Virginia's clean air act is a good policy I just wish it was enforced ,as I have reported the quarry several times and it is still running in the same manner .and the dust is still very bad .especially from 5:00 pm until 7:00 am and the local deq office is absolutely unwilling or unable to enforce the law.The laws are in place enforce them . Thank you

VTCA Aggregate Producer Members account for 91% of all metal/nonmetal mineral production in the Commonwealth. Amendments to the General Permit for Nonmetallic Mineral Mining [9 VAC 5-510] (NMPGP) will have a widespread impact on Virginia’s aggregate producers.

 VTCA Aggregate Producers support the limits the way that they are currently written, the EPA recently declined an opportunity to change them, and air quality continues to improve under the current regulations.

 If the State Air Pollution Control Board elects to open this permit up for review or amendment VTCA would like to be part of an advisory group that is formed.

DEQ Ambient Air Quality Standards Comment
Virginia Clinicians for Climate Action

Virginia Clinicians for Climate Action (VCCA) encourages the Virginia Department of Environmental Quality to update the Ambient Air Quality Standards (9VAC5-30) to protect the future health of Virginia residents. VCCA recommends that Virginia adopt primary and secondary annual standards of 11 µg/m3 and 24-hour standards of 25 µg/m3 for particulate matter (PM2.5) as well as primary and secondary 8-hour standards of 0.060 ppm for ozone (O3), in accordance with American Thoracic Society (ATS) and American Lung Association (ALA) recommendations.1 

The National Academy of Sciences estimated that anthropogenic PM2.5 was responsible for over 100,000 premature deaths a year in the United States, at a cost of $886 billion.2 The World Health Organization attributes 4.2 million deaths per year worldwide to ambient air pollution.3 PM2.5 can enter the lungs and bloodstream, exacerbating heart and lung conditions.4 Globally, air pollution is estimated to cause about 29% of lung cancer deaths, 43% of COPD deaths, 25% of coronary heart disease deaths, and 24% of stroke deaths.3 A recent study published in June 2020 by the Harvard T.H. Chan School of Public Health found that PM2.5 concentrations even lower than our current U.S. air quality standards increases the risk of premature mortality, demonstrating the necessity of updating our standards.5,6 According to 9VAC5-30-67, our current primary ambient air quality standards for PM2.5 are 12µg/m3 (annual) and 35 µg/m3 (24-hour) and our current secondary standards are 15 µg/m3 (annual) and 35 µg/m3 (24-hour).7 In addition to the ATS and ALA, many medical and public health organizations, such as the American Medical Association, American Academy of Pediatrics, American Heart Association, and American Public Health Association, support the more robust standards of 11 µg/m3 (annual) and 25 µg/m3 (24-hour). 

Ozone (O3), or smog, is another harmful air pollutant.9,10 O3 is an oxidant that can react chemically with organic tissue in the body, damaging the lungs and airways.9,10 Exposure to O3 above 0.060 ppm has been associated with higher risk of asthma attacks, emergency department visits, and hospitalizations among children, and can permanently damage children’s developing lungs.11,12 O3 exposures in the range of 0.060-0.075 ppm have also been linked to lower birth weight in newborns, and worsening of respiratory diseases such as COPD and pneumonia in the general population.9,13 A study conducted by Johns Hopkins Bloomberg School of Public Health estimates that 5,210 to 7,990 premature deaths could be avoided annually by attaining a daily maximum 8-hour average ozone standard of 0.060 ppm.15 9VAC5-30-57 states that VA’s current primary and secondary 8-hour ozone standards are 0.070 ppm.8 Adopting stricter standards of 0.060 ppm could save lives and improve the health of all Virginians.

The Virginia Department of Environmental Quality has a responsibility to update the Ambient Air Quality Standards to promote equity in the Commonwealth, as the consequences of air pollution disproportionately harm vulnerable populations, such as children, older adults, people with preexisting respiratory or heart conditions, essential outdoor workers, and low-income communities. Climate change will continue to exacerbate air pollution, putting our communities at risk; thus, it is urgent and important that we establish more protective regulations. 

