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CATF Statement on EPA Proposal on NAAQS
The Clean Air Task Force (CATF) criticizes the EPA's proposal on National Ambient Air Quality Standards (NAAQS) for particulate matter, stating it ignores scientific evidence that current standards are inadequate. CATF highlights that EPA career staff recommended a lower annual average standard of 8 µg/m³, yet political decision-makers maintained the 2012 standard of 12 µg/m³. The statement also condemns the EPA for rushing the proposal, reducing public comment opportunities, and disbanding an expert panel intended to assist the Clean Air Scientific Advisory Committee (CASAC).
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Document type: Statement
Monitoramento da Qualidade do ar no Estado do ACRE - 2019
The report details the implementation of a low-cost sensor network to monitor air quality in Acre, Brazil, finding that many municipalities frequently exceeded WHO safety limits for PM2.5, primarily during the dry season months of August and September.
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Document type: Executive summary
Carbon Pricing, Climate Change, and Air Quality
The briefing examines the shared origins of air pollution and climate change, primarily fossil fuel combustion, and advocates for integrated policy frameworks. It details the significant health and economic burdens of air pollution, particularly in urban areas and for vulnerable groups. The text demonstrates that the health co-benefits of climate mitigation, such as carbon pricing, often outweigh the policy costs. It provides examples of coordinated efforts in Chile, California, the EU, Madrid, and London, while warning that uncoordinated policies—such as incentivizing diesel vehicles for lower CO2 or installing SO2 filters that reduce plant efficiency—can create counterproductive outcomes.
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Document type: Briefing
Ready for Work
The report examines the technical and economic feasibility of electrifying heavy-duty vehicles (HDVs) in the US, highlighting their potential to significantly reduce NOx, PM2.5, and greenhouse gas emissions. It argues that current battery technology is sufficient for the majority of HDV operating ranges and that total cost of ownership is becoming competitive with diesel. The document recommends a combination of financial incentives, infrastructure investment, and regulatory standards to drive the transition.
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Document type: Report
Comments on the Environmental Protection Agency’s (“EPA”) “Policy Assessment for Review of the National Ambient Air Quality Standards for Particulate Matter, External Review Draft.”
The document provides formal comments on the EPA's External Review Draft of the Policy Assessment for the review of PM2.5 NAAQS. It asserts that the EPA is legally obligated to set standards based solely on health and welfare effects, without considering cost or feasibility, and must protect vulnerable subpopulations. The authors criticize the EPA for disbanding the particulate matter review panel, following a flawed memorandum from former Administrator Pruitt that suggests combining science and policy assessments, and failing to issue a second draft of the Integrated Science Assessment (ISA). Finally, the document argues that current PM2.5 standards are insufficient, citing evidence of mortality risks at levels as low as 8 μg/m3, and recommends lowering the primary annual standard to 8-10 μg/m3 and the 24-hour standard to 25-30 μg/m3.
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Document type: Statement
Comments on the Provisional Atmospheric Emission License (PAEL) Issued to Thabametsi Power Company (Pty) Ltd.
The report argues that the PAEL for the Thabametsi power plant is based on flawed Atmospheric Impact Reports and permits outdated sub-critical CFB technology that is less efficient and more polluting than super-critical alternatives. It highlights that the license fails to require continuous emissions monitoring and underestimates NOx, SO2, and particulate matter emissions. Furthermore, the author asserts that adding a new coal plant to the Waterberg Bojanala Priority Area is unjustified given existing violations of National Ambient Air Quality Standards (NAAQS) in the region.
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Document type: Report
India's Energy Transition: The Cost of Meeting Air Pollution Standards in the Coal-fired Electricity Sector
The document estimates that installing SOx, NOx, and PM pollution-control technology in India's coal power plants will cost up to INR 86,135 crore (USD 12 billion), potentially increasing electricity tariffs by 9–21 per cent. It argues that the Ministry of Power must enforce strict compliance to ensure air pollution externalities are reflected in power prices and to prevent non-compliant plants from continuing operations without a phase-out plan.
