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Review of the National Ambient Air Quality Standards for Particulate Matter

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American Petroleum Institute filings
16

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American Petroleum Institute filed 16 comments on this docket between May 20, 2009 and Sep 6, 2012. 150 other organizations filed here. The comment window closed 5079d ago.

What American Petroleum Institute filed (16)

Sep 6, 2012· Comment submitted by David Heinold, AECOM on behalf of the American Petroleum Institute (API)· EPA-HQ-OAR-2007-0492-9813

In comments submitted by the U.S. Department of the Interior, the Department recommends that EPA set the level of the proposed secondary PM2.5 extinction standard for urban visibility to 25 dv, based on a visibility preference study conducted for Phoenix, one of several such studies that EPA reviewed. The scientific method requires that before a finding can be accepted, it must be independently verified by other studies. However, the wide degree of scatter among the preference studies indicates that none of study results have been replicated due to different study approaches and varying locations. This is an indication that there are factors that are not appropriately addressed in the studies. The wide degree of scatter may indicate that one or more of the following types of confounding factors may be at play: 1) there are regional differences in the level of extinction that affect their visual preferences, 2) there are inherent flaws and differences in the design of the studies that add to the scatter, 3) the assumption that light extinction at 550 nm is a suitable measure of urban visibility is invalid and/or 4) no single level of visibility impairment is applicable to the wide range of vistas among urban area settings throughout the country. Therefore, the use of any one of these inconsistent studies for proposing the standard is unjustifiable on scientific grounds and EPA must conduct additional studies to address these sources of uncertainty before a legitimate secondary standard can be promulgated.

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Sep 5, 2012· Comment submitted by Ted Steichen on behalf of American Petroleum Institute (API)· EPA-HQ-OAR-2007-0492-9575

After reading the comments offered by the Department of the Interior, API respectfully provides the attached rebuttal. Please see the comments of the American Petroleum Institute located in this docket for more information.

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Sep 5, 2012· API Comment submitted by David Heinold and Robert Paine, AECOM on behalf of the American Petroleum Institute (API)· EPA-HQ-OAR-2007-0492-9528

Attachment 14 to API's Comments on the NAAQS PM Proposed Rule EPA–HQ–OAR–2007–0492 Selected Comments on Issues Solicited by EPA Regarding the Proposed PM NAAQS Per EPA Listing Provided at time of the Public Hearings.

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Sep 5, 2012· API Comment submitted by Ted Steichen, American Petroleum Institute (API)· EPA-HQ-OAR-2007-0492-9527

Attachment 13 to API Comments to NAAQS PM Proposed Rule EPA–HQ–OAR–2007–0492 ATTACHMENT 13 Previous comments filed that have not been addressed: 13-1 Comments by the American Petroleum Institute on the National Ambient Air Quality Standards Integrated Science Assessment for Particulate Matter Second External Review Draft (July 2009), 74 Fed. Reg. 38185 (July 31, 2009), Docket No. EPA-HQ-ORD-2007-0517 filed October 13, 2009 13-2 Summary Comments by ExxonMobil on the National Ambient Air Quality Standards Integrated Science Assessment for Particulate Matter, EPA/600/R-08/139 filed March 12, 2009 13-3 Comments by ExxonMobil on the National Ambient Air Quality Standards Integrated Science Assessment for Particulate Matter, EPA/600/R-08/139 filed March 12, 2009 13-4 Attachment to the Comments by ExxonMobil on the National Ambient Air Quality Standards Integrated Science Assessment for Particulate Matter, EPA/600/R-08/139 filed March 12, 2009

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Sep 5, 2012· API Comment submitted by Ted Steichen, American Petroleum Institute (API)· EPA-HQ-OAR-2007-0492-9531

Attachment 12 to API's Comments on the NAAQS PM Proposed Rule, Docket ID No. EPA-HQ-OAR-2007-0492 Comments on EPA's RIA of the NAAQS PM Proposal

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Sep 5, 2012· API Comment submitted by Ted Steichen, American Petroleum Institute (API)· EPA-HQ-OAR-2007-0492-9530

Comments of the American Petroleum Institute to the NAAQS PM Proposed Rule, Docket ID No. EPA–HQ–OAR–2007–0492

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Sep 1, 2010· Comment submitted by Ted Steichen, Senior Policy Advisor, Regulatory and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-OAR-2007-0492-0247

Filed on regulations.gov — full text not in the inline record.

