Review of the Air Quality Criteria Document for Particulate Matter

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ecosystems are. There are a host of papers that address this issue and at least some should becited.8. In looking at PM per se, it is interesting to note that the chapter fails to mention to onetype of ecosystem for which deposition of PM is likely to be very important – urban andsuburban forests (largely in parks). There is a great deal of literature on these systems. In fact, itmight be best to replace the current discussion of deposition to the IFS sites and replace thatmaterial with the urban suburban forest analysis.Specific Issues1. There is little reason to consider in much depth the consequences of PM on vegetationand ecosystems. In fact, most of the material in Chapter 4 characterizing the effects onvegetation and ecosystems could be reduced by 50% or more. Much of the informationis appropriate to other documents (e.g., deposition of sulfur and nitrogen) but is onlytangentially (at best) related to PM and the standard setting process.2. The discussion of wet and dry deposition on ecosystem processes is largely a function ofresearch conducted in the east where precipitation is the major mode of deposition. Inthe western US, dry processes are far more important as a vector for deposition. It isrecommended that the research in the West be given some parity in the discussionassuming that the discussion of deposition remains. In light of No. 1 (above), this issuemay be moot.3. The discussion of direct effects of PM on vegetation (4.2.1) is appropriate to thisdocument but has no relevance to the standard setting process since effects are seen atlevels well above ambient rates of deposition. This section could be reduced in length by75% or more.4. The discussion of the consequences of nitrogen input to ecosystems (4.2.1.2) is hard tojustify in the depth presented. If it is important to include, it is recommended that thedissimilarity between the eastern and western US be highlighted.5. The same concern for sulfur is appropriate. The detail is only tangentially related to theissue of PM and the deposition is unlikely to be of consequence.6. On page 4-22, reference is made to the fact that ecosystem level responses to stress beginat the population level. I am not quite sure that is accurate.7. On page 4-24, the following statement is offered, “In contrast, anthropogenic stressesusually are severe, debilitating stresses”. I find it difficult to agree with this statement.In the same paragraph, the four categories of stresses seem to be awkward. Where wouldnitrogen deposition or CO2 increase fall in this scheme?8. On page 4-25, reference is made to the concept of secondary succession and chronicstresses. The concept of secondary succession as presented is not accurate and the syntaxof those sentences is not accurate. The entire process of secondary succession is a datedconcept in ecology and its relevance here is marginal.9. On page 4-26, the comment is made that it is difficult to determine responses ofecosystems to stress. As a blanket statement, this is simply not accurate. Maybe themagnitude of the response is not known with certainty but the direction and many of thechanges are known with certainty.10. The section on particulate matter, atmospheric turbidity and effects on vegetationprocesses (page 4-34) is weak from a cause-effect perspective. This could be deleted.11. Is the section on solar UV radiation (p4-39) needed in this document? The argument istenuous.12. The conclusion paragraph (4-84) is too bold a statement regarding the effects. The leadshould be less alarmist and simply state that there is little reason to address secondaryeffects of PM on vegetation and ecosystem processes. It is important to be accurate,particularly in the summary sections.13. On pages 4-113, the work of Chestnut and Davis is presented on the willingness to payfor visibility. It is important that the results and conclusions of the authors be reportedrather than simply that they conducted a study.14. If one is discussing nitrogen and sulfur in the PM document, then all of the otherA - 79
atmospheric stressors associated with PM should be included as well. These wouldinclude base cations, hydrogen ions, heavy metals, pesticide residues, oxidants, etc. Analternative would be to simply list these as part of the deposition process but not relevantto the CD.15. The processes discussed governing how PM affects vegetation are only a fragment of thephysics, chemistry and biology of PM. The concepts to be included should be effects ofvelocity and particle size on deposition, solubilization, evapoconcentration, rainfallevents, wash off, re-suspension, transcuticular migration, etc.16. Deposition to surface waters is entirely missing in the CD and yet this is a major issue forunderstanding estuaries and lakes. There is a host of data for this topic for majorresources and the largest set of data is for the Great Lakes. Its omission in light of whatis included (e.g., nitrogen and sulfur at IFS sites) is a problemRonald H. White, M.S.T.Chapter 6: Epidemiology of Human Health Effects from Ambient Particulate Matter -General CommentsOverall, this chapter presents a comprehensive review of the extensive body ofepidemiological studies published since completion of the 1996 particulate matter criteriadocument. The chapter properly interprets the studies discussed and appropriately emphasizesthe strengths and weaknesses of the current scientific evidence of the health effects of particulatematter.One key issue that requires further attention is the need for a consistent approach withexplicit criteria throughout the chapter for the selection of the analyses from the studies includedfor summarization in the tables. For example, there are several criteria described (pg. 184; lines8 –17) as providing the basis for selection of the analyses summarized in Table 6-19 and 6-20.However other summary tables do not explicitly provide the criteria for the selection of analysessummarized in the tables. Providing these criteria make the approaches used in selecting theanalyses included for summarization in these tables and avoid concerns regarding author bias inthe selection of analyses included for summarization.The discussion of the infant mortality/related morbidity studies that have been publishedsince 1996 should be expanded. These data are important new findings that significantlyaugment the more limited data available in the 1996 CD. A table summarizing these studiesshould also be included in the chapter.The discussion of lung cancer associated with PM exposure in the long-term prospectivestudies should be expanded and receive additional attention in the text. Given the finding of astatistically significant association of PM and lung cancer in the recent expanded ACS studyanalysis by Pope, which I would presume will be included in the next revision of the CD, thishealth endpoint deserves substantial further elaboration and emphasis. In addition, the entirediesel particulate health effects literature regarding lung cancer is not referred to in thisdiscussion. Recognizing that the EPA Diesel Particulate Health Assessment document reviewsthis literature in detail, the relevant science should be summarized in this chapter’s discussion ofthe lung cancer issue and the reader referred to the Diesel Health Assessment document for amore complete discussion of this scientific literature.Specific CommentsPg. 6-226: This discussion regarding alternative methodological approaches to addressingconfounding omits reference to the selection of study areas where potentially confounding airpollutant levels are relatively low (e.g. Vedal’s 1998 study of asthmatic and nonasthmaticchildren in Port Albeni, B.C.).Appendix 6A and 6B: There is no explanation in Chapter 6 as to the rationale for the inclusion ofA - 80
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known, the potential causes deserve
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SCIENCE ADVISORY BOARD STAFFMr. A.
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Review of the Air Quality Criteria Document for Particulate Matter

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