Comments on the Environmental Protection Agency’s (“EPA”) “Policy Assessment for Review of the National Ambient Air Quality Standards for Particulate Matter, External Review Draft.”

The document provides formal comments on the EPA's External Review Draft of the Policy Assessment for the review of PM2.5 NAAQS. It asserts that the EPA is legally obligated to set standards based solely on health and welfare effects, without considering cost or feasibility, and must protect vulnerable subpopulations. The authors criticize the EPA for disbanding the particulate matter review panel, following a flawed memorandum from former Administrator Pruitt that suggests combining science and policy assessments, and failing to issue a second draft of the Integrated Science Assessment (ISA). Finally, the document argues that current PM2.5 standards are insufficient, citing evidence of mortality risks at levels as low as 8 μg/m3, and recommends lowering the primary annual standard to 8-10 μg/m3 and the 24-hour standard to 25-30 μg/m3.

• The EPA is legally prohibited from considering economic costs or technological feasibility when establishing the numerical value of the NAAQS, as the standards must be based solely on the latest scientific knowledge regarding public health and welfare.
• The NAAQS must be set to protect the most sensitive members of the population, including children, the elderly, and those with heart or lung disease, rather than just the average healthy individual.
• The EPA committed a critical process failure by disbanding the 20-member particulate matter review panel on October 10, 2018, leaving the 7-member CASAC without necessary expertise in air pollution epidemiology.
• The 'Pruitt NAAQS Memo' issued on May 9, 2018, is described as flawed because it suggests combining integrated science, risk and exposure, and policy assessments into a single review, which risks conflating science and policy.
• The EPA's current review process is criticized for releasing the draft Policy Assessment (PA) and Integrated Science Assessment (ISA) simultaneously, which contradicts the traditional sequential approach where the ISA informs the PA.
• Scientific evidence, including studies from U.S. and Canadian cities, indicates that the current PM2.5 annual standard of 12 μg/m3 is not protective enough, with mortality risks observed at levels as low as 8 μg/m3.
• The authors recommend that the EPA revise the primary annual PM2.5 standard to a range of 8-10 μg/m3 and the 24-hour standard to 25-30 μg/m3 to ensure an adequate margin of safety.

APA

Clean Air Task Force (2019). Comments on the Environmental Protection Agency’s (“EPA”) “Policy Assessment for Review of the National Ambient Air Quality Standards for Particulate Matter, External Review Draft.”. https://cdn.catf.us/wp-content/uploads/2019/11/21093010/EDF-PM-PA-Comments-11-12-FINAL.pdf

Chicago

Clean Air Task Force. Comments on the Environmental Protection Agency’s (“EPA”) “Policy Assessment for Review of the National Ambient Air Quality Standards for Particulate Matter, External Review Draft.”. 2019. https://cdn.catf.us/wp-content/uploads/2019/11/21093010/EDF-PM-PA-Comments-11-12-FINAL.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=Comments on the Environmental Protection Agency’s (“EPA”) “Policy Assessment for Review of the National Ambient Air Quality Standards for Particulate Matter, External Review Draft.” |date=12 November 2019 |url=https://cdn.catf.us/wp-content/uploads/2019/11/21093010/EDF-PM-PA-Comments-11-12-FINAL.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2019comments, author = {{Clean Air Task Force}}, title = {{Comments on the Environmental Protection Agency’s (“EPA”) “Policy Assessment for Review of the National Ambient Air Quality Standards for Particulate Matter, External Review Draft.”}}, publisher = {Clean Air Task Force}, year = {2019}, month = nov, url = {https://cdn.catf.us/wp-content/uploads/2019/11/21093010/EDF-PM-PA-Comments-11-12-FINAL.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }