Comment submitted by Ted Steichen, Advisor, Regulatory and Scientific Affairs, American Petroleum Institute (API)

The American Petroleum Institute (API) represents over 400 member companies involved in all aspects of the oil and natural gas industry. API is pleased to submit the following comments on the Particulate Matter National Ambient Air Quality Standards: Scope and Methods Plan for Health Risk and Exposure Assessment. API finds the planned air quality analyses are insufficient to fully and accurately characterize risk associated with ambient concentrations of PM. API recommends that EPA rework the Scope and Methods Plan to develop a more accurate risk and exposure assessment reflecting the available science issues and data analysis methods raised in the comments.