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

The American Petroleum Institute (API) represents nearly 400 member companies involved in all aspects of the oil and natural gas industry. API is pleased to submit the following comments on the Integrated Science Assessment (ISA) for Particulate Matter (PM) First External Review Draft. API finds this First Draft does not provide sufficient scientific evidence to suggest PM2.5 causes health effects at levels below the current NAAQS. API recommends that EPA develops the Second Draft to more accurately reflect the available science issues raised in the comments below and the Attachments.