Statement Of David Tuft

Environmental Protection Agency
Aging Initiative Public Listening Session
Tampa, Florida
April 3, 2003

David Tuft
Fuel Cells 2000/Breakthrough Technologies Institute

"Don't Discount Seniors' Health: Clean up dirty diesel engines"

I'm here this afternoon to support strong controls on heavy diesel equipment that will protect all Floridians, and especially seniors from health hazards associated with pollution from these engines. Diesel engines commonly seen around construction sites, road building sites and agricultural farms, remain one of the single largest sources of fine particulate pollution we call "soot".

In the Tampa, St. Petersburg, and Clearwater area, exhaust from heavy diesel equipment contributes more fine particle emissions than all the cars, trucks and buses combined. Even among young people, fine particulate matter lodges in the deepest regions of the lungs exacerbating cases of asthma, difficult or painful breathing, and chronic bronchitis. It's also been determined to be a likely carcinogen.

As we have been hearing today, older Americans are especially vulnerable to health problems associated with air pollution. As our bodies age, they are less able to detoxify and eliminate toxins, and we suffer from the accumulation of a lifetime of contaminant exposure.

I, too am troubled by recent White House and EPA actions that have justified weakened environmental protections with cost-benefit calculations that devalue the life of a senior citizen. I am concerned that in its proposed rule for nonroad engines, the EPA will follow OMB guidance and discount senior lives, resulting in a far weaker rule than would otherwise be the case.

In a February 2003 report to Congress, the Office of Management and Budget insisted that when designing new health and safety standards, older people should count differently than younger people. The OMB's "Draft 2003 Report to Congress on the Cost and Benefits of Federal Regulations" suggests that when assessing premature mortality risks in regulatory analyses, agencies should, quote, "make appropriate quantitative adjustments", end quote, to the value of statistical lives based on age. In addition, the guidance document recommends calculating life values based on life-years instead of whole lives, a devise that, in practice, penalizes the elderly who statistically have fewer years of life remaining.

As we have heard others say, in the snowmobile rule, the EPA determined that people 70 years or older are worth 63 percent of that of a younger person. Further, the EPA applied a discount rate of 3 percent per life year remaining, further reducing the value of a senior's life from $2.3 million to $1.25 million. Overall, this "alternative" formulation reduced the benefit of the rule from $77 billion to $8 billion. Subsequently, the snowmobile rule was weakened from its original standard of reducing carbon monoxides by 50 percent to only 30 percent.

Governor Whitman, your office has worked tirelessly on a rule to cut emissions from nonroad diesel engines. I ask you today, can you assure us that the EPA will not undo that excellent work by discounting senior lives? I urge you to tell OMB not to contaminate the rule with the senior death discount.

I thank you for you time your willingness to come to Tampa to hear these concerns.

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