Search Results
Search this site
1136 results found with an empty search
- Marcellus Shale on the Radio
GASP was recently honored to be part of the first Essential Pittsburgh radio program, a new show on Essential Public Radio 90.5 FM. The program will feature local news, local issues, and local people, and we shared the hour with a few other knowledgeable guests. We tried to cram Marcellus Shale into that one hour, but as that’s impossible, we hope to be back on the program as it pursues this topic. Click the link here and scroll down to Feb. 10 to listen.
- Your Environmental Road Trip Stops in Larimer
Guest Blog by University of Pittsburgh Student Jeff Gordon The Kingsley Association, a community-based organization in East Liberty that was founded in 1893, is hard at work on a green initiative in East Liberty called Imagine Larimer. Imagine Larimer hopes to engage and transform their community by increasing housing options, expanding healthy food options, and creating local, family-sustaining jobs. Green collar jobs are a big part of these plans. The Association is running its second annual Energy Auditors Training, which takes 15 community residents and teaches them how to examine homes for energy loss and make recommendations to increase energy efficiency. The program will last six weeks. Last year’s program started January 31 and signups are happening now. Kingsley’s goal is to revive the community, by teaching residents to be more sustainable, who will then teach their neighbors and friends. On its 29th community gathering, Kingsley Association brought in Mark Dixon to boost awareness of sustainable technologies and inspire the community to continue its green transformation. Dixon, who has worked as a programmer in the Silicon Valley, quit his job and joined two friends to travel across all 50 states in search of answers about the environment. Driven by their own need to learn about the environment, this adventure became “Your Environmental Road Trip” or "YERT," a funny, informative film about environmental actions that people all across the country are taking. Throughout the trip, they challenged themselves on multiple occasions to reduce their environmental impact, and attempted some quirky challenges, like eating only corn for three days. The documentary looks at problems around the world like peak oil, the separation of people from their food, burning coal under Centralia, Pennsylvania, and some sustainable innovations. Imagine if all the known green technologies were implemented today. What if everyone lived in Earthships, which use a combination of recycled goods and passive solar design? Instead of driving on petroleum-based asphalt, we could be driving on solar highways, which have solar panels and LED road signs under a glass road. Instead of seeing acres of corn being grown for animal feed or to saturate our food with sugar, travelers could see wind farms and be amazed at the beauty of renewable energy. What if your farmer was a friend who you see weekly, not some unknown cog in the food industry machinery? People all across the world are doing big and small things to reduce their impact on the planet, and hearing their voices is entertaining and inspiring. The goal of “YERT” and the green initiatives of The Kingsley Association is to inform people that technologies for a sustainable world are available. The methods for change exist–we just need people behind the effort. If we get enough like-minded people together, we can change our communities. And that’s how we change the world.
- The Economic Impact of Environmental Protection: The Myth of the Job Killing Environmental Regulatio
President Obama on June 14 visited the Carnegie Mellon National Robotics Engineering Center in Pittsburgh’s Lawrenceville neighborhood. Obama chose the Robotics Center as the backdrop for a speech promoting the Advanced Manufacturing Partnership (AMP), a collaboration between the Obama administration, engineering universities, like Carnegie Mellon University, and industry, such as Allegheny Technologies. The goal of AMP, as the President put it, is to revitalize the U.S. manufacturing sector. Then, on Sept. 2, Obama ordered EPA Administrator Lisa Jackson to halt her agency’s efforts to revise the 2008 health standard for ground-level ozone. The 2008 standard, created by the Bush-led EPA, has been widely criticized as inadequate to protect the public health and contrary to the requirements of the Clean Air Act. Administrator Jackson has described the 2008 standard as “not legally defensible.” Obama’s stated reason for halting the ozone reconsideration was “the importance of reducing regulatory burdens and regulatory uncertainty.” How do we reconcile these statements? In June, Obama suggested the reinvigorated domestic manufacturing sector resulting from his AMP initiative would ensure a bright future for America. Then in September the President stated that an ozone standard that is protective of public health and consistent with the requirements of the Clean Air Act would be too burdensome for industry to bear. Does a strong domestic manufacturing sector depend on our willingness to continue to breathe unhealthy air? The answer is no, but one of the biggest impediments to improving the environment is the pervasive misconception that a healthy environment and a healthy economy are incompatible. You don’t have to look far to find evidence to counter this misconception. Just eight blocks from the CMU Robotics Center is the McConway and Torley (M&T) steel foundry. This foundry has operated since the 1860s, producing steel castings for railcars. A few weeks prior to Obama’s visit, M&T and GASP reached an agreement which will reduce the foundry’s emissions of particulate matter and manganese, a toxic heavy metal, by 25 percent or more. The agreement addresses GASP’s health-related air quality concerns