White House Chief of Staff Jeff Zients
Dear Mr. Zients, The undersigned state and regional associations representing sectors and industries across the U.S. economy urge you to maintain the existing National Ambient Air Quality Standards for particulate matter (PM2.5). A proposed revision to this standard is under review by the White House Office of Information and Regulatory Affairs. This proposal could put nearly 40% of the U.S. population in areas of nonattainment,1 risking jobs and livelihoods across the nation and making it significantly more difficult to obtain permits to build new factories, bridges, and roads that will power our economic growth. Implementation of the Infrastructure Investment and Jobs Act, the CHIPS and Science Act, and the Inflation Reduction Act have the potential to infuse substantial investments into our states and communities, but all of that is now threatened by the permitting restrictions that would flow from this proposal. This regulation will put nearly every goal to encourage manufacturing in our states and regions at risk and could prevent the American economy from reaching its full potential.
Our members have innovated and worked with regulators to lower PM2.5 emissions significantly. The Environmental Protection Agency’s 2022 Air Trends and National Emissions Inventory report shows that PM2.5 concentrations have declined by 42% since 2000,2 driven by major emissions reductions from both mobile sources and the power sector. As a result, our air is cleaner than at any point in modern times. The current PM2.5 standard is set at 12 μg/m3; yet, some are advocating a standard as low as 8 μg/m3—which is lower than naturally occurring levels in many parts of the country. This proposal is also far more stringent than the guidelines in place in Europe, where the current EU standard is 25 μg/m3 more than twice the current level in the U.S.
The vast majority of PM2.5 emissions in the U.S. (84%) come from wildfires, road dust, and other nonpoint sources.3 As we have seen this year, the Canadian wildfires have had a more dramatic effect on air quality in the U.S. than any industrial sources. Nonattainment designations will be influenced heavily by these past three years of wildfire emissions, making compliance with existing standards—let alone any new standards—much more difficult. In many areas, there may not be sufficient offsetting emission-reduction options, and as a result, investments across the country could be brought to a grinding halt. Even without the new air quality data, the EPA’s Regulatory Impact Analysis failed to identify sufficient controls for all areas of the country to attain any of the proposed standards.4 In fact, the EPA has already proposed to disapprove a California state plan for failing to demonstrate that it can attain the current 2012 standard.5
Despite the vast majority of emissions coming from nonpoint sources, the cost of complying with this regulation will fall solely on our members. It will impact our ability to create jobs, innovate, and invest in America. A recent analysis conducted by Oxford Economics and commissioned by the National Association of Manufacturers found that if the proposed PM2.5 regulations are implemented, GDP will be reduced by nearly $200 billion and nearly 1 million current jobs will be put at risk. In addition, these numbers may actually understate the problem because they do not include the most recent air quality data.
Notably, these economic impacts will be localized rather than evenly dispersed across the country. Some states will be hit harder than others, but all states will miss out on new manufacturing facilities and jobs due to the permitting roadblocks mandated as a result of tighter standards. Under the proposed rule, close to 650 counties, equivalent to 22% of all U.S. counties, could be placed out of attainment. Even in areas that would meet the EPA’s proposed standards, current PM2.5 background levels are so close to the proposed standards that no room would be left for new economic development, virtually ensuring severe economic consequences. The inability to invest in America as a result of this proposal creates perverse outcomes, in which new facilities could be located in foreign countries with more lax air standards due to these administrative hurdles—undermining the economic and environmental goals of your administration.
In practice, these proposed standards are aspirational in that they are set at background levels, which effectively means that any industrial emissions could put a locality out of attainment. While our members continue to innovate, making cleaner products and pioneering cleaner processes, no one can comply with a regulation that sets the standard at effectively zero.
We strongly encourage your administration to maintain the existing standards, which will ensure that we remain among the countries with the cleanest air in the world while also supporting much-needed economic growth.
Sincerely,
Chris V. Isaacson, President and CEO, Alabama Forestry Association
Patrick Cagle. President, Alabama Mining Association
Kati Capozzi, President and CEO, Alaska Chamber
Deantha Skibinski, Executive Director, Alaska Miners Association
Danny Seiden, President and CEO, Arizona Chamber of Commerce and Industry
Randy Zook, President and CEO, Arkansas State Chamber of Commerce
Lance Hastings, President and CEO, California Manufacturers & Technology Association
Loren Furman, President and CEO, Colorado Chamber of Commerce
Chris DiPentima, President and CEO, Connecticut Business & Industry Assn, Inc.
