
(U.S. EPA, 2020, Chapter 4). This includes expanded evidence for the
relationships between long-term exposures and cardiovascular effects,
metabolic effects, nervous system effects, cancer, and mortality.
However, key limitations in the evidence that were identified in the
2009 ISA persist in studies that have become available since the last
review. As discussed in the PA, these limitations include the
following:
The use of a variety of methods to estimate
PM10-2.5 exposures in epidemiologic studies and the lack of
systematic evaluation of these methods, together with the relatively
high spatial and temporal variability in ambient PM10-2.5
concentrations and the small number of monitoring sites, results in
uncertainty in exposure estimates;
The limited number of studies that evaluate
PM10-2.5 health effect associations in copollutant models,
together with evidence from some studies for attenuation of
associations in such models, results in uncertainty in the independence
of PM10-2.5 health effect associations from co-occurring
pollutants;
The limited number of controlled human exposure and animal
toxicology studies of PM10-2.5 inhalation contributes to
uncertainty in the biological plausibility of the PM10-2.5-
related effects reported in epidemiologic studies.
Thus, while new evidence is available for a broader range of health
outcomes in the current review, including an increase in the number of
studies that report effects related to long-term PM10-2.5
exposure, that evidence is subject to the same types of uncertainties
that were identified in the last review of the PM NAAQS. As in the last
review, these uncertainties contribute to the conclusions in the 2019
ISA that the evidence for the PM10-2.5-related health
effects discussed in this section is ``suggestive of, but not
sufficient to infer'' causal relationships.
2. CASAC Advice
As part of its review of the draft PA, the CASAC has provided
advice on the adequacy of the public health protection afforded by the
current primary PM10 standard. As for PM2.5
(section II.C.2), the CASAC's advice is documented in a letter sent to
the EPA Administrator (Cox, 2019a).
In its comments on the draft PA, the CASAC concurs with the draft
PA's overall preliminary conclusions that it is appropriate to consider
retaining the current primary PM10 standard without
revision. The CASAC finds the more limited approach taken for
PM10, compared with the approach taken for PM2.5,
to be ``reasonable and appropriate'' given the less certain evidence
and the conclusion that ``key uncertainties identified in the last
review remain'' (Cox, 2019a, p. 13 of consensus responses). To reduce
these uncertainties in future reviews, the CASAC recommends
improvements to PM10-2.5 exposure assessment, including a
more extensive network for direct monitoring of the PM10-2.5
fraction (Cox, 2019a, p. 13 of consensus responses). The CASAC also
recommends additional human clinical and animal toxicology studies of
the PM10-2.5 fraction to improve the understanding of
biological causal mechanisms and pathways (Cox, 2019a, p. 13 of
consensus responses). Overall, the CASAC agrees with the EPA that ``. .
. the available evidence does not call into question the adequacy of
the public health protection afforded by the current primary
PM10 standard and that evidence supports considering of
retaining the current standard in this review'' (Cox, 2019a, p. 3 of
letter).
3. Administrator's Proposed Decision on the Current Primary
PM10 Standard
This section summarizes the Administrator's considerations and
proposed conclusions related to the current primary PM10
standard and presents his proposed decision to retain that standard,
without revision. As discussed above for PM2.5 (II.C.3), in
establishing primary standards under the Act that are ``requisite'' to
protect the public health with an adequate margin of safety, the
Administrator is seeking to establish standards that are neither more
nor less stringent than necessary for this purpose. He recognizes that
the Act does not require that primary standards be set at a zero-risk
level; rather, the NAAQS must be sufficiently protective, but not more
stringent than necessary.
Given these requirements, and consistent with the primary
PM2.5
[[Page 24126]]
standards discussed above (II.C.3), the Administrator's final decision
in this review will be a public health policy judgment that draws upon
the scientific information examining the health effects of
PM10-2.5 exposures, including how to consider the range and
magnitude of uncertainties inherent in that information. His decision
will require judgments based on an interpretation of the science that
neither overstates nor understates its strengths and limitations, nor
the appropriate inferences to be drawn.
As an initial matter, the Administrator notes that the decision to
retain the primary PM10 standard in the last review
recognized that epidemiologic studies had reported positive
associations between PM10-2.5 and mortality or morbidity in
cities across North America, Europe, and Asia. These studies
encompassed a variety of environments where PM10-2.5 sources
and composition were expected to vary widely. Although most of these
studies examined PM10-2.5 health effect associations in
urban areas, some studies had also linked mortality and morbidity with
relatively high ambient concentrations of particles of non-urban
crustal origin. Drawing from this evidence, the EPA judged it
appropriate to maintain a standard that provides some measure of
protection against exposures to PM10-2.5, regardless of
location, source of origin, or particle composition (78 FR 3176,
January 15, 2013). The Agency further judged it appropriate to retain a
PM10 standard to provide such protection given that the
varying concentrations of PM10-2.5 permitted in urban versus
non-urban areas under a PM10 standard, based on the varying
levels of PM2.5 present (i.e., lower PM10-2.5
concentrations allowed in urban areas, where PM2.5
concentrations tend to be higher), appropriately reflected differences
in the strength of PM10-2.5 health effects evidence.
Since the last review, the Administrator notes that the evidence
for several PM10-2.5-related health effects has expanded,
particularly for long-term exposures. Recent epidemiologic studies
continue to report positive associations with mortality and morbidity
in cities across North America, Europe, and Asia, where
PM10-2.5 sources and composition are expected to vary
widely. While the Administrator recognizes that important uncertainties
remain, as described below, he also recognizes that the expansion in
the evidence since the last review has broadened the range of effects
that have been linked with PM10-2.5 exposures. Such studies
provide an important part of the body of evidence supporting the ISA's
strengthened causality determinations (and new determinations) for
long-term PM10-2.5 exposures and mortality, cardiovascular
effects, metabolic effects, nervous system effects and cancer (U.S.
EPA, 2019; U.S. EPA, 2020, section 4.2). Drawing from his consideration
of this evidence, the Administrator proposes to conclude that the
scientific studies that have become available since the last review do
not call into question the decision to maintain a primary
PM10 standard that provides some measure of public health
protection against PM10-2.5 exposures, regardless of
location, source of origin, or particle composition.
With regard to uncertainties in the evidence, the Administrator
notes that the decision in the last review highlighted limitations in
estimates of ambient PM10-2.5 concentrations used in
epidemiologic studies, the limited evaluation of copollutant models to
address the potential for confounding, and the limited number of
experimental studies supporting biologically plausible pathways for
PM10-2.5-related effects. These and other limitations in the
PM10-2.5 evidence raised questions as to whether additional
public health improvements would be achieved by revising the existing
PM10 standard.
In the current review, despite the expanded body of evidence for
PM10-2.5-related health effects, the Administrator
recognizes that similar uncertainties remain. As summarized above
(III.B), these include uncertainties in the PM10-2.5
exposure estimates used in epidemiologic studies, in the independence
of PM10-2.5 health effect associations, and in support for
the biological plausibility of PM10-2.5-related effects
(e.g., from controlled human exposure and animal toxicology studies)
(U.S. EPA, 2020, section 4.2). These uncertainties contribute to the
determinations in the 2019 ISA that the evidence for key
PM10-2.5-related health effects is ``suggestive of, but not
sufficient to infer'' causal relationships (U.S. EPA, 2019). In light
of his emphasis on evidence supporting ``causal'' and ``likely to be
causal'' relationships (II.A.2, III.A.2), the Administrator judges that
the PM10-2.5-related health effects evidence provides an
uncertain scientific foundation for making standard-setting decisions.
He further judges that, as in the last review, limitations in this
evidence raise questions as to whether additional public health
improvements would be achieved by revising the existing PM10
standard.
In reaching conclusions on the primary PM10 standard,
the Administrator also considers advice from the CASAC. As noted above,
the CASAC recognizes the uncertainties in the evidence for
PM10-2.5-related health effects, stating that ``key
uncertainties identified in the last review remain'' (Cox, 2019a, p. 13
of consensus responses). Given these uncertainties, the CASAC agrees
with the PA conclusion that the evidence ``does not call into question
the adequacy of the public health protection afforded by the current
primary PM10 standard'' (Cox, 2019a, p. 3 of letter). The
CASAC further recommends that this evidence ``supports consideration of
retaining the current standard in this review'' (Cox, 2019a, p. 3 of
letter).
When the above information is taken together, the Administrator
proposes to conclude that the available scientific evidence continues
to support a PM10 standard to provide some measure of
protection against PM10-2.5 exposures. This conclusion
reflects the expanded evidence for PM10-2.5-related health
effects in the current review. However, important limitations in the
evidence remain. Consistent with the decision in the last review, the
Administrator proposes to conclude that these limitations lead to
considerable uncertainty regarding the potential public health
implications of revising the existing PM10 standard. Given
this uncertainty, and consistent with the CASAC's advice, the
Administrator proposes to conclude that the available evidence does not
call into question the adequacy of the public health protection
afforded by the current primary PM10 standard. Therefore, he
proposes to retain the primary PM10 standard, without
revision, in the current review. The Administrator solicits comment on
this proposed decision and on the supporting rationale described above.
IV. Rationale for Proposed Decisions on the Secondary PM Standards
This section presents the rationale for the Administrator's
proposed decision to retain the current secondary PM standards, without
revision. This rationale is based on a thorough review of the latest
scientific information generally published through December 2017,\45\
as presented in the ISA, on non-ecological public welfare effects
[[Page 24127]]
associated with PM and pertaining to the presence of PM in ambient air.
The Administrator's rationale also takes into account the PA's
evaluation of the policy-relevant information in the ISA and
quantitative analyses of air quality related to visibility impairment
and the CASAC's advice and recommendations, as reflected in discussions
of the drafts of the ISA and PA at public meetings and in the CASAC's
letters to the Administrator.
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\45\ In addition to the review's opening ``call for
information'' (79 FR 71764, December 3, 2014), ``the current ISA
identified and evaluated studies and reports that have undergone
scientific peer review and were published or accepted for
publication between January 1, 2009 and March 31, 2017. A limited
literature update identified some additional studies that were
published before December 31, 2017'' (U.S. EPA, 2019, Appendix, p.
A-3). References that are cited in the ISA, the references that were
considered for inclusion but not cited, and electronic links to
bibliographic information and abstracts can be found at: https://hero.epa.gov/hero/particulate-matter.
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In presenting the rationale for the Administrator's proposed
decision and its foundations, section IV.A provides background on the
general approach for review of the secondary PM standards, including a
summary of the approach used in the last review (section IV.A.1) and
the general approach for the current review (section IV.A.2). Section
IV.B summarizes the currently available evidence for PM-related
visibility impairment and section IV.C summarizes the available
information for other PM-related welfare effects. Section IV.D presents
the Administrator's proposed conclusions on the current secondary PM
standards.
A. General Approach
In the last review of the PM NAAQS, completed in 2012, the EPA
retained the secondary 24-hour PM2.5 standard, with its
level of 35 [mu]g/m\3\, and the 24-hour PM10 standard, with
its level of 150 [micro]g/m\3\ (78 FR 3228, January 15, 2013). The EPA
also retained the level, set at 15 [micro]g/m\3\, and averaging time of
the secondary annual PM2.5 standard, while revising the
form. With regard to the form of the annual PM2.5 standard,
the EPA removed the option for spatial averaging (78 FR 3228, January
15, 2013). Key aspects of the Administrator's decisions on the
secondary PM standards for non-visibility effects and visibility
effects are described below in section IV.A.1.
1. Approach Used in the Last Review
The 2012 decision on the adequacy of the secondary PM standards was
based on consideration of the protection provided by those standards
for visibility and for the non-visibility effects of materials damage,
climate effects and ecological effects. As noted earlier, the current
review of the public welfare protection provided by the secondary PM
standards against ecological effects is occurring in the separate, on-
going review of the secondary NAAQS for oxides of nitrogen and oxides
of sulfur (U.S. EPA, 2016, Chapter 1, section 5.2; U.S. EPA, 2020,
Chapter 1, section 5.1.1). Thus, the consideration of ecological
effects in the 2012 review is not discussed here. Rather, the sections
below focus on the prior Administrator's consideration of climate and
materials effects (section IV.A.1.a) and visibility effects (section
IV.A.1.b).
a. Non-Visibility Effects
With regard to the role of PM in climate, the prior Administrator
considered whether it was appropriate to establish any distinct
secondary PM standards to address welfare effects associated with
climate impacts. In considering the scientific evidence, she noted the
2009 ISA conclusion ``that a causal relationship exists between PM and
effects on climate'' and that aerosols \46\ alter climate processes
directly through radiative forcing and by indirect effects on cloud
brightness, changes in precipitation, and possible changes in cloud
lifetimes (U.S. EPA, 2009c, section 9.3.10). Additionally, the major
aerosol components with the potential to affect climate processes
(i.e., black carbon (BC), organic carbon (OC), sulfates, nitrates and
mineral dusts) vary in their reflectivity, forcing efficiencies, and
direction of climate forcing (U.S. EPA, 2009c, section 9.3.10).
