Tamara
McCann
Thies
<
tthies@
beef.
org>

10/
25/
2005
12:
45
PM
T
o
Jon
Scholl/
DC/
USEPA/
US@
EPA,
Sally
Shaver/
RTP/
USEPA/
US@
EPA,
Beth
Sauerhaft/
DC/
USEPA/
US@
EPA,
Charles
Ingebretson/
DC/
USEPA/
US@
EPA,
Jason
Burnett/
DC/
USEPA/
US@
EPA
c
c
bruce.
knight@
usda.
gov,
burleson.
smith@
usda.
gov,
rconnery@
hollandhart.
com
S
u
b
j
e
c
t
Coarse
PM
and
Agriculture
First,
I
want
to
thank
you
for
giving
the
agriculture
industry
the
opportunity
to
visit
with
Administrator
Johnson
last
week
about
our
opposition
to
regulating
coarse
particulate
matter
under
the
National
Ambient
Air
Quality
Standards
of
the
Clean
Air
Act.
While
agriculture
is
committed
to
protecting
the
public's
health
and
believes
in
using
appropriate
BMPs
to
control
emissions,
we
are
opposed
to
regulation
that
is
not
justified
by
sound
science.
We
do
not
believe
EPA
staff's
proposed
regulation
of
coarse
PM
is
warranted
by
the
science
at
this
time,
and
believe
that
an
urban­
only
standard
is
unsupportable
and
would
be
thrown
out
by
the
courts,
leaving
agriculture
with
a
national
standard
based
on
weak
and
uncertain
data.
The
Supreme
Court
requires
that
the
NAAQS
standards
be
set
no
more
or
less
restrictive
than
necessary
to
protect
the
public's
health.
We
do
not
believe
current
evidence
meets
this
requirement.

In
addition,
imposition
of
the
current
or
proposed
standard
would
be
no
less
than
devastating
to
agriculture.
Much
of
the
agriculture
economy
is
located
in
the
arid
western
portion
of
the
United
States
where
compliance
with
a
coarse
PM
NAAQS
would
often
be
impossible,
even
after
utilization
of
appropriate
BMPs.
The
NAAQS
is
not
a
standard
that
can
be
determined
to
be
met
simply
by
using
BMPs
or
some
other
method
to
control
emissions.
Instead,
the
NAAQS
must
be
met,
no
matter
what.

Considering
the
fact
that
this
is
the
first
time
a
real
coarse
PM
standard
is
being
considered,
we
are
hopeful
the
EPA
will
refrain
from
imposing
such
a
standard
unless
and
until
sound
science
indicates
one
is
warranted.
I
have
attached
several
documents
that
I
am
hopeful
will
be
informative
and
helpful
as
this
process
moves
forward.
The
first
two
are
assessments
completed
by
Dr.
Jonathan
Borak,
epidemiologist
and
Professor
of
Medicine
at
Yale
University,
highly
qualified
and
published
in
occupational
health,
toxicology,
epidemiology
and
the
clinical
application
of
those
specialties.
We
can
arrange
for
a
briefing
with
Dr.
Borak
if
you
would
like
one.
The
second
two
documents
were
prepared
by
Bob
Connery,
our
consultant
from
Holland
and
Hart
law
firm,
to
address
several
mortality
studies
of
concern
to
Acting
Assistant
Administrator
Bill
Wehrum.
When
drafting
the
document,
Bob
referred
to
the
Criteria
Document,
the
Staff
Paper
and
Dr.
Borak's
assessments.
The
fifth
document
is
the
long
version
of
the
short
slide
presentation
I
gave
last
week
during
the
meeting.

Please
let
me
know
if
you
have
any
questions
or
concerns
after
reviewing
the
documents.

Thank
you,
again,
for
your
time
and
consideration
of
our
concerns.

Sincerely,

Tamara
<<
PM
Borak
Letter
to
CASAC
050405.
pdf>>
<<
PM
Borak
Comments
of
Final
Staff
Paper
081105.
pdf>>
<<
PM
Wehrum_
letter
101905.
pdf>>
<<
PM
Wehrum
Letter
attachment
101905.
pdf>>
<<
PM
Power
Point
Presentation
101005.
PPT>>

Tamara
McCann
Thies,
Esq
Director,
Environmental
Issues
NCBA
1301
Pennsylvania
Ave
NW
Suite
300
Washington
DC
20004­
1701
202­
347­
0228
http://
hill.
beef.
org
