The Washington American Lung Association's "State of the Air in Washington" Report is Hot Air
2006-10
The Washington Chapter of the American Lung Association’s (WALA) announcement of their “State of the Air in Washington” Report in May 2006 states that “on average the air quality is unhealthy one day per week” in all urban areas of the State.[1] Their headline data show poor, that is, unhealthy, air quality for 111 days in King County, or about one poor or unhealthy day in every three. The report goes on to tout the virtues of numerous mitigation strategies that are being taken or pushed by regional air pollution agencies to reduce ozone and particulate matter (PM) levels.
The report argues this will, in turn, reduce personal exposures to poor air. WALA places specific emphasis on the protection of children and adults with asthma or other respiratory disease.
The WALA’s claims about the health risks at current air quality levels of ozone and PM, however, are totally fallacious. Their claims are based on the intentional misuse of the Air Quality Index (AQI) data derived from daily observations taken throughout Washington. The Lung Association report does not exhibit any reasonable knowledge about how the Index relates to federal ambient air standards for these pollutants. Worse, the WALA not only altered the actual definitions of terms used in the AQI, but it also transposed the pertinent health effects warnings.
For purposes of brevity, I will focus on the WALA’s discussion of ozone air quality, although my findings and conclusions are equally applicable to particulate matter.
In 1976, an interagency task force headed by the President’s Council on Environmental Quality developed the Air Quality Index.[2] I was the senior advisor for air quality on the Council Staff at that time and was intimately involved in the development of the AQI. The current AQI was mandated for nationwide implementation in the Clean Air Act of 1977. Official guidance on how the Index is to be used has been published in federal regulations.[3] There is no latitude in the guidance for altering the wording of the AQI descriptor intervals or the health advisory language.
In the 1970s, there were some 35 jurisdictions employing 29 different types of air quality indices. A sample of these alternative indices reflected the use of 10 different descriptor words for the same AQI rating of 25. The President’s Task Force resolved this confusion by developing a universal index for nationwide use. By deliberately misusing the Index’s descriptions, the Lung Association has turned the clock back 30 years.
The AQI is simply a calculated number from 0 to 600 based on the ratio of daily observed air quality levels for each of the five pollutants relative to their respective health standards. An AQI of 100 equals the National Ambient Air Quality Standard (NAAQS) except for particulate matter (PM). The highest calculated Air Quality Index, regardless of the pollutant, is reported daily along with the appropriate health descriptor and warning as appropriate. Originally an AQI between 50 and 100 was described as “Satisfactory,” but was later changed to “Moderate” to indicate a slight or moderate air pollution problem.
There has never been any inference by the United States EPA, Washington Department of Ecology (WDOE) or Washington Department of Health (WDOH) that there are any populations at risk when the AQI moves from 49 to 51. One can always make the hypothetical argument that there may be a few sensitive individuals who might experience an adverse health response at AQI at or just below 100. This is accepted thinking, but it is not even close to the vast population exposure domain between levels of 50 and 100 claimed by the Lung Association.
To take this manipulation even further, the Lung Association fallaciously substituted the word “Poor” for “Moderate” for all days in the 50 to 100 range. The WALA further added the word “Unhealthy” as a synonym for poor in its press release. Particulate matter accounts for the vast majority of the reported “Moderate” AQI levels.
Contrary to the WALA’s negative image of Washington’s ozone and particulate matter levels, the state is well below the Federal National Ambient Air Quality Standard for healthy air. The highest ozone levels measured in the state are at remote locations east and southeast of Enumclaw. These observations are not only much higher than those observed in the urban areas of Puget Sound, but are in full compliance and are, in fact, almost 20 percent below the federal standard.[4]
Despite that, the Lung Association does not consider this sizable margin as being good enough and gives the region only a “C” grade in its most recent report card.[5] This is an arbitrary rating and is not based on any science.
Based on my analysis, using the Lung Association’s data and standard would mean that all urban areas with a current “C” grade would have to achieve an ambient ozone standard of 0.062 parts per million (PPM) in order to get an “A” grade. This is 27 percent below the current, and already conservative, federal standard of 0.085 PPM. The WALA’s grading system is not based on any scientific analysis and rejects the past work of recognized scientists in the air pollution field.
The current ozone standard was set in 1997 after an exhaustive scientific and regulatory review process. The Federal Register states that the standard is set “to provide increased protection to the public especially children and other at risk populations” and that the standard “will protect public health with an adequate margin of safety.”[6]
Protecting exercising children from respiratory stress was the primary basis for the current NAAQS. The EPA’s population exposure model used in establishing the standard was applied to the Puget Sound Region by this author. The exposure model concluded that there were no children at risk anywhere in the region.
The Burden of Asthma Report,[7] which the Lung Association highlights in support of its concern about ozone health effects in the state, contradicts its use in the WALA report. In the report, the Washington Department of Health sets forth what the air quality goal should be to protect asthmatics in Washington. The Agency embraced the National Healthy People 2010 Objective 8-1 Goal, which is to achieve zero population exposure above the NAAQS by 2012.[8] An analysis of current air quality data shows full compliance with the Objective 8-1 Goal by a significant margin.