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\46\ In the climate sciences research community, PM is
encompassed by what is typically referred to as aerosol. An aerosol
is defined as a solid or liquid suspended in a gas, but PM refers to
the solid or liquid phase of an aerosol. In this review of the
secondary PM NAAQS the discussion on climate effects of PM uses the
term PM throughout for consistency with the ISA (U.S. EPA, 2019) as
well as to emphasize that the climate processes altered by aerosols
are generally altered by the PM portion of the aerosol. Exceptions
to this practice include the discussion of climate effects in the
last review, when aerosol was used when discussing suspending
aerosol particles, and for certain acronyms that are widely used by
the climate community that include the term aerosol (e.g., aerosol
optical depth, or AOD).
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Noting the strong evidence indicating that aerosols affect climate,
the prior Administrator further considered what the available
information indicated regarding the adequacy of protection provided by
the secondary PM standards. She noted that a number of uncertainties in
the scientific information affected our ability to quantitatively
evaluate the standards in this regard. For example, the ISA and PA
noted the spatial and temporal heterogeneity of PM components that
contribute to climate forcing, uncertainties in the measurement of
aerosol components, inadequate consideration of aerosol impacts in
climate modeling, insufficient data on local and regional microclimate
variations and heterogeneity of cloud formations. In light of these
uncertainties and the lack of sufficient data, the 2011 PA concluded
that it was not feasible in the last review ``to conduct a quantitative
analysis for the purpose of informing revisions [to the secondary PM
NAAQS] based on climate'' (U.S. EPA, 2011, pp. 5-11 to 5-12) and that
there was insufficient information available to base a national ambient
air quality standard on climate impacts associated with ambient air
concentrations of PM or its constituents (U.S. EPA, 2011, section
5.2.3). The prior Administrator agreed with this conclusion (78 FR
3225-3226, January 15, 2013).
With regard to materials effects, the she also considered effects
associated with the deposition of PM (i.e., dry and wet deposition),
including both physical damage (materials effects) and aesthetic
qualities (soiling effects). The deposition of PM can physically affect
materials, adding to the effects of natural weathering processes, by
promoting or accelerating the corrosion of metals; by degrading paints;
and by deteriorating building materials such as stone, concrete, and
marble (U.S. EPA, 2009c, section 9.5). Additionally, the deposition of
PM from ambient air can reduce the aesthetic appeal of buildings and
objects through soiling. The ISA concluded that evidence was
``sufficient to conclude that a causal relationship exists between PM
and effects on materials'' (U.S. EPA, 2009c, sections 2.5.4 and 9.5.4).
However, the 2011 PA noted that quantitative relationships were lacking
between particle size, concentrations, and frequency of repainting and
repair of surfaces and that considerable uncertainty exists in the
contributions of co-occurring pollutants to materials damage and
soiling processes (U.S. EPA, 2011, p. 5-29). The 2011 PA concluded that
none of the evidence available in the last review called into question
the adequacy of the existing secondary PM standards to protect against
material effects (U.S. EPA, 2011, p. 5-29). The prior Administrator
agreed with this conclusion (78 FR 3225-3226, January 15, 2013).
In considering non-visibility welfare effects in the last review,
as discussed above, the prior Administrator concluded that, while it is
important to maintain an appropriate degree of control of fine and
coarse particles to address non-visibility welfare effects, ``[i]n the
absence of information that would support any different standards . . .
it is appropriate to retain the existing suite of secondary standards''
(78 FR 3225-3226, January 15, 2013). Her decision was consistent with
the CASAC advice related to non-visibility effects. Specifically, the
CASAC agreed with the 2011 PA conclusions that, while these effects are
important, ``there is not currently a strong technical basis
[[Page 24128]]
to support revisions of the current standards to protect against these
other welfare effects'' (Samet, 2010a, p. 5). Thus, the prior
Administrator concluded that it was appropriate to retain all aspects
of the existing 24-hour PM2.5 and PM10 secondary
standards. With regard to the secondary annual PM2.5
standard, she concluded that it was appropriate to retain a level of
15.0 [mu]g/m\3\ while revising only the form of the standard to remove
the option for spatial averaging (78 FR 3225-3226, January 15, 2013).
b. Visibility Effects
Having reached the conclusion to retain the existing secondary PM
standards to protect against non-visibility welfare effects, the prior
Administrator next considered the level of protection that would be
requisite to protect public welfare against PM-related visibility
impairment and whether to adopt a distinct secondary standard to
achieve this level of protection. In reaching her final decision that
the existing 24-hour PM2.5 standard provides sufficient
protection against PM-related visibility impairment (78 FR 3228,
January 15, 2013), she considered the evidence assessed in the 2009 ISA
(U.S. EPA, 2009c) and the analyses included in the Urban-Focused
Visibility Assessment (2010 UFVA; U.S. EPA, 2010b) and the 2011 PA
(U.S. EPA, 2011). She also considered the degree of protection for
visibility that would be provided by the existing secondary standard,
focusing specifically on the secondary 24-hour PM2.5
standard with its level of 35 [micro]g/m\3\. These considerations, and
the prior Administrator's conclusions regarding visibility are
discussed in more detail below.
In the last review, the ISA concluded that, ``collectively, the
evidence is sufficient to conclude that a causal relationship exists
between PM and visibility impairment'' (U.S. EPA, 2009c, p. 2-28).
Visibility impairment is caused by light scattering and absorption by
suspended particles and gases, including water content of aerosols.\47\
The available evidence in the last review indicated that specific
components of PM have been shown to contribute to visibility
impairment. For example, at sufficiently high relative humidity values,
sulfate and nitrate are the PM components that scatter more light and
thus contribute most efficiently to visibility impairment. Elemental
carbon (EC) and organic carbon (OC) are also important contributors,
especially in the northwestern U.S. where their contribution to
PM2.5 mass is higher. Crustal materials can be significant
contributors to visibility impairment, particularly for remote areas in
the arid southwestern U.S. (U.S. EPA, 2009c, section 2.5.1).
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\47\ All particles scatter light and, although a larger particle
scatters more light than a similarly shaped smaller particle of the
same composition, the light scattered per unit of mass is greatest
for particles with diameters from ~0.3-1.0 [micro]m (U.S. EPA,
2009c, section 2.5.1). Particles with hygroscopic components (e.g.,
particulate sulfate and nitrate) contribute more to light extinction
at higher relative humidity than at lower relative humidity because
they change size in the atmosphere in response to relative humidity.
---------------------------------------------------------------------------
Visibility impairment can have implications for people's enjoyment
of daily activities and for their overall sense of well-being (U.S.
EPA, 2009c, section 9.2). In consideration of the potential public
welfare implication of various degrees of PM-related visibility
impairment, the prior Administrator considered the available visibility
preference studies that were part of the overall body of evidence in
the 2009 ISA and reviewed as a part of the 2010 UFVA. These preference
studies provided information about the potential public welfare
implications of visibility impairment from surveys in which
participants were asked questions about their preferences or the values
they placed on various visibility conditions, as displayed to them in
scenic photographs or in images with a range of known light extinction
levels.\48\
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\48\ Preference studies were available in four urban areas in
the last review. Three western preference studies were available,
including one in Denver, Colorado (Ely et al., 1991), one in the
lower Fraser River valley near Vancouver, British Columbia, Canada
(Pryor, 1996), and one in Phoenix, Arizona (BBC Research &
Consulting, 2003). A pilot focus group study was also conducted for
Washington, DC (Abt Associates, 2001), and a replicate study with 26
participants was also conducted for Washington, DC (Smith and
Howell, 2009). More details about these studies are available in
Appendix D of the PA.
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In noting the relationship between PM concentrations and PM-related
light extinction, the prior Administrator focused on identifying an
adequate level of protection against visibility-related welfare
effects. She first concluded that a standard in terms of a
PM2.5 visibility index would provide a measure of protection
against PM-related light extinction that directly takes into account
the factors (i.e., species composition and relative humidity) that
influence the relationship between PM2.5 in ambient air and
PM-related visibility impairment. A PM2.5 visibility index
standard would afford a relatively high degree of uniformity of visual
air quality protection in areas across the country by directly
incorporating the effects of differences of PM2.5
composition and relative humidity. In defining a target level of
protection in terms of a PM2.5 visibility index, as
discussed below, she considered specific elements of the index,
including the basis for its derivation, as well as an appropriate
averaging time, level, and form.
With regard to the basis for derivation of a visibility index, the
prior Administrator concluded that it was appropriate to use an
adjusted version of the original IMPROVE algorithm,\49\ in conjunction
with monthly average relative humidity data based on long-term
climatological means. In so concluding, she noted the CASAC conclusion
on the reasonableness of reliance on a PM2.5 light
extinction indicator calculated from PM2.5 chemical
composition and relative humidity. In considering alternative
approaches for a focus on visibility, she recognized that the available
mass monitoring methods did not include measurement of the full water
content of ambient PM2.5, nor did they provide information
on the composition of PM2.5, both of which contribute to
visibility impacts (77 FR 38980, June 29, 2012). In addition, at the
time of the proposal, she recognized that suitable equipment and
performance-based verification procedures did not then exist for direct
measurement of light extinction and could not be developed within the
time frame of the review (77 FR 38980-38981, June 29, 2012).
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\49\ The revised IMPROVE algorithm (Pitchford et al., 2007) uses
major PM chemical composition measurements and relative humidity
estimates to calculate light extinction. For more information about
the derivation of and input data required for the original and
revised IMPROVE algorithms, see 78 FR 3168-3177, January 15, 2013.
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With regard to the averaging time of the index, the prior
Administrator concluded that a 24-hour averaging time would be
appropriate for a visibility index (78 FR 3226, January 15, 2013).
Although she recognized that hourly or sub-daily (4- to 6-hour)
averaging times, within daylight hours and excluding hours with
relatively high humidity, are more directly related to the short-term
nature of the perception of PM-related visibility impairment and
relevant exposure periods for segments of the viewing public than a 24-
hour averaging time, she also noted that there were data quality
uncertainties associated with the instruments used to provide the
hourly PM2.5 mass measurements required for an averaging
time shorter than 24 hours. She also considered the results of analyses
that compared 24-hour and 4-hour averaging times for calculating the
index. These analyses showed good correlation between 24-hour and 4-
hour
[[Page 24129]]
average PM2.5 light extinction, as evidenced by reasonably
high city-specific and pooled R-squared values, generally in the range
of over 0.6 to over 0.8. Based on these analyses and the 2011 PA
conclusions regarding them, the prior Administrator concluded that a
24-hour averaging time would be a reasonable and appropriate surrogate
for a sub-daily averaging time.
With regard to the statistical form of the index, the prior
Administrator settled on a 3-year average of annual 90th percentile
values. In so doing, she noted that a 3-year average form provided
stability from the occasional effect of inter-annual meteorological
variability that can result in unusually high pollution levels for a
particular year (78 FR 3198, January 15, 2013; U.S. EPA, 2011, p. 4-
58).\50\ Regarding the annual statistic to be averaged, the 2010 UFVA
evaluated three different statistics: 90th, 95th, and 98th percentiles
(U.S. EPA, 2010b, chapter 4). In considering these alternative
percentiles, the 2011 PA noted that the Regional Haze Program targets
the 20 percent most impaired days for improvements in visual air
quality in Federal Class I areas and that the median of the
distribution of these 20 percent worst days would be the 90th
percentile. The 2011 PA further noted that strategies that are
implemented so that 90 percent of days would have visual air quality
that is at or below the level of the standard would reasonably be
expected to lead to improvements in visual air quality for the 20
percent most impaired days. Lastly, the 2011 PA recognized that the
available studies on people's preferences did not address frequency of
occurrence of different levels of visibility and did not identify a
basis for a different target for urban areas than that for Class I
areas (U.S. EPA, 2011, p. 4-59). These considerations led the prior
Administrator to conclude that 90th percentile form was the most
appropriate annual statistic to be averaged across three years (78 FR
3226, January 15, 2013).
