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November 21, 2012 

The Honorable Lisa Jackson 

Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, N.W. 

Washington, D.C. 20460 

Dear Administrator Jackson, 

We are concerned about the Environmental Protection Agency's (EPA) proposed rule to 

reduce National Ambient Air Quality Standards (NAAQS) for fine particulate matter (PM2.5). 

This proposed rule would impact our states and local communities by imposing burdensome new 

restrictions on economic growth --just at the time these areas are struggling to attract much 

needed new jobs. The Agency is proceeding in an expedited fashion despite stakeholder 

comments stating that these regulations will impose an undue burden and despite telling a federal 

court last May that the Agency would need until August 2013 to review those comments and 

finalize the PM25 rule. 

EPA's proposal to lower PM 2.5 NAAQS comes as counties and states are showing 

tremendous success in implementing the current standards. According to EPA's own analysis, 

PM2 5 emissions have been cut in half over the last ten years, dropping by 1.1 million tons per 

year. Air quality is also improving as average PM25 concentrations have been reduced by 27% 

over that same period. While certain states continue their work to attain the current standards, 

they all share the achievement of cleaner air. EPA's proposal to further reduce PM 25 NAAQS 

unfairly moves the goalposts in mid-game, and puts many communities at risk of being 

stigmatized as non-attainment. 

Reducing PM25 NAAQS from the current 15 g/m3 to EPA's proposed range of 13 to 12 

pg/m3 will have wide-ranging impact across the country. EPA data indicates numerous counties 

meeting the current standard will fail this new more stringent range. Far more counties face nonattainment should EPA select 11 ig/m3 , an outcome for which Agency accepted comments. 

When accounting for EPA designation and implementation policies, the proposed rule puts 

hundreds of counties at risk of non-attainment. 

Counties designated as non-attainment areas face immediate, substantial, and long-lasting 

economic consequences. Existing facilities are often required to install new, expensive controls. 

Local infrastructure is impacted as federal funds for transportation projects are withheld unless 

those projects can be shown not to increase PM 2.5 emissions. New businesses seeking to build or 

upgrade operations must install the most effective PM 2.5 emissions controls, without 

consideration of cost, and are subject to enhanced EPA oversight. In addition, businesses must 

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The Honorable Lisa Jackson 

November 21, 2012 

Page 2 

offset new PM2,5 emissions by paying for emissions reductions at existing facilities. n the 

absence of affordable offsets, new projects cannot proceed. 

Moreover, restrictions do not end once non-attainment areas achieve the PM 25 NAAQS. 

Instead, these counties must petition EPA to be redesignated to attainment by submitting a 

complex maintenance plan listing numerous mandatory and long-lasting measures. The sum of 

all these non-attainment regulatory burdens is lost business investment in local communities, 

reducing tax revenues supporting local schools as well as first responders and effectively 

hamstringing any efforts to overcome present fiscal hardships. 

In light of the substantial economic impact involved, and in keeping with President 

Obama's Executive Order 13563, we believe that the Agency should not force stringent new 

NAAQS too quickly. Doing so will hurt counties and states - many still implementing the 

current PM25 NAAQS - struggling to move out of challenging economic conditions. Rather, 

EPA should maintain the current standards, and work with communities to continue the longterm trend of PM25 emissions reductions.
The Honorable Lisa Jackson 

November 21, 2012 

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The Honorable Lisa Jackson 

November21, 2012 

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The Honorable Lisa Jackson 

November 21, 2012 

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List of Signatures 

1. Rep. Bob Latta 

2. Rep.John Barrow 

3. Rep. James Lankford 

4. Rep. Andy Harris 

5. Rep. Steve Austria 

6. Rep. Jason Aitmire 

7. Rep. Bob Gibbs 

8. Rep. Bill Johnson 

9. Rep. David McKinley 

10.Rep. Brett Guthrie 

11.Rep. Rob Bishop 

12.Rep. James Renacci 

13.Rep. Jeff Duncan 

14.Rep. Marsha Blackburn 

15.Rep. Bill Shuster 

16.Rep. Sue Myrick 

17.Rep. Tim Murphy 

18.Rep. Todd Rokita 

19.Rep. Harold Rogers 

20. Rep. Lynn Westmoreland 

21. Rep. Shelley Moore Capito 

22. Rep. Jo Ann Emerson 

23. Rep. Bob Goodlatte 

24. Rep. Robert Aderholt 

25. Rep. Michele Bachmann 

26. Rep. Larry Kissell 

27. Rep. Bill Flores 

28. Rep. Bill Huizenga 

29. Rep. H. Morgan Griffith 

30. Rep. Tim Scott 

31. Rep. Steve King 

32. Rep. Mark Critz 

33. Rep. Steve Stivers 

34. Rep. Billy Long 

35. Rep. John Kline 

36. Rep. Don Young 

37. Rep. Rick Crawford 

38. Rep. Jim Matheson 

39. Rep. Louie Gohmert
40. Rep. Spencer Bachus 

41. Rep. Sanford D. Bishop, Jr. 

42. Rep. Tom Petri 

43, Rep. Joseph Pius 

44. Rep. Peter Roskam 

45. Rep. Pat Tiberi 

46. Rep. Reid Ribble 

47. Rep. Pete Olson