while allowing M&T to carry out a proposed facility expansion. It’s good for the economy and the environment. While the improved air pollution controls will likely create additional costs for M&T, the company still plans to operate and expand its Lawrenceville foundry. Common wisdom states that when confronted with the costs of complying with tougher environmental standards, companies like M&T shut down their U.S. facilities, put Americans out of work, and move operations to places with weaker environmental standards. If Obama had stopped by McConway and Torley after the robotics lab speech, maybe he wouldn’t have been so quick to conclude that environmental regulations like the revised ozone standard are excessively burdensome. Admittedly, M&T’s decision to improve its environmental performance in Lawrenceville rather than pack it up and head to Ciudad Juárez is just one case. But when economists look for evidence that U.S. manufacturers are running for the border to evade U.S. environmental regulations—often called the “pollution haven hypothesis”— they have a hard time finding it. While some studies suggest environmental regulations do have a negative effect on domestic industry, some find no statistically significant effect, and some find an economic benefit. After decades of study, publications on the issue still contain observations like, “despite anecdotal evidence and the predictions of theoretical studies, little empirical verification for the existence of pollution havens has been found.”[Cole & Elliot page 530] If it’s safe to conclude anything from the conflicting research and ongoing debate, it’s that if the pollution haven effect does exist it’s either very small or very well hidden in confounding data. It seems logical that if environmental regulations impose costs on industry, industry would try to evade those costs by doing things like moving their operations to countries with weaker environmental regulations. But then why is this effect so hard to find? First, regulated entities often derive benefits from environmental regulations which offset some of the costs of regulatory compliance. These include benefits to society as a whole that industry also receives; for example, improved air quality might result in an industry experiencing fewer employee sick days and increased productivity. There are also benefits that are more unique to the regulated entities themselves; for instance, when a coal-fired power plant installs a sulfur dioxide (SO2) scrubber, the plant might be able to reduce costs by switching to a cheaper, higher sulfur content coal and still meet its SO2 emission limits. In the case of M&T, the air pollution controls required under the agreement with GASP may provide the foundry with more operational flexibility in the future by allowing the facility to maintain a safe level of emissions while operating at a higher production rate. Another reason it’s not clear that the pollution haven effect exists is that the costs of complying with environmental regulations are just one of many factors relevant to industry location decisions. Other factors include tax rates, prevailing wages, currency exchange rates, levels of corruption or insecurity, workforce education levels, transportation infrastructure, access to natural resources, and proximity to markets. Given this multitude of other considerations, the cost of complying with environmental regulations is often too insignificant to merit consideration, let alone influence the location decision. Consider the decline of the American steel industry. The cost of complying with environmental regulations is sometimes implicated as a cause of the industry’s collapse. A closer examination reveals that environmental regulations had little, if anything, to do with the decline of domestic steel production. First, if the steel collapse were in fact due to a competitive disadvantage created by environmental regulation, we would expect the steel producers who undercut U.S. prices to be operating heavily polluting facilities located in impoverished nations with nonexistent environmental regulations. Instead, the U.S. industry’s biggest rivals in the 1970s and '80s were Japan and countries in Western Europe, [CBO page 13] relatively prosperous nations whose pollution control expenditures per ton of steel produced were similar to, if not greater than, those of the U.S. [CBO page 48]. Second, the timelines of the American steel decline and the rise in U.S. environmental regulations don’t match up. With the exception of a few state and local air pollution control agencies, U.S. environmental regulation did not begin in earnest until the 1970s, the decade which saw the creation of the EPA and the enactment of most of the federal environmental laws we are familiar with today. [EPA created (1970), the Clean Air Act amendments (1970, 1977), the National Environmental Policy Act (1970), the Clean Water Act (1972), the Endangered Species Act (1973), the Safe Drinking Water Act (1974), and the Resource Conservation and Recovery Act (1976). ] Further, it often takes many years after the enactment of a law for it to be implemented and enforced. As of 1977 not a single U.S. steel mill was in full compliance with the Clean Air Act, [Reitze page 12] meaning no mill was burdened with whatever competitive disadvantage those regulations might have created. While U.S. environmental regulation increased in the 1970s, clear evidence of the U.S. industry’s growing inability to compete with foreign rivals is evident as far back as the late 1950s (see tables)—a time when the U.S. industry’s average annual expenditure on pollution abatement projects was shrinking [Kim & Howse Appendix 1, Table 3] U.S. Percentage of World Steel Production [NAS 1985 page 71] U.S. iron & steel industry percentage rate of return on equity (ROE) after taxes relative to