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\50\ The EPA recognized that a percentile form averaged over
multiple years offers greater stability to the air quality
management process by reducing the possibility that statistically
unusual indicator values will lead to transient violations of the
standard, thus reducing the potential for disruption of programs
implementing the standard and reducing the potential for disruption
of the protections provided by those programs.
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With regard to the level of the index, she considered the
visibility preferences studies conducted in four urban areas (U.S. EPA,
2011, p. 4-61). Based on these studies, the PA identified a range of
levels from 20 to 30 deciviews (dv) \51\ as being a reasonable range of
``candidate protection levels'' (CPLs).\52\ In considering this range
of CPLs, she noted the uncertainties and limitations in public
preference studies, including the small number of stated preference
studies available; the relatively small number of study participants
and the extent to which the study participants may not be
representative of the broader study area population in some of the
studies; and the variations in the specific materials and methods used
in each study. She concluded that the substantial degree of variability
and uncertainty in the public preference studies should be reflected in
a target protection level at the upper end of the range of CPLs.
Therefore, she concluded that it was appropriate to set a target level
of protection in terms of a 24-hour PM2.5 visibility index
at 30 dv (78 FR 3226-3227, January 15, 2013).
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\51\ Deciview (dv) refers to a scale for characterizing
visibility that is defined directly in terms of light extinction.
The deciview scale is frequently used in the scientific and
regulatory literature on visibility.
\52\ For comparison, 20 dv, 25 dv, and 30 dv are equivalent to
64, 112, and 191 megameters (Mm-\.1\), respectively.
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Based on her considerations and conclusions summarized above, the
prior Administrator concluded that the protection provided by a
secondary standard based on a 3-year visibility metric, defined in
terms of a PM2.5 visibility index with a 24-hour averaging
time, a 90th percentile form averaged over 3 years, and a level of 30
dv, would be requisite to protect public welfare with regard to visual
air quality (78 FR 3227, January 15, 2013). Having reached this
conclusion, she next determined whether an additional distinct
secondary standard in terms of a visibility index was needed given the
degree of protection from visibility impairment afforded by the
existing secondary standards. Specifically, she noted that the air
quality analyses showed that all areas meeting the existing 24-hour
PM2.5 standard, with its level of 35 [micro]g/m\3\, had
visual air quality at least as good as 30 dv, based on the visibility
index defined above (Kelly et al., 2012b, Kelly et al., 2012a). Thus,
the secondary 24-hour PM2.5 standard would likely be
controlling relative to a 24-hour visibility index set at a level of 30
dv. Additionally, areas would be unlikely to exceed the target level of
protection for visibility of 30 dv without also exceeding the existing
secondary 24-hour standard. Thus, the prior Administrator judged that
the 24-hour PM2.5 standard ``provides sufficient protection
in all areas against the effects of visibility impairment--i.e., that
the existing 24-hour PM2.5 standard would provide at least
the target level of protection for visual air quality of 30 dv which
[she] judges appropriate'' (78 FR 3227, January 15, 2013). She further
judged that ``[s]ince sufficient protection from visibility impairment
would be provided for all areas of the country without adoption of a
distinct secondary standard, and adoption of a distinct secondary
standard will not change the degree of over-protection for some areas
of the country. . . adoption of such a distinct secondary standard is
not needed to provide requisite protection for both visibility and
nonvisibility related welfare effects'' (78 FR 3228, January 15, 2013).
2. Approach for the Current Review
To evaluate whether it is appropriate to consider retaining the
current secondary PM standards, or whether consideration of revision is
appropriate, the EPA has adopted an approach in this review that builds
upon the general approach used in the last review and reflects the body
of evidence and information now available. As summarized above, past
approaches have been based most fundamentally on using information from
studies of PM-related visibility effects, quantitative analyses of PM-
related visibility impairment, information from studies of non-
visibility welfare effects, advice from the CASAC, and public comments
to inform the selection of secondary PM standards that, in the
Administrator's judgment, protect the public welfare from any known or
anticipated effects.
Similarly, in this review, the EPA draws on the available evidence
and quantitative assessments pertaining to the public welfare impacts
of PM in ambient air. In considering the scientific and technical
information, the Agency considers both the information available at the
time of the last review and the information that is newly available in
this review. This includes information on PM-related visibility and
non-visibility effects. Consistent with the approach in the last
review, the quantitative air quality analyses for PM-related visibility
effects provide a context for interpreting the evidence of visibility
impairment and the potential public welfare significance of PM
concentrations in ambient air associated with recent air quality
conditions.
B. PM-Related Visibility Impairment
The information summarized here is based on the EPA's scientific
assessment of the latest evidence on visibility effects associated with
PM; this assessment is documented in the ISA
[[Page 24130]]
and its policy implications are further discussed in the PA. In
considering the scientific and technical information, the PA reflects
upon both the information available in the last review and information
that is newly available since the last review. Policy implications of
the currently available evidence are discussed in the PA (as summarized
in section IV.D.1). The subsections below briefly summarize the
following aspects of the evidence: The nature of PM-related visibility
impairment (section IV.B.1), the relationship between ambient PM and
visibility (section IV.B.2), and public perception of visibility
impairment (section IV.B.3).
1. Nature of PM-Related Visibility Impairment
Visibility refers to the visual quality of a human's view with
respect to color rendition and contrast definition. It is the ability
to perceive landscape form, colors, and textures. Visibility involves
optical and psychophysical properties involving human perception,
judgment, and interpretation. Light between the observer and the object
can be scattered into or out of the sight path and absorbed by PM or
gases in the sight path. The conclusions of the ISA that ``the evidence
is sufficient to conclude that a causal relationship exists between PM
and visibility impairment'' is consistent with conclusions of causality
in the last review (U.S. EPA, 2019, section 13.2.6). These conclusions
are based on strong and consistent evidence that ambient PM can impair
visibility in both urban and remote areas (U.S. EPA, 2019, section
13.1; U.S. EPA, 2009c, section 9.2.5).
2. Relationship Between Ambient PM and Visibility
The fundamental relationship between light extinction and PM mass,
and the EPA's understanding of this relationship, has changed little
since the 2009 ISA (U.S. EPA, 2009c). The combined effect of light
scattering and absorption by particles and gases is characterized as
light extinction, i.e., the fraction of light that is scattered or
absorbed per unit of distance in the atmosphere. Light extinction is
measured in units of 1/distance, which is often expressed in the
technical literature as visibility per megameter (abbreviated
Mm-\1\). Higher values of light extinction (usually given in
units of Mm-\1\ or dv) correspond to lower visibility. When
PM is present in the air, its contribution to light extinction is
typically much greater than that of gases (U.S. EPA, 2019, section
13.2.1). The impact of PM on light scattering depends on particle size
and composition, as well as relative humidity. All particles scatter
light, as described by the Mie theory, which relates light scattering
to particle size, shape, and index of refraction (U.S. EPA, 2019,
section 13.2.3; Van de Hulst, 1981; Mie, 1908). Fine particles scatter
more light than coarse particles on a per unit mass basis and include
sulfates, nitrates, organics, light-absorbing carbon, and soil (Malm et
al., 1994). Hygroscopic particles like ammonium sulfate, ammonium
nitrate, and sea salt increase in size as relative humidity increases,
leading to increased light scattering (U.S. EPA, 2019, section 13.2.3).
Direct measurements of PM light extinction, scattering, and
absorption are considered more accurate for quantifying visibility than
PM mass-based estimates because measurements do not depend on
assumptions about particle characteristics (e.g., size, shape, density,
component mixture, etc.) (U.S. EPA, 2019, section 13.2.2.2).
Measurements of light extinction can be made with high time resolution,
allowing for characterization of subdaily temporal patterns of
visibility impairment. A variety of measurement methods have been used
(e.g., transmissometers, integrating nephelometers, teleradiometers,
telephotometers, and photography and photographic modeling), each with
its own strengths and limitations (U.S. EPA, 2019, Table 13-1).
However, there are no common performance-based criteria to evaluate
these methods and none have been deployed broadly across the U.S. for
routine measurement of visibility impairment.
In the absence of a robust monitoring network for the routine
measurement of light extinction across the U.S., estimation of light
extinction based on existing PM monitoring can be used. A theoretical
relationship between light extinction and PM characteristics has been
derived from Mie theory (U.S. EPA, 2019, Equation 13.5) and can be used
to estimate light extinction by combining mass scattering efficiencies
of particles with particle concentrations (U.S. EPA, 2019, section
13.2.3; U.S. EPA, 2009c, sections 9.2.2.2 and 9.2.3.1). However,
routine ambient air monitoring rarely includes measurements of particle
size and composition information with sufficient detail for these
calculations. Accordingly, a much simpler algorithm has been developed
to make estimating light extinction more practical.
This algorithm, known as the IMPROVE algorithm,\53\ provides for
the estimation of light extinction (bext), in units of
Mm-\1\, using routinely monitored components of fine
(PM2.5) and coarse (PM10-2.5) PM. Relative
humidity data are also needed to estimate the contribution by liquid
water that is in solution with the hygroscopic components of PM. To
estimate each component's contribution to light extinction, their
concentrations are multiplied by extinction coefficients and are
additionally multiplied by a water growth factor that accounts for
their expansion with moisture. Both the extinction efficiency
coefficients and water growth factors of the IMPROVE algorithm have
been developed by a combination of empirical assessment and theoretical
calculation using particle size distributions associated with each of
the major aerosol components (U.S. EPA, 2019, section 13.2.3.1, section
13.2.3.3).
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\53\ The algorithm is referred to as the IMPROVE algorithm as it
was developed specifically to use monitoring data generated at
IMPROVE network sites and with equipment specifically designed to
support the IMPROVE program and was evaluated using IMPROVE optical
measurements at the subset of monitoring sites that make those
measurements (Malm et al., 1994).
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The original IMPROVE algorithm, so referenced here to distinguish
it from subsequent variations developed later, was found to
underestimate the highest light scattering values and overestimate the
lowest values at IMPROVE monitors throughout the U.S. (Malm and Hand,
2007; Ryan et al., 2005; Lowenthal and Kumar, 2004) and at sites in
China (U.S. EPA, 2019, section 13.2.3.3). To resolve these biases, a
revised IMPROVE equation was developed (Pitchford et al., 2007). Since
the last review, Lowenthal and Kumar (2016) further offered a number of
modifications to the revised IMPROVE equation, with a focus of the
application of the IMPROVE equation in remote sites. In particular, one
of the modifications was to increase the multiplier to estimate the
concentration of organic matter, [OM], from the concentration of
organic carbon, [OC]. This modification was based on their evaluations
of monitoring data from remote IMPROVE sites, which showed that in
areas further away from PM sources, PM mass is often more oxygenated
and contains a larger amount of organic PM. (U.S. EPA, 2019, section
13.2.3.3). As discussed below in section IV.D.1, analyses conducted in
the current review estimate PM-related visibility impairment using each
of these versions of the IMPROVE equation.
[[Page 24131]]
3. Public Perception of Visibility Impairment
In the last review, visibility preference studies were available
from four areas in North America.\54\ Study participants were queried
regarding multiple images that, depending on the study, were either
photographs of the same location and scenery that had been taken on
different days on which measured extinction data were available or
digitized photographs onto which a uniform ``haze'' had been
superimposed. Results of those studies indicated a wide range of
judgments on what study participants considered to be acceptable
visibility across the different study areas, depending on the setting
depicted in each photograph. As a part of the 2010 UFVA, each study was
evaluated separately, and figures were developed to display the
percentage of participants that rated the visual air quality depicted
as ``acceptable'' (U.S. EPA, 2010b). Based on the results of the
studies in the four cities, a range encompassing the PM2.5
visibility index values from images that were judged to be acceptable
by at least 50% of study participants across all four of the urban
preference studies was identified (U.S. EPA, 2010b, p. 4-24; PA, Figure
5-2). Much lower visibility (considerably more haze resulting in higher
values of light extinction) was considered acceptable in Washington,
DC, than was in Denver, and 30 dv reflected the highest degree of
visibility impairment judged to be acceptable by at least 50 percent of
study participants (78 FR 3226-3227, January 15, 2013).
