Memo
to
EPA
Docket
From:
Andrew
Beck
Director,
Public
Outreach
Office
of
the
Administrator
Jason
Burnett
Senior
Policy
Advisor
Office
of
Air
and
Radiation
On
July
12,
2006,
a
group
of
industry
representatives
met
with
EPA
Administrator
Stephen
Johnson
to
share
a
synopsis
of
their
previously
submitted
comments
on
the
NAAQS
PM10
proposed
standards.
Certain
industry
groups
attending
this
meeting
strongly
oppose
EPA's
proposed
revision
to
the
coarse
PM
rule
and
believe
EPA
should
continue
its
current
efforts
to
implement
the
existing
standard,
and
allow
sufficient
time
to
fully
realize
it
impacts
and
benefits.
Others
advocated
a
PM10­
2.5
with
the
same
level
and
form
as
the
current
PM10
standard.
Industry
representatives
also
believe
that
EPA
does
not
have
the
legal
authority
to
develop
urban
standards
and
there
should
be
a
national
standard.
CAA
calls
for
a
national
standard
to
be
developed,
not
a
state
or
regional
standard.
Any
proposal
to
regulate
coarse
particulate
matter
only
in
urban
areas
raises
substantial
concern
over
EPA's
legal
authority.
Under
the
Clean
Air
Act,
EPA's
authority
is
limited
to
adopting
national
ambient
air
quality
standards.

Industry
representatives
express
that
EPA
has
attempted
to
redefine
the
urban
coarse
standard
to
take
focus
off
of
its
urban­
only
character.
They
said
this
attempted
redefinition
is
inconsistent
with
EPA's
statutory
obligations
to
promulgate
national
standards.
They
also
said
that
the
proposed
standard
would
preempt
state
and
local
authority
to
devise
implementation
plans,
compliance
strategies
and
air
monitoring
programs
appropriate
to
that
area.

There
was
also
strong
agreement
by
industry
representative
present
at
the
meeting
that
there
is
not
adequate
science
to
change
the
current
rule
and
that
the
agency
needs
develop
data
for
source
specific
locations.
Representatives
offered
to
partner
with
EPA
to
do
more
research
on
source
specific
locations
and
collect
more
data.

Representatives
from
the
group
said
that
if
agriculture
and
mining
are
exempt
from
the
standard,
then
the
residential
construction
industry
stated
should
also
be
exempt
because
they
are
a
similar
source
coarse
material.

The
below
list
of
stakeholders
were
present
at
the
meeting:

Engine
Manufacturing
Association­
Jed
Mandel,
CEO
Alliance
of
Automobile
Manufacturers­
Greg
Dana,
VP,
Environmental
Affairs,
and
Susan
Conti,
Attorney
National
Association
of
Home
Builders­
Michael
Mittelholzer,
Ass.
VP,
Environmental
Policy
and
Gary
Suskauer,
Environmental
Policy
Analyst
American
Trucking
Association­
Richard
D.
Holcomb,
General
Counsel
&
Senior
VP
EPA
officials
present
were:

Administrator
Steve
Johnson
Charles
Ingebretson,
Chief
of
Staff
Amy
Dewey,
Office
of
Public
Liaison
Jason
Burnett,
Office
of
Air
&
Radiation
Andrew
Beck,
Office
of
Public
Liaison
