Testimony July 12, 2023

Testimony to the NYC Council Hearing on the City’s Response to Poor Air Quality Events

Thank you for the opportunity to submit testimony on behalf of the 5BORO Institute — a think tank dedicated to advancing innovative and implementable solutions to tackle NYC’s most challenging problems. In our testimony, we aim to highlight innovative initiatives that the City should pursue to prepare against and respond to future air quality events. The strategies we recommend include initiatives that city governments across the world have successfully been taking in the face of air quality emergencies.


One month ago, New York City was engulfed in smoke from the over 400 wildfires raging across Canada, with New Yorkers experiencing the worst air quality of any city in the world at the time. Some areas in the city recorded an Air Quality Index (AQI) as high as 484, well above the 100 AQI threshold designating unhealthy conditions. 

The impact of wildfire smoke on public health is a critical concern. NYC Health + Hospitals, the city’s public system, saw an uptick in patients with respiratory symptoms in some of its emergency departments during the city’s poor air quality days. Lower-income, mostly Black and Hispanic communities, represented a disproportionate share of asthma-related emergencies in the city. 

Wildfire smoke is composed of fine particulate matter (also called PM2.5), which are minuscule enough to penetrate deep into the lungs and flow into our bloodstream. Particulate matter is the largest environmental health risk in the nation, responsible for 63% of deaths from environmental causes. A 2010 assessment from the NYC Department of Health and Mental Hygiene estimated that each year, PM2.5 pollution in New York City caused more than 3,000 deaths, 2,000 hospital admissions for lung and heart conditions, and approximately 6,000 emergency department visits for asthma in children and adults.

Short-term exposure, in the range of hours to days, can cause immediate issues such as premature mortality, increased hospital admissions, acute and chronic bronchitis, asthma attacks, emergency room visits, and respiratory symptoms like coughing and irritation. Long-term exposure can result in reduced lung function and premature death, particularly in people with pre-existing conditions. Seniors, children, and residents of environmental justice neighborhoods that are historically underserved are also particularly at risk.

During June’s air quality emergency event, many New Yorkers, including public servants and city workers, expressed their discontent with the City’s response and shared that the smoke-filled skies seemed to catch our city off guard. In the subsequent air quality event in early July, the City took some more proactive measures to alert and prepare the public. 

With climate change, wildfire frequencies are projected to continue rising, suggesting that similar events are likely to occur again. Given the negative health impacts associated with poor air quality, the City must prepare to protect New Yorkers in the face of future air quality threats — especially our most vulnerable residents, including children, seniors, outdoor workers, residents with pre-existing conditions, and New Yorkers who are impacted by environmental justice inequities.


During periods of wildfire smoke and on poor air quality days, the City should implement measures to improve air quality levels, reduce health risks, and help New Yorkers better prepare for such events. The City should work with public health experts to establish tiers of AQI thresholds that trigger a set of compounding response actions to protect New Yorkers. This includes taking action to prevent additional air pollution, reduce New Yorkers’ exposure to harmful air pollutants, and advance education, outreach, and preparedness. We highlight potential strategies to address each of these actions below:

1. Prevent additional air pollution 

While up to 40% of the fine particulate pollution in New York City’s air comes from areas upwind of the city, the rest of the pollution comes from the five boroughs. In-city pollution primarily comes from fuel combustion in vehicles, trucks, buildings, and industrial uses. During extreme air quality days, the City should aim to limit the pollution it generates to prevent worsening air quality and associated health risks, including with measures to:

Reduce vehicular traffic

Every year, motor vehicles generate over a tenth of the fine particulate pollution in the air in NYC. Vehicle emissions can have significant health impacts, with more than 2,000 New York State residents estimated to have died prematurely in a single year from its effects. Since vehicles are significant sources of air pollutants, reducing the number of them traversing our roads during bad air days could help mitigate New Yorkers’ exposure to polluted air. NYC took some action in line with this principle during the June emergency, by canceling Alternate Side Parking during the height of the poor air quality to limit idling, traffic, and New Yorkers’ exposure to the ambient air.

Many other cities worldwide have implemented policies to further restrict traffic on poor air quality days. One example is the No-Drive Day program in Mexico City. This program restricts the use of private vehicles on different days of the week based on their license plate numbers, with exemptions for vehicles including emergency vehicles, vehicles registered for people with disabilities, and electric and hybrid vehicles. Another example is Delhi’s Graded Response Action Plan. This is a set of emergency measures implemented in the Indian region to curb air pollution. When the AQI exceeds 450, measures include restrictions on truck entry and bans on certain vehicles and industries.