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\54\ Preference studies were available in four urban areas in
the last review: Denver, Colorado (Ely et al., 1991), Vancouver,
British Columbia, Canada (Pryor, 1996), Phoenix, Arizona (BBC
Research & Consulting, 2003), and Washington, DC (Abt Associates,
2001; Smith and Howell, 2009).
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Since the time of the last review, no new visibility preference
studies have been conducted in the U.S. Similarly, there is little
newly available information regarding acceptable levels of visibility
impairment in the U.S.
C. Other PM-Related Welfare Effects
The information summarized here is based on the EPA's scientific
assessment of the latest evidence on the non-visibility welfare effects
associated with PM. This assessment is documented in the ISA and its
policy implications are further discussed in the PA. In considering the
scientific and technical information, the PA reflects consideration of
both the information available in the last review and information that
is newly available since the last review. The subsections below briefly
summarize the evidence related to climate effects (section IV.C.1) and
materials effects (section IV.C.2).
1. Climate
In this review, as in the last review, the ISA concludes that
``overall the evidence is sufficient to conclude that a causal
relationship exists between PM and climate effects'' (U.S. EPA, 2019,
section 13.3.9). Since the last review, climate impacts have been
extensively studied and recent research reinforces and strengthens the
evidence evaluated in the 2009 ISA. New evidence provides greater
specificity about the details of radiative forcing effects \55\ and
increases the understanding of additional climate impacts driven by PM
radiative effects. The Intergovernmental Panel on Climate Change (IPCC)
assesses the role of anthropogenic activity in past and future climate
change, and since the last review, has issued the Fifth IPCC Assessment
Report (AR5; IPCC, 2013) which summarizes any key scientific advances
in understanding the climate effects of PM since the previous report.
As in the last review, the ISA draws substantially on the IPCC report
to summarize climate effects. As discussed in more detail below, the
general conclusions are similar between the IPCC AR4 and AR5 reports
with regard to effects of PM on global climate.
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\55\ Radiative forcing (RF) for a given atmospheric constituent
is defined as the perturbation in net radiative flux, at the
tropopause (or the top of the atmosphere) caused by that
constituent, in watts per square meter (Wm-2), after allowing for
temperatures in the stratosphere to adjust to the perturbation but
holding all other climate responses constant, including surface and
tropospheric temperatures (Fiore et al., 2015; Myhre et al., 2013).
A positive forcing indicates net energy trapped in the Earth system
and suggests warming of the Earth's surface, whereas a negative
forcing indicates net loss of energy and suggests cooling (U.S. EPA,
2019, section 13.3.2.2).
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Atmospheric PM has the potential to affect climate in multiple
ways, including absorbing and scattering of incoming solar radiation,
alterations in terrestrial radiation, effects on the hydrological
cycle, and changes in cloud properties (U.S. EPA, 2019, section
13.3.1). Atmospheric PM interacts with incoming solar radiation. Many
species of PM (e.g., sulfate and nitrate) efficiently scatter solar
energy. By enhancing reflection of solar energy back to space,
scattering PM exerts a cooling effects on the surface below. Certain
species of PM such as black carbon (BC), brown carbon (BrC), or dust
can also absorb incoming sunlight. A recent study found that whether
absorbing PM warms or cools the underlying surface depends on several
factors, including the altitude of the PM layer relative to cloud cover
and the albedo (i.e., reflectance) of the surface (Ban-Weiss et al.,
2014). PM also perturbs incoming solar radiation by influencing cloud
cover and cloud lifetime. For example, PM provides nuclei upon which
water vapor condenses, forming cloud droplets. Finally, absorbing PM
deposited on snow and ice can diminish surface albedo and lead to
regional warming (U.S. EPA, 2019, section 13.3.2).
PM has direct and indirect effects on climate processes. PM
interactions with solar radiation through scattering and absorption,
collectively referred to as aerosol-radiation interactions (ARI), are
also known as the direct effects on climate, as opposed to the indirect
effects that involve aerosol-cloud interactions (ACI). The direct
effects of PM on climate result primarily from particles scattering
light away from Earth and sending a fraction of solar energy back into
space, decreasing the transmission of visible radiation to the surface
of the Earth and resulting in a decrease in the heating rate of the
surface and the lower atmosphere. The IPCC AR5, taking into account
both model simulations and satellite observations, reports a radiative
forcing from aerosol-radiation interactions (RFari) from anthropogenic
PM of -0.35 0.5 watts per square meter (Wm-2)
(Boucher, 2013), which is comparable to AR4 (-0.5 0.4
Wm-2). Estimates of effective radiative forcing \56\ from
aerosol-radiation interactions (ERFari), which include the rapid
feedback effects of temperature and cloud cover, rely mainly on model
simulations, as this forcing is complex and difficult to observe (U.S.
EPA, 2019, section 13.3.4.1). The IPCC AR5 best estimate for ERFari is
-0.45 0.5 Wm-2, which reflects this uncertainty
(Boucher, 2013).
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\56\ Effective radiative forcing (ERF), new in the IPCC AR5,
takes into account not just the instantaneous forcing but also a set
of climate feedbacks, involving atmospheric temperature, cloud
cover, and water vapor, that occur naturally in response to the
initial radiative perturbation (U.S. EPA, 2019, section 13.3.2.2).
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By providing cloud condensation nuclei, PM increases cloud droplet
number, thereby increasing cloud droplet surface area and albedo
(Twomey, 1977). The climate effects of these perturbations are more
difficult to quantify than the direct effects of aerosols with RF but
likely enhance the cooling influence of clouds by increasing cloud
reflectivity (traditionally referred to as the first indirect effect)
and lengthening cloud lifetime (second indirect effect). These effects
are reported as the radiative
[[Page 24132]]
forcing from aerosol-cloud interaction (ERFaci) (U.S. EPA, 2019,
section 13.3.3.2).\57\ IPCC AR5 estimates ERFaci at -0.45
Wm-2, with a 90% confidence interval of -1.2 to 0
Wm-2 (U.S. EPA, 2019, section 13.3.4.2). Studies have also
calculated the combined effective radiative forcing from aerosol-
radiation and aerosol-cloud interactions (ERFari+aci) (U.S. EPA, 2019,
section 13.3.4.3). IPCC AR5 reports a best estimate of ERFari+aci of -
0.90 (-1.9 to -0.1) Wm-2, consistent with these estimates
(Boucher, 2013).
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\57\ While the ISA includes estimates of RFaci and ERFaci from a
number of studies (U.S. EPA, 2019, sections 13.3.4.2, 13.3.4.3,
13.3.3.3), this discussion focuses on the single best estimate with
a range of uncertainty, as reported in the IPCC AR5 (Boucher, 2013).
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PM can also strongly reflect incoming solar radiation in areas of
high albedo, such as snow- and ice-covered surfaces. The transport and
subsequent deposition of absorbing PM such as BC to snow- and ice-
covered regions can decrease the local surface albedo, leading to
surface heating. The absorbed energy can then melt the snow and ice
cover and further depress the albedo, resulting in a positive feedback
loop (U.S. EPA, 2019, section 13.3.3.3; Bond et al., 2013; U.S. EPA,
2012b). Deposition of absorbing PM, such as BC, may also affect surface
temperatures over glacial regions (U.S. EPA, 2019, section 13.3.3.3).
The IPCC AR5 best estimate of RF from the albedo effects is +0.04
Wm-2, with an uncertainty range of +0.02 to +0.09
Wm-2 (Boucher, 2013).
A number of new studies are available since the last review that
have exampled the individual climate effects associated with key PM
components, including sulfate, nitrate, OC, BC, and dust, along with
updated quantitative estimate of the radiative forcing with the
individual species. Sulfate particles form through oxidation of
SO2 by OH in the gas phase and in the aqueous phase by a
number of pathways, including in particular those involving ozone and
H2O2 (U.S. EPA, 2019, section 13.3.5.1). The main
source of anthropogenic sulfate is from coal-fired power plants, and
global trends in the anthropogenic SO2 emissions are
estimated to have increased dramatically during the 20th and early 21st
centuries, although the recent implementation of more stringent air
pollution controls on sources has led to a reversal in such trends in
many places (U.S. EPA, 2019, section 13.3.5.1; U.S. EPA, 2020, section
2.3.1). Sulfate particles are highly reflective. Consistent with other
recent estimates (Takemura, 2012, Zelinka et al., 2014, Adams et al.,
2001, described below), on a global scale, the IPCC AR5 estimates that
sulfate contributes more than other PM types to RF, with RFari of -0.4
(-0.6 to -0.2) Wm-2, where the 5% and 95% uncertainty range
is represented by the numbers in the parentheses (Myhre et al., 2013),
which is the same estimate from AR4. Sulfate is also a major
contributor to the influence of PM on clouds (Takemura, 2012). A total
effective radiative forcing (ERFari+aci) for anthropogenic sulfate has
been estimated to be nearly -1.0 Wm-2 (Zelinka et al., 2014,
Adams et al., 2001).
Nitrate particles form through the oxidation of nitrogen oxides and
occur mainly in the form of ammonium nitrate. Ammonium preferentially
associates with sulfate rather than nitrate, leading to formation of
ammonium sulfate at the expense of ammonium nitrate (Adams et al.,
2001). As anthropogenic emissions of SO2 decline, more
ammonium will be available to react with nitrate, potentially leading
to future increases in ammonium nitrate particles in the atmosphere
(U.S. EPA, 2019, section 13.3.5.2; Hauglustaine et al., 2014; Lee et
al., 2013; Shindell et al., 2013). Warmer global temperatures, however,
may decrease nitrate abundance given that it is highly volatile at
higher temperatures (Tai et al., 2010). The IPCC AR5 estimates RFari of
nitrate of -0.11 (-0.3 to -0.03) Wm-2 (Boucher, 2013), which
is one-fourth of the RFari of sulfate.
Primary organic carbonaceous PM, including BrC, are emitted from
wildfires, agricultural fires, and fossil fuel and biofuel combustion.
SOA form when anthropogenic or biogenic nonmethane hydrocarbons are
oxidized in the atmosphere, leading to less volatile products that may
partition into PM (U.S. EPA, 2019, section 13.3.5.3). Organic particles
are generally reflective, but in the case of BrC, a portion is
significantly absorbing at shorter wavelengths (<400 nm). The IPCC AR5
estimates an RFari for primary organic PM from fossil fuel combustion
and biofuel use of -0.09 (-0.16 to -0.03) Wm-\2\ and an
RFari estimate for SOA from these sources of -0.03 (-0.27 to +0.20)
Wm-\2\ (Myhre et al., 2013). Changes in the RFari estimates
for individual PM components since AR4 have generally been modest, with
one exception for the estimate for primary organic PM from fossil fuel
combustion and biofuel use (Myhre et al., 2013).\58\ The wide range in
these estimates, including inconsistent signs for forcing, reflect
uncertainties in the optical properties of organic PM and its
atmospheric budgets, including the production pathways of anthropogenic
SOA (Scott et al., 2014; Myhre et al., 2013; McNeill et al., 2012;
Heald et al., 2010). The IPCC AR5 also estimates an RFari of -0.2
Wm-\2\ for primary organic PM arising from biomass burning
(Boucher, 2013).
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\58\ The estimate of RFari for SOA is new in AR5 and was not
included in AR4 (Myhre et al., 2013).
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Black carbon (BC) particles occur as a result of inefficient
combustion of carbon-containing fuels. Like directly emitted organic
PM, BC is emitted from biofuel and fossil fuel combustion and by
biomass burning. BC is absorbing at all wavelengths and likely has a
large impact on the Earth's energy budget (Bond et al., 2013). The IPCC
AR5 estimates a RFari from anthropogenic fossil fuel and biofuel use of
+0.4 (+0.5 to +0.8) Wm-\2\ (Myhre et al., 2013). Biomass
burning contributes an additional +0.2 (+0.03 to +0.4)
Wm-\2\ to BC RFari, while the albedo effect of BC on snow
and ice adds another +0.04 (+0.02 to +0.09) Wm-\2\ (Myhre et
al., 2013; U.S. EPA, 2019, section 13.3.5.4, section 13.3.4.4).
