September 11th Terrorist Attacks on New York City

February 11,2002

Good morning Chairman Lieberman, Senator Clinton and members of the Subcommittee, my name is Eric A. Goldstein and I am the director of the New York Urban Program at the Natural Resources Defense Council, Inc. ("NRDC"). NRDC, as you know, is a national, non-profit legal and scientific organization active on a wide range of environmental issues, including urban air quality. Since shortly after its founding in 1970, NRDC has placed a special focus on the New York region's environment and the quality of life of city residents. We are especially grateful to you for convening this hearing and for your continuing interest and dedication to safeguarding air quality and environmental health in New York.

In the aftermath of the September II th tragedy, my NRDC colleagues Megan Nordgren, Mark Izeman and I began collecting data and conducting interviews as part of year-long study of the environmental impacts of the World Trade Center attacks and government's response to the problems identified. Weare releasing a preliminary version of that study this coming Wednesday, and would ask you to consider incorporating this full document into the hearing record. This morning I will briefly make three points and propose four recommendations for action by this Subcommittee to help address air quality problems in the wake of the Trade Center disaster.

First, it is important to state what is widely known to anyone who lives or works in the vicinity of Ground Zero --the September 11 th attacks, in addition to the horrific loss of human lives and huge economic dislocations, constituted an unprecedented assault on Lower Manhattan's environment. The collapse of the 110 story towers, the conflagration of vast amounts of toxic materials, the forceful distribution of debris and dust, and the long-burning fires at Ground Zero combined to create what was unquestionably the single largest air pollution episode in the history of New York City. NRDC's report estimates that at least 10,000 New Yorkers suffered short-term respiratory and other pollution-related impacts from the Trade Center's collapse and subsequent fires. Thousands of apartments and offices in the immediate vicinity ~- Ground Zero received significant loadings of polluted dust --everything from asbestos to fiberglass to pulverized cement to, in many cases, metals and other toxic substances.

There is, of course, much we do not yet know about the air quality impacts from the September 11 th attacks. That is why the health studies now being undertaken by distinguished medical institutions like Columbia University's Mailman School of Public Health and Mt. Sinai's Selikoff Center for Occupational and Environmental Medicine, as well as similar work at New York University's Nelson Institute of Environmental Medicine, is so important.

But here in most condensed fashion is what we can say about air quality right now. In general, outdoor air quality in lower Manhattan today is approaching or similar to levels in this area prior to September 11th, with the exception of the Ground Zero work-pile and localized hot spots, such as areas with heavy concentrations of diesel equipment or vehicles and, at times, areas where Trade Center debris is being moved or transferred to barges. The most worrisome air pollution problem facing Lower Manhattan now involves indoor pollution threats in some residences and offices that were engulfed with thick layers of contaminated dust and whose buildings were not properly cleaned.

In short, from what we now know, the bulk of the exposures have already occurred and the bulk of damage from the terrorist attacks has been felt. The air pollution challenges that remain are manageable and solvable. But, they exist and they shouldn't be swept under the rug.

Let me briefly turn to government's response to the environmental health challenge presented by the September 11th attacks. In many ways, the response of government agencies and their employees to the Trade Center attacks was heroic and a testament to the merits of public service, which is too often undervalued. Environmental and health agency staff performed many tasks with distinction. U.S. Environmental Protection Agency personnel, for example, undertook numerous assignments including the removal of hazardous waste from the Ground Zero site, the deployment of HEPA vacuuming trucks for collection of dust layers from city streets, and the establishment of sophisticated air monitoring and testing facilities. But when one closely examines the governmental response to air pollution impacts from the collapse of the Trade Center Towers and the subsequent fires, a more complicated picture emerges.

