EPA’s Costly, Unnecessary Soot Proposal

EPA continues to act tone deaf to the real-world needs of U.S. businesses and regular Americans. Its particle standards proposal issued this week is a good example of the kind of investment-squelching overregulation that ultimately could hurt the country’s energy future.

With the country’s air continuing to improve under the existing fine-particle soot standard, EPA proposed tightening it. The rule is scheduled to be finalized in December. Howard Feldman, API’s directory of regulatory and scientific affairs, says the rule’s benefits aren’t worth its costs:

“Air quality will continue to improve dramatically under the current government standards, but EPA’s proposal could substantially increase costs to states, municipalities, businesses and ultimately consumers without justified benefits. We are concerned that it could come at a significant economic cost and lost investments and limit our ability to produce the energy our nation needs.”

Between 2000 and 2010 concentrations of fine-particle soot fell by 27 percent, according to EPA. Feldman says three-fourths of Americans today live in areas where air quality meets today’s standards, and that the trend will continue – which suggests the new standard is unnecessary.

Feldman also says EPA based its proposal on “faulty scientific analysis,” that important data have been ignored and some of its purported findings are actually misinterpretations. How tightly the standards are set is a policy judgment. Because there is no bright line to guide the standard setting, the impacts of the standards matter. Feldman:

“A more stringent rule will discourage economic investment in counties that fail to meet new federal standards.  It’s in our interest to have both clean air and a vibrant domestic economy. However, the new standards would put many regions out of attainment, and companies considering a place to build a plant or refinery could perceive non-attainment as non-investment.”

Again, in the context of an economy trying to regain its footing, EPA is tossing out banana peels – with potential costs on a number of fronts that ultimately will hit real people. This economic anti-stimulus also is an unnecessary energy impediment.

It illustrates why, if we’re serious about a secure energy future, a common-sense regulatory structure is needed. By that we mean a regulatory process that’s open to all and based on sound science and legitimate cost-benefit analysis. By that standard EPA’s proposal falls well short.

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EPA’s Unjustified Particulate Matter Proposal

Three good reasons EPA should shelve a proposal to tighten its air pollution standard governing particulate matter:

Science doesn’t justify it.Current control programs are working.A more stringent standard could harm jobs and economic growth.

EPA is scheduled to hold public hearings on its PM 2.5 standard today in Philadelphia and Sacramento – part of a commenting period that runs into August. The proposal, which is to be finalized by the end of the year, would tighten the standard from 15 micrograms per cubic meter to 12 or 13 micrograms.

API’s Howard Feldman, director of regulatory and scientific affairs, discussed the proposal during a conference call with reporters:

“Changing the standard should be supported by clear scientific analysis. The science in this case cannot demonstrate a proven ‘cause and effect’ between levels below the current standard and health consequences. In part, this is because in EPA’s analysis it failed to adequately address confounding factors. 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.”

Feldman, who was to deliver testimony in Philadelphia, said a tighter standard could result in higher costs for providing and using energy, meaning fewer businesses would be created, fewer would expand and fewer workers would be hired. Feldman:

“Existing control programs are working. According to EPA, between 2000 and 2010, concentrations of PM 2.5 in the air fell by 27 percent. As a result, more than three-fourths of Americans today live in areas where air quality meets today’s standards.”

Dr. Julie Goodman of Gradient, an expert in toxicology, epidemiology and in assessing health risks from chemicals in products and the environment, also joined the call. Goodman said EPA has not produced “coherent evidence” that a new PM standard is necessary:

“There’s no evidence that lowering (the standard) 2 to 3 micrograms will have any effect on health. In other words, there’ll be no (real) health benefits from lowering the standard.”

Goodman’s remarks for the Philadelphia hearing can be read here.

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