Acid Rain/Air Pollution: The Situation in Florida and the Southeast (1999)

Acid Deposition Levels and Trends

1. Florida is one of the top 10 states in the U.S. in production of sulfur and nitrogen oxides (32,32.8). The acidity of rainfall in Florida increased markedly between 1955 and 1980;

the average sulfate and nitrate concentrations increased by factors of 1.6 and 4.5,

respectively(7,16). Sulfur dioxide emissions in Florida increased by over 30 % between 1985

and 1992 due primarily to growth of energy use and increased incineration. NOx emissions have increased 14% between 1970 and 1994(44). Hydrogen chloride emissions have also increased due to an increase in incineration. Total U.S. sulfur emissions in 1980 were approx. 26 tons (32.3, 25.3). Title IV of the U.S. Clean Air Act(CAA) is designed to reduce emissions by 10 tons over the 1980 level by 2010. The level in 1994 was approx. 21 million tons(28.5). The decline has been primarily due to increased use of low sulfur coal. A 2003 Office of Management and Budget (OMB) study found that the Acid Rain Program accounted for the largest quantified human health benefits – over $70 billion annually – of any major federal regulatory program implemented in the last 10 years, with benefits exceeding costs by more than 40:1.

Title IV of the CCA is designed to reduce utility nitrogen oxide emissions by approx. 20% by 2010 (32.3), while Title II would reduce mobile source emissions by approx. 15%.

North Florida rainfall is approximately 16 times more acidic than unpolluted rainfall(ph 5.6), with a PH approximately 4.4. Summer rainfall has average PH values 0.2 to 0.3 lower than winter rainfall.

2. Florida anthropogenic sources are estimated by FCG(12) to account for 66% of sulfur

dioxide deposition in Florida and out of state sources 34%. Florida utilities were estimated to

account for 44% of sulfur deposition in Florida. The total statewide sulfur and nitrogen oxide

emissions are approx. 937,000 tons and 810,000 tons per year, respectively. For sulfur oxides, 91% was from point sources, with 68% from utilities. For nitrogen oxides, 52% was from point sources, with 32% from utilities. Approx. 1/3 of the sulfur deposited in Florida is in dry form.

3. Both sulfur and nitrogen oxides are expected to increase with population growth over the next decade given current trends, especially if much of the large amounts of electricity imported from Georgia and Alabama were replaced by power produced in Florida(14). Even with increased controls at many facilities, NOx emissions in the U.S. are expected to increase by 3 to 5% between 1994 and 2015 due to increased electricity demand and increased coal plant utilization.

4. Over the 3 1/2 year period(July 1981 to Dec 1984) the average statewide PH of preciitation

in Florida was approximately 4.6, ranging from 4.3 for some sites and years to more than 4.8

for other sites and years, with many specific rainfall events below or above this range. This

compares with a PH of 4.3 in some areas of the Midwest and Northeast. The acidity of rainfall

varied throughout the state depending on local sources, transport from distant sources,

frequency of rainfall, etc. The lowest PH levels recorded were in north central Florida and north Florida, with the least acidic rainfall in south Florida. Sulfate and nitrate deposition levels also generally followed this pattern, with levels varying depending on previously listed conditions. Average sulfate deposition was approx. 14 kilograms per hectre per year‑ranging from 9 to 18 kg/ha/yr at specific sites‑ (kg/ha=.89 lb/acre). Nitrate deposition was approx. 8 kg/ha/year, ranging from 7.2 to 9.2 kg/ha/yr.Sulfate levels were higher in north‑central areas and lower in south Florida. There was less regional difference in nitrate levels(12).

5. Stratospheric non‑volcanic sulfuric acid aerosol mass at northern mid‑latitudes has increased approx. 5 % per year between 1980 and 1990(19.5). Natural sulfate and nitrogen sources are insignificant(38). Sulfates in the stratosphere are a factor in ozone depletion, as well as the greenhouse effect. Electric utilities produce 69% of all sulfur dioxide emissions in the U.S (33.1,38). Industrial boilers/sources are responsible for about 17% of sulfur emissions, while vehicles produce about 3.5%(38).

Electric utilites produce about 32.3% of nitrogen oxide emissions, while highway vehicles

produce about 32.3%, non‑highway vehicles 12%, and industrial fuel combustion 15.2%(38).

Volatile organic compounds(VOCs) are also a major factor in production of smog, ozone, and

acidic air(38). Highway vehicles produce about 27% of VOCs, while solvent utilization

produces 27%, waste disposal and incineration 10%, and off‑highway vehicles 9%.

6. Seven Florida counties have frequent periodic high levels of ozone and don't meet Federal

ozone standards. Acidic emissions have been documented to be a major factor in the

ozone/smog/acid fog problem in urban areas(19,34,5). Florida recorded 221 violations of the

EPA's health standard for smog and totaled 33 ozone alert days where the air was unsafe in the summer of 1998. Children living in smoggy California communities suffer greater rates of asthma than youngsters in less polluted areas, and Children in high-pollution areas who are active in sports have a three to four times higher risk of developing asthma than those in less smoggy communities(58). Children living in smoggy areas are advised not to participate in sports or active play out of doors when pollution is high.

Acid Deposition Effect on Lakes and Streams.

7. There are 2 basic acidification processes affecting water bodies‑ long term chronic

acidification and short term episodic acidification during rainstorms or snowmelt(32.3,25.3).

Both have major impacts on fish and ecosystem diversity, with the short term type of

acidification currently affecting more water bodies. Most surface waters range in PH from 6.5 to

8.0 where there is sufficient acid neutralizing capacity(ANC). Calcium is the main buffering agent for water body ph, but phosphates, silicates, sulfides, and organic anions can also contribute to total ANC. Generally an ANC of 50 microequivalences per liter correlates to a PH of approx. 6.5 in the eastern U.S. Lakes and streams with ANCs of 200 microeq/l or less are sensitive and subject to damage at moderate acidic deposition rates, while water bodies with ANCs of less than 40 microeq/l are critically sensitive to even moderate levels of deposition. Pulses of highly acidic water flushing into systems, especially where aluminum or other toxic metals are present in soil or sediments often results in acutely toxic, lethal chemical conditions.

