Air quality is important to all of us. So important, in fact, that one of the first modern environmental laws in the United States was the Clean Air Act. Enacted by Congress in 1963 a full seven years before the Environmental Protection Agency even existed and nine years before the Clean Water Act was enacted, the law was aimed squarely at reducing and controlling air pollution as booming industrial growth fueled a national conversation concerned with the negative impacts of human activity on the environment.
While federal standards for air quality are easily linked to the issues of public health and environmental protection, they also have deep implications for economic growth, manufacturing, and agriculture. The need to balance these two sides has been the basis of nearly all debate surrounding environmental regulations. When the pendulum swings too far on either side, balance is lost. This is the case with the EPA’s recent lowering of fine particulate matter standards, known as PM2.5.
PM2.5 refers to particulate matter that measures less than 2.5 micrometers in diameter, more than 20 times smaller than the width of human hair. The tiny particles are composed of a complex mixture that can include road dust and smoke from forest fires, as well as liquid droplets from naturally occurring atmospheric reactions. PM2.5 levels are regulated under the National Ambient Air Quality Standards (NAAQS), a key component of the CAA.
PM2.5 levels in the U.S. have declined by 42% over the past twenty years and in many places have returned to naturally occurring background levels as industry has innovated to meet the challenge of reducing emissions. This significant achievement makes the EPA’s lowering of standards perplexing and has alarmed the manufacturing sector, especially in industries such as fertilizer production.
To understand industry’s alarm, the concept of “headroom” is key. Headroom refers to the difference between the maximum allowed levels of PM2.5 and current ambient levels of PM2.5 As an example, think of a glass. The size of the glass is the maximum allowed level and the amount of water already in the glass is the current ambient level. Headroom is the amount of space left in the glass. If the glass is 12oz and the amount of water is 8oz, there is room for an additional 4oz before it spills over. But when you shrink the glass down to 9oz you are now only left with 1oz to add.
Where this becomes a significant problem is in areas that are already “full” or close to it. If that 9oz glass is filled to the brim, then more water cannot be added under the new standards. The very real fear from industry is that these lowered limits will lead to ‘permitting gridlock’ as a full glass leads to a “non-attainment” designation from the EPA. Limited headroom and a non-attainment status for an area will prevent new plants from being built, push manufacturing to other countries with less stringent environmental regulations, and stall plant upgrades aimed at enhancing environmental protections. A recent NAM-commissioned analysis by Oxford Economics found that a standard at this level could reduce GDP by nearly $200 billion and cost as many as 1 million jobs through 2031.
Proponents of the lowered PM2.5 standards argue that industry just needs to do a better job of reducing emissions. But as stated before, PM2.5 levels have dropped over 40% over the past two decades because of industry efforts. In fact, industry has done such a good job reducing these emissions that only 16% of current PM2.5 levels are from industrial sources while a whopping 84% originate from non-point sources such as wildfires, road dust, and vehicle emissions.
As a cornerstone of global agriculture, the fertilizer industry plays an indispensable role in sustaining food security and supporting agricultural productivity. The lowering of PM2.5 standards are not just a regulatory hurdle for the fertilizer industry, rather they could substantially harm the ability of the industry to operate and grow, impact the production of fertilizers, and have a cascading effect on agriculture and food security. The pendulum has swung too far.
