Comment submitted by Wendy Bernstein

My name is Wendy J. Bernstein M.D., and I work from Berkeley, California in the San Francisco Bay Area. As a community psychiatrist with decades of experience working with marginalized communities in California, I have seen the pain of parents caring for children with asthma - the fear that their child will die, the guilt that they can’t afford to move to an area with cleaner air, the economic hardship of missed work due to their child’s need for care, the fear that they will be fired due to absences. I have seen the ripple effects of grandparents living in industrial zones who become ill with cancer and can no longer care for their grandchildren. I have seen the despair of people who know that their living conditions are unfair and unsafe, but can’t do anything about it. We now know that fine particulate matter and nitrogen oxides from traffic pollution damage every organ in the body. We have seen increases in rates of depression (1), ADHD (2), and dementia (3) associated with air pollution, and decreases in health costs when air pollution is reduced (4). This is why I oppose the proposed delay in implementing Tier 4 Criteria Pollutant Standards. Vehicles sold under weaker standards will remain on the road for 15 to 20 years, so even a 2 year delay means millions more vehicles unnecessarily poisoning our air. As an EV driver for the past 12 years, I can attest to the superiority of these cars over internal combustion engines as far as cost to operate, quiet, pleasure of driving, and total lack of tail pipe emissions. As EV’s approach purchase price parity with gas operated cars, there is no reason to delay clean air standards other than catering to the oil and gas industry lobbyists. A regulatory analysis that counts costs to industry but refuses to count costs to human health is hypocritical at best. The EPA has a statutory mandate under the Clean Air Act to protect public health. For the developing lungs and brains of children, to avoid sky rocketing health costs, and for common decency, the EPA must withdraw the proposed delay entirely. References: 1. https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2843119 (depression in medicare population) 2. https://www.sciencedirect.com/science/article/abs/pii/S0013935119307273 (adhd) 3. https://pmc.ncbi.nlm.nih.gov/articles/PMC10683861/#R88 cog across lifespan 4. https://pubmed.ncbi.nlm.nih.gov/33296187/ (saving lives by cleaning up air)