8. (NAS) Using the fact diatoms are good indicators of PH in lakes, an analysis of diatoms in

lake sediments was used to develop a PH history for lakes in the U.S(and Florida). This was

used to determine trends in acidification of lakes. It was determined that acid depositon is

causing acidification of lakes in the U.S(25), and in Florida(30.5,32.3). The scientists involved in the NAS study called for large decreases in acid depositon to alleviate this trend(25).

The increasing acidity of lakes and streams along with increased ultraviolet‑B radiation caused by thinning of the ozone layer are resulting in serious declines in frog and amphibian populations all over the world(42). According to University researchers, the 2 factors

act synergistically to damage amphibian eggs, even though current levels of either factor alone

cause little damage.

9. Studies based on analysis of 1981 and 1982 data from the NADP system suggests that to

avoid acute damage to moderately sensitive lakes, an area should receive no more than 14 to 16

kilograms per hectre per year of sulfur deposition (kg/ha=.89 lb/acre). This was the level that

appeared to produce acidity levels of 4.6 to 4.7 PH.(11.5 & 15). A study of acidification

mechanisms in the U.S. concluded that when wet sulfate deposition exceeds 12 kg per hectre

per year, lakes in eastern N. America become acidified over a relatively short period of time.

Lower levels can result in acidification in poorly buffered lakes or over a longer period of

time(31). After numerous studies, Canada, New York, and the New England states adopted a

target critical load of 6.7 kg sulfer /hectare/ year(wet deposition) as needed to protect sensitive watersheds, though this was determined to be not sufficient for some sensitive, poorly buffered areas(32.3). That load corresponds to a PH of approx. 5.3 in the majority of watersheds of that area. After an extensive study program, the state of Minnesota adopted a sulfur deposition standard to protect sensitive watersheds of 3.7 kg sulfur/ hectare/year(wet deposition). The U.S. EPA nitrogen bounding study(NBS) projects that sulfur emissions in the east coast would need to be less than 5 kg/ha/year to maintain sensitive surface waters in a reasonable ANC range assuming nitrogen levels are about the same as now(32.3).

Analysis of lake regions using EPA models for CAAA studies indicate that to maintain lake

acidity levels at 1985 levels would require reductions beyond the CAAA limits in SO2 and NOx

of 25 % for mid‑Appalachian lakes and 40 to 50% for Adirondack region lakes. 70% of

Adirondack lakes and streams are expected to suffer episodic acidification each year and 30 %

of mid‑Appalachian lakes(32.3).

Studies have also shown that episodic acidication during snowmelt or rainstorms have major

short term and long term affects on water bodies, affecting many more water bodies than

chronic acidification. Stream assessments by chemical measures during low flow were found to

poorly predict the status and fish and other species over the long term.

10. Based on the EPA Eastern Lakes Survey, Florida contains the largest population of acidic

lakes in the U.S. Approx. 12% of Florida lakes were highly acidic, a level which usually implies

little or no life can exist in the lake. At least 20 % of the lakes in Florida(approx. 3000) have PH

equal to or less than 5.5 and low buffering capacity, putting them in EPA's most vulnerable

category to acid rain. Over 1/3 of Florida lakes were considered currently vulnerable to acid

rain with low buffering capacity(ANC less than 50). 54% of Florida's lakes were in the

potentially vulnerable category with relatively low buffering capacity. Charles Elkins, an EPA

official involved in the lakes survey said Florida may have some cause for concern(11,33). 63% of the lakes in the region including the Central Trail Ridge region north of 29 degrees latitude and the Panhadle are acidic(ANC< 0 micro eq/l). 53% had PH less than 5.5. Most of these were seepage lakes(25.3). 75% of Fla.acid streams had dissolved oxygen content < 2 mg/l). 75% of Panhandle lakes are acidic, and 26 % of all north Fla. lakes(32.3). According to the study(NSWS), the largest cause of acidic lakes was acidic deposition.

11. In a Canadian study the PH of a small Precambrian Shield lake was gradually lowered

artificially from 6.8 to 5.0 by addition of sulfuric acid. The study found dramatic changes in the

food web at higher levels of PH than expected and an indication that irreversable stresses occur on aquatic systems earlier in the acidification process than was realized. Key organisms in the food chain were eliminated at PH 5.8, which were caused by additions of the hydrogen ion alone, not by the secondary effect of aluminum toxicity which becomes more severe as PH

goes below 5.5. No species of fish reproduced at PH below 5.4(27.5).

According to a joint EPA/Dept. of Interior panel summary of lake studies, modification in any

thropic level resulting from acidification can disrupt food chains in lakes and result in the

instability of lake ecosystems.(32.5 & 11) The study gives the following table of changes usually observed as lake PH decreases: below 6.0 changes in phytoplankton composition.

changes in amphibian reproductive success.

changes in benthic invertebrate composition & diversity.

disappearance of mulluscs(clams, snails,etc.)

below PH 5.5

reduction in zooplankton diversity and biomass.

increased soluability of aluminum and heavy metals.

disappearance of mayflys, crawfish, common shiners, rainbow trout

below PH 5.0

reduction in microbial decomposition, resulting in accumulations

of organic debris; large reduction in life diversity;

disappearance of trout. effects on waterfowl are possible due to reduced food

availability or reproductive failure by accumulation of

metals mobilized by acids,but no clear threshold level.

* calcium buffered waters are less susceptible to effects of low PH.

12. Researchers have documented reductions in PH, loss of alkalinity, and increases in sulfates

in north and central Florida lakes over the last 25 years(7,13,16,18). The approx. 2000

soft‑water lakes in the sandhill region of north and central Florida obtain most of their water

from rainfall and seepage, and are especially susceptible to acid rain. Lakes in N. Florida have

the potential to respond to rainfall acidity approx. 50% faster on average than the lakes of S.

Florida(12).

13. Brezonik in studies of 20 Central Florida lakes found that more acidic lakes had lower

concentrates of organic nutrients, chlorophyll, phytoplankton, and zooplankton. Acid lakes also

showed a greater degree of oligotropic conditions and decreased productivity. All 20 lakes

showed increases in sulfates with several showing a doubling over two decades. Acidic Florida

lakes also had a higher concentration of toxic metals such as aluminum than non‑acidic

lakes(13). The soluability of aluminum increases as PH goes below 6.0 and is a maximum between 4.5 and 5.0. As inorganic aluminum concentration goes above 30 micrograms per liter, effects on water bodies and the food chain increae(32.3). Studies indicate that once a system is acidified and damaged, full recovery is unlikely even if acid deposition is reduced drastically(32.3).