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Document type: Policy brief
Truck Driver Misclassification: Climate, Labor, and Environmental Justice Impacts
The Coalition for Healthy Ports (CHP) and Earthjustice advocate for the New Jersey DEP to adopt the Advanced Clean Trucks (ACT) Rule and the Heavy-Duty Omnibus Low-NOx Rule to reduce harmful emissions in environmental justice communities. They argue that MHDV electrification is economically viable and technically feasible, citing a projected $8.9 billion net societal benefit for New Jersey from 2020 to 2050 under the ACT Rule. The coalition emphasizes that the burden of pollution and the costs of vehicle upgrades fall disproportionately on misclassified contract truck drivers and low-income communities of color, particularly in the Ironbound section of Newark. They further recommend a lower fleet-reporting threshold, the adoption of cargo-handling equipment and ocean-going vessel regulations, and the implementation of zero-emission zones to address the cumulative impacts of the goods-movement industry.
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Document type: Statement
THE COST OF AVAILABLE POLLUTION ABATEMENT TECHNOLOGIES REQUIRED TO MEET MINIMUM EMISSION STANDARDS FOR SULPHUR DIOXIDE (SO2)
The Centre for Environmental Rights (CER) asserts that South Africa's Minimum Emission Standards (MES) for sulphur dioxide (SO2) are already weak compared to other developing nations and should be strictly enforced. The CER disputes claims by Eskom and Sasol that compliance is too expensive, citing expert analysis that suggests Eskom's capital cost estimates for flue gas desulphurisation (FGD) and low NOx burners are significantly inflated. The document highlights that failure to comply with the MES could lead to approximately 16,000 avoidable premature deaths, while doubling the SO2 limit to 1000mg/Nm3 would cause an additional 3,300 premature deaths. It recommends the use of FGD as the best available technology for long-term operation and dry sorbent injection (DSI) only for plants nearing decommissioning.
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Document type: Statement
NEED FOR IMMEDIATE ENFORCEMENT ACTION RELATING TO ESKOMS FLAGRANT NON-COMPLIANCE WITH ATMOSPHERIC EMISSION LICENCE CONDITIONS AT KENDAL POWER STATION
The Centre for Environmental Rights (CER) is urging the South African government to penalize Eskom for chronic air pollution at the Kendal power station. Evidence from 2016-2019 shows frequent exceedances of particulate matter (PM) limits, with some units emitting 12 to 13 times the allowable limit. The CER argues that previous enforcement notices have been ineffective and that Eskom is violating both its AEL and the National Environmental Management Act's duty of care, impacting the health of communities in the Highveld Priority Area.
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Document type: Statement
Tackling Coal-Driven Air Pollution in China and India
The report analyzes how China and India are tackling coal-driven air pollution through stricter emission standards, renewable energy subsidies, and improved air quality monitoring, contrasting these efforts with Indonesia's current policy landscape. It highlights that while China and India are shifting toward renewables and implementing rigorous coal plant standards, Indonesia continues to expand its coal capacity and maintains more lenient emission limits and scarce air quality data.
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Document type: Report
AIR QUALITY IMPACTS AND HEALTH EFFECTS DUE TO LARGE STATIONARY SOURCE EMISSIONS IN AND AROUND SOUTH AFRICA’S MPUMALANGA HIGHVELD PRIORITY AREA (HPA)
The report finds that 14 industrial facilities in South Africa's Mpumalanga Highveld Priority Area (HPA) caused between 305 and 650 early deaths in 2016 due to PM2.5 pollution. The most significant contributors were the Lethabo, Kendal, and Kriel power stations. Modeling indicates that compliance with the 2020 Minimum Emission Standards (MES) would reduce these annual early deaths by 60%, preventing between 182 and 388 deaths. The report also highlights severe exceedances of World Health Organization (WHO) guidelines for SO2 and NO2, particularly at sensitive sites like schools and hospitals. In 2016, these 14 facilities accounted for up to 92% of the daily ambient SO2 limit, suggesting that national air quality standards cannot be met without reducing emissions from these specific sources.
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Document type: Report
Review of Dr. Andrew Gray’s “AIR QUALITY IMPACTS AND HEALTH EFFECTS DUE TO LARGE STATIONARY SOURCE EMISSIONS IN AND AROUND SOUTH AFRICA’S MPUMALANGA HIGHVELD PRIORITY AREA (HPA)” (June2019)
Professor Peter Orris reviews Dr. Andrew Gray's modeling of emissions from 12 coal-fired power plants, a Synfuels facility, and a NatRef refinery in South Africa. Orris concludes that these facilities create a significant public health hazard, contributing to hundreds of premature deaths annually via PM2.5 exposure. He notes that while implementing the 2020 Minimum Emission Standards (MES) would significantly reduce PM2.5-related deaths, it would not eliminate all WHO guideline exceedances for SO2 and NO2. The review emphasizes the vulnerability of children and the elderly at sensitive sites like schools and hospitals.
