EPA Is Reconsidering The PM2.5 NAAQS. The Sooner, The Better. – Environment

0
17


United States:

EPA Is Reconsidering The PM2.5 NAAQS. The Sooner, The Better.

To print this article, all you need is to be registered or login on Mondaq.com.

EPA announced yesterday that it will
“reconsider” the Trump EPA’s decision not to change
the PM2.5 National Ambient Air Quality
Standard. I’ve blogged numerous times about the
growing body of evidence that exposure to concentrations of
PM2.5 below the current NAAQS causes significant
additional mortality and morbidity.  The evidence is
clear.

I certainly agree that climate change is an existential threat
and that’s where our emphasis needs to be.  At the same
time, it’s human nature to focus on the here and now. 
Here and now, people are dying or becoming ill because of exposure
to PM2.5.  Many of them of children or
elderly.  Many of them are in environmental justice
communities.  Tightening the PM2.5 should be a
priority for EPA.

Fortunately, many of the measures that should be implemented to
address climate change would also reduce
PM2.5 exposures.  Let’s hear it for
co-benefits.  And I don’t care which way the co-benefits
run.  We can reduce PM2.5 exposure through our
climate change regulation.  Or, if there is concern about
existing legal authority to reduce GHG emissions, we can reduce
emissions to reduce PM2.5 concentrations –
and address climate at the same time.

Either way, the requirement to set NAAQS remains at the core of
the Clean Air Act.  If EPA is to protect public health with
“an adequate margin of safety”, it should be undeniable
that the PM2.5 NAAQS needs to be more stringent.

I will agree with the Trump administration on one point –
the NAAQS development process takes way too long.  EPA’s
timeline for reconsidering the Trump decision provides that a
proposed rule will be issued in the summer of 2022 and a final rule
will be issued in the Spring of 2023.  By the time state
implementation plans are revised to include measures to attain the
new NAAQS, it will be sometime in 2025 or 2026.

There really should be a better way.  I know that EPA wants
to bulletproof the new NAAQS, but it should not take this long.

To view Foley Hoag’s Law and the Environment Blog
please click
here

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.

POPULAR ARTICLES ON: Environment from United States

PFAS Air Emissions Regulations

Bryan Cave Leighton Paisner LLP

Typically when considering the regulatory risk presented by per- and polyfluoroalkyl (“PFAS”) compounds, businesses think of the regulation of drinking water, groundwater, and consumer products.

Final Minimum Risk Levels For PFAS: What Do They Mean?

Dickinson Wright PLLC

In May 2021, the federal Agency for Toxic Substances and Disease Registry (ATSDR) finalized a report containing toxicological profiles and associated Minimal Risk Levels (MRLs) for several perfluoroalkyls (PFAS),…



Read More: EPA Is Reconsidering The PM2.5 NAAQS. The Sooner, The Better. – Environment

0 0 vote
Article Rating
Subscribe
Notify of
guest
0 Comments
Inline Feedbacks
View all comments

Get more stuff like this
in your inbox

Subscribe to our mailing list and get interesting stuff and updates to your email inbox.

Thank you for subscribing.

Something went wrong.