14. Acid rain, mainly in the form of nitrogen oxides, is causing serious damage and mass killings of aquatic life in Atlantic coastal waters and bays, as well as in large lakes. Reversal of the rapid decline in Atlantic coastal waters and fisheries will require measures to control air pollution as well as sewage and dumping of waste(25.8,43,46). In many regions, nitrogen oxide is becoming a more important factor in acidification than sulfer oxide, with many water bodies and some soils becoming nitrogen saturated. Nitrogen deposition has been determined to play a major role in episodic acidification events in eastern streams and lakes(32.3). California studies have recommended nitrogen deposition limits of 10 to 20 kg/hectare/year to protect watersheds in that state, and 5 kg for some especially sensitive areas(32.3).

Nitrogen oxides, produced mainly by vehicles and power plants, are producing damage to

aquatic life not only by acidification but through eutrophication (43,46). The excess nitrogen

along with other nutrients creates excessive growth of algae, which chokes off the oxygen supply and blocks sunlight needed by other aquatic life, resulting in anoxic zones where aquatic organisms can't survive. In the summer of 1994 thousands of lobsters, crabs, etc. were killed by this mechanism in Long Island Sound. Other serious recent occurrences took place in Cheasapeake Bay, Delaware Bay, the New York Bight, Long Island's Narragansett Bay, North Carolina's Albemarie‑Pamlico Sound, Lake Okeechobee, Tampa Bay,etc. Air emissions were estimated to be responsible for approx. 75% of the nitrates entering the Chesapeake Bay(43).

Likewise, South Florida regional water management officials have estimated that pollutants in

rainfall are responsible for at least 25% of the nitrogen entering Lake Okeechobee which is in

serious decline and the source of much of south Florida's drinking water(28,25.8); and a recent DER funded study of the Apalachicola River and Bay by FSU researchers found atmospheric emissions to be the major contributor to the nitrogen load of that system(36.5). Utility emissions make up the majority of point source emissions, with most of the deposition the result of long range transport(43).

The increasing levels of nitrogen deposition are also having adverse effects on many ecosystems such as Midwest grasslands, which are experiencing loss of diversity, increases in non‑native species, and other ecosystem disruptions(75).

(14.5) Accumulation of atmospheric oxidants and mercury causing high levels of mercury deposition in coastal areas of Arctic and Antarctica which is activated by sunlight, resulting in very high levels of mercury in wild life such as whales and polar bears(64,36.8,37.5). Ozone polluted air causes increased mercury oxidation and deposition(65,37.3). Factors influencing the uptake of mercury by organisms in lakes and rivers include pH, organic carbon levels, and sulfate levels(37.3). According to a report released by the National Wildlife Federation May 29, 2003, mercury in Florida rainfall measures more than 5 times the federal health standard for lakes(37.1).The high emissions and deposition are causing high levels of mercury in the food chain such as in fish in lakes, rivers, and bays all over Florida(37.2). Increasing mercury exposure from fish and other sources such as dental amalgam(36.8c) and vaccinations(36.8b) are causing widespread chronic health problems, as documented in the medical literature. Federal agencies have found toxic metal exposure to be the number one toxics problem affecting large numbers of people(37.4).

Effect on Health

15. Serious respiratory problems caused by ambient air concentrations of SO2 and NOx

include chronic bronchitis, bronchoconstriction, other pulmonary function impairments, cough,

lung inflammation, increased incidence of infectious respiratory disease, asthma, and increased

mortality through respiratory disease(32.3,53). Sulfate particles are a major component of small particulate emissions that have been found to be significant factors in increasing lung disease and mortality. Sulfate aerosols comprise the majority of acidic aerosols in ambient air and a large share to total inhalable particulate matter in the eastern U.S.(29.5,53).

A high correlation has been found between sulfur dioxide in the air and respiratory/ cardiovascular disease(4,5,6,8,20.3,22,36.2,36.4,32.8,32.3,63). SO2 and sulfites have been found to have toxic effects which result in damage such as bronchitis, bronchoconstriction,etc.(48). SO2 and sulfites have also been found to potentiate carcinogenic effects of PAHs(48).

One of the mechanisms is the inhibitation of detoxification of xenobiotic compounds by inhibiting the enzymatic conjugation of glutathione(GSH)(51). Researchers at Brookhaven National Laboratory have estimated that about 2% of the deaths in the U.S. each year are due to atmospheric sulfur pollution, which affects the lungs and cardiovascular systems(32.8). The small sulfate particles have been found to concentrate deeper in the lungs than most larger inhaled particles. Sulfur particulate air pollution has been found to cause increased acute respiratory disease in children. Sulfuric acid mists have shown documented adverse effects on healthy non‑smokers at levels of 100 micrograms per cubic meter. There is also evidence that acid sulfates and sulfur dioxide render lung tissues more susceptible to the carcinogenic effects of other carcinogens(32.8). A study of a plant emitting 100 to 300 tons of sulfuric acid aerosols per month in Yakkarchi Japan found that lung disease declined with increasing distance from the plant. The incidence of lung disease dropped sharply when the plant installed sulfuric acid controls(22).

A study of hospital admissions at 79 hospitals in Ontario by Dr. David Bates of the Univ. of

British Columbia found admissions for respiratory disease in the summer correlated with sulfur

dioxide and ozone concentrations. The strongest correlation was between concentration of

sulfates with admissions for asthma(7,22). The rate for asthma cases and asthma deaths have

increased by over 40% from 1982 to 1992(29). Toxic metal rich particulate matter such as from utility residual oil fly ash has been found to affect the respiratory and immune systems, increasing sensitivities of those susceptible to allergies, and allergic conditions such as eczema(52).

A 1995 study by EPA estimated the health benefits from sulfur oxide reductions due to the 1990 clean air act to be between $3 billion and $11 billion in 1997, and between $12 billion and $40 billion in 2010 when fully implemented. Sulfates were found to be an important component of PM2.5 and therefore deep lung pollutants. The health savings came primarily from reductions in premature deaths, reductions in chronic bronchitis and asthma, fewer lung and heart related doctor visits and hospital stays, etc. The related costs of compliance were estimated as $1.2 billion in 1997 and $2.4 billion in 2010. A recent study compared the link between sulfur dioxide levels and hospital admission rates in seven European cities and regions, including London, Birmingham, Madrid, Paris and Rome. Their results showed that an increase of only 10 micrograms per cubic meter of sulphur dioxide would lead to a one per cent rise in hospital admissions for coronary problems within the next 48 hours(63).

