NCBA Urges EPA to Reject Regulation Based on Flawed Science
WASHINGTON –The National Cattlemen’s Beef Association (NCBA) submitted comments to the U.S. Environmental Protection Agency (EPA) in opposition to flawed science behind EPA’s review of the National Ambient Air Quality Standards (NAAQS) for Particulate Matter (PM). The comments were submitted in response to EPA’s 2nd Draft Integrated Science Assessment (ISA) that appears to lay the foundation to set the coarse PM (i.e. dust) standard at levels of 12-15 ug/m3—1/10th of the current standard.
“Under the 2nd draft ISA, dust would be regulated below naturally occurring levels in much of the West, including pristine national parks,” said Tamara Thies, NCBA chief environmental counsel. “EPA must fairly and carefully evaluate coarse PM health evidence before proceeding forward.”
Coarse PM is nothing more than the dust kicked up by cars or trucks traveling on dirt roads or a tractor tilling a field, and has long been found to be of no health concern at ambient levels. Because of the high dust levels found in the arid west, many critical western industries have a difficult time meeting the current NAAQS, even with use of best management practices to control dust. Both existing and new sources of coarse PM, including agriculture sources, would be affected by EPA’s decision. For parts of the country having trouble meeting the current PM standard, EPA has proposed “no-till” days for agriculture. New sources of coarse PM emissions would simply not be allowed—forcing producers to cut back on their operations.
“This standard is virtually unattainable for vast areas of the country, especially in the West,” said Thies. “It would effectively bring economic growth and development to a halt.”
EPA’s NAAQS review is required every five years under the Clean Air Act. EPA is not allowed to consider economic impacts in its decision-making process once the science document has been finalized. In the latest draft of the document (July 2009), EPA relies on a flawed study—and reinterprets studies it had previously labeled as “inconclusive”—to conclude that there is evidence of adverse health effects from coarse PM at levels of 12-15 ug/m3.
NCBA’s comments were submitted jointly with the National Mining Association, Newmont Mining Corporation and the Western Business Roundtable.