October 21, 2005

Stephen L. Johnson
Administrator
Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460

Dear Administrator Johnson:

On behalf of the membership of the undersigned physician and public health

organizations, we strongly encourage you to adopt stricter air quality standards
for particulate matter. As medical and health professionals, we confront daily the
impact air pollution has on the health and lives of the patients and citizens we
serve.

As you know, the EPA Office of Research and Development has completed a
comprehensive review of existing research on the health effects of exposure to
particulate air pollutants. The findings of the research community, as
summarized in the EPA Criteria Document and reviewed and validated by the
Clean Air Scientific Advisory Committee (CASAC), clearly show that there are
adverse health effects at levels below the current standard. The air quality
standards for particulate matter need to be tightened.

The EPA Staff Paper has laid out a range of options for revising the current
NAAQS for particulate matter to protect our nation’s health. These
recommendations have been endorsed by CASAC. We strongly recommend
that EPA adopt as strict a standard as possible to provide the highest level of
protection against the known adverse health effects of air pollution, since safe
levels cannot be identified.

Specifically, we are recommending the EPA propose a revised National Ambient

Air Quality Standard (NAAQS) for fine particulate matter (PM 2.5) as follows:

ƒ 12 µg/m3 for the average annual standard

ƒ 25 µg/m3 for the 24-hour standard
ƒ 99th percentile used for compliance determination

The undersigned organizations would like to highlight the need for a stricter 24-
hour standard. Spikes in exposure to particulate matter pose significant risk to
vulnerable populations including the elderly and children. By tightening the
standard for 24-hour exposures, the EPA will generate significant health benefits
for vulnerable populations and the entire populace. At the ranges recommended
in the Staff Paper, we see substantial tightening the 24-hour standard as a critical
component of the EPA revision of the particulate matter standards.

We also strongly recommend that EPA strengthen the form of the current 24-
hour standard. The current 98th percentile form allows nearly three weeks of
dangerous air pollution exposure to be excluded from calculating compliance with
the daily standard. Additionally, air pollution spikes caused by forest fires and
other exposure anomalies can be excluded from the calculation. Such
exclusions inappropriately lower exposure averages and gives the public a false
impression of the level of air pollution in their area.

We look forward to reviewing and commenting on the proposed revised

particulate matter air quality standards due to be issued later this year. We hope
your agency will start the process on a positive note by proposing strict standards
to best protect the public health.

Sincerely,

American Thoracic Society

American Association of Cardiovascular and Pulmonary Rehabilitation
American Association of Respiratory Care
American College of Cardiology
American College of Preventative Medicine
American Public Health Association
National Association for the Medical Direction of Respiratory Care