all other U.S. manufacturing [NAS 1985 page 113] A more plausible explanation for the American steel industry’s decline is that the industry made a series of strategic missteps, starting back as far as the 1950s, such as the late adoption of the basic oxygen furnace, the inability to take advantage of inexpensive imported ore due to the industry’s resistance to abandoning the vertical integration model, and inaccurate demand growth projections [see e.g. John P. Hoerr, And the Wolf Finally Came, pages 93-100 (University of Pittsburgh Press, 1988)] So why, despite a lack of convincing evidence, is the belief that environmental regulations are bad for the economy so widely held? Especially given that adherents of this belief must also accept the ridiculous notion that environmental policymakers are either oblivious or indifferent to the resulting economic harm, or are actively motivated to destroy the U.S. economy? The primary goal when developing public policy is, of course, to ensure that the policy will accomplish what it is intended to, but this doesn’t mean policymakers are blind to the value of crafting policies in a manner which minimizes costs and maximizes benefits. In fact, industry can be counted on to make policymakers aware of costs or technical challenges a proposed rule might impose on them—just look at the industry comments in the docket for any significant proposed environmental rule. Office of Management and Budget analyses of the costs and benefits of major federal rules show that the benefits of EPA rules typically exceed the costs, often by a great margin [OMB 2011, Appendices A, B, & D]. Back to the revised air quality standard for ozone: While policymakers typically try to minimize costs and maximize benefits, the national ambient air quality standards are a bit of an exception. In 2001 the U.S. Supreme Court held that the Clean Air Act does not permit the EPA to consider costs as a factor in setting these air quality standards. So one might expect the costs of air quality standards like the revised ozone standard would be an exceptional case where the costs do exceed the benefits. However, despite the prohibition on letting cost influence the final ambient air quality standards, EPA did prepare estimates of the costs and benefits of setting the ozone standard at a variety of levels, ranging from the 2008 standard of 75 parts per billion (ppb) down to 55 ppb. The analysis found that if the standard were set as low as 65 ppb the projected economic benefits would still likely exceed the costs. In late September Lisa Jackson told the House Energy and Commerce Committee the final rule would have set the revised standard at 70 ppb. (By the way, if you’re wondering how it could be permissible for EPA to prepare cost benefit analyses of various ozone air quality standards if the agency prohibited from considering costs, the answer is EPA promised they wouldn’t let those cost-benefit analyses affect their ultimate decision. . . ) If revising the ozone standard to 70 ppb would likely produce a net economic benefit, why did it provoke such controversy? Why were politicians, media personalities, and industry representatives insisting it would lead to financial ruin? Even when a policy change would create a net economic benefit, that rising tide may not lift all boats. Much of the opposition to the revised standard originated with captains of industry who feared that in the rising regulatory tide, their boats would be among the unlucky ones to sink. However, keep in mind the profits those industry players would stand to lose are profits they currently enjoy only because they are placing some costs of their operations on the general public in the form of environmental damage, asthma, heart attacks, respiratory illnesses, and shorter lifespans. Without the regulation, the costs industry places on the general public exceed the costs the rule would impose on industry. By failing to revise the ozone standard, the public suffers more than the industry benefits. But let’s pretend for a moment that the industry talking points are right, and environmental regulations have made U.S. industry less competitive and have caused more economic harm than good. Generations of Americans fought for the safer workplaces, better wages, and cleaner environment these “burdensome” regulations provide. These protections are part of America’s history and values. If they also make American businesses less competitive, it’s because we’re competing with countries that don’t share these values. Those who attack regulations on the belief they place U.S. industry at a competitive disadvantage fail to realize that the alternative is to let foreign nations that don’t share our respect for the environment and workers dictate how clean our air, safe our workplaces, and high our wages should be. If a company does suffer a competitive disadvantage as a result of efforts to reduce its environmental impact or improve working conditions, they ought to be rewarded for making that sacrifice, not penalized because the price of their product is now 2 percent higher than a rival product made in a sweatshop or a smoke-belching factory overseas. The solution to any competitive disadvantage U.S. industry might suffer as a result of operating responsibly is to eliminate that competitive disadvantage. We could accomplish this through our personal buying decisions and our trade policies, or we could do this by eliminating the regulations that encourage safe workplaces, fair pay, and environmental protections. Obama said the goal of the AMP plan was to create “a renaissance of American manufacturing.” If we want a renaissance, we pursue this goal with respect for workers and the environment. If we discard these values, the result will look less like a renaissance and more like a return to the abuses and injustice of the gilded age.
