4/14/2006 Reminder: EPA proposal leaves Owens Valley in the dust
Comments on the Environmental Protection Agency’s proposed rules and amendments for National Ambient Air Quality Standards for Particulate Matter are due April 17.

The EPA’s Clean Air Scientific Advisory Committee recommended tightening particulate matter pollution limits to protect public health and to comply with the Clean Air Act, but the EPA has proposed limits at a level that even its own committee sees as inadequate. Proposed rules loosen or abolish monitoring and control standards for rural areas such as the east side of the Sierra Nevada--or for that matter, most of the western United States--which means federal air quality standards wouldn’t apply any more even for those who live or travel in rural areas with air quality poor enough to harm their health.

The new proposed rules and amendments would revoke current national 24-hour particulate matter (PM10) air pollution monitoring standards and restrict proposed monitoring to “urbanized” areas with “a population of at least 100,000 persons” |1|. The rules would ignore the recommendations of the EPA’s own advisory committee |2|, exclude control of “agricultural sources and mining sources,” and specifically exclude “any ambient mix of PM10-2.5 that is dominated by rural windblown dust and soils and PM generated by agricultural and mining sources” from monitoring |3|.

In other words, areas like the Owens (dry) Lake, which has been called “possibly the greatest or most intense human-disturbed dust source on earth” |4| would not qualify for monitoring under the EPA’s new rules, nor would Mono Lake or other rural areas with similar problems throughout the United States.

PM-10 pollution has been linked to chronic obstructive pulmonary disease, cardiovascular problems, asthma and other respiratory problems (particularly among children, athletes, and the elderly) and to increased risk of premature death among those 50 years old or older. |5|.

Airborne pollution flowing from the Owens lake bed carries a toxic cocktail of arsenic, cadmium, nickel, and sulfates. Windblown dust storms from the lake have engulfed not only the small communities of Lone Pine, Independence, Keeler, and Olancha, Calfornia, but have also rolled as far north as Bishop and as far south as the China Lake Naval Weapons Center and Ridgecrest. Although Los Angeles has made significant strides in reducing pollution from the lake bed--which dried after Los Angeles diverted the lower Owens River to its aqueduct--more work remains. Unfortunately, Los Angeles has recently shown reluctance to expand that work. |6|

Due to windblown dust from the lake bed, the Great Basin Unified Air Pollution Control District has already issued more than a dozen Stage 1 and Stage 2 air pollution health advisories for communities in the Owens Valley since this January. |7| A Stage 1 health advisory recommends that children, the elderly, and people with heart and lung problems refrain from strenuous outdoor activities in the area; a Stage 2 advisory simply recommends that everyone refrain from strenuous outdoor activities in the area. |8|

The Owens Valley is bordered by three National Parks and several Wilderness Areas. The vast majority of Inyo County is public land. Fishing, ranching, hiking, bicycling, running, skiing, Forest Service and Bureau of Land Management activities, and other “strenuous outdoor” tourism and employment constitute significant contributions to Inyo County’s economy and to neighboring Mono County's economy. Consequently, toxic dust storms affect not only residents’ health but also their livelihoods.

“Rural windblown dust” also causes health problems across the U.S. in communities that would not qualify for monitoring under the EPA’s proposed rules. Aside from health problems caused by PM-10 pollution from crustal sources in rural areas |9|, including arsenic- and cadmium-laced windblown dust throughout Arizona |10|, windblown dust from rural areas, mines, and agricultural sources carries:

• coccidioidomycosis, or “Valley Fever” (which bears a heavy cost in both human terms and economic terms) |11|
• other human pathogens, aerosolized manure, and pesticide-laden dust |12|
• silica (which can cause severe scarring of the lungs, cancer, and other disorders) |13|
• heavy metals--including lead, zinc, mercury, and uranium--and additional silica from mining operations |14|
• PM10 from both wood fires and wildfires |15|
• automobile pollution from mobile sources, for example, exhaust from the cars of millions of urban and rural residents who drive through rural areas en route to parks and recreation areas, including the Grand Canyon, Yosemite, Yellowstone, and Great Smoky Mountains National Park |16|.

