Testimony of Dr. John R. Balmes on behalf of the American Thoracic Society I am John Balmes, MD, Professor of Medicine at the University of California, San Francisco and Professor of Environmental Health Sciences at the University of California, Berkeley School of Public Health. I am an attending Physician in Pulmonary and Critical Care Medicine at San Francisco General Hospital and I conduct research on the health effects of air pollution. I am presenting comments today on behalf of the American Thoracic Society. The American Thoracic Society is a medical professional society with over 13,000 members who are dedicated to the prevention, diagnosis, treatment and research of respiratory illnesses. The American Thoracic Society is deeply concerned about air pollution, both as an underlying cause of respiratory illness and its ability to cause exacerbations of pre existing respiratory illness.

The American Thoracic Society will submit extensive formal comments on several issues in the EPA proposed rule. However, today, I will limit my comments to issues surrounding the proposed standard for coarse thoracic particles. This standard is precedent setting because by focusing on urban areas only, it assumes that sources of particles outside of urban areas do not convey any increased risk to health.

The ATS is extremely disappointed that EPA has proposed that the coarse thoracic particle standard apply to urban areas only. We see this as a major flaw in the proposed rule. It is true that there is less research on the health effects of exposure to coarse thoracic particles than on those of fine particles. However, there is no research that shows rural particles are safe. I repeat, there is no research showing that rural particles are safe.

In fact, the limited available evidence seems to show adverse health effects from exposure to coarse particles found in more rural areas. For example, work done here in California by Cal/ EPA investigators using data for a 10 year period from the rural Coachella Valley showed a greater cardiovascular mortality risk for coarse particles than for fine particles. In addition, a series of toxicological studies by Becker et al., some of which have been supported by U. S. EPA,, have demonstrated greater cytotoxicity and proinflammatory effects of coarse particles than fine particles. We also note that PM10 in rural areas will contain particles from urban type sources  diesel engines, highways, power plants and other industrial facilities. Limiting application of the daily coarse particle standard based on geographic population areas is not supported by the available scientific data.

Recommendation: The EPA daily coarse thoracic particle standard should apply to both urban and rural areas. The ATS is also deeply concerned about the EPA proposal to stop monitoring coarse thoracic particles in rural areas. The EPA is correct in recognizing there are limited data on the health effects of coarse particles in rural areas. However, the appropriate response to limited data is not to stop monitoring altogether. Rather than addressing the need for more data, suspending monitoring of coarse particles would ensure that there will be a continuing lack of data on the health effects of exposures to coarse particles in rural areas. EPA's proposal to suspend monitoring in rural areas is the equivalent of the ostrich burying its head in the sand.

Recommendation: EPA should continue monitoring of coarse particle exposures in rural areas.

The ATS is equally concerned about the proposed exemptions of particles emitted from mining and agricultural activities. Again, there is no scientific basis for saying these particles are safe to breathe. In fact, mine generated dust would be expected to contain relatively high concentrations of silica and metals that are known to be toxic. In addition, mines and agriculture both use diesel equipment that generates toxic particles. Excluding mine and agriculture sourced particles may be good for business but it is not good for health Recommendation: EPA should regulate all coarse thoracic particles, regardless of source.

The American Thoracic Society strongly believes that federal air quality standards must be based on a careful review of the available scientific knowledge. The role of the Clean Air Scientific Advisory Committee in the air quality standard setting process is critical to ensure such a careful review. In the case of the proposed PM standard, the EPA Administrator has chosen to reject the recommendations of CASAC on the basis that the committee did not adequately review the available scientific data. While the ATS respects the authority of the Administrator to reject the advice of CASAC for policy reasons, it is a dangerous precedent for the Administrator to do so by impugning the integrity of the committee's scientific review. The review of scientific knowledge conducted through the Clean Air Act process that leads to a CASAC recommendation is the most careful and deliberative review conducted in the field of environmental health. CASAC members are highly qualified scientists who are thoroughly vetted. They are the best people to judge the state of scientific knowledge on the health effects of a criteria pollutant. For an EPA administrator to cast aspersions on the quality of CASAC's scientific judgment is akin to stating that there is insufficient scientific evidence of global warming.

Recommendation: EPA should accept the recommendations of its own highly qualified scientific advisory committee. On behalf of the entire membership of the American Thoracic Society, I would like to thank the EPA staff for the opportunity to comment on this important rule.


Johnd Bachmann 12/ 10/ 2003 05: 22 PM To: Amy_ L._ Farrell@ omb. eop. gov cc: Subject: Revised Tables Art requested for section IX of the IAQR Art asked for some tables of design values to be added into section IX  here is a replacement version of the section we sent yesterday with the table cut in, to make review in context easier. The redline is compared to the original version sent Monday so you can see all changes since then highlighted.