Particulate pollution from cars, power plants and factories leads to development of heart disease, with heart effects being even more significant than respiratory effects(70). Exposure to tiny-particle pollution can actually lead to ischemic heart disease, which causes heart attacks, as well as irregular heart rhythms, heart failure and cardiac arrest. Such PM2.5 pollution provoke low-grade pulmonary inflammation, accelerating development of atherosclerosis —— a leading cause of heart disease —— and altering heart function.

15.5 Studies by Harvard School of Public Health ,Johns Hopkins School of Public Health, and

Brigham Young University researchers have confirmed earlier EPA findings that there is a strong relationship between small particulate pollution and respiratory disease (26.5,26.6,27.9,53). Only particulates 15 microns and smaller served as a strong predictor of respiratory disease. Sulfates are a major component of such small particulate pollution. Children living in the areas with high small particulate levels had more than twice as much risk of chronic lung disease as those in areas with low levels of small particulates. Overall death rates were 17 percent higher in the most polluted urban areas compared to least polluted areas, and death rates from heart and lung disease were 31 percent higher. Even cities with average pollution that meets are air pollution regulation had death rates 5 percent higher than areas with cleaner air due to greater heart and lung disease(26.6,53). Research in France, done in the 18 days a year when air pollution is at its worst, showed a 250 per cent increase in heart attacks among smokers, compared with 161 per cent in the general population(69). The current EPA rule for particulates is no more than 150 ug/M3 of particles less than 10‑micron. The John Hopkins study found that for each 10 ug/M3 over a 24 hour period, the death rate from all causes rose over ½ %.(53) All 3 analyses yielded evidence that EPA's current particulate standard(PM equal to or less than 50 micrograms per cubic meter) is not sufficient to protect children's health. The level of particulate pollution and ozone levels in an area have also been found to be directly related to the development of asthma in adults(26.8). Studies of a non‑smoking population in California found significantly higher rates of asthma among members of the group living in areas with higher levels of ozone or suspended particulates. Traffic emissions of pollutants such as nitrogen oxide have also been found to affect children's immune system so as to increase allergies, asthma, and systemic allergic conditions such as eczema(52).

The tiniest particles in air pollution from fossil fuel combustion, one-tenth-of-a-micron particles, accumulated inside cell structures called mitochondria. Mitochondria are the workhorses of cells. They combine sugar and oxygen to produce the fuel that keeps cells running. The study shows that the pollution damaged the shape of mitochondria, causing them to stop producing the cellular fuel and start producing other chemicals, which lead to more inflammation and cell damage(62).

A study comparing respiratory problems in areas in 74 metropolitan areas found hospital admissions for respiratory problems were, on average, 19 percent higher in the 37 areas with the highest air pollution compared with the 37 areas with the least amount of pollution. Similarly, outpatient care was 18 percent higher and hospital admissions were 10 percent higher(1.5). Controlling for demographic and health factors, the researchers found Medicare would have saved an average of $76.70 per person in inpatient care and $100.30 in outpatient care for every drop of 10 micrograms per cubic meter in air pollution.

Regular exposure to air pollution can stunt the growth of children's lungs, leading to a lifetime of reduced respiratory capacity, health problems, and even early death(71). Children in Calif. breathing dirty air were up to five times more likely to grow up with weakened lungs, a finding true across the board, not just in children with preexisting conditions like asthma. In the communities with the dirtiest air, such as Upland in San Bernardino County, almost 10% of the children studied had "clinically significant" reductions in their ability to breathe. In Long Beach, where air pollution levels were lower but still significant, the number was about 6%.

16. Chronic low level exposure to nitrogen oxides has been shown to cause acute respiratory

infections in infants and children, as well as causing chronic aging/deterioration of lungs and

emphysema in adults (32.8,32.9). Also fetal deaths were found to rise significantly with urban air pollution, with nitrogen oxide having the highest impact and appearing to be responsibel for

about 20% of fetal deaths/spontaneous abortions, due to causing hypoxia or insufficient oxygen (47). Nitrogen oxides also have been found to form nitrosamines and similar carcinogenic chemical species in urban air at dangerous levels, as well as being a major factor in ozone formation. Fetal death are also correlated with sulfur dioxide and carbon monoxide(47). Air pollution affects children most significantly and respiratory disease is the leading cause of death among children(49). In a California study by the Calif. Air Resources Board, lung growth is about 5% lower in polluted counties and asthma is more prevelant and more severe in counties with higher nitrogen oxide and particulates(49).

More than a dozen studies in the United States, Brazil, Europe, Mexico, South Korea and Taiwan have linked smog to low birth weight, premature births, stillbirths and infant deaths(55). A study by scientists from the Harvard School of Public Health and the University of Basel in Switzerland concluded that as many as 11% of infant deaths in the United States--about 3,000 per year--may be a result of microscopic particles in the air. In a 1998 study of pregnant women in Sao Paulo, Brazil, scientists found that women exposed to high levels of nitrogen and sulfur oxides were 18% more likely to have their pregnancies terminate in stillbirths. In a separate study, a team of researchers from the United States and Sweden found that pregnant women in five U.S. cities who were exposed to elevated levels of carbon monoxide during their third trimester were 31% more likely to give birth to underweight babies(55). Another study by UCLA researchers, which was published last year and focused on Southern California, concluded that mothers are 20% more likely to have a baby prematurely when exposed to elevated amounts of microscopic particles in the final six weeks of pregnancy. African-American women exposed to high levels of everyday pollutants in automobile exhaust, cigarette smoke and incinerators in the third trimester of pregnancy tended to have smaller babies with smaller than average skulls(60). Dr. Perera, director of the Columbia Center for Children's Environmental Health, said the study's findings were particularly troubling because low birth weight and smaller skulls had been found to correspond with poor health and mental problems later in life. Another study, which is to be published, expands on earlier research by the EPA and Centers for Disease Control that looked at 4 million infants in 86 metropolitan areas and compared the incidence of mortality with fluctuating rates of particulate pollution. That study concluded that as particulate matter increased in the air, the infant mortality rate rose by 10% to 40%(55a).

