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

As prepared for delivery

Press briefing teleconference on PM standard proposal
Howard Feldman, API director of regulatory and scientific affairs

Tuesday, June 12, 2012

Opening statement:

Good morning everyone. Thanks for calling in.

This Thursday EPA will propose new particulate matter air pollution standards, which are expected to include a range of possible values.

We urge the agency to include the current annual fine particle standard of 15 micrograms per cubic meter in the range of standards for which they are soliciting comments. At this point in the process, EPA should not be pre-judging the outcome and should take comments on a broad range for the annual standards. It is good public policy.

Air quality progress under the current standards, control programs, and industrial initiatives has been substantial. According to EPA, between 2000 and 2010, concentrations of PM 2.5 fell by 27 percent. As a result, more than three-fourths of Americans today live in areas where air quality meets today’s standards.

Air quality will continue to improve whatever standards are chosen, and by continuing to implement the existing standards we would avoid the potentially heavy added economic costs of more stringent standards, which our economy and American workers cannot afford. Specifically, as a result of measures already proposed or being implemented, 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 reducing the number of Americans exposed to concentrations above the standard.

Another reason why EPA should accept comment on the current standards is that the agency’s scientific evidence falls short of demonstrating that more stringent ones are necessary.

EPA has not proven a “cause and effect” between PM 2.5 and health effects. It has failed to adequately address confounding factors. And it has assumed rather than provided evidence for a linear relationship between pollution levels and health effects.

The truth is that taken as a whole the studies cut in different directions when it comes to making a case for lowering the standards. That’s a concern considering how many industries and consumers could be affected if the standards were to be lowered.

As part of a larger industry delegation, we met with the White House’s Office of Management and Budget yesterday to ask that the current standards be included in the proposal. We made the case I’ve just outlined. We also let them know that we did not believe that sufficient time had been allowed for a thorough interagency review of EPA’s proposal, and we urged them to conduct such a review.

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

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