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Proposed Endangerment Finding for Greenhouse Gases under the Clean Air Act (CAA)

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American Medical Association filings
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American Medical Association filed 1 comment on this docket between Jun 23, 2009 and Jun 23, 2009. 235 other organizations filed here. The comment window closed 6244d ago.

What American Medical Association filed (1)

Jun 23, 2009· Comment submitted by Michael D. Maves, MD, MBA, American Medical Association (AMA)· EPA-HQ-OAR-2009-0171-3149

June 23, 2009 The Honorable Lisa Jackson Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Ave., NW Washington, DC 20460 RE: Docket ID No. EPA-HQ-OAR-2009-0171 Dear Administrator Jackson: On behalf of the physician and medical student members of the American Medical Association (AMA), I want to convey our strong support for the proposed finding by the Environmental Protection Agency that persistent greenhouse gases such as carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride, endanger the public's health and welfare. The AMA has a lengthy history of public health advocacy in general, and of supporting clean air policies that would impose more stringent standards on particulate matter, mercury, and ozone. We continue to advocate for strong science-based environmental health policy in the United States and through the World Medical Association. Increases in greenhouse gas concentrations have been shown as a contributing factor in global climate change, and multiple and severe effects of climate change on health have been documented by numerous governmental and scientific bodies, including the Intergovernmental Panel on Climate Change (IPCC), the U.S. Climate Change Science Program, and the World Health Organization. The AMA supports and concurs with these findings. The most recent IPCC report projects that, without intervention, global greenhouse gas emissions will continue to increase, as will the rate of warming. It is estimated that if greenhouse gas emissions continue at the current rate or are increased, the rate of climate change for the 21st Century will be above what was observed in the 20th Century. The increases in these greenhouse gas emissions have already caused documented health problems. Peer-reviewed research conclusively demonstrates that increased atmospheric concentrations of ozone and particulate matter cause adverse health effects in humans, The Honorable Lisa Jackson June 23, 2009 Page 2 especially among more sensitive populations. In particular, increased ozone, formed by a reaction between nitrogen oxides (NOx) and volatile organic compounds (VOCs), has been linked to several respiratory problems. The reaction between VOCs and NOxs is accelerated during heat waves. In adults, increased exposure to elevated concentrations of ozone causes an inflammatory response and damages the lung and respiratory tract epithelia. The IPCC reports that exposure to elevated concentrations of ozone is also associated with increased hospital admissions for pneumonia, chronic obstructive pulmonary disease, asthma, allergic rhinitis and other respiratory diseases, and with premature mortality. Children are at greater risk than adults from the adverse effects of air pollution for several reasons. Children have a higher level of activity and a faster breathing rate based on their size when compared to adults, which increases the effective dose of inhaled pollutants. Also, children spend more time outdoors than adults and are still undergoing lung development. This disproportionate potential burden on children necessitates the development of clean air policy that protects human health, especially that of the most vulnerable individuals. The respiratory effects of increased greenhouse gases are only one of the documented health effects from global climate change. Excess mortality due to extreme temperatures and increases in infectious disease are some of the most well-known adverse health effects from climate change. We must avoid future climate-related risks to the basic supports for human health, including adequate food, clean water, and secure habitat. The United States will not be able to avoid the health effects of climate change simply by developing novel medical treatments. While we are fortunate to have a strong and prosperous nation, we have also witnessed the impacts of a changing climate o…

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Abstract

The Supreme Court decision on Mass. v. EPA in April 2007, stated that carbon dioxide (CO2) meets the CAA definition of air pollution and that EPA must decide whether or not greenhouse gases cause endangerment (or whether scientific uncertainty precludes EPA from making a reasoned judgment). The basis for this decision must be the statutory criteria laid out under Section 202 of the CAA. In December 2007, EPA developed and submitted to OMB a proposal for an endangerment finding (in conjunction with a proposed GHG transportation rulemaking). It was withdrawn a few weeks later following passage of the Energy Independence and Security Act. OAR is now working to issue a proposed endangerment determination.

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Proposed Endangerment Finding for Greenhouse Gases under the Clean Air Act (CAA) (EPA) — American Medical Association | OpenPolis