The Fertilizer Institute (TFI) on Jan. 27 issued a sharp rebuke to the US Environmental Protection Agency (EPA) for its proposed rule to tighten national ambient air quality standards (NAAQS) for fine particulate matter (PM2.5).

EPA on Jan. 6 announced a proposal to lower the primary health-based annual PM2.5 standard from a level of 12 micrograms per cubic meter down to 9-10 micrograms to “better protect communities, including those most overburdened by pollution.”

EPA completed its last review of the PM NAAQS in 2012, and the Trump Administration in December 2020 announced its decision to retain the 2012 standard. But EPA this month said “thousands of new studies” since 2012 have highlighted the dangers of soot exposure, and the 2012 standard “may not be adequate to protect public health and welfare.

“Fine particles, sometimes called soot, can penetrate deep into the lungs and can result in serious health effects that include asthma attacks, heart attacks, and premature death – disproportionately affecting vulnerable populations including children, older adults, those with heart or lung conditions, as well as communities of color and low-income communities,” EPA said.

“These particles may be emitted directly from a source, such as construction sites, unpaved roads, fields, smokestacks, or fires,” the agency said. “Other particles form in the atmosphere as a result of complex reactions of chemicals such as sulfur dioxide and nitrogen oxides, which are pollutants emitted from power plants, industrial facilities, and vehicles.”

EPA said strengthening the PM2.5 standard to 9 micrograms per cubic meter would prevent an estimated 4,200 premature deaths per year and 270,000 lost workdays per year, and would result in as much as $43 billion in net health benefits by 2032.

EPA is proposing to revise other aspects related to the PM standards as well, such as monitoring requirements and the Air Quality Index (AQI). While the agency said it currently plans to retain the primary 24-hour PM2.5 standard of 35 micrograms per cubic meter, it said it will take comments on revising this level to as low as 25 micrograms per cubic meter. 

“Our work to deliver clean, breathable air for everyone is a top priority at EPA, and this proposal will help ensure that all communities, especially the most vulnerable among us, are protected from exposure to harmful pollution,” said EPA Administrator Michael S. Regan. “This proposal to deliver stronger health protections against particulate matter is grounded in the best available science, advancing the Biden-Harris Administration’s commitment to scientific integrity and a rigorous scientific process.”

TFI President and CEO Corey Rosenbusch warned, however, that lowering PM2.5 standards beyond what is technically possible could have the unintended consequence of reducing domestic fertilizer production, while forcing manufacturing to other countries with significantly lower environmental protections and less efficient production methods. He urged EPA to retain the current PM NAAQS, which he said has dramatically reduced air pollution.

“At a time when the need to strengthen the domestic fertilizer industry has been made clear by multiple global crises and echoed by the Biden Administration, now is not the time to hamstring fertilizer production by making new production facilities or the expansion of existing production more difficult or, in some instances, impossible,” Rosenbusch said.

“PM2.5 emissions have declined nearly 40% over the past twenty years, and they continue to go down,” he continued. “Under the current standards we have both environmental protection and robust commerce. We are in the Goldilocks zone where those things are balanced. Why mess with that when EPA’s own data has shown uncertainties related to the health benefits of reducing levels below current standards?”

Rosenbusch said that as NAAQS levels have dropped and industry continues to adapt through technology and innovation, local air quality in many parts of the country has returned to “background levels” of particulate matter that are naturally occurring.

“Imagine responsibly operating a facility in an area that is well within PM2.5 guidelines, but you are geographically downwind from a wildfire two states over and now all of a sudden your area receives a ‘nonattainment designation’ from the EPA,” Rosenbusch said. “Now you can’t expand, you can’t grow, you can’t operate at your normal levels, and the EPA is telling you to install technology that doesn’t exist while they readily admit in their own analysis that even they haven’t been able to determine how states can attain lower PM2.5 standards.”

EPA will accept public comment for 60 days after the proposal is published in the Federal Register. EPA said it will also conduct a virtual public hearing over several days, with the schedule to be announced after the Federal Register notice.