17. Research teams of FSU, Univ. of Miami, and EPA scientists indicated that

studies have found a link between "acid air" and the high lung cancer rate along Florida's Atlantic Coast(3,4,5,33.2,36.4)). Acid air was found to often be over 100 times as acidic as acid rain and to have more serious direct health effects(5,19,34,36.4). Sulfur dioxide can be chemically transformed into fine sulfate particles that mix with water in the air, liquify, and become aerosols that can penetrate the deepest tissues of the lungs(20.3,32.8,36.2,36.4,5). Sulfur and nitrogen oxides appear to be more readily transformed into sulfuric and nitric acids by Florida's hot humid climate conditions(5,36.4). These acids also appear to be mixing with airborne toxic metals and transforming the metals into a form more dangerous to human health and to the food chain (36.6,32.8,20.3,36.2). The synergistic effect of air pollution has been found to be much greater than the additive effects of individual pollutants(68).

Lung cancer rates along the east coasts of Florida, Georgia, and South Carolina are among the

highest in the nation, and both acid air and lung cancer rates peak in the Jacksonville

area(3,5,33.3). The lung cancer rate in the Jacksonville area has more than doubled in the last

30 years and the area has had a large increase in the level of sulfate particulates (33.2,33.3,17.5,5,7). Similar high levels of lung cancer rates and hot humid climatic

conditions also are found on the Northwest Gulf Coast. The lung cancer rate for both the

northeast Atlantic coast area and northwest Gulf coast area are more than 40 % above the national average(17.5,33.3). These areas also are known to be areas of high ozone

concentrations(32.8).

17.5. Exposure to ozone at levels above and also below the EPA ambient standard causes

serious acute and chronic health effects(39). NOx and SOx and volatile organics are precursors

of ground level ozone. Children, the elderly, and those suffering from asthma or other respiratory

diseases are especially affected by ozone(39,39.4,6). At 90 parts per billion(ppb) which is

below the U.S. EPA national standard for ozone, 51% of children studied suffer measurable

adverse affects while 13 % suffer significant effects and 1% are incapacitated(39,39.4). Long

term exposure at this level causes permanent reduced lung function. It also causes an increase of

at least 20% in asthma attacks and at least 10% increased emergency room visits and

admissions for respiratory ailments such as acute bronchitis, pneumonia, and

emphysema(39,39.2,39.6). Mortality is increased by at least 3% for each 100 ppb increase in

the daily one‑hour maximum ozone concentration. The current Federal EPA standard has

consistently been found to be insufficient to protect the health of people, especially children,

elderly, and those suffering from lung disease(39). The Maine standard for ozone is 81 ppb

while the national standard is 124 ppb. Breathing federally allowed levels of carbon monoxide or

small particles were also found to cause heart disease and increased hospitalizations.

18. There is a well documented health danger from acidification of water supplies. Acidic

deposition increases the corrosiveness of water and causes increased solubility of heavy metals

from the soil into groundwater and from home water pipes into drinking water(Kirkmeyer,12 &

22 & 32.8). Toxic metals are the number one environmental health probem in the U.S.(other

than smoking) and have been documented to cause learning disabilities, neurological disorders,

cardiovascular disease, kidney disease, birth defects, and cancer(36.8). Researchers have found

the levels in water due to acidic pollutants are having serious and permanent adverse health

effects(15.5,35).

Public drinking water systems can be treated to raise PH and remove toxic metals, but such

treatment increases cost. Some treatments also cause other adverse health impacts. Elevated

levels of metals exceeding drinking water standards have been documented for pipes made of

lead, copper, or galvanized steel. Untreated private wells appear to offer the highest individual

risk from increased heavy metal absorption if public water is regularly tested and treated. The

FCG study estimates approx. 20% of Floridians obtain water from private wells. However as

noted by EPA(20), any increase in acidity of water can add incrementally to the level of metals in water and humans. An EPA drinking water survey(35) has found that a high percentage of drinking water in Florida(over 50% in some areas) contains levels of lead or other heavy metals high enough to cause significant health effects. The dissolving of lead from materials such as pipe solder or the soil is facilitated by acidic waters(PH<6.0).

Studies in the U.S., Canada, and Sweden have found a significant correlation between elevated

levels of mercury in fish and increasing acidity of a water body(32.8,33.5,12,15.5,36.8a). Acidification of surface water increases the conversion of inorganic mercury to methylmercury‑‑ a more dangerous form which is bioconcentrated in the aquatic food chain and fish. Fish and seafood is the primary source of mercury exposure to humans from the food chain, and has already reached levels in many areas that is doing serious damage(15.5,66,37.2). Thousands of rivers and lakes in the U.S. have high levels of mercury in fish and the food chain, including more than 50% of lakes or streams in Florida with fish exceeding the FDA standard of 0.5 ppm(30.7,37.2) and EPA mercury health criterion of 0.3 ppm(37.2). HRS has issued health warnings related to eating predator fish from these freshwater bodies as well as from saltwater fish throughout Florida(37.2). The largest source of mercury in the Florida environment appears to be emissions from garbage incinerators and coal power plant which was estimated at approximately 15 tons each per year by DER staff and other researchers in 1989 but has declined some since additional controls on incinerators (30.7,10.7,36.8).

A major new concern is the growing presence of aluminum in water due to acid rain. Aluminum

is the most common metal in soil but is insoluable in neutral or alkaline water. The solubility of

aluminum increases rapidly as PH decreases below 6.0 (32.8). Because of acid rain the increase

of dissolved aluminum in lakes is extremely large, according to researchers at the Univ. of

Ontario. Aluminum is toxic to fish at only 100 parts per billion(ppb) and much higher levels are

being observed. Adverse effects of aluminum on fish and birds is becoming common in some areas. Considerable evidence exists supporting a relation between aluminum in humans with neurological disorders such as dementia, Alzheimer’s disease, Parkinson’s disease, and amyotrophic lateral sclerosis(22,31.5,36.8). The non degradability of metals means that once released they accumulate in the environment, so trends need to be assessed before critical levels are approached in the environment(14.5).

Increased acidity has also been found to cause increased solubility of asbestos in commonly use public water system asbestos‑cement pipes(12,32.8). A positive correlation has been found between asbestos in drinking water and abdominal cancer(32.8). An EPA survey found approx. 11 % of the U.S. public is exposed to significant asbestos concentrations in water of over 10 million fibers per liter.