Limit unnecessary construction and City pollution sources

Dust and debris from construction can add additional coarse particulate matter to the air and exacerbate respiratory illnesses. The City has enacted regulations to limit dust emissions from construction-related activities, but to reduce the risks posed by poor air quality to construction workers working outside and to limit the amount of construction pollution generated, the City should also pause its non-critical construction work on the most severe air quality days. As a part of its Graded Response Action Plan, Delhi halts all construction activities on the worst air quality days.

The City should also consider similar measures when possible for garbage collection. Garbage trucks in NYC emit high levels of pollutants, particularly worsening the air quality in neighborhoods near waste transfer stations. Like construction workers, sanitation workers also work outdoors and are at higher risk of exposure to ambient air pollution. To address this issue, the City of Philadelphia paused garbage collection and road repavings during the height of the air pollution last week to protect its employees and residents. 

Discourage grilling or gas appliance use 

The City should inform the public of the risks of exposure to additional pollution from grilling and cooking, both outdoors and indoors. Outdoors, grilling or barbecuing can emit air pollutants, making it evident that taking steps to discourage these methods on bad air days can reduce an individual’s risk. The City should also do direct outreach to street vendors with guidance to exercise care, since they are directly exposed for extended periods of time to both bad ambient air quality and pollution generated by their gas or diesel grills.

Indoors, appliances like gas stoves add additional harmful air pollutants, like particulate matter and nitrous oxides, that can exacerbate the health effects of wildfire smoke. Children living in households with gas stoves are 42% more likely to have asthma, and gas burners and ovens increase indoor nitrous oxides to levels that surpass EPA outdoor standards. Regardless of the type of stove, cooking methods like char-broiling, burning food, and cooking with low-smoke point oils can further add air pollution. During bad smoke days, the City should encourage at-risk residents to limit cooking times, use cooking methods that limit air pollution, and whenever possible, use range hoods that vent outdoors.

2. Reduce New Yorkers’ exposure to harmful air pollutants

Staying indoors and following certain precautionary measures can reduce an individual’s exposure to wildfire smoke. During days with severe air quality conditions, the City should proactively take measures to limit New Yorkers’ exposure to outdoor pollution, including with strategies to:

Establish Clean Air Centers

To mitigate heat-related illnesses or fatalities during extreme heat events, the City operates cooling centers in air-conditioned public facilities. Drawing from this approach, the City should establish Clean Air Centers as well, providing New Yorkers with safe havens during poor air quality days. The City should outfit libraries, museums, shopping malls, theaters, NYCHA community centers, schools and other spaces across the five boroughs with effective air filtration systems and resources for communities during air quality emergencies.

This has been a model commonly deployed across the west coast, where cities have been disproportionately affected by wildfire smoke. The State of California is outfitting over 300 public and private facilities like libraries and senior centers with ventilation system upgrades and portable air cleaners to create a statewide network of Clean Air Centers. In 2019, the City of Seattle began rolling out its Clean Air Shelter program, which upgraded community centers and hubs with HVAC and air filtration systems in advance of the wildfire season. 

Promote remote work and school options

During poor air quality days, the City should promote remote work for eligible public employees when feasible, and encourage private employers to follow suit by facilitating remote work arrangements. 

The City took some action on schooling during the June emergency, by cancelling outdoor school activities on Wednesday, June 7 during the worst of the wildfire smoke and offering remote schooling on Friday, June 9 (students were already scheduled to be off of school on Thursday, June 8 for what’s known as Anniversary Day/Chancellor’s Conference Day). 

In future air quality events, schools should proactively offer the option for students to stay home if their family circumstances allow and provide as early a notice as possible. It is important to recognize that many NYC parents are essential workers or do not have the flexibility for children to stay home during the day, so providing flexibility is key to ensure the safety of students. 

Provide shelter and direct outreach to New Yorkers experiencing homelessness

New York City enacts a Code Blue and Code Red weather emergency policy during days when temperatures plunge to extreme cold or rise to extreme highs, respectively. Under these policies, outreach teams actively check on people who live on the streets and in the subway more frequently and provide transportation to facilities. These policies also enable individuals experiencing homelessness to stay at shelters or drop-in centers without going through the normal intake process. 

Drawing from these existing protocols, the City should implement a similar system during poor air quality days to conduct active outreach and ease barriers to appropriate shelter to support New Yorkers experiencing homelessness. Other cities have taken alternative measures to protect unhoused residents. For example, Seattle opened temporary shelters to provide additional respite to people experiencing homelessness during wildfire smoke days.

Distribute appropriate masks

Respirator masks (commonly referred to as N95 or KN95 masks) can protect residents from wildfire smoke and air pollution. During the June emergency, Governor Hochul announced that approximately one million masks would be distributed across the state at transit centers, parks, and other facilities. The City also announced it was distributing masks the day following the peak smoke at select fire stations and police precincts. During the early July smoke event, the City was more proactive, announcing that they were distributing masks at these locations the day of the peak air quality impact.

