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 time. 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

1 U.S. Air Quality Standards and the Manufacturing Sector (April 2023), https://documents.nam.org/COMM/NAM_Air_Quality_Standards_Analysis_Web_Version.pdf 

2 https://gispub.epa.gov/air/trendsreport/2023/#air_trends 

3 Id

4 EPA PM2.5 RIA, see https://www.epa.gov/system/files/documents/2023-01/naaqs-pm_ria_proposed_2022-12.pdf 

5 See https://www.govinfo.gov/content/pkg/FR-2022-10-05/pdf/2022-21492.pdf in which the EPA states the following: “We now propose that the State has not demonstrated that it is capable of fulfilling the remaining aggregate tonnage commitments necessary to attain the 2012 annual PM2.5 NAAQS in the SJV by December 31, 2025.”