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Howard Feldman's remarks at press briefing teleconference on PM standard

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Press briefing teleconference on PM standard 
Howard Feldman, API regulatory and scientific affairs director
Wednesday, December 12, 2012

Opening statement:

Good morning everyone. Thanks for calling in.

EPA’s proposed rule to tighten the national ambient air quality standards for fine particles, the so-called PM 2.5 standards, is now at OMB. We have a meeting with them shortly. Tightening the standards would have certain costs and doubtful benefits. We urge the administration to retain the existing PM standards.

We support keeping the standards where they are, not only because there is no compelling evidence for changing them, but because our current emission control programs implementing the existing standards are working and continue to reduce pollution levels.

According to EPA, between 2000 and 2010, concentrations of PM 2.5 fell by 27 percent nationwide. As a result, more than three-fourths of Americans today live in areas where air quality meets or exceeds today’s standards.

Moreover, looking forward and considering just control measures already proposed or being implemented under the current regulations, we could expect to reduce particulate pollution by more than one million tons annually (about 20 percent) in the next couple of years – and make steady progress further reducing the number of Americans living in areas exceeding the current standards.

The point is that before implementing new standards with questionable benefits and potentially high costs, we should give current regulations, including our cleaner fuels in cleaner vehicles, a chance to work!

And the benefits would be questionable. When PM standards were proposed in 2006, EPA reviewed thousands of studies. It decided not to change the annual primary PM 2.5 standard due to the uncertainty of the science. In this latest proposal, EPA reviewed 300 new epidemiological studies. The results of these studies are mixed; some show adverse effects and others do not.

What’s puzzling is that EPA’s own analysis supporting its new proposal failed to adequately address the possibility that health impacts observed in some of the epidemiological studies could be traced to another cause or causes.

EPA also assumed rather than demonstrated a linear relationship between pollution and health effects, concluding that harm to health must occur even at very low levels. Experience does not validate that.

Another important point needs to be kept in mind when it comes to costs. The new rule would not be happening in a vacuum. Other regulations, including the forthcoming ozone rules, the refinery sector rules and pending greenhouse gas regulations for refineries, and the delayed boiler MACT rules, may be finalized and imposed in the very near future.

The collective impacts of all of these and other potential new regulations at a time when 12 million Americans are still unemployed would be a blow to our economy as it struggles to recover and put Americans back to work. These rules could significantly slow business development and job creation. It makes no sense to risk this when the necessity of many of these regulations is ambiguous at best.

Polling shows that Americans support more domestic oil and natural gas development and the new jobs it would bring.

We need smart regulations, and government needs to do a better job of coordinating regulations as well as assuring that each new regulation makes a positive difference at reasonable cost.

Finally, it is important to put this new proposal in full context. We have made substantial progress reducing virtually all kinds of emissions – not just PM – and the momentum of existing programs will assure us of more progress. The air will continue to get cleaner. Criteria pollutants will continue on a steady downward trend. Even greenhouse gas emissions are in decline thanks in large part to rising use of natural gas.

Thanks, and now I’d be happy to take your questions.
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