Comments on Behalf of Industry Trade Associations on EPA’s Transition to New or Revised Particulate Matter NAAQS

The industry trade associations on whose behalf these comments are made are interested in revisions to the National Ambient Air Quality Standard (NAAQS or standard) for fine particulate matter (PM2.5) and the transition to any new revised standard for PM2.5. The diverse memberships of the various associations listed above collectively represent a large portion of the U.S. economy. While the comments below represent a consensus of these associations, many individual associations and their members will submit separate comments that will cover several of these issues in greater detail and/or topics that are not addressed herein.

Although we are providing comments in response to EPA’s recent request for input on possible approaches for the transition to a new NAAQS for PM, we continue to oppose EPA’s proposed reduction of the 24-hour standard for PM2.5 and the adoption of a coarse PM standard. As explained in detail in comments submitted on April 17, 2006, regarding EPA’s Proposed National Ambient Air Quality Standards for Particulate Matter, we believe that the proposal is not supported by the key epidemiological studies identified by EPA in the proposal or by new studies provided in the docket for the proposed rule. Our comments on this ANPR should not be viewed as a reversal of this position or any endorsement of EPA’s current proposal on revising the PM NAAQS.