Current PM 10 monitoring rules provide equal protection under the law. Under new rules, rural areas and residents already subjected to unhealthy and out-of-compliance air quality would not even qualify for monitoring because of proposed rules’ emphasis on population density and on who generates the pollution rather than on the level of pollution. Constitutional considerations aside (the 14th Amendment to the U.S. Constitution says that no state shall “deny to any person within its jurisdiction the equal protection of the laws”) |17|, the rules would overlook at least one third of the U.S. population and at least three quarters (75%) of its land mass, if not more |18|.

Whether or not the EPA chooses to protect rural residents as well as urban residents, windblown dust makes no distinctions. Human pathogens such as coccidioidomycosis have been carried as PM-10 pollution not only to neighboring urban areas from rural areas, but across continents and oceans as well |19|.


Write, fax, or e-mail a letter to the EPA (information below). Or if you prefer, sign on to someone else’s letter (links below).

If you’re writing your own letter

1. Be sure to identify your comments with the identification information “Re: Docket ID No. EPA-HQ-OAR-2001-0017 and Docket ID No. EPA–HQ– OAR–2004–0018”

2. Send your comments to one of the following addresses (deadline April 17):
a. Over the Web: go to and follow online instructions
b. E-mail:
c. Fax: 202-566-1749
d. Mail: Docket ID No. EPA-HQ-OAR-2001-0017 and EPA–HQ– OAR–2004–0018, Environmental Protection Agency, Mailcode: 6102T, 1200 Pennsylvania Avenue NW, Washington, DC 20460 (The EPA requests two copies if you choose to mail your comments).

3. The EPA’s proposed rules, amendments, and other comments are posted on the World Wide Web at We suggest including one or more of the following points in your letter in your own words:

--Remind the EPA that people in rural areas--like people in urban areas--have lungs, enjoy being able to breathe, and are entitled to equal protection under the law. The proposed rules would subject rural residents to worse air pollution standards and less protection than urban residents would receive.

--Ask that the EPA establish a national monitoring program for PM 10-2.5 (particulate matter than ranges from 10 to 2.5 micrometers in size) across the nation regardless of population density or that, at the very least, the EPA maintains current PM-10 monitoring standards in rural areas. Trying to protect the health of the nation while ignoring its rural communities is like trying to drive children to school with the windshield covered: it’s possible to get there by looking through the rear view mirror and out the side windows, but it’s much safer, easier, and healthier to look ahead than to drive backwards or drive blindly.

--Ask that the EPA follow its own committee’s recommendations to continue to study the health effects of such pollution rather than giving certain industries a blanket exemption. Rural dust can be more toxic than urban dust or less toxic than urban dust--it’s not the rural or agricultural nature of the dust that determines its toxicity, it’s the content and the size.

--Ask the EPA to revise its proposed PM 2.5 daily and annual standards and PM 10-2.5 daily standard downward to the lower end of the ranges recommended by the committee it asked to study the problem, the Clean Air Science Advisory Committee, and to apply those standards throughout the nation.

--Ask the EPA not to leave the Owens Valley in the dust.

If you’d rather not write your own letter, or if you need a bit more help:

The Mono Lake Committee has posted information and a sample letter at A wealth of local information is available as well in the Great Basin Unified Air Pollution Control District’s comments, which are posted at The American Lung Association and the League of Conservation Voters have posted more general prepackaged e-mail sign-on letters at and at respectively.


1. p. 2736. Environmental Protection Agency. December 2005. 40 CFR Parts 53 and 58
[EPA-HQ-OAR-2004-0018; FRL-8015-9] Revisions to Ambient Air Monitoring Regulations. Proposed Rule; amendments. Downloaded from April 11, 2006.

See also Environmental Protection Agency. December 2005. 40 CFR Part 50 [EPA–HQ– OAR–2004–0018] National Ambient Air Quality Standards for Particulate Matter; Proposed Rule. Downloaded from April 11, 2006.

2. Clean Air Scientific Advisory Committee. March 2006. Letter: Recommendations Concerning the Proposed National Ambient Air Quality Standards for Particulate Matter. EPA-CASAC-LTR-06-002. Downloaded from April 10, 2006.

3. p. 2718. Environmental Protection Agency. December 2005. 40 CFR Parts 53 and 58
[EPA-HQ-OAR-2004-0018; FRL-8015-9] Revisions to Ambient Air Monitoring Regulations. Proposed rule; amendments. Downloaded from April 11, 2006.