Given the discomfort or distrust that many NYC communities have with police, the City should establish distribution points in facilities such as hospitals and libraries to effectively respond to smoke events and poor air quality days. The City should also focus on neighborhoods and communities that are disproportionately at risk of respiratory illness. Schools should also have masks ready to be distributed to staff and students. Given the proliferation of both reusable and disposable masks following the onset of the COVID-19 pandemic, the City should provide clear guidance to residents on which masks are effective against air pollutants.

Improve air quality in underground subway stations

The City should also advocate for the State to mobilize resources to improve air quality levels in our public transportation system, especially for underground subway stations. A NYU-led study found that NYC’s underground stations can have high concentrations of fine particulate matter. Pollution levels can climb further during poor air quality events, increasing underground pollution levels overall. During the June wildfire smoke emergency, researchers conducted air quality measurements in various subway platforms and found elevated AQI readings, including an AQI surpassing 1,000 in one PATH station. However, air quality improves significantly inside a train. 

Our subways are the life-blood of our city, with millions of daily riders. To protect the majority of New Yorkers who use transit to commute, the State should monitor air quality in subway stations and take appropriate measures to reduce levels of pollution underground. This could be done by installing more powerful ventilation fans or platform filtration systems.

3. Advance education, outreach, and preparedness

Given the risk of misinformation and New Yorkers’ need for clear guidance on safety practices, the City should develop a communication framework to properly inform residents on the best practices to adopt during poor air quality days. This may include taking action to:

Send out alerts and raise awareness on the impacts of poor air quality 

The public should be notified of poor air quality in advance whenever possible and receive regular up-to-date information. The City’s NotifyNYC program and Advance Warning System disseminates information and alerts to residents during emergencies and critical situations. Although the City released an air quality advisory alert on Monday, June 5 in advance of the poor air quality, only people that had signed up were notified. The City did not issue alerts through their own channels until the evening of June 7, after the AQI had already started to spike.

During the following air quality event in early July, the City was more proactive by sending out alerts and increasing awareness via social media one day in advance, a strategy they should continue to take for future events. For future air quality emergencies, additional strategies could include pushing a wireless emergency alert message sent to every NYC-area mobile device — similar to AMBER alerts. To serve NYC’s diverse population, these alerts should include links to information in different languages. The City should also utilize its partnership with LinkNYCs to deliver both real-time data and clear instructions about precautionary measures. During severe emergency events, the City could also consider using megaphones on police cruisers to deliver key messages on safety precautions such as closing windows — a measure it took to share safety information during the heights of the COVID-19 pandemic.

Ensure the preparedness of outdoor employers and workers

People with outdoor employment — such as employees working in sanitation, park maintenance, street vending, and delivery services — are particularly at risk of extreme pollution. Comprehensive safety guidelines should be provided to employers and their workers engaged in outdoor activities. 

The City should develop informative fact sheets, detailed health and safety plans, and potential trainings that outline specific measures and protocols to be followed. The State of California has created tailored resources for outdoor employers, and both Oregon and Washington implemented emergency rules for outdoor workers in 2021 to address wildfire smoke conditions.

Enhance emergency management readiness through proactive planning

NYC Emergency Management, the City’s emergency planning and response agency, provides resources to New Yorkers on how to prepare against various hazards, including extreme heat, building collapses, and terrorist attacks. The City should develop resources for poor air quality and smoke days, with tips and resources to plan for such events.

The agency also runs a number of programs to train the public and community groups on emergency preparedness. NYC Emergency Management should offer trainings on air quality and deploy trained individuals to provide resources to their communities during events. This includes adding air quality resources to its existing NYC Community Emergency Response Team (NYC CERT) program as well as its Community Preparedness program. The City should also deploy up-to-date guidance and alerts to leaders in community groups and faith-based organizations with best health practices and precautions to disseminate across their communities.

Advocate for federal climate resilience action

New York City should advocate for the federal government to develop a comprehensive national climate resilience strategy. Cities across the nation are already experiencing a wide array of climate impacts — including flooding, extreme heat, and wildfire smoke — and these symptoms of the climate crisis will continue to grow in scale and geography. In addition to the critical need to decarbonize our systems and advance a green economy, federal policy should help our cities be better prepared for a changing climate and its impacts. A comprehensive national climate resilience strategy could help to inform and shape the next generation of infrastructure, policies, and programs — such as natural disaster assistance, flood insurance, and coastal resilience projects — to set up frameworks to account for a changing climate and help protect cities and residents.

It is time for NYC to establish new policies to protect New Yorkers from poor air quality. With a warming climate and increasing climate threats — we must act now to prepare our city and all New Yorkers.