19. According to a Yale University Medical Study, acid pollutants are the third leading cause of

cancer in the U.S.‑ causing approx. 150,000 deaths per year and much more respiratory

disease(36). Transplacental exposure to carcinogenic air pollutants from the combustion of fossil fuels is a growing health concern, given evidence of the heightened susceptibility of the fetus. These mutagenic/carcinogenic pollutants include aromatic compounds such as polycyclic aromatic hydrocarbons that bind to DNA, forming chemical-DNA adducts. I n a cross-sectional study of 67 mothers and 64 newborns from the Krakow Region of Poland, that aromatic-DNA adducts are positively associated with DNA damage and mutant frequency in the newborns(61).

Effect on Forests

20. There has been an extensive forest decline that has occurred in the last 2 or 3 decades in

Europe and North America. Due to the severity of the problem in Europe and Canada,

restrictive measures have been passed to lower emissions including the passage of a National

Referendum by Switzerland that bans all truck traffic in that country other than local traffic. A

recent book surveying forest growth patterns throughout the U.S., found serious forest decline throughout the U.S. and damage from acid rain(Little, 20.5). In a 2 part series Tomlinson surveys the extent of the damage (3.5a), while Johnson and Siccama give a discussion of evidence and what is known regarding possible causes of the decline(3.5b). Spruce‑fir forests throughout the Eastern U.S. are undergoing rapid decline with high percentages of standing trees at elevations over 2500 feet dead or dying(20.5). The high mortality rates followed periods of declining growth rates in the 1960s and 1970s (2,20.5,23).

21. The nutrients calcium, sodium, potassium, and magnesium leach from the soil at increasing

rates as acidity increases, depriving trees or plants of needed nutrients. The solubility of

aluminum in the soil and other heavy metals(lead,cadmium,zinc,etc.) being deposited on leaves

and soils by air pollution increases with increasing acidity. These heavy metals are toxic to

plants, damaging roots and inhibiting calcium uptake and nutrient recycling(10,12,26.3). The

interaction of heavy metals and acid deposition is a factor in forest dieback currently occurring in Europe and N. America as well as in the buildup of heavy metals in forests soils. The main

sources of such heavy metals are incinerators, auto emissions, and power plants(17,20,26.3). In addition to the soil acidification damage mechanism, other damage mechanisms include ozone damage, excess nitrogen deposition, deposition of toxic metals or organic chemicals, and general stress due to combinations of these factors(12).

22. Ozone and nitrogen oxide are important factors in adverse effects on forest and plant

growth. Nitrogen oxides appear to play a larger role in ozone formation than previously realized. Efforts to control damage to forests should include efforts to control ozone and nitrogen oxides, as well as sulfur dioxide. In addition to controls on power plants, controls on motor vehicles should be looked at(1). Nitrous oxide is increasing in the U.S. at 2 to 3% per decade(75).

Nitrous oxide has the potential to delete large numbers of neurons from the developing brain by a newly discovered mechanism involving interference in the action of neurotransmitters

[glutamate and ‑amino butyric acid (GABA) at N‑methyl‑d‑aspartate (NMDA)] and GABAA

receptors during the synaptogenesis period, also known as the brain growth‑spurt period. Transient interference (lasting >= 4 hr) inthe activity of these transmitters during the synaptogenesis period (the last trimester of pregnancy and the first several years after birth in humans) causes millions of developing neurons to commit suicide (die by apoptosis) Thus exposure to nitrous oxide during the fetal or early infant period can cause developmental damage(54).

Increasing concentrations of ozone cause a linear reduction in carbon dioxide uptake in all

species of plants and trees studied, and a reduction in growth rates(27,20.6). Ozone damage is greater in conjunction with acidic pollutants and for lower PH(32.8).

23. Average growth rate of existing pine trees in the Southeast have decreased in the last

decade and mortality has increased, according to annual growth rate inventories conducted by

the Southeastern Forest Experiment Station since 1933. Slash pine growth rates have declined approximately 40% in Georgia coastal plains compared to the 1950s. Throughout Piedmont and mountain areas of the Southeast, the radial growth rate of most yellow pines have dropped 30 to 50 % over the last 30 years, and mortality rates almost doubles form the early 1970s to 1985 (20.5). No widespread consistent decline has been documented for Florida for existing trees, but loss of pine tree volume production on stands of pines due to mortality increased 76 % from 1970 to 1985. Mortality rates for all pine species increased in the Southeast over the last decade, with slash pine mortality increasing the most(30).

24. According to a U.S. Forest Service study in 1986, 77% of all Eastern white pine stands

surveyed showed noticeable air pollution damage. Declines of white pines in Tennessee have

been shown to be related to atmospheric oxidants(23).

25. Core samples have shown that there has been a sharp, simultaneous, and continuous decline in the growth rate of a wide variety of trees in the eastern part of the country since the 1960s.

There is also evidence other areas of the country are vulnerable. The pattern is similar to the

period prior to the widespread decline of European forests. Dr. J.C. Bernabo, Executive

Director of the National Assessment Program believes that the pollutant soup harming trees

includes sulfur dioxide, nitrogen oxides, ozone, heavy metals, and volatile organic chemicals(28). Acid rain has been found to be saturating forests with nitrogen, which can cause slowed growth and reduced levels of carbon dioxide removal(40).

26. A study of forests in the Southern Appalachian Mountains has documented a surprising

rapid decline since 1983, going from no observable damage prior to that time to a widespread

dieback of the tops of trees, and other symptoms similar to the decline in Germany. On Mount

Mitchell, N. Carolina, in 1984 approx. 78 % of the trees had less than 10% defoliation. But one

year later 39% were up to 50% defoliated, and tree mortality had increased to 7% from 1%.

The current rapid decline is a continuation of long term decline starting with declining growth rates in the late 1950s(9). On the summit of Mount Mitchell, ozone levels exceed levels needed to cause damage to trees (as documented by controlled studies) more than 50 % of the time(20.5).

27. Researchers have found much of the sensitive, deep sands of Florida to be especially

susceptible to leaching by acid rain of nutrients such as calcium, magnesium, and potassium,as

well as to the toxic effects of aluminum(7,16,32.8). Candler or other low base saturation soils

are particularly susceptible to acid rain. Pines in some areas of Florida appear to be especially

susceptible to acid rain. Some vegetable and fruit crops are also susceptible to acid rain.

