Lead NAAQS Critique
For an industrial trade association; Gradient provided oral comment at US EPA's public hearing on the Proposed Rule for the National Ambient Air Quality Standard (NAAQS) for Lead; and we also prepared written comments on the Proposed Rule. Our comments focused on EPA's process for reviewing the NAAQS and EPA's failure to adjust for the difference between maximum quarterly and annual average air lead levels in its derivation of the NAAQS. Our client submitted comments to the docket and the Final Rule was issued in October; 20
Project Highlights
- Public hearing presentation
- Submission to EPA Docket