John Bachmann U. S. EPA C404 04 Research Triangle Park, NC27711 Voice 919 541 5359 Fax 919 541 2464 email Bachmann. JohnD@ epa. gov


From:
Jones, DonnaLee<EMAIL_ADDRESS>Sent:
Tuesday, November 17, 2015 5:58 PM
To:
David Ailor<EMAIL_ADDRESS><EMAIL_ADDRESS>Cc:
Raymond, Gabrielle<EMAIL_ADDRESS>Subject:
form for by-product facilities to use for reporting operating levels

David  -  Good idea about getting list together. Here is a form they should use. All facilities should provide a response, even those that have contacted me previously, so that we have all the information in the same format.

I will send the meeting minutes to you after I get your comments on the action items and ICR changes because we are adding this to the minutes.

I will send you an updated Enclosure 2 in Word to use for redline purposes; this version reflects the ICR changes that were discussed but not any that are still under discussion. I will also send Enclosure 1 that has not changed but it will be in Word.

_____________________________________________________________
Regards,
Donna Lee Jones, Ph.D.
Senior Technical Advisor, Metals Sector
U. S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Sector Policies and Programs Division / Metals & Inorganic Chemicals Group (D 243-02)
Research Triangle Park, NC  27711  Tele:<PHONE_NUMBER>  Fax<PHONE_NUMBER>
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
"Reasonableness never fails to be appreciated."  - anon.

<< coking-survey-CBI.docx >>


PAPERWORK REDUCTION ACT SUBMISSION Please read the instructions before completing this form. For additional forms or assistance in completing this form, contact your agency's Paperwork Clearance Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102, 725 17th Street NW Washington, DC 20503.

1. Agency/ Subagency originating request EPA SPD/ SPIB 2. OMB control number b. G None a_ 2060 0170 _ _ __ __

3. Type of information collection ( check one) a. G New collection b. G Revision of a currently approved collection c. X Extension of a currently approved collection d. G Reinstatement, without change, of a previously approved collection for which approval has expired e. G Reinstatement, with change, of a previously approved collection for which approval has expired f. G Existing collection in use without an OMB control number 4. Type of review requested ( check one) a. X Regular b. G Emergency  Approval requested by: / / c. G Delegated 5. Small entities Will this information collection have a significant economic impact on a substantial number of small entities? G Yes X No For b f, note item A2 of Supporting Statement Instructions 6. Requested expiration date a. X Three years from approval date b. G Other Specify: / /___

7. Title: Recordkeeping and Periodic Reporting of the Production, Import, Export, Recycling, Destruction, Transhipment, and Feedstock Use of Ozone Depleting Substances ( Renewal)

8. Agency form number( s) ( If applicable) NA EPA ICR # 1432.25 9. Keywords: Ozone depleting substances, Class I Ozone depleting substances, phaseout, stratospheric ozone, Clean Air Act, Montreal Protocol on Substances that Deplete the Ozone Layer 10. Abstract: The international treaty The Montreal Protocol on Substances that Deplete the Ozone Layer ( Protocol) and Title VI of the Clean Air Act ( CAA) established limits on total United States ( U. S.) production, import, and export of class I and class II controlled ozone depleting substances ( ODS). Under its Protocol commitments, the U. S. is obliged to cease production and import of class I controlled substances with exemptions for essential uses, critical uses, previously used material, and material that will transformed, destroyed, or exported to developing countries. Additionally, the CAA has its own limits on production and consumption of controlled substances that EPA must adhere to and enforce. To maintain oversight and to ensure compliance with its regulations and international agreements, EPA requires companies to adhere to regulations listed in 40 CFR part 82.

11. Affected public ( Mark primary with " P" and all others that apply with " X") a. Individuals or households d. Farms b. P Business or other for profit e. Federal Government c. Not for profit institutions f. State, Local or Tribal Government 12. Obligation to respond ( Mark primary with " P" and all others that apply with " X") a. G Voluntary b. G Required to obtain or retain benefits c. P Mandatory 13. Annual reporting and recordkeeping hour burden a. Number of respondents 1,138 b. Total annual responses 1,860 1. Percentage of these responses collected electronically 0 % c. Total hours requested 8,370 d. Current OMB inventory 9,937 e. Difference ( 1,567) f. Explanation of difference 1. Program Change 0 2. Adjustment ( 1,567) 14. Annual reporting and recordkeeping cost burden ( in thousands of dollars)

a. Total annualized capital/ startup costs $ 0 b. Total annual costs ( O& M) $ 6 c. Total annualized cost requested $ 6 d. Current OMB inventory $ 1 e. Difference $ 5 f. Explanation of difference 1. Program change 0 2. Adjustment $ 5 15. Purpose of information collection ( Mark Primary With " P" and all others that apply with " X") a. __ Application for benefits e. __ Program planning or management b. __ Program evaluation f. __ Research c. __ General purpose statistics g. _ P_ Regulatory or compliance d. __ Audit 16. Frequency of recordkeeping or reporting ( check all that apply) a. X Recordkeeping b. Q Third party disclosure c. X Reporting 1. X On occasion 2. Q Weekly 3. Q Monthly 4. X Quarterly 5. Q Semi annually 6. X Q Annually 7. Q Biennially 8. Q Other ( describe)