Virginia has an opportunity to act as a leader in our country by reforming our standards and encouraging other states to follow. VCCA believes our proposed updates to VA’s standards are necessary to protect public health in the Commonwealth. 

Works Cited

1. Thousands of Lives Would Be Saved If Counties Met ATS Clean Air Standards. 2018. https://www.thoracic.org/about/newsroom/press-releases/journal/2018/thousands-of-lives-would-be-saved-if-counties-met-ats-clean-air-standards.php. Accessed July 30, 2020.

2. Goodkind AL, Tessum CW, Coggins JS, Hill JD, Marshall JD. Fine-scale damage estimates of particulate matter air pollution reveal opportunities for location-specific mitigation of emissions. Proceedings of the National Academy of Sciences. 2019;116(18):8775-8780. doi:10.1073/pnas.1816102116

3. Ambient air pollution. World Health Organization. https://www.who.int/gho/phe/outdoor_air_pollution/en/#:~:text=Particulate%20matter%20pollution%20is%20an,countries%20disproportionately%20experience%20this%20burden.&text=In%202016%2C%20indoor%20and%20outdoor,one%20in%20nine%20deaths%20globally. Published August 28, 2018. Accessed July 29, 2020.

4. How Does PM Affect Human Health? | Air Quality Planning Unit | Ground-level Ozone | New England. EPA. https://www3.epa.gov/region1/airquality/pm-human-health.html#:~:text=Fine particles (PM2.5) pose,eyes, nose, and throat. Published October 10, 2019. Accessed July 29, 2020.

5. Wu X, Braun D, Schwartz J, Kioumourtzoglou MA, Dominici F. Evaluating the impact of long-term exposure to fine particulate matter on mortality among the elderly. Science Advances. 2020;6(29). doi:10.1126/sciadv.aba5692

6. Harvard T.H. Chan School of Public Health. More evidence of causal link between air pollution and early death. ScienceDaily. www.sciencedaily.com/releases/2020/06/200626141413.htm Published June 26, 2020. Accessed July 29, 2020. 

7. Agency 5. State Air Pollution Control Board. Virginia Law. https://law.lis.virginia.gov/admincode/title9/agency5/. Accessed July 29, 2020.

8. Health Organizations Comment National Ambient Air Quality Standards. March 17, 2015. https://www.aafa.org/media/1656/health-organizations-comment-national-ambient-air-quality-standards-march-17-2015.pdf. Accessed July 30, 2020.

9. Ozone. American Lung Association. https://www.lung.org/clean-air/outdoors/what-makes-air-unhealthy/ozone. Accessed July 29, 2020.

10. Ozone Generators that are Sold as Air Cleaners. EPA. https://www.epa.gov/indoor-air-quality-iaq/ozone-generators-are-sold-air-cleaners#:~:text=When inhaled, ozone can damage,body to fight respiratory infections. Published December 23, 2019. Accessed July 29, 2020.

11. Strickland MJ, Klein M, Flanders WD, et al. Modification of the effect of ambient air pollution on pediatric asthma emergency visits: susceptible subpopulations. Epidemiology. 2014;25(6):843-850. doi:10.1097/EDE.0000000000000170

12. Strickland MJ, Darrow LA, Klein M, et al. Short-term associations between ambient air pollutants and pediatric asthma emergency department visits. Am J Respir Crit Care Med. 2010;182(3):307-316. doi:10.1164/rccm.200908-1201OC

13. Rice MB, Guidotti TL, Cromar KR; ATS Environmental Health Policy Committee. Scientific evidence supports stronger limits on ozone. Am J Respir Crit Care Med. 2015;191(5):501-503. doi:10.1164/rccm.201411-1976ED

14. Vicedo-Cabrera Ana M, Sera Francesco, Liu Cong, Armstrong Ben, Milojevic Ai, Guo Yuming et al. Short term association between ozone and mortality: global two stage time series study in 406 locations in 20 countries BMJ 2020; 368 :m108

15. Berman JD, Fann N, Hollingsworth JW, et al. Health benefits from large-scale ozone reduction in the United States. Environ Health Perspect. 2012;120(10):1404-1410. doi:10.1289/ehp.1104851