EPA at it again

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CrappieKeith

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EPA Releases Draft Proposal

for Next PM 2.5 Standard

WASHINGTON, D.C.



From John Crouch, HPBA Director of Public Affairs



The Clean Air Act requires EPA to periodically review its standards for ambient (outdoor) air quality. On Friday, June 15, 2012, EPA announced its final draft assessment of the National Ambient Air Quality Standard (NAAQS) for particulates. Both the EPA and much of the eastern press used the word "soot" to reference this standard, although our western members, and much of the western media, will more accurately characterize this as the "fine particulate standard" or the PM 2.5 standard.



Because this standard triggers rules that in turn lead to almost all of the local wood-burning restrictions, (hearth dealers) may be interested and/or concerned about the press this action may receive. This action is separate and distinct from the decisions on the NSPS, and the two issues should not be confused. The NSPS is a regulation of products, and this action, the Particulate Matter NAAQS, is a regulation covering local, outdoor air quality. Part of the EPA's press release is below.



The most important aspect of this announcement is that EPA is proposing to leave the 24-hour standard for PM 2.5 where it now stands, without any changes. This is good news for HPBA western affiliates, since it means that only a few new areas may fall into non-attainment status in two years, when the EPA finalizes the determination of which areas attain this new standard, and which areas fail to attain the new standard.



The reason that a few areas may fall into non-attainment, even though the 24-hour standard is not changing, is that some communities "slipped by" the process in 2009. The PM standard requires three years of consecutive data, and a few areas, such as Yakima, Washington, avoided being designated as non-attainment in the last round due to the absence of three years of data. These areas will probably be regulated in this next round of PM 2.5 non-attainment designations and consequently can expect new, local regulations.



Designations under this new rule will not take place until late in 2014 or early 2015 and the local rules two years thereafter. There is one other important aspect of the announcement itself that our industry needs to be aware of, and that is the mischaracterization of Libby, Montana. As part of this announcement, the EPA has included a map of the handful of counties that they project might still be in non-attainment in 2020.



Please look at this map.



Unfortunately, this map includes Lincoln County, Montana, which is the home of Libby. Some members may not read the fine print on the map which says "based on EPA modeling of 2005 emissions." They will need to be reassured that the map uses, as a baseline, data from Libby that predates our changeout! It is not clear why EPA chose to use data from that year, but a cynical view is that there may be something in the data set, probably unrelated to us, which is to their advantage in suggesting that the annual standard, which they do propose to change, will be easy for some areas to attain.



Bottom line: The new PM 2.5 standards may implicate a few new areas, but it will not impact us nearly as much as the 2007 changes did to the 24-hour standard. The announcement also contains the unfortunate implication that Libby did not benefit from our work, which is absolutely wrong. Any questions about wood smoke and hearth products can be directed to me, John Crouch, [email protected]. The following contains the core of the release:



EPA Proposes Clean Air Standards for Harmful Soot Pollution/99 percent of U.S. counties projected to meet proposed standards without any additional actions.



EPA's proposal would strengthen the annual health standard for harmful fine particle pollution (PM2.5) to a level within a range of 13 micrograms per cubic meter to 12 micrograms per cubic meter. The current annual standard is 15 micrograms per cubic meter. The proposed changes, which are consistent with the advice from the agency's independent science advisors, are based on an extensive body of scientific evidence that includes thousands of studies - including many large studies that show negative health impacts at lower levels than previously understood.



By proposing a range, the agency will collect input from the public as well as a number of stakeholders, including industry and public health groups, to help determine the most appropriate final standard to protect public health. It is important to note that the proposal has zero effect on the existing daily standard for fine particles or the existing daily standard for coarse particles (PM10), both of which would remain unchanged.
 
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