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“Rural or Urban, It’s Ridiculous to Regulate Dust in the Wind”

U.S. cattle producers testify today across the nation

( Note: Farmers and ranchers preserve America’s open space, take care of the land every day, and have lead conservation efforts across the nation for generations. Therefore, this issue is very important to them and we hope you will consider their perspective on dust control (coarse PM), an issue being debated in EPA hearings today that is often misunderstood.)

Washington, D.C. (March 8, 2006) – The National Cattlemen’s Beef Association (NCBA), the voice of the U.S. cattle industry, is testifying simultaneously at three Environmental Protection Agency (EPA) hearings today regarding air quality standards and coarse particulate matter. The EPA is assessing the basis for regulation of coarse particulate matter (“coarse PM”) under the Clean Air Act. NCBA is submitting extensive comments found online at http://hill.beef.org/coarseparticulatematter and has released the following statement from NCBA Director of Environmental Issues Tamara Thies.

“Coarse particulate matter is fugitive dust, or basically dust in the wind, and has never been demonstrated to have adverse impacts on health at ambient levels. Leading scientists have conducted a thorough review of the existing science on coarse PM and agree evidence is weak, limited, uncertain, and not sufficient to support a risk assessment.

“Under the EPA National Ambient Air Quality Standards (NAAQS), air quality standards must be about protecting public health. These standards cannot be arbitrarily imposed without scientific backing. For more than 30 years the EPA has excluded fugitive dusts in making determinations of ambient compliance because there is not sufficient supporting evidence.

“Picture this: children sprinting around a baseball diamond in springtime. Dust gets kicked up, a small cloud of dirt particles fill the air as a base runner slides into home plate. It’s dusty for a bit, but harmless; you wouldn’t whip out a dust-o-meter or call off the ballgame due to dust levels!

“Controlling dust in the wind has been a priority land management practice for America’s farm and ranch families for generations. We manage fugitive dust with proactive dust control measures, best management practices, not by imposing unscientific unempirical regulatory standards.

“Every day, producers employ environmentally friendly practices including windbreaks, watering down dirt roads and using sprinklers to reduce dirt in cattle pens. Many of these activities are mandated and/or monitored by clean air permits/committees.

“We urge fellow environmentalists to take a long, hard look at this issue. The proposed requirements to regulate dust in the air are undisputedly unattainable and are at levels which would put U.S. farmers and ranchers out of business. There exists no valid NAAQS standard for dust in the wind. The agricultural community leads land conservation efforts, lives off the land, and is extremely valuable to the American economy. Do we really want to put hard-working, environmentally friendly families out of business so they sell off rural lands to developers?

The Untold Story Regarding Coarse Particulate Matter Findings

“The Clean Air Scientific Advisory Committee’s review of the coarse PM standard over the last three years has been marked by controversy and abrupt, unexplained changes of position.

“In its own final Staff Paper in June 2005, the EPA noted the studies and data on which it based its proposal were weak, uncertain, limited, and not even adequate to support a health risk assessment, since they did not fulfill the minimum requirements for such assessments.

“Dr. Jonathan Borak with Yale University School of Medicine, a renowned expert in epidemiology and toxicology, conducted an extensive review of current science on coarse PM. Dr. Borak’s review concluded there was not a scientific basis for the adoption of a ‘coarse PM standard’ a/k/a regulation of dust, at this time. Check out Dr. Borak’s findings at: http://hill.beef.org/coarseparticulatematter

“The studies suggested to support regulating urban dust in the wind are fatally flawed. The EPA acknowledges fatal flaws in the four studies suggested as its basis for the proposed coarse PM standard.  Unfortunately, the severe problems that negate any reliance on these four studies are not discussed in EPA’s initial review but only mentioned in a later discussion of a possible “alternative interpretation” of the health evidence.

“In addition, in an egregious failure to guard against the appearance of any unfair and unsound scientific weighing of the evidence on coarse PM, the EPA failed to consider and weigh the far larger number of studies with much larger and more powerful databases and longer duration that specifically considered coarse PM, but did not find statistically significant associations.

“The EPA clearly acknowledges the uncertainties associated with the scientific data, by stating they are soliciting comments on ‘not adopting a thoracic coarse particle standard at this time, and taking into account any new relevant research that becomes available as a basis for considering a more targeted standard for thoracic coarse particles in the next periodic review of the PM NAAQS.’  This is the correct ultimate outcome. Regulation based on weak and limited studies is not what Congress had in mind.”

To review NCBA’s extensive comments on this issue, Dr. Borak’s review, and background information go to: http://hill.beef.org/coarseparticulatematter.




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