Joint Comments of ALA, ED, and NRDC on EPA’s Second Draft Staff Paper on PM, 3-31-05
The American Lung Association, Environmental Defense (ED), and the Natural Resources Defense Council (NRDC) have filed written comments on EPA’s second draft Staff Paper supporting more stringent air quality standards for particulate matter.
“EPA staff scientists are compelled by the clear evidence in the Criteria Document to propose strengthened primary and secondary air quality standards for fine particles, and set new standards for coarse particles. The EPA staff scientists’ recommendations to strengthen the level and form of the fine particle standards are well supported by the scientific evidence. The rationale used to derive recommended levels for the fine particle standards from the scientific studies are sound, and the analyses of the air quality monitoring data support more protective forms of the standards.” state the comments.
A consensus has emerged in the scientific and public health community that the current standards are clearly not protecting the health of Americans and must be strengthened.
The American Lung Association, ED, and NRDC strongly support lowering both the annual average and the 24-hour fine particle standards, while tightening the way compliance with the standards is measured.
Specifically, the comments favor:
• An annual average PM2.5 standard of 12 µg/m3 or lower, with no monitor averaging, coupled with a 24-hour PM2.5 standard of 25 µg/m3 or lower, 99th percentile. EPA’s ranges should be modified to accommodate this option;
• A 24-hour PM10-2.5 particle standard in the range of 25-30 µg/m3, 99th percentile and consideration of an annual standard; and
• A PM2.5 secondary standard to protect against urban visibility impairment of 20 µg/m3 or below, based on a 4-hour rolling average during daylight hours.
A full copy of the comments, including recommendations for strengthening the risk assessment, air quality analyses, and staff recommendations, are attached.
EPA must issue a final version of the Staff Paper by June 30, 2005.
Attachments
- Comments of ALA, ED, and NRDC on Second Draft PM Staff Paper
- 33005-final-comments-of-al.pdf
Joint comments filed 3-31-05
