Yawn: EPA Promulgates New Fine Particulate Standard

On Friday, EPA announced promulgation of its revised fine particulate, or PM2.5, NAAQS. Why am I yawning? Let me count the ways:

1. Because, in 2009, the District of Columbia Court of Appeals rejected EPA's prior effort to keep the PM2.5 standard at 15 ug/m³.

2. Because, as I have previously noted, the Court of Appeals pretty much told EPA that it could not ignore the advice of its Clean Air Science Advisory Committee in setting the NAAQS.

3. Because the CASAC basically advised EPA to set a standard of 12-13 ug/m³.

4. Because the Court of Appeals recently affirmed EPA's revised NOx NAAQS, in part because EPA had relied on CASAC in setting the new NOx NAAQS.

Bottom line? If you know anyone who wants to wager that the new PM2.5 NAAQS will be overturned, have them contact me; I have a bridge to sell them.