ASA Discusses Air Quality Standards With EPA
The Automotive Service Association (ASA) is very concerned about the recent air quality standards proposal as outlined by the U.S. Environmental Protection Agency (EPA). EPA has reviewed and proposed to change the national ambient air quality standards for ozone and particulate matter.
With respect to the ozone, EPA proposes to change the primary standard in several ways. First, since longer exposure periods are of greater concern at lower ozone concentrations, attainment of the standard would no longer be based upon one-hour averages, but instead on eight-hour averages. Second, as a result of this change in averaging time, the level of the standard would be lowered from the present 0.12 parts per million to 0.08 parts per million. Lastly, the current test of attainment is whether a site exceeds the one-hour standard on an average of no more than once per year, averaged over three years. The proposed test would be based on a three-year average of eight-hour ozone concentrations.
With regard to particulate matter, EPA's proposal calls for establishing a fine particle standard that is targeted at those particles that are less than 2.5 microns in diameter. This new standard would limit the acceptable daily ambient concentrations to 50 micrograms per cubic meter and annual concentrations to 15 micrograms per cubic meter. Attainment will be determined by whether an area is meeting the 50 microgram standard 98 percent of the time averaged over a three-year period.
There are several concerns with the new proposal from the independent repairer's perspective. First, many states are having great difficulty meeting the current EPA air quality regulations. Second, we are reasonably assured that large areas not currently described as non-attainment areas will be abruptly thrown into the category of having to meet certain standards. Is the public prepared?
The public has had a very difficult time adjusting to emissions inspection and maintenance (I&M) programs across the country. Beginning first with California and continuing to Maine, Maryland, and other states, programs have been eliminated or diluted in some cases to the point of being ineffective. Some states have acclimated to successful centralized or decentralized programs.
We must not forget that any backlash from emissions I & M could eventually impact the few remaining (less than 20) safety inspection programs across the country.
Congress has not been remiss in addressing the new proposed regulations. Members of the House Appropriations Committee accused EPA Administrator Carol Browner of misrepresenting the facts on the agency's air quality standards. With the many scientific uncertainties, several members felt Browner moved too quickly on the standards. The chairman of the House Government Reform Regulatory Affairs Subcommittee called the standards a "regulatory fraud" and urged EPA to begin again. Also questioned is whether the agency might have violated the Regulatory Flexibility Act, the Unfunded Mandates Reform Act and the Small Business Regulatory Enforcement Fairness Act in proposing the standards without proper review of their impact on the small business community.
Many of the facts the EPA stated to Congress have been questioned by the House Appropriations Committee, as well as by the chairman of the House Commerce Committee.
ASA recently met with Mary Nichols, assistant administrator for Air and Radiation at the EPA. Nichols assured ASA that EPA would make every effort to protect emissions inspections flexibility and enforcement as the regulations moved toward finalization. EPA has had a formal comment period, as well as conducted public hearings around the country. ASA has submitted congressional testimony and formal comments to the agency concerning the proposed rule.
It is very important that independent repairers analyze the new rule based on the facts. As a special interest, do we benefit from a geographically expanded air quality standard? If this produces more inspections, won't there be more repairs? Will the public tolerate the sacrifices necessary for meeting these new standards? Does the new proposal put our current emissions and safety inspection programs at risk?
ASA will continue to work with Congress and EPA in an effort to advance its position.
Nichols commended ASA for its thoughtful policymaking process. Nichols was very helpful to us during the information availability debate and is currently developing a new rule to be published later this summer that enhances the independent repairer's access to information.
Bob Redding is ASA's Washington, D.C., representative. He can be reached at (202) 543-1440.
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AutoInc. Magazine ®, Vol. XLV No. 6, June 1997