28. The high temperatures and humidity in Florida speed up the formation of sulfuric acid in the atmosphere; the problem is likely to get worse as the state's population grows and utilities

continue to switch from oil to coal (U.S. EPA,1982).

Atmospheric Pollutant Effect on Crops

29. Tests on soybeans showed yield reductions ranging from 6.7% at the lowest sulfur dioxide

test level to 32% at the highest test levels.

Compared to charcoal filtered air, soybean yields ranged from 1% lower at ambient ozone

conditions to 34% lower when ozone was at 199% of the ambient level(10.5).

The effects of interaction of the 2 gases were less than additive at lower levels of ozone and more than additive at higher levels(10.5).

Ozone reduced yields of corn, winter wheat, alfalfa, timothy grass, and clover even at ambient

levels. Sulfur dioxide levels did not affect these crops, but sulfur dioxide in combination with

ozone had an effect on corn. Compared to charcoal filtered air, yields of potatoes were reduced by ambient levels of ozone and reduced by 80% for the highest ozone level. Sulfur dioxide affected the number ,sugar content, and total solids of potatoes.

30. Recent studies have found considerable crop losses are occurring due to ozone damage.

Two recent large studies estimated crop losses due to ozone as follows:

Crop N.A.P.A.P.(25.4) Office of Technology Assessment(32.8)

alfalfa 30 % ‑‑‑

peanuts ‑‑‑ 24 %

soybeans 7 % 13 %

cotton 7 % ‑‑‑

wheat ‑‑‑ 6.0%

corn and sorghram 1 % 2.5 %

_________ _________

Total Crops 5 to 10 % 10 %

According to Walter Heck, Chairman of the National Crop Loss Assessment Committee

(EPA), total crop losses in the U.S. due to ozone are over $5 billion per year(20.5,20.6). A

study by Cornell University researchers estimated total U.S. crop losses due to air pollution at

over 12% per year and over $6.5 billion.

Similar studies by agricultural researchers at North Carolina Univ. estimate U.S. Crop losses of between $5 billion and $10 billion annually(50). Major crop losses due to ozone are also being seen in other countries such as China and threaten agricultural self sufficiency of those countries(50).

31. There is a strong influence by relative humidity level on internal pollutant uptake of sulfur

dioxide and ozone by plants or crops such as soybeans. For the same exposure level, vegetation growing in humid areas experience a significantly greater internal flux of pollutants than that in more arid regions(24). Florida is especially susceptible to plant damage by air pollutants because of its humid climate.

Materials Damage

32. According the EPA, Acidic deposition‑related damage to both functional items and

monuments represents a very large economic cost to society(32.3,32.4). Research for the

NAPAP study found that between 31 to 78 percent of corrosion of galvanized steel and copper

is due to wet and dry acidic deposition, depending on region and atmospheric conditions(32.3).

Sulfur dioxide is a significant factor in corrosion time of copper, aluminum, zinc, and galvanized

steel(Lipfert et al, 12). Total annual costs for acidic damage to car finishes appear to be from

$100 million to $850 million(32.4).

Stone and masonry is susceptible to damage by acidic pollutants through chemical reactions with calcium carbonate. This produces accelerated decay of stone buildings, masonry buildings,

bridges, monuments, etc. from acid deposition. Acidic pollutants also chemically attack paper,

textiles, leather, photographic materials, etc. and cause increased deterioration. Sulfur dioxide

also accelerates paint aging, especially for oil based paints (12 & 27.8 & 32.8,32.3).

33. Acid fog(or humid acid air) in urban areas is becoming a serious problem. The PH of urban

fog is often much lower than that of acid rain and has been measured as low as 1.7 in some

urban areas. Acid fog or acid air in humid areas has been found to often be between 10 to 100

times more acidic than acid rain in the same area. Acid fog has significant adverse effects on

materials, health, and plants(19,34,5).

34. Four major car importers have moved their import operations from Jacksonville due to acid

rain damage to paint finish of cars(World Cars/BMW, Hyundai, Saab, and Peugeot).

Jacksonville Electric Authority and the Port Authority are being sued for millions of dollars by

the importers for damage to car finishes (5.5).

Cost/Benefit Estimates

35. A joint study by the U.S. Army Corps of Engineers, the Brookhaven National Laboratory,

and EPA estimated the damage to buildings alone done by acid rain in 17 northeastern and

midwestern states as over $6 billion per year. The study concluded an acid rain control program would probably pay for itself just in reduced damage to building materials and paint finishes alone(21). H.L. Magaziner testifying before Congress for the American Institute of Architects indicated that corrosion costs are high and are several billion dollars per year(20.7)

A Midwest Research Institute study estimated acid deposition damage to paint surfaces as over $35 billion per year(27.2). Scholle (27.8) summarizes a study by F.H. Haynie in which Haynie estimates the damage to zinc coated transmission lines as between .0028 mills and .0132 mills per kwh transmitted. A study published in the journal: Material Performance estimated damage to metal buildings and structures at over $2 billion per year(30.3).

36. A Congressionally funded 1985 study on air pollution effects on 4 major

crops(soybeans,peanuts,wheat,corn) estimated that air pollution is costing farmers between 2

and 3 billion dollars per year(32.8). For example average peanut yields were found to have

been reduced by 24% due to air pollution. Similar levels of reduced yield have been found for

tomatos in some areas. A study with similar level of crop damage due to ozone was published in Science in 1987. A more recent EPA study put the cost at over $5 billion per year(20.5), and a study by researchers at Cornell Univ. put the cost at approximately $6.5 billion (6.5). Other

studies summarized in (37) have estimated air pollutants damage to forests and lakes in the Eastern U.S. as over $ 7 billion per year.

37. Visibility impairment due to sulfate haze impairs civilian and military air traffic, as well as the scenic view in National Parks and recreational areas(25.6). A committee of the National

Academy of Sciences estimates that sulfate contribute approx. 65 % of the visibility impairment

in the east, and results in a significant economic cost. Haze curtails or slows commercial, military, or private air traffic from 2% to 12% of the time in summer(32.8). The National Park Service estimates tourist related losses due to visability impairment at over $6 billion per year.

