"
Johnston,
A.
Todd"
<
ajohnston@
nma.
org>

04/
24/
2006
12:
04
PM
T
o
Bill
Wehrum/
DC/
USEPA/
US@
EPA,
Jason
Burnett/
DC/
USEPA/
US@
EPA
c
c
S
u
b
j
e
c
t
NMA
Coarse
PM
Comments
I
attach
the
National
Mining
Association's
(
NMA)
comments
on
the
EPA's
coarse
PM
NAAQS
proposal.
The
comments
submitted
to
the
docket
contain
numerous
exhibits;
however,
I
direct
you
attention
in
particular
to
exhibits,
labeled
"
G"
and
"
H"
and
"
I."

Exhibit
G
was
prepared
by
Gale
Hoffnagle.
Gale
headed
the
primary
association
of
air
pollution
control
professionals,
the
Air
Pollution
Control
Association,
is
a
Certified
Consulting
Meteorologist,
and
one
of
the
most
experienced
experts
in
the
country
on
modeling
and
measuring
air
pollutants.
His
comments
address
whether
the
ambient
monitoring
data
for
PM10­
2.5
used
in
the
epidemiologic
studies
on
which
EPA
relies
to
support
its
coarse
proposal
are
adequately
representative
of
the
exposure
of
those
suffering
various
morbidity
or
mortality
effects
to
serve
as
the
basis
for
any
conclusion
that
the
exposure
and
effects
are
linked.
His
conclusion
is
that
the
ambient
monitors
for
PM10­
2.5
are
representative
of
only
limited
areas
around
the
monitor,
and
thus
not
representative
of
the
large
urban
areas
for
which
the
epidemiologic
data
are
collected.

Gale
also
addresses
the
equivalence
issue
and
whether
the
form
of
the
standard
EPA
has
chosen
in
the
proposal
helps
ameliorate
compliance
difficulties
for
sources
whose
PM10
emissions
are
dominated
by
the
coarse
(
PM10­
2.5)
faction.
His
conclusions,
generally,
are
1)
it
is
not
possible
to
establish
a
coarse
standard
that
is
equivalent
to
PM10
due
to
the
wide
variation
in
the
fine
and
coarse
PM
fractions
of
PM10
in
different
parts
of
the
country;
and
2)
because
the
standard
is
significantly
more
stringent
for
sources
of
fugitive
dust,
the
98%
form
makes
little
difference
in
terms
of
a
source's
ability
to
comply.
Exhibit
H
was
prepared
by
Dr.
Jonathan
Borak
of
Yale
University
School
of
Medicine,
an
expert
in
toxicology,
epidemiology
and
occupational
health
exposure
to
pollutants.
Dr.
Borak's
comments
provide
a
thorough,
detailed
review
and
analysis
of
the
scientific
rationale
and
basis,
as
well
as
the
underlying
studies,
on
which
EPA
relies
to
support
its
coarse
PM
recommendation.
He
concludes
that
there
is
no
basis
to
justify
regulating
of
PM10­
2.5,
"
only
arguments
and
hypotheses
that
mainly
reflect
biological
plausibility
rather
than
empirical
findings.
That
general
lack
of
evidence
persists
even
at
exposure
levels
substantially
higher
than
those
considered
health
relevant
in
the
Proposed
Coarse
PM
NAAQS."

Dr.
Borak's
comments,
combined
with
EPA's
own
admissions
concerning
the
weak
and
inadequate
scientific
basis
supporting
a
standard
and
its
subsequent
reliance
on
the
notion
of
equivalence
to
an
invalid
1987
PM10
standard,
makes
it
pretty
clear
that,
despite
EPA's
best
efforts,
the
case
simply
isn't
there
to
support
a
coarse
PM
standard
for
ambient
exposure.
Further,
even
if
one
were
to
ignore
the
serious
flaws
in
the
studies
purporting
to
link
coarse
PM
to
health
endpoints,
Gale
Hoffnagle's
work
demonstrates
that
the
monitors
of
PM10­
2.5
do
not
represent
urban
areas
for
which
the
epidemiologic
studies
cited
to
support
the
proposal
were
performed.
As
Gale's
comments
point
out,
this
limitation
alone
renders
the
ambient
air
basis
for
the
epidemiologic
results
incorrect
and
inappropriate.

For
these
and
other
reasons
discussed
more
fully
in
our
comments,
we
do
not
believe
that
there
is
a
sound
or
adequate
basis
for
the
adoption
of
a
coarse
PM
NAAQS.

Exhibit
I
provides
a
snapshot
of
the
various
federal
and
state
laws
and
regulations
that
require
the
control
of
fugitive
dusts
at
mine
sites.
Critics
of
the
administration's
proposal
allege
a
"
roll­
back"
of
requirements
to
control
coarse
PM.
This
is
simply
not
the
case.
Coarse
PM
emissions
from
mining
operations
will
continue
to
be
subjected
to
pervasive
regulation
requiring
the
use
of
control
technologies,
and
best
management
practices,
regardless
of
whether
they
are
separately
subjected
to
a
NAAQS
requirement.

Please
contact
me
if
you
have
any
questions.

A.
Todd
Johnston
Director
of
Air
Quality
National
Mining
Association
101
Constitution
Avenue,
NW
Suite
500
East
Washington,
DC
20001
202­
463­
2668
ajohnston@
nma.
org