Dust, or mineral dust, is mobilized from dry or disturbed soils as
a result of both meteorological and anthropogenic activities. Dust has
traditionally been classified as scattering, but a recent study found
that dust may be substantially coarser than currently represented in
climate models, and thus more light-absorbing (Kok et al., 2017). The
IPCC AR5 estimates RFari as -0.1 0.2 Wm-\2\
(Boucher, 2013), although the results of the study by Kok et al. (2017)
would suggest that in some regions dust may have led to warming, not
cooling (U.S. EPA, 2019, section 13.3.5.5).
The new research available in this review expands upon the evidence
available at the time of the last review. Consistent with the evidence
available in the last review, the key PM components, including sulfate,
nitrate, OC, BC, and dust, that contribute to climate processes vary in
their reflectivity, forcing efficiencies, and direction of forcing.
Radiative forcing due to PM elicits a number of responses in the
climate system that can lead to significant effects on weather and
climate over a range of spatial and temporal scales, mediated by a
number of feedbacks that link PM and climate. Since the last review,
the evidence base has expanded with respect to the mechanisms of
climate responses and feedbacks to PM radiative forcing. However, the
new literature published since the last review does not reduce the
considerable
[[Page 24133]]
uncertainties that continue to exist related to these mechanisms.
Unlike well-mixed, long-lived greenhouse gases in the atmosphere,
PM has a very heterogenous distribution across the Earth. As such,
patterns of RFari and RFaci tend to correlate with PM loading, with the
greatest forcings centralized over continental regions. The climate
response to this PM forcing, however, is more complicated since the
perturbation to one climate variable (e.g., temperature, cloud cover,
precipitation) can lead to a cascade of effects on other variables.
While the initial PM radiative forcing may be concentrated regionally,
the eventual climate response can be much broader spatially or be
concentrated in remote regions, and may be quite complex, affecting
multiple climate variables with possible differences in the sign of the
response in different regions or for different variables (U.S. EPA,
2019, section 13.3.6). The complex climate system interactions lead to
variation among climate models, with some studies showing relatively
close correlation between forcing and surface response temperatures
(e.g., Leibensperger et al., 2012), while other studies show much less
correlation (e.g., Levy et al., 2013). Many studies have examined
observed trends in PM and temperature in the U.S. Climate models have
suggested a range of factors which can influence large-scale
meteorological processes and may affect temperature, including local
feedback effects involving soil moisture and cloud cover, changes in
the hygroscopicity of the PM, and interactions with clouds alone (U.S.
EPA, 2019, section 13.3.7). While evidence in this review suggests that
PM influenced temperature trends across the southern and eastern U.S.
in the 20th century, this evidence is not conclusive and significant
uncertainties continue to exist. Further research is needed to better
characterize the effects of PM on regional climate in the U.S. before
PM climate effects can be quantified.
While expanded since the last review, the evidence of PM-related
climate effects is still limited by significant uncertainties,
particularly for understanding effects at regional scales. Large
spatial and temporal heterogeneities in direct and indirect PM
radiative forcing, and associated climate effects, can occur for a
number of reasons, including the frequency and distribution of
emissions of key PM components contributing to climate forcing, the
chemical and microphysical processing that occurs in the atmosphere,
and the atmospheric lifetime of PM relative to other pollutants
contributing to radiative forcing (U.S. EPA, 2019, section 13.3). In
addition to the uncertainty in characterizing radiative forcing, large
uncertainty exists in quantifying changes in specific climate variables
associated with PM-related radiative forcing. Moreover, studies have
shown that predicting climate variables for regions within the U.S.
(which is of particular interest for the review of the PM NAAQS) is
more uncertain than predicting climate variables globally due to
natural climate variability (e.g., Deser et al., 2012) and
uncertainties in the representation of key atmospheric processes in
state-of-the-art climate models. Furthermore, quantifying the influence
of incremental changes in U.S. anthropogenic emissions on regional
climate is subject to even greater uncertainty because the signal of
U.S. anthropogenic emissions is relatively small compared with the
global emissions considered in the studies cited above. Overall, these
limitations and uncertainties make it difficult to quantify how
incremental changes in the level of PM mass in ambient air in the U.S.
would result in changes to climate in the U.S. Thus, as in the last
review, the PA concludes that the data remain insufficient to conduct
quantitative analyses for PM effects on climate in the current review
(U.S. EPA, 2020, section 5.2.2.2.1).
2. Materials
In considering the evidence available in the current review of PM-
related materials effects, the current evidence continues to support
the conclusion from the last review that there is a causal relationship
between PM deposition and materials effects. Effects of deposited PM,
particularly sulfates and nitrates, to materials include both physical
damage and impaired aesthetic qualities. Because of their electrolytic,
hygroscopic, and acidic properties and their ability to sorb corrosive
gases, particles contribute to materials damage by adding to the
effects of natural weathering processes, by potentially promoting or
accelerating the corrosion of metals, degradation of painted surfaces,
deterioration of building materials, and weakening of material
components.\59\ The newly available evidence on materials effects of PM
in this review are primarily from studies conducted outside of the U.S.
on buildings and other items of cultural heritage and at concentrations
greater than those typically observed in the U.S.; however, they
provide limited new data for consideration in this review (U.S. EPA,
2019, section 13.4).
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\59\ As discussed in the ISA (U.S. EPA, 2019, section 13.4.1),
corrosion typically involves reactions of acidic PM (i.e., acidic
sulfate or nitrate) with material surfaces, but gases like
SO2 and nitric acid (HNO3) also contribute.
Because ``the impacts of gaseous and particulate N and S wet
deposition cannot be clearly distinguished'' (U.S. EPA, 2019, p. 13-
1), the assessment of the evidence in the ISA considers the combined
impacts.
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Materials damage from PM generally involves one or both of two
processes: soiling and corrosion (U.S. EPA, 2019, section 13.4.2).
Soiling and corrosion are complex, interdependent processes, typically
beginning with deposition of atmospheric PM or SO2 to
exposed surfaces. Constituents of deposited PM can interact directly
with materials or undergo further chemical and/or physical
transformation to cause soiling, corrosion, and physical damage.
Weathering, including exposure to moisture, ultraviolet (UV) radiation
and temperature fluctuations, affects the rate and degree of damage
(U.S. EPA, 2019, section 13.4.2).
Soiling is the result of PM accumulation on an object that alters
its optical characteristics or appearance. These soiling effects can
impact the aesthetic value of a structure or result in reversible or
irreversible damage to the surface. The presence of air pollution can
increase the frequency and duration of cleaning and can enhance
biodeterioration processes on the surface of materials. For example,
deposition of carbonaceous components of PM can lead to the formation
of black crusts on surfaces, and the buildup of microbial biofilms \60\
can discolor surfaces by trapping PM more efficiently (U.S. EPA, 2009c,
p. 9-195; U.S. EPA, 2019, section 13.4.2). The presence of PM may alter
light transmission or change the reflectivity of a surface.
Additionally, the organic and nutrient content of deposited PM may
enhance microbial growth on surfaces.
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\60\ Microbial biofilms are communities of microorganisms, which
may include bacteria, algae, fungi and lichens, that colonize an
inert surface. Microbial biofilms can contribute to biodeterioration
of materials via modification of the chemical environment.
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Since the last review, very little new evidence has become
available related to deposition of SO2 to materials such as
limestone, granite, and metal. Deposition of SO2 onto
limestone can transform the limestone into gypsum, resulting in a
rougher surface, which allows for increased surface area for
accumulation of deposited PM (Camuffo and Bernardi, 1993; U.S. EPA,
2019, section 13.4.2). Oxidation of deposited SO2 that
contributes to the transformation of limestone to gypsum can be
enhanced by the formation of surface coatings from deposited
[[Page 24134]]
carbonaceous PM (both elemental and organic carbon) (McAlister et al.,
2008, Grossi et al., 2007). Ozga et al. (2011) characterized damage to
two concrete buildings in Poland and Italy. Gypsum was the main damage
product on surfaces of these buildings that were sheltered from rain
runoff, while PM embedded in the concrete, particularly carbonaceous
particles, were responsible for darkening of the building walls (Ozga
et al., 2011).
Building on the evidence available in the 2009 ISA, research has
progressed on the theoretical understanding of soiling of cultural
heritage in a number of studies. Barca et al. (2010) developed and
tested a new methodological approach for characterizing trace elements
and heavy metals in black crusts on stone monuments to identify the
origin of the chemicals and the relationship between the concentrations
of elements in the black crusts and local environmental conditions.
Recent research has also used isotope tracers to distinguish between
contributions from local sources versus atmospheric pollution to black
crusts on historical monuments in France (Kloppmann et al., 2011). A
study in Portugal found that biological activity played a major role in
soiling, specifically in the development of colored layers and in the
detachment process (de Oliveira et al., 2011). Another study found
damage to cement renders, often used for restoration, consolidation,
and decorative purposes on buildings, following exposure to sulfuric
acid, resulting in the formation of gypsum (Lanzon and Garcia-Ruiz,
2010).
Corrosion of stone and the decay of stone building materials by
acid deposition and sulfate salts were described in the 2009 ISA (U.S.
EPA, 2009c, section 9.5.3). Since that time, advances have been made on
the quantification of degradation rates and further characterization of
the factors that influence damage of stone materials (U.S. EPA, 2019,
section 13.4.2). Decay rates of marble grave stones were found to be
greater in heavily polluted areas compared to a relatively pristine
area (Mooers et al., 2016). The time of wetness and the number of
dissolution/crystallization cycles were identified as hazard indicators
for stone materials, with greater hazard during the spring and fall
when these indicators are relatively high (Casati et al., 2015).
A study examining the corrosion of steel as a function of PM
composition and particle size found that changes in the composition of
resulting rust gradually changed with particle size (Lau et al., 2008).
In a study of damage to metal materials under in Hong Kong, which
generally has much higher PM concentrations than those observed in the
U.S., Liu et al. (2015) found that iron and steel were corroded by both
PM and gaseous pollutants (SO2 and NO2), while
copper and copper alloys were mainly corroded by gaseous pollutants
(SO2 and O3) and aluminum and aluminum alloy
corrosion was mainly attributed to PM and NO2.
A number of studies have also found materials damage from PM
components besides sulfate and black carbon and atmospheric gases
besides SO2. Studies have characterized impacts of nitrates,
NOX, and organic compounds on direct materials damage or on
chemical reactions that enhance materials damage (U.S. EPA, 2019,
section 13.4.2). Other studies have found that soiling of building
materials can be attributed to enhanced biological processes and
colonization, including the development and thickening of biofilms,
resulting from the deposition of PM components and atmospheric gases
(U.S. EPA, 2019, section 13.4.2).
Since the last review, other materials have been studied for damage
attributable to PM, including glass and photovoltaic panels. Soiling of
glass can impact its optical and thermal properties and can lead to
increased cleaning costs and frequency. The development of haze \61\ on
modern glass has been measured and modeled, with a strong correlation
between the size distribution of particles and the evolution of the
mass deposited on the surface of the glass. Measurements showed that,
under sheltered conditions, mass deposition accelerated regularly with
time in areas closest to sources of PM (i.e., near roadways) and coarse
mineral particles were more prevalent compared to other sites (Alfaro
et al., 2012). Model predictions were found to correctly simulate the
development of haze at site locations when compared with measurements
(Alfaro et al., 2012).
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\61\ In this discussion of non-visibility welfare effects, haze
is used as it has been defined in the scientific literature on
soiling of glass, i.e., the ratio of diffuse transmitted light to
direct transmitted light (Lombardo et al., 2010). This differs from
the definition of haze as used in the discussion of visibility
welfare effects in section V.B above, where it is used as a
qualitative description of the blockage of sunlight by dust, smoke,
and pollution.
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Soiling of photovoltaic panels can lead to decreased energy
efficiency. For example, soiling by carbonaceous PM decreased solar
efficiency by nearly 38%, while soil particles reduced efficiency by
almost 70% (Radonjic et al., 2017). The rate of photovoltaic power
output can also be degraded by soiling and has been found to be related
to the rate of dust accumulation. In five sites in the U.S.
representing different meteorological and climatological
conditions,\62\ photovoltaic module power transmission was reduced by
approximately 3% for every g/m\2\ of PM deposited on the cover plate of
the photovoltaic panel, independent of geographical location (Boyle et
al., 2017). Another study found that photovoltaic module power output
was reduced by 40% after 10 months of exposure without cleaning,
although a number of anti-reflective coatings can generally mitigate
power reduction resulting from dust deposition (Walwil et al., 2017).
