Only days after EPA’s science advisors reiterated their stance that EPA had ignored science (and the science advisors) in proposing unsuitably weak new standards for particle pollution, another shoe has dropped.
And it’s a big foot.
The National Association of Manufacturers is rallying corporate opposition to any change in the current standards. The powerful manufacturing lobby is urging member companies to contact EPA and argue that new standards “will impose significant burdens on my company.”
NAM also urges that companies make a truly bizarre argument – that tougher new standards could “undermine” existing requirements, including those involving diesel engines and electric power plants. (Actually, tougher standards would underscore that additional cleanup needs to be done to protect people’s health.)
The NAM attack appears to have been cobbled together rather hastily. You’ll note the NAM web site and the suggested letter both misspell the word “regulations.”
NAM Prosperity Project
Submit Comments to the EPA on Revised Fine Particulate Matter Regulations
On January 17, 2006, the EPA opened a 120 day comment period on a proposed revision to the agency’s National Ambient Air Quality Standard (NAAQS) for fine particulate matter (PM 2.5). Among the regulatory proposals include scenarios whereby the current standard would become more stringent, thereby increasing environmental compliance costs and adding to a climate of business uncertainty. Ironically, the EPA has not yet completely implemented the current standard for PM 2.5 and therefore has an incomplete picture of air quality and public health goals that it would like to achieve by issuing a new standard altogether. The NAM is opposed to the EPA’s proposals that would lead to a stricter PM 2.5 standard and advocates keeping the current standard in place. Final comments are due April 17, 2006.
We have included draft comments for your use. Please add your own comments to the following letter to help better explain how the added cost of more stringent regualtions will affect your business and employees. To submit comments to the Environmental Protection Agency, simply fill out the information below and click "Continue." Draft comments will appear that you may edit and then send to the EPA.
[HERE IS THE NAM SUGGESTED LETTER]
I am writing today to urge the Environmental Protection Agency not to impose a stringent, new National Ambient Air Quality Standard (NAAQS) for fine particulate matter (PM 2.5). This will impose significant burdens on my company, along with other U.S. manufacturers that are facing fierce international competition. These new regualtions being proposed do not make any significant contribution to the environment and public health.
The EPA should adopt the regulatory option of keeping the existing standard, which has not yet been fully implemented. The EPA's proposal is bad policy because it is not grounded in sound science, and changing the standard now would create investment and business uncertainty.
The Bush Administration has already issued a number of rules that will make significant strides toward reducing emissions of PM including the Clean Air Interstate Rule (CAIR) to reduce emissions from power plants in the eastern United States, and the Clean Diesel Program to reduce emissions from highway, non-road and stationary diesel engines. We believe that an untimely revision of the PM 2.5 standard could undermine these already existing rules.
Although the Clean Air Act requires the EPA to periodically review air quality standards to ensure they provide adequate health and environmental protection, it does not mandate that such a review result in revision of an existing standard.
If you have any questions regarding these comments, you may contact me at the address below.