Integrated Science Assessment for Oxides of Nitrogen - Health Criteria

Comment from the American Petroleum Institute See attached file(s)

The American Petroleum Institute (API) represents over 550 oil and natural gas companies, leaders of a technology-driven industry that supplies most of America's energy, supports more than 9.8 million jobs and 8 percent of the U.S. economy, and, since 2000, has invested nearly $2 trillion in U.S. capital projects to advance all forms of energy, including alternatives. API's members engage in all segments of the oil and gas industry and operate facilities and produce products affected by the NO2 NAAQS. Accordingly, API is pleased to offer these comments on the U.S. Environmental Protection Agency (EPA) First Draft Integrated Science Assessment for Oxides of Nitrogen – Health Criteria (draft ISA.) Key Findings: 1.) The evidence provided in the draft ISA does not support EPA's conclusions 2.) Exposure ascertainment for NO2 is largely unreliable in depicting actual individual-level exposures 3.) The inventory of NOx sources is incomplete and the uncertainties are not adequately discussed in the draft ISA API requests EPA properly document the causality assigned to various effects and reconsider their causality classifications to reflect a better understanding of the current science; a more robust treatment of exposure ascertainment is needed. API also asks the draft ISA apportion the sources of NOx and how their anticipated relative contributions will change in the years ahead. See attached file(s)

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