Energy efficiency can also be impacted by the soiling of building
materials, such as light-colored marble panels on building exteriors,
that are used to reflect a large portion of solar radiation for passive
cooling and to counter the urban heat island effect. Exposure to acidic
pollutants in urban environments have been found to reduce the solar
reflectance of marble, decreasing the cooling effect (Rosso et al.,
2016). Highly reflective roofs, or cool roofs, have been designed and
constructed to increase reflectance from buildings in urban areas, to
both decrease air conditioning needs and urban heat island effects, but
these efforts can be impeded by soiling of materials used for
constructing cool roofs. Methods have been developed for accelerating
the aging process of roofing materials to better characterize the
impact of soiling and natural weather on materials used in constructing
cool roofs (Sleiman et al., 2014).
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\62\ Of the five sites studied, three were in rural, suburban,
and urban areas representing a semi-arid environment (Front Range of
Colorado), one site represented a hot and humid environment (Cocoa,
Florida), and one represented a hot and arid environment
(Albuquerque, New Mexico) (U.S. EPA, 2019, section 13.4.2; Boyle et
al., 2017).
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Some progress has been made since the last review in the
development of dose-response relationships for soiling of building
materials, yet some key relationships remain poorly characterized. The
first general dose-response relationships for soiling of materials were
generated by measuring contrast reflectance of a soiled surface to the
reflectance of the unsoiled substrate for different materials,
including acrylic house paint, cedar siding, concrete, brick,
limestone, asphalt shingles, and window glass with varying total
suspended particulate (TSP) concentrations (Beloin and Haynie, 1975;
U.S. EPA, 2019, section 13.4.3). Continued efforts to develop dose-
response curves for soiling have led to some advancements for modern
materials, but these relationships
[[Page 24135]]
remain poorly characterized for limestone. One study quantified the
dose-response relationships between PM10 and soiling for
painted steel, white plastic, and polycarbonate filter material, but
there was too much scatter in the data to produce a dose-response
relationship for limestone (Watt et al., 2008). A dose-response
relationship for silica-soda-lime window glass soiling by
PM10, NO2, and SO2 was quantified
based on 31 different locations (Lombardo et al., 2010; U.S. EPA, 2019,
section 13.4.3, Figure 13-32, Equation 13-8). The development of this
dose-response relationship required several years of observation time
and had inconsistent data reporting across the locations.
Since the time of the last review, there has also been progress in
developing methods to more rapidly evaluate soiling of different
materials by PM mixtures. Modern buildings typically have simpler
lines, less detailed surfaces, and a greater use of glass, tile, and
metal, which are easier to clean than stone. There have also been major
changes in the types of materials used for buildings, including a
variety of polymers available for use as coatings and sealants. New
economic and environmental considerations beyond aesthetic appeal and
structural damage are emerging (U.S. EPA, 2019, section 13.4.3).
Changes in building materials and design, coupled with new approaches
in quantifying the dose-response relationship between PM and materials
effects, may reduce the amount of time needed for observations to
support the development of material-specific dose-response
relationships.
In addition to dose-response functions, damage functions have also
been used to quantify material decay as a function of pollutant type
and load. Damage can be determined from sample surveys or inspection of
actual damage and a damage function can be developed to link the rate
of material damage to time of replacement or maintenance. A cost
function can then link the time for replacement and maintenance to a
monetary cost, and an economic function links cost to the dose of
pollution based on the dose-response relationship (U.S. EPA, 2019,
section 13.4.3). Damage functions are difficult to assess because it
depends on human perception of the level of soiling deemed to be
acceptable and evidence in this area remains limited in the current
review. Since the last review, damage functions for a wide range of
building materials (i.e., stone, aluminum, zinc, copper, plastic,
paint, rubber, stone) have been developed and reviewed (Brimblecombe
and Grossi, 2010). One study estimated long-term deterioration of
building materials and found that damage to durable building material
(such as limestone, iron, copper, and discoloration of stone) is no
longer controlled by pollution as was historically documented but
rather that natural weathering is a more important influence on these
materials in modern times (Brimblecombe and Grossi, 2009). Even as PM-
attributable damage to stone and metals has decreased over time, it has
been predicted that there will be potentially higher degradation rates
for polymeric materials, plastic, paint, and rubber due to increased
oxidant concentrations and solar radiation (Brimblecombe and Grossi,
2009).
As at the time of the last review and described just above,
sufficient evidence is not available to conduct a quantitative
assessment of PM mass or component-related soiling and corrosion
effects. While soiling associated with PM can lead to increased
cleaning frequency and repainting of surfaces, no quantitative
relationships have been established between characteristics of PM or
the frequency of cleaning or repainting that would help to inform the
EPA's understanding of the public welfare implications of soiling (U.S.
EPA, 2019, section 13.4). Similarly, while some information is
available with regard to microbial deterioration of surfaces and the
contribution of carbonaceous PM to the formation of black crusts that
contribute to soiling, the available evidence does not support
quantitative analyses (U.S. EPA, 2019, section 13.4). While some new
evidence is available with respect to PM-attributable materials
effects, the data are insufficient to conduct quantitative analyses for
PM effects on materials in the current review.
D. Proposed Conclusions on the Current Secondary PM Standards
In reaching proposed conclusions on the current secondary PM
standards, the Administrator takes into account policy-relevant
evidence-based and quantitative information-based considerations, as
well as advice from the CASAC. Evidence-based considerations draw from
the EPA's assessment and integrated synthesis of the scientific
evidence of PM-related welfare effects in the ISA (U.S. EPA, 2019,
section 13.2). Quantitative information-based considerations draw from
the EPA's assessment of recent air quality and associated PM-related
visibility impairment in the PA (U.S. EPA, 2020, Chapter 5). Section
IV.D.1 below summarizes evidence- and quantitative information-based
considerations and the associated conclusions reached in the PA.
Section IV.D.2 describes advice received from the CASAC on the
secondary standards. Section IV.D.3 presents the Administrator's
proposed decision on the current secondary PM standards.
1. Evidence- and Quantitative Information-Based Considerations in the
Policy Assessment
The PA considers the degree to which the available scientific
evidence and quantitative information supports or calls into question
the adequacy of the protection afforded by the current secondary PM
standards. In doing so, the PA considers the evidence assessed in the
ISA, including the extent to which the new evidence for PM-related
visibility impairment, climate effects, or materials effects alters key
conclusions from the last review. The PA also considers quantitative
analyses of visibility impairment and the extent to which they may
indicate different conclusions from those in the last review regarding
the degree of protection from adverse effects provided by the current
secondary standards.
With regard to visibility impairment, the PA presents updated
analyses based on recent air quality information, with a focus on
locations meeting the current 24-hour PM2.5 and
PM10 standards. In the absence of advances in the monitoring
methods for directly measuring light extinction, and given the lack of
a robust monitoring network for the routine measurement of light
extinction across the U.S. (section IV.B.2), as in the last review, the
PA analyses use calculated light extinction to estimate PM-related
visibility impairment (U.S. EPA, 2020, section 5.2.1.1). Compared to
the last review, updated analyses incorporate several refinements.
These include (1) the evaluation of three versions of the IMPROVE
equation \63\ to calculate light extinction (U.S. EPA, 2020, Appendix
D, Equations D-1 through D-3) in order to better understand the
influence of variability in equation inputs; \64\ (2) the
[[Page 24136]]
use of 24-hour relative humidity data, rather than monthly average
relative humidity as was used in the last review (U.S. EPA, 2020,
section 5.2.1.2, Appendix D); and (3) the inclusion of the coarse
fraction in the estimation of light extinction in the subset of areas
with PM10-2.5 monitoring data available for the time period
of interest (U.S. EPA, 2020, section 5.2.1.2, Appendix D). The PA's
updated analyses include 67 monitoring sites that measure
PM2.5, including 20 sites that measure both PM10
and PM2.5, that are geographically distributed across the
U.S. in both urban and rural areas (U.S. EPA, 2020, Appendix D, Figure
D-1).\65\
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\63\ Given the lack of new information to inform a different
visibility metric, the metric used in the PA is that defined by the
EPA in the last review as the target level of protection for
visibility (discussed above in section IV.A.1): A PM2.5
visibility index with a 24-hour averaging time, a 90th percentile
form averaged over 3 year, and a level of 30 dv (U.S. EPA, 2020,
section 5.2.1.2).
\64\ While the PM2.5 monitoring network has an
increasing number of continuous FEM monitors reporting hourly
PM2.5 mass concentrations, there continue to be data
quality uncertainties associated with providing hourly
PM2.5 mass and component measurements that could be input
into IMPROVE equation calculations for sub-daily visibility
impairment estimates. Therefore, the inputs to these light
extinction calculations are based on 24-hour average measurements of
PM2.5 mass and components, rather than sub-daily
information.
\65\ These sites are those that have a valid 24-hour
PM2.5 design value for the 2015-2017 period and met
strict criteria for PM species for this analysis, based on 24-hour
average PM2.5 mass and component data that were available
from monitors in the IMPROVE network, CSN, and NCore Multipollutant
Monitoring Network (U.S. EPA, 2020, Appendix D). PM10-2.5
monitoring data is available for 20 of the 67 sites examined.
---------------------------------------------------------------------------
In areas that meet the current 24-hour PM2.5 standard
for the 2015-2017 time period, all sites have light extinction
estimates at or below 27 dv using the original and revised IMPROVE
equations (and most areas are below 25 dv; U.S. EPA, 2020, section
5.2.1.2). In addition, the one location that exceeds the current 24-
hour PM2.5 standard also has light extinction estimates at
or below 27 dv (U.S. EPA, 2020, Figure 5-3). These findings are
consistent with the findings of the analysis in the last review with
older air quality data from 102 sites (Kelly et al., 2012b; 78 FR 3201,
January 15, 2013).
When light extinction is calculated using the updated IMPROVE
equation from Lowenthal and Kumar (2016), the resulting 3-year
visibility metrics are slightly higher at all sites compared to light
extinction calculated using the IMPROVE equations used in previous
reviews (U.S. EPA, 2020, Figure 5-4). These results are consistent with
the higher OC multiplier included in the IMPROVE equation from
Lowenthal and Kumar (2016), reflecting the use of data from remote
areas with higher concentrations of organic PM when validating that
equation. As such, it is important to note that the Lowenthal and Kumar
(2016) version of the IMPROVE equation may overestimate light
extinction in non-remote areas, including in the urban areas in the
PA's analyses.
Nevertheless, when light extinction is calculated using the
Lowenthal and Kumar (2016) equation for those sites that meet the
current 24-hour PM2.5 standard, the 3-year visibility metric
is generally at or below 30 dv. The one exception to this is a site in
Fairbanks, Alaska that just meets the current 24-hour PM2.5
standard in 2015-17 and has a 3-year visibility index value just above
30 dv, rounding to 31 dv (compared to 27 dv when light extinction is
calculated with the original and revised IMPROVE equations) (U.S. EPA,
2020, Appendix D, Table D-3). However, the unique conditions at this
urban site (e.g., higher OC concentrations, much lower temperatures,
and the complete lack of sunlight for long periods) affect quantitative
relationships between OC, OM and visibility (e.g., Hand et al., 2012;
Hand et al., 2013), making the most appropriate approach for
characterizing light extinction in this area unclear.
In the last review, the EPA noted that PM2.5 is the size
fraction of PM responsible for most of the visibility impairment in
urban areas (77 FR 38980, June 29, 2012). Data available at the time of
the last review suggested that PM10-2.5 is often a minor
contributor to visibility impairment (U.S. EPA, 2010b), though it may
make a larger contribution in some areas in the desert southwestern
region of the U.S. However, at the time of the last review, there was
little data available from PM10-2.5 monitors to quantify the
contribution of coarse PM to calculated light extinction.
Since the last review, an expansion of PM10-2.5
monitoring efforts has increased the availability of data for use in
estimating light extinction with both PM2.5 and
PM10-2.5 concentrations included as inputs in the equations.