- Citizens Air Modeling Workshop
Allegheny County Health Department's Air Program will hold a Citizens Air Modeling Workshop from 1 p.m. to 2:30 p.m. Oct. 28. The workshop will consist of an introduction to air quality modeling including definitions, components, Gaussian plume modeling, and a look at EPA’s recommended models with a focus on description/operation of AERSCREEN–EPA’s screening model. The workshop will be held at the Air Program’s Lawrenceville office at 39th and Penn Avenue in the first-floor conference room. For more information or to RSVP, contact Tony Sadar at ASadar@achd.net.
- Breathe Project Launch
Title: Breathe Project launch Location: Children’s Museum, 10 Children’s Way, Allegheny Square, Pittsburgh, PA 15212 Link out: Click here Description: Join the official launch of the Breathe Project, an initiative to improve the Pittsburgh region’s air quality. You will be joined by a coalition of the region’s leaders in business, organized labor, health care, education, professional sports, philanthropy, environmental nonprofits, and our neighbors who are working together to clean up our air for the health of our families and economy. Be among the first to hear about solutions underway and exciting plans for making our air among the cleanest in the country at this special event. The first 200 participants will also receive a free Breathe Project T-shirt and personal air quality monitor. RSVP to Donna Evans — devans@heinz.org Start Time: 1 p.m. Date: Oct. 27, 2011 End Time: 2 p.m.
- Bipartisan ‘Clean Construction’ Bill Introduced in House
The proposed new legislation, which was introduced on October 6th by Rep. Richard Hanna (R-NY-24th) and Representative Donna Edwards (D-MD-4th), would fund cleaner diesel for federally-funded highway projects in PM2.5 non-attainment and maintenance areas, the areas that most need help in meeting the federal health-based air quality standards. The Associated General Contractors of America (AGC) and the non-profit Clean Air Task Force (CATF) signaled their strong support for the bipartisan legislation that would provide state transportation officials the authority and funding to incorporate the use of clean construction equipment that would help improve air quality. Diesel engines are the workhorse of our economy; diesel powers nearly all of the heavy-duty vehicles and equipment that are required to build and repair our roads, bridges, hospitals and schools. Emissions from older equipment can be reduced by up to 85 percent with the installation of cost-effective technology, and newly manufactured diesel-powered vehicles and equipment are becoming cleaner every day. While new diesel engines will include innovative clean diesel technology that achieves near-zero particulate matter emissions, fleet turnover of equipment without that modern air pollution reduction technology will take many years. A federal bill bolsters the recent clean construction legislation passed by Pittsburgh City Council and voluntary emission reduction policies like the one UPMC enacted this summer.
- Have a Ball, Learn About Air Quality with GASP 2011
Friday, Oct. 21, GASP has the Highmark SportsWorks at the Carnegie Science Center all to ourselves. Come join us from 6 to 9 PM and run, bounce, spin, and climb on nearly 30 hands-on exhibits. SportsWorks has activities suited for all ages. Think baseball looks easy? Have your fastball clocked and see if you can get it in the strike zone. Try climbing to the top of the 25′ climbing wall or strapping into the bungee cords and turn yourself into a yo-yo. Grab some delicious hors d’ oeuvres or a mixed drink and join us in the conference room to hear from athletes from the Pittsburgh Passion, the Steel City Derby Demons, and USRowing, as well as local health professionals, to hear about air quality and how air pollution affects athletic performance. End the night by munching on desserts and claiming the silent auction prizes that you bid on, such as the beautiful silver and turquoise pendant or nature print pictured here. Our annual fall event is a fundraiser, but it is also a great way to reconnect with staff or members and to learn about GASP’s recent work on air quality issues and plans for the future. Tickets are $50/person ($25 for ages 6-12, free for 5 and under). Purchase tickets online, or pay by check or credit card by calling GASP at (412) 325-7382. Parking at the SportsWorks is available for $5.
