EPA Goes Back-to-Basics on NAAQS Reviews

Posted on 5/11/2018 by Roger Marks

power_plant_cleanpowerplan.gifCurrent US EPA Administrator Scott Pruitt on May 9th signed a memorandum establishing a “back-to-basics” approach to Clean Air Act-required reviews of National Ambient Air Quality Standards (NAAQS).

The memo, inspired by an April 12 Presidential memorandum to EPA, lays out five principles to guide EPA’s decision making pursuant to these air quality standards.

What Are NAAQS?

Under the Clean Air Act, EPA is required to set maximum allowable levels for six criteria pollutants in the ambient air: ozone, particulate matter, carbon monoxide, lead, sulfur dioxide, and nitrogen dioxide. In areas where the pollution level rises above the NAAQS, facilities face more stringent requirements for building or modifying sources of air pollution.

The Clean Air Act also requires EPA to review these NAAQS levels every five years and adjust them, if necessary. Each time US EPA updates its NAAQs requirements for a given pollutant—as the Agency did for ozone on October 1, 2015—the update triggers a reassessment of regional attainment status. States must determine which regions attain the updated standard and which don’t and submit the data to US EPA.

EPA must complete the area designations within two years once the Agency updates any NAAQS.

5 Principles for Back-to-Basics NAAQS Reviews

The NAAQS memo lists five back-to-basics principles for EPA to follow to improve the NAAQS review process.
  1. Meet Statutory Deadlines. EPA will look for efficiencies to expediate the review process, which often drags on past the time limits mandated by law. EPA was sued in March 2018 for failure to complete area designations for its lowered ozone NAAQS, for example.

  2. Address All CAA Provisions for NAAQS Reviews. EPA specifically calls attention to Section 109(d)(2), which outlines the Clean Air Scientific Advisory Council’s role for providing advice and feedback on NAAQS standards. Pruitt’s memo states that EPA has not always met its full responsibilities under this section in previous NAAQS reviews.

  3. Streamline and Standardize the Process for Development and Review of Key Policy-relevant Information. EPA plans to improve its review of “policy-relevant science,” studies, and analyses “that address key questions related to the adequacy of primary and secondary NAAQS.”

  4. Differentiate Science and Policy Considerations in NAAQS Review Process. EPA wants to better distinguish between “science advice” and “policy advice” received from advisors and more clearly separate the pure science from the additional considerations—social, economic, etc.—that the Administrator considers before approving any NAAQS action.

  5. Issue Timely Implementation Regulations and Guidance. EPA pledges to do a better job of releasing guidance and information pursuant to changing NAAQS rules to the regulated community and State agencies.
Read the whole memo here.

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