For 2015-2017, 20 of the 67 PM2.5 sites analyzed in the PA
have collocated PM10-2.5 monitoring data available. These 20
sites meet both the 24-hour PM2.5 standard and 24-hour
PM10 standard. All of these sites have 3-year visibility
metrics at or below 30 dv regardless of whether light extinction is
calculated with or without the coarse fraction, and for all three
versions of the IMPROVE equation. Generally, the contribution of the
coarse fraction to light extinction at these sites is minimal,
contributing less than 1 dv to the 3-year visibility metric. However,
these 20 locations would be expected to have relatively low
concentrations of coarse PM. If PM10 and PM10-2.5
data were available in locations with higher concentrations of coarse
PM, such as in the southwestern U.S., the coarse fraction may be a more
important contributor to light extinction and visibility impairment
than in the locations examined in the PA analyses.
In summary, the findings of these updated quantitative analyses are
consistent with those in the last review. The 3-year visibility metric
is generally at or below 27 dv in areas that meet the current secondary
standards, with only small differences observed for the three versions
of the IMPROVE equation. Though such differences are modest, the
IMPROVE equation from Lowenthal and Kumar (2016) always results in
higher light extinction values, which is expected given the higher OC
multiplier included in the equation and its validation using data from
remote areas far away from emissions sources. There is very little
difference in estimates of light extinction when PM10-2.5 is
included in the equation, although a somewhat larger coarse fraction
contribution to light extinction would be expected in areas with higher
coarse particle concentrations. Overall, the PA finds that updated
quantitative analyses indicate that the current secondary PM standards
provide a degree of protection against visibility impairment similar to
the target level of protection identified in the last review, defined
in terms of a PM visibility index.
With regard to PM-related climate effects, the PA recognizes that
while the evidence base has expanded since the last review, the new
evidence has not appreciably improved the understanding of the spatial
and temporal heterogeneity of PM components that contribute to climate
forcing (U.S. EPA, 2020, sections 5.2.2.1.1 and 5.4). Despite
continuing research, there are still significant limitations in
quantifying the contributions of PM and PM components to the direct and
indirect effects on climate forcing (e.g., changes to the pattern of
rainfall, changes to wind patterns, effects on vertical mixing in the
atmosphere) (U.S. EPA, 2020, sections 5.2.2.1.1 and 5.4). In addition,
while a number of improvements and refinements have been made to
climate models since the last review, these models continue to exhibit
variability in estimates of the PM-related climate effects on regional
scales (e.g., ~100 km) compared to simulations at the global scale
(U.S. EPA, 2020, sections 5.2.2.1.1 and 5.4). While new research has
added to the understanding of climate forcing on a global scale, there
remain significant limitations to quantifying potential adverse effects
from PM on climate in the U.S. and how they would vary in response to
incremental changes in PM concentrations in the U.S. Overall, the PA
recognizes that while new research is available on climate forcing on a
global scale, the remaining uncertainties and limitations are
significant, and the new global scale
[[Page 24137]]
research does not translate directly to use at regional spatial scales.
Thus, the evidence does not provide a clear understanding at the
spatial scales needed for the NAAQS of a quantitative relationship
between concentrations of PM mass in ambient air and the associated
climate-related effects (U.S. EPA, 2020, sections 5.2.2.2.1 and 5.4).
The PA concludes that the evidence does not call into question the
adequacy of the current secondary PM standards for climate effects.
With regard to materials effects, the PA notes the availability of
new evidence in this review related to the soiling process and the
types of materials that are affected. Such evidence provides some
limited information to inform dose-response relationships and damage
functions associated with PM, though most recent studies have been
conducted outside the U.S. (U.S. EPA, 2020, section 5.2.2.1.2; U.S.
EPA, 2019, section 13.4). The recent evidence includes studies
examining PM-related effects on the energy efficiency of solar panels
and passive cooling building materials, though there remains
insufficient evidence to establish quantitative relationships between
PM in ambient air and these or other materials effects (U.S. EPA, 2020,
section 5.2.2.1.2). While new research has expanded the body of
evidence for PM-related materials effects, the PA recognizes the lack
of information to inform quantitative analyses assessing materials
effects or the potential public welfare implications of such effects.
Thus, the PA concludes that the evidence does not call into question
the adequacy of the current secondary PM standards for materials
effects.
Overall, the PA recognizes that the newly available welfare effects
evidence, critically assessed in the ISA as part of the full body of
evidence, reaffirms the conclusions on the visibility, climate, and
materials effects of PM as recognized in the last review (U.S. EPA,
2020, sections 5.2.1.1., 5.2.2.1, and 5.4). Further, there is a general
consistency of the currently available evidence with the evidence that
was available in the last review, including with regard to key aspects
of the decision to retain the standards in the last review (U.S. EPA,
2020, sections 5.2.1.1, 5.2.2.1, and 5.4). The quantitative analyses
for visibility impairment for recent air quality conditions indicate a
similar level of protection against visibility effects considered to be
adverse in the last review (U.S. EPA, 2020, sections 5.2.1.2 and 5.4).
Collectively, the PA finds that the evidence and quantitative
information-based considerations support consideration of retaining the
current secondary PM standards, without revision (U.S. EPA, 2020,
section 5.4).
2. CASAC Advice
As part of its review of the draft PA, the CASAC has provided
advice on the adequacy of the current secondary PM standards. In its
comments on the draft PA, the CASAC concurs with staff's overall
preliminary conclusions that it is appropriate to consider retaining
the current secondary PM standards without revision (Cox, 2019a). The
CASAC ``finds much of the information . . . on visibility and materials
effects of PM2.5 to be useful, while recognizing that
uncertainties and controversies remain about the best ways to evaluate
these effects'' (Cox, 2019a, p. 13 of consensus responses). Regarding
climate, while the CASAC agrees that research on PM-related effects has
expanded since the last review, it also concludes that ``there are
still significant uncertainties associated with the accurate
measurement of PM contributions to the direct and indirect effects of
PM on climate'' (Cox, 2019a, pp. 13-14 of consensus responses). The
committee recommends that the EPA summarize the ``current scientific
knowledge and quantitative modeling results for effects of reducing
PM2.5'' on several climate-related outcomes (Cox, 2019a, p.
14 of consensus responses), while also recognizing that ``it is
appropriate to acknowledge uncertainties in climate change impacts and
resulting welfare impacts in the United States of reductions in
PM2.5 levels'' (Cox, 2019a, p. 14 of consensus responses).
When considering the overall body of scientific information for PM-
related effects on visibility, materials, and climate, the CASAC agrees
that ``the available evidence does not call into question the
protection afforded by the current secondary PM standards and concurs
that they should be retained'' (Cox, 2019a, p. 3 of letter).
3. Administrator's Proposed Decision on the Current Secondary PM
Standards
This section summarizes the Administrator's considerations and
conclusions related to the current secondary PM2.5 and
PM10 standards and presents his proposed decision to retain
those standards, without revision. In establishing secondary standards
under the Act that are ``requisite'' to protect the public welfare from
any known or anticipated adverse effects, the Administrator is seeking
to establish standards that are neither more nor less stringent than
necessary for this purpose. He notes that secondary standards are not
meant to protect against all known or anticipated effects, but rather
those that are judged to be adverse to the public welfare. Consistent
with the primary standards discussed above (sections II.C.3 and
III.C.3), the Act does not require standards to be set at a zero-risk
level; but rather at a level that limits risk sufficiently so as to
protect the public welfare, but not more stringent than necessary to do
so.
Given these requirements, the Administrator's final decision in
this review will be a public welfare policy judgment that draws upon
the scientific and technical information examining PM-related
visibility impairment, climate effects and materials effects, including
how to consider the range and magnitude of uncertainties inherent in
that information. The Administrator recognizes that his final decision
will be based on an interpretation of the scientific evidence and
technical analyses that neither overstates nor understates their
strengths and limitations, nor the appropriate inferences to be drawn.
As an initial matter in considering the secondary standards, the
Administrator notes the longstanding body of evidence for PM-related
visibility impairment. As in the last review, this evidence continues
to demonstrate a causal relationship between ambient PM and effects on
visibility (U.S. EPA, 2019, section 13.2). The Administrator recognizes
that visibility impairment can have implications for people's enjoyment
of daily activities and for their overall sense of well-being.
Therefore, as in previous reviews, he considers the degree to which the
current secondary standards protect against PM-related visibility
impairment.
In doing so, the Administrator adopts an approach consistent with
the approach used in the last review (section IV.A.1). That is, he
first defines an appropriate target level of protection in terms of a
PM visibility index that accounts for the factors that influence the
relationship between particles in the ambient air and visibility (i.e.,
size fraction, species composition, and relative humidity). He then
considers air quality analyses examining this PM visibility index in
locations meeting the current 24-hour PM2.5 and
PM10 standards (U.S. EPA, 2020, section 5.2.1.2).
To identify a target level of protection, the Administrator first
defines the specific characteristics of the visibility index. He notes
that in the last review, the EPA used an index based on estimates of
light extinction by PM2.5
[[Page 24138]]
components calculated using an adjusted version of the original IMPROVE
algorithm. As described above (sections IV.B and IV.D.1), this
algorithm allows the estimation of light extinction using routinely
monitored components of PM2.5 and PM10-2.5,\66\
along with estimates of relative humidity. While revisions have been
made to the IMPROVE algorithm since the last review (U.S. EPA, 2020,
section 5.2.1.1), the Administrator recognizes that our fundamental
understanding of the relationship between ambient PM and light
extinction has changed little and that the various IMPROVE algorithms
can appropriately reflect this relationship across the U.S. In the
absence of a robust monitoring network to directly measure light
extinction (sections IV.B.2 and IV.D.1), he judges that estimated light
extinction, as calculated using the IMPROVE algorithms, continues to
provide a reasonable basis for defining a target level of protection
against PM-related visibility impairment in the current review.
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\66\ In the last review, the focus was on PM2.5
components given their prominent role in PM-related visibility
impairment in urban areas and the limited data available for
PM10-2.5 (77 FR 38980, June 29, 2012; U.S. EPA, 2020,
section 5.2.1.2).
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In further defining the characteristics of a visibility index based
on estimates of light extinction, the Administrator considers the
appropriate averaging time, form, and level of the index. With regard
to the averaging time and form, the Administrator judges that the
decisions made in the last review remain reasonable. In that review, a
24-hour averaging time was selected and the form was defined as the 3-
year average of annual 90th percentile values. The decision on
averaging time recognized the relatively strong correlations between
24-hour and sub-daily (i.e., 4-hour average) PM2.5 light
extinction (78 FR 3226, January 15, 2013), indicating that a 24-hour
averaging time is an appropriate surrogate for the sub-daily time
periods relevant for visual perception. This decision also recognized
that the longer averaging time may be less influenced by atypical
conditions and/or atypical instrument performance (78 FR 3226, January
15, 2013). The decision to set the form as the 3-year average of annual
90th percentile values noted that (1) a 3-year average provides
stability from the occasional effect of inter-annual meteorological
variability (78 FR 3198, January 15, 2013; U.S. EPA, 2011, p. 4-58);
(2) the 90th percentile corresponds to the median of the distribution
of the 20 percent worst days for visibility, which are targeted in
Class I areas by the Regional Haze Program; \67\ and (3) available
studies on people's visibility preferences did not identify a basis for
a different target than that identified for Class I areas (U.S. EPA,
2011, p. 4-59). Given the similar information available in the current
review, the Administrator judges that these decisions remain reasonable
and, therefore, that it remains appropriate to define a visibility
index in terms of a 24-hour averaging time and a form based on the 3-
year average of annual 90th percentile values.
---------------------------------------------------------------------------
\67\ In the last review, 90th, 95th, and 98th percentile forms
were evaluated (U.S. EPA, 2010b, section 4.3.3; 78 FR 3198, January
15, 2013), and a standard with a 90th percentile form was reasonably
expected to limit the occurrence of days with peak PM-related light
extinction (78 FR 3198, January 15, 2013).
---------------------------------------------------------------------------
The level of the index was set at 30 dv in the last review,
reflecting the highest degree of visibility impairment judged to be
acceptable by at least 50% of study participants in the available
visibility preference studies (78 FR 3226-3227, January 15, 2013). The
focus on 30 dv, rather than a lower level, was supported in light of
the important uncertainties and limitations in the underlying public
preference studies. Consistent with the last review, the Administrator
notes the following uncertainties and limitations in these studies
(U.S. EPA, 2020, section 5.2.1.1):
The available studies may not capture the full range of
visibility preferences in the U.S. population, particularly given the
potential for preferences to vary based on the visibility conditions
commonly encountered and the types of scenes being viewed.
