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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 PM 25rule.
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, PM 2 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 PM 25concentrations 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 PM 25 NAAQS from the current 15 g/m 3to EPA's proposed range of 13 to 12 pg/m 3will have wide-ranging impact across the country. EPA data indicates numerous countiesmeeting the current standard will fail this new more stringent range. Far more counties face nonattainment should EPA select 11 ig/m 3 , 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

PRINTEO ON RECvCLD PAPEFThe Honorable Lisa Jackson

November 21, 2012 Page 2

offset new PM 2,5 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 PM 25NAAQS - 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 PM 25emissions reductions.The Honorable Lisa Jackson

November 21, 2012 Page 3The Honorable Lisa Jackson

November21, 2012 Page 4The Honorable Lisa Jackson

November 21, 2012 Page 5List 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 Gohmert40. 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