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.
This
memo
summarizes
their
concerns.
Industry
representatives
said
that
they
were
greatly
concerned
with
the
proposed
revisions
to
the
PM2.5
standard.
They
also
said
that
need
to
replace
the
existing
standard
is
unsubstantiated
based
on
the
fact
that
the
current
standard
meets
the
legal
requirement
of
being
"
requisite
to
protect
the
public
health,"
and
EPA's
own
studies
show
that
the
existing
standard
is
even
more
protective
than
initially
perceived
in
1997.
Additionally,
industry
representatives
said
that
EPA's
intent
to
move
the
goalpost
before
the
existing
standards
are
even
implemented
is
an
unreasonable
burden
to
place
on
the
States
as
they
have
not
yet
developed
plans
to
implement
the
costly
1997
standard.
They
also
said
that
an
improper
standard
could
have
far­
reaching
economic
impacts
on
the
United
States,
as
energy
prices
will
rise
and
manufacturing
jobs
will
be
forced
to
move
off­
shore,
causing
increased
consumer
prices.

The
group
stated
that
the
new
science
is
ambiguous
and
does
not
compel
more
stringent
PM2.5
NAAQS.
Although
many
new
studies
have
been
published
since
the
existing
PM2.5
standards
were
established,
the
groups
stated
that
EPA
has
chosen
to
"
cherry
pick"
those
studies
which
have
selectively
emphasized
statistically
significant
reasons
for
tightening
the
standard,
while
discounting
those
studies
that
argue
for
the
maintenance
of
the
existing
standard.
The
group
also
said
that
CASAC
itself
has
overlooked
the
fact
that
under
the
current
standard,
health
risks
are
lower
than
assumed
in
1997.
The
Supreme
Court
has
ruled
that
NAAQS
are
not
a
"
zero
risk"
standard.
Industry
representatives
said
the
cost
of
implementing
a
tighter
standard,
however,
are
fraught
with
risk.
In
order
to
meet
EPA's
proposed
15/
35
standard,
the
United
States
will
be
forced
to
spend
$
20­
60
billion/
year
on
top
of
the
existing
standard,
and
at
the
expense
of
other
air
quality
programs.
They
also
said
that
the
integrity
of
the
carefully
crafted
CAIR
rules
will
be
jeopardized
by
States
forced
to
conform
to
a
more
stringent
standard,
and
the
number
of
nonattainment
counties
will
rise
under
EPA's
proposed
revision.
The
consequences
of
being
a
nonattainment
county
will
include
stricter
requirements
for
facilities;
more
restrictive
and
longer
permitting
processes;
potential
loss
of
federal
highway
and
transit
funding;
and
loss
of
industry
and
economic
development,
the
group
said.

The
groups
distributed
materials
that
are
also
included
in
the
docket.

The
below
list
of
stakeholders
were
present
at
the
meeting:
American
Petroleum
Institute­
Red
Cavaney,
President
American
Chemistry
Council­
Jack
Gerard,
CEO
Portland
Cement
Association­
Tom
Gibson,
Sr.
Vice
President,
Government
Affairs
American
Forest
&
Paper
Association­
Donna
Harman,
Sr.
VP,
Government
Affairs
U.
S.
Chamber
of
Commerce­
William
Kovacs,
VP,
Environment
&
Regulatory
Affairs
Edison
Electric
Institute­
Tom
Kuhn,
President
Engine
Manufacturers
Association­
Jed
Mandel,
CEO
American
Electric
Power
for
Utility
Air
Regulatory
Group
­
John
M.
McNamus,
VP,
Environmental
Services
American
Road
&
Transportation
Builders
Association­
T.
Peter
Ruane,
CEO
American
Iron
&
Steel
Institute­
Andrew
Sharkey,
President
&
CEO
National
Petrochemical
&
Refiners
Association­
Bob
Slaughter,
President
Hunton
&
Williams
LLP­
Joe
Stanko
National
Association
of
Manufacturers­
Jay
Timmons,
Sr.
VP,
Policy
&
Government
Affairs
and
Bryan
Brendle,
Director,
Air
Quality
Alliance
of
Automobile
Manufacturers­
Fred
Webber,
CEO
Associated
General
Contractors
of
America­
Stephen
E.
Sandherr,
CEO
EPA
officials
present
were:

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