Multipollutant Air Quality Management G. M. Hidy and W.T. Pennell Comment

1. Multipollutant Air Quality ManagementG. M. Hidy and W.T. PennellComment Allan H. Legge PhD. President Biosphere Solutions Calgary, Alberta ACE 2010 Critical Review , June 23, 2010

2. QUESTION • Is it responsible to propose that a multi-pollutant risk analysis methodology can be developed and could evolve from current air quality regulations/legislation that would be able to address multiple pollutants and multiple effects when the primary emphasis is on adverse effects on human health?

3. FUNDAMENTAL CONCERNS • Primary emphasis on human health when one must consider the environment as a whole • Assumption that the effects on receptors of exposure to multiple pollutants are ‘only’ additive when it has been documented that responses can be ‘antagonistic’ (less-than-additive) or synergistic (more-than-additive) [Fangmeier et al. 2002] • Air quality management including regulations/legislation have been ‘operationalized’ and ‘institutionalized’ to the point where the process of air quality management is more important than the reason for air quality management. • Scientific knowledge and understanding of the environment is inadequate

4. Definition of Clean Air • “Clean air” is represented by air that is essentially odorless, tasteless, looks clear and has no measureable short- or –long term adverse effects on people, animals and the environment. (Legge et al. 1992)