One major problem was overlapping jurisdiction among at least nine city, state, and federal agencies, which meant that no single agency was in overall charge of the environmental aspects of the response to the September 11th attacks in New York. For example, no agency took the lead in insuring environmental safety for those working at Ground Zero. And no agency took affirmative charge of the environmental clean-up and inspection of environmental conditions prior to re-occupancy of residences and office buildings that were coated with debris and pollution. Many such problems, NRDC believes, resulted from shortcomings by the Giuliani Administration, which handled so many other aspects of the September 11th response magnificently and which was in tight, overall command of the entire rescue, recovery and clean-up effort. And the low profile of the City's Department of Environmental Protection -- the 6,000 person department with wide-ranging New York City Charter duties to respond to environmental emergencies -- lends support to the growing belief the department, for whatever reason, did not rise to the challenges posed by the September 11th attacks.

A second major problem involved communicating environmental health information to the public. There appeared to be no coordinated strategy for conveying such information to concerned citizens, no regular briefings by governmental leaders of environmental or health agencies, and no one place for citizens to turn for environmental guidance and advice. Moreover, government statements on air quality, at least as the public understood them, stressed the good news and de-emphasized issues that might raise further concerns. By focusing almost exclusively on long-term risks in their public statements, government officials omitted warnings regarding short-term health effects, particularly to Ground Zero workers and other sensitive sub-groups. Admittedly, government agencies had a very difficult assignment here, and were responding not to an industrial accident but an unprecedented act of war. Nevertheless, as a result of shortcomings on the communication front, a troubling credibility gap on environmental health issues emerged.

A third difficulty, and one of continuing concern, has been environmental safety shortcomings at Ground Zero. While the rescue, recovery and site clean-up operations have made remarkable progress under exceptionally challenging circumstances, the way environmental health issues have been handled represents a glaring exception to this post- September 11 th record of accomplishment. A prime example has been the failure to require Ground Zero workers to wear appropriate respirators. The OSHA representatives -- who will be speaking later and who will probably state that they were only at Ground Zero in an advisory capacity and did not or could not insist upon the wearing of respirators by the Ground Zero work force --certainly have some explaining to do. Among other on-site safety problems of significance were undue delays in establishing worker safety training procedures.

A final shortcoming in government's environmental response to the Trade Center attacks involves problems assisting Lower Manhattan residents on environmental safety and clean-up issues. In addition to the previously stated communications gaps, city agencies failed to provide complete and proper clean-up protocols to many Lower Manhattan residents and failed to inspect even the most heavily contaminated buildings for environmental safety, prior to re-entry. Once again, no agency took overall responsibility for supervising the environmental clean-up and safe re-occupancy of apartments (and office buildings) immediately surrounding Ground Zero. It was left, for the most part, to residents and building managers to sort these complex challenges out for themselves.

Let me conclude by listing four of the recommendations contained in the forthcoming NRDC World Trade Center report, on which we believe this Subcommittee could be most helpful:

1) Urge the New York City Department of Environmental Protection and the U.S. Environmental Protection Agency (with whatever other agencies they deem appropriate) to: (a) create an Air Pollution Assistance Center located in the Ground Zero vicinity, fully staffed with a range of government personnel who could provide one-stop advice for local residents and office workers, and (b) create a Joint Task Force that will promptly begin door-to-door visits to and inspections of individual buildings, to verify environmental conditions, at least in the immediate ring of buildings within a ten-block radius of Ground Zero;

2) Prod the Occupational Safety and Health Administration and relevant New York City officials to commence without further delay enforcement of environmental safety rules at the Ground Zero work site;

3) Assist medical institutions, such as those listed above, in securing monies for public health studies, and help obtain funds for a full health registry of all Lower Manhattan residents and workers who may have been affected by pollution in the aftermath of September 11th, and

4) Consider convening a second hearing this spring to review whether federal Clean Air Act pollution standards and/or pollution monitoring requirements for New York need revision in the wake of lessons learned from the September 11th tragedy.

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Thank you very much for inviting NRDC to testify at this important hearing. We stand ready to assist this Subcommittee in addressing the air quality impacts of the World Trade Center disaster in any way we can.