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Comments to EPA on Review of Secondary NAAQS

In April 2024, the Environmental Protection Agency (EPA) proposed retaining the secondary national ambient air quality standards (NAAQS) for nitrogen oxides (NOx) and particulate matter (PM) and setting a new annual average standard for sulfur oxides (SOx). Policy Integrity submitted comments arguing that although the Proposed Rule begins to assess the various adverse welfare effects of SOx, NOx, and PM emissions and depositions that different populations may face, EPA should assess, consider, and present more information regarding both distributional impacts and future risks. 

Specifically, Policy Integrity’s comments make the following recommendations:

  • EPA should set secondary NAAQS that prevent anticipated adverse and disproportionate public welfare impacts on environmental justice communities, including potential impacts to drinking water quality, subsistence fishing, and recreational opportunities; 
  • EPA should consider how future climate change risks may interact with and potentially exacerbate the effects caused by SOx, NOx, and PM emissions; and
  • EPA should explain, in its economic analysis under Executive Orders 12,866 and 14,094, whether the Proposed Rule or alternatives may provide a benefit by protecting against future risks, such as the risk of changing SO2 emissions patterns, if applicable.