For all of you looking to add a new acronym to your vocabulary this week, how about NAAQS? It stands for National Ambient Air Quality Standards, and the Environmental Protection Agency (EPA) is currently reviewing its NAAQS for particulate matter.
To give you some perspective, a typical strand of hair is about 70 micrometers in width, and EPA is proposing to regulate any particulate greater than 2.5 microns. Despite the assurances of EPA Administrator Lisa Jackson that her agency has no intention of regulating dust on farms and ranches, the ag industry is understandably pretty nervous. Even county governments have serious concerns that such standards may force them to pave dirt roads and the like at considerable expense to taxpayers.
Without question, the regulation of particulate matter and the new standards aren’t intended to focus on agriculture. In fact, the leading generator of particulate matter is combustion, particularly from coal-fired electricity plants. This move, however, is all about accomplishing what the federal government had hoped to accomplish with cap and trade. And rural America may just once again be caught in the crossfire.
What’s most concerning about this measure is that it appears legislation isn’t required to accomplish it. EPA seemingly has the authority to issue these standards under the premise that particulate matter produces a health risk. Not surprisingly, the studies have been done in urban areas and no studies have been done comparing rural areas to urban areas.
Even the science in urban areas is dubious, however, as they are population studies with no known direct cause and effect. EPA simply has data that indicates particulate matter is increasing at the same time that other studies indicate growing incidence of things like heart disease.
Moreover, the impacts of these standards can’t be mitigated through legislation. In fact, EPA isn’t even allowed to consider the economic effects of such standards beyond the actual cost to implement them. Hopefully, in drafting its standard, EPA will take the time to address some of these concerns and take into account submitted public comments. The result then will be challenged in court, thus delaying its implementation long enough that by the time the issue is resolved, there is a new and more sensible EPA administrator.
Last week, EPA officials were taken to task on a range of subjects by the House Ag Committee. However, the fervor of that bipartisan dressing down of EPA was equaled by EPA’s insistence that ag and rural America simply misunderstand the agency’s intent. I truly believe EPA doesn’t understand the havoc it is seeking to wreak on rural America.