The U.S. Environmental Protection Agency (EPA) on March 8 began conducting hearings across the country on federal particulate matter (PM) standards. The hearings follow EPA’s December 20 proposed major revisions to its National Ambient Air Quality Standard (NAAQS) for fine particulate matter (PM2.5).
The proposed revisions would take place prior to full implementation of the current PM2.5 standard, which was established in 1997, and would take effect before the effectiveness of recent tools developed to help states meet the NAAQS has been assessed.
Standards Recently Toughened
PM2.5 describes any particle–including dust, dirt, soot, smoke, and liquid droplets–smaller than 2.5 micrometers in diameter (approximately 1/30th the width of an average human hair). These particles, detectable only through a microscope, come from a variety of domestic and foreign sources, and their regulation requires standards that are narrowly tailored and exceedingly complex.
Since 1997, EPA has treated PM2.5 as a single pollutant regardless of its source or chemical composition. During the Clinton administration, EPA adopted two different standards for ambient amounts of PM2.5: an annual average limit of 15 micrograms per cubic meter (µg/m3) and a daily limit of 65 µg/m3. When developed in the mid 1990s, these standards were widely hailed by the environmental community for significantly strengthening EPA’s air quality programs. Recent evidence shows they have been even more successful than originally predicted.
Owing to the complexity of the issue, it has taken EPA eight years to implement the standards. During that time EPA developed a suite of tools to help ease the burden of regulation, including the Clean Air Interstate Rule and a plethora of mobile source standards.
Activists Not Satisfied
Despite the acclaim offered for the 1997 standards, environmental organizations want more regulation, and in 2003, the American Lung Association filed a lawsuit to compel revision of the 1997 NAAQS. Due to the stringency of the 1997 standards, local communities expected to experience difficulties in achieving them, but rather than defend its ongoing efforts, EPA signed a consent decree agreeing to consider major revisions of the PM2.5 NAAQS, thereby placing affected parties in a position of further uncertainty.
To change the PM2.5 NAAQS at this point–without providing any opportunity to observe how the current standard affects human health and the economy–is seen by many analysts as unreasonable.
Economic Impact Deep
EPA’s new proposal would lower the daily exposure standard for PM2.5 to 35µg/m3, making it nearly 50 percent more stringent. This reduction will force new areas of the country onto EPA’s non-attainment list. Affected local economies will be subjected to costly economic sanctions, including loss of federal highway funding, new and costly permitting requirements, and increased enforcement actions and regulatory micromanagement by EPA.
In addition, EPA’s proposal will result in higher prices for basic goods and services. For example, consumers will pay more for gasoline as the number of boutique fuel mandates expand and fuel prices are raised across the board to cover increased costs. These price increases would disproportionately affect the poor and elderly.
Nonetheless, environmentalists are not applauding EPA’s announced approach to ratchet down emissions standards and expand the agency’s regulatory reach. Instead, the environmental community has expressed outrage at EPA’s proposal, calling it a “gift to polluters” and a maintaining of the status quo. Many are demanding changes to the NAAQS that would push virtually every single state into non-attainment.
Problem Imaginary, Solution Costly
Environmentalists’ demands and the increased costs of complying with EPA’s new standards might be reasonable if they were convincingly justified by scientific knowledge. However, there is no firm scientific support on the record for EPA’s action. As researchers continue to look into the associations between PM2.5 exposure and human health, their studies, when uncertainties are taken into account, fail to find any firm correlation between health problems and the levels of PM2.5 exposure that EPA is targeting.
Taken as a whole, EPA has made great progress to date in addressing health threats from PM2.5. The U.S. Chamber and other stakeholders contend EPA should avoid disrupting its current programs and wait until adequate time has passed to judge their effectiveness and their impact on human health. Any further regulatory actions beforehand, these organizations say, are premature.
William L. Kovacs ([email protected]) is vice president of the U.S. Chamber of Commerce Environment, Technology, and Regulatory Affairs Division.