17. Statistical methods Does this information collection employ statistical methods?

Q Yes XQ No 18. Agency contact ( person who can best answer questions regarding the content of this submission) Name: Kirsten M. Cappel Phone: ( 202) 343 9556 OMB 83 I 10/ 95 19. Certification for Paperwork Reduction Act Submissions On behalf of this Federal agency, 1 certify that the collection of information encompassed by this request complies with' 5 CFR 1320.9.

NOTE: The text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320.8( b)( 3), appear at the end of the instructions. The certification is to be made with reference to those regulatory provisions as set forth in the instructions.

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

( a) It is necessary for the proper performance of agency functions;

( b) It avoids unnecessary duplication;

( c) It reduces burden on small entities;

( d) It uses plain, coherent, and unambiguous terminology that is understandable to respondents;

( e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

( f) It indicates the retention periods for recordkeeping requirements;

( g) It informs respondents of the information called for under 5 CFR 1320.8( b)( 3): ( I) Why the information is being collected' ( ii) Use of information; ( iii) Burden estimate; ( iv) Nature of response ( voluntary, required for a benefit, or mandatory); ( v) Nature and extent of confidentiality; and ( vi) Need to display currently valid OMB control number;

( h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected ( see note in Item 19 of the instructions);

( I) It uses effective and efficient statistical survey methodology; and ( j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in Item 18 of the Supporting Statement.

Signature of Program Official Date Signature of Senior Official or designee Oscar Morales, Director Collection Strategies Division Office of Environmental Information Date OMB 83 I 10/ 95 Certification Requirement for Paperwork Reduction Act Submissions 5 CFR 1320.9 reads " As part of the agency submission to OMB of a proposed collection of information, the agency ( through the head of the agency, the Senior Official or their designee) shall certify ( and provide a record supporting such certification) that the proposed collection of information

"( a) is necessary for the proper performance of the functions of the agency, including that the information to be collected will have practical utility;

"( b) is not unnecessarily duplicative of information otherwise reasonably accessible to the agency;

"( c) reduces to the extent practicable and appropriate the burden on persons who shall provide information to or for the agency, including with respect to small entities, as defined in the Regulatory Flexibility Act 5 U. S. C § 601( 6)), the use of such techniques as:

"( 1) establishing differing compliance or reporting requirements or timetables that take into account the resources available to those who are to respond; "( 2) the clarification, consolidation, or simplification of compliance and reporting requirements; or collection of information , or any part thereof; "( 3) an exemption from coverage of the collection of information, or any part thereof;

"( d) is written using plain, coherent, and unambiguous terminology and is understandable to those who are to respond;

"( e) is to be implemented in ways consistent and compatible, to the maximum extent practicable, with the existing reporting and recordkeeping practices of those who are to respond;

"( f) indicates for each recordkeeping requirement the length of time persons are required to maintain the records specified;

"( g) informs potential respondents of the information called for under § 1320.8( b)( 3); [ see below]

"( h) has been developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected, including the processing of the information in a manner which shall enhance, where appropriate, the utility of the information to agencies and the public;

"( I) uses effective and efficient statistical survey methodology appropriate to the purpose for which the information is to be collected; and "( j) to the maximum extent practicable, uses appropriate information technology to reduce burden and improve data quality, agency efficiency and responsiveness to the public."

NOTE: 5 CFR 1320.8( b)( 3) requires that each collection of information:

"( 3) informs and provides reasonable notice to the potential persons to whom the collection of information is addressed of: "( I) the reasons the information is planned to be and/ or has been used to further the proper performance of the functions of the agency; "( ii) the way such information is planned to be and/ or has been used to further the proper performance of the functions of the agency; "( iii) an estimate, to the extent practicable, of the average burden of the collection ( together with a request that the public direct to the agency any comments concerning the accuracy of this burden estimate and any suggestions for reducing this burden); "( iv) whether responses to the collection of information are voluntary, required to obtain or retain a benefit ( citing authority), or mandatory ( citing authority); "( v) the nature and extent of confidentiality to be provided, if any ( citing authority); and "( vi) the fact that any agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number."

OMB 83 I ( Instructions) 10/ 95