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Aug 26, 2010· Comment submitted by Julie E. Goodman, PhD DABT, Gradient on behalf of the American Petroleum Institute· EPA-HQ-OAR-2007-0492-0239

Filed on regulations.gov — full text not in the inline record.

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Aug 23, 2010· Comment submitted by Julie E. Goodman, Ph.D., DABT and Juhi K. Chandalia, M.S., Gradient Corp. on Behalf of The American Petroleum Institute (API)· EPA-HQ-OAR-2007-0492-0234

We are submitting comments regarding the use of the Cox Proportional Hazards Model to be considered by CASAC before the call on Wednesday August 25th regarding the Second Draft PM Policy Assessment.

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Aug 17, 2010· Comment submitted by Ted Steichen, American Petroleum Institute (API)· EPA-HQ-OAR-2007-0492-0188

API finds the second draft of the PAD perpetuates and compounds the flaws that were present in the first draft. It continues to mischaracterize the recent science and the significance of that science for the levels and forms of NAAQS that protect public health adequately under the terms of the Clean Air Act. Further, it incorporates additional reliance on a body of science that has only been deemed "suggestive of a causal relationship." Accordingly, EPA staff's recommendations would result in primary PM NAAQS that would be inconsistent with the Act. If the PAD is to serve its intended purpose of aiding the Administrator in judging whether the current primary standards continue to be "requisite" to protect the public health, EPA staff must remedy the enormous shortcomings of the PAD, as identified in these comments and API's comments on the first draft of this document. Please see the attached comments for a more detailed explanation of our concerns and suggested improvements.

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Apr 27, 2010· Comment submitted by Ted Steichen, Senior Policy Advisor, Regulatory and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-OAR-2007-0492-0096

Filed on regulations.gov — full text not in the inline record.

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Apr 14, 2010· Comment submitted by David W. Heinold, CCM, AECOM on behalf of the American Petroleum Institute (API)· EPA-HQ-OAR-2007-0492-0086

Filed on regulations.gov — full text not in the inline record.

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Mar 16, 2010· Comment submitted by Ted Steichen, Policy Advisor, Regulatory and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-OAR-2007-0492-0072

Comments on EPA's PM Risk & Exposure Assessment, 2nd Draft and the 2nd Draft of the PM Urban-Focused Visibility Assessment

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Nov 10, 2009· Comment submitted by Ted Steichen, Policy Advisor, Regulatory and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-OAR-2007-0492-0059

API finds that the 2009 PM RA Draft requires significant revision, in its current form, it should not be used to provide a basis for determining the level of the PM2.5 standard. Similarly, the 2009 PM UFRA does not provide justification or sufficient technical basis for EPA to establish a secondary NAAQS based on visibility impairment.

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May 20, 2009· Comment submitted by Ted Steichen, Advisor, Regulatory and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-OAR-2007-0492-0014

The American Petroleum Institute (API) represents over 400 member companies involved in all aspects of the oil and natural gas industry. API is pleased to submit the following comments on the Particulate Matter National Ambient Air Quality Standards: Scope and Methods Plan for Urban Visibility Impact Assessment (PM UVIA Plan). A review of PM UVIA Plan to study visual air quality (VAQ) in urban areas raises questions as to whether it is necessary, practical, or feasible for EPA to establish a welfare-based particulate standard that protects urban visibility.

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May 20, 2009· Comment submitted by Ted Steichen, Advisor, Regulatory and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-OAR-2007-0492-0013

The American Petroleum Institute (API) represents over 400 member companies involved in all aspects of the oil and natural gas industry. API is pleased to submit the following comments on the Particulate Matter National Ambient Air Quality Standards: Scope and Methods Plan for Health Risk and Exposure Assessment. API finds the planned air quality analyses are insufficient to fully and accurately characterize risk associated with ambient concentrations of PM. API recommends that EPA rework the Scope and Methods Plan to develop a more accurate risk and exposure assessment reflecting the available science issues and data analysis methods raised in the comments.

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Abstract

Docket for Particulate Matter Review

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Co-filers (150)

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