The available preference studies were conducted 15 to 30
years ago and may not reflect the visibility preferences of the U.S.
population today.
The available preference studies have used a variety of
methods, potentially influencing responses as to what level of
visibility impairment is deemed acceptable.
Factors that are not captured by the methods used in
available preference studies may influence people's judgments on
acceptable visibility, including the duration of visibility impairment,
the time of day during which light extinction is greatest, and the
frequency of episodes of visibility impairment.
Because no visibility preference studies have been conducted in the
U.S. since the last review, the Administrator recognizes that these
uncertainties and limitations persist. Therefore, in the current review
his consideration of the degree of visibility impairment constituting
an adverse public welfare impact is based on the same preference
studies, with the same uncertainties and limitations, that were
available in the last review. Drawing from this information, the
Administrator judges it appropriate to again use 30 dv as the level of
the visibility index.
Having concluded that it remains appropriate in this review to
define the target level of protection in terms of a visibility index
based on estimated light extinction as described above (i.e., with a
24-hour averaging time; a 3-year, 90th percentile form; and a level of
30 dv), the Administrator next considers the degree of protection from
visibility impairment afforded by the existing secondary standards. He
considers the updated analyses of PM-related visibility impairment
presented in the PA (U.S. EPA, 2020, section 5.2.1.2), which reflect
several improvements over the previous review. Specifically, the
updated analyses examine multiple versions of the IMPROVE algorithm,
including the version incorporating revisions since the last review
(section IV.D.1). This approach provides an improved understanding of
how variation in equation inputs impacts calculated light extinction
(U.S. EPA, 2020, Appendix D). In addition, for a subset of monitoring
sites with available PM10-2.5 data, updated analyses better
characterize the influence of the coarse fraction on light extinction
(U.S. EPA, 2020, section 5.2.1.2).
The Administrator notes that the results of these updated analyses
are consistent with the results from the last review. Regardless of the
IMPROVE equation used, they demonstrate that the 3-year visibility
metric is at or below about 30 dv in all areas meeting the current 24-
hour PM2.5 standard,\68\ and below 25 dv in most of those
areas (section IV.D.1). In the locations with available
PM10-2.5 monitoring, which met both the current 24-hour
PM2.5 and PM10 standards, 3-year visibility
metrics were at or below 30 dv regardless of whether the coarse
fraction was included in the calculation (U.S. EPA, 2020, section
5.2.1.2). Given the results of these analyses, the Administrator
concludes that the updated scientific
[[Page 24139]]
evidence and technical information support the adequacy of the current
secondary PM2.5 and PM10 standards to protect
against PM-related visibility impairment. While the inclusion of the
coarse fraction had a relatively modest impact on calculated light
extinction in these analyses, he nevertheless recognizes the continued
importance of the PM10 standard given the potential for
larger impacts in locations with higher coarse particle concentrations,
such as in the southwestern U.S., which were not included in the PA's
analyses due to insufficient coarse particle data (U.S. EPA, 2019,
section 13.2.4.1; U.S. EPA, 2020, section 5.2.1.2).
---------------------------------------------------------------------------
\68\ As discussed in the PA (U.S. EPA, 2020, section 5.2.1.2),
one site in Fairbanks, Alaska just meets the current 24-hour
PM2.5 standard and has a 3-year visibility index value of
27 dv based on the original IMPROVE equation and 31 dv based on the
Lowenthal and Kumar (2016) equation. At this site, use of the
Lowenthal and Kumar (2016) equation may not be appropriate given
that PM composition and meteorological conditions may differ
considerably from those under which revisions to the equation have
been validated (U.S. EPA, 2020, section 5.2.1.2).
---------------------------------------------------------------------------
With respect to non-visibility welfare effects, the Administrator
considers the evidence for PM-related impacts on climate and on
materials and concludes that it is generally appropriate to retain the
existing secondary standards and that it is not appropriate to
establish any distinct secondary PM standards to address non-visibility
PM-related welfare effects. With regard to climate, he recognizes that
a number of improvements and refinements have been made to climate
models since the time of the last review. However, despite continuing
research and the strong evidence supporting a causal relationship with
climate effects (U.S. EPA, 2019, section 13.3.9), the Administrator
notes that there are still significant limitations in quantifying the
contributions of the direct and indirect effects of PM and PM
components on climate forcing (U.S. EPA, 2020, sections 5.2.2.1.1 and
5.4). He also recognizes that models continue to exhibit considerable
variability in estimates of PM-related climate impacts at regional
scales (e.g., ~100 km), compared to simulations at the global scale
(U.S. EPA, 2020, sections 5.2.2.1.1 and 5.4). The resulting uncertainty
leads the Administrator to conclude that the scientific information
available in the current review remains insufficient to quantify, with
confidence, the impacts of ambient PM on climate in the U.S. (U.S. EPA,
2020, section 5.2.2.2.1) and that there is insufficient information at
this time to base a national ambient standard on climate impacts.
With respect to materials effects, the Administrator notes that the
evidence available in the current review continues to support the
conclusion that there is a causal relationship with PM deposition (U.S.
EPA, 2019, section 13.4). He recognizes that deposition of particles in
the fine or coarse fractions can result in physical damage and/or
impaired aesthetic qualities. Particles can contribute to materials
damage by adding to the effects of natural weathering processes and by
promoting the corrosion of metals, the degradation of painted surfaces,
the deterioration of building materials, and the weakening of material
components. While some new evidence on materials effects of PM is
available in this review, the Administrator notes that this evidence is
primarily from studies conducted outside of the U.S. (U.S. EPA, 2019,
section 13.4). Given the more limited amount of information on the
quantitative relationships between PM and materials effects in the
U.S., and uncertainties in the degree to which those effects could be
adverse to the public welfare, the Administrator judges that the
scientific information available in the current review remains
insufficient to quantify, with confidence, the public welfare impacts
of ambient PM on materials and that there is insufficient information
at this time to support a distinct national ambient standard based on
materials impacts.
Taken together, the Administrator concludes that the scientific and
technical information for PM-related visibility impairment, climate
impacts, and materials effects, with its attendant uncertainties and
limitations, supports the current level of protection provided by the
secondary PM standards as being requisite to protect against known and
anticipated adverse effects on public welfare. For visibility
impairment, this conclusion reflects his consideration of the evidence
for PM-related light extinction, together with his consideration of
updated analyses of the protection provided by the current secondary
PM2.5 and PM10 standards. For climate and
materials effects, this conclusion reflects his judgment that, although
it remains important to maintain secondary PM2.5 and
PM10 standards to provide some degree of control over long-
and short-term concentrations of both fine and coarse particles, it is
generally appropriate to retain the existing secondary standards and
that it is not appropriate to establish any distinct secondary PM
standards to address non-visibility PM-related welfare effects. His
conclusions on the secondary standards are consistent with advice from
the CASAC, which agrees ``that the available evidence does not call
into question the protection afforded by the current secondary PM
standards'' and recommends that the secondary standards ``should be
retained'' (Cox, 2019a, p. 3 of letter). Thus, based on his
consideration of the evidence and analyses for PM-related welfare
effects, as described above, and his consideration of CASAC advice on
the secondary standards, the Administrator proposes to retain those
standards (i.e., the current 24-hour and annual PM2.5
standards, 24-hour PM10 standard), without revision.
V. Statutory and Executive Order Reviews
Additional information about these statutes and Executive Orders
can be found at https://www2.epa.gov/laws-regulations/laws-and-executive-orders.
A. Executive Order 12866: Regulatory Planning and Review and Executive
Order 13563: Improving Regulation and Regulatory Review
The Office of Management and Budget (OMB) determined that this
action is a significant regulatory action and it was submitted to OMB
for review. Any changes made in response to OMB recommendations have
been documented in the docket. Because this action does not propose to
change the existing NAAQS for PM, it does not impose costs or benefits
relative to the baseline of continuing with the current NAAQS in
effect. Thus, the EPA has not prepared a Regulatory Impact Analysis for
this action.
B. Executive Order 13771: Reducing Regulations and Controlling
Regulatory Costs
This action is not expected to be an Executive Order 13771
regulatory action. There are no quantified cost estimates for this
proposed action because EPA is proposing to retain the current
standards.
C. Paperwork Reduction Act (PRA)
This action does not impose an information collection burden under
the PRA. There are no information collection requirements directly
associated with a decision to retain a NAAQS without any revision under
section 109 of the CAA and this action proposes to retain the current
PM NAAQS without any revisions.
D. Regulatory Flexibility Act (RFA)
I certify that this action will not have a significant economic
impact on a substantial number of small entities under the RFA. This
action will not impose any requirements on small entities. Rather, this
action proposes to retain, without revision, existing national
standards for allowable concentrations of PM in ambient air as required
by section 109 of the CAA. See also American Trucking Associations v.
EPA, 175 F.3d 1027, 1044-45 (D.C. Cir. 1999) (NAAQS do not have
significant impacts upon small entities because NAAQS themselves impose
no
[[Page 24140]]
regulations upon small entities), rev'd in part on other grounds,
Whitman v. American Trucking Associations, 531 U.S. 457 (2001).
E. Unfunded Mandates Reform Act (UMRA)
This action does not contain any unfunded mandate as described in
the UMRA, 2 U.S.C. 1531-1538, and does not significantly or uniquely
affect small governments. This action imposes no enforceable duty on
any state, local, or tribal governments or the private sector.
F. Executive Order 13132: Federalism
This action does not have federalism implications. It will not have
substantial direct effects on the states, on the relationship between
the national government and the states, or on the distribution of power
and responsibilities among the various levels of government.
G. Executive Order 13175: Consultation and Coordination With Indian
Tribal Governments
This action does not have tribal implications, as specified in
Executive Order 13175. It does not have a substantial direct effect on
one or more Indian Tribes. This action does not change existing
regulations; it proposes to retain the current primary NAAQS for PM,
without revision. Executive Order 13175 does not apply to this action.
H. Executive Order 13045: Protection of Children From Environmental
Health Risks and Safety Risks
This action is not subject to Executive Order 13045 because it is
not economically significant as defined in Executive Order 12866. The
health effects evidence for this action, which includes evidence for
effects in children, is summarized in section II.B above and is
described in the ISA and PA, copies of which are in the public docket
for this action.
I. Executive Order 13211: Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution or Use
This action is not subject to Executive Order 13211, because it is
not likely to have a significant adverse effect on the supply,
distribution, or use of energy. The purpose of this document is to
propose to retain the current PM NAAQS. This proposal does not change
existing requirements. Thus, the EPA concludes that this proposal does
not constitute a significant energy action as defined in Executive
Order 13211.
J. National Technology Transfer and Advancement Act (NTTAA)
This action does not involve technical standards.
K. Executive Order 12898: Federal Actions To Address Environmental
Justice in Minority Populations and Low-Income Populations
The EPA believes that this action does not have disproportionately
high and adverse human health or environmental effects on minority,
low-income populations and/or indigenous peoples, as specified in
Executive Order 12898 (59 FR 7629, February 16, 1994). The
documentation related to this is contained in sections II through IV
above. The action proposed in this document is to retain, without
revision, the existing NAAQS for PM based on the Administrator's
conclusion that the existing standards protect public health, including
the health of sensitive groups, with an adequate margin of safety and
protect the public welfare. As discussed in section II, the EPA
expressly considered the available information regarding health effects
among at-risk populations in reaching the proposed decision that the
existing standard is requisite.
L. Determination Under Section 307(d)
Section 307(d)(1)(V) of the CAA provides that the provisions of
section 307(d) apply to ``such other actions as the Administrator may
determine.'' Pursuant to section 307(d)(1)(V), the Administrator
determines that this action is subject to the provisions of section
307(d).
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List of Subjects in 40 CFR Part 50
Environmental protection, Air pollution control, Carbon monoxide,
Lead, Nitrogen dioxide, Ozone, Particulate matter, Sulfur oxides.
Andrew Wheeler,
Administrator.
[FR Doc. 2020-08143 Filed 4-29-20; 8:45 am]
BILLING CODE 6560-50-P