- Minimizing Diesel Emissions on Campus Workshop
Title: Minimizing Diesel Emissions on Campus workshop Location: Chatham University, Beckwith Hall Description: Facilities Managers, Sustainability Coordinators, those in charge of capital projects, and other interested people can learn more about reducing diesel pollution on your college or workplace campus. Learn more from experts at UPMC, the Allegheny County Health Department, Columbia University, GASP, and Clean Water Action, about: — PA’s diesel idling law and Allegheny County’s off-road idling law — Policies for minimizing diesel emissions from construction equipment to protect air quality — Pittsburgh’s Clean Air Act of 2010 — Potential Funding and more The workshop is FREE Register by emailing gasp@gasp-pgh.org or klawson@cleanwater.org Start Time: 09:00 Date: 2011-09-22 End Time: 12:00
- GASP on the Airwaves
The Summer Interns at Heinz Endowments teamed up with the Saturday Light Brigade recently to create a series of podcasts about environmental and social issues affecting our region. Based on their slide show, they spent a lot of time wearing big, cool headphones and looking at sound waves on laptops. And that’s just fine, as long as they keep producing programs as interesting as they have. Listen to “Clean Air: A Work in Progress” to hear our executive director and others discuss air quality in our area. Click on other segments to learn about some pluses to high gasoline prices, the state of transit in “America’s Most Livable City,” or how the Marcellus industry has affected the social structure of some rural communities. Good work, yinz!
- Physical Activity and Temporal Trends in Air Quality
“It was the best of times, it was the worst of times (to exercise!)” Joe Osborne, Legal Director We all know that getting regular exercise is important to stay healthy, and that breathing polluted air is unhealthy. As our oxygen requirements increase during strenuous exercise, our breathing rate increases to meet this increased oxygen demand. As a result, our exposure to air pollution increases as well. You may be thinking that this is exactly the excuse you’ve been looking for to adopt an entirely sedentary lifestyle. While the problem of increased air pollution exposure during physical activity is real, replacing these health risks with the health risks associated with prolonged physical inactivity isn’t a solution. Instead, individuals should seek out convenient ways to minimize their exposure to air pollution during exercise. That doesn’t mean wear a gas mask, but before you go jogging, you might want to check the current air quality in your area by visiting www.airnow.gov. If air quality is poor, consider exercising indoors or waiting a few hours to see if air quality improves. As I’ll discuss in more detail in a future article, you can also significantly reduce your exposure to traffic-related air pollution by selecting jogging or cycling routes that avoid major roads when possible. Air pollution concentrations tend to follow relatively predictable temporal patterns. Perhaps the simplest way to minimize exposure to air pollution during exercise is to familiarize yourself with these patterns. Once you know when air pollution is most and least likely to be a problem, you can adjust your routine to avoid outdoor during the times when air quality is poor. Many parts of Pennsylvania (along with much of the eastern United States) struggle to meet federal health-based standards for two pollutants: particulate matter and ozone. By looking at air quality monitor data for these pollutants, it’s easy to spot some temporal trends in pollutant concentrations. Below I’ll use hourly average pollution concentrations measured at the air quality monitor site in Pittsburgh’s Lawrenceville neighborhood to point some of these patterns out. While this monitor data is from Pittsburgh, these air pollution trends are not unique to the Steel City. These same air pollution trends and the resulting advice about when to exercise hold true just about everywhere.[1] Ozone The chart below lists the number of times in 2008 the hourly average ozone concentration at the Lawrenceville air quality monitor reached or exceeded .075 parts per million (ppm).[2] Hourly ozone concentrations at or above .075 ppm only occurred between April and September. This is because ozone is formed from the reaction of other pollutants (most notably nitrogen oxides and volatile organic compounds) in the presence of sunlight. Less sun means less ozone—one bright side to those short, gloomy winter days. Rather than focusing only on concentrations of .075 ppm or greater, you can see the same summertime increase by looking at average hourly ozone concentrations by month: Now let’s look at ozone concentrations by hour during the April to September ozone season: As you might expect given the relationship between sunlight and ozone formation, ozone concentrations are highest during and shortly after the sunniest part of the day. So the lessons for ozone are clear. From late fall to early spring, ozone is rarely, if ever a concern. During ozone season, ozone levels are usually at their highest in mid- to late-afternoon. Particulate Matter Like ozone, particulate matter (PM2.5) concentrations also vary by season, though not as drastically as ozone. Particulate matter can be a problem any time during the year, but unhealthy PM2.5 concentrations are most common between June and September. The following charts are based on 2006-2008 PM2.5 data from Pittsburgh’s Lawrenceville air quality monitor. The chart below shows the percentage of hours by month where 1-hour average PM2.5 concentrations were at or above the federal short-term standard.