US EPA Proposes New Particulate Standard for PM2.5

Hearing on Proposed Standard will be held July 19, 2012 in Sacramento, CA

The EPA is proposing to strengthen the national ambient air quality standards (NAAQS) for fine particulate matter (PM2.5). The current annual primary (health) standard for PM2.5 is 15 micrograms per cubic meter (?g/m3). This standard was set in 2006. EPA is now proposing to lower the standard to between 12 and 13 ?g/m3 and is also considering comments on lowering the annual average to 11 ?g/m3. EPA is proposing to retain the current 24-hour daily standard for PM2.5 and daily standard for PM10. EPA is also proposing to create a new secondary 24-hour standard for fine particulates to protect and improve visibility.

In addition, EPA proposes changes to the ambient air monitoring, reporting, and network design requirements associated with the PM standards. This would include the addition of a "Near-road" component to the PM2.5 monitoring and compliance network.

EPA has scheduled two public hearings on the proposed PM standards, July 17 in Philadelphia, Pennsylvania and July 19, 2012 in Sacramento California. Anyone wishing to make oral comments at the hearings are instructed to notify Alan Rush at rush.alan@epa.gov (preferred method for registering) or (202) 564-1658. To view the Federal Register announcement for information about the public hearings go to http://www.gpo.gov/fdsys/pkg/FR-2012-07-02/pdf/2012-16045.pdf. EPA's website for the regulatory actions on Particulate Matter including the new proposed standards is http://www.epa.gov/pm/actions.html. The deadline to submit written comments is August 31, 2012.

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The Construction Industry Air Quality Coalition (CIAQC) does not believe EPA has adequately demonstrated the need to the lower annual primary PM2.5 standard and will offer the following recommendations at the July 19 public hearing in Sacramento.

First, EPA needs to stop and reassess its PM2.5 strategy. There is no need to change the standard at this time. If there is conclusive evidence of premature death attributable to PM2.5 in other regions of the country such as the “rust belt” as some of the data may show, then they should adopt a standard for that region only, once they figure out the cause.

Second, they need to restore the integrity of their scientific review process. EPA risk assessments should be peer reviewed by an independent body, not agency staff. Including all the available studies on a given topic under their consideration would also be an important step in restoring the agency's scientific credibility. Excluding studies that disagree with their preconceived notion does not make the science settled.

Third, EPA needs to consider variable standards only where real health impacts are identified. If impacts are identified in a particular region, a special standard may be required. It is time to move away from the one-size-fits-all mentality and approach.

Fourth, the cost/benefit analysis process needs to be redone. The health benefits are always inflated or improperly calculated and the compliance costs are always underestimated. An honest assessment by an independent source, publicly reviewed and critiqued would also restore credibility to the process. This should be done before the standard setting process is initiated to ensure that the standards actually match the benefits.

Finally, EPA should not accept studies where the underlying data is not available for independent review and confirmation. Drawing research conclusions and saying “trust me, that’s what the data shows”, then refusing to make the data publicly available should disqualify the research from being used for regulatory purposes. The stakes are too high for anything less than a fully transparent process.

The Construction Industry Air Quality Coalition is going to vigorously pursue these recommendations at the EPA’s California hearing. You can also submit comments directly to EPA (commenting instructions). Visit the CIAQC website, www.CIAQC.com for updates and more information.

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