PM2.5 Emissions From Wildfires — No Longer So Exceptional!
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Last week, the Clean Air Scientific Advisory Committee formally
transmitted its recommendations to EPA Administrator Regan
regarding the PM2.5 NAAQS. Consistent with trade press
reporting over the past few months, the majority of CASAC members
recommended that the PM2.5 NAAQS be set between 8-10
ug/m3. A minority recommended the range be set
between 10-11 ug/m3. I’d be surprised if the
revised NAAQS is set above 10 ug/3. PICHUR
For me, what’s interesting about the letter is the
EPA should consider the implications of the exceptional events
approach when applied to wildfires, particularly with respect to
the risk assessment.
Apparently, that language was toned from draft language that
more strongly suggested that EPA should change its exceptional
events policy. Even so, it’s a pretty important
issue. As the detailed CASAC comments note:
Exceptional events. EPA allows exclusion
of wildfire PM events under the exceptional event rule when
calculating PM2.5 design values. In some parts of the country
wildfires are no longer “exceptional”. The dramatic
increase in wildfires over the last decade is not natural; it is a
combination of anthropogenic climate change, forest management
practices, and power line ignition incidents. These are (in theory)
at least partially controllable. Given the potential for
significant adverse health events, it may be time to reconsider the
current approach to excluding the high PM exposures from wildfire
events in design values.
Should we really consider forest fires to be natural
events? After all, Democrats think that the increase in
wildfires is tied to human-caused climate change. Republicans
blame Democratic forest management. Both explanations support
the conclusion that many wildfires are not natural events.
At CASAC’s suggestion, I’ve considered the implications
of the exceptional events approach and I think it’s time for a
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