[3] Like ozone, PM2.5 concentrations are most likely to be elevated between late spring and early fall. So what times of day are PM2.5 concentrations most likely to be elevated? The following chart depicts average hourly PM2.5 concentrations from June to September. Early-morning (~6-8 am) and late-evening (~8-9 pm) bumps are evident. These hourly patterns can be largely attributed to two causes: increased mobile source emissions during rush hour and temperature inversions. Normally, air temperature decreases as altitude increases. During an inversion, this pattern is reversed, cutting off convection and trapping local air pollution rather than allowing it to rise and disperse. If you ever step outside during the late night or early morning and notice a pervasive sulfur odor in the air, chances are an inversion is to blame. Elevated PM2.5 concentrations can occur any time of the year, but, like ozone, are most common from the late spring to early fall. Unlike ozone, PM2.5 concentrations are most likely to be high late at night and in the early morning. Putting it all together While unhealthy air quality can occur at any time of the year, those seeking to reduce their exposure to air pollution during outdoor physical activities should be most mindful of current air quality from late spring through early fall. When it comes to identifying the best time of day to exercise, ozone and PM2.5 concentrations don’t match up so conveniently. The chart below shows the percentage of hourly averages for PM2.5 and ozone in excess of the short-term standard for each pollutant: Given the divergent hourly patterns of PM2.5 and ozone, there are only a few portions of the day when concentrations of both pollutants are unlikely to be elevated. Best bets are to try to plan outdoor exercise between 9 am and 1 pm or 6 pm and 8 pm. Keep in mind, these are just general trends. Air quality can be good (or bad) at any time of the day or year. It’s always best to check the current air quality before exercising outdoors. Again, I’m not suggesting you reduce your general level of physical activity. It’s far from clear under what circumstances the numerous positive health effects of exercise are outweighed by the negative health effects of increased exposure to air pollution, but if you reduce your exposure to air pollution by reducing your level of physical activity, there’s a good chance you’re doing yourself more harm than good. Use this information to increase the amount of time you spend exercising when air quality is good, not to decrease the amount of time you spend exercising in general. Back to post [1] Among the few exceptions to this general pattern are areas where air pollution concentrations are dominated by an intermittent local pollution source. Seasonal variations are, of course, based on seasons, so annual trends would be offset by ~6 months in the southern hemisphere and muted or nonexistent near the equator. Back to post [2] Why .075 ppm? Because the most recent short-term national ambient air quality standard (NAAQS) for ozone is set at .075 ppm. averaged over 8 hours. I use the hourly averages for ozone because an 8-hour average would mask the temporal variation in ozone concentrations, not to second-guess EPA’s decision that 8-hour averages are most relevant to human health effects. Does this mean you’d have to jog for 8-hours straight in air exceeding the NAAQS standard? No, the same document in which EPA justifies the 8-hour standard also acknowledges that exercise can increase the sensitivity to and adverse health effects of ozone, meaning multi-hour exposures to high ozone levels are more likely to result in adverse health effects if an individual is physically active during a portion of that multi-hour exposure). U.S. EPA, Air Quality Criteria for Ozone and Related Photochemical Oxidants (Vol. I) page E-22, available at: http://oaspub.epa.gov/eims/eimscomm.getfile?p_download_id=456384. Back to post [3] The NAAQS standard is 35 microgram per cubic meter (μg/m3) averaged over 24-hours. As I stated above regarding the 8-hour averaging time for the ozone standard, I’m focusing on hourly averages for PM2.5 because it provides a better sense of temporal trends, not to second guess the federal PM2.5 standard’s 24-hour averaging time.










