The People of America's Oil and Natural Gas Indusry

Retain Current Particulate Matter Standard – Because It’s Working

Mark Green

Mark Green
Posted December 12, 2012

Later this week EPA is expected to finalize standards for particulate matter 2.5. EPA could and should retain the existing standard. During a conference call with reporters API’s Howard Feldman, director of regulatory and scientific affairs, outlined the reasons:

  • Certain costs and doubtful benefits
  • Efficacy of the current standard
  • Questionable scientific foundation for a new standard
  • Poor coordination with other regulatory initiatives

From a public health standpoint a tighter National Ambient Air Quality Standard for particulate matter (PM) isn’t needed. Feldman said that according to EPA data concentrations of PM fell by 27 percent nationwide between 2000 and 2010. Today three-quarters of all Americans live in areas where air quality meets or exceeds the current standard. Feldman:

“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 1 million tons annually, about another 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 cost would be more regulation heaped on an economy still struggling to regain its footing – even as EPA considers a wave of other measures, including stricter rules on ozone and refinery greenhouse gas emissions as well as tighter limits on emissions from industrial and commercial boilers and process heaters. All could be finalized and implemented in the near future. Feldman:

“The new rule would not be happening in a vacuum. … 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…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.”

Feldman said that when PM standards were proposed in 2006, EPA reviewed thousands of studies and decided not to change the annual primary PM rule because of scientific uncertainty. EPA’s latest proposal included review of 300 new epidemiological studies, he said, some of which showed adverse effects from PM and others that didn’t. Meanwhile, EPA’s analysis didn’t address the possibility that health impacts described in some of the studies might be traced to another cause or causes, he said.

Suggested in the PM issue is the way regulatory efforts that are ill-timed, uncoordinated, lacking in proper scientific foundation and detached from prudent cost-benefit analysis can cost jobs, chill investment and harm energy production to the detriment of everyone. Instead, we need a common-sense approach to regulation that’s based on sound science and considers all impacts. It’s a critical component to a sound energy policy. Feldman:

“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. … 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.”

Industry supports keeping the standards where they are – because they’re working and because there’s no compelling evidence for change.


Mark Green joined API after a career in newspaper journalism, including 16 years as national editorial writer for The Oklahoman in the paper’s Washington bureau. Mark also was a reporter, copy editor and sports editor. He earned his journalism degree from the University of Oklahoma and master’s in journalism and public affairs from American University. He and his wife Pamela live in Occoquan, Va., where they enjoy their four grandchildren.