4. Hinkley, T.K. U.S. Geological Survey: Mineral Dusts in the Southwestern U.S. Downloaded from the World Wide Web April 3, 2006.

5. Many studies have appeared on the effects of PM-10 pollution. For samples of the discussion, see

a. Brunekreef B. and Forsberg B. 2005. Epidemiological evidence of effects of coarse airborne particles on health. Eur Respir J. 26(2):309-18.

b. Ostro, B.D., Hurley S., and Lipsett, M.J. 1999. Air pollution and daily mortality in the Coachella Valley, California: a study of PM10 dominated by coarse particles. Environ Res. 81(3): 231-8.

c. Carlisle, A.J., and Sharp, N. C. 2001. Exercise and outdoor ambient air pollution. Br J Sports Med 35: 214-22.

6. For information on windblown dust from the Owens Lake, see
a. Reheis, M.C. U.S. Geological Survey. 1997. Owens (Dry) Lake, California: A Human-Induced Dust Problem. Downloaded from the World Wide Web April 6, 2006.
b. Great Basin Unified Air Pollution Control District. Owens Lake. Downloaded from the World Wide Web April 10, 2006.

For recent articles on Los Angeles’ lawsuit appealing dry lake dust reduction measures, see
c. Klusmire, J. April 2006. Dry Lake legal battle takes flight. The Inyo Register. 136 (41): A1.
7. Archived health advisories from the Great Basin Unified Air Pollution Control District (GBUAPCD) can be found on the World Wide Web at (downloaded April 10, 2006).

8. GBUAPCD explains its health advisories on the World Wide Web at (downloaded April 10, 2006).

9. See Ostro, B.D., Hurley S., and Lipsett, M.J. 1999. Air pollution and daily mortality in the Coachella Valley, California: a study of PM10 dominated by coarse particles. Environ Res. 81(3): 231-8.

10. Wrona, N.C. Director, Arizona Department of Environmental Quality. 2005. Subject: OAQPS Staff Paper Publication No. EPA-452/D-05-005. Letter to Mr. Fred Butterfield, EPA Science Advisory Board, dated August 4, 2005.

11. Coccididioidomycosis or “Valley Fever” is a well-known hitchhiker on rural, windblown dust in Arizona, California, and New Mexico. Because the spores are frequently a component of PM-10 pollution, they can be tracked using pollution monitoring mechanisms already in place. The following articles describe the spore’s health effects, virulence, costs, endemic rural presence, and ability to travel in windblown dust:
a. Comrie, A.C. 2005. Climate Factors Influencing Coccidioidomycosis Seasonality and Outbreaks. Environ Health Perspect. 113(6): 688-92.
b. Pappagianis, D. and Einstein, H. 1978. Tempest from Tehachapi Takes Toll or Coccidioides Conveyed Aloft and Afar. West J Med 129: 527-530.
c. Pappagianis, D. 1988. Epidemiology of Coccidioidomycosis. Curr Top Med Mycol. 2: 199-238.
d. Williams, P.L., Sable, D.L., Mendez, P. and Smyth, L.T. 1979. Symptomatic coccidioidomycosis following a severe natural dust storm. An outbreak at the Naval Air Station, Lemoore, Calif. Chest 76(5): 577-70.
e. Durry E., Pappagianis D., Werner S.B., Hurtwagner L., Sun R.K., Maurer M., McNeil MM, and Pinner R.W. 1997. Coccidioidomycosis in Tulare County, California, 1991: reemergence of an endemic disease. J Med Vet Mycol 35(5):321-6.
f. Centers for Disease Control and Prevention. 2001. Coccidioidomycosis among persons attending the world championship of model airplane flying--Kern County, California, October 2001. (The CDC also describes Coccidoidomycosis and its dust-loving nature on its web site at ).

12. See Popendorf, W., Donham K.J., Easton D.N., and Silk, J. 1985. A synopsis of agricultural respiratory hazards. Am Ind Hyg Assoc. J. 46(3): 154-161.

For a discussion of airborne manure issues, see Pillai SD and Ricke SC. 2002. Bioaerosols from municipal and animal wastes: background and contemporary issues. Can J Microbiol. 48(8):681-96.

13. For a description of abundant silica in wind-blown dust, see Gillette, D. 1997. Soil derived dust as a source of silica: aerosol properties, emissions, depositions, and transport. J Expo Anal Environ Epidemiol 7(3):303-11.

