On March 28, AGC responded (via individual and coalition comments) to the U.S. Environmental Protection Agency’s (EPA) premature revision to the National Ambient Air Quality Standards (NAAQS) for particulate matter (PM). AGC supports the establishment of reasonable air quality rules that are necessary, based on sound science and measurably improve public health. However, this proposal would greatly increase the stringency of the PM NAAQS ahead of schedule, without clear justification in the science, and contrary to the Administration’s commitment to improve infrastructure and create jobs. Geographic areas that cannot meet these standards could face sanctions, such as a loss of federal highway funding or inability to permit new projects. AGC urged EPA to retain the current standards and highlighted a concern that states—in an attempt to meet the standards—may place restrictions on the use and operation of diesel equipment, which are, in essence, construction bans.
AGC’s comments detailed the potential impacts of EPA’s proposal on construction, including potential construction bans in geographic areas so designated by EPA, which would have a negative effect on employment, gross domestic product, manufacturing shipments, the completion of critical infrastructure projects, and the delivery of important public services. Construction bans coupled with the loss of federal funding could delay the renovation and improvement of public infrastructure, including highway and transit construction projects, and bridge construction and repairs. Public health and welfare projects would also suffer—impeding efforts to deliver clean water or improve the safety of our transportation system.
The construction industry’s ongoing supply chain and energy challenge could be exacerbated by EPA’s proposal. The markets for several key materials used in construction tend to be local, whenever feasible, due to the cost of shipping these materials long distances. If plants have to curtail production or close, then it will impact the availability of local materials, constrain the supply chain, and result in increased emissions (including PM and greenhouse gases) and costs from shipping.
EPA pushed this proposal out ahead of schedule at a time when their own data show PM air quality is consistently improving overall. Mobile sources of PM are also steadily declining. In general, vehicle and heavy-duty trucks are roughly 99 percent cleaner than 1970s models.
For more information, contact Melinda Tomaino at melinda.tomaino@agc.org.