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Document type: Report
Who Bears the Burden?
The Union of Concerned Scientists analysis reveals that Asian American, African American, and Latino residents in Massachusetts face significantly higher exposure to PM2.5 from cars, trucks, and buses than white residents. This disparity is attributed to historical decisions regarding transportation, housing, and land use. The document advocates for prioritizing clean transportation technologies—such as electric vehicles and buses—and infrastructure improvements in the most burdened communities to reduce health inequities.
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Document type: Fact sheet
Who Bears the Burden?
The analysis finds that Latino, Asian American, and African American residents in the Northeast and Mid-Atlantic are exposed to significantly higher levels of vehicle-related PM2.5 pollution than white residents. The report highlights that white residents comprise 85% of those in the lowest pollution areas, while people of color are overrepresented in the most polluted census tracts, often located near major highways in urban centers. The document argues for targeted investments in clean transportation, such as electric vehicles and buses, to reduce these environmental inequities.
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Document type: Fact sheet
Who Bears the Burden?
The Union of Concerned Scientists finds that Asian American, Latino, and African American residents in New York State are exposed to significantly higher levels of vehicle-derived PM2.5 pollution than white residents. The highest concentrations are found in New York City, particularly in the West Bronx, where pollution is linked to severe health risks including cardiovascular disease and asthma. The document argues that these inequities result from historical land-use and transportation decisions and recommends prioritizing electric vehicle infrastructure, cleaner fuels, and expanded public transit in the most burdened communities.
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Document type: Fact sheet
Air quality in Germany – evidence hearing on the health impacts of air pollution
The Higher Administrative Court of Münster scheduled a two-day evidence hearing on 9-10 May 2019 featuring science and health experts to resolve debates over air quality rules and diesel restrictions in Germany. This follows legal actions in 35 German cities supported by ClientEarth and Deutsche Umwelthilfe (DUH) to enforce air quality limits. While some officials and specialists have questioned the science linking nitrogen dioxide (NO2) to health issues, the briefing notes that the majority of researchers, the European Commission, and Germany's environment minister maintain that limits are based on sound science. The hearing aims to provide the evidence necessary to adjudicate appeals regarding diesel restrictions in 14 cities in North Rhine-Westphalia.
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Document type: Briefing
How and Why the U.S. EPA Is Changing its Policy on Mercury
The U.S. EPA has proposed a change in how it calculates the benefits of the Mercury and Air Toxics Standards (MATS) for coal- and oil-fired power plants. By excluding 'co-benefits'—reductions in pollutants not directly targeted by the rule, such as particulate matter (PM2.5)—the EPA argues that the regulation is no longer 'appropriate and necessary' under the Clean Air Act. While the MATS originally prevented 11,000 premature deaths and 130,000 asthma attacks annually, removing co-benefits, which account for over 90% of monetized benefits, dramatically lowers the perceived value of the regulation relative to its compliance costs. Although the MATS remain in place for now, this methodological shift opens the door for the EPA to potentially rescind the standards or delist power plants as affected sources. Electric utilities have expressed concern over this shift, noting they have already invested over USD 18 billion in pollution-control upgrades. The report also notes that increased mercury emissions in the U.S. could adversely affect Canada due to transboundary transport.
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Document type: Report
Eskom Power Station Exceedances of Applicable Atmospheric Emission License (AEL) Limit Values for PM, SO2 & NOx During April 2016 to December 2017
The report identifies 3,217 self-reported exceedances of AEL limits across 14 coal-fired power stations over a 21-month period. It highlights chronic pollution issues, particularly regarding particulate matter at stations without fabric filters, and criticizes the lack of electronic, standardized reporting.
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Document type: Report
Air quality and health impacts of ESKOM’s planned non-compliance with South African Minimum Emission Standards
The report finds that granting Eskom's requests for non-compliance with Minimum Emission Standards would lead to significant excess emissions of SO2, NOx, particulate matter, and mercury, resulting in an estimated 16,000 avoidable premature deaths across South Africa, with 3,100 of those in the Gauteng region.
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Document type: Research paper