38. An American Lung Association Study in 1988 estimated health costs and lost work

productivity due to acid rain pollutants at over $40 billion per year(25.7). A study commissioned

by Los Angeles officials found that air pollution related health costs and lost work productivity in the Los Angeles area are over $10 billion per year(21.5). A study commissioned by the Clean Air Coalition in 1985 estimated annual environmental, materials, and health damage at over $50 billion per year in the U.S.

39. A recent EPA report estimated that the economic damage from sulfur dioxide emissions was between $490 to $728 per ton of emissions(33.1). Another EPA report estimated the cost of small particulate matter(under 10 microns) at $2400 to $9000 per ton of particulate emissions.

This would yield a cost in Florida based on Florida emissions and the most conservative EPA

estimate of approximately $500 million per year for sulfur dioxide emissions alone. The EPA

studies and a study by Olav Holmeyer(19.7) for the Commission of European Communities

found that the uncounted "societal cost" of unscrubbed coal power production are almost as

much as the direct cost that is typically considered in energy policy decisions. Holmeyer's estimates for the range of damages from sulfur dioxide was between .3 to 1.6 cents per kwh and for nitrogen oxides was between .35 to 1.8 cents per kwh. An assessment by the New York Public Service Commission put the societal economic cost of coal power at 1.4 cents per kwh (26.7).

40. Alex Radin, Executive Director of the American Public Power Association(APPA) says that

"APPA believes that equitable acid rain controls are warranted." If unchecked, sulfur dioxide

emissions will increase 5 million tons over 1980 levels to 31 million tons by 2000. Nitrogen

emissions would increase nearly 3 million tons to 20.7 million tons. Reductions in emissions will force increases in electric rates of from 2.6% to over 5% for the 11 most effected states.

Assuming use of technologies available today, control costs for the bill with the most

current support would be between $2.6 billion and $5 billion annually.

Use of new technology will likely lower this cost.

41. "OTA's analysis of acid deposition and other transported air pollutants concludes that these substances pose substantial risks and costs to American resources." "Any program to reduce emissions significantly would require 7 to 10 years to implement, and perhaps longer for major impacts on the problem(32.8).

42. Based on studies and evaluations performed by Staff of the New York Public Service

Commission, the New York PSC uses a cost of 1.405 cents per kwh in policy and bidding

procedures as the environmental cost of standard coal plants with a defined set of emission

rates and other impacts(26.7). Technologies with lower emission rates or impacts get assigned

proportionately lower environmental costs. Of the above total .905 cents is related to air

emissions‑ with .25 cents for sulfur dioxide, .55 cents for nitrogen oxides, .005 cents for

suspended particulates, and .1 cents for carbon dioxide. Only 20 % of the full carbon dioxide estimate of .5 cents per kwh was included for official purposes due to controversy over the impacts of global warming. The other .5 cents per kwh recognized the higher land and water impacts of coal plants due to coal piles, coal handling facilities, and ash disposal.

43. The California Energy Commission staff performed a study of atmospheric pollution and

abatement cost for the South Coast Air Basin in Los Angeles. Out of an estimated total external cost for coal plants of 7.85 cents per kwh, 3.53 cent was for sulfur dioxide, 3.56 cents was for nitrogen oxides, and .76 cents was for carbon dioxide(10.3 &19.9).

44. The Wisconsin Public Service Commission and Northwest Power Planning Councils use

adders of 15% and 10% respectively for environmental and health costs when comparing coal

plants to conservation or alternative energy options(19.9).

45. A 1989 study of Schelberg estimated a total external environmental/health cost of 2.71 cents

per kwh‑‑ of which 0.31 cents was for sulfur dioxide, 0.83 cents was for nitrogen oxides, and

1.58 cents was for carbon dioxide(19.9).

46. Estimates of the societal cost of increased health care expenditures, environmental

degradation, and lost employment due to atmospheric emissions range from $100 billion to

$300 billion per year(19.8).

47. Even before the Persian Gulf War, the U.S. Department of Defense was spending at least

$20 billion per year to safeguard oil supplies in the Persian Gulf area. This amounts to a cost of

at least $20 per barrel of oil imported to the U.S. from the Middle East, and is a subsidy of a

lower price of oil both in the U.S. and abroad(19.8). Other hidden tax credits and subsidies

keep oil and gas prices low in the U.S. and encourage overuse; energy imports are the major

factor in the U.S. balance of trade deficits which have made the U.S. the worlds' greatest debtor nation. The U.S. has more tax credits and much lower taxes on fuel than our major foreign competitors.

48. A recent Pace University study of the societal costs of generating electricity commissioned

by the U.S. Dept. of Energy estimated the societal cost of sulfur dioxide emissions as over

$4000 per ton(26). Their estimate of the total societal cost of a wide variety of electric

generating options is given in Table 1. The study also points out that 20 states have required

utilities to include environmental externality costs in some manner in planning, bidding, or other resource acquisition procedures, and at least 9 more state have current formal processes considering inclusion of such cost. Table 2 combines the Pace Univ. study societal costs with estimates of variable production costs for the different plant options to give estimates of total societal operating costs(6.2).

49. A study by D.L. Block of the Florida Solar Energy Center developed estimates of the direct

environmental and health cost of emissions by utilities in Florida. The estimate of the composite cost of emissions was 2.0 cents per kwh(6.3).

50. EPA estimates that the average cost to utilities of reducing sulfur emission levels under the

CAA is about $240 per ton, but that the marginal cost of additional sulfur reductions would be

about $500 per ton(32.3). The estimated average cost for Florida was estimated to be $272

per ton. EPA estimates that the application of low‑NOx burners to reduce nitrogen oxide emissions in dry bottom wall fired and tangentially fired boilers would be about $159 per ton(32.3).

NOx Removal Cost(45)

Technology Capital Cost($MM) $/Ton NOx Removed

Gas Reburning(N.G. at $2.68/mmBtu) 5.1 $590

Coal Reburning 17.4 $520

SNCR(50% urea solution at $.50/gal) 2.7 $710

SCR(Anh.Am. at $162/ton and catalyst 12.9 $590

replacement at 3 years at $350/cu ft

CAIRE combuster for cyclone units 17.6 $267

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(20.7) H.L. Magaziner, American Institute of Architects, testimony in (22.4).

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edits(1.5,55,58-71)[see 56,57 in work version] (this is best version of references)