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CATF Statement on EPA Proposal on NAAQS

Today, EPA has proposed a rule on the National Ambient Air Quality Standards (NAAQS) for particulate matter (PM) that is yet another example of the Trump EPA failing to honor its core mission—to promote the American people’s public health. And in a time of a serious pandemic threatening the respiratory systems of millions of Americans, this proposal is even more dangerous.

First off, the proposal fails to keep pace with advances in scientific research. Far from promoting public health, EPA proposes not to strengthen the NAAQS despite strong new scientific evidence that the existing standards, which have not been updated since 2012, are not adequate to protect public health with the adequate margin of safety required by the Clean Air Act.

EPA’s own Integrated Science Assessment and Policy Assessment findings for fine particulate matter, which are supposed to support the standards, are based on the latest scientific knowledge on the effects of PM, as put together by the career staff at EPA, and indicate severe health impacts at PM2.5 concentrations below the current annual average standard of 12 µg/m3. EPA’s career staff acknowledged this research and indeed, recommended an annual average standard as low as 8 µg/m3.

But even as the uncertainty surrounding harmful health effects due to low concentrations of PM2.5 has been continuously reduced, and EPA has noted the “absence of a discernible threshold” for health impacts, the political decisionmakers at the Agency have determined that the standard issued in 2012 is good enough.  This dismissal of the latest scientific knowledge is unconscionable, and patently ignores the overarching statutory requirement to promote public health.

This EPA has also rushed the proposal—truncating the NAAQS review process by reducing opportunities for public review and comment and refusing to provide second drafts for external review. EPA also reduced the expertise for external review of the science and policy documents by disbanding a panel of 28 additional experts chosen to assist the Clean Air Scientific Advisory Committee (CASAC) in its review and deliberations.

The policy position was also developed before the scientific assessment was even complete. “That’s a clear case of putting the cart before the horse and calls into question whether the final proposal is truly science-based,” said Hayden Hashimoto, attorney with CATF. “Basing the NAAQS on the latest science is not only required by statute, but would provide valuable public health benefits and lessen the already huge burden on our health care system by reducing the number of asthma attacks, heart attacks, and premature mortality.  EPA must withdraw this rule and replace it with a proposal that tightens the standards to be consistent with the latest scientific knowledge,” he said.