Relying on that faulty analysis, WALA touts a whole series of air pollution mitigation strategies it believe will reduce this fabricated population exposure risk.
With respect to ozone exposure, none of the strategies discussed by the Lung Association will reduce future ozone levels by any measurable amount, including the implementation of the California auto emissions standard. The Puget Sound Clean Air Agency (PSCAA) has not conducted a defensible regulatory analysis to support this or any other mitigating strategy. Without a basis in science, those regulations appear to be a “control for control sake” approach.
Valid air quality models are available, but their use has been ignored primarily because the results will not support the agency’s new regulatory proposals. For example, the adoption of the California auto emissions standards are not technically justified from an air quality perspective in any written agency documentation. The PSCAA simply claims that the California standards are needed to “preserve the air shed for further growth.”
Without any supporting technical documentation, the agency has continued to claim that the region might slip into non-attainment of the ozone standard and suffer onerous regulatory sanctions from EPA. The actual threat the agency identifies, however, is a result of normal year to year variation in summertime weather, not our personal driving or lawn mowing habits. In other words, the changes represent a seasonal cycle, not a longer, year to year trend.
If we had maintained the current federal auto emissions standards rather than the California standards, the probability that the Puget Sound Region will slip into non-attainment in 2030 due to adverse weather conditions is about one in one hundred (actually 1.2 in 100). The California standards might reduce this probability by the equivalent of two chances in one thousand. This is the same probability as flipping a coin nine times and getting all heads or all tails. I surely would not rely on this outcome to preserve our air shed, especially given the high cost for getting this insignificant increase in assurance.
State Does not Back the Claims
Finally, the Lung Association is not being honest about the scientific evidence backing for its claims. The WALA claims that its report was prepared in collaboration with Washington’s regional air pollution authorities. The Lung Association’s media director, Paul Payton, said the Washington State Department of Ecology Air Program approved the report’s content and conclusions.[9] He could not, however, provide any documentation regarding this supposed approval.
When contacted, Stu Clark, the Air Program Director at the Washington Department of Ecology stated that “WDOE follows the federal policy when reporting the AQI, but the WDOE recognizes that there are sensitive individuals who may experience respiratory symptoms in the Moderate Category.”[10] He confirmed that the only involvement by his agency in the WALA report was to review the basic Air Quality Index data, but it did not review the report’s findings as reflected in their press release.
Without WDOE’s backing, the WALA report and press release is without any scientific basis, and, as the above analysis shows, the report relies on an obvious misreading of the actual data. It appears that Lung Association officials relied on their collaboration with PSCAA to claim their report has statewide regional air agency support. I contacted Alice Collingwood, PSCAA’s public relations manager. She confirmed that PSCAA was essentially a full partner in preparing the report.[11] She said she may have seen the press release but did not comment on it. If in fact PSCAA endorsed or remained silent about the changes to the AQI terms, for example, changing “Moderate” to “Poor” or “Unhealthy,” it would essentially constitute a breach of the federal directive about maintaining the reliability of the Air Quality Index.
The Lung Association’s claim that people in Washington are being routinely exposed to unhealthy air once a week or more is based in an unscientific reading of the data, if not a deliberately false interpretation. The proposed new regulations to reduce ozone levels are designed to be politically appealing, but in engineering terms they are only behavior modification initiatives which cannot be justified by science.
The Lung Association’s claim that Washington’s air is unhealthy contradicts the science indicating that Washington’s air quality poses no threat to health. The WALA is telling the public that during 111 days in King County when the Air Quality Index fell between 50 and 100 the air was “unhealthy,” when according to federal standards the air quality was actually “Moderate,” or satisfactory.
The public deserves a more honest and reasoned appraisal of our air quality than that provided by the Washington Chapter of the American Lung Association. It does not serve the American Lung Association’s credibility to put its name on a report and press release that are so poorly constructed.
[1] “State of the Air in Washington 2006 Report,” WALA, May 17, 2006.
[2] Ott, Wayne R., “Environmental Indices, Theory and Practice,” Ann Arbor Science Publications, Ann Arbor, MI, 1979.
3 “Guidance for Reporting of Daily Air Quality-Air Quality Index (AQI),” EPA-454/R-99-010, OAQPS, RTP, NC, July 1999.
[4] Testimony of Kay H. Jones Ph.D. on SB 5397, Senate Water, Energy and Environmental Committee, Olympia, February 9, 2005.
[5] “State of the Air: 2006,” American Lung Association, undated.
[6] 40 CFR Part 50 Vol. 62 No 138, July 18, 1997.
[7] “The Burden of Asthma in Washington State,” WDOH, June 2005.
[8] Ibid, p. 89.
[9] Interview with Paul Payton, August 2006.
[10] Interview with Stu Clark, August 2006.
[11] Interview with Alice Collingwood, September 2006.