For a discussion of the health effects of breathing quartz silica, see Canada’s National Occupational Health & Safety Resource site on the Web at

14. Mine tailings often contain materials that can be transported by wind or that are emitted into the atmosphere. These materials include mercury (for example, see a), cadmium, lead, and zinc (for examples, see b, c, and d). Uranium can also be carried in windblown tailings (see d).

a. Nacht, D.M., Gustin, M.S., Engle, M.A., Zehner, R.E., Giglini, A.D. 2004. Atmospheric mercury emissions and speciation at the sulphur bank mercury mine superfund site, Northern California. Eviron Sci Technol 38(7): 1977-83.

b. Pierzynski, G.M., Lambert, M., Hetrick, B.A.D., Sweeney, D.W., and Erickson, L.E. 2002. Phytostabilization of Metal Mine Tailings Using Tall Fescue. Pract. Periodical of Haz., Toxic, and Radioactive Waste Mgmt 6(4): 212-217.

c. Hasselbach, L., Ver Hoef J.M., Ford J., Neitlich P., Crecelius E., Berryman S., Wolk, B. and Bohle T. 2005. Spatial patterns of cadmium and lead deposition on and adjacent to National Park Service lands in the vicinity of Red Dog Mine, Alaska. Sci Total Environ, 348(1-3):211-30.

d. Neuberger J.S. and Hollowell J.G. 1982. Lung cancer excess in an abandoned lead-zinc mining and smelting area. Sci Total Environ 25(3):287-94.

e. Thomas, P.A. 2000. Radionuclides in the terrestrial ecosystem near a Canadian uranium mill--Part III: Atmospheric deposition rates (pilot test). Health Phys 78(6): 633-40.

15. The town of Mammoth Lakes in Mono County California is a good example of a “rural” community that suffers from excessive PM10 pollution in winter “due to a combination of wood smoke and cinders put on icy roads for traction in winter” (Great Basin Unified Air Pollution Control District web site, “History and Purpose,”, downloaded April 10, 2006.)

16. Tailpipe emissions have been or are becoming a significant concern at many of the nation’s National Parks. Yosemite, Sequoia, and Kings Canyon National Parks--accessible from Mono and Inyo Counties--suffered for many years from air pollution that sometimes exceeded that of cities; Yosemite still exceeds the EPA’s limits for ozone pollution. Great Smoky Mountains National Park suffers from pollution that rivals Los Angeles’ (and tops the National Parks Conservation Association’s list of the nation’s five most polluted national parks on the Web at Winter snowmobile emissions are a significant concern at Yellowstone (see Mockler, K. 1999. Dirty air in the deep of winter. High Country News 31(22): Bulletin Board), and windblown urban pollution is still a concern for the Grand Canyon (see and Rural gateway communities adjacent to National Parks, however, escape scrutiny.

17. See Amendment 14 (and Amendments 11-27) to the Constitution at . (The Constitution itself can be found at ).

18. The United States Department of Agriculture estimates, based on U.S. Census figures, that approximately 68 percent of Americans lived in urbanized areas in 2000 (see “Measuring Rurality: What Is Rural?” on the USDA’s website at, downloaded April 11, 2006) and that at least 75 percent of the nation’s land mass would be classified as strictly rural (see “Measuring Rurality: New Definitions in 2003” at, downloaded April 11,2006). Thus, by U.S. Census standards, at least 90 million Americans (32 percent of the year 2000 population as defined by the U.S. Census--see more at live in non-urbanized areas that would likely not qualify for PM10-2.5 monitoring. EPA definitions of “urbanized,” however, would be even stricter, focusing on the most densely populated portions of urbanized areas (see p. 2737 of Environmental Protection Agency. December 2005. 40 CFR Parts 53 and 58
[EPA-HQ-OAR-2004-0018; FRL-8015-9] Revisions to Ambient Air Monitoring Regulations. Proposed rule; amendments. Downloaded from April 11, 2006).

19. For a surprising list of human, other animal, and plant pathogens that travel across oceans and continents on wind-blown dust from rural and urban areas, see Shinn, E.A., Griffin, D.W., and Seba, D.B. 2003. Atmospheric transport of mold spores in clouds of desert dust. Arch Environ Health 58(8) 498-504.

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