Lisa B. Himber, President, Maritime Exchange - Delaware River & Bay
Brewster B. Bevis, President, Associated Industries of Florida
Lloyd Avram, President and CEO, Georgia Association of Manufacturers
Sherry Menor-McNamara, President and CEO, Chamber of Commerce Hawaii
Alex LaBeau, President, Idaho Association of Commerce & Industry
Benjamin J. Davenport, Executive Vice President, Idaho Mining Association
Mark Denzler, President and CEO, Illinois Manufacturers’ Association
Mark A. Biel, Chief Executive Officer, Chemical Industry Council of Illinois
Brian Burton, President and CEO, Indiana Manufacturers Association
Mike Ralston, President, Iowa Association of Business and Industry
Alan Cobb, President and CEO, Kansas Chamber of Commerce
Frank Jemley III, President and CEO, Kentucky Association of Manufacturers
Tucker Davis, President, Kentucky Coal Association
Will Green, President and CEO, Louisiana Association of Business and Industry
Greg Bowser, President and CEO, Louisiana Chemical Association
Tommy Faucheux, President, Louisiana Mid-Continent Oil and Gas Association
Mike Moncla. President, Louisiana Oil and Gas Association
Adam Haddox, Executive Director, Louisiana Pulp and Paper Association
Patrick Strauch, Executive Director, Maine Forest Products Council
Mary Kane, President and CEO, Maryland Chamber of Commerce
Brooke Thomson, President, Associated Industries of Massachusetts
John Walsh, President and CEO, Michigan Manufacturers Association
Jami Des Chenes, Executive Director, Michigan Chemistry Council
Jason Geer, President and CEO, Michigan Oil and Gas Association
Jim Holcomb, President and CEO, Michigan Chamber of Commerce
Doug Loon, President and CEO, Minnesota Chamber of Commerce
John McKay, President and CEO, Mississippi Manufacturers Association
Ray McCarty, President and CEO, Associated Industries of Missouri
Todd O’Hair, President and CEO, Montana Chamber of Commerce
Bryan Slone, President, Nebraska Chamber of Commerce & Industry
Ray Bacon, Executive Director, Nevada Manufacturers Association
Michael Skelton, President and CEO, Business & Industry Assoc. New Hampshire
Michele N. Siekerka, Esq., President and CEO, New Jersey Business & Industry Association
Carla J. Sonntag, President and CEO, New Mexico Business Coalition
Heather C. Mulligan, President and CEO, The Business Council of New York State, Inc.
Harold King, President, Council of Industry (Hudson Valley)
Peter Ahrens, Executive Director, Buffalo Niagara Manufacturing Alliance
Gary Salamido, President and CEO, NC Chamber
Ross M. Smith, President, North Carolina Manufacturers Alliance (NCMA)
Arik Spencer, President and CEO, Greater North Dakota Chamber
Ryan Augsburger, President, Ohio Manufacturers Association
Steve Stivers, President and CEO, Ohio Chamber of Commerce
Jenn Klein, President, Ohio Chemistry Technology Council
Pat Tiberi, President and CEO, Ohio Business Roundtable
Robert Brundrett, President, Ohio Oil and Gas Association
Chad Warmington, President and CEO, State Chamber of Oklahoma
Brook A. Simmons, President, The Petroleum Alliance of Oklahoma
Angela Wilhelms, President and CEO, Oregon Business & Industry
David N. Taylor, President and CEO, Pennsylvania Manufacturers' Association
Darlene J. Robbins, President, NE Pennsylvania Manufacturers & Employers Assoc.
Matt Gabler, Executive Director, Pennsylvania Forest Products Association
Peter Vlahos, President, Pennsylvania Aggregates & Concrete Assoc. (PACA)
John Olson, President, Pennsylvania Builders Association
Luke Bernstein, President and CEO, Pennsylvania Chamber of Business & Industry
Steven Kratz, President, Pennsylvania Chemical Industry Council
Rachel Gleason, Executive Director, Pennsylvania Coal Alliance
Daniel Weaver, President and Executive Director, Pennsylvania Independent Oil and Gas Association
Ted Harris, Executive Vice President, Pennsylvania Petroleum Association
Matt Smith, President, Greater Pittsburgh Chamber of Commerce
David M. Chenevert, Executive Director, Rhode Island Manufacturers Association
Bob Morgan, President and CEO, South Carolina Chamber of Commerce
Sara H. Hazzard, President and CEO, South Carolina Manufacturers Alliance
David Owen, President, South Dakota Chamber of Commerce and Industry
Kwinn Neff, President, South Dakota Mineral Industries Association
Bradley Jackson, President and CEO, Tennessee Chamber of Commerce
Candace Dinwiddie, Executive Director, Tennessee Forestry Association
Chuck Laine, President, Tennessee Mining Association
Tom Midyett, President. Tennessee Paper Council
Glenn Hamer. President and CEO, Texas Association of Business
Richard A. “Tony” Bennett, President and CEO, Texas Association of Manufacturers
Todd R. Bingham, President and CEO. Utah Manufacturers Association
Brian Somers, President, Utah Mining Association
Rikki Hrenko-Browning, President, Utah Petroleum Association
William Driscoll, Vice President, Associated Industries of Vermont
Brett Vassey, President and CEO, Virginia Manufacturers Association
Kristofer Johnson, President and CEO. Association of Washington Business
Rebecca McPhail, President, West Virginia Manufacturers Association
Kurt Bauer, President and CEO, Wisconsin Manufacturers and Commerce
Robert Jensen, Executive Director, Alliance of Wyoming Manufacturers
Travis Deti, Executive Director, Wyoming Mining Association
Andrew Shall, President, Graphic Media Alliance (OH, MI, KY)
Keith A. Christman, President, Decorative Hardwoods Association
Jaret Gibbons, Executive Director, Appalachian Region Independent
CC: The Honorable Lael Brainard, Director of the National Economic Council
The Honorable Michael Regan, Administrator, EPA
Steve Ricchetti, Counselor to the President
Ali Zaidi, National Climate Advisor
John Podesta, Counselor to the President
Gene Sperling, Counselor to the President
